Moonlight Fire Area Restoration Project

Botany Report and Biological Evaluation for Threatened, Endangered, and Sensitive

Prepared by: Bruce Davidson Botanist, Enterprise

for: Mt. Hough Ranger District Plumas National Forest

April 25, 2017

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Table of Contents

Introduction ...... 2 Proposed Action and Alternatives ...... 2 Framework for Analysis ...... 4 Purpose and Need ...... 4 Issues ...... 4 Other Resource Concerns ...... 4 Legal Framework...... 4 Resource Indicators and Measures ...... 7 Supporting Documents or Other Disclosures ...... 8 Methodology ...... 8 Spatial and Temporal Context for Effects Analysis ...... 10 Affected Environment ...... 10 Existing Condition ...... 10 Species Considered ...... 10 Environmental Impacts ...... 16 Alternative A – No Action ...... 16 Alternative B – Proposed Action ...... 16 Alternative C - California spotted owl interim recommendations Alternative ...... 26 Alternative D – Reforestation without the use of herbicides alternative ...... 26 Summary ...... 27 Summary of Environmental Effects ...... 27 Compliance with Laws, Regulations, and Policies ...... 28 References Cited ...... 29

List of Tables

Table 1. Threatened, endangered and sensitive (TES) indicators and measures for assessing effects ...... 7 Table 2. Threatened, endangered and sensitive plants considered ...... 11 Table 3. Threatened, endangered and sensitive plant indicators and measures for alternative A . 16 Table 4. Threatened, endangered and sensitive plant indicators and measures for alternative B.. 17 Table 5. Summary comparison of effects to TES plants ...... 27

List of Figures

Figure 1. Pulsifer’s milkvetch occurrence 007C and non-system road U3030 ...... 19 Figure 2. Adobe parsley occurrence 050658-001 and trail #12M29 decommissioning ...... 21 Figure 3. Susanville beardtongue occurrence 001 and proposed activities ...... 23

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Introduction This specialist report evaluates and documents the environmental impacts of the proposed Moonlight Fire Restoration Project and three alternatives on botanical resources, including federally endangered or threatened, and Forest Service Region 5 sensitive plants. It provides sufficient analysis to determine if these effects would be significant, and if the proposal and alternatives are in compliance with relevant laws, regulations, and policies. In addition, appendix A documents a similar analysis of effects to watch list plants, and appendix B addresses effects to noxious weeds.

Proposed Action and Alternatives The proposed action and alternatives are described in detail in the environmental assessment and its appendices. Please refer to the Moonlight Restoration Environmental Assessment for the proposed action and alternative descriptions.

The following proposed activities were analyzed for potential effects to botanical resources because the actions may disturb plants and habitats:

• Mechanical thin • Grapple pile • Mastication • Hand thin, hand pile • Pile burn, underburn • Reforestation – site preparation (could include equipment), planting, and release (could also include equipment and/or herbicide application) • Transportation system actions

o Decommission system roads and trails o Obliterate non-system routes o Improve system roads and trails for water quality o Reconstruct and maintain haul routes o Construct and decommission temporary roads o Trail maintenance • Fence Actions analyzed include any activity that may cause a change to soils or vegetation. All of the proposed vegetation treatments and transportation management actions in each of the alternatives have potential to affect noxious weeds and rare plants or their habitats; therefore, all proposed actions will be analyzed.

Standard Management Requirements and Design Features Common to All Action Alternatives The proposed action and alternatives incorporate standard management requirements and project-specific design features to minimize unintended impacts to project area resources. The complete list of these design features is in appendix C of the environmental assessment. The following design features would be implemented to minimize effects to botanical resources.

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• Protect known threatened, endangered, sensitive, and watch list plant species according to Plumas National Forest current interim management prescriptions. If additional protected plant species are found during the life of the project, conduct an assessment and apply appropriate management prescriptions. • Prevent spread of invasive species with equipment: Use contract clauses to require that the activities of contractors are conducted to prevent and control the introduction, establishment, and spread of aquatic and terrestrial invasive species. For example, where determined to be appropriate, use agreement clauses to require contractors to meet Forest Service-approved vehicle and equipment cleaning requirements/standards prior to using the vehicle or equipment in the National Forest System. • Cleaning equipment: Require all off-road equipment and vehicles (Forest Service and contracted) used for project implementation to be free of weeds. Clean all equipment and vehicles of all mud, dirt, and plant parts. This will be done at a vehicle washing station or steam-cleaning facility before the equipment and vehicles enter the project area. • Staging areas: Do not stage equipment, materials, or crews in areas infested with invasive plant species where there is a risk of spread to areas of low infestation. • Known and existing infestations: Known infestations would be designated as control areas where equipment and soil disturbing project activities would be excluded. These areas would be designated on project maps and delineated in the field with day-glow orange noxious weed flagging. The currently known noxious weeds in the project area are: barbed goatgrass (Aegilops triuncialis), yellow starthistle (Centaurea solstitialis), spotted knapweed (Centaurea stoebe), Canada thistle (Cirsium arvense), Scotch broom (Cytisus scoparius), common St. Johnswort (Hypericum perforatum), Dyer’s woad (Isatis tinctoria), and medusahead ( caput- medusae). Most weed species are limited in extent, except for Canada thistle, which has increased dramatically throughout the area after the Moonlight Fire. Known infestations would be prioritized for prevention and control measures based on species abundance (less common weeds would receive higher priority), risk of spread from activities, and other site-specific factors. If avoidance would unreasonably constrain our ability to implement the proposed restoration activities, equipment and vehicles would be cleaned prior to leaving the infested area. Additional weed control and monitoring mitigations would be developed to ensure project activities do not spread invasive plants. • Road construction, reconstruction, and maintenance: All earth-moving equipment, gravel, fill, or other materials need to be weed free. Onsite sand, gravel, rock, or organic matter would be used where possible. • Revegetation: If skid trails, landings, or stream crossings require soil stabilization, weed-free equipment, mulches, and sources would be used. On-site material would be chipped to use as mulch to the extent possible. If mulch is imported to the site use weed free rice straw (preferred) or certified weed free straw. Avoid seeding in areas where revegetation will occur naturally, unless invasive plant species are a concern. Save topsoil from disturbance and put it back to use in onsite revegetation, unless contaminated with invasive plants. All activities that require seeding or planting would need to use locally collected native seed sources or those identified by the botanist. A seed mix would be developed when specific site locations and conditions (dry, moist, wet, etc.) are determined.

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Required Monitoring Common to All Action Alternatives Monitoring is not required for the three sensitive plant locations with specific design features identified, or for any other sensitive plant site.

When implementing project treatment and transportation system activities, if noxious weed infestations would be disturbed: 1) implement control treatment before activities begin; 2) avoid infestations during implementation as much as is feasible; and 3) follow up with monitoring and additional control measures as needed. Framework for Analysis The following topics and issues will be analyzed in this report. Effects analysis will focus on disclosing the extent to which the alternatives meet the purpose and need, addressing public concerns (issues), providing sufficient analysis to determine if the effects would be significant, and compliance with relevant laws, regulations, and policies.

Purpose and Need The analysis will describe the extent to which the project proposals and alternatives satisfy the purpose and need for the project for botanical resources. The botanical resources addressed in this analysis did not drive the purpose and need for the proposed action.

Issues Herbicide use may affect non-target plant species. Proposed actions may impact rare plants or their habitats, and may contribute to the spread of invasive plants.

Other Resource Concerns Public comments were received concerning the maintenance of native plant communities and control of non-native invasive plants. Native plant communities are generally promoted by some of the proposed restoration actions, including riparian planting, aspen stand improvements, and reducing the dominance of post-fire shrubs in treated areas. This analysis considers native plant diversity by evaluating and providing protection as needed for rare plants, which occur in diverse plant communities and can be considered indicators of vegetation diversity. An analysis of all plant communities, including common understory plants and their expected responses, is not achievable or required for vegetation management planning. The risk of the proposed project causing non-native invasive plants to spread or be introduced is evaluated in the Noxious Weed Risk Assessment.

Legal Framework

Land and Resource Management Plan The Plumas National Forest Land and Resource Management Plan (the Forest Plan) (USDA Forest Service 1988) as amended by the Sierra Forest Plan Amendment (SNFPA) Supplemental Final Environmental Impact Statement and Record of Decision (USDA Forest Service 2004a, 2004b), provides management direction and standards and guidelines for the vegetation, watershed, and recreation management activities proposed in the Moonlight Fire Area Restoration Project. The Management direction is summarized in the environmental assessment. Forest Plan guidance relevant to botanical resources are described in more detail below.

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Relevant Standards and Guidelines The Plumas National Forest Land and Resource Management Plan as amended by the Sierra Nevada Forest Plan Amendment (SNFPA) Final Supplemental Environmental Impact Statement (Forest Plan as amended) provides management direction for all Plumas National Forest Sensitive plants; that direction is to “maintain viable populations of sensitive plant species” (USDA Forest Service 1988, USDA Forest Service 2004a). The Forest Plan also provides forest-wide standards and guidelines to:

• Protect sensitive and special interest (watch list) plant species as needed to maintain viability;

• Inventory and monitor sensitive plant populations on an individual project basis; and

• Develop species management guidelines to identify population goals and compatible management activities and prescriptions that will maintain viability.

Management direction for sensitive plant species on the Plumas National Forest is also provided in the Sierra Nevada Forest Plan Amendment (SNFPA) Final Supplemental Environmental Impact Statement (USDA Forest Service 2004a). The standards and guidelines provided in the SNFPA include conducting field surveys, minimizing or eliminating direct and indirect impacts from management activities, and adhering to the Regional Native Plant Policy. The Record of Decision (ROD) for the 2004 Sierra Nevada Forest Plan Amendment identified the following standards and guidelines applicable to botanical resources:

• Noxious weeds management (management standards and guidelines 36-49) • Wetland and meadow habitat (management standard and guideline 70) • Riparian habitat (management standard and guideline 92) • Bog and fen habitat (SNFPA ROD page 65, standard and guidelines118) • Sensitive plant surveys (corrected errata, April 19, 2005)

Special Area Designations

The Mud Lake Research Natural Area is located in the project area. Baker’s Cypress (Hesperocyparis bakeri), a rare tree species in California (and watch list plant for the Plumas National Forest), is the focus of this area. Management direction for the Mud Lake Research Natural Area was first outlined in the 1988 Plumas National Forest Land and Resource Management Plan. This direction was amended on May 30, 1989 by the Mud Lake Research Natural Area Designation Order, replacing it with the management prescription provided in the Mud Lake Research Natural Area Establishment Record and stating that it be managed in compliance with all relevant laws, regulations, and manual direction regarding research natural areas.

Species Management Guides/Conservation Strategies Individual species conservation strategies, or species management guidelines, for the Plumas National Forest have not been completed for most of the Forest’s sensitive species. Until these conservation strategies have been completed, the Plumas National Forest has developed interim management prescriptions (USDA Forest Service 2014) that will be followed to ensure compliance with the Forest Plan as amended. Interim management prescriptions for the species present are described in the Affected Environment section.

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Federal Law

Endangered Species Act This biological evaluation is being prepared in accordance with the Endangered Species Act of 1973 as amended (16 USC 1531 et seq.). Under this act, federal agencies must ensure that any action authorized, funded, or carried out by the agency is not likely to (a) jeopardize the continued existence of any listed species or (b) result in the destruction or adverse modification of a listed species’ designated critical habitat. Section 7 of the act requires federal agencies to consult the U.S. Fish and Wildlife Service concerning listed (i.e. threatened or endangered) plant species that fall under their jurisdiction.

National Environmental Policy Act of January 1, 1970 National Environmental Policy Act (NEPA) directs all federal agencies to consider and report the potential environmental impacts of proposed federal actions and established the Council on Environmental Quality.

Federal Noxious Weed Act of January 3, 1975 The Federal Noxious Weed Act authorizes the Secretary of Agriculture to designate plants as noxious weeds by regulation; to prohibit the movement of all such weeds in interstate or foreign commerce except under permit; to inspect, seize and destroy products and to quarantine areas, if necessary to prevent the spread of such weeds; and to cooperate with other federal, state and local agencies, farmers associations and private individuals in measures to control, eradicate, prevent, or retard the spread of such weeds.

Executive Orders

Executive Order 11990 Protection of Wetlands This Executive Order requires each federal agency to provide leadership and to take action to minimize the destruction, loss or degradation of wetlands and to preserve and enhance the natural and beneficial values of wetlands in carrying out the agency's responsibilities for acquiring, managing and disposing of federal lands and facilities; providing federally undertaken, financed, or assisted construction and improvements; and conducting federal activities and programs affecting land use, including but not limited to water and related land resources planning, regulating and licensing activities.

Executive Order 13112 Executive Order 13112 (USDA Forest Service 1999) was signed on Feb 3, 1999, establishing the National Invasive Species Council to ensure that Federal programs and activities to prevent and control invasive species are coordinated, effective and efficient. Executive Order 13112 defines an invasive species as “…an alien (or non-native) species whose introduction does, or is likely to cause economic or environmental harm or harm to human health". This Executive Order directs federal agencies to prevent the introduction of invasive species, detect and respond rapidly to and control such species, not authorize, fund, or carry out actions that it believes are likely to cause or promote the introduction or spread of invasive species unless the agency has determined and made public its determination that the benefits of such actions clearly outweigh the potential harm caused by invasive species; and that all feasible and prudent measures to minimize risk of harm will be taken in conjunction with the actions.

Forest Service Manual and Handbooks Forest Service Manual (FSM) 2670.22 (USDA Forest Service 2005) directs national forests to “maintain viable populations of all native and desired nonnative wildlife, fish, and plant species in habitats distributed throughout their geographic range on National Forest System lands.” To comply with this

6 Moonlight Fire Area Restoration Project, Botany Report direction, Forests are encouraged to track and evaluate effects to additional species that may be of concern even though they are not currently listed as sensitive. Such plant species are referred to as special interest or watch list species.

Forest Service Manual (FSM) 2900 (USDA Forest Service 2011) contains national direction for noxious weed management. Specific policies included in FSM 2900 include:

• Determine the risk of introducing, establishing, or spreading invasive species associated with any proposed action, as an integral component of project planning and analysis, and where necessary provide for alternatives or mitigation measures to reduce or eliminate that risk prior to project approval. • Ensure that all Forest Service management activities are designed to minimize or eliminate the possibility of establishment or spread of invasive species on the National Forest System, or to adjacent areas. Integrate visitor use strategies with invasive species management activities on aquatic and terrestrial areas of the National Forest System. At no time are invasive species to be promoted or used in site restoration or re-vegetation work, watershed rehabilitation projects, planted for biofuels production, or other management activities on national forests and grasslands. • Use contract and permit clauses to require that the activities of contractors and permittees are conducted to prevent and control the introduction, establishment, and spread of aquatic and terrestrial invasive species. For example, where determined to be appropriate, use agreement clauses to require contractors or permittees to meet Forest Service-approved vehicle and equipment cleaning requirements/standards prior to using the vehicle or equipment in the National Forest System. Additional direction is contained in:

• FSM 2070.3 Vegetation Ecology Policy • FSM 2609.26 Botanical Program Management Handbook • FSM 2670.3 Threatened, Endangered, and Sensitive Species Policy • FSM 2671 Coordination • FSM 2672 Planning for Management and Recovery, 2672.42 Standards for Biological Evaluations

Resource Indicators and Measures

Table 1. Threatened, endangered and sensitive (TES) plant indicators and measures for assessing effects Used to address: P/N, Resource Resource issue, Forest Plan or Element Indicator Measure law/reg/policy? Source Acres of TES TES plants TES plant presence occurrences potentially No affected Number of TES TES plants TES plant presence occurrences potentially No affected Qualitative discussion of TES TES plants Determination category Yes FSM 2670 plant responses to proposed activities

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Supporting Documents or Other Disclosures If needed, a Biological Assessment will be prepared in compliance with Section 7 of the Endangered Species Act. The Biological Assessment will focus on analysis for federally threatened, endangered, and candidate species in support of consultation with the U.S. Fish and Wildlife Service.

Methodology The analysis of effects on rare plant species was a three-step process (FSM 2672.43). In the first step, all listed or proposed rare species that were known or were believed to have potential to occur in the analysis area were identified. This list was developed by reviewing the U.S. Fish and Wildlife lists for the project area (U.S. Fish and Wildlife Service 2016a, 2016b), USDA Forest Service Region 5 Sensitive Species List, Plumas National Forest rare plant records, and California Natural Diversity Database records (California Natural Diversity Database 2017).

The second step was completing field surveys. The project area was reviewed using aerial photographs, soils maps and known occurrences to help determine potential habitat for rare species. Complete surveys were conducted by Plumas National Forest and contract botanists at all identified special habitat sites. Surveys were also conducted at selected known Sensitive and Watch list plant sites to assess the current condition of these populations.

Field surveys were designed around the flowering period and ecology of the rare plant species identified in step one. For each rare plant site found, information was collected that described the size of the occurrence, habitat characteristics and identified any existing or potential threats. Location information was collected using a global positioning system (GPS).

Over the last several years, field surveys have been conducted on approximately 69,251 acres (49 percent) of the 140,619 acre botany analysis area, defined below. As standard protocol, Forest Service staff survey for and document rare plants and invasive plant infestations when they are found. The most recent and extensive surveys were completed in 2015 and 2016, for the Moonlight area restoration and range projects.

Survey and occurrence information was used in step three of the analysis—conflict determination. Data were imported into a geographic information system (GIS) and used to develop mitigation measures to prevent or minimize likely detrimental effects.

Because the proposed actions are associated with differing degrees and types of impacts to vegetation, the actions will be addressed in groups of similar effects. Mechanical thinning would have the greatest effect on vegetation due to the use of equipment and tree falling within treatment areas. The next greatest effects would be from grapple piling due to equipment and soil disturbance, followed by pile burning, under burning, hand thinning, and fencing.

Determination Categories This biological evaluation reviews the proposed action and alternatives in sufficient detail to determine the level of effect that would occur to Region 5 sensitive plant species. One of three possible determinations is chosen based on the available literature, a thorough analysis of the potential effects of the project, and the professional judgment of the botanist who completed the evaluation. The three possible determinations (from FSM 2672.42) are:

• No impact

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• May affect individuals, but is not likely to result in a trend toward Federal listing or loss of viability in the planning area • May affect individuals, and is likely to result in a trend toward Federal listing or loss of viability for the [name of species] in the planning area Similar categories for federally listed threatened and endangered species are:

• No effect • May affect, not likely to adversely affect • May affect, likely to adversely affect Determination categories are not required for watch list species, but effects are described and similar conclusions are made without using the specific determination language reserved for threatened, endangered and sensitive plants.

Information Sources This analysis was completed using the following data and information sources:

• Project area records (e.g., rare species, meadows, seeps/springs, habitats, noxious weeds, etc.), including results of project area surveys for rare species and noxious weeds.

• GIS layers of the following data: treatment units, transportation routes, plant communities, meadows, seeps and springs, fens, threatened, endangered and sensitive plants, special interest plants and noxious weeds.

• California National Diversity Database records (California Natural Diversity Database 2017) and California Native Plant Society Inventory of Rare and Endangered Plants (California Native Plant Society 2017).

• Scientific literature

Incomplete and Unavailable Information Basic information describing the life history, ecology, pollination biology, and specific habitat requirements is lacking for most of the sensitive species that occur within the botany analysis area. The scientific literature and internal government documents (i.e. species-specific conservation assessments) were utilized for the analysis whenever available; however more frequently the analysis of effects was based on observations by qualified individuals, field experience, unpublished monitoring results, and studies of comparable species.

Analysis assumptions The following assumptions were used in the analysis of botanical resources:

Assumption 1: Direct and indirect effects may be detrimental or beneficial depending on the species and its suitable habitat requirements.

Assumption 2: Direct effects are most likely to occur within a zone of 30 feet from the edge of proposed project activities and indirect effects are most likely to occur within a zone of 100 feet.

Assumption 3: All standards and guidelines, standard operating procedures, project specific design features and mitigations would be fully adhered to and implemented.

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Assumption 4: Where surveys were not completed within project area, suitable habitat for Sensitive species is assumed occupied.

Spatial and Temporal Context for Effects Analysis

Direct, Indirect, and Cumulative Effects Boundaries Referred to hereafter as the botany analysis area, the geographic boundary for analyzing effects to botanical resources is the area within 1 mile of proposed activities. This area was chosen to include all rare plants and noxious weeds that are known to occur within project treatment units, occur along access routes, as well as have habitat and a “source” (potential for seed dispersal) population within close proximity to proposed activities. Those species located within this geographic area were considered to have the highest potential to be affected by the proposed project. Conversely, species outside of the analysis area (that is, those species that only are considered to have “potential” to occur) were not considered to have a high likelihood of being affected by the proposed project either directly, indirectly, or cumulatively and therefore were not analyzed. Other actions occurring outside this boundary would not contribute to cumulative effects.

Short-term timeframe: 1 year after project implementation, because it is within one year (the next growing season) that impacts to plants could first take effect, measurable by a change in numbers of individuals, coverage by the species, plant vigor, pollination, or other community interactions.

Long-term timeframe: 25-30 years, because climate change, unforeseeable future projects, demographic changes, etc. make assumptions beyond this timeframe too speculative. Affected Environment

Existing Condition Plant communities in the project area consist primarily of Sierra mixed conifer forests, eastside pine and montane chaparral, with smaller components of white fir, Douglas-fir, and montane hardwoods. Within these broader vegetation types there are a number of other, less geographically defined, plant communities that provide important habitat for rare plant species. These include riparian corridors, meadows, springs and rocky areas or rock outcrops. These communities support a wide range of potential habitat for sensitive plant species. Recent botanical surveys have been completed in nearly all areas of proposed activities.

Species Considered Table 2 lists all federally threatened, candidate and Region 5 sensitive , moss, lichen and fungi species considered for this project. Included is the listing status, whether the species is known to occur in the analysis area, within 100 feet, or within an activity area (unit), and whether the species is analyzed in detail.

In the status column, the following acronyms are used:

FT = federally listed threatened,

S = Forest Service sensitive

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Table 2. Threatened, endangered and sensitive plants considered Occurs within Species Is there potential for the species to be Status 1 mile/100 feet/within an Common Name affected? activity area Allium jepsonii No. Habitats of serpentine soils or foothill S No Jepson's onion woodlands are not present in project area. Astragalus lemmonii No. Potential habitat was searched and S No Lemmon’s milkvetch the species was not found.

Astragalus lentiformis Possible, due to suspected suitable S No habitat in Great Basin scrub and lens-pod milkvetch subalpine forest. Astragalus pulsiferae var. No. Proposed project is outside its known coronensis S No geographic range. Modoc plateau milkvetch Astragalus pulsiferae var. Yes. 3 occurrences are in the Botany pulsiferae S Yes/Yes/Yes analysis area, including one roadside Pulsifer's milkvetch occurrence.

Astragalus webberi No. Proposed project is outside the known S No geographic range, and mostly too high in Webber's milkvetch elevation. Balsamorhiza macrolepis No. Habitats of serpentine soils or foothill var. macrolepis S No woodlands are not present in project area. big scale balsamroot Boechera constancei No. No serpentine outcrops are in the S No Constance's rock cress project area. Botrychium ascendens No. Potential habitat was searched and S No upswept moonwort the species was not found. Botrychium crenulatum No. Potential habitat was searched and S No scalloped moonwort the species was not found. Botrychium lunaria No. Potential habitat was searched and S No common moonwort the species was not found. Botrychium minganense No. Potential habitat was searched and S No Mingan moonwort the species was not found. Botrychium montanum No. Potential habitat was searched and S No western goblin the species was not found. Botrychium pinnatum No. Potential habitat was searched and S No northwestern moonwort the species was not found. Bruchia bolanderi No. Potential habitat was searched and S No Bolander's bruchia the species was not found. Buxbaumia viridis No. Potential habitat was searched and S No bug-on-a-stick the species was not found. Calycadenia oppositifolia No. Proposed project is too high in S No Butte County calycadenia elevation. Clarkia gracilis ssp. No. Proposed project is too high in albicaulis S No elevation. white-stemmed clarkia Clarkia mildrediae ssp. No. Proposed project is outside its mildrediae S No geographic range. Mildred’s clarkia

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Occurs within Species Is there potential for the species to be Status 1 mile/100 feet/within an Common Name affected? activity area Clarkia mosquinii No. Proposed project is outside its S No Mosquin's clarkia geographic range. Cypripedium fasciculatum No. Potential habitat was searched and S No clustered lady's-slipper the species was not found. Cypripedium montanum No. Potential habitat was searched and S No mountain lady's-slipper the species was not found. Eleocharis torticulmis No. Proposed project is too high in S No twisted spike rush elevation. Eremogone cliftonii No. Proposed project is outside its S No Clifton’s eremogone geographic range. Eriogonum microthecum var. schoolcraftii No. Proposed project is outside its S No Schoolcraft's wild geographic range. buckwheat Eriogonum umbellatum var. No. Proposed project is too high in ahartii S No elevation, and no serpentine outcrops are Ahart’s buckwheat present. Fissidens aphelotaxifolius No. No waterfalls or wet cliffs present in S No brook pocket moss project area.

Fissidens pauperculus No. Proposed project is too high in S No elevation and proposed project is outside minute pocket moss its geographic range. Frangula purshiana ssp. No. Proposed project is outside its ultramafica S No geographic range. caribou coffeeberry Fritillaria eastwoodiae No. Proposed project is outside its S No Butte County fritillary geographic range. Helodium blandowii No. Potential habitat was searched and S No Blandow's bog moss the species was not found. Ivesia aperta var. aperta No. Potential habitat was searched and S No Sierra Valley ivesia the species was not found. Ivesia sericoleuca No. Potential habitat was searched and S No Plumas ivesia the species was not found. Ivesia webberi No. Proposed project is outside its FT No Webber's ivesia geographic range. Juncus luciensis No. Proposed project is outside its S No Santa Lucia dwarf rush geographic range.

Lewisia cantelovii No. No wet rocky cliff faces in project S No area, project elevation is mostly too high, Cantelow's lewisia and likely outside its geographic range. Lewisia kelloggii ssp. No. Potential habitat was searched and hutchisonii S No the species was not found. Hutchison's lewisia Lewisia kelloggii ssp. No. Proposed project is outside its kelloggii S No geographic range. Kellogg’s lewisia

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Occurs within Species Is there potential for the species to be Status 1 mile/100 feet/within an Common Name affected? activity area Yes. 4 occurrences are in the botany roseanum analysis area, and a portion of one is S Yes/Yes/Yes adobe parsley present at the end of a trail proposed for decommissioning. Meesia uliginosa No. Potential habitat was searched and S No broad-nerved hump-moss the species was not found. Mielichhoferia elongata No. Proposed project likely too high S No elongate copper moss elevation and outside geographic range. Yes. One occurrence is in the botany Monardella follettii analysis area, but is not within 100 feet of S Yes/No/No Follett’s monardella any proposed activity. Potential impacts to habitats are considered. Monardella stebbinsii No. Potential habitat was searched and S No Stebbin's monardella the species was not found. Oreostemma elatum No. Potential habitat was searched and S No Plumas alpine-aster the species was not found. Packera (Senecio) No. Potential habitat was searched and eurycephala var. lewisrosei S No the species was not found. cut-leaved ragwort

Packera (Senecio) layneae No. The project area is too high in FT No elevation and is outside the geographic Layne's butterweed range of the species. Peltigera gowardii No. Potential habitat was searched and S No veined water lichen the species was not found. personatus No. Potential habitat was searched and S No closed-throated the species was not found. beardtongue Yes. Seven occurrences are in the botany Penstemon sudans analysis area, and one occurrence is S Yes/Yes/Yes Susanville beardtongue present along a road proposed for maintenance.

Poa sierrae No. The project area is outside the S No geographic range and mostly too high Sierra bluegrass elevation for this species. Pyrrocoma lucida No. Potential habitat was searched and S No sticky pyrrocoma the species was not found. Sedum albomarginatum No. Potential habitat was searched and S No Feather River stonecrop the species was not found.

Those species present within the botany analysis area were considered to have the highest potential to be impacted by the proposed project activities. Conversely, species outside of the analysis area were not considered likely to be impacted by the proposed project either directly, indirectly, or cumulatively.

Federally Listed Plants Official species lists for this project area were obtained on October 27, 2016, from the Reno and Sacramento Fish and Wildlife Offices (U.S. Fish and Wildlife Service 2016a, 2016b). No plant species are included on the lists.

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The only federally threatened plant species known to occur on the Plumas National Forest is Packera layneae (Layne’s butterweed). This species grows in open rocky areas on gabbro and serpentine-derived soils that are between 650 and 3,300 feet in elevation. The Plumas National Forest has four occurrences, totaling approximately 12 acres. There is no suitable habitat for this species within or near the Moonlight Range project area.

Two additional species of federal concern that may have the potential to occur on the Plumas National Forest are the federally threatened Orcuttia tenuis (slender Orcutt grass) and Ivesia webberi (Webber's ivesia). Orcuttia tenuis is limited to relatively deep vernal pools with clay soil. Ivesia webberi is found in open areas of sandy volcanic ash to gravelly soils in sagebrush and eastside pine. Based on field surveys, no suitable habitat for these two species occurs within the project area.

No threatened or endangered species are known or suspected to occur within the project area and a Biological Assessment is not needed.

Sensitive Plants There are four sensitive plant species with occurrences documented within 1 mile of proposed project activities: Pulsifer’s milkvetch (Astragalus pulsiferae var. pulsiferae), adobe parsley (Lomatium roseanum), Follett’s monardella (Monardella follettii), and Susanville beardtongue (Penstemon sudans). All other sensitive plant species are not likely to be affected because all or most potential habitats have been surveyed and the species have not been found in the botany analysis area.

Pulsifer’s milkvetch Pulsifer’s milkvetch is an that grows in Great Basin scrub, lower montane coniferous forest, or pinyon and juniper woodland habitats, usually on granitic sandy or rocky substrates, from 4,265 to 5905 feet. Threats to the species include grazing and development (California Native Plant Society 2017).

In California, it is known from Lassen, Plumas, and Sierra Counties, with a total of 27 occurrences. 12 of these occurrences are on the Plumas National Forest. Three occurrences are within the botany analysis area, one of which is a (non-system) roadside occurrence. This non-system road is proposed for obliteration. They are small occurrences with a total of less than one tenth acre.

Plumas National Forest Management Prescription for Pulsifer’s milkvetch: Protect at least 30 percent of all known occurrences within a project analysis area from all disturbances associated with management activities. Protect all plant occurrences from soil displacement activities. Hand thin and scatter or pile outside of occurrences. Do not construct fire control line through occurrences. Allow for at least 5 years rest between disturbance prescriptions to the same occurrence. Evaluate other activities on a site-by-site basis considering species abundance, population size, geographic distribution, and known species ecology (USDA Forest Service 2014).

Adobe parsley This plant is found in rocky, shallow soil and often on wind-swept ridge tops on the Plumas and Lassen National Forests. Its habitat has little or no canopy cover and dry soil in an elevation range of between 5,880 to 7280 feet. Threats to the species include grazing, vehicles, and logging and possibly wind generation facilities, but many sites have very few threats (California Native Plant Society 2017).

Adobe parsley ranges from southeastern Oregon, nearby northwestern Nevada, and adjacent northeastern California. In California, there are seven documented occurrences. Two of the 4 known occurrences on

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the Plumas National Forest are located along the northern boundary of the project area, for a total of 103 acres in the botany analysis area.

Plumas National Forest Management Prescription for adobe parsley: Protect all plant occurrences from ground disturbance that result in soil displacement. Evaluate other activities on a site-by-site basis considering species abundance, population size, geographic distribution, and known species ecology (USDA Forest Service 2014).

Follett’s monardella, Monardella follettii Follett’s monardella is a small shrub that grows in rocky serpentine areas at elevations between 1,970 feet and 6,560 feet. The species is threatened by fire, mining, logging, shading, and potentially road maintenance and vehicles (California Native Plant Society 2017).

Follett’s monardella grows only in California (Nevada and Plumas Counties), with a total of 27 documented occurrences. 17 occurrences are on the Plumas National Forest, and only one is in the botany analysis area for this project.

Plumas National Forest Management Prescription for Follett’s mondardella: Protect 50 percent of known occurrences within a project area from ground disturbance. Favor protection of locations that have open tree and shrub canopies (less than 50 percent cover) over those with closed tree and shrub canopies. In control areas, keep handpiles at least 20 feet from plants to protect individuals and seedbank from excessive heat. Avoid scattering slash on plants. Evaluate potential effects of prescribed fire on a site-by-site basis considering factors such as population size, fuel load, season of burn, predicted intensity and duration of burn, and risk of wildfire vs. potential effects from prescribed fire. Develop monitoring plans to evaluate fire effects on individuals and populations before prescribe burning operations. Favor allowing ground disturbance and prescribed fire in areas of dense shrub or tree cover. Evaluate other activities on a site-by-site basis considering species abundance, population size, geographic distribution, and known species ecology (USDA Forest Service 2014).

Susanville beardtongue, Penstemon sudans Susanville beardtongue is found in pinyon and juniper woodlands and openings in yellow pine and mixed conifer forests, usually on rocky volcanic soils. Although often abundant where it occurs, Susanville beardtongue is restricted to a relatively small area in Lassen and Plumas Counties, California, and adjacent Nevada. Apparently suitable habitat is widespread in northeastern California, and the factors restricting its range are unknown. Threats to this species include invasive plant spread, grazing, road construction, and logging (California Native Plant Society 2017).

This species is known from 38 occurrences in California, most of which occur on land managed by the Bureau of Land Management in the vicinity of Susanville, California (California Natural Diversity Database 2017). The number of plants at known occurrences varies from fewer than 50 to more than 1,000. Four occurrences are known on the Plumas National Forest, covering approximately 21 acres, and all are within the botany analysis area.

Plumas National Forest Management Prescription for Susanville beardtongue: Protect all occurrences from ground disturbance. Evaluate other activities based on species abundance, population size, geographic distribution, and known species ecology (USDA Forest Service 2014).

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Environmental Impacts

Alternative A – No Action If the proposed actions are not taken, no threatened, endangered or sensitive plants would be affected, including the four species present in the botany analysis area. With no direct or indirect effects expected, there would be no cumulative effects to consider.

Alternative A would have no impact on any threatened, endangered or sensitive plant species because no actions would occur.

Table 3. Threatened, endangered and sensitive plant indicators and measures for alternative A Acres within 100 feet of Number of sites within 100 Species Determination proposed activities feet of proposed activities Astragalus pulsiferae ssp. pulsiferae 0 0 No impact Pulsifer’s milkvetch Lomatium roseanum 0 0 No impact adobe parsley Monardella follettii 0 0 No impact Follett’s monardella Penstemon sudans 0 0 No impact Susanville beardtongue

Alternative B – Proposed Action The proposed action, described in detail in the Moonlight Fire Area Restoration Project Environmental Assessment, includes all of the actions summarized in the Introduction section. Most sensitive plant occurrences are well distanced from proposed activities and would not be directly or indirectly affected. However, one occurrence each of Pulsifer’s milkvetch, adobe parsley, and Susanville beardtongue could be damaged by the proposed activities. Site-specific design features for their protection have been developed and are presented below.

• In order to prevent adverse impacts to Pulsifer’s milkvetch occurrence 007C along the non-system road U3030, the occurrence will be flagged and the area avoided during obliteration activities. • In order to prevent adverse impacts to adobe parsley at the northern end of trail #12M29, the occurrence will be flagged and avoided if ground disturbing activities are required at this end of the trail segment to be decommissioned. • In order to prevent adverse impacts to Susanville beardtongue sub-occurrence 001G along road 28N08, the occurrence will be flagged and avoided if ground disturbing activities outside the existing road prism are required at this location.

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Direct and Indirect Effects - Alternative B

Table 4. Threatened, endangered and sensitive plant indicators and measures for alternative B Acres within 100 Number of sites Species feet of proposed within 100 feet of Determination activities proposed activities With the identified avoidance Astragalus pulsiferae ssp. measure implemented, the proposed action may affect individuals but is pulsiferae 0.02 1 not likely to lead to a loss of Pulsifer’s milkvetch viability or trend toward federal listing. With the identified avoidance measure implemented, the proposed Lomatium roseanum action may affect individuals but is 0.4 1 adobe parsley not likely to lead to a loss of viability or trend toward federal listing. Although one occurrence exists in the botany analysis area, it is over 1,000 feet from proposed activities and would not be directly affected by the proposed actions. Monardella follettii 0 0 With noxious weed prevention, Follett’s monardella monitoring, and control measures required, the proposed activities would be highly unlikely to affect the occurrence. The proposed activities are expected to have no impact to Follett’s monardella. With the identified avoidance measure implemented, the proposed Penstemon sudans action may affect individuals but is 0.3 1 Susanville beardtongue not likely to lead to a loss of viability or trend toward federal listing.

Direct effects occur when plants are physically impacted by management activities. Proposed activities may affect rare plants by physical damage from equipment, tree felling, or trampling by project personnel.

Indirect effects are those that are separated from an action in either time or space. Habitat components including soils, shading, and species composition of the plant and pollinator community may directly and indirectly be altered by the proposed actions. These effects can be beneficial or detrimental to rare plants, and may include increased soil erosion, increased light reaching the ground, introduction or promotion of conditions favorable for non-native invasive plants, effects to pollinator species, or other changes to rare plant habitats. The project carries a risk of spreading or introducing noxious weeds; however, the risk is significantly reduced by implementing the project design features for the preventing and controlling these invasive species (see appendix B, Noxious Weed Risk Assessment). Noxious weeds are not expected to increase in areas more than 100 feet from disturbed treatment areas or roads and trails due to this project.

Pulsifer’s milkvetch One sub-occurrence (less than one tenth acre) of Pulsifer’s milkvetch is reported along a non-system road proposed for obliteration. Although this perennial plant species recruits new individuals after disturbance,

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it is unknown to what extent these activities cause adverse effects to established plants or habitats. While these plants have been located in old road beds, they are more often found scattered across lightly vegetated side slopes. Road obliteration activities could damage or kill plants from the ground disturbance of re-contouring actions. A design feature would protect this occurrence from such direct effects, but indirect effects are still possible, mainly the increased recruitment of new Pulsifer’s milkvetch plants and increased risk of non-native invasive plants in disturbed areas. Although the known on-road individuals would be protected, the U3030 road obliteration could provide suitable disturbance for new individuals to become established. Weed prevention measures described in the Noxious Weed Risk Assessment are expected to reduce the risk of weed spread due to project activities.

No other known Pulsifer’s milkvetch occurrences would be affected by any other proposed actions, but some areas of suitable habitat could be affected by this and other road and trail activities.

The following design feature is included in the proposed action to protect Pulsifer’s milkvetch from excessive disturbance:

In order to prevent adverse impacts to Pulsifer’s milkvetch occurrence 007C along the non-system road U3030, the occurrence will be flagged and the area avoided during obliteration activities.

Because some areas of suitable habitat could be affected by proposed road and trail activities, and a risk of noxious weed spread is present, the Moonlight Fire Area Restoration Project (alternative B) may affect individuals, but is not likely to result in a trend toward Federal listing or loss of viability for Pulsifer’s milkvetch (Astragalus pulsiferae ssp. pulsiferae).

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Figure 1. Pulsifer’s milkvetch occurrence 007C and non-system road U3030

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Adobe parsley In this project area, adobe parsley is documented for 2 miles along the ridge separating the Lassen and Plumas National Forests (site ID 051102_LORO7_003, 050658-LORO7-001). For this project, the only area of concern is along the northernmost section of trail #12M29, where approximately 100 feet of the end of the route falls within the occurrence. The last 0.15 miles of the trail is proposed for decommissioning due to wetland impacts, but the closure would also benefit the adobe parsley occurrence which is located at the very end of the trail and extends along the ridge in both directions. Decommissioning trail #12M29 would reduce the risk of off-highway vehicle (OHV) impacts to the occurrence. However, adobe parsley individuals could be damaged if ground disturbing activities are implemented in the occurrence area (approximately the last 30 feet of the trail, as mapped). Ground disturbing activities are not expected to be required along the last 30 feet of the trail to implement the trail decommissioning, but if they are required, the following design feature would protect adobe parsley in accordance with Plumas National Forest Interim Management Prescriptions (USDA Forest Service 2014):

In order to prevent adverse impacts to adobe parsley at the northern end of trail #12M29, the occurrence will be flagged and avoided if ground disturbing activities are required at this end of the trail segment to be decommissioned.

This site constitutes only a small portion of the extensive adobe parsley occurrence. Loss of a few individuals that might be trying to become established in the OHV trail would not cause a downward trend. No other known adobe parsley occurrences would be affected by any other proposed actions.

Indirect effects from noxious weed spread are also possible, but would be minimized by prevention/control measures. Because on-trail individuals may be directly impacted, and a risk of noxious weed spread is present, the Moonlight Fire Area Restoration Project (Alternative B) may affect individuals, but is not likely to result in a trend toward Federal listing or loss of viability for adobe parsley (Lomatium roseanum).

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Figure 2. Adobe parsley occurrence 050658-001 and trail #12M29 decommissioning

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Follett’s monardella One occurrence is in the botany analysis area, over 1,000 feet from the nearest proposed activity which would be system trail improvements along trail #10M37. Additional habitat areas were not encountered during surveys. Due to the distance from proposed activities, no direct effects would occur to these sites, and indirect effects are unlikely from noxious weed spread. Because known occurrences and habitats are not likely to be affected, the Moonlight Fire Area Restoration Project (alternative B) would have no impact on Follett’s monardella (Monardella follettii).

Susanville beardtongue Only one occurrence (051102_PESU10_001) is within 100 feet of the proposed activities. A very small portion of the northern tip of thinning unit 419 is approximately 90 feet from the edge of the occurrence, which is upslope and would be unlikely to be affected by the activities on the slope below. No protection measures are needed for this situation. However, the nearby sub-occurrence 051102_PESU10_001G is mapped across road 28N08, which is proposed for improvements for water quality. Some road improvement activities, specifically those with ground disturbance outside the existing road prism, could damage or kill Susanville beardtongue individuals and reduce the sustainability of the sub-occurrence. We don’t know if there are specific road improvements needed for this very short road segment, but the occurrence would be protected from direct damage by implementing the following design feature:

In order to prevent adverse impacts to Susanville beardtongue sub-occurrence 001G along road 28N08, the occurrence will be flagged and avoided if ground disturbing activities outside the existing road prism are required at this location.

If individual plants have colonized portions of the existing road bed, they could be damaged by vehicle use and maintenance activities, but loss of these individuals would not cause a downward trend for the sub-occurrence, or species. Indirect effects from noxious weed spread are also possible, but would be minimized by prevention and control measures. Because on-road individuals may be directly impacted, and a risk of noxious weed spread is present, the Moonlight Fire Area Restoration Project (alternative B) may affect individuals, but is not likely to result in a trend toward Federal listing or loss of viability for Susanville beardtongue (Penstemon sudans).

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Figure 3. Susanville beardtongue occurrence 001 and proposed activities

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Cumulative Effects – Alternative B A cumulative effect can result from the incremental effect of the current action when added to the effects of past, present and reasonably foreseeable future actions.

This cumulative effects analysis does not attempt to quantify the effects of past human actions by adding up all prior actions on an action-by-action basis. There are several reasons for not taking this approach. First, a catalog and analysis of all past actions would be impractical to compile and unduly costly to obtain. Current conditions have been impacted by innumerable actions over the last century (and beyond) and trying to isolate the individual actions that continue to have residual impacts would be nearly impossible. Second, providing the details of past actions on an individual basis would not be useful to predict the cumulative effects of the proposed action or alternatives. Focusing on individual actions could be less accurate than looking at existing conditions, because there is limited information on the environmental impacts of individual past actions and one cannot reasonably identify each and every action over the last century that has contributed to current conditions. Past natural events have also contributed to cumulative effects. Looking at current conditions captures the residual effects of past human actions and natural events, regardless of which particular action or event contributed those effects. Third, public scoping for this project did not identify any public interest or need for detailed information on individual past actions. Finally, the Council on Environmental Quality issued an interpretive memorandum on June 24, 2005 regarding analysis of past actions, which states, “agencies can conduct an adequate cumulative effects analysis by focusing on the current aggregate effects of past actions without delving into the historical details of individual past actions.

The additive effects of past actions (such as off-highway vehicle use, wildfires, wildfire suppression, timber harvest, mining, nonnative plant introductions and livestock grazing) have shaped the present landscape and corresponding populations of rare plants. However, data describing the past distribution and abundance of rare plant species is extremely limited, making it impossible to quantify the effects of historic activities on the resources and conditions that are present today. Undoubtedly, some plant species have always been rare due to particular ecological requirements or geographic isolation. It is also likely that past actions have caused some species to become rarer and encouraged others to become more common. Rare plant surveys did not begin until the early 1980s on the Plumas National Forest. In many cases, even when project-level surveys were conducted, there is very little documentation that describes whether past projects avoided or protected rare plant species during project implementation. In addition to these unknowns, changes have been made to the Regional Forester’s Sensitive species list. Therefore, in order to incorporate the contribution of past activities into the cumulative effects, this analysis uses the current abundance and distribution of rare plant species as a baseline for the existing condition shaped by the impacts of past actions.

Past, present and future activities have and will continue to alter rare plant populations and their habitats to various degrees. These management activities include grazing, timber harvest, wildfire, fire suppression, prescribed fire, mining, recreational use, road construction and maintenance. However, the approach taken in this analysis is that, if direct and indirect adverse effects on rare plant species in the analysis area are minimal or would not occur, then they would not contribute substantially to cumulative effects on the species. In addition, the effects of future projects would likely be minimal or similar to those described in this analysis if existing management guidelines (such as field surveys, protection of known rare species locations and noxious weed mitigations) remain in place. Past, present and future foreseeable actions considered for this project are listed in appendix D of the Moonlight Fire Area Restoration Project Environmental Assessment and are discussed specifically below in relation to rare plants and the proposed action.

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The list of reasonably foreseeable future actions was reviewed for possible interaction of effects to the rare plants present in the current botany analysis area. The following projects were found to be relevant for further consideration in the cumulative effects analysis for this resource due to their overlap with the botany analysis area:

• Antelope Lake Fuels Reduction Project is not expected to impact any threatened, endangered or sensitive plant species because none are known to be present in the activity areas.

• Wildcat Fuels Reduction and Vegetation Management Project - In the botanical review for the Wildcat project, no federally listed or Region 5 sensitive plant species were detected in the Wildcat Project area, and no effects to those species are anticipated.

• Moonlight Range Project (Antelope, Antelope Lake, Lights Creek, and Lone Rock Allotments and meadow restoration actions) may contribute minor amounts of soil disturbance and plant damage to adobe parsley and Susanville beardtongue from ongoing livestock grazing.

• The botany analysis for the Moonlight Invasive Plant Treatment Project determined that Astragalus pulsiferae var. pulsiferae, Lomatium roseanum, Oreostemma elatum, and Penstemon sudans may be affected, but would not lead to a downward trend. No known occurrences are expected to be affected, directly or indirectly. However, indirect effects to habitat for these four sensitive plants may occur because habitat requirements are not fully understood and unknown consequences may result. If they arise, indirect effects are expected to be very minor, most likely manifesting as subtle changes to potential habitats. There would likely be long term benefits from controlling the advancement of weed infestations.

• Mud Lake Baker Cypress fuel treatments is not expected to affect any threatened, endangered, sensitive, or watch list plants (except for the watch list plant Baker cypress) because none are known to be present, even with surveys being accomplished.

• Moonlight Aquatic Organism Passage – The botany analysis for the Moonlight Aquatic Organism Passage Project determined that there would be no effect on any threatened, endangered, sensitive, or watch list plants.

• Moonlight Off-Channel Water Sources – The botany analysis for the Moonlight Off-Channel Water Sources Project determined that there would be no effect on any threatened, endangered, sensitive, or watch list plants.

• Herby’s Mining – Southwest of Antelope Lake, the Herby’s Mine plan of operations includes mineral exploration with high levels of ground disturbance, but also site reclamation. The area has been surveyed and no threatened, endangered, sensitive, or watch list plants were found. No effects to these species are expected.

• Road maintenance and repair activities in the botany analysis area could affect Lomatium roseanum and Penstemon sudans individuals or habitat, making a very minor contribution to the total cumulative effects of all actions. Only a very small portion of one Lomatium roseanum occurrence is within 100 feet of the roads and trails analyzed in Hungry Creek, Indian Creek, and Smith Creek watersheds, and the occurrence would be protected per that project’s design features. This location, the northern end of trail 12M29, is also included in the current proposed action to complete the same decommissioning.

• Private lands forest management, including ground-disturbing activities and herbicide use, may indirectly affect Astragalus pulsiferae var. pulsiferae, Lomatium roseanum, Monardella follettii,

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and Penstemon sudans habitats by inadvertently promoting non-native grasses, such as cheatgrass, and other invasive species on areas adjacent to National Forest System lands. Considerable increases in cheatgrass have been observed on private and federal lands in the project area. If infestations become established in rare plant habitats, the invasive plants could outcompete rare plant individuals or reduce their reproductive success. At this time, no sensitive plant occurrences in the Moonlight Fire Area Restoration Project are within 100 feet of mapped noxious weeds.

For sensitive plant species, when the effects of these past, present and reasonably foreseeable future actions are combined with the effects predicted for the current proposed action, the total would still be minor and insignificant, with the possibility of some individuals being impacted, but no downward trends expected for any occurrences.

Alternative C - California spotted owl interim recommendations Alternative This alternative is intended to reduce risk to California spotted owl habitat in the short term relative to the risk associated with current standards and guidelines. The spatial extent of proposed actions is the same as alternative B, but treatment types are adjusted.

Direct and Indirect Effects - Alternative C The areas of potential conflict with sensitive plants would be the same as those described for alternative B. Treatment types at these locations would also be the same as alternative B, as would the effects, indicators, and design features. Because the discussions would be the same, please refer to alternative B effects section above. To avoid duplicating a table of indicators and measures with the same values, please also refer to alternative B, table 4, above.

Cumulative Effects – Alternative C Because the direct and indirect effects are the same as alternative B, the cumulative effects would also be the same as described for alternative B.

Alternative D – Reforestation without the use of herbicides alternative This alternative would be the same as the proposed action, except that there would be no herbicides used for the release treatments. Release treatments would include machine pulling and piling, mastication, or hand grubbing only.

Direct and Indirect Effects - Alternative D The areas of potential conflict with sensitive plants would be the same as those described for alternative B. Compared with alternative B, ground disturbance would be greater with alternative D in those areas where herbicide use is replaced with machine based release treatments. However, after project surveys no sensitive plant occurrences are known to exist in or near these treatment areas, so they would not be affected in either alternative. The effects, indicators, and design features would be the same as alternative B. Because the discussions would be the same, please refer to alternative B effects section above. To avoid duplicating a table of indicators and measures with the same values, please also refer to alternative B, table 4, above.

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Cumulative Effects – Alternative D Because the direct and indirect effects are the same as alternative B, the cumulative effects would also be the same as described for alternative B. Summary The activities and locations of concern for sensitive plants are the same for all action alternatives.

Pulsifer’s milkvetch, adobe parsley, and Susanville beardtongue may be affected by the proposed activities. They are documented at one location each where transportation system activities are proposed. The action alternatives include specific “flag and avoid” design features to prevent or minimize adverse impacts to the occurrences. It is possible that some individuals have colonized areas that would be affected by road maintenance, and these individuals may be damaged or killed. In addition, minor amounts of soil and habitat disturbance from transportation system activities could alter rare plant habitats. The project also carries a risk of spreading or introducing noxious weeds; however, the risk is significantly reduced by implementation of the project design features for the prevention and control of these invasive species. Increases in noxious weeds due to this project are not expected to occur in areas more than 100 feet from disturbed treatment areas or roads and trails.

Follett’s monardella is documented at one location in the project area, and it is over 1,000 feet from the nearest activity (trail system improvements along trail #10M37). Due to this distance, no effects to Follett’s monardella plants or habitats are expected.

Because they are not known or suspected to occur in the botany analysis area, no other threatened, endangered, or sensitive plant species would be affected by the proposed actions.

Summary of Environmental Effects Table 5. Summary comparison of effects to TES plants Species Indicator/Measure Alternative A Alternatives B, C and D Astragalus pulsiferae Acres within 100 feet of proposed 0 acres 0.02 acres ssp. pulsiferae activities Pulsifer’s milkvetch Number of sites within 100 feet of 0 sites 1 site proposed activities Effects Determination No impact May affect individuals but is not likely to lead to a loss of viability or trend toward federal listing Lomatium roseanum Acres within 100 feet of proposed 0 acres 0.4 acres adobe parsley activities Number of sites within 100 feet of 0 sites 1 site proposed activities Effects Determination No impact May affect individuals but is not likely to lead to a loss of viability or trend toward federal listing Monardella follettii Acres within 100 feet of proposed 0 acres 0 acres Follett’s monardella activities Number of sites within 100 feet of 0 sites 0 sites proposed activities

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Species Indicator/Measure Alternative A Alternatives B, C and D Effects Determination No impact No impact Penstemon sudans Acres within 100 feet of proposed 0 acres 0.3 acres Susanville activities beardtongue Number of sites within 100 feet of 0 sites 1 site proposed activities Effects Determination No impact May affect individuals but is not likely to lead to a loss of viability or trend toward federal listing

Compliance with Laws, Regulations, and Policies Because the needs of threatened, endangered, sensitive and other rare plants have been evaluated and protection measures established, the Moonlight Range Project complies with the forest plan as amended, the Endangered Species Act, and all applicable Executive Orders and Forest Service Manual direction. The project is also compliant with the Federal Noxious Weed Act, Executive Order 13112, Forest Service Manual 2900, and forest plan guidance concerning noxious weeds.

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References Cited California Natural Diversity Database (CNDDB). 2017. – Downloadable GIS data set. Retrieved on February 13, 2017 from California Department of Fish and Game: http://www.dfg.ca.gov/biogeodata/cnddb/mapsanddata.asp

California Native Plant Society (CNPS). 2017. Online Inventory of Rare and Endangered Plants (8th Edition). California Native Plant Society. Sacramento, CA. Available online (accessed January 2017) at http://www.rareplants.cnps.org/

U.S. Fish and Wildlife Service (USFWS). 2016a. List of threatened and endangered species that may occur in the Moonlight Range Project. Nevada Fish and Wildlife Office. Reno, Nevada.

U.S. Fish and Wildlife Service (USFWS). 2016b. List of threatened and endangered species that may occur in the Moonlight Range Project. Sacramento Fish and Wildlife Office. Sacramento, California.

USDA Forest Service. 1988. Plumas National Forest Land and Resource Management Plan. USDA Forest Service Plumas National Forest, Quincy, CA.

USDA Forest Service. 1999. Executive Order 13112. Presidential Documents, Invasive Species, President William Clinton. Federal Register Vol. 64, No. 25, February 8, 1999.

USDA Forest Service. 2004a. Final Environmental Impact Statement for the Sierra Nevada Forest Plan Amendment. USDA Forest Service Pacific Southwest Region, Vallejo, CA

USDA Forest Service. 2004b. Record of Decision Sierra Nevada Forest Plan Amendment. USDA Forest Service Pacific Southwest Region, Vallejo, CA

USDA Forest Service. 2005. Forest Service Manual 2670-2671. Threatened, Endangered and Sensitive Plants and Animals. Chapter 2670. National Headquarters, Washington, DC. Effective: September 23, 2005.

USDA Forest Service. 2011. Forest Service Manual 2900 – Invasive Species Management. Chapter – Zero Code. National Headquarters, Washington DC. Effective: December 5, 2011.

USDA Forest Service. 2014. Plumas National Forest, Interim Management Prescriptions: Threatened, Endangered, Sensitive and Special Interest Plants. Quincy, CA: Plumas National Forest.

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