Revision of the Inyo, Sequoia, and Sierra National Forests Land Management Plans

Draft Biological Evaluation for Sensitive Report

Developed for the Draft Environmental Impact Statement

Prepared by: Michele Slaton Botanist

for: the Inyo, Sequoia, and Sierra National Forests

5/24/2016

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Draft Biological Evaluation for Sensitive Plants

Introduction The purpose of this document is to analyze the potential effects of the proposed revised land management plans for the Inyo, Sequoia, and Sierra National Forests on species listed as sensitive by the Regional Forester of the Pacific Southwest Region of the U.S. Forest Service. This biological evaluation will determine whether or not the proposed plans will result in a trend toward Federal listing or a loss of viability for sensitive plant species. The Forest Service is directed by Forest Service Manual 2672.4 to complete a biological evaluation for all Forest Service planned, funded, executed or permitted programs and activities.

Effects to threatened, endangered, and proposed species were analyzed in the Biological Assessment, with determinations given there and summarized in the draft environmental impact statement for the revised forest plans. Threatened, endangered, and proposed plant species will not be discussed further in this document.

Current Management Direction Project Area The forests are currently being managed under the 1988 Land and Resource Management Plan (Inyo Forest Plan), the 1988 Sequoia National Forest Land and Resource Management Plan (Sequoia Forest Plan), and the 1992 Sierra National Forest Land and Resource Management Plan (Sierra Forest Plan), plus amendments to each of these plans, including the 2001 and 2004 Forest Plan amendments. These plans include management prescriptions, standards and guidelines, and other plan components that apply to all activities on the three national forests. Sensitive Species Sensitive species are designated by the Regional Forester of the Pacific Southwest Region. The most recent update to the Regional Forester's sensitive plant species list was formalized on July 3, 2013 (USDA Forest Service, 2013). United States Department of Agriculture Regulation 9500-4 directs the Forest Service to avoid actions which may cause a sensitive species to become threatened or endangered (Forest Service Manual 2670.12, Forest Service Manual 2670.22) (USDA Forest Service, 2005). Populations of all sensitive species of wildlife, fish, and plants must be maintained at viable levels in habitats distributed throughout their geographic range on National Forest System lands (Forest Service Manual 2670.22). Forest Service Handbook 2609.26, Chapter 10, provides detailed direction on management and conservation of sensitive plant species (USDA Forest Service 2014).

Standards and guidelines of the Inyo National Forest, as stated in the Inyo Forest Plan, require the development and implementation of a consistent, systematic, biologically sound strategy to manage sensitive species and their habitats so that federal listing does not occur (USDA Forest Service, 1988a). For the Sequoia National Forest, standards and guidelines from the Sequoia Forest Plan require that sensitive plants be conserved (USDA Forest Service, 1988b). The Sierra Forest Plan, under goals and objectives, directs that habitat for sensitive fish, wildlife, and plant species be managed in a manner that prevents any species from becoming a candidate for threatened or endangered status. Standards and guidelines in the Sierra Forest Plan state that the Sierra National Forest is to manage sensitive plant species to avoid future federal listing, to ensure maintenance of genetic and geographic diversity and viable populations of sensitive plants; and to develop sensitive plant species management guides to

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identify populations goals and compatible management activities that will maintain viability (USDA Forest Service, 1992).

For all three national forests, the Sierra Nevada Forest Plan Amendment 2004 Record of Decision includes a standard and guideline requiring that field surveys for threatened, endangered, proposed, and sensitive plant species be conducted early enough in the project planning process that the project can be designed to conserve or enhance these plants or their habitat.

Additional management direction for sensitive plants on the Inyo is described in the Inyo National Forest Sensitive Plant Management Plan (USDA Forest Service, 1991). The Sensitive Plant Management Plan states that District and Forest activities will not disturb any plant population or part of a sensitive plant's essential habitat until its status is determined through a biological evaluation. After an evaluation is completed, no action will be taken that will cause a population to fall below the number of individuals necessary to maintain a viable population.

Description of Proposed Action The Inyo, Sequoia, and Sierra National Forests encompass nearly 4.6 million acres of National Forest System lands located at the southernmost extent of the Sierra Nevada mountain range. Every national forest managed by the Forest Service is required to have a land management plan (forest plan) that is consistent with the National Forest Management Act of 1976. The three Forests are currently managed under land management plans identified in the section above. The three southern Sierra Nevada national forests began efforts to revise their forest plans in 2012 as part of a set of “early adopters” of the newly approved 2012 planning regulations (36 CFR 219, 2012).

The Inyo, Sequoia, and Sierra National Forests are revising their existing forest plans to meet the legal requirements of the National Forest Management Act of 1976; to address changed conditions and provide consistent management direction (as appropriate) across the three national forests; to incorporate changes in law, regulation, and policy; and to use new scientific information. The general objectives of the revised land management plans are to develop a fully integrated plan to guide the management of land and resources of the plan area, and to display short- and long-term management intent for the plan area to the public, Federal, State, Tribal, and local governments (Forest Service Manual 1920.2).

Three revision topics areas were originally identified to address in revising the forest plans: fire management, ecological integrity, and sustainable recreation and designated areas. Following distribution of the proposed action, the following issues were developed to respond to public concerns, resulting in a revised list of topics:

1. Ecological Resilience, Wildlife Habitat, and Wildfire 2. Forest Resilience and Forest Density 3. Fuels Treatments and Fire Management 4. Watershed Restoration 5. Protecting Aquatic Diversity 6. Recommended Wilderness Plan components, including desired conditions, and standards and guidelines were developed giving consideration to each of these issues. Because each has a potential tie to the viability of sensitive species, this biological evaluation evaluated several pieces of coarse scale and fine scale plan direction that may

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affect these species. A full description of the proposed action and alternatives can be found in the draft environmental impact statement and draft forest plans for the Inyo, Sequoia, and Sierra National Forests. Further detail on plan components most directly linked to the viability of plant species is given in the Botany Specialist Report that accompanies the draft environmental impact statement and draft plans.

Affected Environment General The flora of the planning area is notably diverse, reflecting the area’s complex geology, topography, and climate. The close juxtaposition of such variable habitats has created opportunities for genetic isolation and subsequent evolution. As a result, the area has an exceptionally high level of endemism relative to other regions of the United States (CNPS 2015). The planning area is situated at the intersection of ’s three major floristic provinces (Baldwin et al. 2012): California Floristic Province, , and Desert. Detail on these regions is provided in the draft environmental impact statement Chapter 3, At-Risk Plants, Affected Environment section.

In summary, the plan area spans a 10,000 elevation gradient on the east and west sides of the Sierra Nevada Mountain Range. The Sierra Nevada bioregion includes the Sierra Nevada Foothills subregion, which borders the Great Central Valley region to the west, and is characterized by blue-oak/foothill-pine woodlands and (Baldwin et al. 2012). The High Sierra Nevada subregion is topographically complex, with vegetation that may be dominated by ponderosa pine, mixed conifer, Jeffrey pine, red fir, lodgepole pine, mountain hemlock, whitebark pine, foxtail pine, or western white pine. Treeless alpine areas, meadows, and riparian areas, are also common. The southern High Sierra Nevada subregion supports some pinyon pine and sagebrush. In the Eastern Sierra Nevada Region, the elevation gradient is abrupt, creating rapid transitions from desert and sagebrush vegetation at the lowest elevations, to pinyon pine woodlands, coniferous forests, and alpine areas. The region includes most conifers found on the west side of the Sierra Nevada, but mixed conifer is relatively uncommon. The White and subregion is situated in the rainshadow of the Sierra Nevada, and receives less precipitation, as evident in the arid-adapted vegetation, including pinyon-juniper, mountain mahogany, sagebrush, bristlecone and limber pine, and large expanses of high alpine areas. Species Evaluated All sensitive species identified by the Regional Forester for the Inyo, Sierra, and Sequoia National Forests are listed in table 1 through table 6 (USDA Forest Service, 2013). There is a total of 139 sensitive species across all three national forests, and each species may be included on the sensitive species lists for one, two, or three forests. Sensitive species identified for a Forest were designated by the Regional Forester following direction in FSH 2609.26, Chapter 30: “the Regional Forester] must consider those species that are known, reported, or suspected to occur on, or in the immediate vicinity of National Forest System lands in the Region” (USDA Forest Service, 2014). In contrast, the 2012 planning rule directs that species of conservation concern must be documented to occur within each respective plan area. Therefore, the evaluation of actual presence of individual plants of sensitive species within each Forest was an essential part of this analysis.

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Table 1. Regional Forester sensitive species without known occurrences in the plan area for the Inyo National Forest. These species were not identified as species of conservation concern (SCC). Table includes occurrence and status notes for select species. Sensitive Species SCC Occurrence and Status Notes Botrychium paradoxum no Habitat identified on Forest in 2013 Sensitive Plant List development, but no known occurrences. Botrychium tunux no Habitat identified on Forest in 2013 Sensitive Plant List development, but no known occurrences. Botrychium yaaxudakeit no Habitat identified on Forest in 2013 Sensitive Plant List development, but no known occurrences. Cladium californicum no CNDDB polygon overlaps Forest; No plants found on Forest during 2014 and 2016 surveys in Lead and Addie Canyons, Inyo Mts. Draba asterophora var. no See Appendix I. asterophora Meesia uliginosa no Habitat identified on Forest in 2013 Sensitive Plant List development, but no known occurrences. Phacelia novenmillensis no Habitat identified on Forest in 2013 Sensitive Plant List development, but no known occurrences.

Table 2. Regional Forester sensitive species with documented occurrences in the plan area for the Inyo National Forest. Table indicates if a species is of conservation concern and includes occurrence and status notes for select species. Sensitive Species SCC Occurrence and Status Notes Abronia nana ssp. covillei no See Appendix I. Botrychium lunaria no See Appendix I. Cryptantha incana no See Appendix I. Draba cruciata no See Appendix I. Draba incrassata no See Appendix I. aequifolius no See Appendix I. Erigeron multiceps no See Appendix I. Hulsea vestita ssp. pygmaea no See Appendix I. Lupinus lepidus var. culbertsonii no See Appendix I. Peltigera gowardii no See Appendix I. Pinus albicaulis no Candidate species included as At-Risk Species, but not Species of Conservation Concern. Senecio pattersonensis no See Appendix I. Abronia alpina yes See Appendix I. Astragalus cimae var. sufflatus yes Astragalus johannis-howellii yes Astragalus lemmonii yes Astragalus lentiginosus var. yes kernensis Astragalus monoensis yes Astragalus ravenii yes Boechera bodiensis yes Boechera evadens yes Boechera pinzliae yes

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Sensitive Species SCC Occurrence and Status Notes Boechera shockleyi yes Boechera tiehmii yes Boechera tularensis yes Botrychium ascendens yes Botrychium crenulatum yes Botrychium lineare yes Botrychium minganense yes Bruchia bolanderi yes excavatus yes Calyptridium pygmaeum yes Carex tiogana yes Cordylanthus eremicus ssp. yes kernensis Cryptantha circumscissa var. yes rosulata Cryptantha roosiorum yes Dedeckera eurekensis yes Draba monoensis yes Draba sharsmithii yes Ericameria gilmanii yes Erigeron uncialis var. uncialis yes Eriogonum wrightii var. olanchense yes Helodium blandowii yes Hesperidanthus jaegeri yes Horkelia hispidula yes Hulsea brevifolia yes Lupinus duranii yes Lupinus padre-crowleyi yes Mentzelia inyoensis yes Monardella beneolens yes Petrophyton acuminatum yes (Petrophytum caespitosum ssp. acuminatum) Phacelia inyoensis yes Phacelia monoensis yes Plagiobothrys parishii yes Polemonium chartaceum yes Polyctenium fremontii (williamsiae) yes Potentilla morefieldii yes Streptanthus gracilis yes Streptanthus oliganthus yes Trifolium kingii ssp. dedeckerae yes

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Table 3. Regional Forester sensitive species without known occurrences in the plan area for the Sequoia National Forest. These species were not identified as species of conservation concern (SCC). Table includes occurrence and status notes for select species. Sensitive Species SCC Occurrence and Status Notes latimeri no Habitat identified on Forest in 2013 Sensitive Plant List development, but no known occurrences. Sidotheca caryophylloides no Habitat identified on Forest in 2013 Sensitive Plant List development, but no known occurrences. Stylocline masonii no Habitat identified on Forest in 2013 Sensitive Plant List development, but no known occurrences; see Appendix I.

Table 4. Regional Forester sensitive species with documented occurrences in the plan area for the Sequoia National Forest. Table indicates if a species is of conservation concern and includes occurrence and status notes for select species. Sensitive Species SCC Occurrence and Status Notes Calochortus palmeri var. palmeri no See Appendix I. Canbya candida no See Appendix I. Cryptantha incana no See Appendix I. Delphinium inopinum no See Appendix I. Hulsea vestita ssp. pygmaea no See Appendix I. Lupinus lepidus var. culbertsonii no See Appendix I. Mielichhoferia elongata no See Appendix I. Mimulus discolor no No longer recognized as a unique taxon; included with M. montioides in Baldwin et al. (2012) Monardella linoides ssp. oblonga no See Appendix I. Pinus albicaulis no Candidate species included as At-Risk Species, but not Species of Conservation Concern. Streptanthus gracilis no Recognized R5 Sensitive known from INF, but single record for SQF from 1970 has not been verified to occur within the administrative boundary Astragalus ertterae yes Astragalus lentiginosus var. kernensis yes Astragalus shevockii yes Boechera evadens yes Boechera shevockii yes Boechera tularensis yes Botrychium crenulatum yes Botrychium minganense yes Botrychium montanum yes Brodiaea insignis yes Bruchia bolanderi yes Calochortus striatus yes Calochortus westonii yes Calyptridium pygmaeum yes Carlquista muirii yes Cinna bolanderi yes See Appendix I.

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Sensitive Species SCC Occurrence and Status Notes Cordylanthus eremicus ssp. kernensis yes Cryptantha circumscissa var. rosulata yes Deinandra mohavensis yes Delphinium purpusii yes Dicentra nevadensis yes Draba cruciata yes See Appendix I. Dudleya cymosa ssp. costatifolia yes Eriastrum tracyi yes Erigeron aequifolius yes Erigeron multiceps yes Eriogonum breedlovei var. breedlovei yes Eriogonum nudum var. regirivum yes Eriogonum ovalifolium var. yes monarchense Eriogonum twisselmannii yes Erythronium pusaterii yes Fritillaria brandegeei yes Fritillaria striata yes Gilia yorkii yes Helodium blandowii yes Heterotheca monarchensis yes See Appendix I. Heterotheca shevockii yes Horkelia tularensis yes Hulsea brevifolia yes Iris munzii yes Leptosiphon serrulatus yes Lewisia congdonii yes Lewisia disepala yes Meesia uliginosa yes Mielichhoferia shevockii yes Mimulus gracilipes yes See Appendix I. Mimulus norrisii yes Mimulus shevockii yes Monardella beneolens yes Navarretia peninsularis yes Navarretia setiloba yes Nemacladus calcaratus yes Nemacladus twisselmannii yes Oreonana purpurascens yes Oreonana vestita yes Peltigera gowardii yes See Appendix I.

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Sensitive Species SCC Occurrence and Status Notes Petrophyton acuminatum yes (Petrophytum caespitosum ssp. acuminatum) Phacelia novenmillensis yes See Appendix I. Streptanthus cordatus var. piutensis yes Streptanthus fenestratus yes Symphyotrichum defoliatum yes Trifolium kingii ssp. dedeckerae yes

Table 5. Regional Forester sensitive species without known occurrences in the plan area for the Sierra National Forest. These species were not identified as species of conservation concern (SCC). Table includes occurrence and status notes for select species. Sensitive Species SCC Occurrence and Status Notes Botrychium lunaria (will be B. neolunaria) no Habitat identified on Forest in 2013 Sensitive Plant List development, but no known occurrences. Botrychium paradoxum no Habitat identified on Forest in 2013 Sensitive Plant List development, but no known occurrences. Botrychium tunux no Habitat identified on Forest in 2013 Sensitive Plant List development, but no known occurrences. Botrychium yaaxudakeit no Habitat identified on Forest in 2013 Sensitive Plant List development, but no known occurrences. Mimulus filicaulis no Habitat identified on Forest in 2013 Sensitive Plant List development, but no known occurrences. Mimulus pulchellus no Habitat identified on Forest in 2013 Sensitive Plant List development, but no known occurrences. Helodium blandowi no Habitat identified on Forest in 2013 Sensitive Plant List development, but no known occurrences. Petrophyton acuminatum (Petrophytum no Habitat identified on Forest in 2013 Sensitive Plant List caespitosum ssp. acuminatum) development, but no known occurrences.

Table 6. Regional Forester sensitive species with documented occurrences in the plan area for the Sierra National Forest. Table indicates if a species is of conservation concern and includes occurrence and status notes for select species. Sensitive Species SCC Occurrence and Status Notes Cinna bolanderi no See Appendix I. Erigeron aequifolius no See Appendix I. Glyceria grandis no Although there is a single occurrence within the administrative boundary, it is a historic occurrence on private land, with no status or threat information available. Heterotheca monarchensis no See Appendix I. Lupinus lepidus var. culbertsonii no See Appendix I. Mielichhoferia elongata no See Appendix I. Peltigera gowardii no See Appendix I. Pinus albicaulis no Candidate species included as At-Risk Species, but not Species of Conservation Concern. Allium yosemitense yes Boechera tularensis yes

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Sensitive Species SCC Occurrence and Status Notes Botrychium ascendens yes Botrychium crenulatum (B. lunaria yes var. crenulatum) Botrychium lineare yes Botrychium minganense yes Botrychium montanum yes Bruchia bolanderi yes Calyptridium pygmaeum yes Camissonia sierrae ssp. alticola yes Carlquistia muirii yes Carpenteria californica yes Clarkia biloba ssp. australis yes Clarkia lingulata yes Collomia rawsoniana yes Cypripedium montanum yes Delphinium inopinum yes See Appendix I. Dicentra nevadensis yes Draba sharsmithii yes Eriastrum tracyi yes Eriogonum nudum var. regirivum yes Eriogonum ovalifolium var. yes See Appendix I. monarchense Eriophyllum congdonii yes Erythronium pluriflorum yes Fissidens aphelotaxifolius yes Gilia yorkii yes See Appendix I. Horkelia parryi yes See Appendix I. Hulsea brevifolia yes See Appendix I. Leptosiphon serrulatus yes See Appendix I. Lewisia congdonii yes Lewisia disepala yes Lewisia kellogii ssp. kelloggii yes Lupinus citrinus var. citrinus yes Meesia uliginosa yes Mielichhoferia shevockii yes Mimulus gracilipes yes Mimulus norrisii yes Platanthera yosemitensis yes Streptanthus fenestratus yes Tauschia howellii yes Trifolium bolanderi yes

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Table 7. Species accounts, including a brief summary of the habitat needs and ecological requirements for all sensitive species present in the Plan area, are given below (FSM 2672.4). Information primarily from Baldwin et al. (2016) and CNPS (2016). 2013 FS R5 Regional Forester Sensitive Plant Species (RFSS) INF SQF SNF RFSS RFSS RFSS Abronia alpina (Ramshaw Meadows abronia) occupies loose, granitic gravel in meadow X borders within subalpine forests in Ramshaw and Templeton Meadows of the Kern Plateau, around 8750 ft. in elevation, and blooms May-Sept, peaking typically in July. Abronia nana var. covillei (Coville's dwarf abronia) is found in pinyon-juniper and X subalpine forests, typically on carbonate substrates over a broad elevation gradient from 5000-10200 ft. in the Inyo and White Mts. and blooms June-Aug. Allium yosemitense (Yosemite onion) occurs on open, rocky slopes in the central Sierra X Nevada, 800-2200 m in elevation and blooms May-June. Astragalus cimae var. sufflatus (inflated Cima milk-vetch) grows in sagebrush scrub and X pinyon-juniper woodland, on carbonate, rocky substrates, 1500-2075 meters in elevation. There is one occurrence on the Forest in the Whippoorwill Flat area of the Inyo Mts. Astragalus ertterae (Walker Pass milk-vetch) occurs in open areas with sandy, granitic X soil in pine/oak woodlands, 1750-1900 m elevation, and blooms April-May. Astragalus johannis-howellii (Long Valley milk-vetch) grows in sandy, volcanic ash or X pumice within sagebrush scrub at 2040-2530 m elevation, often in swales with current or former hot spring activity, and blooms June-August. Astragalus lemmonii (Lemmon's milk-vetch) occupies moist alkaline meadows or X lakeshores from 1300-2900 m elevation, primarily in the Long Valley area of the Inyo NF, and blooms May-July. Astragalus lentiginosus var. kernensis (Kern Plateau milk-vetch) grows on dry gravelly X X or sandy slopes and flats, primarily in and around the large meadows of the upper Kern Plateau at 2350-2750 m elevation, and blooms June-July. Astragalus monoensis (Mono milk-vetch) grows in pumice sand/gravel, in open areas X such as sand flats from 2100 to 3400 m in elevation, with all occurrences entirely or partly on the Inyo NF in Mono County, and blooms June –August. Astragalus ravenii (Raven's milk-vetch) grows in gravelly soil from 3400 to 3450 m in X elevation in subalpine or alpine environments with sparse shrub and/or tree cover, and blooms June-Sept. Astragalus shevockii (Shevock’s milkvetch) occurs on granitic sand in Jeffrey pine X forest, ca. 1900 m elevation in the southern High Sierra Nevada, and blooms June- August. Boechera bodiensis (Bodie Hills rockcress) occurs on dry, open, rocky, high or north- X facing slopes or exposed summits of granitic or rhyolitic material, on moisture- accumulating microsites in sagebrush and pinyon-juniper zones, and blooms July- August. Boechera evadens (hidden rockcress) grows on rock outcrops around 2600 m elevation X X in the southern High Sierra Nevada, and blooms in June. Boechera pinzliae (Pinzl's rockcress) grows in gravelly granitic soil in alpine and X subalpine areas from 3000 to 3400 m elevation in the White and Inyo Mountains and NV and blooms in July. Boechera shevockii (Shevock's rockcress) occurs on rock outcrop ledges, ca. 2500 m X elevation in the southern High Sierra Nevada, and blooms in June. Boechera shockleyi (Shockley's rockcress) grows in rock outcrops, gravelly soil X (generally dolemite) from 1200 to 2500 m elevation in the White and Inyo Mountains, and blooms April-May. Boechera tiehmii (Tiehm's rockcress) grows in rock outcrops and gravelly soil from 3000 X to 3600 m elevation in the central High Sierra Nevada and NV, and blooms June- August.

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2013 FS R5 Regional Forester Sensitive Plant Species (RFSS) INF SQF SNF RFSS RFSS RFSS Boechera tularensis (Tulare rockcress) occurs on rocky slopes in subalpine or upper X X X montane coniferous forest, with some reports from meadows. This species blooms June-July. Botrychium ascendens (upswept moonwort) grows in moist meadows or open woodland X X near streams or seeps from 1500 to 3200 m elevation in the central High Sierra Nevada, and Eastern Sierra Nevada. Botrychium crenulatum (scalloped moonwort) lives on saturated hard water seeps and X X X stream margins, 1500-3600 m elevation in the high Sierra Nevada and eastern Sierra Nevada. Botrychium lineare (slender moonwort) grows in moist meadows from 2500 to 4000 m X X elevation in the central and southern High Sierra Nevada. Botrychium lunaria (common moonwort) occurs in moist meadows, 2300 to 3400 m X X elevation in the central High Sierra Nevada. Botrychium minganense (mingan moonwort) grows in meadows and open forest along X X X streams or around seeps from 1500 to 3100 m elevation in the High Sierra Nevada. Botrychium montanum (western goblin) grows in shady conifer woodland, especially X X under Calocedrus along streams, 1500-2100 m elevation in the high Sierra Nevada. Botrychium paradoxum (paradox moonwort) is found in moist meadows and on shrubby X X slopes around 4000 m elevation in the central High Sierra Nevada. Botrychium tunux (moosewort) is found in well-drained, rocky meadows around 3600 m X X elevation in the central High Sierra Nevada. Botrychium yaaxudakeit (giant moonwort) occurs in moist alpine meadows around 3200 X X m elevation in the central High Sierra Nevada. Brodiaea insignis (Kaweah brodiaea) grows in foothill woodlands, 200 to 400 m X elevation in the southern Sierra Nevada, and blooms May-June. Bruchia bolanderi (Bolander's bruchia) colonizes organic or mineral soil along stream X X X banks, in and around meadows, springs, and fens, 3800 to 8200 ft. elevation. The species is opportunistic, taking advantage of disturbed sites where there is minimal competition from other vegetation. Calochortus excavatus (Inyo County star-tulip) is limited to somewhat moist alkaline X soils of the in Inyo County to Black Lake in Mono Co., with at least one occurrence partially on INF lands, at McMurray Meadows west of Big Pine. It is found 1300-2000 m elevation, and blooms April-May. Calochortus palmeri var. palmeri (Palmer's mariposa-lily) grows in meadows or vernally X moist places in yellow-pine forest and chaparral, 1200-2200 m elevation, and blooms May-July. Calochortus striatus (alkali mariposa-lily) grows in alkaline meadows or moist creosote- X bush scrub, 800-1400 m elevation in the southern Sierra Nevada foothills and western , and blooms April-June. Calochortus westonii (Shirley Meadows star-tulip) grows in meadows and open X woodlands, 1500-2000 m elevation in the southern Sierra Nevada, and blooms May- June. Calyptridium pygmaeum (pygmy pussypaws) grows in sandy to gravelly soils, usually X X X dry, on flats or slopes 6500-10200 ft. in elevation in the central and southern High Sierra Nevada, and blooms June-July. Camissonia sierrae ssp. alticola (Mono Hot Springs evening-primrose) grows on shallow X soil on granite outcrops in Ponderosa pine forest, 2000-2350 m elevation, and blooms May-July. Canbya candida (white pygmy-poppy) grows in sandy places in the western Mojave X Desert and adjacent Sierra Nevada, 600-1350 m elevation, and blooms April-May.

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2013 FS R5 Regional Forester Sensitive Plant Species (RFSS) INF SQF SNF RFSS RFSS RFSS Carex tiogana (Tioga Pass sedge) occurs on coarse, wet, limey soil in subalpine and X alpine zones of the central High Sierra, and produces July-Sept. Carlquistia muirii (Muir's tarplant) grows on dry, open sites on granitic soils, 1100-2500 X X m in elevation in the southern Sierra Nevada, and blooms June-October. Carpenteria californica (tree-anemone) grows along streambanks and in chaparral and X oak woodland, 340-1340 m elevation between the Kings and San Joaquin Rivers, Fresno Co. It is a post-fire stump-sprouter, with seedling establishment following burns, and blooms May-July. Cinna bolanderi (Bolander's woodreed) grows in meadows and along streamsides of the X X western Sierra slope, from 1850-2400 m elevation, and blooms July-September. Cladium californicum (California saw-grass) occurs at elevations from 30 m below sea X level to 2150 m above sea level (-100–7000 ft). It prefers alkaline marshes, swamps, springs (including hot springs), perennial streams, and ponds. The soil is usually moist to wet, often alkaline, and may be clay or gravel. The immediately adjacent vegetation is usually riparian, such as palms or willows, and may be dense. The riparian area is usually surrounded by common vegetation of the area, such as creosote bush scrub or pinyon-juniper woodland. The nearest known population to the Inyo NF occurs on BLM land in Addie Canyon of the Inyo Mts. Clarkia biloba ssp. australis (Mariposa clarkia) grows in chaparral and woodlands, 300- X 500 m elevation in the central Sierra Nevada foothills, and blooms May-June. Clarkia lingulata (Merced clarkia) grows in open chaparral and on steep north-facing X slopes, 400-450 m elevation in the central Sierra Nevada foothills, and blooms May- June. Collomia rawsoniana (Rawson's flaming trumpet) grows in shaded areas near stream in X woodlands in the central Sierra Nevada, 1000-2200 m elevation, and blooms June- September. Cordylanthus eremicus ssp. kernensis (Kern Plateau bird's beak) in open forest or X X meadows on summits and north faces of mountains, 2100-3000 m elevation, and blooms June-August. Cryptantha circumscissa var. rosulata (rosette cushion cryptantha) occurs on gravel X X barrens of granitic origin and is known to inhabit alpine to subalpine environments in coniferous forests and boulder and rock fields, and sandy banks near meadows and streams, 2950-3650 m elevation, and blooms July-August. Cryptantha incana (Tulare cryptantha) occours in gravelly or rocky areas in open X X montane coniferous forest; and occasionally chaparral and pinyon woodland 1700-3000 m. This species has also been frequently collected in the understory of red fir forest in gravelly and loamy soils, usually in open areas. It blooms May-August. Cryptantha roosiorum (bristlecone cryptantha) grows in dry, rocky meadows on X carbonate substrates in open bristlecone pine-limber pine forest, from 2570 to 3230 meters elevation, in the Inyo Mountains, and blooms June-July. Cypripedium montanum (mountain lady's-slipper) grows in moist areas, on dry slopes in X mixed-evergreen or conifer forest, 200-2200 m elevation, and blooms March-June. Dedeckera eurekensis (July gold) grows on limestone slopes in the White and Inyo Mts., X 1200-2200 m elevation, in mixed desert scrub to lower pinyon-juniper woodlands, and blooms June-October. Deinandra mohavensis (Mojave tarplant) grows in moist sites or openings in chaparral, X desert scrub, or woodland in the southern Sierra Nevada, and blooms May-January. Delphinium inopinum (unexpected larkspur) occurs in open conifer forest and on rock X X outcrops, 2200-2800 m elevation in the southern High Sierra Nevada, and blooms June- August.

12 Draft Biological Evaluation for Sensitive Plants

2013 FS R5 Regional Forester Sensitive Plant Species (RFSS) INF SQF SNF RFSS RFSS RFSS Delphinium purpusii (rose-flowered larkspur) grows in talus and on cliffs, 300-1300 m X elevation in the southern Sierra Nevada and west edge of the Mojave Desert, and blooms March-May. Dicentra nevadensis (Tulare County bleeding heart) grows in meadows and on gravelly X X soils, 2200-3100 m elevation in the southern High Sierra Nevada, and blooms in July. Draba asterophora var. asterophora (Tahoe draba) occurs in rock crevices, alpine X barrens, and talus, 2600-3300 m elevation in the northern and central High Sierra Nevada, and bloom June-August. Draba cruciata (Mineral King draba) prefers subalpine areas, gravelly or rocky slopes, X X ridges, crevices, cliff ledges, sink holes, and the edges of small drainages in upper montane and subalpine forests. The soil is usually may be derived from granite, metamorphics, or marble. It blooms July-August. Draba incrassata (Sweetwater Mountains draba) grows on alpine barrens and rocky X slopes, 2500-3500 m elevation in the northern Eastern Sierra Nevada, and blooms June-August. Draba monoensis (White Mountains draba) grows in moist gravel and rock crevices, X 3600-4000 m elevation in the White Mts., and blooms July-August. Draba sharsmithii (Mt. Whitney draba) occurs in rock crevices and on slopes, 3300-3800 X X m elevation in the southern High Sierra Nevada, and blooms July-August. Dudleya cymosa ssp. costatifolia (Pierpoint Springs dudleya) grows on limestone X outcrops, 1450-1600 m elevation in the southern High Sierra Nevada, and blooms May- June. Eriastrum tracyi (Tracy's eriastrum) is an annual that grows in open areas on shale or X X alluvium in open woodland or chaparral, 400-1000 m elevation, and blooms May- August. Ericameria gilmanii (Gilman's goldenbush) grows on limestone in open conifer forests, X from 2100 to 3400 m elevation, and blooms August-September. A single occurrence is known on the Inyo NF in the Inyo Mts. Erigeron aequifolius (Hall's daisy) is found only in steep, rocky, granitic crevices with X X X little or no competition from other species. It is generally found on dry ridges, approx. 5200-8000 ft in elevation in mixed conifer forests, and blooms July-August. Erigeron multiceps (Kern River daisy) inhabits meadows and seeps and openings in X X upper montane coniferous forests at 1500-2500 m elevation, generally on flat or nearly flat terrain and sometimes among rock outcrops, and blooms June-August. Erigeron uncialis var. uncialis (limestone daisy) grows in limestone crevices, sagebrush X scrub, and subalpine forest, from 2100 – 2900 meters elevation, and blooms June-July. Eriogonum breedlovei var. breedlovei (Breedlove's buckwheat) grows on quartzite in the X Piute Mts., Kern Co., 2300-2500 m elevation, and blooms June-September. Eriogonum nudum var. regirivum (Kings River buckwheat) grows on gravel in the X X southern Sierra Nevada Foothills, 200-600 m elevation, and blooms August-November. Eriogonum ovalifolium ssp. monarchense (Monarch buckwheat) grows on rocks, 1800 m X X elevation in the Kings River Canyon area, Fresno Co., and blooms June-August. Eriogonum twisselmannii (Twisselmann's buckwheat) grows on rocks in vicinity of the X Needles and Slate Mt., Tulare Co., and blooms June-Septe Eriogonum wrightii var. olanchense ( buckwheat) occurs in alpine to X subalpine areas, usually near or above timberline, 3500-3600 m elevation. Specific habitats include steep west and southwest facing slopes, granitic, in gravels, or flat open gravels with <10% slope. It blooms July-August. Eriophyllum congdonii (Congdon's woolly sunflower) grows in rocky, open, foothill X woodland and yellow-pine forest, 500-1900 m elevation in Mariposa Co. and blooms March-June.

13 Draft Biological Evaluation for Sensitive Plants

2013 FS R5 Regional Forester Sensitive Plant Species (RFSS) INF SQF SNF RFSS RFSS RFSS Erythronium pluriflorum (Shuteye Peak fawn lily) grows in open, rocky places, 2300- X 2550 m elevation in the central High Sierra Nevada, and blooms May-July. Erythronium pusaterii (Kaweah Lakes fawn lily) grows in meadows and on rocky ledges, X 2100-2775 m elevation in the southern High Sierra Nevada, and blooms May-July. Fissidens aphelotaxifolius (brook pocket moss) grows among rocks, in stream channels, X and on waterfalls in lower and upper montane coniferous forest. Fritillaria brandegeei (Greenhorn fritillary) grows in granitic soils in open forest, 1500- X 2100 m elevation in the southern Sierra Nevada and blooms April-June. Fritillaria striata (striped adobe-lily) grows in adobe soil, under 1000 m elevation in the X southern Sierra Nevada foothills, and blooms February-April. Gilia yorkii (Monarch gilia) grows in sunny to semi-shaded, sand- or gravel-filled terraces X X of limestone, 1290-1830 m elevation in the southern High Sierra Nevada, and blooms May-July. Helodium blandowii (Blandow's bog moss) grows between 2000 and 3200 m elevation X X X in wet montane meadows, fens, and seeps, especially under willows in areas of leaf litter, and also in subalpine coniferous forests and near alpine lakes. Hesperidanthus jaegeri (Jaeger's hesperidanthus) grows in rocky crevices, cliffs and X limestone clefts from 1500 to 2800 m elevation, in the White and Inyo Mountains, and blooms April-June. Heterotheca monarchensis (Monarch golden-aster) grows on limestone cracks, ledges, X X and flats, 1000-1900 m elevation in the Kings River Canyon and blooms June-October. Heterotheca shevockii (Shevock's golden-aster) grows in crevices and on shallow sand X in grassland and pine/oak woodland, 400-800 m elevation in the southern Sierra Nevada foothills, and blooms August-September. Horkelia hispidula (White Mountains horkelia) grows in high elevation sagebrush scrub, X sometimes in disturbed habitats next to or in roads, over 3000 m elevation, and blooms June-August. Horkelia parryi (Parry's horkelia) grows in open chaparral, 80-900 m elevation in the X northern and central Sierra Nevada foothills, and blooms April-September. Horkelia tularensis (Kern Plateau horkelia) grows on dry, rocky balds and flats, 2350- X 2850 m elevation in the southern High Sierra Nevada, and blooms June-August. Hulsea brevifolia (short-leaved hulsea) occurs in gravelly soils in montane forests, and X X X appears to benefit from fire. It blooms June-August. Hulsea vestita ssp. pygmaea (pygmy hulsea) inhabits subalpine forests, alpine boulder X X and rock fields, open gravel and talus slopes, and alpine barrens at 3200–3900 m elevation, and blooms June-October. Iris munzii (Munz's iris) grows in wet, grassy sites, in open or partial shade, 540-800 m X elevation in the southern Sierra Nevada foothills and High Sierra Nevada and blooms in April. Leptosiphon serrulatus (Madera leptosiphon) is an annual that grows in openings in X X woodland or chaparral, 300-1300 m elevation in the southern Sierra Nevada and blooms April to May. Lewisia congdonii (Congdon's lewisia) grows on granitic or metamorphic outcrops, X X crevices, rock slides in chaparral, woodland, or conifer forest, 500-2800 m elevation in the central Sierra Nevada, and blooms April to June. Lewisia disepala (Yosemite lewisia) grows in sand or granite of exposed mountain X X summits and knobs in subalpine conifer forest or alpine fell-fields, 1340-3500 m elevation in the central and southern High Sierra Nevada and blooms February-June. Lewisia kelloggii ssp. kelloggii (Kellogg's lewisia) grows in decomposed granite, volcanic X ash, and rubble in conifer forest, 1370-2360 m elevation in the central and southern Sierra Nevada, and blooms May-July.

14 Draft Biological Evaluation for Sensitive Plants

2013 FS R5 Regional Forester Sensitive Plant Species (RFSS) INF SQF SNF RFSS RFSS RFSS Lupinus citrinus var. citrinus (orange lupine) grows in granitic soils in open yellow-pine X forest, 600-1700 m elevation in the central Sierra Nevada foothills, and blooms April- July. Lupinus duranii (Mono Lake lupine) grows on pumice flats in Jeffrey pine forests of X Mono County, 6000-8000 ft., and blooms June-August. Lupinus lepidus var. culbertsonii (Hockett Meadows lupine) grows on rocky slopes 2500- X X X 3000 m elevation in the southern High Sierra Nevada, and blooms July-August. Lupinus padre-crowleyi (Father Crowley's lupine) grows in sagebrush scrub, or open X places in lodgepole pine or Jeffrey pine forests, 2500-4000 m elevation. The species appears to tolerate and possibly require periodic disturbance in some form. It blooms June-September. Meesia uliginosa (broad-nerved hump-moss) is strongly tied to montane fens within the X X X Sierra Nevada bioregion, and grows from 5500-9200 ft. elevation. Mentzelia inyoensis (Inyo blazing star) occurs in Great Basin scrublands and Pinyon- X Juniper woodlands, on rocky sites, washes, calcareous pumice sand, clayey hillsides, from 1150 – 1980 m elevation, and blooms May-August. Mielichhoferia elongata (elongate copper moss) grows on metamorphic rock, usually X X acidic, usually vernally mesic, often on roadsides, and sometimes on carbonate from chaparral to montane and subalpine forests. Mielichhoferia shevockii (Shevock's copper moss) occurs on rocks along roads, in X X similar settings as M. elongata. Mimulus discolor (two-colored monkeyflower), now taxonomically recognized as M. X montioides, occurs in wet openings in lower mixed conifer/oak forest, vernally moist depressions, swales, meadows, and creek edges, and blooms April-June. Mimulus filicaulis (slender-stemmed monkeyflower) occurs on disturbed, moist loamy X soil, generally in partial shade, 1200-1750 m elevation in the central High Sierra Nevada, and blooms May-July. Mimulus gracilipes (slender-stalked monkeyflower) occurs in disturbed or burned areas X X on decomposed granite, 500-1300 m elevation in the central Sierra Nevada foothills, and blooms April-May. Mimulus norrisii (Kaweah monkeyflower) grows in marble crevices, 600-1300 m X X elevation in the southern Sierra Nevada foothills, and blooms March-May. Mimulus pulchellus (yellow-lip pansy monkeyflower) grows in vernally wet depressions X or seepage areas, 600-2000 m elevation in the northern and central Sierra Nevada foothills, and blooms April-July. Mimulus shevockii (Kelso Creek monkeyflower) X Monardella beneolens (sweet-smelling monardella) is found on metamorphic or granitic X X scree slopes, in subalpine mixed conifer forest; grows in clumped prostrate mats, growing up and over boulders, and blooms April-September. Monardella linoides ssp. oblonga (Tehachapi monardella) grows in chaparral and conifer X woodland to forest on gravelly, dry slopes and flats, 1500-2600 m elevation, and blooms June-August. Navarretia peninsularis (Baja navarretia) grows in wet areas in open forest, 1400-2300 X m elevation in the Tehachapi region and blooms June-August. Navarretia setiloba (Piute Mountains navarretia) grows in depressions in clay or gravelly X loam, 500-2100 m elevation, in the southern Sierra Nevada foothills and blooms April- July. Nemacladus calcaratus (Chimney Creek nemacladus) grows on decomposed granite X flats, 1900-2100 m elevation in the Chimney Creek area of the southern High Sierra Nevada, and blooms in June.

15 Draft Biological Evaluation for Sensitive Plants

2013 FS R5 Regional Forester Sensitive Plant Species (RFSS) INF SQF SNF RFSS RFSS RFSS Nemacladus twisselmannii (Twisselmann's nemacladus) grows on granitic sands and X rocks in yellow pine forest in the southern High Sierra Nevada, ca. 2240 m elevation, and blooms in July. Oreonana purpurascens (purple mountain-parsley) is found on ridgetops, generally on X metamorphic rocks, in red fir or lodgepole pine forests, 2375-2860 m elevation in the southern High Sierra Nevada, and blooms May-June. Oreonana vestita (woolly mountain-parsley) grows on ridgetops, gravel, or talus, 1670- X 3500 m elevation, from the lower montane to subalpine coniferous forest zone, and blooms March-July. Peltigera gowardii (veined water lichen) grows on rocks in cold water creeks in upper X X X montane to alpine environments, and appears not to tolerate water pollution. Petrophyton caespitosum ssp. acuminatum (marble rockmat) grows on limestone cliffs, X X X in carbonate and rocky areas, and in lower and upper montane coniferous forests at 900-2350 m elevation, and blooms June-September. Phacelia inyoensis (Inyo phacelia) grows in meadows and alkaline seeps, 915-3200 m X elevation, and blooms May-July. Phacelia monoensis (Mono County phacelia) grows on shrink-swell volcanic clay soils X derived from rhyolite, 1900-2900 m elevation, in the White Mts. and Adobe Hills, and blooms May-July. Phacelia novenmillensis (Nine Mile Canyon phacelia) occurs on dry, disturbed banks X X and gravelly, rocky soils in Jeffrey pine and pinyon-juniper woodland, at approx. 1645- 2640 m elevation, and blooms May-June. Pinus albicaulis (whitebark pine) is found in subalpine forests and in a shrub-like form X X X above timberline on a variety of substrates, in the southern and central Sierra Nevada, and Glass Mts. Plagiobothrys parishii (Parish's popcornflower) is found between elevations of 750-2200 X m (2500-7250 ft) on alkaline soils in mesic sites located within Great Basin scrub and Joshua tree woodlands, and blooms March-June. Platanthera yosemitensis (Yosemite bog orchid) occurs in wet meadows, 2100-2285 m X elevation in the central High Sierra Nevada, and blooms July-August. Polemonium chartaceum (Mason's sky pilot) is restricted to high elevation, alpine X habitats in the White Mts., and blooms July-August. Polyctenium williamsiae (Williams' combleaf) occurs in saline soils, at vernal pool edges, X lake margins, and swales at 1000-2500 m elevation, and blooms May-July. Potentilla morefieldii (Morefield's cinquefoil) grows in rocky alpine barrens, over 3300 m X elevation in the central High Sierra Nevada and White Mts., and blooms June-August. Saltugilia latimeri (Latimer's woodland-gilia) grows on dry desert slopes, on coarse sand X to rocky soils, 400-1900 m elevation, and blooms March-June. Senecio pattersonensis (Mount Patterson senecio) grows on talus slopes, 3000-3700 m X elevation in the central High Sierra Nevada and Eastern Sierra Nevada, and blooms July-August. Sidotheca caryophylloides (chickweed oxytheca) grows in sand or gravel, 1300-2600 m X elevation in the southern High Sierra Nevada, and blooms June-September. Streptanthus cordatus var. piutensis (Piute Mountains jewel-flower) grows in open X chaparral or Piute-cypress stands, 1200-1700 m elevation in the Piute Mts., and blooms June-July. Streptanthus fenestratus (Tehipite Valley jewel-flower) occurs on granite ledges or sand X X in open mixed conifer or oak woodland, 1050-1800 m elevation in the southern High Sierra Nevada, and blooms May-June. Streptanthus gracilis (alpine jewel-flower) occurs on rocky slopes in the southern Sierra X Nevada at 3600-3600 m elevation, and blooms June-September.

16 Draft Biological Evaluation for Sensitive Plants

2013 FS R5 Regional Forester Sensitive Plant Species (RFSS) INF SQF SNF RFSS RFSS RFSS Streptanthus oliganthus (Masonic Mountain jewel-flower) grows on dry, open pinyon X woodland, rocky subalpine forest, and sagebrush scrub, 2000-3050 m elevation, in the central and northern Sierra Nevada, and White Mts., and blooms June-August. Stylocline masonii (Mason's neststraw) occurs on open loose sand of washes and flats, X 100-1200 m elevation, and blooms March-June. Symphyotrichum defoliatum (San Bernardino aster) occurs in grasslands or disturbed X places under 2050 m elevation, and blooms July-November. Tauschia howellii (Howell's tauschia) grows in granitic gravel on ridgetops in fir forests, X 2000-2500 m elevation in the northern High Sierra Nevada, and blooms June-July. Trifolium bolanderi (Bolander's clover) occurs in moist montane meadows, 2000-2300 m X elevation in the central High Sierra Nevada, and blooms June-July. Trifolium kingie ssp. dedeckerae (Dedecker's clover) most commonly occurs on granitic X X soils, among rocks and boulders, in pinyon-juniper woodland, subalpine coniferous forest, and upper montane coniferous forest, at 2100-3500 m elevation, and blooms May July.

Methods The evaluation of effects of the proposed action results in a determination of whether there will be a trend toward federal listing or a loss of viability of sensitive species. This evaluation was completed by examining habitat and occurrence information for each sensitive species (summarized in table 1 through table 6), and identifying the potential effects of the proposed action to individual ecosystems, or habitat, in which species occur. Land management plans do not have direct effects because they do not authorize or mandate any site-specific projects or activities (including ground-disturbing actions). However, there may be implications, or longer term environmental consequences, to sensitive species under this programmatic framework. As a result, all effects discussed in this section are considered indirect effects. Assumptions • Law, policy, and regulations will be followed when planning or implementing site-specific projects and activities. • Plan components will be followed when planning or implementing site-specific projects and activities. • The planning timeframe for the effects analysis is 10 to 15 years; other timeframes may be specifically analyzed depending on the resource and potential consequences. • Monitoring identified in the plan monitoring program and any broader-scale monitoring will occur and the land management plan will be amended, as needed during the life of the plan. • Relevant considerations to the analysis that are common to all alternatives include 1) existing wilderness will continue to be managed as such, 2) there will be a general increase in recreational demand as the human population size increases, 3) weeds and weed seeds will continue to be deposited and spread onto and within the planning area, 4) climate change trends will continue as projected, with warming temperatures and reduced snowpack. • Funding will be available to implement restoration measures proposed, including non-native invasive plant treatments.

17 Draft Biological Evaluation for Sensitive Plants

For all sensitive plant species, extent and condition of habitat were identified as indicators because they are direct measures of ecological conditions needed to maintain viable populations. Extent and condition of habitat were also selected as indicators because relative differences between a no action alternative and the proposed action could be readily compared. Qualitative, rather than quantitative, comparisons were generally made. To evaluate extent and condition of habitat, findings for environmental consequences to terrestrial, aquatic, and riparian ecosystems were relied upon strongly. In other words, the extent and condition of each ecosystem or special type of habitat served as the indicator for individual species.

Where species-specific trends in population size, density, or extent were available, quantitative data were also used to assist in the determination. Previously conducted biological evaluations for project work in the plan area were consulted as sources of information for evaluating potential impacts to species.

Effects of Proposed Action The proposed revised plans were developed under the 2012 Planning Rule, which requires the identification of species of conservation concern as one category of at-risk plants. Species of conservation concern (including most sensitive species) were analyzed in chapter 3 of the draft environmental impact statement for the revised forest plans, and those findings are summarized below. Most plan direction analyzed for species of conservation concern was ‘coarse filter’ management direction, aimed at providing broad ecological conditions for large numbers of species. As a result, potential effects to sensitive species as a group would be generally similar to effects to species of conservation concern. The analysis by ecosystem below therefore applies to all sensitive species. Effects unique to sensitive species that are not species of conservation concern are discussed in the section that follows. Effects Common to Sensitive Species Across Ecosystems Many plan components other than those specifically aimed at botanical species will have potential effects to these species, primarily plan components under revision topics of Sustainable Recreation and Recreation Designated Areas, Fire, Ecological Integrity, and Designated Areas. Overall, the proposed action has a greater potential for short-term negative effects to sensitive species compared to a no action alternative, due to the increased pace and scale of restoration, but it also has more potential for long-term positive effects due to restoration of resilience to ecosystems.

The proposed action would result in short-term and long-term increases in non-native invasive plant species, due to increased vegetation management activity, and an increase in the use of fire, which creates habitat for several invasives, including cheatgrass (Bromus tectorum) and yellow starthistle (Centaurea solstitialis). These increases would be offset to some extent by treatment actions under the proposed action, but it is not expected that treatments will result in total eradications during the lifetime of the plan. Invasive plant species compete with native plant species, and can change the fire regime, leading to negative effects to some species. Although restoration of the fire regime to the natural range of variation is generally beneficial to species of conservation concern, there is no historic proxy for a fire regime under the current condition of non-native invasive plant species infestation. Thus, it is unknown if restoring the fire regime will also result in less impact to native species from invasive species. Adaptive management will be essential to ensure that the increased use of fire does not result in negative effects to native species from the indirect effects of invasive plant species introduction and spread. The effects of non-native invasive plant species to sensitive plants would be greater in some ecosystems than others (e.g. in desert shrublands, sagebrush, and meadows), although non-native invasive plants are known in every ecosystem and likely have adverse effects to sensitive species wherever they co-occur.

18 Draft Biological Evaluation for Sensitive Plants

The Botany Specialist Report lists all applicable plan components that provide for necessary ecological conditions for species of conservation concern. For example, all three national forests have a forestwide desired condition reinforcing that ecological conditions support the persistence of species of conservation concern. There are also forestwide desired conditions that state vegetation conditions, particularly structure and composition, are resilient to climate change and to the frequency, extent, and severity of ecological processes (TERR-FW-DC-02). In addition, many coarse-filter plan components provide for species dependent upon each ecosystem (see below for examples in mixed conifer, subalpine, sagebrush, etc.).

For cases where the coarse filter components identified above were not found sufficient to provide for species persistence, fine filter plan components were included (Table 8 provided in draft environmental impact statement chapter 3). These included desired conditions and guidelines for meadows, special type habitats, and for project-level work that may affect some species of conservation concern. For example, all Forests have a desired condition for special habitats (e.g. limestone, alkali flats, rock outcrops) which states that the composition, diversity, and structure of these habitats are resilient to disturbances such as recreation and grazing. Also, for cases where programmatic planning (e.g. desired conditions for coarse or fine scale ecosystems) is not sufficient to ensure species of conservation concern persistence, all Forests have a guideline which states that projects should protect species of conservation concern by considering them early in the project planning process. This is especially important for species with extremely limited distributions, for which a single management action has the potential to affect an entire population. Effects to Sensitive Species by Ecosystem Effects to sensitive species that occur in the broad ecosystem types identified in the forest plans are discussed below.

Blue Oak- Interior Live Oak Woodland Threats to sensitive plant species in this ecosystem include non-native invasive plants, off-road vehicle use (legal and illegal), and development of lands. Activities conducted under the proposed plan could lead to some negative effects due to competition with non-native invasive species, soil erosion, trampling of individual plants, or loss of habitat. Potential restoration efforts under the proposed action would include those aimed at the desired condition of native plant abundance being maintained, and woodlands occurring in a highly variable and complex landscape pattern (TERR-BLU-DC-1 and 3); these activities would have a positive effect for sensitive plants.

Chaparral-Live Oak Threats to sensitive plant species in this ecosystem include non-native invasive plants, mining, fuels treatments, altered fire regimes, and vehicles. Activities conducted under the proposed plan could lead to some negative effects due to competition with non-native invasive species, soil erosion, trampling of individual plants, or loss of habitat. Potential restoration efforts under the proposed action would include those aimed at the desired condition of native shrub and understory species that reflect the natural range of variability for the site (TERR-CHAP-DC-1); these activities would have a positive effect for sensitive plants.

Montane Forests - Mixed Conifer and Jeffrey Pine Increased pace and scale of fuels treatments, especially using mechanical thinning, are likely to have some site-specific negative effects to sensitive plant habitat extent and quality, particularly for species dependent on those ecosystems identified above as being most departed from desired conditions (mixed conifer and Jeffrey pine). These negative effects can include soil erosion, soil compaction, or trampling.

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All these effects would be mitigated for sensitive species that are species of conservation concern through design features at the project level, but mitigations may not eliminate effects altogether. Some examples of species that may be affected include Carlquistia muirii, Muir’s tarplant and Cypripedium montanum, mountain lady’s slipper. However, long-term, landscape restoration of forested ecosystems, including restoring fire regimes within the natural range of variation, would have positive effects to at-risk plant habitat and quality, including for Hulsea brevifolia, short-leaved hulsea, and Lupinus padre-crowleyi, Father Crowley’s lupine.

Mountain Mahogany Mountain mahogany comprises an extensive zone on the east-side and hosts a number of sensitive species. This ecosystem typically occurs in rocky, inaccessible terrain, but threats include non-native invasive species, altered fire regimes, and mining. Activities conducted under the proposed plan could lead to some negative effects due to competition with non-native invasive species, soil erosion, trampling of individual plants, or loss of habitat. Unlike the no action alternative, special consideration is given in the proposed action to the unique setting of mountain mahogany, and includes a desired condition that the fire return interval is appropriate to allow the soil seed bank of native species to be maintained over the short and long term. Invasive non-native plants also should not dominate between fires (TERR-MOMA- DC-02). Restoration activities would thus have a long-term, beneficial effect to sensitive species in this ecosystem if these desired conditions are met.

Pinyon-Juniper Sensitive species in pinyon-juniper ecosystems may be threatened by non-native invasive plant species, altered fire regimes, vehicles, and mining. Activities conducted under the proposed plan could lead to some negative effects due to competition with non-native invasive species, soil erosion, trampling of individual plants, or loss of habitat. Restoration efforts under the revised forest plans would aim for fire frequency and severity that is within the natural range of variation, and to maintain plant litter and coarse woody debris in sufficient quantities to ensure pinyon pine regeneration, and overall ecosystem health in this type. These actions would have positive effects for the sensitive species that occur there.

Xeric Shrubland/Blackbrush Sensitive species in xeric shrubland and blackbrush ecosystems may be threatened by non-native invasive plant species, altered fire regimes, vehicles, and mining. Unlike other systems where fire exclusion has generally led to too little fire, this ecosystem has experienced greater fire frequency compared to the natural range of variation. Because of the high risk of non-native plant species invasions as a result of activities in this type, and the potential to damage to fragile soil crusts that prevent such invasions, projects in this type may result in negative effects to sensitive species. However, because wildfire and invasive species spread are projected to occur in this system under the no action alternative, the long-term benefits provided by the revised management plans (i.e. reducing fire severity or intensity) may counteract these negative effects to some extent.

Sagebrush For sagebrush ecosystems, threats to sensitive plant species include non-native invasive species, altered fire regimes, vehicles, grazing, and mining. Activities conducted under the proposed plan could lead to some negative effects due to competition with non-native invasive species, soil erosion, trampling of individual plants, or loss of habitat. Desired conditions for sagebrush include a diversity of age and size classes, and of composition, and resilience to disturbances. In addition, grazed areas should be in or trending toward satisfactory soils conditions, functional hydrology and biotic integrity. Potential

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restoration efforts aimed at providing these desired conditions would have beneficial effects for sensitive species that occur there.

Subalpine and Alpine Areas Subalpine areas of the High Sierra Nevada and White-Inyo Mountain Ranges host particularly high densities of at-risk plant species. Among the threats identified to species in these ecosystems is climate change. All forest plans include plan components aimed at preventing loss of at-risk species viability in the face of climate change. For example, desired conditions state that subalpine woodlands and alpine ecosystems are resilient to insects, diseases, fire, wind, and climate change (TERR-ALPN-DC-01). The proposed action includes the potential for some restoration in alpine and subalpine ecosystems that would have potential positive effects for sensitive plants in these ecosystems. Projects that occur in these ecosystems are typically limited in scope, due to the inaccessibility of terrain, high proportion of wilderness, and low tree densities. Invasive species do occur in these ecosystems, but are typically limited in extent and density due to low temperatures and limited habitat; their effect to sensitive species is therefore minimal.

Special Habitats and Aquatic/Riparian Because of the plan components developed with the aim of protecting special habitats as the ecological fabric to maintain the viability of a large suite of at-risk plant species, it is expected that the proposed action would have minimal short-term negative effects to the habitat extent and quality for those at-risk species that depend on them. Restoration efforts, particularly in meadows and other herb-dominated communities, would likely have positive, long-term effects for the many at-risk plant species dependent upon these systems. Examples include species dependent on meadows and special habitats (e.g. moonworts, sedges, meesia moss, Mono Lake lupine, Mono milkvetch, King’s river buckwheat, Monarch buckwheat, Boyden Cave gilia). Table 4 provides the special habitat requirements known for each sensitive species.

Under all action alternatives, increases in dispersed and/or developed recreation are expected to some degree due to increasing human population and recreation demand. Some special habitats (meadows, riparian, rock outcrops), are often places where recreation is more frequent or intense. Consequent trampling (humans or pack stock), increased vectors for non-native invasive species, or habitat alteration are all activities that can have negative effects to sensitive plant habitat extent or quality, or can have negative effects through the introduction of non-native invasive plants. Because special habitats may host sensitive plants, and because these areas may have especially high concentrations of recreational activities, plan components were developed to provide for the continued persistence of at-risk species that occur there. Examples for all three Forests include a guideline that fire suppression activities (e.g. fire line construction and construction of helicopter landing sites) are to be avoided in special habitats, and a standard that special habitats are to be considered in project design. Meadow restoration would also provide benefit to species dependent upon those habitats, especially for those that have been negatively affected by hydrologic alteration (e.g. some moonworts and sedges).

Upper Montane, Red Fir, and Lodgepole Pine Threats to sensitive plant species in this ecosystem include fuels treatments, altered fire regime, non- native invasive plant species, and climate change. Activities conducted under the proposed plan could lead to some negative effects due to competition with non-native invasive species, soil erosion, trampling of individual plants, or loss of habitat. Potential restoration efforts under the proposed action would include those aimed at the desired condition of upper montane vegetation occurring in a complex mosaic of different densities, sizes, and species mixes across large landscapes that vary with topography, soils, and snow accumulation. The composition, structure, and function of vegetation would make these

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systems resilient to fire, drought, insects and pathogens, and climate change; these activities would have a positive effect for sensitive plants. Evaluation of Sensitive Species Not on the Species of Conservation Concern List As described above, plan direction aimed at providing coarse filter ecological conditions for species of conservation concern would provide habitat that ensures viability for sensitive species as well. Some additional considerations led to the determinations regarding viability for sensitive species that are not included as species of conservation concern. These considerations could be categorized into three general groups: 1) species occurrence within the plan area, 2) evidence of greater abundance than previously thought, and 3) sufficiency of information on which to base a substantial concern for persistence, or viability. Effects of the revised forest plans to species in each of these categories will be discussed separately below.

Sensitive Species Not in the Plan Area For the sensitive species listed in table 8, there will be no effect to species as a result of the proposed draft plans.

Table 8. Sensitive species identified for each Forest which actually have no occurrence records there. Inyo NF Sequoia NF Sierra NF Botrychium paradoxum Saltugilia latimeri Botrychium lunaria Botrychium tunux Sidotheca caryophylloides Botrychium paradoxum Botrychium yaaxudakeit Stylocline masonii Botrychium tunux Cladium californicum Botrychium yaaxudakeit Draba asterophora var. Mimulus filicaulis asterophora Meesia uliginosa Mimulus pulchellus Phacelia novenmillensis Helodium blandowi Petrophyton acuminatum

Species That are More Abundant Than Previously Thought During the plan revision process, evaluation of some species indicated greater abundance of populations and/or density of plants in the plan area than previously thought. Plan direction provides for ecological resilience in the ecosystems these species occur, as explained in the sections above. The fact that plan direction provides for ecological conditions that support biodiversity, in addition to evidence of larger population size and number for these species, indicates that viability is not a strong concern for these species in the plan area (see appendix I for write-ups of these species). There would most likely be beneficial effects of the revised plans to these species, as a result of fire regime restoration, non-native invasive species prevention and control, and other restoration activities.

• Abronia nana ssp. covillei (limestone substrates, a special habitat, within pinyon-juniper; Inyo National Forest) • Cryptantha incana (pinyon pine, montane forests, to red fir zone; Inyo National Forest, Sequoia National Forest) • Calochortus palmeri var. palmeri, ( meadows, seeps, and vernally moist areas in chaparral, mixed conifer forest, and yellow pine forest; Sequoia National Forest)

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• Peltigera gowardii (cold water streams in upper montane forests; on the Sierra National Forest, the species is more abundant that previously thought, though this is may not be the case on other Forests; see appendix I).

Species for Which Insufficient Information Exists About Status and Trend There was a number of sensitive species for which occurrence records did exist for the plan area, but had questionable identifications and/or locations, and/or had insufficient information on which to base a concern for persistence, and thus were not included as species of conservation concern. For these species, the lack of information about their occurrence, status, or trend also precluded direct conclusions regarding potential loss of viability. For these species, effects were evaluated by inference of effects to the ecosystems and special habitats upon which they depend. Effects to the sensitive species listed in table 9 would therefore be similar to those discussed above in the sections on Effects Common to Sensitive Species, and Effects by Ecosystem.

Table 9. Sensitive species for which there was insufficient information on which to base a substantial concern for inclusion as species of conservation concern, or base a concern for potential loss of viability. Inyo National Forest Sequoia National Forest Sierra National Forest Botrychium lunaria Canbya candida Erigeron aequifolius Draba cruciata Delphinium inopinum Glyceria grandis Draba incrassata Hulsea vestita ssp. pygmaea Heterotheca monarchensis Erigeron aequifolius Lupinus lepidus var. culbertsonii Lupinus lepidus var. culbertsonii Erigeron multiceps Mielichhoferia elongata Mielichhoferia elongata Hulsea vestita ssp. pygmaea Lupinus lepidus var. culbertsonii Peltigera gowardii Senecio pattersonensis

Finally, adaptive procedures under the 2012 Planning Rule provide for continued consideration of the species included on the species of conservation concern list, and revisions of that list if necessary. If new information indicates that an additional species meets the criteria for being added as a species of conservation concern, the Responsible Official may recommend the addition to the Regional Forester and determine if a change in Forest Plan direction is needed. This provision for potential addition of sensitive species not yet included as species of conservation concern to that list at a later time would also ensure there will not be a loss of viability if conditions change for these species. Cumulative Effects Sensitive plant species are affected by management activities that occur both within the plan area and on adjacent land under private, State, or other Federal management. The consequences of these actions are cumulative across boundaries. These cumulative actions could produce positive results, such as increased habitat extent or improved condition as restoration measures are taken. Similarly, there may be negative impacts, such as habitat loss, or degradation, such as by the introduction or spread of non-native invasive plant species.

Reasonably foreseeable management activities on private, State, or other Federal land would be similar to vegetation management performed on the forest—prescribed burning to restore fire disturbance regimes

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or the thinning or removal trees to reduce the risk of high-severity wildfire, with short term impacts and long term benefits similar to those described above.

Many restoration activities and project design features aimed at protecting plant species are shared by adjacent landowners, in particular the National Park Service and Bureau of Land Management. For example, efforts to use weed and weed seed-free plant material for animal or bedding, soil stabilization and land rehabilitation complements similar efforts in the adjacent Sequoia-Kings Canyon National Park. Combined and coordinated efforts in these areas would improve ecological conditions that provide for sensitive species viability.

Design Criteria Design criteria of the revised forest plans emphasize desired conditions for providing direction in conducting forest activities. As discussed in the sections above, numerous desired conditions are aimed at maintaining overstory and understory vegetation diversity and resilience.

Additional fine filter or project-level design criteria are also included in the proposed action, to ensure the persistence of species of conservation concern. While many species of conservation concern are sensitive species, the direction was written broadly enough to also provide benefit for sensitive species not included as species of conservation concern. This forest-wide direction includes:

• INF-INFR-FW-GDL-05 Minimize vegetative disturbance during road maintenance operations to the greatest extent possible. • INF, SQF, SNF - GEO-FW-GDL-08 During mining-related activities, limit the clearing of trees and other vegetation to the minimum necessary. Clearing of vegetation should be pertinent to the approved phase of mineral exploration and development. • INF, SQF, SNF - SPEC-FW-GDL-03 Projects should protect at-risk plant species and their habitat by considering at-risk plant species early in the NEPA planning process. • INF, SQF, SNF - SPEC-FW-GDL-05 Design features, mitigation, and project timing considerations should be incorporated into ground-disturbing projects that may affect occupied habitat for species of conservation concern. • INF, SQF, SNF - INV-FW-GDL . 01 Use an integrated pest management (IPM) approach in the planning and implementation of all projects and activities. . 02 Projects should be designed to minimize invasive species spread by incorporating prevention and control measures into ongoing management or maintenance activities that involve ground disturbance, terrestrial or aquatic habitat alteration, or the possibility of spreading invasive species. When feasible, projects should include measures to provide invasive species-free gravel, fill, topsoil, and mulch and include follow-up inspections as needed and specified in regional or national strategies. . 03 To the extent feasible, hay, straw and mulch used for animal feed or bedding, soil stabilization and land rehabilitation, or other purposes should be certified by California or the North American Invasive Species Management Association as being weed-free to prevent unintentional introduction of invasive species.

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. 04 Weed-free plant material should be selected for all seeding and mulching projects to restore natural species composition and ecosystem function to the disturbed area. Plant or seed materials should be used that are appropriate to the site, capable of becoming established, and not invasive. . 05 Weed prevention measures should be included, as necessary, when amending or re-issuing permits including, but not limited to livestock grazing, special uses and pack stock operator permits. . 06 The non-chemical method should be used when the Integrated Pest Management approach determines that chemical and one or more other form of management, cost, or feasibility will be comparable in the control of non-native invasive species. • INF, SQF, SNF - TERR-SH-STD- 01 At the project scale, consider special habitats during project design, using sufficiently scaled information to characterize such habitats (TERR-SH-GDL) • INF, SQF, SNF - TERR-SH-GDL-01 During wildfires, avoid fire management activities in special habitats except when necessary to protect life and property. This includes activities such as line construction, staging areas, safety zones, water drafting and/or camps. When conducting fire management activities near special habitats, take extra measures to avoid spread of invasive plants. Species-Specific Plan Components As discussed above, the revised forest plans propose design criteria aimed mainly at conserving the diversity and resilience of the broad ecosystems upon which sensitive species depend. However, specific management direction was included for two at-risk plant species that are also sensitive species. For Ramshaw Meadows abronia (Abronia alpina), the conservation agreement which outlines actions to be taken to benefit this species, and a monitoring plan, was incorporated as a Resource plan into the draft Inyo NF revised plan.

Whitebark pine (Pinus albicaulis), an at-risk species due to its candidate status under the Endangered Species Act, and also an R5 sensitive species, has a number of plan components aimed at protecting its viability. As described in the draft environmental impact statement and Botany Specialist Report, this species is threatened by factors including climate change and insect and disease outbreaks. Some of the negative effects of these threats are beyond the control of the agency, restoration activities that improve resilience of whitebark pine can help to ameliorate existing threats, and thus provide for species viability. Potential effects to whitebark pine of the revised forest plans were discussed in the draft environmental impact statement and Botany Specialist Report. In summary, desired conditions aimed at resilience of whitebark pine forests to climate change and other threats would help ensure there is no loss of viability for this species. In addition, a potential management approach is included to develop a regional whitebark pine conservation and restoration strategy in collaboration with other federal agencies, research organizations, and other partners. While threats to whitebark pine may persist, including insect/disease and climate change, the proposed action would ameliorate some of the negative effects.

Summary Plan components in the revised forest plans were designed to provide for persistence of species of conservation concern. Persistence is defined in the 2012 Planning Rule as the continued existence of a taxon. Similarly, National Forest Management Act regulations (36 CFR 219.36) define a viable species as one “consisting of self-sustaining and interacting populations that are well distributed through the species’ range. Self-sustaining populations are those that are sufficiently abundant and have sufficient diversity to display the array of life history strategies and forms to provide for their long-term persistence and adaptability over time.” A species is described as being well-distributed “when individuals can interact

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with each other in the portion of the species’ range that occurs within the plan area” (36 CFR 219.20). The plan area in this context may consist of one or more national forests, and refers specifically to National Forest System lands within that area.

In evaluating whether species persistence would be provided for under the revised forest plans, the long- term connectivity of habitats was considered to be an important component for persistence; for a species to continue to exist, by inference, it must be viable, and display sufficient abundance to display diversity, and to interact with each other within the range that occurs in the plan area. In other words, intact habitats that provide for viable species must also be present in order for them to persist. Plan components that provide for species persistence in the plan area therefore would by definition not lead to a loss of viability.

Determination For those species determined not to be within the plan area, it is my determination that there is NO IMPACT to individuals or to viability of these species as a result of the proposal.

For sensitive species that do occur within the plan area, it is my determination that the proposal MAY IMPACT INDIVIDUALS, BUT IS NOT LIKELY TO CAUSE A TREND TOWARD FEDERAL LISTING OR A LOSS OF VIABILITY. Plan direction that emphasizes restoration actions across ecosystems will provide benefit both to species of conservation concern, and to other sensitive species that depend upon these same ecosystems. Actions aimed at reducing the threat of non-native invasive species, ensuring that special habitats are considered during the National Environmental Policy Act process for projects, and limiting disturbance during road and mining projects will help to ensure there is no loss of viability or trend toward federal listing for sensitive species. For sensitive species that are not currently recognized as species of conservation concern or at-risk species, the adaptive management process will provide for continual review of the species on these lists, and potential additions to the lists, or revisions in the Forest plans to be made, if sufficient information about threats to species persistence becomes evident within the plan area.

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References Baldwin, B.G., D. H. Goldman, D.J. Keil, R. Patterson, T.J. Rosatti, and D.H. Wilken, editors. 2012. The Jepson Manual: vascular plants of California, second edition. University of California Press, Berkeley.

Baxter, D, S Markos, NR Morin, RL Moe, E Dean, M Nazaire. 2016. Consortium of California Herbaria. Available at: http://ucjeps.berkeley.edu/consortium/. [accessed Jan through Apr 2016].

Clines, Joanna. 2009. Conservation Assessment for Botrychium in California National Forests. Compiled from technical reports prepared by Donald Farrar and Cindy Johnson-Groh.

CNDDB. California Department of Fish and Game, Biogeographic Data Branch. 2016. California Natural Diversity Database. Sacramento, CA. Data downloaded Feb 2016.

CNPS, Rare Plant Program. 2016. Inventory of Rare and Endangered Plants. California Native Plant Society, Sacramento, CA. Available at http://www.rareplants.cnps.org [accessed May 2016].

Laeger, Eve. 2002. Botrychium surveys in California. Prepared for the Sierra Nevada Frameworks. Bodfish, CA.

Natureserve. 2016. NatureServe Web Service. Arlington, VA. U.S.A. Available at: http://services.natureserve.org. [accessed May 2016].

Shevock, J. 1990. CNDDB Field Survey forms for Delphinium inopinum.

Shevock, J.R., and A. Day. 1998. A new Gilia () from limestone outcrops in the southern Sierra Nevada of California. Madroño, Vol. 45, No. 2, pp. 137-140

Sugden, Evan A. 1985. Pollinators of Astragalus monoensis Barneby (Fabaceae): new host records; potential impact of sheep grazing. West. N. American Naturalist, Vol. 45, No. 2, pp. 299-312.

Takenaka, Kellen, 2015. Rough BAER North Zone Sierra National Forest Soil Resource Assessment Report 10 September 2015. http://inciweb.nwcg.gov/photos/CASNF/2015-10-03-0253-Rough- PostFire-BAER/related_files/pict20151004-182150-0.pdf

USDA Forest Service, Inyo National Forest. 1988a. Inyo National Forest Land and Resource Management Plan. Bishop, CA. 317pp

USDA Forest Service, Sequoia National Forest. 1988b. Sequoia National Forest Land and Resource Management Plan.

USDA Forest Service, Inyo National Forest. 1991. Management Direction for the Sensitive Plants on the Inyo National Forest. Bishop, CA. 71pp.

USDA Forest Service, Inyo National Forest. 1992. Species Management Guide for Abronia alpina Bdg. Bishop, CA. 32 pp.

USDA Forest Service, Inyo National Forest. 1994. Inyo National Forest Sensitive Plant Field Guide. Bishop, CA.

USDA Forest Service, Pacific Southwest Region. 2013. Regional Forester Sensitive Species List. Available at: http://www.fs.usda.gov/main/r5/plants-animals/plants [accessed May 5, 2016].

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USDA Forest Service. 2015. Sensitive plant and invasive species monitoring overview. Inyo National Forest.

USDA Forest Service and US Fish and Wildlife Service. 2015. Conservation agreement for Abronia alpina (Ramshaw Meadows abronia) Tulare County, CA. Inyo National Forest and Sacramento Fish and Wildlife Office.

U.S. Fish and Wildlife Service. 2016. Endangered Species Database. Available at: http://www.fws.gov/endangered/. [accessed 2016 Mar 25]

York, D.A. 1999. A Phytogeographic Analysis of the Kings River Basin, California. Unpublished M.A. Thesis, Calif. State Univ. Fresno. 388 pp.

York, D.A. 2002. Eriogonum ovalifolium var. monarchense (Polygonaceae), A new variety from the southern Sierra Nevada, California. Madroño Vol. 49, No. 1, pp. 16-19.

York and Shevock, 1995. Herbarium voucher data submitted by Dana York and James Shevock to various herbaria and entered into the California Consortium of Herbaria online database. Accessed by Joanna Clines, Sierra NF botanist on May 1, 2016: http://ucjeps.berkeley.edu/consortium/

York and Shevock, 1995. Herbarium voucher data submitted by Dana York and James Shevock to various herbaria and entered into the California Consortium of Herbaria online database. Accessed by Joanna Clines, Sierra NF botanist on May 3, 2016: http://ucjeps.berkeley.edu/consortium/

Young, K., and F. Linton. 2015. Rough Fire North Zone BAER Botany Report; September 10, 2015. http://inciweb.nwcg.gov/photos/CASNF/2015-10-03-0253-Rough-PostFire- BAER/related_files/pict20151004-181109-0.pdf

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Appendix I Species: Abronia alpina, Ramshaw Meadows abronia Forest(s) of Consideration: Inyo National Forest

Rank: G2, S2, 1B.1 (Natureserve, 2016)

Habitat: Meadow borders in subalpine conifer forest at 2,650 meters (8,700 feet) elevation (USDA and USFWS, 2015).

Distribution: A single population occurrence is in the Ramshaw Meadows area of the Kern Plateau within the Golden Trout Wilderness, Tulare County (CNDDB, 2016). The population occupies approximately 15 acres.

Herbarium specimens: 23 Collections documented in the Consortium of California Herbaria (Baxter et al. 2016), beginning in the late 1800s (e.g. Purpus 1877, DeDecker 4183, André 244).

Site visit or monitoring information:

Abronia alpina has been monitored by Forest Service personnel and partners at least every three years since 1985, with monitoring reports developed for each visit, in accordance with the 1992 Species Management Guide and 2015 Conservation Agreement. The population shows approximate 10 year cycles in population size fluctuation, with 2015 marking the second lowest population estimate over the last 30 years (USDA 2015).

Notes: This species was originally included as an at-risk species, but not a species of conservation concern, due to its status as a Candidate species under the Endangered Species Act. When the species was removed from Candidacy (Fed. Reg. 10/8/2015), following the implementation of a Conservation Agreement between the USFS and USFWS, Planning Directives indicated that this species now meets the definition of a species of conservation concern.

Known threats: Conifer encroachment, hydrologic alteration (water table lowering), and climate change have been identified as threats. In addition, herbivory and inadequacy of regulatory mechanisms (prior to the implementation of the Conservation Agreement) were identified as threats (USDA and USFWS, 2015). Low populations numbers in 2015 appeared to be due primarily to the ongoing drought.

Conclusion for Inyo National Forest: There is a substantial concern about the species’ capability to persist over the long term in the plan area because only a single population, extremely limited in extent, is known. Monitoring has indicated strong population size fluctuations, with very low numbers in 2015, most likely due to the ongoing drought. The Conservation Agreement addressing the threats to this species and including plans for monitoring and research is aimed especially at potential restoration opportunities. Species: Abronia nana var. covillei, Coville’s dwarf sand verbena Forest(s) of Consideration: Inyo National Forest

Rank: G4T3, S3.2 (CA), S1? (NV), 4.2 (CNPS, 2016), NV Watch List (NV DCRS, 2016).

Habitat: Sagebrush shrublands and pinyon-juniper woodlands, upper montane, and subalpine coniferous forest above 5000 ft., typically in sandy, carbonate habitats.

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Distribution: Many small populations are found in the White and Inyo Mountains. Outside the Inyo National Forest, populations also occur in desert mountain ranges of Inyo and San Bernardino Counties, and in Nevada. Occurrences are not currently tracked or mapped by California Natural Diversity Database (CNDDB 2016). The Nevada Natural Heritage Program reports five occurrences (NV DCRS, 2016).

Herbarium specimens: More than 50 collections documented in the Consortium of California Herbaria, including at least ten from the Inyo National Forest (Baxter et al. 2016; e.g. DeDecker 463, Morefield 4815).

Site visit or monitoring information:

Sensitive plant evaluation forms completed by the Inyo National Forest in 2012 reported 10 occurrences on the INF. Re-examination of those records revealed that these actually were 10 reported sightings/collections, some in overlapping areas. The Inyo National Forest has a total of 11 mapped polygons, based on surveys from 1998, 2009, and 2010, some of which are less than ¼ mi. apart, thus not meeting the definition of distinct populations at the ¼ mi. distance rule. The distribution of populations (near roadways, and along most accessible hiking routes) indicates that there may be more populations and individuals in this habitat in unsurveyed areas; it appears to have a patchy, but relatively consistent distribution in suitable habitat.

Estimated acreage of potentially suitable carbonate habitat in the Inyo Mountains alone is more than 15,000 acres, based on inspection of the current distribution of known populations, and overlays with imagery. Known occupied habitat is smaller in the northern distribution of the White Mountains, but surveys have been restricted due to the difficulty of access outside of the Schulman Grove. It seems likely that more populations may be identified in the White Mountains.

The known occurrences which have been observed on multiple dates by the botanists indicated include:

Upper Harkless Flat: Bagley 1998; Pritchett, 1999

Papoose Flat Vicinity: DeDecker 1988; Andre and LaDoux, 2010

Schulman Grove Vicinity: DeDecker Unknown Date, Morefield 1988

Badger Flat to Inyo Crest; Blue Bell Mine area: Kerr, 1932; JT Howell, est. 1940s-50s; Alexander and Kellogg, 1940; Roos 1953; DeDecker 1953, 1956, 1968; Roos 1967; Andre et al. 2009; Andre and LaDoux 2010; Weis and Slaton 2014

Additional information on population size and distribution was documented in an Email from Mike Uhler to Sue Weis 7/12/2009: “I have already gone back up in the Inyos to do a rough survey of ssp. covillei. I was happy to find several populations with more than 100 individuals… recorded at least 5 sites with Abronia populations, the highest population at 10,973, is higher than the range stated in Jepson… The following day I walked to the top of , along the way I encountered many populations of covillei… I believe there are plants on a granite substrate.”

While many surveys have been conducted, the only monitoring information available is for an INF Ecology Plot (#277) located NE of Badger Flat, which was visited in 2004 and 2015. Individuals were not counted, but only observed to be present within the 1/10 acre area sampled on both dates. No threats or major changes to dominant species cover or composition were noted.

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Known threats: Grazing, mining, vehicles (CNPS, 2016; Natureserve, 2016). There are many historic mines, and some active claims within habitat for this species. However, because of the broad and sparse distribution of this species, it is unlikely that any individual project would impact more than 1% of the population within the Inyo National Forest.

Conclusion for Inyo National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because many populations and individuals are known from a relatively large area on the Inyo National Forest, and though they are constrained to limestone substrates, they are not highly specific to elevation, and thus occupy major vegetation zones from sagebrush to pinyon-juniper, mountain mahogany, and bristlecone pine-limber pine. The threats of mining and grazing do not appear to be substantial because the plant is so widely distributed that impacts are unlikely to affect more than a small proportion of individuals on the Inyo National Forest. Finally, monitoring and surveys have not indicated a downward trend for this species. Species: Botrychium lunaria (B. neolunaria ined.), common moonwort Forest(s) of Consideration: Inyo National Forest

Rank: G5, S2?, CNPR 2B.3

Habitat: Moist meadows, 2300-3400 m elevation.

Distribution: North and South America, Eurasia, Australia, and New Zealand. In North America it occurs from Newfoundland and Labrador west to Alaska, and south to Massachusetts, New York, Michigan, Minnesota, Saskatchewan, New Mexico, Arizona, and California (Natureserve, 2016).

Herbarium specimens:

There are a total of 4 specimens entered in the Consortium for the entire state, with two from the plan area (Baxter et al., 2016):

• Munz 15352, 7/24/1950 S Fork Monache Creek (annotated by D. Farrar as B. crenulatum). • Taylor 7891, 7/4/1981, Lee Vining Creek, at town of Lee Vining, 0.6 miles above Mono Lake. (2002 email from Taylor specifies the location as 150-250 m upstream from the Hwy 395 bridge). This location is on a private parcel, though within the administrative plan area, and is apparently incorrectly mapped in the California Natural Diversity Database (2014). In July, 2007, Sue Weis collected a potential B. lunaria specimen from Trail Canyon in the White Mountains. It was sent to Don Farrar for identification. He replied by email that genetic testing is needed; it may be a new variety of B. simplex.

Site visit or monitoring information:

Forest Botany staff conducted fen and meadow surveys throughout the Sierra Nevada and White Mts. on numerous dates 2001-present in support of packstation management, travel management, grazing permit issuance, fuels projects, and other activities. The single potential B. lunaria occurrence was noted in the section above.

Eve Laeger (2002) conducted numerous surveys for Botrychium across the Forest, with follow-up work conducted in 2004. No B. lunaria was reported.

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Notes: Clines (2009) describes high genetic complexity in this taxon. Field or even herbarium identification appears highly unlikely without genetic verification.

Known threats: Based on the locations of the potential occurrences, and the general habitat known for the species, the threats of hydrologic alteration, trampling, and OHV (severe soil disturbance) were identified for the plan area. While Botrychium may be partially dependent on soil disturbance to create new habitat (Clines, 2009), direct disturbance to existing plants is identified as a threat. Grazing is listed as a possible threat (CNPS, 2016), as is loss of its open habitats to successional overgrowth (Natureserve, 2016).

Conclusion for Inyo National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because there is insufficient information about its status on the Inyo National Forest. Information is insufficient because 1) the single available record is based on a 35- year old collection, 2) the collection appears to be from a private parcel, where no surveys have been conducted, and 3) taxonomic research for this species is strongly needed. Species: Calochortus palmeri var. palmeri, Palmer’s mariposa lily Forest(s) of Consideration: Sequoia National Forest

Rank: Natureserve G3T3? and S3?, CNPS 1B.2

Habitat: Calochortus palmeri var. palmeri occurs in meadows, seeps, and vernally moist areas in chaparral, mixed conifer forest, and yellow pine forest at elevations of 3,300-7,200 feet (1,000–2,200 meters). Hoover describes habitat for Calochortus palmeri var. palmeri as being "along streamlets where soil is wet during growing season but drying in summer." Habitat near Chuchupate Ranger Station consists of the lower end of a small, moderately steep, moist meadow, with a moderate cover of grass and rush and a dense layer of leaf litter about 6-8 inches deep.

Distribution: Calochortus palmeri var. palmeri is sparsely distributed across central and from the Piute mountains, Tehachapi mountains and the La Panza Range south to the San Rafael, San Gabriel, San Bernardino, San Jacinto, and Santa Rosa mountains.

Herbarium specimens: None

Site visit or monitoring information: Weldon Meadow, CNDDB, 1994; Moreland Mill Area, CNDDB, 2009; Bright Star Mine Area, CNDDB, 2009; Piute Mountains, Travel Management Crew/Linton, 2004- 2005; Piute Mountains, Piute Salvage Crew/Linton, 2009.

Notes: None

Known threats: Recent focus on the Piute mountain area (of the Sequoia National Forest) for Timber/Furls/Forest Health Projects and Off Highway Vehicle use, has both threatened populations and expanded knowledge of Calochortus palmeri var. palmeri populations in this area.

Calochortus palmeri var. palmeri can be affected by overgrazing, trampling, flooding, erosion, off- highway vehicles, and development projects. The species is most vulnerable to impacts from grazing between April and August, when the plant is flowering and setting seed. This taxon is also affected by dispersed and developed recreation.

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Conclusion for Sequoia National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because inventories have discovered/expanded the occurrences/population of this species and monitoring has indicated a stable trend for the species. Species: Canbya candida, white pygmy poppy Forest(s) of Consideration: Sequoia National Forest

Rank: NatureServe G3, S3.2, CNPS 4.2

Habitat: Canbya candida is found on sandy, granitic soils, dry rocky areas, and openings in Joshua tree woodlands, pinyon-juniper woodlands, and Mojave Desert scrub habitat, at elevations of 1,970–3,940 feet (600–1,200 meters). It also occurs in areas with disturbed soils, such as fuel-breaks, areas within residential tracts, and roadsides.

Distribution: Canbya candida is endemic to the western Mojave Desert and adjacent mountain slopes in , San Bernardino, Kern, and Inyo counties In Kern County, Canbya candida is known from near Lake Isabella, Walker Pass, and Kelso Peak/Valley. Most occurrences of pygmy poppy are located on private lands.

Herbarium specimens: Cyrus Canyon, Ernest C. Twisselmann, 1971; Walker Pass, Neil Havlik, 1969.

Known threats: Canbya candida is threatened by development and competition with nonnative plant species. Potential threats include significant ground disturbance from recreational activities, road and trail maintenance and construction, small scale gold mining and associated dispersed use, and ongoing development of the major utility and transportation corridor through Cajon Pass. Too frequent fire with an increasing prevalence of cheatgrass, and the effects of fire suppression are also threats.

Conclusion for Sequoia National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because species is widely distributed and monitoring has indicated a stable trend for the species. Species: Cinna bolanderi, Bolander’s woodreed Forest(s) of Consideration: Sequoia and Sierra National Forests

Rank: NatureServe G2, S2, CNPS 1B.2

Habitat: Cinna bolanderi is endemic to meadows and streamsides in the montane zone of the western Sierran slope. Many sites are near groves of big trees (Sequoiadendron giganteum), but by no means all. Soil parent material varies from granitic to metamorphic.

Distribution: Cinna bolanderi is endemic to the southern and central Sierra Nevada, ranging from Tulare County to Mariposa County. Known occurrences are mostly known from Yosemite and Sequoia/Kings Canyon National Parks. There is currently one record each for the Sequoia and Sierra National Forests.

Herbarium specimens: Freeman Creek Grove, J. R. Shevock, 1975; Huntington Lake, Henry M. Pollard, 1951.

Three occurrences are currently documented for the Sierra National Forest.

In 2013 when the Sierra National Forest added Cinna bolanderi to the R5 Sensitive Species list (Clines, 2013), there was one historic location documented for the SNF, a 1951 collection by Pollard from Line

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Creek at Huntington Lake in Fresno County (CAS385175): Pollard s.n. 7/31/51, annotated as Cinna bolanderi by A.E.L. Colwell 4/5/2006; location given as Line Creek, Huntington Lake and vicinity; 7000’ elev.

This historic location needs to be revisited, but meanwhile in late summer 2013 two new occurrences were found in the Huntington Lake area by Forest Service botanists Belinda Lo and Anne Russell: Information from herbarium labels for those two new locations is below:

FRESNO COUNTY: Sierra National Forest, Deer Creek north of Huntington Lake Lat/Long: N37.258133º, W119.171417º Altitude 7140 feet. Growing in wet soil in seep along Deer Creek. Belinda Lo 6 with Anne Russell 7 August 2013 FRESNO COUNTY: Sierra National Forest, north of Bear Butte, meadow along Rancheria Creek Lat/Long: N37.256704º, W119.146798º Altitude 7080 feet. Growing in wet meadow with Glyceria sp., Geranium richardsonii, Heracleum maximum, and Salix sp. Belinda Lo 13 with Anne Russell 27 August 2013

As all 3 Sierra National Forest occurrences are in Fresno County at Huntington Lake. No records exist for the Mariposa or Madera County parts of the Forest.

Site visit or monitoring information: See above.

Known threats: Trampling by recreation (fisherman trials along streams), hydrologic alteration, grazing, and vegetation management. Most known occurrences of Cinna bolanderi are in National Parks and few threats have been observed to date. The two populations on National Forest System lands have not been observed for decades, and field work is needed to assess their level of protection.

The following disturbances have been observed by Yosemite National Park botanists: Bear trampling, deer browsing, social trails, trampling. The 3 occurrences in the Sierra NF are within a cattle grazing allotment where they may be subject to grazing and trampling; and near Huntington Lake, where recreation activity is high along streams each summer and soil compaction and denuding of vegetation occurs at the most popular spots.

Conclusion for Sequoia National Forest: There is substation concern about the species’ capability to persist over the long term in the plan area because of extremely limited distribution and identified threats.

Conclusion for Sierra National Forest: There is substantial concern about the capability of Cinna bolanderi to persist over the long term in the Sierra National Forest because the only 3 occurrences known to date are in riparian areas where livestock and recreation impacts occur. The species is known from fewer than 20 populations within the Sierra and Sequoia National Forests, Yosemite National Park, and Sequoia-Kings Canyon National Park. Species: Cryptantha incana, Tulare cryptantha Forest(s) of Consideration: Inyo National Forest, Sequoia National Forest

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Rank: G1, S1 (CA), 1B.3 (CNPS, 2016) Habitat: Gravelly or rocky area, open conifer forest, occasionally chaparral, 1770-3000 m elevation Distribution: southwestern High Sierra Nevada

Herbarium specimens: 69 Consortium records, including at least 10 from the Inyo National Forest, and many from the Sequoia National Forest (Baxter et al., 2016) Site visit or monitoring information from Inyo NF:

Sue Weis, Botanist, Inyo National Forest, Inyo National Forest Rare Plant Files, Note on Casa Vieja Meadow survey, 2010 Ron Kelley, Botanist, primary author of Cryptantha treatment in The Jepson Manual (Baxter et al., 2012), Inyo National Forest Rare Plant Files, Notes on Kern Plateau, 8/30/2006 Notes: Cryptantha incana was collected at both site visits above, and no threats were noted.

Transfer of collection information into the California Natural Diversity Database would help document the more common distribution of this species. Documentation of threats, if they exist, are also needed.

Known threats: None are given in California Natural Diversity Database (most recent information is 1965), CNPS Inventory (no changes since 2010), or Natureserve, and none were documented in the site visits or collections above.

Conclusion for Inyo National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because numerous collections from the plan area (both on Sequoia and Inyo National Forests) indicate that this species is much more common than previously thought, and that several occurrences could be added the California Natural Diversity Database. In addition, no threats have been documented. Natureserve indicates that ranks were assigned based on the very small number of occurrences, and that ranks have not been reviewed since 2005, and, thus, may need revision.

Conclusion for Sequoia National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because numerous collections from the plan area (both on Sequoia and Inyo National Forests) indicate that this species is much more common than previously thought, and that several occurrences could be added the California Natural Diversity Database. In addition, no threats have been documented. Natureserve indicates that ranks were assigned based on the very small number of occurrences, and that ranks have not been reviewed since 2005, and, thus, may need revision. Species: Delphinium inopinum, unexpected larkspur Forest(s) of Consideration: Sequoia National Forest, Sierra National Forest

Rank: NatureServe G3, S3.3, CNPS 4.3

Habitat: Delphinium inopinum inhabits dry, rock outcrops and open, rocky ridges in pine and red fir forests, at approximately 7,200 to 8800' feet. It is often found in association with Forest Service sensitive species Eriogonum twisselmannii, E. breedlovei var. breedlovei, and Oreonana purpurascens. The more

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rugged sites along the Monarch Divide are relatively stable, but the saddle along the top of Slate Mountain and the Piute Mountain habitats are more vulnerable to disturbances.

Distribution: Delphinium inopinum is found in the southern Sierra Nevada from Fresno County to Kern County. It is found in disjunct populations mostly in the Sequoia National Forest, the majority on the Monarch Divide, Slate Mountain, and the Piute Mountains, the Sierra National Forest (Monarch Divide), as well as in Sequoia NP and on BLM land (near Lamont Peak), from Fresno County through Tulare, Inyo, Kern, and Ventura Counties. Three occurrences straddle the Sierra and Sequoia national forests along the Monarch Divide.

Herbarium specimens: Greenhorn Mountains, O. H. Kapple, 1947; Bodfish Road, Ernest C. Twisselmann, 1956; Piute Mountains, D. E. Breedlove, 1962; above Saddle Springs Campground, Charlotte N. Smith, 1961; Black Mountain, James R. Shevock, 1983; Monarch Divide, T. Ross, 1990.

Specimens in CCH (Baxter et al., 2016) between July 1 and 4, 1990 are from the same collecting trip by Shevock, Ertter, Bartel, Clines, Berg, and Ross. E.g. CAS1097574. Specimens from this trip that were from populations that were on or partially on the Sierra NF are part of California Natural Diversity Database Element Occurrences 29-31, reported to California Natural Diversity Database by Jim Shevock in 1990.

Site visit or monitoring information: Sierra NF, 1997, F. Linton; Piute Mountains, F. Linton, 2004, 2005, 2006, 2007, 2012; Black Mountain, F. Linton, 2010; Slate Mountain, F. Linton, 2005, 2008, 2009, 2012, 2015.

CNDDB EOs 29, 30 and 31 straddle the Sierra and Sequoia National Forest boundary. Shevock (1990) stated that there were no threats and that the habitat was in excellent condition.

Known threats: On National Forest System lands in the Sierra Nevada, Delphinium inopinum faces threats from recreational activities, including off-highway vehicle traffic, and from logging and mining. The Summit National Recreation Trail (31E14) runs through the middle of the Slate Mountain occurrences, putting them at some risk of adverse impact from mountain bike, non-motorized traffic, and trail erosion/maintenance. The Piute Mountain occurrences also have potential threats from logging, mining, and dirt bikes.

The three occurrences (EOs 29, 30 and 31) that are within the Sierra National Forest in the Monarch Divide / Junction Ridge area are remote and extremely difficult to get to, and have been noted as having no threats in the past (Shevock, 1990). In the fall of 2015, the Rough Fire burned through at least part of the area where these 3 occurrences are mapped. The fire perimeter includes EOs 29 and 30, but not 31. Because the habitat is rocky / gravelly, it is possible that the occurrences were not burned, but field work is needed to assess how each occurrence was affected by the fire, if at all. The burned area emergency response botany report indicates that these occurrences may be vulnerable to invasive weed incursion. In addition, the potential effects of climate change could affect the species in the future, but the predictions are too nebulous at this time to add as a clear threat.

Conclusion for Sequoia National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because monitoring has indicated a stable trend for the species.

Conclusion for Sierra National Forest: There is substantial concern about the capability of Delphinium inopinum to persist over the long term in the Sierra National Forest due to the potential for the spread of invasive non-native weeds into habitat after the Rough Fire (Young and Linton, 2015). During the initial

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development of the proposed species of conservation concern list in 2014, there appeared to be no substantial concern about the capability of the three occurrences to persist over the long term in the Sierra National Forest. However, since then, the Rough Fire burned near or within the populations, and the potential for invasive weeds to spread is a new threat. Species: Delphinium purpusii, rose-flowered larkspur Forests of Consideration: Sequoia National Forest

Rank: Natureserve G2, S2 CNPS 1B.3

Habitat: Delphinium purpusii has been collected between 235 and 1495 m (770-4900 ft) in elevation. It has been found on slopes, hillsides, in washes, in ravines, in canyons, above streams, on cliffs, in talus, below or in crevices of rock outcrops, or near large boulders. Areas may be sunny or shaded, and dry to moist. Slopes may be flat to steep, and aspects from east- to north- to west-facing have been observed. The soil is sandy, gravelly, talus, or fractured rock, occasionally a clay loam, and derived mostly from granite or metamorphics, although it also may be a carbonate, and D. purpusii was particularly abundant on a marble outcrop at one site. The surrounding vegetation may be chaparral, foothill woodland, grey pine woodland, yellow pine forest, oak-buckeye woodland, oak woodland, pinyon-juniper woodland, Piute cypress forest, or riparian.

Distribution: This species is endemic to the southern Sierra Nevada, in Kern and Tulare Counties of California Most sites appear to be in the Kern River drainage. This species is known from 19 occurrences on Sequoia National Forest (CNDDB 2012).

Herbarium specimens: Bull Run Creek, J. R. Shevock, 1991; Piute Mountain Road, David Gowen, 2005; Wagy Flat, Ernest C. Twisselmann, 1965; Slate Mountain, Joan Stewart, 2004.

Site visit or monitoring information: Roads End - Kern River, F. Linton, 2007; Lower Kern Canyon, CNDDB, 2010; Piute Mountain Road, Wenk, 2010.

Known threats: Named threats to D. purpusii include grazing, development, foot traffic, dumping or litter, road or trail construction or maintenance, and impacts from non-native plants. At some sites, it was observed that the flowering stems were eaten off by deer. The collections made 1 year after a fire suggest that fire may be beneficial or at least not entirely harmful to this species.

Conclusion for Sequoia National Forest: There is substantial concern about the species’ capability to persist over the long term in the plan area because although sporadic monitoring has indicated a stable trend for the species, there are identified threats and limited distribution. Species: Dicentra nevadensis, Tulare County bleeding heart Forest(s) of Consideration: Sierra National Forest (Sequoia National Forest has this species already proposed as an species of conservation concern)

Rank: NatureServe: G3*/S4 CNPS: 4.3

Habitat: Sandy, gravelly crevices and openings in usually dry, granitic soils at approximately 7,500 - 10,000+ ft. Habitat potentially sensitive to disturbance.

Distribution: Three occurrences are now known on the Sierra National Forest, these constitute the northern distributional limit for the species as currently known. All 3 are within 2 miles of each other in the vicinity of Garlic Meadow, Rodgers Ridge, and Spanish Mountain. Southward within Tulare County,

37 Draft Biological Evaluation for Sensitive Plants there are about 40 occurrences on the Sequoia National Forest and Sequoia National Park. From the 2005 Rare Plant Evaluation Form prepared by the Sequoia National Forest:

Table 10. Herbarium specimens Collector(s) County Quad Date Location Land Elev. Habitat Comments and Manager in feet Accession ID James Fresno Rough 20 Oct North Slope USFS-Sierra 9500’ Base of No threats Shevock and Spur 1995 of Spanish NF, High granitic mentioned, Dana York (375-2) Mountain Sierra RD, (2896 boulders in a remote CAS110638 John Muir m) western wilderness 2 Wilderness white pine with no trail forest access. CAS930918 Collectors RSA620966 indicate SD231101 around 10 plants were seen. Helen Fresno Rough 04 Jul At USGS USFS-Sierra 9368’ On open Within an Sharsmith Spur 1969 bench-mark NF, High ridge-top in active CHSC20386 (375-2) 9368 feet, Sierra RD, (2856 metamorphic livestock west of and John Muir m) rocks, grazing below Wilderness southwest allotment, summit of exposure, but dry rocky Spanish with habitat on a Mountain, Chinquapin, ridgetop is east end of Jeffrey Pine, not likely to Rogers and Western be affected Ridge (due Juniper. by cattle. SE of Garlic Plants very Meadow) abundant in limited colony.

Collector(s) County Quad Date Location Land Elev. in Habitat Comments and Manager feet Accession ID Sierra NF Fresno Rough 07 Sep Rocky slope USFS, 9756’ Granitic and Adjacent to botanists Spur 2011 next to Sierra NF, (2974 metamorphic Garlic Sam Young (375-2) southern High Sierra m) talus at edge Meadow, (Coll. # 72) lobe of Ranger of Garlic which is and Christina Garlic District Meadow, on used by McAdams Meadow. (outside of a south- permitted wilderness) facing slope. livestock. Not flowering, 100s of Talus where will collect a plants but plants grow flowering needs field not specimen to work to accessible submit to confirm size by cattle. A UC/Jeps in of dozer line 2016 population. was constructed to population in 2015.

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Site visit or monitoring information: All 3 Sierra National Forest locations are within the perimeter of the Rough Fire, which burned in summer/fall of 2015. The Dicentra nevadensis site on the north slope of Spanish Mountain was last seen by Jim Shevock and Dana York in 1995, 21 years ago. The site to the west of that one has not been visited since Helen Sharsmith collected a specimen in 1969, to the best of our knowledge. The site adjacent to Garlic Meadow was discovered in 2011 by Forest Service botanist Sam Young, and though it was not flowering, experts familiar with the species confirmed the identification based on specimens and photographs. Whether or not the Rough Fire affected the 3 populations is unknown, but a dozer line was constructed to the rock slope where the Garlic Meadow population grows. Sierra National Forest botany personnel will visit the Garlic Meadow site in 2016 when the plant is blooming to determine whether or not there was damage. The other two sites will be surveyed in 2016 if possible, or within 2-3 years if not.

Known threats: When the species of conservation concern list was first drafted in 2014, the 3 Sierra National Forest occurrences appeared to have few to no threats aside from the unknown effects of climate change. Since that time, the Rough Fire occurred in summer and fall of 2015, and all three Sierra National Forest populations of Dicentra nevadensis are within the fire perimeter. Soil burn intensity maps indicate that the sites were either burned at low intensity of not burned (Takenaka, 2015), which makes sense given the rocky habitat with little fuel to carry a fire. A 6 mile dozer line terminates adjacent to the rocky habitat of the Garlic Meadow occurrence. The potential for invasive weeds to spread and alter habitat for Dicentra nevadensis is now more likely due to the dozer activity. The Sierra National Forest has burned area emergency response funds to survey for and treat invasive weeds, which should help minimize this possibility. In addition, although the Spanish Lakes off-highway vehicle route is shown on official maps as terminating at the John Muir Wilderness boundary, unauthorized driving off-trail and into the wilderness does still occur, against regulation.

Notes: The NatureServe site shows a G3 ranking rather than G4 as in the California Department of Fish and Wildlife’s list (see references below). With fewer than 50 occurrences in only two counties of the Sierra Nevada, G3 may be more suitable. The Sequoia National Forest populations face a variety of threats and the explanation above details threats facing the Sierra National Forest occurrences. A discussion with California Department of Fish and Wildlife and NatureServe is needed. If the G4 and other rankings are due to assessments made in 2001 by California Native Plant Society (as per Nature Serve) and threat levels are assumed low or nonexistent because Dicentra nevadensis is a Forest Service sensitive plant species, that logic falls away entirely if it isn’t included as an species of conservation concern and plan components therefore would not provide for its long term survival in the plan area.

Conclusion for Sierra National Forest: There is a substantial concern about the capability of Dicentra nevadensis to persist over the long term in the plan area because:

The dozer line built in late 2015 for the Rough Fire that ends directly at the Dicentra nevadensis population next to Garlic Meadow, this had not occurred when the initial draft species of conservation concern list was assembled.

Unauthorized off-highway vehicle use of unknown extent from the Spanish Lakes off-highway vehicle trail may be damaging occupied or suitable habitat for Dicentra nevadensis near Garlic Meadow.

The other two Sierra National Forest occurrences further to the east are small and subject to stochastic events (extreme weather, avalanches, climatic conditions that could alter sites unfavorably for persistence of Dicentra nevadensis).

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Species: Draba asterophora (previously D. asterophora var. asterophora), Tahoe draba Forest of Consideration: Inyo National Forest

Rank: G2T2, CA S2, NV S1S2, CNPS 1B.2

Habitat: Rock crevices, alpine barrens, talus, 2600-3300 m elevation

Distribution: n&c SNH (primary El Dorado and Alpine Counties); western Nevada, Washoe County

Herbarium specimens:

• 23 total Consortium records, none from within plan area • Single Consortium record (Smiley 776, 8/14/1916) from just outside Inyo NF on Mt. Gibbs, in Yosemite National park. Site visit or monitoring information

• Dean Taylor, Botanist, Inyo National Forest Rare Plant files, 8/12/1986 • Michèle Slaton, Botanist, Inyo National Forest, Inyo National Forest Ecological Plot Database, 6/2015 • Inyo National Forest Botany Personnel, Natural Resource Information System database Wilderness surveys, Summer 2000 • Surveys were conducted in the Mono Pass area for this species on these dates, but no positive identifications were made. Notes: California Natural Diversity Database Rarefind Note from Jim Morefield that occurrences outside Basin may be mis-identifications

Known threats: Potentially climate change or trampling by hikers, but this assumes correct identification and occurrence on Inyo National Forest at Mono Pass.

Conclusion: There is no substantial concern about the species’ capability to persist over the long term in the plan area because the single occurrence near the Inyo National Forest has not been relocated in 100 years, and other occurrences are long distances from the Forest. The taxonomic identification of the occurrence near the Forest has some uncertainty, and the actual location (if the identification is correct) is most likely outside the plan area. Species: Draba cruciata, Mineral King draba Forest(s) of Consideration: Inyo National Forest, Sequoia National Forest

Rank: G3, S3 (Natureserve, 2016), 1B.3 (CNPS, 2016)

Habitat: Gravelly slopes, subalpine areas, 2500-3050 m elevation (Baxter et al., 2016). Draba cruciata has been found at elevations between 2500 and 3380 m (8230-11100 ft), although it may occur as low as 2400 m (7870 ft) and as high as 3963 m (13000 ft). It prefers subalpine areas, gravelly or rocky slopes, ridges, crevices, cliff ledges, sink holes, and the edges of small drainages. It may be found among larger rocks or boulders. Slopes may be gentle to steep, and aspect may be west to northeast or variable. The soil is usually dry or moist, loamy with humus, clay, sandy, gravelly, or stony, and may be derived from

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granite, metamorphic, or marble. The surrounding vegetation is often red fir forest, white pine forest, lodgepole pine forest, subalpine coniferous forest, or a combination of these.

Distribution: Draba cruciata is said to be restricted to the Mineral King area of Tulare County, California, although there are specimens identified as D. cruciata from Jordan Peak in Tulare County and also in Mono and El Dorado Counties.

Herbarium specimens: Many collected in Tulare Co., outside the plan area. For the plan area, the collections considered include:

• D. cruciata var. cruciata, Smith & Sawyer 7786, 7/11/1974; E of Upper Gaylor Lake, Mono Co. (near INF) • D. cruciata var. integrifolia, Roos 2200, 8/8/1937; Sierra Nevada, Inyo Co. • D. cruciata var. integrifolia, Sharsmith 3353, 8/21/1937; above Mirror Lake, Lone Pine Creek • D. cruciata, DeDecker 4407, 9/5/1977; above Mirror Lake on Mt. Whitney trail • D. cruciata var. integrifolia, Ertter 5004, 7/30/1983; Matlock Lake, Independence Creek • D. cruciata var. integrifolia, Minnich, 7/26/1964; Trail Crest Pass, ca. 2 mi. S of Mt. Whitney • D. cruciata, Shevock 9901, 7/15/1982; ridge N of Jordan Peak ; Jordan Peak, J. R. Shevock & B. J. Ertter, 1988; Jordan Peak, Joan Stewart, 2001 (SQF) Site visit or monitoring information:

There are no records of D. cruciata in the plan area in the CNDDB (2016).

The Mirror Lake site was visited by Forest botany personnel in 2012, and the population was identified as D. sharsmithii.

No information was available for the D. cruciata occurrence on the Sequoia NF (CNDDB Occurrence #1) since the original collection in 1982 (Shevock 9901). CNDDB (2016) notes that the population is disjunct from the majority of occurrences around the Mineral King area and needs fieldwork.

Notes: D. cruciata var. integrifolia has been reclassified taxonomically by Baxter et al. (2016) as D. sharsmithii, which is included as a Species of Conservation Concern. Because DeDecker 4407 and Sharsmith 3353 in Lone Pine Canyon probably represent the same population, it is most likely that this population should be assigned to D. sharmithii.

The potential occurrence of D. cruciata on the Inyo National Forest is thus based upon the record from Smith & Sawyer 7786 for the Upper Gaylor Lakes. A note from Ann Howald from 2015 in the Consortium (Baxter et al., 2016) questions the location of the occurrence as being within Mono County; the description makes it seem more likely to be in Tuolomne.

Known threats: None known; none listed in California Native Plant Society (2016). Natureserve (2016) states “There are few, if any threats, but with about 11 known occurrences, it is quite rare although populations seem stable.”

Conclusion for Inyo National Forest: There is no substantial concern about the capability of Draba cruciata to persist over the long term in the plan area because it is not known to occur in the plan area.

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Conclusion for Sequoia National Forest: There is substantial concern about the capability of Draba cruciata to persist over the long term in the plan area because although sporadic monitoring has indicated a stable trend for the species, there is concern about extremely limited distribution. Species: Draba incrassata, Sweetwater Mountains draba Forest(s) of Consideration: Inyo National Forest

Rank: G3, S3 (CA), 1B.3 (CNPS, 2016)

Habitat: Alpine barrens, rocky slopes

Distribution: northern Eastern Sierra Nevada

Herbarium specimens: More than 40 collections from the Sweetwater Mountains., none from the plan area (Baxter et al., 2016).

CNDDB (2016) shows a collection from “Red Slate Mt. summit slopes, 13,000 + ft.” (Major and Major 1338; DAV #33897, 8/19/1962). It is unknown if the plant was present on the Inyo National Forest, although the mapped area is estimated as a 2/5 mi. radius, including the head of the Convict Creek and McGee Creek drainages. CNDDB (2016) states that field work is needed.

Site visit or monitoring information:

Botanical surveys were conducted on the shoulder of at McGee Pass by Forest botany personnel in 2001 and 2006, in support of packstation and trail project work. D. incrassata was not detected. However, areas over 13,000 ft. elevation were not visited.

Known threats: Potentially climate change. No other threats known.

Conclusion for Inyo National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because its occurrence in plan area has not been verified. A single collection was made more than 50 years ago, potentially outside the Inyo National Forest boundary, with no other information available for the species in the plan area. Species: Eriastrum tracyi, Tracy’s eriastrum Forests of Consideration: Sierra and Sequoia National Forests

Rank: NatureServe G3, S3, CNPS 3.2

Habitat: Chaparral, cismontane woodland; elevation 315 – 1645 meters; often along roads. Substrates described as gravelly shale above compacted clay soil, gravelly loam, coarse granitic sand, stony clay loam, or adobe. Associated with Pinus sabiniana, Juniperus, Artemisia tridentata, Cercocarpus betuloides, Ericameria, Chrysothamnus, Fremontodendron, Calocedrus decurrens, Quercus wislizeni, Arctostaphylos, Eriogonum fasciculatum, Eriodictyon californicum Salvia columbiariae, Avena barbata, Quercus lobata, Achnatherum speciosum, Bromus tectorum, Eriastrum pluriflorum, Ceanothus greggii, Bromus hordeaceus.

Distribution: Eriastrum tracyi occurs in the lower elevations of the eastern side of the southern , and also in the northern and southern Sierra Nevada foothills. It has populations on the Shasta- Trinity, Lassen, Sierra, and Sequoia National Forests.

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Herbarium specimens: Hill just east of Bodfish Gap, Ernest C. Twisselmann, 1966; Ten Mile Creek, James R. Shevock, 1981; Breckenridge Mountian, C B Hardham, 1957; Piute Mountain Road, R. Shevock, 1979.

Known threats: Threatened by off road vehicle use, competition from invasive species, development, grazing, campground expansion, and road maintenance, grading or widening; sand or salt buildup from snow removal.

Conclusion for Sierra National Forest:

Conclusion for Sequoia National Forest: There substantial concern about the species’ capability to persist over the long term in the plan area because of identified threats, limited distribution, and a lack of monitoring information. Species: Erigeron aequifolius, Hall’s daisy Forest(s) of Consideration: Inyo National Forest and Sierra National Forest (Sequoia National Forest includes this species as an species of conservation concern)

Rank: G2, S2.3 (CA; although California Native Plant Society (2016) states S3 for CA), CNPS 1B.3

Habitat: Rock ledges, crevices, 1500-2100 m elevation

Distribution: southern High Sierra Nevada. About 13 occurrences have been reported, primarily on the Sequoia National Forest and in Sequoia-Kings Canyon National Park.

Herbarium specimens: 14 collections in the Consortium (Baxter et al., 2016), none from the INF, several from the Boyden Cave vicinity of the Kings River Canyon.

Site visit or monitoring information:

The only information available for the INF is based on the California Natural Diversity Database record for occurrence #4, based on a field survey form from Norris L., 1982-07-23. The detailed location is given as, “ON OUTCROP ABOUT 30 METERS NORTH OF TRAIL AND JUST SOUTH OF CREEK. MAPPED IN THE NE 1/4 OF THE NE 1/4 OF ESTIMATED SECTION 21.” About 10 plants were seen at that time, though not all cliffs were searched.

The steep, rocky terrain of the Kern River drainage and distance required to travel by vehicle and by foot for those portions that occur on the INF have contributed to extreme infrequency in botanical surveys for habitat of E. aeqifolius.

The only information for the SNF is based on the California Natural Diversity Database occurrence #9, based on the field survey form from Dana York, reporting about 200 plants in 1995.

Notes: During the 2012 R5 Sensitive Species review, Inyo National Forest personnel stated, “Populations are relatively stable due to steep, rugged nature of the habitat, making them inaccessible for timber harvest, grazing, and most recreation.”

A different conclusion for Sequoia National Forest regarding species of conservation concern status of this species was due to the much greater potential for fuels projects in habitat for this species on the Sequoia National Forest; this threat is not present in habitat on the Inyo National Forest, nor on the Sierra National Forest.

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Known threats: No threats were noted by Norris in 1982 for the occurrence on the Inyo National Forest. Natureserve (2016) states that “threats are few due to inaccessibility”. During the 2012 R5 Sensitive Species review, Forest personnel stated, “The only potential threat for known [E. aeqifolius] populations, especially those along trails, would be from hikers/rock climbers. Likelihood of adverse impact is negligible.” For the Sierra National Forest occurrence, Dana York reported in 1995, “most species on limestone are native; rugged mountainous terrain with no trails; no threats.”

Conclusion for Inyo National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because no threats are known. In addition, it is likely that more populations may be detected in the currently unsurveyed terrain of the Kern River drainage.

Conclusion for Sierra National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because no threats are known. Species: Erigeron multiceps, Kern River daisy Forest(s) of Consideration: Inyo National Forest, Sequoia National Forest

Rank: G2, S2.2 (CA), S1 (NV; Natureserve, 2016), 1B.2 (CNPS, 2016)

Habitat: Habitat for Erigeron multiceps consists of primarily of sandy soils in a mixed alluvial woodland dominated by Pinus contorta and Populus balsamifera ssp. trichocarpa. and also on rocky riverbars/islands in sandy soils on sunny openings with moderate herbaceous cover and occasionally beneath a patchy overstory of Salix sp. Elevations range from 1500 to 2550 meters. On the Kern Plateau it is often found growing on previously disturbed sites, such as old logging roads, annual drainages and washes.

Distribution: Erigeron multiceps is restricted to the Northern portion of the Kern Plateau, the middle North Fork of the Kern River, and the Roaring Fork of the Kings River, all in Tulare County. On the Kern Plateau, occurrences are concentrated in the Jackass drainage on Sequoia National Forest lands, with a few found along the South Fork of the Kern River in the Kennedy Mdws. area, on the Sequoia National Forest. The middle North Fork of the Kern occurrences are north of the Kern Ranger Station along the Kern, in Sequoia NP and in the lower Little Kern on the Sequoia National Forest. One occurrence of Erigeron multiceps is found 25 miles north, both up and downstream of the Roaring River Ranger Station, in Kings Canyon NP. Also known from one site in the Spring Mountains of Clark County, Nevada.

Herbarium specimens:

20 collections listed in the Consortium, primarily from the Jackass Meadow and Kern River Flats areas in Kern and Tulare Counties. One from “Bloody Canyon”, with no additional information.

Milano (1992) specimen housed in Inyo National Forest Herbarium is from a population on the Sequoia NF, and notes “heavy grazing”

SQF: Bonita Meadows, J. R. Shevock, 1982; Kennedy Meadows, J. Stewart, 1999; Jackass Meadow, J. R. Shevock, 1982; Fish Creek, J. R. Shevock, 1984.

Site visit or monitoring information:

Gary Milano (1992, email to T. Ritter) reported the populations on the S Fork above and below Kennedy Meadows, elev. 6000 ft. to be 70% blooming.

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Kathleen Nelson reported on 7/9/1999 that she, Sue Weis, and Jim Shevock visited the population near Kennedy Meadows Campground during a Jepson Workshop. Population status and threats were not reported.

Jackass Creek, CNDDB, 1984 to 2013, stable increasing;

Fish Creek, CNDDB, 1984-2013; stable; Kennedy Meadows, California Natural Diversity Database; 1992 to 2012, stable increasing.

Notes: During the 1997 R5 Sensitive plant review, Sequoia National Forest botanist Linda Tanner-Sutton stated, “[E. multiceps] is often found growing on previously disturbed sites, such as old logging roads, annual drainages and washes.”

Known threats: Natureserve (2016) notes the threats of grazing, vehicles, logging, and recreation. Based on overlays of land use and road networks, it appears these threats may pertain to the Sequoia National Forest only. In addition, Teresa Ritter in 1993 remarked during a TES Plan Research and Liaison review that the Kern River daisy on the Sequoia National Forest is under a high level of stress due to activities, including grazing, heavy off-highway vehicle use, and possibly timber harvest. However, as described further above, these threats are not known on the Inyo National Forest; plants on the Inyo National Forest do not occur within a grazing allotment, there is no timber harvest in the area, the area is inaccessible by off-highway vehicle, and no site information is available regarding any other threats in the area.

Many colonies on the Sequoia National Forest are located adjacent to grazed meadows and dirt bike trails, which contribute to plant loss and habitat/soil disturbance.

Conclusion for Inyo National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because there is insufficient information to conclude that there is a substantial threat.

Conclusion for Sequoia National Forest: There is a substantial concern about the species’ capability to persist over the long term in the plan area because of limited distribution and identified threats. Species: Eriogonum alexanderae (E. ochrocephalum var. alexandrae) Alexander’s buckwheat Forest(s) of Consideration: Inyo National Forest

Rank: G5T2T3, S1 (CA), SNR (NV) (Natureserve, 2016), 2B.2 (CNPS, 2016)

Habitat: Clay soils, 1300-1700 m elevation, sagebrush and pinyon-juniper zones

Distribution: Known only from Nevada and from Mono County, California.

Herbarium specimens: Five collections in the Consortium (Baxter et al., 2016), with four from the same location in the plan area (Howald 3476, 3534, 3491, 3492), all from July 2015, E Mono Basin, Forest System Road 4N01, ca. 2 mi. S of intersection with Nevada Hwy 359.

Site visit or monitoring information:

Sue Weis, Inyo NF botanist, reported a survey of the population from July, 2015, which included an infestation of Halogeton glomeratus.

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Notes: Due to recent changes in taxonomic classification in this species, and to recent documentation of the species in California, there are apparent discrepancies in ranks as reported in the various references given below.

Known threats: Trampling (cattle and/or wild horses), invasive plant species, illegal off-highway vehicle use. California Native Plant Society (2016) lists gold mining as a potential threat, but this threat is not known in the vicinity of the occurrence in the plan area.

Conclusion for Inyo National Forest: There is a substantial concern about the capability of Eriogonum alexanderae to persist over the long term in the plan area because of the recently documented threats of invasive plants and trampling in this extremely small population. Species: Eriogonum ovalifolium var. monarchense, Monarch buckwheat (EROVM) Forest(s) of Consideration: Sierra National Forest (SCC for Sequoia NF)

Rank: NatureServe: G5T1/S1 CNPS: 1B.3

Habitat: Cracks and ledges of limestone formations, forming mats in sandy soil, 6030’ elevation.

Distribution: Eriogonum ovalifolium var. monarchense is known from a sole population consisting of fewer than 30 individuals in eastern Fresno County (CNPS, 2016; York, 2002, CDFW, 2016). The site is on limestone ledges on the north side of the Monarch Divide just below the ridge top. It appears to fall on both the Sierra and Sequoia National Forests on the Monarch Divide, within the Monarch Wilderness. Please see table 11 for herbarium data.

Table 11. Herbarium specimens/locations Collector(s) County Quad Date Location Land Elev. Habitat Comments and Manager in feet Accession ID Dana York Fresno Wren Jul 19, Approx. 86 Sequoia and 5900 Limestone Densely RSA669346 Peak 1995 km east of Sierra ledges on matted Fresno, National the N-facing buckwheat. Sierra Forests. side of Only 30 National Monarch individual Forest, Divide mats of this Monarch buckwheat Wilderness, observed. 2400m NW Each mat had of Boyden only a few Cave on the widely spaced N side of the Kings River s. canyon Dana York Fresno Wren Jul 31 2.4 KM N of Sequoia and 5953- Ledges and “ and Jim Peak 1995 Boyden Sierra 6030’ sandy soil Shevock. Cave National on limestone CAS1026991 36.83333 Forests. outcrops. JEPS102914 -118.81695 NY621735

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Site visit or monitoring information: As per York and Shevock (1995) and York (2002): Only 30 individual mats of this buckwheat have been observed at the one documented site. Each mat had only a few widely spaced . Flowers had white perianth segments with pink midribs. Eriogonum ovalifolium var. monarchense grows with: Pinus monophylla, Cercocarpus ledifolius var. intricatus, Yucca whipplei, Argyrochosma jonesii, Erigeron aequifolius, Erysimum capitatum, Garrya flavescens, Gilia yorkii., Heuchera rubescens var. rydbergiana, , Streptanthus fenestratus and Bromus madritensis ssp. rubens (a non-native grass).

Notes: For the first proposed species of conservation concern list, the Sierra National Forest Forest Botanist studied the location information in relation to the Sierra National Forest /Sequoia National Forest boundary and believed that the only known occurrence was strictly on the Sequoia National Forest. Further investigation indicates that the population likely includes at least a small amount of Sierra National Forest land.

Known threats: The primary threat to the continued existence of the taxon is that so few individuals are known to exist (< 30) over a small area of a few thousand square meters. A landslide or other stochastic event could potentially destroy the population (and thus the species), or leave so few genetic individuals that persistence is affected by a genetic bottleneck. The effects of climate change on this buckwheat are unknown, but if conditions at the only known location change significantly, the habitat may no longer support a vigorous, self-perpetuating population. In addition, the presence of the non-native, somewhat invasive red brome (Bromus madritensis var. rubens) could indicate encroachment of invasive non-native plants into the habitat.

Conclusion for Sierra National Forest: There is substantial concern about the capability of Eriogonum ovalifolium var. monarchensis to persist over the long term in the plan area because such a small population (30 individuals scattered over a few thousand square m) is much more vulnerable to extirpation or severe diminishment from random events or climate change than if the species occurred in more sites with greater population numbers. Species: Gilia yorkii, Monarch gilia Forest(s) of Consideration: Sierra National Forest (also proposed species of conservation concern on Sequoia National Forest)

Rank: NatureServe: G1/S1 CNPS: 1B.2

Habitat: Coarse sandy soil - and cracks of limestone formation in canyon live oak woodland.

Distribution: Gilia yorkii is known from only 3 occurrences in eastern Fresno County (CNPS, 2016; Shevock and Day, 1998; CDFW, 2016). One occurrence straddles the Sierra and Sequoia National Forests on a limestone formation of the Monarch Divide within the Monarch Wilderness. The other two occurrences are to the south. Please see table 12 for herbarium data and Map 1 for locations.

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Table 12. Herbarium specimens/locations (all fall within the Wren Peak 7.5’ quad) Collector(s) and County Date Location Land Elev. Habitat Comments Accession ID Manager in m. (feet) Dana York with Fresno Jul 19, 2.4 km NW Sequoia and 1800 Coarse The flowers James Shevock 1995 of Boyden Sierra (5904) sandy soils are light CAS1089953 Cave on the National on a flat purple or Also: N side of the Forests. ridge top on white. Kings River the Dana York Sierra NF 36.83555 - limestone CAS1089949 Occurrence 118.82194* segment of number: (October 13, Monarch *Mapped in GIYO-15-01 1995) GIS ~150 m to Divide. the west of the waypoint shown in CCH because the lat/long shown is outside of the limestone Dana York and Fresno Jun 27, 1 km S of Sequoia NF 1290 SE-exposed A very local James Shevock 1996 Boyden (4231) limestone. annual with CAS1027812 Cave on the pale S-side of the lavender Kings River corollas Canyon found on SE- 36.80555 - exposed 118.81111 limestone Dana York Fresno Sep 300 m. Sequoia NF 1305 Limestone Senescent CAS1089954 22, S/SW of (4280) ridge top in a plants 1995 Boyden saddle Cave. above 36.81388 - Church & 118.81944 Boyden Caves.

Site visit or monitoring information: From the herbarium label for York’s October 13, 1995 collection from the Sierra/Sequoia National Forests: “Found in coarse sandy soils on flats and in cracks on the limestone segment of the Monarch Divide. Xerophytic habitat conditions due too intense exposure to the sun and wind. Associates: Bromus madritensis ssp. rubens, Cercocarpus intricatus, Cercocarpus ledifolius var. intermontanus, Garrya flavescens, Heuchera rubescens, Pinus monophylla, Streptanthus fenestratus, and Yucca whipplei”

Known threats: The primary threat to the continued existence of Gilia yorkii is its extreme rarity. The Sierra/Sequoia National Forests population is on ultra-steep slopes on the Monarch Divide far removed from trails and so difficult to access that few human-caused threats are likely. The effects of climate change on this annual plant adapted to extremely harsh conditions are unknown, but with warmer average temperatures and possibly less average annual precipitation, the habitat may no longer support a self- perpetuating population over the long term. In addition, the presence of the non-native, somewhat invasive red brome (Bromus madritensis var. rubens) could indicate encroachment of invasive non-native plants into the habitat.

Conclusion for Sierra National Forest: For the first draft proposed species of conservation concern list released for public review in July 2016, the lack of obvious immediate threats precluded proposing Gilia yorkii as species of conservation concern.

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Further review resulted in a revised conclusion: based on the information presented in this form, there is substantial concern about the capability of Gilia yorkii to persist over the long term in the plan area because of the extreme rarity of the species (predisposing the one Sierra National Forest population to extirpation by stochastic events – e.g. severe weather), and the potential effects of climate change and competition from annual non-native grasses. Species: Heterotheca monarchensis, Monarch goldenaster Forest of Consideration: Sequoia National Forest, Sierra National Forest

Rank: NatureServe G1, S2, CNPS 1B.3

Habitat: Heterotheca monarchensis is found scattered on south-facing slopes of limestone in cracks, ledges and flats, with higher densities of plants seen in the coarse sandy flats at the base of cliffs, from 3650 - 6000 feet elevation. Growing with mountain mahogany, canyon live oak and pinyon pine, on SE- facing crevices and gravel of carbonate formation, Kings River Canyon. The 3 known occurrences are on Sequoia National Forest in the Kings River canyon, vicinity of Boyden Cave. Currently there are no confirmed plants or populations within the Sierra National Forest boundary.

Distribution: Known from three occurrences on the Windy Cliffs limestone formation northeast and southwest of the Horseshoe Bend of the Kings River (both sides of the Kings) near Boyden Cave. To date, known only from these areas. In these limited areas it occurs, it can be locally abundant.

Herbarium specimens: Windy Cliffs - Monarch Wilderness, Dana York, 1996; Windy Gulch - Monarch Wilderness, Dana York and Jim Shevock, 1996.

All three locations documented in Rarefind (CDFW, 2016) and the California Consortium of Herbaria (Baxter et al., 2016) are in the Sequoia National Forest, at least 0.4 miles from the Sierra National Forest boundary. Accession numbers are CAS1120280, JEPS96214, and UCD133009.

Site visit or monitoring information: The nearest occurrence to the Sierra National Forest boundary is mapped as occurring about 0.4 miles from the Sierra/Sequoia national forest boundary on Monarch Divide. Dana York’s site information (CDFW, 2016) states that clumps were growing on and below the Monarch Divide, but the mapped site is shown only as below the ridge. York also determined that the population was in the Sequoia National Forest, not both Sequoia and Sierra National Forests.

Known threats: The only discernible threat may be competition from exotic annual grasses and disturbance associated with fire suppression activities.

Conclusion for Sierra National Forest: There is no concern about the species’ capability to persist over the long term in the plan area because its occurrence has not been confirmed in the plan area.

Conclusion for Sequoia National Forest: There is concern about the species’ capability to persist over the long term in the plan area because of extremely limited distribution and threat data. Species: Horkelia parryi, Parry’s horkelia Forest of Consideration: Sierra National Forest

Rank: G2, S2 (CA; Natureserve, 2016), 1B.2 (CNPS, 2016)

Habitat: Open areas in chamise chaparral and knobcone pine forest on metamorphic soils (Sierra National Forest)

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Distribution: Four counties in Sierra Nevada: Amador, Eldorado, Calaveras, Mariposa.

Site visit or monitoring information: New information indicates that this species benefits from land treatments that maintain an open canopy, e.g. when first discovered on the Sierra National Forest in 2002 along a road where clearing on either side during suppression of the 2001 Briceburg Fire seemed to facilitate emergence and vigorous growth of 100s if not 1000s of plants (they had not been visible during previous field surveys along this road by Sierra National Forest botanists). Subsequent mastication treatments in 2010 and 2011 similarly appeared to benefit the population. By 2011 plants were so abundant that patches appeared merged and Horkelia parryi was the primary ground cover over possibly several acres. However, the Sierra National Forest has not GPSed the boundaries of the occurrences as they now exist, and doesn’t have a current count of individuals or clumps to support the hypothesis that this species doesn’t need special protection. Because there are only 3 occurrences on the Sierra National Forest, and off-highway vehicle activity is common and often off-route (illegally). Monitoring has not been done to support field observations that plants are spreading, reproducing, and thriving where very light canopy is maintained.

Known threats: Invasive non-native species, unauthorized off-highway vehicle travel, improperly timed mechanical treatments.

Conclusion for Sierra National Forest: There is substantial concern about the capability of Horkelia parryi to persist within the plan area because there are only 3 known occurrences, and threats exist (invasive weeds, off-highway vehicle). Species: Hulsea brevifolia, short-leafed hulsea Forest(s) of Consideration: Sierra National Forest (proposed species of conservation concern for Inyo and Sequoia National Forests)

Rank: NatureServe: G3/S3 CNPS: 1B.2 (CDFW 2016, CNPS 2016)

Habitat: Forest floor and openings in montane coniferous forest, upper montane coniferous forest, and subalpine forest. Soils are coarse granitic or metamorphic soils (volcanic). Often abundant after fire and other disturbance that reduces canopy cover temporarily.

Distribution: Tuolumne County to Tulare County, encompassing short-leafed hulsea documented on the Sierra National Forest, and others on adjacent Forests and in Yosemite National Park totaling about 70 occurrences. The Sierra National Forest is in the process of compiling and updating records for this species and will provide data to California Department of Fish and Wildlife.

Known threats: Hazard tree removal after 4 year drought, invasive non-native plants, road maintenance.

Conclusion for Sierra National Forest: There is a substantial concern about the capability of Hulsea brevifolia to persist over the long term in the plan area because many populations consist of small numbers of plants, and though the species often thrives after fire and along road cuts, the extreme tree mortality between 3000 and 6000 feet on the Sierra National Forest in 2015 and 2016 brings additional threats due to the need for largescale falling and moving of dead trees in habitat of Hulsea brevifolia. Species: Hulsea vestita ssp. pygmaea, pumice hulsea Forest(s) of Consideration: Inyo National Forest, Sequoia National Forest

Rank: G5T2, S2.3 (CA; Natureserve, 2016), 1B.3 (CNPS, 2016)

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Habitat: Subalpine forest and alpine barrens, from 3200-3900 m elevation.

Distribution: Known only from San Bernardino and Tulare Cos. in California. Natureserve (2016) reports the Tulare population as possibly extirpated.

Herbarium specimens: Many collections listed in the Consortium for San Bernardino County. (Baxter et al., 2016). For the plan area:

• Purpus 5196, 9/1/1897, Little Kern, Tulare Co. (Sequoia National Forest) • Twisselmann 15763, 7/30/1969, East Sirretta Pass, Kern Plateau, Tulare Co. (Sequoia National Forest) • Major et al. s.n., 8/6/1966, E side Mt. Tom, Sierra Nevada (Inyo National Forest) • Howe 3048, 4/26/1961, N of Westgard Pass, White Mountains. (Inyo National Forest) Site visit or monitoring information:

Numerous project surveys (CARMA, Travel Management) from 2001-2011 included inventory of the Westgard Pass area, including attempted relocations of the Howe 3048 record (Inyo National Forest Natural Resource Information System database, 2016). The species has not been relocated in this location since the original collection in 1969.

The East side of Mt. Tom has not been extensively surveyed botanically. The Major et al. record has not been relocated since its original documentation in 1966. It seems likely to be a mis-identification.

A single occurrence is reported in the California Natural Diversity Database for the Sequoia National Forest, at the headwaters of the Kern River, representing a likely location for the Purpus 5196 collection. CNDDB (2016) reports the “collection presumed to be from the headwaters of the Little Kern River per B. Ertter, in “On the Trail, with Purpus, in California”, University and Jepson Herbaria Website.”

Notes: Natureserve ranks as listed on their website and on the California Native Plant Society Inventory are inconsistent as of 4/26/2016.

Known threats: California Native Plant Society (2016) reports recreational activities as a potential threat across the species’ distribution. No other threats are known.

Conclusion for Inyo National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because reported occurrences have not been relocated in 40+ years; there is insufficient information positively documenting its current occurrence in the plan area.

Conclusion for Sequoia National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because reported occurrences have not been relocated in 40+ years; there is insufficient information positively documenting its current occurrence in the plan area. Species: Leptosiphon serrulatus, Madera leptosiphon Forest(s) of Consideration: Sierra National Forest (previously proposed species of conservation concern for Sequoia National Forest)

Rank: NatureServe: G3/S3 CNPS: 1B.2 (CDFW 2016, CNPS 2016)

Habitat: Dry slopes in cismontane woodland and lower montane coniferous forest, mostly in decomposed granite soils, but at least one in serpentine soils. Sites apparently vary from well-vegetated

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areas in blue oak woodland to more open, rocky sites. Although most are documented from blue oak woodland at lower elevations (below 3500 feet), at least 2 are known from mixed conifer forest above 5,000 feet where winter snow remains for several months.

Distribution:

West slope of the Sierra Nevada from Mariposa County south to Kern County.

Herbarium specimens/locations:

Mariposa County: At least 5 occurrences are documented in the vicinity of Mariposa outside the Sierra National Forest. The dates for these specimens range from 1890 – 1957 (CCH 2016, CNDDB 2016). Field work is badly needed to confirm the presence of these populations.

Madera County: About 5 occurrences are shown in the Consortium of California Herbaria (2016) – date of collection ranges from 1889-1932. Herbarium specimens at the California State University, Fresno (FSC) not yet in the Consortium of California Herbaria include a Madera County specimen made by Quibell in 1930 (FSC 1888) south of Fish Camp, along the “Fresno-Madera-Wawona Road” near Sugar Pine. This occurrence likely falls within the Sierra National Forest, but it needs field work to confirm. A 1935 collection (UC 623394) from the San Joaquin Experimental Range, if extant, would occur on lands managed by U.S. Forest Service Pacific Southwest Research Station and CSU Fresno.

Fresno County: At least 10 occurrences are found in Fresno County (CCH 2016). Most are historic and need current fieldwork. About 5 fall within the Sierra National Forest: Chris Winchell discovered a population on Cripe Road (south of Peterson Road) near Tollhouse in 2005 (EO 24, CNDDB, 2016). He noted about 100 plants and rated the site as in “good” condition. Winchell also discovered a population of about 400 plants along Forest Road 8S05 (“Million Dollar Mile”), primarily managed by Southern California Edison Co. This site was also deemed in “good” condition (EO 25, CNDB, 2016). Forest Service botanists looked specifically for plants in the area described in EO 12, along Trimmer Springs Road, and have been unable to relocate it to date. Other than the recent occurrences found by Chris Winchell, all Fresno County collections are from 1923-1960. Dana York made a specimen in 1997 of an occurrence that appears to correspond with California Natural Diversity Database EO No. 11 (JEPS119148), in the vicinity of Haslett Basin (Sierra NF). He didn’t state a number of plants, but wrote that they occurred in a “clump” along Forest Road 10S69 (York 1999, CCH 2016).

Site visit or monitoring information: Historically documented from approximately 30 occurrences, few of which have been seen in the last several decades. One occurrence at Millerton Lake in Fresno County (California Natural Diversity Database Element Occurrence No. 9) was extant within the last few years (pers. comm. Christopher Winchell). As described in the section above, 2 occurrences were discovered in Fresno County in 2005 by Chris Winchell, these are in “good” habitat along Forest Roads. Field work is needed to assess the status of this species.

Known threats:

Invasive non-native plants, road maintenance, livestock overuse.

As most occurrences fall outside of public lands, protection varies from none for private land (or protection under CEQA) to protection/conservation on National Forest System lands by virtue of the requirement for National Environmental Policy Act analysis prior to ground-disturbing projects.

Conclusion for Sierra NF: For the first draft proposed species of conservation concern list released for public review in July 2016, the Sierra National Forest Forest Botanist inadvertently left Leptosiphon

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serrulatus off the species of conservation concern list. It is currently a Forest Service sensitive plant species. There is substantial concern about the capability of Leptosiphon serrulatus to persist over the long term in the plan area because at this time Sierra NF botanists have been unable to find several historic occurrences listed in California Natural Diversity Database or the Consortium of California Herbaria. There is a concern that these previously documented occurrences have been extirpated; more field work and documentation is needed. Species: Lupinus lepidus var. culbertsonii, Hockett Meadows lupine Forest(s) of Consideration: Inyo National Forest, Sequoia National Forest, Sierra National Forest

Rank: G3?T2, S2 (CA; Natureserve, 2016), 1B.3 (CNPS, 2016)

Habitat: Rocky slopes, 2500-3000 m elevation (Baldwin et al., 2012); Meadows and seeps in upper montane coniferous forest (mesic, rocky) (CNPS, 2016)

Distribution: southern High Sierra Nevada, though many identifications are questionable (see below)

Herbarium specimens: More than 20 collections are recorded in the Consortium (Baxter et al., 2016).

• Sharsmith 3438, 8/27/1937; Boreal Plateau SW of Siberian Outpost (INF) • Ferris and Lorraine 10695, 7/20/1942; N face of Farewell Gap (SQF) • Everett and Balls 21995, 7/9/1956; Mammoth Lakes vicinity (INF) • Davidson s.n., 7/9/1973; ca. 1 mi. upstream from Lundy Lake (INF) • Halperin & Crafts 445, 8/1/1932; near Rock Creek Lake (INF) • Rice 369, 7/18/1966; Farewell Gap (SQF) • Rice et al. 151, 6/28/1966; Upper Franklin Lake (SQF) • Rice 494, 8/5/1966; Empire Mt. and Timber Gap (SQF) • Taylor 7922, 8/9/1981; Coyote Ridge (INF) • Reveal et al. 7922, 8/9/1981; along Piute Creek trail, Humphrey Basin (SNF) • Long, 8/14/1942; between Golden Trout Camp and Lake Muir (INF) Site visit or monitoring information:

California Natural Diversity Database (2016) maps five occurrences, with three on National Park Service lands, and two on the border of the Sequoia National Forest and Sequoia-Kings Canyon National Park. Occurrence #3 information includes the “only source of information a 1904 collection by Culbertson and a 1959 collection by Hardham. Needs fieldwork.” Occurrence #5 is based on the Ferris and Lorraine 10695 collection, with no additional information since 1942.

Notes: Teresa Sholars email to S. Weis 2/17/2010: “I have looked for this taxon but have not seen it. According to Cox who did his Ph.D these on the group this taxon is only found in a narrow region along the Kaweah River in Tulare Co. and at Farewell Gap”

Ann Howald email to S. Weis 11/4/2014: “…Lupinus lepidus varieties are a complicated group… identification of many individual collections seem somewhat random, when you look through the folders.

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Hardly any specimens have been annotated, and none by Teresa Sholars, who wrote the key. I found out that most specimens labeled as L. l. var. c. at RSA and UCR, definitely aren’t that variety… I did not find any specimens from Mono Co. that looked exactly like var. culbertsonii.”

Known threats: Natureserve (2016) reports that little is known about threats or trends, but that there are likely no threats due to its occurrence almost solely on National Park Service lands.

Conclusion for Inyo National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because there is insufficient information about the species; no collections could be verified to be this species, and no occurrences have been relocated in over 30 years.

Conclusion for Sierra National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because there is insufficient information about the species; no collections could be verified to be this species, and no occurrences have been relocated in over 30 years.

Conclusion for Sequoia National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because there is insufficient information about the species; no collections could be verified to be this species, and no occurrences have been relocated in over 30 years. Species: Mentzelia torreyi, Torrey’s blazing star Forest(s) of Consideration: Inyo National Forest

Rank: G4, S2 (CA; Natureserve, 2016), 2B.2 (CNPS, 2016)

Habitat: Sandy to alkaline fine-textured soils, slopes, scrub, pinyon woodland, 900-2100 m elevation

Distribution in plan area: eastern Sierra Nevada

Herbarium specimens: Over 40 collections in the Consortium from Inyo and Mono Counties. (Baxter et al., 2016). Many are from the Bridgeport area, Owens River gorge and Volcanic Tablelands, primarily outside the plan area. Collections from the plan area include:

• Taylor 4870, 7/17/1982; Black Point, N side Mono Lake • Wood 249, 8/14/1970; N shore of Mono Lake, E of Black Point • Taylor 6080, 7/30/1976; E base of Black Point • DeDecker 4412, 9/22/1977; NE of Black Point • Peirson 9200, 8/12/1930; Mono Lake • Sharsmith 9226, 8/18/1991; 9236, 6/27/1992; Black Point • Schweich 587, 7/8/2009, Black Point • Howald 3532, 8/3/2015, East Mono Basin, ca. 2 mi. S of intersection with NV Hwy 359, and ca. 0.3 mi. E • Schweich 1162, 6/24/2015, Mono Lake Basin Warm Springs • Peirson s.n., 1933, North shore of Mono Lake Site visit or monitoring information:

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Several field surveys by Forest botany personnel 2009-2015 show infestations of Russian thistle (Salsola sp.), cheatgrass (Bromus tectorum), and salt-lover (Halogeton glomeratus) in the northern Mono Basin.

Inyo NF botanist Sue Weis recorded the population recorded by Howald 3532 in the Forest Natural Resource Information System database in 2015, and Michèle Slaton recorded 1% cover for M. torreyi in a Forest ecology plot on the shore of Mono Lake at Black Point in 2011.

Known threats: Invasive plants, mining. Possibly threatened by vehicles, grazing, and trampling (CNPS, 2016).

Conclusion for Inyo National Forest: There is substantial concern about capability of Mentzelia torreyi to persist over the long term in the plan area because many threats, most significantly invasive weeds, have been identified in its highly restricted distribution. Species: Mielichhoferia elongata, elongate copper-moss Forest(s) of Consideration: Sequoia and Sierra National Forests

Rank: NatureServe G4 TNR, S4, CNPS 4.3

Habitat: Mielichhoferia elongata grows on metamorphic, sedimentary, limestone, granite and serpentine rock outcrops that often contain copper or other heavy metals and that are seasonally moist or less commonly on moist soil. Occurrences are generally small and isolated. Habitat is usually in foothill woodland habitats dominated by oaks or chaparral and sometimes with scattered incense cedar, Douglas- fir, and ponderosa pine. The species grows from sea level to 3550 feet.

Distribution: Mielichhoferia elongata is known from the Northern America, Europe and Asia. In North America it is known from Ontario, Canada and Maine west to California and Northwest Territories. In California, it is known from 3 disjunct portions of the state: the Sierra Nevada Mountains in Mariposa, Placer, Fresno, Tulare counties; the Siskiyou Mountains in Siskiyou, Humboldt, Trinity counties; and the central coast in Santa Cruz county. Out of the 41 occurrences in California, 14 are from National Forest System lands. Within the Plan area, two occurrences are on the Siarra National Forest and 3 are on the Sequoia National Forest, in the Kings River Gorge in Fresno County.

Herbarium specimens: Windy Gulch, J. R. Shevock, 1995; Boyden Cave, J. R. Shevock, 1996; Camp 4 – Kings River, J. R. Shevock, 1996; Secate Ridge, J. R. Shevock, 1996; Big Creek, J. R. Shevock, 1996.

Site visit or monitoring information: None

Known threats: Many populations are roadside and could be impacted from road realignment or Highway expansion projects. Mining could have impacts to this species, given its affinity for substrate rocks high in heavy metals.

Conclusion for Sequoia National Forest: There is no substantial concern about the species’ capability to persist over the long term because it appears to be stable and has a circumboreal distribution.

Conclusion for Sierra National Forest: There is no substantial concern about the species’ capability to persist over the long term because it appears to be stable and has a circumboreal distribution. Species: Mimulus gracilipes, slender-stalked monkeyflower Forest(s) of Consideration: Sequoia National Forest (also species of conservation concern on Sierra National Forest)

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Rank: NatureServe G2G3, S2S3, CNPS 1B.2

Habitat: Open sandy and gravelly flats associated with granitic outcrops in chaparral, foothill woodland, and lower mixed conifer forest, as well as burned areas in these same vegetation types. Size of populations varies dramatically in relation to disturbance and rainfall. In good rain years populations can consists of many thousands of robust, large-flowered plants. M. gracilipes responds to wildfire by producing masses of plants, often larger than normal and with more and showier flowers

Distribution: Mimulus gracilipes is known from Mariposa, Madera, and Fresno Counties. It is confirmed in the Sierra National Forest and Yosemite National Park and in several locations downslope and off the Sierra and Sequoia National Forests in the vicinity of Bootjack and Ahwahnee. There is an occurrence near Dunlap close to the Fresno/Tulare county line near the Sequoia National Forest. Elevation ranges from 1500 to at least 4500 feet.

Herbarium specimens: Miramonte, Robert G. Linderman, 1960; San Jose Basin, S. E. Schoenig, 1998; East of Tollhouse, Dana York, 1998.

Known threats: Potential threats are: residential development on private land, competition from noxious weeds such as yellow starthistle, road maintenance and construction; improperly timed fuels or timber treatments, possibly lack of fire, since this Mimulus appears to behave as a "fire follower" (fire annual). In addition, off-highway vehicle use, and possibly invasive non-native grasses are becoming more prevalent in the habitat, even more so after fires.

Conclusion for Sequoia National Forest: There is concern about the species’ capability to persist over the long term in the plan area because of limited distribution and lack Monitoring makes it impossible to determine population and species trends. Species: Monardella linoides ssp. oblonga, Tehachapi monardella Forest(s) of Consideration: Sequoia National Forest

Rank: Natureserve G5T2 and S2, CNPS 1B.3

Habitat: Monardella linoides ssp. oblonga grows among rock outcrops and general openings in mixed conifer forests, yellow pine forests, pinyon-juniper woodlands, and desert scrub habitat.

Distribution: The California Natural Diversity Database contains records for ten occurrences of Monardella linoides ssp. oblonga, all on National Forest System lands. Nine of the occurrences are found on the Los Padres National Forest, and more potential habitat exists that has yet to be surveyed. The tenth occurrence is found on the Sequoia National Forest. The Sequoia National Forest occurrence is east of Tobias Peak in the Kern River Canyon, and needs to be relocated. On the Los Padres National Forest Monardella linoides ssp. oblonga is found in the western Transverse Range in a polygon delimited by the following: Cerro Noroeste in the northwest, Frazier Mountain in the northeast, Alamo Mountain in the southeast, and San Guillermo Mountain in the southwest.

Herbarium specimens: Long Canyon, J. R Shevock, 1984; Danner Meadow, J. R. Shevock, 1982; Lookout Point, Ernest C. Twisselmann, 1962.

Site visit or monitoring information: Cherry Hill Road, McNally Salvage Crew, 2004-2005; Upper Piru Creek; Mount Pinos, Foster, 1999.

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Known threats: This taxon is known to respond positively to wildfire events; however, some occurrences are vulnerable to road/trail maintenance and off-road vehicle activity. Monardella linoides ssp. oblonga is found on road cuts, in campgrounds, adjacent to off-highway vehicle trails, adjacent to hiking trails, and in areas subject to fuels management. Where plants are found in road cuts, 'source' populations are present above the road cut in most instances. Plants found adjacent to off-highway vehicle and hiking trails do not appear to be adversely affected by this land use. Where plants are present on both sides of a trail it is obvious that plants were lost during trail construction. Some plants have also been noted to be impacted by mountain bike use of hiking trails where bicyclists have gone off trail.

Conclusion for Sequoia National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because inventories have discovered/expanded the occurrences/population of this species and monitoring has indicated a stable trend for the species. Species: Peltigera gowardii, western waterfan lichen Forest of Consideration: Inyo National Forest, Sequoia National Forest, Sierra National Forest

Rank: G3G4, S3 (CA; Natureserve, 2015), 4.2 (CNPS, 2016)

Habitat: Rocks in cold water creeks

Distribution: Nine counties in Sierra Nevada in California; Mt. Dana area in Mono County; also Montana, Oregon, Washington

Herbarium specimens:

1. None in Consortium of California Herbaria (http://ucjeps.berkeley.edu/consortium/) 2. Single record from Larson (2005) about an occurrence in the “hanging meadow” of Mt. Dana (Inyo National Forest) Site visit or monitoring information:

1. Sequoia National Forest: Slate Mountain, J. R. Shevock, 1980; Sugarpine Hill, California Natural Diversity Database, 2008 2. Nine occurrences are mapped for the Sierra National Forest in California Natural Diversity Database (2016), however the Sierra National Forest has at least 40 locations. In some cases what had been thought to be two occurrences turned out to have the lichens present continuously, thus 2 were combined into one. The Sierra has specimens to submit to UC/Jeps and will soon provide a shapefile and photographs of some occurrences to California Natural Diversity Database. After teaching field survey crews (botany, timber markers, wildlife, hydrology) to recognize this lichen, many new reports began coming in to Sierra National Forest botanists (since 2009), and were confirmed. 3. CNDDB (2016) reported that the hanging meadow location on Mt. Dana (Inyo National Forest) could not be identified, so the population was mapped as a best guess. 4. Michèle Slaton, Inyo National Forest Botanist, Inyo Inyo National Forest Ecological Plot Database, 8/2013 - did not identify any threats to meadow habitat on Mt. Dana Notes: Lichen specialist, Kerry Knudsen, will be surveying for this species in the Tioga Pass area in 2016, and will report any new locations to the Inyo National Forest.

Very few field botanists are trained in lichen identification. Additional surveys and collection are needed to better document the distribution of this species in the plan area, and potential threats to persistence.

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Known threats: Hydrologic alterations, recreational activities, erosion, logging, vehicles; however, none of these apply to the location of this species on the Inyo National Forest. The species is sensitive to water pollution, but there are no known pollution sources in its location in the plan area.

Natureserve identifies climate change as a threat; as trees move upward, habitat for this species may become unfavorably shaded. However, the location on the Inyo National Forest is not undergoing initial invasion of conifers into the habitat (NAIP imagery, 2015). The location is extremely rocky, consisting of exposed talus and rock glaciers, and is not likely to become suitable for conifer growth in the next several decades. Furthermore, loss of shade which contributes to higher water temperatures would more likely be a concern; the 2010 Conservation Assessment states that most known occurrences in California, Oregon, and much of Washington are partially shaded and at mid-elevations, with one exception.

On the Sequoia National Forest, in addition to the threat of climate change affecting known populations, mountain roads can concentrate water flow and divert natural water drainage systems. At higher elevations, recreation can threaten P. gowardii habitat by changing water flows and increasing sediment loads.

Conclusion for Inyo National Forest: There is no substantial concern about the capability of Peltigera gowardii to persist over the long term in the plan area because known threats identified for this species do not occur in the habitat where this species is found. There is also no evidence of other threats to its persistence in its current known location. In addition, it is likely that additional field surveys by qualified personnel would identify additional occurrences in the plan area.

Conclusion for Sequoia National Forest: There is concern about the species’ capability to persist over the long term in the plan area because of identified threats and limited populations.

Conclusion for Sierra National Forest: There is no substantial concern about the capability of Peltigera gowardii to persist over the long term in the plan area because known threats identified for this species are addressed and minimized during project planning, and in the last few years, numerous additional occurrences have been discovered (bringing the Sierra National Forest total to at least 40), several of which are extensive and vigorous (Sierra National Forest data to be supplied to California Department of Fish and Wildlife, California Native Plant Society). Species: Phacelia novenmillensis, Nine Mile Canyon phacelia Forest(s) of Consideration: Sequoia National Forest

Rank: Natureserve G3, S3, CNPS 1B.2

Habitat: Habitat consists of dry, disturbed banks, sandy, gravelly or rocky sites, often in leaf litter and in Jeffrey pine and pinyon-juniper woodland, and canyon live oak forest. Phacelia novenmillensis responds to wildfire and appears to behave as a "fire follower" (fire annual). It is more often found in metamorphic rock types.

Distribution: Phacelia novenmillensis is found on the eastern slopes of the southern Sierra Nevada in Tulare, Inyo, and Kern counties. It occurs from the south-eastern Kern Plateau southeast into the Owens Peak area, just west on the Owens valley. The majority of known occurrences are on Bureau of Land Management lands in the Caliente Resource area, south-east of Sequoia National Forest. There are no known occurrences on the Inyo National Forest, however, potential habitat may exist.

Herbarium specimens: Scodie Mountains, Erika M. Gardner, Travis Columbus, 2014;

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Pine Flat – Kern Plateau, J. T. Howell and Gordon H. True, 1971; Scodie Mountains, J. R. Shevock, 1992.

Known threats: Off-road foot or vehicular traffic, salvage logging mechanical disturbance, recreational development, cattle grazing/trampling.

Conclusion for Sequoia National Forest: There is concern about the species’ capability to persist over the long term in the plan area because of limited distribution and potential threat. Species: Ribes menziesii var. ixoderme, aromatic canyon gooseberry (RIMEI) Forest(s) of Consideration: Sierra National Forest

Rank (CNPS, CDFW; 2016): NatureServe: G4T2/S2 CNPS: 1B.2

Habitat: Foothill chaparral / oak woodland in the southern Sierra Nevada < 1000 m.

Distribution: Ribes menziesii var. ixoderme ranges from foothills of the Kings River drainage on the Sierra NF in Fresno County southward through Tulare and Kern counties. None of the Tulare or Kern county sites appear to be on National Forest System lands, though they’re near the Sequoia and Los Padres NFs. At least one site is in Sequoia / Kings Canyon National Park.

Herbarium specimens/locations:

Approximately 9 occurrences are known from Fresno, Tulare, and Kern counties based on tabulating herbarium and Rarefind records and accounting for apparent duplicates.

For the Sierra National Forest, at least 3 occurrences exist (on the U.S. Geological Survey Trimmer and Sacate Ridge quads).

The 1980 information from Dan Hamon in Rarefind (CDFW, 2016) stating that plants were seen from Haslett Basin to Bob’s Flat takes in a large area spanning about 6 miles from east to west.

The area from Haslett Basin to Bob’s Flat encompasses the “north base of Cat’s Head Mountain” along Road 10S04 represented by a May 12, 1977 collection by Rubtzoff (RSA800269).

In September 2008, Chris Winchell documented an additional population south of Haslett Basin along the northeast end of Sacate Ridge, on both sides of Forest Road 11S04. The following information was provided by Chris Winchell to Joanna Clines via text message on March 20, 2016: at lat/long 36.92080; - 119.20724 he observed several Ribes menziesii var. ixoderme shrubs on both sides of road 11S04, in bud while nearby Ribes roezlii was already fruiting. He noted that some horizontal stems close to the ground were “layering” – producing roots from buried stems. This is the occurrence that was affected by the Rough Fire – an unknown number of plants were bulldozed (Young and Linton, 2015). Monitoring by the USFS to determine whether the bulldozed shrubs sprout back or not and to better quantify and map the population will occur in spring 2016.

Site visit or monitoring information: Sierra National Forest botanists Joanna Clines and Anne Russell visited the Sacate Ridge population on the Sierra National Forest on April 29, 2016 along Road 11S04 near a wide dozer line created for the Rough Fire in 2015. About a dozen shrubs were observed, in full bloom with a few fruits beginning to form in sunnier spots. More field work is needed to quantify and map the shrubs and assess whether or not any that were bladed for the dozer line are sprouting back.

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Known threats: Fire suppression activities (e.g. dozer line construction) is likely the primary threat on NFS lands. Whether or not this species re-sprouts after fire is not known, but field monitoring will begin in spring 2016. Additional threats are off highway vehicle traffic, especially unauthorized driving, which does occur in the area of Sacate Ridge despite the fact that everything to the west of Road 11S04 is within Sacate Ridge Research Natural Area where no off-highway vehicle traffic is permitted. In addition, competition from non-native invasive weeds such as Italian thistle and tocalote which are common in the general area of Haslett Basin and Sacate Ridge could be damaging to the populations, especially affecting seedling establishment; plus additional weed species that may have been introduced during fire suppression for the Rough Fire.

Conclusion for Sierra National Forest: There is substantial concern about the capability of Ribes menziesii var. ixoderme to persist over the long term in the plan area because of the increased threat of invasive species following the Rough Fire, plus potential damage from unauthorized off-highway vehicle use, and unintentional mortality of shrubs during fire suppression as happened in 2015 during the Rough Fire. In addition, Ribes menziesii var. ixoderme is extremely uncommon on the Sierra National Forest, and is not yet known from other National Forest System lands – all populations to the south of the Sierra National Forest are outside National Forest System lands, one is on National Park Service lands, the rest may not be protected in any way. Species: Senecio pattersonensis, Mono ragwort Forest(s) of Consideration: Inyo National Forest

Rank: G2, S2 (CA), S1 (NV; Natureserve, 2016), 1B.3 (CNPS, 2016)

Habitat: Talus slopes, alpine boulder and rock field, 2900-3700 m elevation

Distribution: central High Sierra Nevada, eastern Sierra Nevada in California; Nevada

Herbarium specimens: Several from Mono County, outside the plan area (Baxter et al., 2016). From within the plan area:

Morefield and Ross, 4703, 7/25/1987, White Mountains., N wall of cirque heading the N Fork of Perry Aiken Creek

Site visit or monitoring information:

Rare plant surveys were conducted by Inyo National Forest botany personnel in 1991, 2004, and 2011 along the White Mountain trail, and at the head of the North Fork of Perry Aiken Creek. However, there have been no revisits to the site for the Morefield and Ross 4703 collection, which occurs on a steep, rugged slope with difficult access (CNDDB Occurrence #1).

Notes: California Natural Diversity occurrence #1 was reported as a noteworthy collection in Madrono 35:2 in 1988, and is reported as disjunct from the rest of California occurrences in the Sweetwater Mountains and adjacent Sierra Nevada (CNDDB, 2016).

Known threats: Potentially climate change; no other threats known. The 2005 Sensitive plant evaluation form reported, “threats not expected to be severe”.

Conclusion for Inyo National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because there is insufficient information about the species in the

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plan area. No recent information was available for the occurrence reported from the Forest, based on a single collection from 1987. Species: Stylocline masonii, Mason’s neststraw Forest(s) of Consideration: Sequoia National Forest

Rank: NatureServe G1, S1, CNPS 1B.1

Habitat: Stylocline masonii is found at elevations between 100 and 1200 m (330-3940 ft). It is usually found in dry washes, flats, plains, canyon bottoms, or flats along rivers or streams. Areas are generally flat to gently sloped, and open, often barren. Frequently the species may be found near the bases of rocks, in small drainages or depressions, or under the drip-lines of shrubs. The soil is sandy, light, loose, and dry, and may be calcareous. The surrounding vegetation may be chenopod scrub, pinyon-juniper or juniper woodland, or foothill woodland.

Distribution; Stylocline masonii is endemic to California, being found in the southern and the southern Sierra Nevada foothills, outer Ranges, and Western of Kern, Los Angeles, Monterey, and San Luis Obispo Counties.

Herbarium specimens: Cyrus Canyon, Ernest C. Twisselmann, 1971.

Known threats: The current threats to Stylocline masonii include development, inundation, or other habitat disturbances. Since it prefers flat sandy areas, disturbance caused by vehicles or recreational activities are almost certainly a threat. Stylocline masonii is a very inconspicuous annual and may be in identifiable condition for only 2-4 weeks in wet years. In dry years, it may not even germinate. There have been only 2 collections since 1971. The species might not tolerate recent disturbance to its habitat.

Conclusion for Sequoia National Forest: There is no substantial concern about the species’ capability to persist over the long term in the plan area because of insufficient information; there has been an inability to relocate it over much of its range, and lack of monitoring for trend.

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