ELDORADO NATIONAL FOREST PLACERVILLE RANGER DISTRICT BIOLOGICAL ASSESSMENT / EVALUATION FOR BOTANICAL SPECIES:

PILLIKEN FOREST HEALTH PROJECT 2016

Prepared By: /s/ Matt Brown Date: 4/13/2016 . Matt Brown Botanist

Table of Contents

I. INTRODUCTION ...... 3 II. CONSULTATION TO DATE ...... 6 III. CURRENT MANAGEMENT DIRECTION ...... 6 IV. PROJECT DESCRIPTION ...... 7 V. EXISTING SPECIES AND CONDITION ...... 7 VI. EFFECTS ...... 16 VII. OTHER MANAGEMENT ISSUES AND RECOMMENDATIONS: ...... 16 VIII. MITIGATIONS AND MONITORING ...... 19 IX. DETERMINATION ...... 19 X. REFERENCES...... 20 APPENDIX A: BOTANY REPORT FOR SPECIAL INTEREST ...... 21 APPENDIX B: NOXIOUS WEED RISK ASSESSMENT ...... 27 APPENDIX C: NOXIOUS/INVASIVE WEEDS OF CONCERN ...... 30

I. INTRODUCTION Purpose: Forest Service Manual 2672.42 specifies that a biological evaluation (BE) and a biological assessment (BA) be prepared to determine if a project may affect any USDA Forest Service (FS) sensitive species and US Fish and Wildlife Service (USFWS) threatened, endangered, or proposed species and their designated or proposed critical habitat. This BE/BA is prepared in accordance with legal requirements set forth under Section 7 of the Endangered Species Act (16 U.S.C. 1536 (c)). The purpose of this BE/BA is to review the Pilliken Forest Health Project in sufficient detail to determine to what extent the proposed action may affect any threatened, endangered, proposed, and sensitive (TES) species for the project area.

The Placerville Ranger District of the Eldorado National Forest proposes reduce stand density in selected plantations and adjacent stands to reduce the risk of future insect and disease infestations.

Location:. The Pilliken Forest Health Project is located within the South Fork Cohesive Strategy Project on the Placerville Ranger District.

Species: Listed A species list was obtained from the USFWS to identify threatened, endangered, or proposed listed species that could occur, or be affected by projects on the Eldorado National Forest from the USDI Fish and Wildlife Service pursuant to Section 7 (c) of the Endangered Species Act. The list is available for review at: (http://www.fws.gov/sacramento/es_species/Lists/es_species_lists_NF-form-page.htm).

Currently the only TEP plant species expected to occur on the Eldorado NF is layneae. Potential habitat for Packera layneae is not found within the proposed project area.

Sensitive There are known occurrences of Pleasant Valley Mariposa lily ( clavatus var. avius) within the project area. In addition, potential habitat for the following species is known to occur in the project area:

1. Allium tribracteatum 2. Botrychium sp. 3. Bruchia bolanderi 4. Calochortus clavatus var. avius 5. Cypripedium montanum 6. Dendrocollybia racemosa 7. Lewisia kelloggii ssp. hutchisonii 8. Lewisia kelloggii ssp. kelloggii 9. Meesia uliginosa 10. Navarretia prolifera ssp. lutea 11. Peltigera gowardii 12. Phaeocollybia olivacea

Table 1 lists all Sensitive plant taxa from the ENF. No other Threatened, Endangered, Proposed, or Sensitive (TEPS) plant taxa have known occurrences or potential habitat on the ENF. Taxa that do not have potential habitat in the project area are not further analyzed in this document. Botanical surveys conducted for the proposed project focused on species with potential habitat. Botanists searched for these (e.g., meadow) as well as for the Sensitive taxa.

Table 1. Habitat potential of the Proposed Pilliken Forest Health Project for the TEPS plant taxa known or suspected to occur on the Eldorado National Forest.

Known in Suitable Project Habitat in Rationale For Determination Of No Suitable Species Status1 On ENF2 Area Project Habitat/No Effect Area

Grows on open ridges with gravelly lahar soils Three-bracted onion (lava cap communities) in and lower & S P No Yes (Allium tribracteatum) upper montane coniferous forests from ~ 3,300 to 10,000 feet in elevation.

El Dorado manzanita Grows on highly acidic slate and shale soils and S K No No is often associated with closed-cone conifer forest (Arctostaphylos nissenana) from about 1,400 to 3,600 feet.

Big-scale balsamroot Grows in chaparral, vernally moist meadows & (Balsamorhiza macrolepis S P No No grasslands, grasslands within oak woodland, and var. macrolepis) ponderosa pine forest below 4,600 feet. Upswept moonwort Grows in lower montane coniferous forest, S P No Yes meadows, and seeps from 4,900 to over 7,500 (Botrychium ascendens) feet in elevation.

Scalloped moonwort Grows in fens, lower montane coniferous forest, S K No Yes meadows, seeps, and freshwater marshes from (Botrychium crenulatum) 4,900 feet to 10,500 feet in elevation.

Common moonwort Grows in meadows, seeps, subalpine and upper S P No No montane coniferous forest from 7,450 feet to over (Botrychium lunaria) 11,000 feet in elevation.

Mingan moonwort Grows in fens, lower and upper montane S K No Yes coniferous forest, meadows, and seeps from 4,900 (Botrychium minganense) to 6,750 feet.

Mountain moonwort Grows in lower and upper montane coniferous S K No Yes forest, meadows, and seeps from 4,900 feet to (Botrychium montanum) 7,000 feet in elevation.

Paradox moonwort Grows in lower and upper montane coniferous S K No Yes forest, meadows, and seeps from 4,900 feet to (Botrychium paradoxum) 7,000 feet in elevation.

Stalked moonwort Grows in lower and upper montane coniferous S P No Yes forest, meadows, and seeps from 4,900 feet to (Botrychium pendunculosum) 7,000 feet in elevation.

Grows in meadows and fens in montane and Bolander’s bruchia subalpine communities from about 5,500 to 9,000 S K No Yes feet. Grows in ephemeral habitats such as (Bruchia bolanderi) erosional ditches or small streamlets through wet meadows.

Pleasant Valley mariposa lily Grows in openings in mixed conifer & ponderosa (Calochortus clavatus S K Yes Yes pine forest, usually on ridgetops and south-facing var. avius) slopes from 2,500 to 5,600 feet.

Grows in moist areas and upland sites with Mountain lady’s slipper P (K on S No Yes northerly aspects, loamy soils and shade, from (Cypripedium montanum) inholding) 3,500 to 5,700 feet (generally <5,000 ft). Known in Suitable Project Habitat in Rationale For Determination Of No Suitable Species Status1 On ENF2 Area Project Habitat/No Effect Area Grows on remains of decayed mushrooms or Branched Collybia occasionally in duff/ litter, in mid-mature to S K No Yes old-growth stands of mixed hardwood-conifer (Dendrocollybia racemosa) forests. Evidence of timber harvest at some extant occurrences. Tahoe draba Restricted to rocky ledges and talus slopes in (Draba asterophora S H No No subalpine and alpine habitats above 8,200 feet. var. asterophora) Cup Lake draba Restricted to sandy slopes, rocky ledges, and talus (Draba asterophora S K No No slopes in subalpine and alpine habitats above var. macrocarpa) 8,200 ft.

Tripod buckwheat Grows on serpentine soils in foothill and S K No No (Eriogonum tripodum) cismontane woodlands below 5,300 feet.

Blandow’s bog-moss Grows in wet meadows, fens, & seeps in S P No No subalpine coniferous forest and alpine lakes from (Helodium blandowii) 6,100 to 9,000 feet. Parry’s horkelia Grows on stony, disturbed, slightly acidic soils in S K No No open chaparral and cismontane woodland below (Horkelia parryi) 3,400 feet. Hutchison’s lewisia Grows in openings in upper montane coniferous forest, often on slate soils and on soils that are (Lewisia kelloggii ssp. S K No Yes sandy granitic to erosive volcanic from 4,800 to hutchisonii) 7,000 feet. Kellogg’s lewisia Grows on granitic and volcanic balds from about (Lewisia kelloggii ssp. S K No Yes 5,000 to 8,000 feet. kelloggii)

Long-petaled lewisia Restricted to subalpine & alpine slopes or basins S K No No (Lewisia longipetala) with deep snow accumulations, above 8,200 feet.

Restricted to steep, nearly vertical cliffs in inner Saw-toothed lewisia gorges of perennial streams and rarely near seeps S K No No (Lewisia serrata) and intermittent streams. Grows between 2,800 and 4,800 feet in the American River watershed.

Broad-nerved hump-moss Grows in permanently wet, primarily spring-fed S P No Yes meadows and fens in montane to subalpine (Meesia uliginosa) coniferous forest from 4,200 to 9,200 feet.

Grows on metamorphic, sedimentary, limestone, and serpentine rock outcrops that often contain Elongate Copper Moss copper or other heavy metals and that are S P No No (Mielichhoferia elongata) seasonally moist or less commonly on moist soil. ponderosa pine. Grows from sea level to 3550 feet.

Yellow bur navarretia Grows in openings in or adjacent to mixed conifer forest or cismontane woodland on rocky (Navarretia prolifera ssp. S K Yes Yes ridgelines, saddles, or eroding ephemeral lutea) drainages from 2,300 to 5,000 feet. Known in Suitable Project Habitat in Rationale For Determination Of No Suitable Species Status1 On ENF2 Area Project Habitat/No Effect Area

Adder’s tongue Grows in moist habitat including wet meadows S P No No (Ophioglossum pusillum) and roadside ditches.

Layne’s ragwort Grows on rocky, gabbroic or serpentinitic soils in T, S K No No chaparral and cismontane woodland below 3,000 (Packera layneae) feet. Grows on rocks in cold, unpolluted spring-fed Veined water lichen streams without marked seasonal fluctuation. K K No Yes Submerged most of year. Peak flows must not (Peltigera gowardii) scour the rocks & gravels where this species attaches. Grows on dry, open, rocky sites (bedrock Stebbins’ phacelia outcrops, rubble or talus) on ledges or moderate S K No No (Phacelia stebbinsii) to steep slopes and on damp, mossy inner gorges from 2,000 to 6,800 feet. Conifer and hardwood forests where it grows in Olive phaeocollybia P (K on S No Yes the humus layer. Logging disturbance, when (Phaeocollybia olivacea) inholding) present, is not intense (e.g. clear-cut or patch-cut).

Whitebark pine Whitebark pine typically occurs on cold and C, S K No No windy high elevation sites in western north (Pinus albicaulis) America (7,000-12,000 feet).

Sierra blue grass Grows in lower montane coniferous forest on S K No No steep, shady, moist slopes from 1,200 feet to (Poa sierrae) 3,800 feet.

1 S = Forest Service Sensitive; T =Federally Listed as Threatened; C= Candidate Species 2 H = historic record; K = known to occur on ENF; P = suspected to occur on ENF

Field reconnaissance: The project area was surveyed for Sensitive plants and invasive plants in 2014 and 2015. Surveys were intuitive targeting potential habitat in the project area. No new sensitive plant occurrences were found in the proposed project footprint.

II. CONSULTATION TO DATE No formal or informal consultation with the USFWS has been conducted since TEP species or potential habitat does not exist in or near the project area.

III. CURRENT MANAGEMENT DIRECTION The goal of the Forest Sensitive Plant Program is to maintain viable populations of sensitive plant species, and under Management Practice 49, the General Direction is to "provide for protection and habitat needs of sensitive plants so that Forest activities would not jeopardize the continued existence of such species" (Land and Resource Management Plan, 1989).

“A [viable] population…has the estimated numbers and distribution of reproductive individuals to ensure the continued existence of the species throughout its existing range within the planning area” (FSM 2670.5)

Current policy as stated in the Forest Service Manual (FSM 2670.32) includes the following: Assist States in achieving their goals for conservation of endemic species.

1. As part of the National Environmental Policy Act process, review programs and activities. 2. Avoid or minimize impacts to species whose viability has been identified as a concern. 3. 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. (The line officer, with project approval authority, makes the decision to allow or disallow impact, but the decision must not result in loss of species viability or create significant trends toward Federal listing.) 4. Establish management objectives in cooperation with the States when projects on National Forest System lands may have a significant effect on Sensitive species population numbers or distributions. Establish objectives for Federal candidate species, in cooperation with the FWS and the States.

The current condition of Sensitive plant species on the Eldorado National Forest reflects the effects of past and present management activities. Presently there is not enough evidence to suggest whether Sensitive plant populations and/or ranges are increasing, decreasing, or stable. Monitoring of occurrences, which detects decreases or increases from year to year, may merely reflect normal variation in individual numbers as a response to annual climatic changes. There is also considerable uncertainty regarding future changes in local climatic patterns. Given the lack of data needed to take a proactive management approach to these Sensitive plant species, the best available interim management approach is to minimize impacts to known occurrences of Sensitive plant species while allowing expansion into suitable unoccupied habitat. This strategy would also maximize the diversity of habitat and microsite conditions (slope, aspect, elevation, etc) for Sensitive plants on the Eldorado National Forest which may be important in face of future climate change. While much is unknown about the potential long-term effects of a warming and/or drying climate on Sensitve plant species, in the near term, maintaining habitat diversity across the species range may be the best means to manage for species which could require unique microsites to persist under future climatic conditions.

IV. PROJECT DESCRIPTION In order to meet the needs of the project, the following actions are proposed on an estimated 2,653 acres of National Forest system land within the South Fork of the American River drainage. The proposed actions consist of thinning, fuels reduction, prescribed burning, and road reconstruction in order to reduce the susceptibility of the existing stands to insect infestation and mortality.

Thinning 1. Commercial thinning on approximately 1,921 acres of 40-year old plantations and 516 acres of natural stands to remove selected conifer trees within identified natural stands and plantations. Within the plantations trees would be removed to attain residual basal areas that would vary from approximately 60 to 110 ft2 /acre. The lower basal areas would occur on the upper portion of the dominant ridges whereas the higher basal areas would occur on the mid to lower portion of the slopes. Within the natural stands, the trees to be harvested would generally be the shade-tolerant, suppressed trees with lower live crown ratios, or trees that show signs of defects or indicators of bark beetles or disease. 2. Remove small trees (4 inches to 10 inches dbh) to landings, or other designated disposal sites, on the commercially thinned areas. 3. Tree tops and small trees would be piled at landings and be made available for either biomass power generation or public fire wood cutting. Material remaining at landings would be burned. 4. Thinning of conifer trees less than 10 inches dbh on approximately 116 acres non-commercial sized plantations. 5. Pruning of select residual trees to increase the height of live crown.

Fuel Reduction 1. Conduct post-harvest treatments, including grapple or tractor piling of existing and activity fuels, or mastication, on thinned areas. 2. Treatment of understory brush in areas of high fuel density. 3. Prescription burning to treat brush and understory fuels on an additional 119 acres within the project area.

Prescribed Burning 1. Prescription burning of piles in accordance with the relevant burn plan that would be developed for this project. 2. Understory burning of treated and adjacent units with priority given to those which strategically reduce the risk of large fires on the surrounding landscape

Transportation System 1. Reconstruction or heavy maintenance on approximately 52 miles of existing system roads. The road reconstruction would primarily consist of replacement of failed culverts, installation of graded dips or water-bars to control road surface drainage, pothole repair, surface grading roadside brushing and some road widening to accommodate log trucks. 2. Construction of approximately 0.5 mile of temporary road and turn-around, to be decommissioned within three years of the project completion. 3. An undetermined number of temporary landings may be established or enlarged to accommodate the accumulations of biomass removed from the thinned stands. The size of the log landings may range from ¼ to ½ acre in size depending on how much logging debris is generated.

Table 1. Roads proposed for temporary construction, reconstruction or maintenance under the Proposed Action.

Design Features

Heterogeneity within Units

Silvicultural prescriptions will be designed to promote structural and species heterogeneity by incorporating recommendations from PSW-GTR-220 and PSW-GTR-237 to meet the following goals:

1. Reduce shading around oaks to improve growing conditions

2. Increase the percentage of shade intolerant pine and hardwoods in natural stands

3. Retain clumps of large trees

4. Retain large trees with defects such as rot, cavities, and multiple tops

5. Increase stand variability in species and structure

Cultural Resources 1. Protect historic properties within the area of potential effects (APE) from adverse effect through the application of the Approved Standard Protection Measures detailed in Appendix E of the "Programmatic Agreement among the U.S.D.A. Forest Service, Pacific Southwest Region (Region 5), the State Historic Preservation Officer, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation Regarding Processes for Compliance with Section 106 of the National Historic Preservation Act for Management of Historic Properties by the National Forest of the Pacific Southwest Region (Regional PA, 2013)."

2. Identify all resources at risk (RAR) within the APE with flagging and/or on maps prior to initiating project activities. Consider as exclusion zones areas in which activities would occur within the APE and areas in which the archaeological survey has been deferred unless reviewed by the district archaeologist on a case-by-case basis. 3. Establish protection measures specific to prescribed burn activities, detailed in the Regional PA, 2013, Appendix E, Section 2.2, (b)(1)(A-K), for each RAR based on coordination between cultural resource managers and fuels specialists prior to implementation. 4. Should any previously unrecorded cultural resources be encountered during implementation of this project, immediately cease all work in that area and immediately notify the District Archaeologist. Resume work subsequent to approval by the District Archaeologist for implementation of additional protection measures, as necessary to meet provisions in the Regional PA (2013). Should any cultural resources become damaged in unanticipated ways by activities proposed in this project, follow the steps described in the Regional PA, 2013 for inadvertent effects.

Botany 1. Sensitive Plant populations within the project area would be flagged for avoidance. Due to the fact that prescribed burn implementation could occur several years after completion of thinning or other treatments, the project leader or burn boss would notify the project botanist prior to line construction in order to re-flag occurrences. All ground disturbing activities, burn piles, hazard tree removal, roadside brushing, mechanical equipment, line construction, and spring burning would be excluded from sensitive plant protection areas unless approved by project botanist. 2. Where necessary to remove trees from within Sensitive plant boundaries, the project botanist would be consulted to mitigate impacts. All thinning of trees adjacent to site boundaries would be directionally felled away from the site. Hand thinning and prescribed fire within sensitive plant protection areas may occur at the recommendation of the project botanist. The project botanist would be notified prior to implementation of the prescribed burn in sensitive plant populations and if available would be onsite to take part in, and/or monitor burning and associated effects. At a minimum, a post burn visit would be conducted by the botanist. If new sensitive plant occurrences are discovered during project implementation the project botanist would be notified to develop necessary protection measures. 3. Sensitive fungi surveys will conducted in a sampling of units in the Pilliken project area prior to implementation. If new populations are found the project botanist will be consulted and necessary protection measures will be developed. 4. Application of Magnesium Chloride for dust abatement will not occur within 100 feet of roadside occurrences of Sensitive plant or watch-list species. 5. Lava caps, which support unique plant communities in the project area, would be protected from motorized equipment and vehicles. Line construction through lava cap communities would be avoided when feasible. If necessary, line construction would be completed with hand tools only. 6. Eldorado National Forest Priority 1 and 2 invasive plant infestations within the project area would be flagged for avoidance and treated using integrated pest management techniques as a part of the Pilliken project for up to 3 years after implementation. Treatments under the project will tier to the Eldorado National Forest Invasive Plant EA and may include a combination of techniques including tarping, manual removal, string trimming, and targeted herbicide application. 7. Off-road equipment vehicles would be cleaned to insure it is free of soil, seeds, vegetative matter or other debris before entering National Forest System lands to prevent the introduction or spread of invasive plants. Prior to the start of operations, the Forest Service would do a visual inspection for such debris. Where possible, work in areas with invasive plant infestations last. If working in infestations or infested areas, equipment shall be cleaned before moving to other un-infested National Forest lands. These areas will be identified on project maps. 8. Where proposed road work occurs in known invasive plant infestations equipment would be cleaned prior to leaving infested areas. 9. All earth-moving equipment, gravel, fill or other materials would be weed free. Onsite sand, gravel, rock, or organic matter would be used where possible. 10. Straw or mulch used for erosion control would be certified weed-free. A certificate from the county of origin stating the material was inspected is required. 11. Any seed used for restoration or erosion control would be from a locally collected source (following the Eldorado National Forest Seed, Mulch and Fertilizer Prescription, 2000).

Soils 1. Ground based yarding would not occur on slopes exceeding 35 percent without a site specific environmental analysis by a soil scientist determining that damage is unlikely. 2. Skid trails would be placed within the unit in order not to exceed 15 percent of the total unit area. Skid trails would be adequately drained in order to prevent overland water flow. Skid trails should not be placed perpendicular to slopes greater than 20 percent on soils with severe/very severe erosion hazards, on these slopes skid trails should contour the hillside. 3. Reuse existing skid trails where practical in all units that currently have skid trails. Skid trail location would be approved prior to use. Do not reuse skid trails on steep slopes where soils are highly erosive. 4. Leave appropriate amounts of coarse woody debris (5 trees/acre). 5. Organic matter would be left on site so that at least 50 percent of the soil surface is covered with litter and fine woody material. On steeper slopes with high erosion hazards, organic matter would be left on site so that at least 70 percent of the soil surface is covered with litter and fine woody material to reduce soil erosion and increase soil productivity. 6. Avoid wet areas and slumps within units. Identify these areas and flag for avoidance during layout.

V. EXISTING SPECIES AND HABITAT CONDITION Sensitive Plant Species Within the Pilliken Project there are three occurrences of Pleasant Valley Mariposa lily.

Population ID Status Suggested Treatment CACLA_105 Plants occur in thick deer Proposed hand treatment to brush directly along Plum thin deer brush to release Creek Rd CACLA. CACLA_117 Site last visited 2004 Outside of project boundary but within 500 feet. Keep equipment out of population. Do not use as staging area. CACLA_140 Plants occur along lava cap Population just beyond area, one plant found project boundary. Keep equipment out of population. Do not use as staging area

The Pilliken Plantation units as a whole were dry mixed conifer forest with very few riparian species within them, and occasional riparian areas along the boundaries. The dominant trees included , Pseudotsuga menziesii, and occasional swaths of Calocedrus decurrens, , Quercus kelloggii, and . The shrub layer was consistently present across the entire project area which is typical of plantation stands, but varied in density from a barren duff-covered understory beneath a thick canopy, to very dense shrub cover. The most common shrub species are Ceanothus integerrimus, Ceanothus cordulatus, Arctostaphylos patula, Ribes roezlii, Symphoricarpos mollis and Quercus vacciniifolia. Some of the most common understory forb and gramminoid species include: Bromus carinatus, Pteridium aquilinum, Elymus glaucus, Kelloggia galioides, Osmorhiza chilensis, Lathyrus nevadensis/sulphureus, and Viola lobata.

Listed Species Layne’s ragwort (Packera layneae) Layne’s butterweed is a perennial herb in the sunflower family (CNPS, 2001; USFWS, 2002) found in foothill woodland and chaparral habitats along the west slope of the in El Dorado and Tuolumne Counties at elevations between 60 and 3,000 feet. About 36 occurrences of this plant are documented on the Eldorado National Forest. Of the 32 documented occurrences in El Dorado County, two are located wholly on the ENF, one is located partially on the ENF, and one is located on a state-owned ecological preserve, and the remainder are found on private lands primarily in the Cameron Park area. There is no potential habitat for this listed species within the proposed analysis area.

Sensitive species Three-bracted onion (Allium tribracteatum) Three-bracted onion is known only from 36 occurrences in Calaveras and Tuolumne counties, and only found in the Stanislaus National Forest. It occurs on thin volcanic soils along the ridges near Crandall Peak and along Highway 108 in Tuolumne County. Since adding the species to the ENF sensitive plant list in 2006 the onion has not been found on the forest. One occurrence has been confirmed on rhyolite on private land near Wilseyville in Calaveras County. This indicates a larger range than was previously known and that this species may occur on the Eldorado National Forest. Populations range in size from 5 to approximately 10,000 individuals.

Three-bracted onion is found in lower and upper montane coniferous forests on gravelly lahar (volcanic mud flow soils, often referred to as "lava caps"). This habitat is open and very vulnerable to disturbance. Potential impacts include disturbance from roads, OHV trails, timber landings, skid trails, Helitack base construction, garbage dumps, underground utility lines, utility pole maintenance, and camping locations.

Moonworts (Botrychium spp.) Botrychium species are widely distributed in North America and elsewhere. In California they occur infrequently in a variety of moist habitats throughout the Sierra Nevada and other portions of the state. Most moonwort species show a marked affinity for neutral substrates with high mineral content, especially soils developed on limestone bedrock or otherwise containing high calcium content. High elevation habitats suitably moist and cool are abundant throughout the Sierra Nevada and mountains, but these mountains are mostly composed of granites, volcanics, and crustal basalts not rich in soluble calcium. However, leaf litter from incense cedar may favorably modify soils for some moonworts.

Documentation of population numbers and distribution patterns are incomplete largely because members of this genus are difficult to distinguish, and very uncommon and sporadic in distribution (Wagner and Wagner, 1993). These species appear sensitive to activities such as grazing, trampling, logging, and recreational activities such as OHV use.

Seven species of moonworts are listed as Sensitive species. They were listed as a group because 1) most species in this genus are rare in California; 2) individual species are very difficult to distinguish from each other; and 3) all have similar habitat preferences (wet or moist soils such as in meadows and fens or along the edges of lakes and streams). From the CNPS online inventory (CNPS, 2007): 1. Upswept moonwort (Botrychium ascendens): lower montane coniferous forest, meadows, seeps, 4,900 to over 7,500 feet 2. Scalloped moonwort (Botrychium crenulatum): Fens, lower montane coniferous forest, meadows, seeps, freshwater marshes, 4,900 to over 10,500 feet 3. Common moonwort (Botrychium lunaria): Meadows, seeps, subalpine and upper montane coniferous forest, 7,450 to over 11,000 feet 4. Mingan moonwort (Botrychium minganense): Fens, lower and upper montane coniferous forest, 4,900 to 6,750 feet. 5. Mountain moonwort (Botrychium montanum): Lower and upper montane coniferous forest, meadows, seeps, 4,900 to 7,000 feet. 6. Paradox moonwort (Botrychium paradoxum): Lower and upper montane coniferous forest and meadows. 7. Stalked moonwort (Botrychium pendunculosum): Lower and upper montane coniferous forest and meadow.

Threats to moonworts are defined as actions that alter existing site characteristics, including actions that would change the microclimate, canopy coverage, hydrology, or mycorrhizal association on a site from the regime that has supported a given population. Potential actions that could alter site condition include timber harvest, firewood cutting, fire suppression, road widening and maintenance activities, livestock grazing, invasive plant establishment, herbicide use, and recreational activity (camping and off-road vehicle driving).

Bolander’s bruchia moss (Bruchia bolanderi) Endemic to western North America from California north to Oregon and east to Nevada and Utah (Shevock pers. comm.). California populations are known from Fresno, Tehama, Madera, Mariposa, Nevada, Tuolumne, Tehama and Plumas counties (Plumas, Stanislaus, Sierra NF known). Bruchia bolanderi typically occurrs in lower montane coniferous forest, meadows, edges of fens, springs and seeps, upper montane coniferous forest/ damp soil; elevation 1700-2800 meters. The species is opportunistic, taking advantage of disturbed sites and minimal competition from other vegetation. direct impacts from cattle cause damage to populations, although this vagile species appears capable of reestablishing itself in recently disturbed soils. The ephemeral nature of this species, and its occurrence in disturbed sites allow some flexibility in management. There are two occurrence known from the Eldorado National Forest. One in the vicinity of Schneider Cow Camp and another in along the Twin Lakes Trail.

Mariposa Lily (Calochortus clavatus var. avius) Pleasant Valley mariposa lily is known almost exclusively from El Dorado and Amador counties in the area between and the North Fork of the , with exceptions in Calaveras and Mariposa Counties. One hundred thirty nine occurrences have been documented within a roughly 420 square-mile area (CNDDB, 2015). Of the 120 occurrences wholly or partly on NFS land, ten are believed to have been extirpated. Population size ranges from a few plants into the thousands. This species is only known from Eldorado National Forest and private land, no other National Forest has yet found any additional occurrences.

The elevation of known occurrences ranges from 900 to 5,800 feet; however, Calochortus clavatus var. avius is most often found on gravelly lahar and openings in mixed-conifer on south-facing canyon slopes, spurs, and ridges in sparse stands of conifers, oaks, and manzanita and/or bear clover (Chamaebatia foliolosa) in mixed-conifer and ponderosa pine forests between 2,500 to 5,700 feet. The openings typically have rocky soils, with rocks and cobbles apparent at the surface. Plants often are found at the edge of openings, adjacent to or within shrubs. Aggregates of occurrences are found along east-west trending ridges that possess numerous south-facing spurs.

Plants of this perennial bulb may remain dormant in some years, or plants may emerge vegetatively but then enter dormancy without flowering. Post-fire numbers within occurrences may increase but the majority of plants are suppressed adults that are released rather than new plants (Walker, pers. comm., 2011). Populations do not readily expand. Seedlings that have been observed (e.g., post-fire) generally do not become established or reappear in subsequent years (Taylor, pers. comm., 2011).

Threats include OHV activities, road/highway construction and expansion, fire line construction, and residential and agricultural development at lower elevations.

Mountain Lady's Slipper (Cypripedium montanum) Mountain lady's slipper is an uncommon orchid in California. It grows throughout the northwest: From Alaska to California and east to Montana. In California, it reaches as far south as Santa Cruz County along the coast and Madera County in the Sierra Nevada. The species is known from the Stanislaus and Plumas NF, but has not been documented on the Tahoe NF. On the ENF, one occurrence is located on a private land inholding within the Amador Ranger District.

Mountain lady's slipper grows in both moist and dry conditions at elevations between 600 and 6,700 feet, although less common above 4,800 feet. It grows in moist sites near streams or sometimes near the edge of small seeps but also in relatively dry conditions on hillsides in mixed conifer forests. The one population within the ENF is on a private inholding and has northwest and northeast aspects and is located at an elevation of 5,200 feet. Potential habitat is extensive across the Eldorado National Forest and in the proposed project area. Surveys for this species have been ongoing since 1998 on the Eldorado National yet no occurrence has been found on the Forest.

High intensity fires are one of the greatest threats to mountain lady’s slippers. This threat ranked highest in the statewide threat analysis (R5 Conservation assessment), and is supported by research and literature. Clustered and mountain lady’s slippers are intolerant to fires that burn through the litter layer above mineral soil. The species may tolerate less intense fires that do not eliminate the duff layer and leave the forest canopy fully or partially intact. Heavy fuel loads may pose a threat to many populations by increasing the risk of intense fire. Large scale fires could result in significant negative effects to multiple populations of these species.

In addition to fire, mechanical disturbance: timber harvest, fire lines could threatened occurrences of Mountain lady’s slipper orchid. Disturbances that affect the rhizomes of these species, duff and litter layer, and the structure of the upper soil horizons may threaten plants and populations, as do those activities that remove the forest canopy. Such mechanical disturbances ranked second statewide in the threat analysis, and include timber harvest activities, construction of fire lines, culvert relocation, and other ground disturbing activities. A high ranking of this disturbance is consistent with information on the species responses to rhizome disturbance and forest canopy removal.

(Dendrocollybia racemosa) Dendrocollybia racemosa (DERA) occurs in Clallam, Jefferson, King, Okanogan, Pierce, Snohomnish, and Thurston counties in Washington, in Clackamas, Douglas, Jackson, Josephine and Land counties in Oregon, and in California in Del Norte, Humboldt, Trinity, Siskiyou, Mendocino, Marin, Napa, (Castellano et al. 2003), Placer, Nevada, Tuolumne, and Yuba Counties. Occurrences are very patchy. Occurrences are dictated by the presence of the intended host (unidentified mushrooms) within forested areas. Presumably whatever threatens the host, general habitat, microclimates, and/or host’s substrate or symbiotic partner will likewise imperil CORA16 (Norvell 2002).

In general this species is solitary or occurs in small groups growing from a grain-like sclerotium on the decayed remains of decayed mushrooms, or in duff of mixed hardwood-conifer woods; fruiting from late fall to mid-winter. DERA is mycoparasitic and fruits after rapidly digesting its host; it also develops protective sclerotia that are assumed to enable it to lie dormant for long periods. Presumably DERA is vulnerable to removal of the host mushroom and substrate prior to fruiting or sclerotia formation, to removal or destruction of the sclerotia within the litter and mushroom residue, and to destruction of the habitat that fosters growth of the intended host. It is also presumably vulnerable to alteration of the microhabitat and microclimate regimes, incidential catastrophic events and logging activities that would displace the protective sclerotia and/or host mushroom population. Habitat information from 2011 occurrences indicated an affiliation with Douglas fir forests with California hazel as an associated species. Stand age ranged from mid-mature to old-growth; timber harvest was evident in three of the six occurrences

Kellogg’s and Hutchison’s Lewisia (Lewisia kelloggii ssp. kelloggii and ssp. hutchisonii) Kellogg’s and Hutchison’s lewisia were added to the ENF sensitive plant list in 2006 after researchers separated the species form those plants occurring in Idaho from plants occurring in California (Wilson et al. 2005). The plants in Idaho have been renamed as Lewisia sacajaweana. The change makes L. k. ssp. kelloggii and L. k. ssp. hutchisonii endemic to California. Kellogg’s lewisia is known from 25 occurrences on four National Forests in California Hutchison’s is known from 56 occurrence on five National Forest.

Kellogg’s and Hutchison’s lewisia usually occur on ridgetops or relatively flat open areas with widely spaced trees in partial to full sun. Most soils are reported to be sandy granitic to erosive volcanic with granitic boulders. Kellogg’s and Hutchison’s lewisia are spring ephemeral perennial herb, thus the survey window for the species is restricted to June and July when the plants produces fleshy and flowers. After flowering the succulent portion of the pedicel shrinks down, pulling the flower below ground level. This feature of the plants biology limits the survey window for Kellogg’s and Hutchison’s Lewisia to the summer months when the plant is flowering.

Threats include off-highway vehicles since they travel easily across the flat, open habitat of where Kellogg’s lewisia often occurs. Other potential threats include camping; hiking and other activities that compact soil and/or trample plants. Native plant gathering for traditional uses may affect some populations. Plants are most susceptible to impact from trampling during the spring months before the plant becomes dormant. During dormancy the plant can tolerate some disturbance as it is under the soil surface and relatively protected from trampling and other direct impacts.

Broad-nerved hump-moss (Meesia uliginosa) Meesia uliginosa also has a worldwide distribution. There are 46 known occurrences in California and the majority of the California occurrences are in the Sierra Nevada (CNDDB, 2015). Its distribution is sporadic throughout the Sierra Nevada and fewer occurrences are known than for M. triquetra. It is known to occur from Siskiyou County south to Tulare County with one collection from the San Jacinto Mountains in Riverside County. Populations of M. uliginosa are reported to be small and infrequently encountered. There are no known occurrences of M. uliginosa on the Eldorado NF but potential habitat does exist (CNPS, 2015).

M. uliginosa grow in bogs and fens in cold, permanently saturated, spring-fed meadows and fens at elevations between 4,200 to 9,200 feet. It often grows in association with Sphagnum moss, Drosera (sundew), and Vaccinium (huckleberry). This moss occurs in fens, peaty soil banks, seeps, meadows, and rock fissures These meadows are generally in the upper levels of mixed conifer to subalpine forests.

The two most critical factors affecting the abundance and distribution of fen species such as M. uliginosa are hydrology and the nutrient concentration of incoming water. Changes in hydrology may occur through ditching related to road or trail construction or cattle trails. Direct trampling by livestock has also been identified as a threat.

Navarretia prolifera ssp. lutea (Yellow bur navarretia) Navarretia prolifera ssp. lutea is a highly localized subspecies that is restricted to a narrow east-west band 18 miles long and 8 miles wide centered over Pollock Pines, El Dorado County. All of the known occurrences are found within ten miles of Pollock Pines Within the 144 square-mile area described above there are 84 (ENF, 2015a) documented occurrences of this annual forb. About two-thirds of these occurrences are located on federal land; the remainder are found on private lands.

All of the occurrences of N. prolifera ssp. lutea occur in openings in or adjacent to mixed conifer forests dominated by ponderosa pine, incense cedar, sugar pine, and California black oak. Shrub dominants and herbaceous associates typically include manzanita (Arctostaphylos spp.), buckbrush (Ceanothus cuneatus), hill lotus (Lotus humistratus), bicolored monkeyflower (Mimulus bicolor), mountain pretty face (Triteleia ixiodes ssp. analina), and silver hairgrass (Aira caryophyllea). The majority of occurrences are found on the Ledmount soil series, a very shallow, cobbly sandy loam, underlain by hard volcanic breccia. Habitat for N. prolifera ssp. lutea is found on or near rocky ridgelines, saddles, or eroding ephemeral drainages at elevations of 2,325 to 5,000 feet on gentle slopes with aspects of south to west. No plants have been found in pine needle or oak leaf duff.

These sparsely vegetated and non-forested openings where N. prolifera ssp. lutea occurs may be openings that result from thin soils, or they may be due to human disturbances such as logging activities, road building, or housing development. On disturbed sites, the displaced vegetation may return and reduce the suitability of the site to support N. prolifera ssp. lutea, resulting in the decline in numbers and area occupied by N. prolifera ssp. lutea and its possible elimination from the site.

Peltigera gowardii (Veined water lichen) 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. Although it has a broad distribution, its’ distribution is limited to isolated site clusters. Veined water lichen is infrequently reported. Where populations occur, the number of individuals are generally few. Surveys for this species have been conducted in support of projects on the Eldorado National Forest since 2006 when this lichen was added to the ENF Sensitive plant list. In 2008 multiple populations of Peltigera hydrothyria were discovered on the Eldorado NF growing within the stream channel of Cat, Anderson, and Mehrten Creek (tributaries to the Middle Fork of the ). Additional populations were found in 2009 in Dark Canyon Creek, tributaries to Cat Creek and two unnamed tributaries to the North Fork Cosumnes River. There ae currently 17 known occurrences on the ENF. Across California there are 80 known occurrences across the Plumas, Eldorado, Stanislaus, Mendocino, Six Rivers, Klamath, Inyo, Sierra, Sequoia and LTBMU.

Within the Sierra Nevada, this species is found in cold, unpolluted streams (or in the spray zone) in mixed conifer forests between 2,500 and 8,000 ft. It grows on rock (usually large rocks and bedrock); in shade. The water is very clear and peak flows are not of the intensity that would lead to scouring. According to the 2010 R5 Conservation Assessment, P. hydrothyria is known almost exclusively from streams with little sedimentation or scouring. During high water events, scouring might occur from gravel and rock movement, or even from sediment abrasion. The thin, gelatinous thallus of P. hydrothyria is presumably quickly abraded or completely removed from substrates during such events. Sedimentation may also be detrimental to P. hydrothyria colonies by physically covering thalli, reducing photosynthesis. Watershed- disturbing activities leading to sedimentation at and above occurrence sites can threaten populations. The streamlets have a rich aquatic bryophyte flora and are rarely more than 8 inches deep with little seasonal variation in water levels.

Threats include any management activity that would kill plants, change the shade component of the habitat, or reduce/damage water quality/clear water. P. hydrothyria populations are known to correspond to habitat characteristics outside of the stream channel, including canopy cover (shading) and presence of old growth forest. The relevant characteristics of old growth forests are uncertain and may overlap the canopy cover relationship in that they both tend to increase shading. Management activities that affect forest structure around known occurrences, particularly when altering the shading of the stream, could be detrimental to P. hydrothyria populations. may be a localized threat to P. hydrothyria populations in multiple ways. Wildfire may directly impact canopy cover shading populations, may increase sedimentation through removal of vegetation and reduction of duff, may increase nutrient runoff, and may even alter watershed hydrology.

Global climate change is expected to warm air temperatures in California, which could subsequently warm water temperatures and impact habitat for the aquatic lichen. Additionally, snow-pack in the Sierra Nevada is expected to decrease, which could allow stream water temperatures to increase and reduce stream flows rapidly during summers. Given the current trajectory of air temperatures, stream temperatures are likely rising throughout the Sierra and if the trend continues, P. hydrothyria could be significantly impacted at a regional scale (USDA R5, 2010).

Aquatic noxious weeds of concern for aquatic veined lichen on the Eldorado include Didymo (Didymosphenia geminate), parrots feather (Myriophyllum aquaticum), hydrilla (Hydrilla verticillata), and Eurasian milfoil (Myriophyllum spicatum). None of these species, excluding didymo are known from the Eldorado NF but do occur in the vicinity of the forest (ENF, 2015b). Of particular concern for veined aquatic lichen is the potential invasion of occupied streams by Didymo. Didymo has been noted in a number of rivers in the Sierra Nevada including the Feather River, the South Fork of the American River, and the Rubicon River and is generally spread by anglers. The spread of this invasive algae would likely be detrimental to veined aquatic lichen since the algae covers rocks and streambeds where the lichen is known to occur

Olive phaeocollybia (Phaeocollybia olicacea) PHOL is endemic to western North America and in the United States from Washington south to California (Castellano et. al. 2003). PHOL is known from Clallam, Grays Harbor and Jefferson Counties in Washington ; Benton, Clackamas, Columbia, Coos, Lane, Lincoln, Linn, Multinomah, Douglas and Josephine counties in Oregon (Castellano et. al. 2003); and Del Norte, Humboldt, Trinity, Marin, Mendocino, Siskiyou, Sonoma and Yuba counties in California. Distribution is patchy across its range. The US Forest Service Natural Resources Information System (NRIS) contains 53 element occurrences of PHOL as of February 2013.

PHOL is threatened by activities that significantly removes the host trees or disturbs the ground to the point that microclimate and moisture regimes are changed. The most serious, long-term threat may be the predicted rapid spread of Phytophthora ramosa (sudden oak death) to its oak partner-trees. PHOL is in the ectomycorrhizal (ECM) functional group. ECM fungi develop interdependent relationships with living host species whereby the fungus obtains carbohydrates from the host plant and the host plant obtains mineral nutrients and water from the fungus. The underground fungal tissue or mycelia is the network along which this transport of carbohydrates, mineral nutrients and water occur. Habitat for PHOL is generally characterized as conifer and hardwood forests where it can grow in arcs in the humus layer.

Whitebark Pine (Pinus albicaulis) Whitebark pine is a dominant tree in many upper subalpine forest of western North America, but is limited to the subalpine and timberline zones between 7,000 and 12,000 feet. In 2011 U.S. Fish and Wildlife determined the whitebark pine warrants protection under the Endangered Species Act (ESA) and was added to the list of candidate species eligible for ESA protection and review. Potential threats to this high elevation species includes mortality from white pine blister rust, mountain pine beetle, catastrophic fire and fire suppression, and climate change. Additional threats on the Eldorado NF includes

Special Interest Plants and plant Communities Refer to Appendix A, Botany report for Special Interest Species.

Noxious Weeds See Appendix B for the Noxious Weed Risk Assessment and Appendix C for Noxious Weeds of Concern for the ENF. Implementation of included design criteria should minimize the likelihood of project activities enhancing or spreading into the proposed project area.

VI. EFFECTS Analysis area defined: This analysis addresses activities and actions associated with Pilliken Forest Health Project on Eldorado National Forest. The cumulative effects for botany are bound in time by the first botany records on the Eldorado National forest (early 1980’s) and covers all proposed activities that are likely to occur in the project area during the next 5 years. The spatial extent of the analysis includes all known and potential occurrences found within the area of the proposed project.

Direct and indirect effects for known sensitive plants Negative, effects of the proposed project are not expected for TES plants since design criteria have been included to prevent direct and indirect effects to known Sensitive plant species. Further discussion of specific risks from project activities and site project design criteria that address the potential risks are provided below:

Thinning units: The proposed project would conduct mechanical thinning activities on 1,921 acres of 40 year old plantation and 516 acres of natural stands to reduce stand density. Adverse impacts to sensitive terrestrial plants could occur if mechanical equipment damages or uproots sensitive plants, compact soils, or alter overstory condition. Within the Pilliken project area there are three occurrences within 500 feet of proposed thinning units. Adverse direct impacts to known occurrences within thinning units are not expected since occurrences and associated potential habitat will be flagged for avoidance prior to project implementation.

All known terrestrial sensitive plant occurrences within 500 feet of proposed thinning units are not expected to be directly impacted by proposed thinning activities. To insure that occurrences are not inadvertently impacted by additional activities associated with thinning projects (landing construction, skid trails, piling, road improvements, danger tree removal, etc.) all sensitive plant occurrences will be flagged and included on project area maps prior to project initiation. All activities will be excluded from these sensitive plant occurrences unless approved by the project botanist in advance of implementation.

Table 2. Terrestrial plants occurrences within 500 ft of proposed units. Sensitive plant Status Suggested Unit occurrence Treatment CACLA_105 Plants occur in thick Proposed hand 6150050 deer brush directly treatment to thin (adjacent) along Plum Creek deer brush to release Rd CACLA. CACLA_117 Site last visited 2004 Outside of project boundary but within 6140118 500 Feet. Keep (adjacent) equipment out of population. Do not use as staging area CACLA_140 Plants occur along Population just lava cap area, one beyond project 6140116 plant found boundary. Keep (adjacent) equipment out of population. Do not use as staging area

Activities associated with prescribe fire (line construction, pile burning, broadcast burning): Within the Pilliken project area, approximately 2,437 acres of prescribed burning will be conducted. In general the actual prescribed fire has limited impacts on understory terrestrial plant communities and sensitive plant species since these species are adapted to growing on a landscape where wildfire was historically an integral component of shaping and maintaining the plant communities where these sensitive species occur. Prescribed burning activities proposed for the Pilliken project includes creepy pile, jackpot, and general understory burning. While the actually burning activities are relatively benign, the prep work associated with burning does involve some risk to terrestrial sensitive plants.

Fire-line construction can directly impact terrestrial sensitive plant occurrences by potentially uprooting, crushing, or altering habitat condition (canopy closure, microsite hydrology, covering plants, etc.) if fire-line is constructed through an occurrence. None of the known Sensitive plant occurrences within the Pilliken project area are within proposed units, but CACLA-105 does occur adjacent to unit 6150050 and could be impacted by line construction. Since fire-line construction can occur several years after completion of thinning and other treatments, the project botanist will be consulted prior to line construction to reflag any sensitive plant occurrence that may need to be updated and to insure line construction within the project area does not affect known sensitive plant occurrences. When laying out future burn units, fire-line construction will be developed to avoid direct impacts to sensitive plant occurrences. Other activities that may impact sensitive plants include creating handpiles prior to burning or felling hazard trees into sensitive plant occurrences. Since sensitive plant occurrences will be flagged for avoidance this is not expected to be a concern within the project area.

Roadwork in the project area: Proposed road work for the Pilliken project includes 52 miles of reconstruction. Potential threats for terrestrial sensitive plants during road construction are primarily the physical disturbance to roadside occurrences. There are two known occurrences of Pleasant Valley adjacent to or bisected by designated roadways in the project area (see Table 5). Impacts to these known occurrences are not expected since all occurrences will be flagged for avoidance. If road maintenance, reconstruction or brushing is required adjacent to terrestrial sensitive species, the project botanist will be contacted prior to initiating roadwork to insure impacts to sensitive plants are avoided.

Table 5 Known terrestrial sensitive plant species within the project area adjacent to proposed road reconstruction (< 200 feet). Road Activity Occurrence None Plum Creek (10N40) CACLA_105 identified None Slide On (10NY09) CACLA_140 Identified

Dust abatement: The application of magnesium chloride for dust abatement may directly impact sensitive plant species if magnesium chloride is applied to roadside sensitive plant populations or is transported to sensitive plant species downslope of the application site. This is of particular concern for Pleasant Valley mariposa lily occurrences on shallow soils along existing roads in the project area. Magnesium and chloride are both essential nutrients for normal plant growth but at application rates used for dust abatement can become toxic causing leaf necrosis, or even death for some species.

Hazard trees and roadside brushing: Roadside brushing could impact Sensitive plant populations by crushing or disturbing plants. Additionally, chipping brush could introduce a thick layer of mulch atypical for sensitive plant populations in the project area, potentially impacting recruitment of new seedlings for Pleasant Valley mariposa lily. Pilling materials could also crush individual plants. The two roadside occurrences of Pleasant Valley Mariposa lily will be flagged for avoidance and should not be impacted by roadside brushing. Hazard tree removal in sensitive plant populations could result in individual plants being crushed during felling operation. If hazard trees are identified in sensitive plant populations the project botanist would be consulted to mitigate impacts. If hazard trees are identified on the perimeter of an occurrence trees will be directionally felled away from the occurrence.

Invasive plant introduction: Soil disturbances can provide opportunities for the introduction and proliferation of invasive species. These species have the potential to quickly outcompete native plants including Sensitive plants for sunlight, water, and nutrients. These species can also form dense monocultures which can alter habitat for Sensitive plant species. Seeds of these species can be carried into Sensitive plant areas on prescribed burning equipment, vehicles, and on workers boots and clothing. The magnitude of this impact is difficult to predict since it is contingent on the introduction of a noxious weed species into an area, an event which may or may not occur.

Generally the Pilliken project is free of invasive plant species but there are a number of priority isolated infestations along access routes and adjacent to project units (see noxious weed risk assessment). These infestations could easily be spread during project activities including into Pleasant Valley Mariposa lily populations. Additionally the proposed thinning and fuels work in the Pilliken project area will increase the susceptibility of treated units to future invasions. To limit the potential for spread, known priority infestations would be treated during Pilliken project implementation using methods described in the Eldorado Forest Invasive Plant EA. This will reduce existing seed sources throughout the project area which is an important preventive measure when using mechanical equipment and prescribed fire to manipulate forest structure. Additional standard measures included in the proposed Pilliken project such as excluding vehicle traffic from known infestations, equipment cleaning, and use of weed free material will further limit the risk of invasive species spreading into the project area and impacting sensitive plant occurrences. While the risk of invasion cannot be completely eliminated these measures are expected to greatly limit the potential introduction and spread of invasive species in the project area, thereby reducing the risk of invasive plants impacting known sensitive plant occurrences.

Direct effects for undiscovered sensitive plants in the project area Potential habitat for a number of sensitive plant species occurs in the Pilliken project area but occurrences were not found during recent surveys. While survey coverage for the project was extensive, it is still possible that past and recent surveys overlooked existing sensitive plants (surveys can only positively state a species presence, not its absence). If surveys inadvertently overlook sensitive plants, these individuals could be affected by project activities including, fire-line construction, prescribed burning, thinning activities, or road maintenance. If new occurrences are found during project implementation the project botanist would be contacted and necessary mitigations developed to limit impacts to newly discovered sensitive plant species.

Two new species of fungi were discovered on the Eldorado NF in the fall of 2015 prior to the completion of surveys for the Pilliken project. Potential habitat for both species (Phaeocolybia olivaceae and Dendrocollybia racemosa) occurs in the project area but surveys for these fungi have yet to occur. To mitigate risks of impacts to undetected occurrences, sampling of potential habitat would occur prior to implementation. While surveys are effective when the fruiting body is visible, the extent to which a species occurs on the surface and a correlation with the abundance underground is unknown. When a survey does not find the fruiting body it could still be present at the site, because of this it is important to manage habitat to remain suitable for the fungi by:

• Retain trees that are known fungi host species if possible (Douglas fir and hardwoods). • Retain a component of the largest diameter trees distributed throughout the treated stand, which will help retain most diverse ectomycorrhizal species and will help retain the sensitive fungi, which are old growth associates. • Retain shrub layer. Some of the more important shrubs to retain are Arctostaphylos species and Salix species, which are also hosts for ectomycorrhizal species. • Retain standing and down coarse woody debris. Scattered islands of down wood throughout a management unit, including many sizes ranging from twigs to large logs, as well as a variety of decay classes, is preferable to one size or decay class of down wood homogeneously covering the forest floor.

The Pilliken proposed action is expected to achieve many of the above recommendations and should maintain suitable habitat for fungi species, including R5 Sensitive fungi, but impacts to undetected populations is still plausible given the difficulty in detecting rare fungi.

Cumulative Effects In order to understand the contribution of past actions to the cumulative effects of the proposed action and alternatives, this analysis relies on current environmental conditions as a proxy for the impacts of past actions. This is because existing conditions reflect the aggregate impact of all prior human actions and natural events that have affected the environment and might contribute to cumulative effects and is consistent with National Environmental Policy Act (NEPA) Regulations (36 CFR 220.4(f)) (July 24, 2008).

Forest Service Ativities: Adverse impacts to sensitive plants from recent (1989-2011) activities have largely been minimized by the use of mitigation measures, mainly the use of avoidance. Ongoing and future management activities in the Pilliken project area would likely include road maintenance, hazard tree removal and implementation of ongoing FS projects in the area. It is anticipated that future impacts to sensitive plants would continue to be minimized through the use of avoidance for the above foreseeable actions. Avoidance or other means of mitigating impacts to sensitive plant occurrences is consistent with direction contained in in the ENF LMRP, which includes under Standard And Guideline 49 (p. 4-91), "provide for the protection and habitat needs of sensitive plants so that Forest activities would not jeapardize the continued existence of such species."

Climate change: Anthropogenic caused increases in temperatures and changes in precipitation are likely to impact both ecosystem structure and ecosystem processes (IPCC, 2007). Climate controls many ecosystem processes including species distribution and abundance, regeneration, vegetation productivity and growth, and disturbance all of which could affect FS sensitive species on the Eldorado National Forest. While there is some uncertainty regarding the scale, rate, and direction of future climatic conditions in the western United States and the Sierra Nevada (North et al., 2009) some general observation regarding past changes and expected future changes are generally agreed upon.

Climate change effects on precipitation and mean temperature have been difficult to predict with considerable variation between different models. According to Dettinger (2005), the most common prediction among the most recent models for California is temperature warming by about 9 degrees F by 2100, with precipitation remaining similar or slightly reduced compared to today. Most models agree that summers would be drier than they are currently, regardless of levels of annual precipitation. Current estimates of predicted climate change on vegetation patterns forecast that forest types and other vegetation dominated by woody plants in California would migrate to higher elevations as warmer temperatures make those areas suitable for colonization and survival (Lenihan et al. 2003). However, rare and uncommon species are expected to experience a number of barriers when adjusting to a rapidly changing climate because of the combination of a small number of occurrences, narrow elevational ranges, and requirements for specific soils types. Some of the FS Sensitive plant species (Pleasant Valley Mariposa lily, Hutchison’s Lewisia, and Three-bracted onion) with potential habitat in project area are restricted to limited areas within the forest. Plants confined to outcrops of special soils are generally expected to have a far lower chance of successful migration to suitable new sites and thus far greater risks of extinction in the face of climate change, than plants that are soil generalists (Harrison 2009). Because of the uncertainty in scale, direction, and rate of future climate change, current management of sensitive species on the Eldorado NF would focus maintaining viable populations throughout the species known range.

VII. OTHER MANAGEMENT ISSUES AND RECOMMENDATIONS: None.

VIII. MITIGATIONS AND MONITORING Sensitive plants Any new occurrences of sensitive plants identified within the project area would be flagged and avoided when necessary.

IX. DETERMINATION

For Listed Species The proposed Pilliken Forest Health Project will not affect Packera layneae or its habitat. Formal consultation with the U.S. Fish and Wildlife Service pursuant to Section 7 of the Endangered Species Act is not required.

For Candidate species The proposed Pilliken Forest Health Project would not affect Pinus albicaulis.

For Sensitive Species There is no potential habitat for Arctostaphylos nissenana, Balsamorhiza macrolepis var. macrolepis, Draba asterophora var. asterophora, Draba asterophora var. macrocarpa, Eriogonum tripodum, Helodium blandowii, Horkelia parryi, Lewisia longipetala, Lewisia serrata, Ophioglossum pusillum, Phacelia stebbinsii, and Poa sierra in the project area. Therefore the proposed action would not affect these species.

Some suitable habitat for Allium tribracteatum, Botrychium ascendens, Botrychium crenulatum, Botrychium lunaria, Botrychium minganense, Botrychium montanum, Botrychium paradoxum, Botrychium pendunculosum, Bruchia bolanderi, Cypripedium montanum, Dendrocollybia racemosa, Lewisia kelloggii ssp. kelloggii, Lewisia kelloggii ssp. kelloggii ssp. hutchisonii, Meesia uliginosa, Navarretia prolifera ssp. lutea, Peltigera gowardii, and Phaeocollybia olivacea occurs in the Pilliken Project area, but no occurrences were not found during past or recent surveys. Because past surveys cannot positively state the absence of a sensitive plant species it is possible that the proposed project could affect undetected individuals in the project area. Therefore, the proposed project may affect undiscovered individuals but is not likely to result in a trend toward Federal listing or loss of viability for the 17 species listed above.

Occurrences of Calochortus clavatus var. avius occur in the proposed Pilliken Project area. All occurrences will be flagged and avoided during project implementation. Because past surveys cannot positively state the absence of a sensitive plant species it is possible that the proposed project could affect undetected individuals of Calochortus clavatus var. avius and area. Therefore, the proposed project may affect undiscovered individuals but is not likely to result in a trend toward Federal listing or loss of viability for Calochortus clavatus var. avius.

X. REFERENCES CNPS (California Native Plant Society). 2015. Inventory of Rare and Endangered Plants of California (online version). Eldorado National Forest. 2016. Sensitive plant habitat and occurrence maps, and unpublished occurrence records. Eldorado National Forest. 1989. Land and Resource Management Plan. Pacific Southwest Region. USDA Forest Service. Eldorado National Forest. 2016. Noxious Weed GIS database. Placerville, CA Eldorado National Forest. 2015. Scoping Notice for Pilliken Forest Health Project. USDA Forest Service, Pacific Southwest Region, Eldorado National Forest, Pacific Ranger District. USDA Forest Service. 1990. Forest Service Manual: Wildlife, Fish, and Sensitive Plant Habitat Management (section 2670), WO Amendment 2600-90-1. Effective 6/1/90. USDA Forest Service. 1990. Threatened and Endangered Plants Program Handbook (R-5 FSH 2609.25) Amendment 1, Exhibit 1: R-5 Sensitive Plant Species. USDA Forest Service. 2011. Forest Service Manual: Noxious Weed Management (section 2900). USDA Forest Service. 2001. Forest Service Guide to Noxious Weed Prevention Practices. USDA Forest Service. 2012. Regional Forester's List of Sensitive Plant Species (Revision). Pacific Southwest Region. USDA Forest Service. 2004. Pacific Southwest Region. Sierra Nevada Forest Plan Amendment, Final Supplemental Environmental Impact Statement.

APPENDIX A: BOTANY REPORT FOR SPECIAL INTEREST PLANTS

I. INTRODUCTION

Purpose: The purpose of the Botany Report is to describe effects on Special Interest (or watch list) plant species, special interest plant communities, and other botanical resources.

Special Interest Plant Species and communities:

There are no watch list species of concern in project area.

Lava cap: These plant communities are generally dominated by high diversity of herbs and shrubs adapted to growing on rocky and volcanic soils eroded from Mehrten formation mudflow. Early each spring, these rocky areas give rise to a rich and varied ephemeral plant community. The rest of the year lava cap communities often have a sparse barren appearance. This community type is recognized by CNPS as a sensitive plant community type. Threats to these unique plant communities include OHV activity, fuels reduction activities, landing construction and invasive plant introduction. Because of the lava cap physical situation, on fairly level ridgetops, much of this habitat has been impacted by the construction of roads, trails, and landings. The forest generally avoids ground disturbance including landings, and equipment staging on pristine lava cap communities.

II. CURRENT MANAGEMENT DIRECTION

Special Interest species: A number of plant species do not meet all of the criteria to be included on the Regional Forester’s Sensitive Plant List, but are of sufficient concern that we need to consider them in the planning process. These include species that are locally rare – as opposed to declining throughout their range – are of public concern, occur as disjunct populations, are newly described taxa, or lack sufficient information on population size, threats, trend or distribution.

Such species make an important contribution to forest biodiversity and are addressed as appropriate through the NEPA process. To better identify these species, forests have been encouraged to develop watch lists for these special interest species. These watch lists are dynamic and updated as the need arises to reflect changing conditions and new information.

Table 1. Watch list species with potential habitat in the Pilliken Project Area (updated 2016)

Potential CNPS Lower Elevation Upper Elevation Species Common Name Habitat Habitat in Ranking (ft) (ft) project Area

Allium sanbornii Up to Congdon's onion 4.3 Serpentine outcrops No var. congdonii 4,000

Allium sanbornii Up to Sanborn's onion 4.2 Serpentine outcrops No var. sanbornii 5,020 Alpine boulder &

Astragalus rock field in Austin's 1B.3 No 7,600 8,825 austiniae subalpine milkvetch coniferous forest. Alpine boulder & Astragalus Whitney's milk- rock field in Above 4,900 whitneyi var. 4.3 No vetch subalpine lenophyllus coniferous forest. Rock crevices and Bolandra Sierra bolandra 4.3 wet cliffs along No 3,100 4,200 californica streams. Potential CNPS Lower Elevation Upper Elevation Species Common Name Habitat Habitat in Ranking (ft) (ft) project Area Moist and wet meadow, seeps, fens Botrychium Yosemite Above 5,000 -- and streamside Yes simplex moonwort habitats about 6,000 feet in elevation.

Calystegia Van Zuuk’s 1B.3 Serpentine outcrops No 1,640 3,900 vanzuukiae morning glory Narrow endemic from the western Carex cyrtostachya arching sedge 1B.2 slope of the Yes 2,000 4,460 northern Sierra Nevada of California Upper montane coniferous forest to Subalpine Above 4,500 Carex davyi Davy's sedge 1B.3 coniferous forest; Yes

Dry often sparse meadows or rocky areas. Occurs in occasionally flooded Climacium Tree Climacium Above ~3,500 (limited information 2B.1 mineral soil, Yes dendroides moss available) especially on lake and river margins Cismontane woodland Ceanothus Fresno 4.3 (openings), lower No 3,650 6,900 fresnensis ceanothus montane coniferous forest Alpine boulder and Chaenactis rock field (granitic), alpine dusty Above 9,800 douglasii var. 2B.3 Rocky or gravelly No maindens alpina ridges, talus, fell- fields, crevices Serpentine outcrops, open Chlorogalum red hills shrubby or wooded Up to 1B.2 No grandiflorum soapwort hills; Chaparral, 3,150 Foothill Woodland, Yellow Pine Forest Foothill woodland, chaparral, cismontane Clarkia biloba ssp. Brandegee's 4.2 woodland, lower No Up to 3,000 brandegeeae clarkia montane coniferous forest. Often found growing in road cuts Foothill woodland, cismontane woodland, lower Clarkia virgata Sierra clarkia 4.3 No 2,460 to 5,675 montane coniferous forest, yellow pine forest Potential CNPS Lower Elevation Upper Elevation Species Common Name Habitat Habitat in Ranking (ft) (ft) project Area Subalpine, alpine gravel, talus, Claytonia fell-fields crevices, growing In 2B.3 No Above 8,500 megarhiza claytonia crevices between rocks in rocky or gravelly soils. Wet, open to northern shaded, generally Corallorhiza trifida coralroot; Early 2B.1 coniferous forest. In Yes 4,500 5,600 coralroot California, under firs, in partial shade

Fens, meadows and Drosera anglica English sundew 2B.3 seeps often with No 4,250 6,500 Sphagnum

Fens, meadows and Drosera round leaf -- seeps often with No Up to 8,900 rotundifolia sundew Sphagnum Upper montane Dryopteris filix- coniferous forest Above 7,800 male fern 2B.3 No mas (granitic, rocky); Granitic cliffs

Growing on Cutleaf monkey decomposed granite Above 3,100 Mimulus laciniatus 4.3 Yes flower in moist sandy places.

streambanks and other moist places in Myrica hartwegii Sierra sweet bay 4.3 Yes Up to 6,000 foothill and low montane forest

Holzinger’s Orthotrichum Usually on rock in and orthotrichum 1B.3 along streams, rarely No 2,345 6,000 holzingeri moss on tree limbs.

Sites in which it occurs include open rocky areas, Perideridia Mother Lode 4.2 chaparral openings, No Up to 3,500 bacigalupii Yampah slopes, and road cuts. Usually on serpentine Potential CNPS Lower Elevation Upper Elevation Species Common Name Habitat Habitat in Ranking (ft) (ft) project Area

Open conifer forest, Coleman's Rein scrub; often in Piperia colemanii 4.3 Yes 3,900 7,545 Orchid sandy soils.

Generally dry sites, scrub, woodland; petaled rein Chaparral, Foothill Piperia leptopetala 4.3 Yes 1,100 7,300 orchid Woodland, Yellow Pine Forest, Red Fir Forest.

Meadows, dry Pseudostellaria Sierra Starwort 4.2 understory of mixed Yes 4,000 7,200 sierrae oak or conifer forest

white beaked- Wet meadows, fens, Rhynchospora alba 2B.2 No Up to 6,700 rush seeps, and marshes

Rhynchospora brownish Wet meadows, fens, 2B.2 No Up to 6,560 capitellata beakrush seeps, and marshes

Riparian areas; of concern below Sambucus nigra L. 3,000’ as host plant Blue Elderberry -- No Up to 3,200 ssp. caerulea for Threatened Valley Elderberry Longhorn Beetle Potential CNPS Lower Elevation Upper Elevation Species Common Name Habitat Habitat in Ranking (ft) (ft) project Area

Wetland-riparian, Sparganium natans Small bur reed 4.3 No 2,800 8,560 lake margins.

Mixed Evergreen Forest, Douglas-Fir Taxus brevifolia Pacific yew -- Forest, Yellow Pine No Up to 4,600 Forest, Red Fir Forest Mixed Evergreen California Forest, Douglas-Fir Torreya californica -- No Up to 3,000 nutmeg Forest, Yellow Pine Forest

Chaparral, Cismontane woodland, Lower Viburnum oval-leaved montane coniferous 2B.3 No Up to 4,500 ellipticum viburnum forest. Chaparral, yellow-pine forest, generally n-facing slopes

Stony red clay and El Dorado gabbroic soils; often Wyethia reticulata County mule 1B.2 No Up to 2,060 in openings in ears gabbro chaparral

III. EXISTING ENVIRONMENT The Pilliken Plantation units as a whole were dry mixed conifer forest with very few riparian species within them, and occasional riparian areas along the boundaries. The dominant trees included Pinus ponderosa, Pseudotsuga menziesii, and occasional swaths of Calocedrus decurrens, Abies concolor, Quercus kelloggii, and Pinus lambertiana. The shrub layer was consistently present across the entire project area which is typical of plantation stands, but varied in density from a barren duff-covered understory beneath a thick canopy, to very dense shrub cover. The most common shrub species are Ceanothus integerrimus, Ceanothus cordulatus, Arctostaphylos patula, Ribes roezlii, Symphoricarpos mollis and Quercus vacciniifolia. Some of the most common understory forb and gramminoid species include: Bromus carinatus, Pteridium aquilinum, Elymus glaucus, Acnatherum sp, Kelloggia galioides, Osmorhiza chilensis, Lathyrus nevadensis/sulphureus, and Viola lobata.

IV. DESIGN CRITERIA

• If new watch plant occurrences are discovered during project implementation the project botanist would be notified to develop necessary protection measures.

• Lava caps, which support unique plant communities in the project area, would be protected from motorized equipment and vehicles. Line construction through lava cap communities would be avoided when feasible. If necessary, line construction would be completed with hand tools only.

V. EFFECTS Alternative 1: Watchlist species: There are no known watch list plants within the project area. Therefore direct and indirect effects from the proposed action are not expected. However, if past and recent surveys inadvertently overlook special interest plants, it is possible that some individuals may be affected directly by project activities. Indirect effects from project activity to undiscovered individuals may include soil compaction, crushing or uprooting individual plants, altered overstory conditions and potential introduction of non-native species and noxious weeds.

If any new special interest plant species are discovered in the project area, necessary actions would be considered to limit impacts from project activities. Therefore, the proposed project is not expected to cause cumulative effects for special interest plant species within the proposed project area.

Lavacaps: Lavacap communities occur throughout the project area. Impacts to lavacap communities from equipment staging, thinning activities, landing construction, and fire line construction will be avoided during project implementation.

VI. MITIGATION None required.

APPENDIX B: NOXIOUS WEED RISK ASSESSMENT

Five factors of weed spread were analyzed for the proposed Pilliken Forest Health Project. Determinations of risk (High, Moderate, and Low) are summarized below along with the total risk of weed spread for the proposed project if suggested mitigation measures are implemented.

If the proposed project includes all listed mitigation measures to reduce or eliminate the risks of introducing or spreading noxious weeds in the project area then it is my determination that the risk of spreading noxious weeds in the project area is Low.

Introduction: This assessment is in compliance with the Eldorado National Forest Land and Resource Management Plan (USFS ENF LRMP 1988), the Sierra Nevada Forest Plan Amendment (SNFPA) FSEIS and Record of Decision (ROD), Executive Order on Invasive Species (Executive Order 13112), and the direction in the Forest Service Manual section 2900, Noxious Weed Management (2012), which includes a policy statement calling for a risk assessment for noxious weeds to be completed for every project. The overriding principle stated in these documents is that the costs associated with preventing an infestation are much less than the costs of eliminating a population once it has expanded, and of dealing with the effects of a degraded plant community.

Noxious weeds generally possess one or more of the following characteristics: aggressive and difficult to manage, poisonous, toxic, parasitic, a carrier or host of serious insects or disease, or being nonnative or new to or not common to the United States or parts thereof (FSM 2900). In order to control noxious weeds the US Forest Service has adopted an integrated weed management approach to reduce the spread of noxious weeds on to, and from National Forest System lands. The main objective of this integrated approach to weed management is to prevent the introduction and establishment of noxious weed infestations, and control (contain and suppress) existing noxious weed infestations on National Forest System lands (FSM 2900). In addition when any ground disturbing action or activity is proposed, the federal agency is required to determine the risk of introducing or spreading noxious weeds associated with the proposed action (FSM 2900).

1. Noxious Weeds Present In or Near Project Area (Low) Overall, the Pilliken Project area is relatively free of priority invasive species. There are eighteen priority weed sites in the project area (see Tables 1). Three of these were existing sites prior to 2015. The yellow star thistle (Centaurea solstitialis) site CESO3_006-03, and the barbed goat grass (Aegilops triuncialis) AETR_013-01 did not contain any plants when surveyed. Rush skeleton weed site CHJU_048-01 contained approximately 100 plants, but this site is not directly within or adjacent to any units – it is merely along an access road. There are five new priority weed sites discovered during surveys including only medusa head (Elymus caput-medusae) and rush skeleton weed (Chondrilla juncea), and one low priority weed site, Klamath weed (Hypericum perforatum) The area of the largest newly discovered weed populations is about 1 acre, the rest are typically smaller than 0.25 acres.

Two landing near unit 6140107 and 6140118 are heavily infested with invasive species (Table 1). Use of either landing could spread invasive species into adjacent units.

Table 1. Unit Weed Site Common Name comments Road 6100151 AETR-013-01 Goatgrass No plants found in 2014 10N31 TACA8-036_01 Medusahead roadside 10N31 6120011 CHJU-173_01 Rush skeleton weed - 11N47 CHJU-173_02 Rush skeleton weed - 11N47 6140104 TACA8-037_01 Medusahead Roadside 10N41B CHJU-171_01* Rush skeleton weed Avoid landing 10N40 6140107 TACA8-035_01* Medusahead Avoid landing 10N40 6140116 AETR-051_01 Goatgrass Found in 2015 10NY09 6140116, 6140119, CESO3-007_02 Yellow star thistle Very limited infestations scattered along road 10N10Y 6140116 AETR-033_01 Goatgrass Dense throughout landing NA CESO3-007_04 Yellow star thistle Avoid landing NA 6140118 CHJU-180_01 Rush skeleton weed Avoid landing NA

CYSC4-075_01 Scotch broom Avoid landing NA TACA8-033_01 Medusahead Avoid landing NA 6140118 and CESO3-007_01 Yellow star thistle Handtreated in 2012 10N10Y 6140119 6150050 (adjacent) CHJU-049_01 Rush skeleton weed - 10N40 Outside project area AETR-050_01 Goatgrass Outside project area Outside project area CESO3-006_03 Yellow star thistle Outside project area Outside project area CHJU-172_01 Rush skeleton weed Outside project area 10N40DN Outside project area CESO3-008_01 Yellow star thistle Scattered infestation 10NY08E

In addition to the species listed in Table 1, low priority weeds were noted in low levels throughout the project area including, mullein (Verbascum thapsus), bull thistle (Cirsium vulgare) and cheat grass (Bromus tectorum), but due to their low levels it is not expected that project work will overly impact these species and spread them much further throughout the project area.

2. Habitat Vulnerability (Low) The proposed action would thin and remove conifers using ground based commercial logging within units that are predominantly densely vegetated either with small trees, small trees and shrubs, or sparse understory vegetation with a dense overstory of mixed conifer species. Stands such as the ones identified for this project are common on the ENF. Botanical knowledge gained from years of surveying similar dense stands suggests that the vegetation is composed of native species and the degree of shade under these stands is not conducive to invasive plants establishment. The project does propose to temporarily reduce native vegetation cover, which may provide enough sunlight for some weed species, but the lack of weed propagules (seeds/stems/roots) for the majority of the project area significantly reduces the risk of weed invasion. Project activities would also involve road work through lavacap and riparian communities. Prescribe fire would predominantly occur in mixed conifer forest but may also occur in lava cap and riparian communities. These communities are vulnerable to invasion by different suites of noxious weed species as described below:

Lava cap: Lava cap plant communities are vulnerable to noxious weed invasion if propagules are introduced. These plant communities are generally dominated by high diversity of herbs and shrubs adapted to growing on rocky and volcanic soils eroded from Mehrten formation mudflow. The limited canopy closure in many lava cap communities increases the vulnerability of these unique plant assemblages to invasion by noxious weed species adapted to growing in dry upland conditions such as yellow starthistle (Centaurea solstitialis), barbed goatgrass (Aegilops triuncialis), and medusahead (Elymus caput-medusae). Unfortunately, non-native annual grasses have already become established as a minor component of many lava cap plant communities on the forest.

Riparian communities: Proposed project activities that may introduce invasive species may occur within (roads bisecting stream channel) or adjacent to riparian areas. These riparian areas are susceptible to noxious weed invasion to riparian invaders, especially in areas that have been recently disturbed. Riparian areas on the Eldorado NF are particularly vulnerable to invasion by perennial pepperweed (Lepidium latifolium), Canada thistle (Cirsium arvense), oblong spurge (Euphorbia oblongata), and Himalayan blackberry (Rubus armeniacus).

Mixed conifer forests: Intact upland conifer forests are largely resilient to invasion by invasive species on the forest. When openings are created (roadways, prescribe fire, thinning projects) annual grasses, bull thistle (Cirsium vulgare), mullein (Verbascum thapsus), and other non-native species often become establish following the disturbance. However, these infestations rarely form dense monocultures and are easily outcompeted by native trees and shrub regeneration. More invasive species like yellow starthistle (Centaurea solstitialis), brooms, spotted knapweed (Centaurea maculata) and perennial pepperweed (Lepidium latifolium) can also become established in these upland communities and are a concern for the Forest.

3. Non-project Weed Vectors (Moderate) Weed vectors currently in the project area and vicinity include: off-highway vehicles (OHVs) such as motorcycles and four-wheel drive vehicles; road maintenance equipment; recreationists; private cars and trucks; Forest Service vehicles and workers; logging equipment on private land and FS; and wildlife. Natural dispersal from wind may also spread the seeds of some invasive species into the proposed project area. Wildlife may also disperse certain noxious weeds that can become attached to fur, or when viable seeds pass through digestive systems. Vehicles traveling routes and roads may pick up seeds from existing infestations and spread them to other locations on the forest. For some species, seeds can become affixed to clothing and gear (e.g. non-native annual grasses). Other species do not have dispersal mechanisms for attaching and would most like travel in mud on vehicle and tire tread (e.g. yellow starthistle, scotch broom, and spotted knapweed). 4. Habitat Alteration Expected as Result of Projects (Moderate) The proposed project would result in some habitat alteration due to hazard tree removal, fire line construction, prescribed fire, hand thinning, road construction, and timber harvest. All thinning and fuel removal treatments would temporarily increase the amount of light reaching the ground and in some instances the exposure of bare mineral soil. This is important because seeds of potential and known invasive plants all require sunlight and contact with mineral soil for germination and growth (Zouhar, 2008). In addition, proposed treatments such as burning could benefit noxious species by: inducing seed germination, temporarily reducing or eliminating competition from native plants, and increasing nutrient availability for noxious weeds. All these factors combine to make conditions ideal for weed seed to germinate and flourish immediately following fire and mechanical thinning (Asher et al., 2001).

A majority of known infestations within the Pilliken project area adjacent to proposed mechanical thinning units and prescribe burn areas (Table 1). After project implementation these infestations are at a high risk for spreading into recently disturbed areas and should be annually monitored and treated to prevent the spread of these infestations.

Long-term habitat alterations associated with the proposed Pilliken Forest Health project are expected to be minimal. Low intensity prescribed fires, and thinning, all remove smaller trees from the stand while leaving mature conifers in the overstory. In addition many native shrubs have been observed to readily resprout or geminate in the years immediately following mastication and fire (USDA Forest Service, FEIS 2008), and often increase in cover when overstory density is reduced. Thus, long-term habitat alterations conducive to the spread and establishment of noxious weed (i.e. increased bare ground and light) are not expected for much of the project area because remaining conifers and native vegetation will provide sufficient canopy cover to exclude most invasive species. During the interim period required for native vegetation to re-establish in the understory it is important to monitor and remove any new noxious weeds that may spread into newly open areas created immediately after the fire.

5. Increased Vectors as a Result of Project Implementation (Moderate) The proposed project would temporarily increase potential weed vectors due to the increase in project related vehicle use (ground base harvesting equipment, masticator, equipment used for road reconstruction and maintenance, etc). Potential introduction of invasive may occur when equipment is first brought into the project area or if equipment travels or is used within existing infestations in the project area. The greatest risk for spreading existing infestations is likely to occur during proposed road reconstruction since most existing infestations are currently restricted to travel corridors. Additionally the landing adjacent to unit 6140107 is heavily infested with medusahead grass (Elymus caput-medusae) which will likely spread into the unit during project implementation. Even if infestations are treated prior to implementation existing seedbanks could be spread further into the project area during ground disturbing project activities.

Another potential vector for invasive species related to project activities is the importation of materials such as fill, gravel, and rock during road reconstruction. Erosion control material such as straw and seeds can also introduce new noxious weeds into the project area.

Management requirements have been incorporated into the project to reduce or eliminate the likelihood of most vector opportunities related to the proposed project (see section 6).

6. Mitigation Measures The following mitigation measures should be included in the Pilliken project. These mitigation measures have been designed to limit the potential introduction of new noxious weeds into the project area and limit the potential spread of existing priority invasive plant infestations.

• Eldorado National Forest Priority 1 and 2 invasive plant infestations within the project area would be flagged for avoidance and treated using integrated pest management techniques as a part of the Pilliken project for up to 3 years after implementation. Treatments under the project will tier to the Eldorado National Forest Invasive Plant EA and may include a combination of techniques including tarping, manual removal, string trimming, and targeted herbicide application.

• Off-road equipment vehicles would be cleaned to insure it is free of soil, seeds, vegetative matter or other debris before entering National Forest System lands to prevent the introduction or spread of invasive plants. Prior to the start of operations, the Forest Service would do a visual inspection for such debris. Where possible, work in areas with invasive plant infestations last. If working in infestations or infested areas, equipment shall be cleaned before moving to other un-infested National Forest lands. These areas will be identified on project maps.

• Where proposed road work occurs in known invasive plant infestations equipment would be cleaned prior to leaving infested areas.

• All earth-moving equipment, gravel, fill or other materials would be weed free. Onsite sand, gravel, rock, or organic matter would be used where possible.

• Straw or mulch used for erosion control would be certified weed-free. A certificate from the county of origin stating the material was inspected is required.

• Any seed used for restoration or erosion control would be from a locally collected source (ENF, Seed, Mulch and Fertilizer Prescription, 2000).

7. Anticipated weed response to proposed action (Low Risk) The proposed Pilliken project would: 1) occur in relatively intact forest communities with a moderate risk for invasion and 2) occur in a portion of the Eldorado with few high priority noxious weed infestations; but does involves activities that could introduce or spread existing noxious weeds. Because of the above factors, the anticipated weed response to the proposed action is High/Moderate if recommended mitigations are not included. By including all of the mitigations listed in section 6, it is anticipated that the risk of spreading and/or introducing noxious weeds would be reduced to a low level of risk.

This weed risk assessment is restricted to the project description in this Biological Evaluation. If activities are proposed that extend beyond the activities described in this document, then a new assessment would be required APPENDIX C: NOXIOUS/INVASIVE WEEDS OF CONCERN

Invasive Plant List for the Eldorado National Forest 2/23/2016

Group 1 (Eradicate): Highly invasive species known to occur on the Eldorado National Forest. Species are uncommon and are a priority for inventory, control, and eradication. Acroptilon repens Russian knapweed Cirsium arvense Canada thistle Aegilops triuncialis barbed goatgrass Euphorbia oblongata oblong spurge Ailanthus altissima Chinese tree of heaven Isatis tinctoria dyer’s woad Arundo donax Arundo Lepidium latifolium tall whitetop Centaurea calcitrapa purple starthistle Lythrum salicaria purple loosestrife Centaurea diffusa diffuse (white) knapweed Sorghum halepense Johnson grass Centaurea stoebe spotted knapweed

Group 2 (Control): Established or widespread species known to occur on the Eldorado National Forest. Inventory all infestations. Annually treat a portion of known infestations, focusing first on eradicating/containing isolated outlying infestations and, over time, reducing the footprint of larger, less isolated infestations. Carduus pycnocephalus Italian thistle Elymus caput-medusae medusahead Centaurea melitensis tocalote Foeniculum vulgare Fennel Centaurea solstitialis yellow starthistle Genista monspessulana French broom Chondrilla juncea rush skeleton weed Spartium junceum Spanish broom Cytisus scoparius Scotch broom

Group 3 (Control): Established or widespread species known to occur on the Eldorado National Forest. Inventory and treat isolated leading edge infestations or where concurrent with higher priority infestations. Brassica nigra black mustard Melilotus officinalis yellow sweet clover Bromus tectorum cheat grass Rubus armeniacus Himalayan blackberry Chenopodium botrys Jerusalem-oak goosefoot Rubus laciniatus cut leaf blackberry Cirsium vulgare bull thistle Salsola tragus Russian thistle/tumbleweed Hedera helix English Ivy Silybum marianum milk thistle Hypericum perforatum Klamath weed Torilis arvensis hedge parsley Lathyrus latifolius perennial sweet pea Tribulus terrestris puncture vine Leucanthemum vulgare Oxeye daisy Vinca major periwinkle Melilotus alba white sweet clover

Group 4 (Manage through education and prevention): Species are well established across forest or have minor economic or ecological impacts. Forest will use appropriate prevention and education measures to limit further spread. Bromus diandrus ripgut brome Festuca arundinacea tall fescue Bromus madritensis var. rubens red brome Hirschfeldia incana mustard Conium maculatum poison hemlock Lychnis coronaria rose campion/ mullein pink Cynodon dactylon Bermuda grass Sisymbrium altissimum Jim Hill mustard Cynosurus echinatus spiny dogtail Verbascum thapsus mullein Dactylis glomerata Orchard grass

Potential invasives: Species not yet found on the Eldorado National Forest. If found, infestations should be inventoried and targeted for eradication or control. Aegilops cylindrica Jointed goatgrass Polygonum sachalinensis Sakhalin knotweed Cardaria chalepensis small whitetop Potentilla recta Sulfur cinquefoil Cardaria draba hoarycress Sesbania punicea Scarlet wisteria Cardaria pubescens whitetop Tamarix chinensis Salt Cedar Carduus nutans musk thistle Tanacetum vulgare tansy Carthamus lanatus Woolly distaff thistle Ulex europaeus Gorse Centaurea pratensis meadow knapweed Centaurea sulphurea Sicilian starthistle Cortaderia selloana pampas grass Dittrichia graveolens stinkwort Euphorbia esula leafy spurge Linaria genistifolia ssp. dalmatica dalmatian toadflax Linaria vulgaris yellow toadflax Nicotiana glauca Tree tobacco Onopordum acanthium Scotch thistle Phragmites australis common reed Polygonum cuspidatum Japanese knotweed