Biological Assessment for Threatened, Endangered & Sensitive (TES) Plants

Biological Assessment for Threatened, Endangered & Sensitive (TES) Plants,

Biological Evaluation for Region 2 Sensitive Plant Species, and

Plant Species of Local Concern Report

Slack Weiss Analysis Project

Parks Ranger District

MEDICINE BOW-ROUTT NATIONAL FORESTS & THUNDER BASIN NATIONAL GRASSLAND

Jackson County, Colorado

Version: June 22, 2015

Prepared By: _____/s/ Marti Aitken______Date:____June 22, 2015____ Marti Aitken, Botanist

Contents Summary ...... 2 Introduction ...... 3 Description of the Proposal ...... 3 Project and Analysis Area ...... 3 Purpose and Need ...... 3 Proposed Actions and Alternatives ...... 4 Alternative 1: No Action ...... 4 Alternative 2: Proposed Action ...... 4 Design Criteria Benefiting Botanical Resources ...... 5 Affected Environment ...... 6 Field Reconnaissance ...... 6 Threatened and Endangered Plant Species ...... 6 Consultation To Date ...... 7 Sensitive Species Considered in the Analysis ...... 7 Species of Local Concern (SoLC) ...... 7 Effects to Species Evaluated ...... 10 Alternative 1 - No Action ...... 10 Direct Effects to Plant Species Evaluated ...... 10 Indirect Effects to Terrestrial Species Evaluated ...... 10 Indirect Effects to Wetland & Aquatic Species Evaluated ...... 10 Alternative 2 - Proposed Action ...... 10 Direct Effects to Terrestrial Plant Species Evaluated ...... 10 Direct Effects to All Wetland & Aquatic Plant Species Evaluated ...... 11 Indirect Effects to Terrestrial Species Evaluated ...... 11 Indirect Impacts to All Wetland & Aquatic Species Evaluated ...... 13 Cumulative Impacts to All Plant Species Evaluated ...... 13 Determinations and Rationales ...... 14 References ...... 15

Summary No federally listed, candidates, threatened, or endangered plant species wiil be affect by the proposed action. This analysis determined that Alternative 1 would have no impacts (NI) for 2 R23 sensitive species and 13 of the species of local concern. This analysis determined that Alternative 2 would have no impacts (NI) for 16 of the R2 sensitive species and 1 the species of local concern. Alternative 2 may adversely impact individuals and/or populations but would not result a trend towards federal listing (MAII) 5 R2 sensitive species and 2 species of local concern. This analysis determined that Alternative 2 would have beneficial impacts (NBI) for 2 of the R2 sensitive species and 10 the species of local concern.

Introduction The purpose of this biological evaluation is to analyze and determine the likely effects of the alternatives on federally listed species (endangered, threatened, and proposed), Forest Service sensitive species (FSM 2670.31-2670.32) and species of local concern.

This Biological Evaluation (BE) conforms to legal requirements set forth under section 7 of the Endangered Species Act (ESA) (19 U.S.C. 1536 (c), 50 CFR 402.12 (f) and 402.14). Section 7(a) (1) of the ESA requires federal agencies to use their authorities to further the conservation of listed species. Section 7(a) (2) requires that federal agencies ensure any action they authorize, fund, or carry out is not likely to jeopardize the continued existence of federally-listed species, or destroy or adversely modify designated critical habitat.

Forest Service policy requires that a review of programs and activities, through a biological evaluation (BE), be conducted to determine their potential effect on threatened and endangered species, species proposed for listing, and sensitive species (FSM 2670.3). Under the ESA, a Biological Assessment (BA) must be prepared for federal actions that are “major construction activities” to evaluate the potential effects of the proposal on listed or proposed species. The contents of the BA are at the discretion of the federal agency, and will depend on the nature of the federal action (50 CFR 402.12(f)). A BE may be used to satisfy the ESA requirement to prepare a Biological Assessment. Preparation of a Biological Evaluation as part of the NEPA process ensures that TEPS species receive full consideration in the decision-making process.

Description of the Proposal Project and Analysis Area The Slack Weiss Project area is located on the Parks Ranger District of the Medicine Bow-Routt National Forests and Thunder Basin National Grassland in Jackson County, approximately 25 miles south of Walden, Colorado, in Townships 4 & 5 North, Ranges 79, 80, & 81 West, 6th PM. Based on watershed boundaries, the Analysis Area encompasses approximately 139,748 acres This analysis of botanical resources applies only to National Forest Service Lands (24,015 acres) within the analysis area. Purpose and Need The primary purpose of this project is to improve forest health, reduce threats to public safety, and provide commercial and noncommercial forest products while minimizing environmental effects in the project area. A secondary purpose of the project is to address other resource conflicts and needs identified in the project area. The project would advance Forest Service goals, objectives, and desired conditions of the 1997 Routt National Forest Revised Land and Resource Management Plan (Forest Plan) including managing for ecosystem function and providing for multiple-uses and sustainability of National Forests in an environmentally acceptable manner (Forest Plan, 1-1 to 1-3).

The mountain pine beetle epidemic has affected large portions of the Slack Weiss project area, resulting in reduced regeneration, diversity, and resiliency of forest cover types; and high hazard fuel conditions due to tree mortality. The project would implement a variety of silvicultural treatments and fuels treatments to:

Encourage establishment and better growing conditions for aspen and lodgepole pine regeneration, through natural regeneration and/or artificial reforestation;

Manage timber stands to create optimum conditions for forest resiliency, growth, and regeneration; Reduce the development of large, continuous hazardous fuels and associated threats to public safety by removing dead, dying, and susceptible trees; Enhance wildlife habitat; and Provide commercial forest products and/or biomass to industry.

In addition, other resource conflicts and needs have been identified in the project area including fence damage and risk of damage associated with dead and dying trees; and travel-related impacts on recreation, watershed, heritage, and other values. Implementing actions to address these issues would benefit range, hydrology, recreation, heritage, and wildlife resources while minimizing environmental effects in the project area.

Proposed Actions and Alternatives

Alternative 1: No Action Alternative 1 is the No Action Alternative. Under this alternative, the Slack Weiss Analysis Project would not be implemented, and current management would continue in the project area. No silvicultural treatments would occur to improve or restore forest health. Standing or down fuel would not be reduced, and fuels treatments would not occur to provide for public safety. No additional forest products would be utilized. Roads would remain unchanged and maintenance thereof would continue as scheduled. Other identified resource conflicts and needs related to wildlife, fuels, range, recreation, and heritage would not be addressed. Under the No Action Alternative, valid previously approved management actions would continue to be implemented in the project area, and new independent actions could be analyzed and/or implemented.

Alternative 2: Proposed Action The Proposed Action Alternative is designed to specifically meet the purpose and need for this project. Table 1 summarizes the proposed activities which are explained in detail in the Slackweiss Notice of Proposed Activities.

Table 1. Proposed Action (Alternative 2). Resource Proposed Activity Estimated Quantity Units

Timber Salvage/ Sanitation Cut 1,000.09 acres

Timber Commercial Harvest – Clearcut all but aspen 395.58 acres

Timber Commercial Harvest – Clearcut/ Overstory Removal 266.03 acres

Timber Seed Tree 107.69 acres

Timber Commercial Thinning 56.51 acres

Timber Meadow Restoration 7.14 acres

Timber Specified system road construction 1.4 miles

Timber Temporary road construction 2.5 miles Fuels Prescribed Fire (mountain shrub, aspen, grassy meadows, conifer 1025 acres Reduction stands)

Resource Proposed Activity Estimated Quantity Units Fuels Mechanical treatment 55 acres Reduction Range Mgmt Fence construction 1.6 miles

Range Mgmt Dead tree removal 19.9 acres

Rec Designate unauthorized trail to connect NFSR 700.2F & 704.1 0.37 miles

Travel Mgmt Decomission segment of NFSR 104.1, 711.1 and 711.1A 10.1 miles

Travel Mgmt Decomission unauthorized routes on 708.1 0.8 miles Watershed Indian Creek Revegetation 5 acres Mgmt

Design Criteria Benefiting Botanical Resources Plant occurrence and habitat protection Delineate a 100 ft buffer around known occurrences of R2 sensitive and local concern plant species and flag for avoidance. Avoid any loss of rare wetlands such as fens and springs. Where revegetation is appropriate, ork with the forest botanist to identify appropriate species for planting. Time prescribed fire to reduce the spread of invasive (native and non-native) species. Management of heavy equipment to benefit botany Clean all equipment before entering project area to avoid introduction of non-native species. Use transportation mats during transportation of equipment between road and excavation areas to avoid soil compaction. Within units, streamside management zones will be designated wherever wet depressional areas, springs or other riparian and wetland habitats exist. No heavy equipment will be allowed to operate within these streamside management zones. Keep heavy equipment out of streams, swales, and lakes, except to cross at designated points, build crossings, or do restoration work, or if protected by at least 1 foot of packed snow or 2 inches of frozen soil. Within units, streamside management zones will be designated wherever wet depressional areas, springs or other riparian and wetland habitats exist. No heavy equipment will be allowed to operate within these streamside management zones. Fuels and timber management practices to benefit botany Fell trees away from identified buffered populations. Limit operations in buffered population areas to hand and/or non-ground disturbing mechanical equipment. Unless identified as a fuel hazard, trees felled in buffered areas would be left on site Do not place or burn slash piles or broadcast burn slash in buffered areas. Keep all slash out of perennial and intermittent stream courses, and all riparian areas and wetlands. Do not accumulate slash in ephemeral stream courses. Landings should be located in upland areas to minimize the potential for slash piles and burning of slash to affect protected stream courses.

Affected Environment Elevation in the project area ranges from 8,600 to 11,600 feet. Area vegetation is comprised of lodgepole pine, aspen, and shrub communities in the lower and mid elevations, with Engelmann spruce-subalpine fir forests in the upper elevations. Spruce–fir is also present in the drainages and north slopes in the lower elevations. There are many mixed species stands in the area. Understory vegetation is a mix of forbs, grasses, and shrubs. Some stands also have an understory of fir with some spruce and lodgepole pine.. No calcareous or carbonate materials are known to occur in the analysis area. Field Reconnaissance In 2014, 940 acres of the project area were surveyed. These surveys targeted suitable sensitive plant habitats and wetlands within and adjacent to proposed timber and fuel treatment units. An additional 1,563 acres of habitat in the project area have been surveyed as part of other projects including Forest- wide Hazard Tree removal. Records from these prior surveys are included in this analysis.

All surveys discussed in this document follow the NRIS protocol. In most cases, reconnaissance efforts consist of a pre-field review and a field survey and surveys were conducted at a time when the presence of the greatest number (most but not all) of sensitive plant species could be determined and additional time was spent searching in areas of past species occurrences.

Threatened and Endangered Plant Species The U.S. Fish and Wildlife Service updates the list of threatened and endangered species by county monthly on the online Species by County Reports. This list was used to determine that no federally Threatened, Endangered or Proposed (TES) plant species or designated critical habitat occur in the analysis area (USFWS 2015).

Table 2 identifies threatened, endangered, and proposed plant species that may have suitable habitat in the analysis area or are located downstream of the project and could potentially be affected. This table also documents the rationale for excluding a species. If suitable but unoccupied habitat is present, then additional survey is needed, or presence can be assumed and potential effects evaluated.

Table 2. Threatened, Endangered and Proposed Species Considered and Evaluated SPECIES COMMON RATIONALE CONSERVATION POTENTIAL BRIEF HABITAT AND RANGE AND SCIENTIFIC 1 FOR STATUS TO OCCUR? 2 DESCRIPTION NAME EXCLUSION Highly seleniferous, greyish ELEV, brown soils from shales of the Osterhout milkvetch E No Niobrara, Pierre, and Astragalus osterhouti HAB Troublesome formations. Elev. 7400-7900 ft. Occurs on unplowed, calcareous prairies and sedge meadows often associated with the Platte Western Prairie River. Known from tall grass ELEV, prairie areas in Nebraska and Fringed Orchid T No east, may be affected by water RANGE Platanthera praeclara depletions of the Platte River in WY and CO (USFWS 2011c, NatureServe 2012). Water- related, but no water manipulations in this project. 1 Status Codes (USFWS 2012): E=federally listed endangered; T=federally listed threatened; P=federally proposed/candidate for listing

2 Exclusion Rationale Codes: HAB= no habitat present in Analysis Area; ELEV= outside elevational range of species; RANGE= outside distributional range of species; ODR= outside known distributional range of species

There are no threatened, endangered or proposed species, designated critical habitat, or suitable in the action area and neither alternative includes depletion to the Platte River watershed. No federally listed Threatened, Endangered or Proposed (TES) plant species or habitats were expected or found in the project area. Therefore no consultation with the US Fish and Wildlife Service has been initiated for the proposed action, no further analysis is needed, and a determination of no effect can be made for the species listed above.

Consultation To Date No consultation with the US Fish and Wildlife Service has been conducted to date for federally listed plants on this project.

Sensitive Species Considered in the Analysis The 2013 Region 2 Sensitive Species List consists of 88 species, of which 33 are known or suspected to occur on the Routt National Forest. Based on the pre-field review 23 species have potential to occur within the project area. Surveys detected presence for one R2 sensitive species, lesser panicled sedge (Carex diandra). Presence of triangleglobe moonwort (Botrychium ascendens) and narrowleaf moonwort (B. lineare) cannot reasonably be determined during surveys and will therefore be carried forward in the analysis (R2 FSM 2672.43). Suitable habitat exists for additional species. Species evaluated in this analysis are summarized in Table 3.

No further analysis is needed for species that are not known or suspected to occur in the project area, and for which no suitable habitat is present. Table 3 documents the rationale for excluding a species. If suitable but unoccupied habitat is present, then potential effects are evaluated.

Species of Local Concern (SoLC) Based on the pre-field review and field survey 62 SoLC species had potential habitat. Surveys detected three species in the project area: Richardson’s needlegrass Achnatherum richardsonii, Stiff clubmoss (Lycopodium annotinum)and Sagebrush beardtongue (Penstemon cyanthophorus). Presence of several Botrychium species were detected but have not yet be positively identified to species. Because presence of eight Botrychium species generally cannot reasonably be determined during surveys, species will also be carried forward in the analysis (R2 FSM 2672.43). No further analysis is given for species not known to occur in the project area. Species evaluated in this analysis are summarized in Table 4.

Table 3. Region 2 Sensitive Plant Species Considered and Evaluated.

Conservation Potential Rational for Effects Analysis Species Common and Scientific Name Status (CO) to occur? Exclusion Brief Habitat Description Habitat Group Siberian sea thrift G5/S1 No HAB, ELEV Occurs in moist alpine habitats. 11,900-13,000 ft. Armeria maritime ssp. siberica Park milkvetch Occurs in hummocky willow cars and sedge-grass transition to G4/S2 Yes Wetlands Astragalus leptaleus shrub. 8,800 ft. Trianglelobe moonwort Occurs in meadows, roadsides, ravines in gravel and litter with G3/S1 Yes Terrestrial-M Botrychium ascendens other Botrychium spp. 7,000-15,000 ft. Narrowleaf grapefern Occurs in stream edges, forest edges, and upland habitats. Up G2G3/S2S3 Yes Terrestrial-M Botrychium lineare (B. furcatum) to 10,500 ft. Peculiar moonwort G3G4/S1 No ELEV Occurs on streamsides and LPP forests. 6,400-7,700 ft. Botrychium paradoxum Lesser panicled sedge Yes- Occurs in floating & non floating peatland-fens and pond G5/S1 Wetland Carex diandra Found edges. 6,100-8,600 ft. Documented in Project Area. Livid sedge G5/S1 Yes Occurs on floating mats, bogs, fens, and marls. 9,000-10,000 ft. Wetland Carex livida Clawless draba G2/S2 Yes Rocky, gravelly slopes and talus 10,000 -15,000 ft. Terrestrial-E Draba exunguiculata Lesser yellow lady’s slipper orchid G5/S2 No ELEV Damp mossy woods along streams and bogs. 4,000-6,400 ft. Cypripedium parviflorum Gray's draba G2/S2 Yes Rocky, gravelly slopes and talus 10,000 -15,000 ft. Terrestrial-E Draba grayana Roundleaf sundew G5/S2 Yes Acid fens and floating mats. 9,100-9,800 ft. Wetlands Drosera rotundifolia Dropleaf buckwheat G3/S2 Yes Occurs in sparse bunchgrass communities. 6,100-8,600 ft Terrestrial-E Eriogonum exilifolium Whitebristle cottongrass Occurs in fens, saturated sedge meadows and willow carrs. G4?T3T4/S3 Yes Wetlands Eriophorum altaicum var. neogaeum 9.500-14,000 ft. Slender cottongrass Occurs in fens, saturated sedge meadows and willow carrs, near G5/S1S2 Yes Wetlands Eriophorum gracile aspen stands. 6,900-10,500 ft. Plains rough fescue Occurs on sloped montane meadows and forest edges. 6,800- G4/S1 Yes Terrestrial-M Festuca hallii 11,000 ft. Rabbit Ears gilia Occues in openings in conifer forest slopes, ridges. Known G5T2 Yes Terrestrial-M Ipomopsis aggregata ssp. weberi from Parks Range. 7,200-10,000. Simple bog sedge G5/S2 Yes Calcareous peatlands. 8,970-12,800 ft. Wetlands Kobresia simpliciuscula Colorado tansyaster Occurs in sparse, gravelly mountain parks and on dry alpine G3/S3 Yes Terrestrial-E Machaeranthera coloradoensis tundra. 8,400- 12,500. White adder's-mouth orchid G4Q/S1 No ELEV Shaded streamsides, mossy wet areas. 7200-8000 ft. Malaxis brachypoda Rocky Mountain monkeyflower Occurs on wet rocky outcrops and scree in subalpine spruce-fir G1/S1 Yes Terrestrial-E Mimulus gemmiparus and aspen. 8,500-10,500 ft. Kotzebue's grass of Parnassus G5/S2 No HAB Occurs on subalpine and wet rocky ledges. 10,000-12,000 ft. Parnassia kotzebuei Harrington's beardtongue Occurs on open sagebrush slopes calcareous soils. CO endemic. G3/S3 Yes Terrestrial-M Penstemon harringtonii 6,800-9,200 ft. Rock cinquefoil Occurs on granitic outcrops and gravel. Associated with G2/S2 No HAB Potentilla rupincola ponderoa and limber pines. 6,900-10,500 ft. Ice cold buttercup Occurs on ridgetops and peaks, in rocks and scree. 10,000- NR Yes Wetlands Ranunculus karelinii 14,100 Occurs under moderately dense canopies of spruce/fir & Dwarf raspberry NR Yes Terrestrial-F lodgepole pine, occasionally on the edges of riparian areas and Conservation Potential Rational for Effects Analysis Species Common and Scientific Name Status (CO) to occur? Exclusion Brief Habitat Description Habitat Group Rubus arcticus ssp. acaulis other willow dominated wetlands. 7,000-10,000 ft. Sageleaf willow Occurs in fens and seeps in cool, boreal forests. 6,600-10,600 G5/S2 Yes Wetlands Salix candida ft. Autumn willow Occurs in calcareous fens and saturated meadows in crystalline G4/S1 No HAB Salix serissima mid-elevation forests. 7,800-9,300 ft. Club spikemoss Occurs on mossy banks, wet meadows, marshy places, beaver NR Yes Aquatic Selaginella selaginoides ponds, wet spruce forests. Up to 9,500 ft. Sphagnum G5/S2 Yes Occurs in acid fens, floating mats. 7,000- 12,000 ft. Wetlands Sphagnum angustifolium Occurs on iron fens, wetter areas of ombrotrophic bogs and Baltic sphagnum G4/S1 No HAB Sphagnum balticum ditches 7,000-12,000 ft. Largeflower tritellia Occurs in grassy areas in sagebrush at edge of aspen, lodgepole G4/S1 No ELEV Tritellia grandiflora pine forests. 4,600-8,000 ft. Lesser bladderwort Occurs in shallow waters of fens and freshwater wetland. 6,600 G5/S2 No ELEV Utricularia minor to 8,600 ft. Selkirk's violet Moist, shaded ravines and cold boreal and hardwood forest G5/S1 Yes Terrestrial-F Viola selkirkii habitats. 8,500-9,100 ft.

Table 4. Species of local concern considered in this analysis. Conservation Effects Analysis Species Common and Scientific Name Status (CO) Habitat Group Richardson’s needlegrass (Achnatherum richardsonii) G5/S1 Terrestrial-M Reflected moonwort (Botrychium echo) G4/S3S4 Terrestrial-M Western moonwort (B. hesperium) G4/S3 Terrestrial-M Lanceleaf moonwort (B. lanceolatum) G4G5/S3 Terrestrial-M Common moonwort (B. lunaria) NR Terrestrial-M Mingan moonwort (B. minganense) G4G5/S3 Terrestrial-M Leathery grapefern (B. multifidum) G5/S1S2 Terrestrial-M Pale moonwort (B. pallidum) NR Terrestrial-M Northern moonwort (B. pinnatum) G4/S2 Terrestrial-M Little grapefern (B. simplex) G5/S2 Terrestrial-M Stiff clubmoss (Lycopodium annotinum) NR Wetlands Sagebrush beardtongue (Penstemon cyanthophorus) G3/S3 Terrestrial-M White-veined wintergreen (Pyrola picta) G4G5/S4 Terrestrial-F

Effects to Species Evaluated No Threatened or Endangered species are carried forth in the analysis. Thus, the following effects section applies only to Forest Service R2 sensitive species and species of local concern. This analysis discusses effects by habitat groups. Habitat groups are identified for each species in Table 3 and Table 4. Alternative 1 - No Action

Direct Effects to Plant Species Evaluated High mortality of trees is expected to continue for the duration of the mountain pine beetle (MPB) infestation. Species analyzed in this report would continue to experience any current levels of disturbance. In forested habitats (Terrestrial-F), the possibility of dead trees falling and crushing individuals or populations may increase as a function of time following individual tree mortality.

Indirect Effects to Terrestrial Species Evaluated Under the No Action Alternative, vegetation treatments and other actions would not occur. Tree mortality would continue to increase fuel loads, thus increasing potential for high intensity and high severity wildfire, whether the result of the MPB epidemic (Lynch et al. 2006; Romme et al. 2007), or stand-replacing fires typical for these forest types (Jenkins et al. 2008). In some areas, these fires could possibly create or improve habitat for select plant species by opening up meadows or reducing the litter accumulation and competition from other plants or by increasing water yield. In other areas, wildfires or controlled fires would create high ground temperatures that could sterilize the soil and eliminate fungal species that are necessary for the survival of others, such as moonworts (Botrychium spp.). Species likely to experience these effects are in terrestrial groups ‘F’ and ‘M’. Species in group ‘Terrestrial-E’ are unlikely to experience these effects because they occur in areas that do not ‘carry’ fire and are unlikely to burn.

Indirect Effects to Wetland & Aquatic Species Evaluated Increased run-off has been predicted to occur as a result of the MPB epidemic. Fens, riparian areas and other wetlands are sensitive to any kind of perturbations, especially those that would alter their hydrologic regime (Gage & Cooper 2006a,b). Because dead trees would contine to intercept some moisture until they fall naturally, the increased run-off may be reduced or delayed (Uunila et al. 2006). Wetland and aquatic group species are most likely to experience these effects.

Alternative 2 - Proposed Action

Direct Effects to Terrestrial Plant Species Evaluated Direct effects included trampling of individuals resulting in breaking, crushing and/or uprooting individuals. Individuals may be covered or smothered by slash, chips, or soil and may have trees fallen over them. These impacts can physically damage individuals, populations, and/or the habitat where they grow. This may reduce growth, development and/or seed set. Such impacts may also cause mortality of individuals. These impacts to individual plants can reduce population size, change metapopulation structure, and potentially affect viability of the species on the planning unit or across the species’ range. Species identified in Table 3 and Table 4Table 4 in the groups Terrestrial-M and Terrestrial-F may experiencethese direct impacts because they may occur in units proposed for timber or fuels reduction treatments. Likelihood of impacts occurring to species occurring in proposed activity units have been reduced through design criteria.

Species identified in Table 3 andTable 4Table 4 in Terrestrial-E occur in habitats that occur in the project area, but not in any proposed activity units. No direct impacts are expected for these species.

Direct Effects to All Wetland & Aquatic Plant Species Evaluated Owing to the terrestrial nature of the proposed activities, no direct effects to these species are expected. Design criteria restrict activities in these habitats.

Indirect Effects to Terrestrial Species Evaluated Indirect effects generally occur later in time (after the action has been completed) and result from changes made to the habitat. Habitat modifications may cause shifts in hydrologic, solar, and soil characteristics of rare plant habitats, and may also impact pollinators or mycorrhizae associated with rare plant species. Alteration of vegetation structure is a significant component of several specific treatments in the proposed action. Removal of overstory trees increases solar radiation at the ground and can cause sites to become warmer and drier. Effects of dropping, lopping and scattering these materials is less clear and varies with the amount of slash left on the ground. Light amounts of slash may create warmer, drier conditions while heavier amounts of slash may create shading that increases microsite moisture and humidity.

These management activities may have a beneficial effect for species that prefer more open, non-forested conditions. However, long-term beneficial indirect effects may be overcome by trampling, excessive soil disturbance, and noxious weed introduction and spread. In contrast, species that inhabit interior forest sites are adapted to closed canopy forests and low light conditions typically thrive in cool, moist and shaded conditions. Changing the vegetation structure to more open, warmer, and drier conditions could be detrimental to these species. Furthermore, many of these species have complex mycorrhizal associations. Mycorrhizae require organic matter found in the duff layer, and mechanical treatment is likely to disturb and disrupt the duff layer.

Following timber harvest, some units may require site preparation in order to achieve higher regeneration rates and stocking densities for species like lodgepole pine. Site preparation removes all exisiting vegetatation in order to expose mineral soil. In many units this may extirpate white-veined wintergreen populations.

At the landscape scale, this alternative would reduce fuel loads and therefore, reduce the risk of a high severity fire. For this reason, this alternative would have the lowest potential for irreversible and irretrievable effects from a major wildfire.

However, the proposed management activities may alter the distribution, quantities and qualities of the fuel loads thereby changing fire severity in local areas. Areas that have recently been treated with “drop, lop, and scatter” may burn more readily and with higher intensity due to the large amounts of fine fuels. Areas with thick layers of jackstrawed timber, once ignited would also likely result in high severity burns. Increased fire intensity would likely extirpate species in high severity fires (Busse et al. 2005).

Little published research exists on the effects of fuel treatements on understory vegetatioin. Research from the USFS Experimental Forests has found that the mechanical treatments (including mastication) combined with prescribed fire significantly decreased native species richness (Collins et al. 2007) and increased both richness and cover of exotic species (Collins et al. 2007; Metlen & Fiedler, 2006). Although small, these differences may increase over time (Collins et al. 2007; Metlen & Fiedler, 2006)

The fuel loading would be lower under this alternative; therefore, the risk of a high severity wildfire would also be lower under this alternative. For this reason, this alternative would have the lowest potential for irreversible and irretrievable effects from a major wildfire. However, areas that have recently

11 been treated with “drop, lop, and scatter” may burn more readily and with higher intensity due to the large amounts of fine fuels. Areas with thick layers of jackstrawed timber, once ignited would also likely result in high severity burns. Increased fire intensity would likely extirpate species in high severity fires (Busse et al. 2005).

Moderate to low-intensity burns alone are not thought to provide the magnitude of disturbance necessary for exotic species invations (Collins et al. 2007; Knapp et al, 2007), but do seem to decrease native species diversity (Collins et al. 2007) at least temporarily (Metlen & Fiedler, 2006). However, Collins et al. (2007) found prescribed fire treatments substantially reduced white-veined wintergreen (Pyrola picta).

Introduction of invasive plant species poses a negative impact to all species (and their habitats) evaluated in this report. Noxious weeds can lead to detrimental habitat changes. Noxious weeds can indirectly impact rare plant species through alloelopathy (the production and release of plant compounds that inhibit the growth of other plants) (Ridenour & Callaway 2001), changing fire regimes, and direct competition for light, nutrients, or water. Subsequent weed control efforts (hand pulling, hoeing, mowing, or herbicide application) could also negatively impact rare plant species by uprooting, clipping, or killing them.

Changes in hydrologic function could potentially impact species inhabiting wet or mesic habitats such as ponds, fens, or other wetlands. Heavy soil disturbance exacerbates soil erosion and sedimentation. A more open environment with increased runoff could increase upland erosion and stream peak flows. Increased stream flows result in stream down-cutting and the subsequent drying of adjacent areas. Sedimentation affects seed germination and recruitment.

Use of heavy machinery may result in several impacts to soils including increased soil compaction (particularly wet soils) and creating ground disturbances that result in erosion. Soil compaction hampers seedling emergence. Erosion removes nutrients, and exposes lower soil horizons which are unsuitable for colonization by most rare species. These soil disturbances will likely be detrimental to mycorrhizal relationships needed by some rare plant species (Goss & Varennes 2002).

Opening the forest canopy can alter forage condition and quality, leading livestock and wildlife to alter foraging behavior. Opening the forest canopy can result in increased forage and result in more intense use of the area. Rare species may be impacted by livestock and wildlife as they graze in or travel to the corridor.

Some species, such as moonworts, rely on light disturbance. Disturbances and land management activities may create and maintain suitable habitat for these species or may negatively impact existing populations depending on the disturbance timing, intensity and frequency (Beatty et al. 2003, Muller 2000, Zika et al. 1995). However, significant ground disturbance may damage above- and/or below-ground growth. And also negatively affect mycorrhizal relationships necessary during all stages of moonwort life cycle (Vanderhorst 1997).

Decomissioning of 7.1 miles of road would create plant habitat that especially favors moonworts (Botrychium spp.) and may known populations currently bisected by NFSR 708.1 to expand. The proposed meadow restoration work may also create habitat for moonworts.

These effects apply to species is terrestrial groups M and F. No effects are expected for species in terrestrial group E because the habitat does not occur in any areas proposed for activities.

Indirect Impacts to All Wetland & Aquatic Species Evaluated Wetland and aquatic species covered in this analysis may be impacted by activities that result in altered hydrology, increased sedimentation, or introductions of non-native native species. Cumulative Impacts to All Plant Species Evaluated Because no Threatened or Endangered species are analyzed in the document, ESA cumulative effects are not evaluated. Cumulative impacts, as define by NEPA are discussed below.

Numerous past and on-going activities within the project area have resulted in the current conditions. These activities include vegetation management projects, recreational use and the creation and maintenance of an extensive road system. Creation of new roads in the area is current and on-going, primarily the result of unmanaged, illegal recreation activity by off-road vehicle users. Other activities include: livestock grazing, timber harvest and thinning, insect and disease outbreaks, fire suppression, prescribed fire, mining, motorized and non-motorized recreational use, road construction, urban development (sub-dividing and development of private land), and noxious weed infestation.

Current management direction is designed to eliminate or reduce negative cumulative impacts by protecting TES plant species from direct and indirect impacts. It is difficult to determine if the current condition of plant habitats and the projected changes due to management activities are with the natural variability over time because long-term data are usually lacking, and many TES plant habitats have a long history of disturbance (i.e. an undisturbed reference is often lacking). For some species, particularly those that do not tolerate disturbance or are found under dense canopy conditions, minimizing on-site changes to TES plants is an effective way of reducing cumulative impacts. Even though the cumulative effects analysis for TES plants is hampered by the absence of historic data and the lack of an undisturbed reference, cumulative effects may be minimized by reducing the local (direct and indirect) effects. For other species, particularly those that are disturbance tolerators or fire-followers, minimizing on-site changes can be detrimental. These species tolerate or benefit from on-site changes, which result in opening the stand, reducing the potential for catastrophic fire, and increasing light reception in the understory. Thus, the response to the management activities is species-dependent.

If adverse effects are not minimized at the local level, cumulative effects may result. Past and present forest management activities have caused changes in plant community structure and composition across the forests. These management activities have altered the present landscape to various degrees and have had direct, indirect, and possibly cumulative effects on these plant species. These effects can be minimized by implementing integrated design features or mitigation measures to monitor or offset impacts to these plant species. With these protective measures in place, cumulative effects are less likely to occur.

For these plant species analyzed in this document, historical population data is unavailable. It is unknown whether these species have always been rare or if management activities have made them less common across the landscape due to cumulative effects. By performing botanical surveys and protecting or enhancing known populations of these species, cumulative effects will be minimized.

The actions and effects described above can be both additive and interactive to each other and to the direct and indirect effects described above. Because there are policies, standards and guidelines that limit effects to their habitat, the cumulative effects are not expected contribute to any change in status or viability. Also, the cumulative effects are not expected contribute to an increase in any current or predicted downward trend in population numbers or density or to current or predicted downward trends in habitat capability that would reduce the existing distribution of any of the R2 sensitive plant species carried forward into this analysis.

Determinations and Rationales These determinations assume the alternative adheres to the design criteria presented in this analysis. Determinations are summarized in Table 5Error! Reference source not found. and Table 6. Rationale for determinations follows the tables.

Table 5: Determination and rational for R2 Sensitive Species. SPECIES COMMON Alt 2- SPECIES COMMON Alt 2- Alt 1- No Alt 1- No AND SCIENTIFIC Proposed AND SCIENTIFIC Proposed Action Action NAME Action NAME Action Park milkvetch Ipomopsis aggregata ssp. NI-1 NI-1 Astragalus leptaleus weberi Trianglelobe moonwort Simple bog sedge NI-1 BI NI-1 NI-1 Botrychium ascendens Kobresia simpliciuscula Narrowleaf grapefern Colorado tansyaster NI-1 BI Botrychium lineare Machaeranthera NI-1 NI-1 Lesser panicled sedge coloradoensis NI-1 MAII Carex diandra Rocky Mountain Livid sedge monkeyflower NI-1 NI-1 NI-1 NI-2 Carex livida Mimulus gemmiparus Clawless draba Harrington's beardtongue NI-1 NI-1 NI-1 MAII Draba exunguiculata Penstemon harringtonii Gray's draba Ice cold buttercup NI-1 NI-1 NI-1 NI-1 Draba grayana Ranunculus karelinii Roundleaf sundew Dwarf raspberry NI-1 NI-2 NI-1 MAII Drosera rotundifolia Rubus arcticus ssp. acaulis Dropleaf buckwheat Sageleaf willow NI-1 NI-1 NI-1 NI-2 Eriogonum exilifolium Salix candida Whitebristle cottongrass Club spikemoss NI-1 NI-2 Eriophorum altaicum var. NI-1 NI-2 Selaginella selaginoides neogaeum Sphagnum NI-1 NI-2 Slender cottongrass Sphagnum angustifolium NI-1 NI-2 Eriophorum gracile Selkirk's violet NI-1 MAII Plains rough fescue Viola selkirkii NI-1 NI-1 Festuca hallii Scarlet gilia NI-1 MAII

Table 6: Determination and rationale for species of local concern.

Common name Species Alternative 1 Alternative 2 Richardson’s needlegrass Achnatherum richardsonii NI-1 MAII reflected grapefern Botrychium echo NI-1 BI western moonwort Botrychium hesperium NI-1 BI lanceleaf grapefern Botrychium lanceolatum NI-1 BI common moonwort Botrychium lunaria NI-1 BI Mingan moonwort Botrychium minganense NI-1 BI leathery grapefern Botrychium multifidum NI-1 BI pale botrychium Botrychium pallidum NI-1 BI northern moonwort Botrychium pinnatum NI-1 BI little grapefern Botrychium simplex NI-1 BI Stiff clubmoss Lycopodium annotinum NI-1 NI-2 Sagebrush beardtongue Penstemon cyanthophorus NI-1 BI White-veined wintergreen Pyrola picta NI-1 MAII

Alternative 1: No Action A determination of “No Impact” (NI-1) was made for all evaluatedspecies because lack of action will not impact species except under extreme and unlikely scenarios.

Alternative 2: Proposed Action A determination of “No Impact” (NI-1) was made for nine R2 Sensitive Species because the action will not impact species except under extreme and unlikely scenarios.

A determination of “No Impact” (NI-2) was made for seven R2 Sensitive Species and one Species of Local Concern because design features protect known populations and habitats within and adjacent to treatment units from all anticipated impacts

A determination of MAII was five R2 Sensitive Species and two Species of Local Concern because although design criteria are in place to protect individuals and populations, indirect effects of activities may result in loss of individuals or populations.

A determination of BI was two R2 Sensitive Species and ten Species of Local Concern (all Botrychium species) because these species would benefit from road decommissioning.

References Beatty, B.L., W.F. Jennings, & Rawlinson. R.C 2003. Botrychium ascendens W.H. Wagner (trianglelobe moonwort), B. crenulatum W.H. Wagner (scalloped moonwort), and B. lineare W.H. Wagner (narrowleaf grapefern): a technical conservation assessment. [Online]. USDA Forest Service, Rocky Mountain Region. Available: http://www.fs.fed.us/r2/projects/scp/assessments/botrychiums.pdf [Jan 28, 2008]. Busse, M.D., K.R. Hubbert, G.O. Fiddler, C.J. Shestack, and R.F. Powers. 2005. Lethal Soil Temperatures During Burning of Masticated Forest Residues. International Journal of Wildland Fire 14:267-276. Collins, B.M., J.J. Moghaddas, and S.L. Stephens. 2007. Initial changes in forest structure and understory plant communities following fuel reduction activities in a Sierra Nevada mixed conifer forest. Forest Ecology and Management 239:102-111. Gage, E. and D.J. Cooper. 2006a. Carex livida L. (livid sedge): a technical conservation assessment. [Online]. USDA Forest Service, Rocky Mountain Region. Available at: http://www.fs.fed.us/r2/projects/scp/assessments/carexlivida.pdf Gage, E. and D.J. Cooper. 2006b. Drosera rotundifolia L. (roundleaf sundew): a technical conservation assessment. [Online]. USDA Forest Service, Rocky Mountain Region. Available at : http://www.fs.fed.us/r2/projects/scp/assessments/droserarotundifolia.pdf Goss M.J., De Varennes A., 2002, Soil disturbance reduces the efficacy of mycorrhizal associations for early soybean growth and N2 fixation, Soil Biology and Biochemistry, 34 (8), pp. 1167-1173. Jenkins, M.J., E. Hebertson, W. Page, and C.A. Jorgensen. 2008. Bark beetles, fuels, fires and implications for forest management in the Intermountain West. Forest Ecology and Management 254:16-34. Knapp, E.E., D.W. Schwilk, J.M. Kane, and J.E. Keeley. 2007. Role of burning season on initial understory vegetation response to prescribed fire in a mixed conifer forest. Canadian Journal of Forest Research 37:11-22. Lynch, H.J., R.A. Renkin, R.L. Crabtree, and P.R.Moorcroft. 2006. The Influence of a Previous Mountain Pine Beetle (Dendroctonus ponderosae) Activity on the 1988 Yellowstone Fires. Ecosystems 9:1318 – 1327. Metlen, K.L. and C.E. Fiedler. 2006. Restoration treatment effects on the understory of ponderosa pine/Douglas-fir forests in western Montana, USA. Forest Ecologly Management 222:355-369. Muller, S. 2000. Assessing occurrence and habitat of Ophioglossum vulgatum L. and other Ophioglossaceae in European forests. Significance for nature conservation. Biodiversity and Conservation 9: 673-681. Ridenour, W.M., Callaway, R.M. 2001. The relative importance of allelopathy in interference: the effects of an invasive weed on a native bunchgrass. Oecologia 126:444–450 Romme, W. H., J. Clement, J. Hicke, D. Kulakowski, L. H. MacDonald, T. L. Schoennagel, and T. T. Veblen. 2007. Recent Forest Insect Outbreaks and Fire Risk in Colorado Forests: A Brief Synthesis of Relevant Research.

Colorado Forest Restoration Institute Publication:24 ppU.S. Fish and Wildlife Service. 2015. Slackweiss Official Species List. January 20, 2015. Consultation Tracking Number: 06E24100-2015-SLI-0055. Uunila, L., B. Guy, and R. Pike. 2006. Hydrologic Effects of Mountain Pine Beetle in the Interior Pine Forests of British Columbia: Key Questions and Current Knowledge. Streamline Watershed Management Bulletin Vol. 9 No. 2 Spring 2006. FORREX Forest Research Extension Partnership. Kamloops, BC 6 pp. Vanderhorst, J. 1997. Conservation Assessment of Sensitive Moonworts (Ophioglossaceae; Botrychium Subgenus Botrychium) on the Kootenai National Forest. Agreement No. 11011454002, report prepared for: Kootenai National Forest Supervisors Office, Libby, MT. Available at: http://nhp.nris.state.mt.us/plants/reports/botry.pdf [11/11/05]. Zika, P.F., R. Brainerd and B. Newhouse. 1995. Grapeferns and moonworts (Botrychium, Ophioglossaceae) in the Columbia Basin. A report submitted to the Eastside Ecosystem Management Project, U.S. Forest Service Walla Walla, Washington. 126 pages. Available at: http://icbemp.gov/science/scirpt.html.