BIOLOGICAL ASSESSMENT FOR FEDERALLY LISTED THREATENED OR ENDANGERED PLANT SPECIES

AND

BIOLOGICAL EVALUATION FOR FOREST SERVICE SENSITIVE PLANT SPECIES

FOR THE PROPOSED FRENCH FIRE RECOVERY AND REFORESTATION PROJECT

Sierra National Forest, Bass Lake Ranger District Madera County, California

July 2015

Prepared By: /s/ Joanna Clines Date: July 28, 2015 Forest Botanist EXECUTIVE SUMMARY

The French Fire burned nearly 14,000 acres within the San Joaquin River Canyon in July and August 2014. The Bass Lake Ranger District has completed an Environmental Assessment for the French Fire Recovery and Reforestation Project, to analyze a set of activities intended to recover salvage timber from the burned area and remove hazard trees along roadways, reforest with conifers using herbicides for competing vegetation, manage fuels, maintain a strategic network of fuel breaks (DFPZs) and eradicate the invasive medusahead (Elymus caput-medusae) and other non-native invasive weeds. There are no federally listed plant species in the project area, thus the BA provides information sufficient to establish this; and concludes that no consultation with U.S. Fish and Wildlife Service is necessary for plants. The BE provides species accounts and effects analysis for the Proposed Action and four alternatives, focusing on the four FS sensitive plant species known to occur in the burn (Mono Hot Springs evening primrose, Yosemite lewisia, Rawson’s flaming trumpet, and western waterfan lichen), as well as for five sensitive species that may occur based on the presence of suitable habitat (Bolander’s woodreed, Brook pocket-moss, short-leaved hulsea, Kellogg’s lewisia, and Madera leptosiphon). Because the Project has been designed to protect and conserve FS sensitive plants and their habitat, Project Design Criteria specifying measures to be taken to ensure that negative effects to sensitive plants either do not occur or are minimal; the determination for all nine FS sensitive plant species for the action alternatives (2-5) is that the Project “may affect individuals, but is not likely to lead to a trend toward federal listing or a loss of viability.” This “may affect” determination is because the fire burned through or right up to most of the known sensitive plant populations, and while all are expected to recover; activities proposed would occur adjacent to or near these plants, with at least some chance that a few plants would be affected directly or indirectly. No cumulative effects threshold would be crossed by implementation of any of the alternatives. I. INTRODUCTION

The purpose of this Biological Assessment/Biological Evaluation (BA/BE) is to review the proposed French Fire Recovery and Reforestation Project in sufficient detail to determine the potential effects on Threatened, Endangered, and Sensitive (TES) plant species. Specifically, the BA will analyze effects on federal candidate, proposed, threatened, or endangered species and/or critical habitat; and determines whether formal consultation or conference is required with the US Fish and Wildlife Service, pursuant to the Endangered Species Act. The BE will analyze effects on Forest Service Sensitive Plant species to determine whether the proposed action and/or alternatives would be likely to result in a trend toward a Sensitive species becoming federally listed. This BA/BE was prepared in compliance with direction established in Forest Service Manual 2670 (USDA Forest Service 2005, 2009) and conforms to legal requirements set forth under Section 7 of the Endangered Species Act (19 U.S.C. 1536 (c), 50 CFR 402.12 (f) and 402.14 (c).

(From EA 3/29/14): The Sierra National Forest (Sierra NF), Bass Lake Ranger District (BLRD) is proposing the French Fire Recovery and Reforestation Project (French Fire RRP) (Maps 1 and 2). The BLRD is proposing to take management action to respond to conditions created by the French Fire, which burned approximately 13,832

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acres of National Forest System (NFS) lands on the Bass Lake Ranger District of the Sierra National Forest (SNF) during July and August 2014. Proposed activities include salvaging roadside hazard trees, recovering the economic value of fire-killed/ fire-damaged trees (hereafter termed fire-affected), re-establishing forested conditions, and eradicating invasive non-native plants. For details of proposed activities under each alternative, and for information on other resources affected by the Project, please refer to the Environmental Assessment (EA) for the French Project, which was prepared in compliance with the National Environmental Policy Act (NEPA) and other relevant federal and state laws and regulations.

Map 1. Locality Map – French Fire Recovery and Restoration Project.

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Map 2. French Fire area showing soil burn severity.

The federally listed and Forest Service sensitive plants considered in this document are listed below (species with asterisks are known to occur within the project boundary):

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Federal Threatened MARIPOSA PUSSYPAWS Calyptridium pulchellum

FS Sensitive BOLANDER’S REEDGRASS Cinna bolanderi BROOK POCKET-MOSS Fissidens aphelotaxifolius KELLOGG’S LEWISIA Lewisia kelloggii ssp. kelloggii MADERA LEPTOSIPHON Leptosiphon serrulatus MONO HOT SPRINGS EVENING PRIMROSE* Camissonia sierrae ssp. alticola RAWSON’S FLAMING TRUMPET* Collomia rawsoniana SHORT-LEAFED HULSEA Hulsea brevifolia YOSEMITE LEWISIA* Lewisia disepala WESTERN WATERFAN LICHEN* Peltigera gowardii

Species without asterisks have suitable habitat within the project area, but have not been documented there to date. Appendix A contains the Sierra National Forest TES plant list. All but the nine species listed above are unlikely to occur within the French Fire RRP area because they only occur at higher or lower elevations, the Project is outside their known distributional range, or there is no habitat present.

II. CONSULTATION TO DATE

The Sierra National Forest Botanist checked the US Fish and Wildlife Service web site for proposed, candidate, and federally listed plants that may be found in the project area (US Fish and Wildlife Service, 2015). The list contains two plant species: Mariposa pussypaws (Calyptridium pulchellum) and Keck’s checkermallow (Sidalcea keckii), and shows critical habitat for Keck’s checkermallow, succulent owl’s clover (Castilleja campestris ssp. succulenta), and San Joaquin valley orcutt grass (Orcuttia inaequalis) as potentially occurring within the Forest. Only Mariposa pussypaws is found in the Sierra NF. None of the critical habitat listed falls within the Sierra NF boundary.

Mariposa pussypaws is found below 3600’ in foothill, rather than montane habitats. This tiny annual plant grows on rock outcrops and gravelly or sandy soil in foothill woodland and foothill chaparral. Two populations occur in the Sierra National Forest, both in the vicinity of Sugarloaf Mountain on the High Sierra RD. There is also a population in Madera County along a USFS road on PG&E property. There are no known occurrences of Mariposa pussypaws in or near the project area; the nearest are 7 miles away (Sugarloaf Mountain) and 8 miles away (PG&E lands). The French project occurs above the elevation range for Mariposa pussypaws. Further information on all 9 occurrences of Mariposa pussypaws is available in the draft Conservation Assessment (Guilliams and Clines, 2012).

The nearest known population of Keck’s checkermallow is about 5 miles to the southwest of the southern Sierra NF boundary at Piedra (USDI Fish and Wildlife Service, 2003a). This annual plant grows in clay soils (derived from serpentine) in sparsely-vegetated grasslands at elevations between 400 and 1,400 feet in the foothills of the Sierra Nevada in Fresno and Tulare counties. There is potentially suitable habitat in the area of Hog

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Mountain near Trimmer, just inside the southern Sierra NF boundary. Surveys in the spring of 2004 did not locate Keck’s checkerbloom in that area; however, there is a possibility that undiscovered populations occur in the Sierra NF. The French Fire RRP is above the elevation range for Keck’s checkermallow and does not have serpentine or serpentine-derived clay soils. The nearest designated Critical Habitat for Keck’s checkermallow is in Fresno County about 5 miles to the west of the southern Sierra NF boundary (USDI Fish and Wildlife Service, 2003a).

Vernal pool plant species and Critical Habitat: Critical habitat for succulent owl’s clover is outside the Sierra NF about 4 miles to the west of the Forest boundary (U.S. Fish and Wildlife Service, 2003b). Succulent owl’s clover inhabits vernal pools of various types, which are not common on the Sierra NF. The nearest known populations of succulent owl’s clover are about 4 miles to the west of the Forest boundary on Kennedy Table (Madera County) and on Big Table Mountain (Fresno County) (U.S. Fish and Wildlife Service, 2003b). This species has never been reported to occur within the Forest (CNDDB, 2015; UC Berkeley, 2015). Critical habitat for San Joaquin Valley Orcutt grass is the same as that mapped for succulent owl’s clover (U.S. Fish and Wildlife Service, 2003b). San Joaquin Valley Orcutt grass has never been documented within the Sierra NF either (CNDDB, 2015; UC Berkeley, 2015). There are vernal pools/swales in some areas of the Forest, but they have not been documented to have these two listed species and are different in their geomorphology and drainage than the pools on the nearby “table” mountains, which are topped with basalt (J. Clines, personal observations)

Because no federally listed, proposed, or candidate plant species or critical habitat occurs in the French project area, no consultation is necessary with US Fish and Wildlife Service, and no further analysis will occur for federally listed plant species in this document.

III. CURRENT MANAGEMENT DIRECTION

Existing management direction for federally listed, proposed, and candidate species and Forest Service Pacific Southwest Region Sensitive species is summarized as follows:

Forest Service Manual 2672 (USDA Forest Service 2009) provides standards for biological evaluations and provides a list of all Regional Forester designated sensitive wildlife and plant species occurring on National Forest System lands. Current policy as shown in the Forest Service Manual (FSM 2672.4) is to conduct a pre-field review of available information, and in instances where there is evidence of Sensitive Plant species or habitat, conduct a field reconnaissance if necessary to determine whether the Project poses a threat to Sensitive Plants. The results of surveys and conflict determination and resolution (if applicable) are documented in the BE.

The most recent update to the Regional Forester's Sensitive Plant Species List was formalized on July 3, 2013 (USDA Forest Service, 2013). The species analyzed for the French Fire RRP are based on this 2013 updated list (Appendix A). The following direction was provided to R5 Forests:

“Sensitive species that should be considered for a given project are those that are likely to occur in the project area and may be directly or indirectly affected by the project. Actual occurrence can be

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determined by conducting species surveys or can be assumed present if suitable habitat exists, and the project is within the geographic range of the species. The purpose of the Sensitive species analysis is to evaluate effects and, if needed, help to identify project design considerations to minimize identified adverse effects. To be most efficient and to best meet the proactive conservation objective of the Sensitive species program, project design considerations should be considered by the Interdisciplinary Team during development of the proposed action.”

These instructions were followed during development and design of the French Fire RRP: project design criteria are built into the Proposed Action and alternatives to conserve and ensure long-term sustainability of FS Sensitive plant species (see EA)

Sierra National Forest Land and Resource Management Plan, as amended (USDA FS; 1992, 2004). The Forest Plan direction for Sensitive species is to develop and implement management practices to ensure that Sensitive species do not become threatened or endangered because of Forest Service actions. The Forest Wide Goals and Objectives identified in the Forest Plan for candidate, proposed, threatened, and endangered plant species and Forest Service R5 Sensitive plant species are:

a) Manage fish, wildlife and plant habitats to maintain viable populations of all resident fish, wildlife and plant species,

b) Manage habitat for State and Federally listed threatened and endangered fish, wildlife and plant species to meet the objectives of their recovery plans,

c) Emphasize habitat improvement for sensitive, threatened, endangered and harvest species,

d) Manage habitat for Forest Service sensitive fish, wildlife and plant species in a manner that prevents any species from becoming a candidate for threatened or endangered status. Manage botanical resources to maintain present diversity of species.

Under Forest Plan Management Standards and Guidelines, the Forest is to manage Sensitive Plant species to avoid future listing as threatened and endangered, and to ensure maintenance of genetic and geographic diversity and viable populations of Sensitive plants (S&G # 68). The Forest Plan also states that the Forest will conduct Sensitive Plant surveys and field investigations prior to any ground-disturbing activity in areas that Sensitive Plants are known or suspected to occur. Avoidance or mitigation measures are to be included in project plans and Environmental Assessments (USDA FS 1992).

Sierra Nevada Forest Plan Amendment, US Forest Service 2004:

Standard and Guideline for Sensitive Plant Surveys

125. “Conduct field surveys for TEPS plant species early enough in the project planning process that the project can be designed to conserve or enhance TEPS plants and their habitat. Conduct surveys according to procedures outlined in the Forest Service Handbook (FSH 2609.26). If additional field surveys are to be conducted as part of project implementation, survey results must be documented in the project file.”

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IV. PROJECT DESCRIPTION: PROPOSED FRENCH FIRE RECOVERY AND REFORESTATION PROJECT From the Environmental Assessment:

Alternative 1 (No Action)

The analysis of the no action alternative provides reviewers a baseline to compare the magnitude of environmental effects of the action alternatives and the potential long-term impacts from not implementing the Project. Under the no action alternative, salvage harvest, hazard tree removal, DFPZ creation and maintenance, SCE power line fuels treatment, invasive weed treatment as described in the action alternatives, prescribed burning, and tree planting in specified treatment areas would not occur.

Current management plans would continue to guide management of the Project area, for example recreation, grazing, Burned Area Emergency Response (BAER) treatments for invasive weeds and roads, and fire suppression would continue under existing decisions and authorities. In general, existing conditions in the Project area would be driven by vegetation response to fire effects, amount of precipitation, and insect attack. Fire-affected trees would be subject to decay and breakage. High and moderate severity areas most affected by the fire would see shrubs sprout and seeds scarified by heat would germinate in the spring of 2015. Surviving conifers adjacent to high and moderate severity areas would cast seed. Areas of low and very low severity still dominated by conifers would see increased growth. There would be no invasive weed control beyond the manual and mechanical control to be conducted with BAER funds in 2015. Alternative 2 (Proposed Action)

Alternative 2 includes eight groups of activities that consist of: removing roadside and developed recreation site hazard trees, removing fire affected trees for economic recovery, snag retention, fuels reduction, road maintenance and construction of temporary roads and landings, reforestation treatments (site preparation, planting, and release, including the use of herbicides), and invasive weed eradication and control (including the use of herbicides).

Of the 13,832 total acres within the project boundary, 7,926 acres were analyzed in detail for potential treatment; approximately 7,863 acres have some form of treatment proposed (Detailed Analysis Units). The remaining 8,136 acres have no treatments proposed due to fire severity, resource concerns, slopes greater than 35%, LRMP standard and guideline limitations on treatment, and/or no treatment is needed to meet the purpose and need. Please see the EA for locations of treatment areas under Alternative 2.

To meet the purpose and need for the project, the following activities are proposed under Alternative 2:

2.1. Remove Roadside and Developed Recreation Site Hazard Trees

Hazard trees would be felled and removed along approximately 60 miles of roads within the Project area (totaling approximately 2353 acres, if calculated with no overlap of treatments). Hazard trees will be assessed within 300 feet of the road or developed recreational areas; the majority of hazard trees marked to be removed would be within one tree height of these areas or approximately 150 feet.

Fire-affected and insect-affected trees along roads and near structures and developed recreation sites would be felled and removed. Determinations of hazard trees will be made using the Hazard Tree Guidelines for Forest Service Facilities and Roads in the Pacific Southwest Region (Angwin et al. 2012). In addition, hazard trees would be identified using the fire mortality guidelines from Marking Guidelines for Fire-Injured Trees in California

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(Smith and Cluck 2011), with an average probability of mortality = 0.7 used to determine which trees would be expected to die within 5 years. Hazard trees (which could be either fire-killed or live trees) would have to be within striking distance of a road, trail, or other improvements and show a high failure potential. High failure potential is determined by the presence of substantial defects such as, but not limited to, excessive lean, bole and root decay, bole cracks, severe burn injury to roots and/or bole, and dead tops.

The following activities are proposed for roadside and developed recreation site safety hazard treatments:

Mechanically remove fire-affected trees utilizing ground-based systems. Non-merchantable trees may be masticated (shredded), machine piled, removed as biomass or felled and left on site and potentially hand piled. Merchantable trees (generally greater than 10 inches diameter at breast height (dbh) depending on timing of removal) would be removed commercially harvested as sawlogs.

Treat slash concentration by hand or mechanically piling and burning, up to 300 feet within identified road corridors, to create and maintain a strategic control point for firefighter safety during fire suppression operations.

The 300 foot roadside buffer would have fuels manipulation and/or reduction. This would be completed using varying methods dependent on the landscape, treatment, and fuel loading, including lop and scatter to 18 inches from the ground, jackpot or pile burning, machine and hand piling, and biomass removal. The treatment would meet the requirements for both fuels reduction and soil protection.

All hazard trees within Fish Creek and Rock Creek Campgrounds would be cut and removed, and slash piled and burned.

Borax fungicide treatment would be applied on all freshly cut conifer stumps 3 inches in diameter or larger (dead trees as well as trees with any green foliage) within developed recreation areas.

2.2. Recover Economic Value of Fire and Insect-Affected Trees

Removal of merchantable fire and insect-affected trees (sawlogs) utilizing mechanically ground-based logging systems is proposed to meet the need to recover economic value from the Project area, totaling approximately 3,371 acres.

Fire-affected conifer trees would be felled and removed from high and moderate fire severity areas on ground suitable for ground based harvest, during the first harvest the treated area is under 2,000 acres. Additionally other areas of high and moderate conifer mortality will occur as drought and insects take their toll on fire weakened trees, this is referred to as secondary entry. The affected conifers in the secondary entry would be felled and removed from these additional areas; having burned less severely, in conjunction with fire stress, drought conditions and insects infestation increase the conifer mortality. This second entry would total approximately 910 acres. Plantations within the fire area that would be treated include 477 acres.

Tree removal operations within high and moderate fire severity areas would remove all trees in excess of snag retention needs using a probability of mortality rating. Areas of lower fire severity adjacent or within tree removal stands (high and moderate severity) are priorities for snag retention requirements.

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2.3. Retain Snags

The Project’s snag retention strategy requires the equivalent of 4 snags per acre be left throughout the Project area, maintaining heterogeneity in the landscape for wildlife. Snags on slopes exceeding 35 percent that do not pose a roadside hazard would be left to retain habitat for wildlife; snags would be left in large patches (1 to 200 acres+) and multi-snag clumps, particularly in key spotted owl and black-backed woodpecker habitat. Some snags would be randomly distributed throughout the stands to meet soil resource standards while in other areas, patches (several acres) or clumps of 4 to 10 snags would be left for wildlife resources. Snag retention patches or clumps are composed of dead (high and moderate severity) and live (low and very low severity) trees where possible. Snag retention needs would be evaluated and averaged for each 10 acres of trees removed. Where necessary, standing snags in areas that would be reforested could be felled, lopped and scattered to provide a safe working environment.

2.4. Re-establish Forested Conditions

Approximately 7,315 acres of NFS land experienced moderate to high vegetation burn severity, 3,320 acres of this mortality is in treatment areas. The area harvested for timber would be hand planted with 1 and 2-year-old mixed conifer seedlings (emphasizing shade intolerant pines where appropriate).

Reforestation includes site preparation and planting of native conifer seedlings in areas of moderate and high fire severity. Areas of naturally seeded conifers would be thinned and managed along with planted seedlings. All manually and mechanically piled vegetation would be burned, except where retained for wildlife cover. Site preparation and planting would take place on up to 3,000 acres. Replanting would be undertaken in failed portions of plantations where necessary, if feasible.

Site preparation (jack pot and pile burning of slash concentrations) for planting would include mastication of dead trees and brush, hand felling of dead trees, tractor piling of slash and brush, grapple piling, and chemical (Glyphosate and R11 surfactant) ground application. Site preparation related chemical treatments are specifically proposed to control bear clover (Chamaebatia foliosa).

Planting would be accomplished by hand. Power augers, hoedads, planting shovels or other hand planting tools would be used. Maintaining the trees as they grow and protecting them from competing shrubs, grasses, or bear clover would be accomplished by hand (hoes, axes, and chainsaws) or in some instances chemical (Glyphosate and R11 surfactant) ground application. Post-planting related chemical treatments are specifically proposed to control competing brush that sprouts from roots or stump collar where hand treatments alone have proven ineffective. These species include deer brush (Ceanothus integerrimus), mountain whitethorn (Ceanothus cordulatus), green leaf mazanita (Arctostaphylos patula), and bear clover.

2.5. Road Maintenance, Road Reconstruction, and Construction of Temporary Roads and Landings

In order to implement the Project and other management activities in the area, approximately 83 miles of existing NFTS roads would be repaired and maintained as necessary. Activities may include grading, improving drainage features, laying gravel, replacing culverts, etc. The Project design utilizes as many existing suitable temporary roads, skid trails, and landings as possible. Some existing temporary roads and landings would be reopened and approximately 2 miles of new temporary roads and landings would be constructed for Project implementation. Pre-haul maintenance would be completed to ensure that roads and drainage structures are functional.

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Dust abatement would include a combination of water and dust abatement binder such as oil or magnesium chloride.

Approximately 2.5 miles of Maintenance Level 1 (closed roads) road segments would be upgraded to Maintenance Level 2 roads (high-clearance vehicles) for administrative use only. Approximately 2 miles of temporary roads would be constructed to implement the salvage logging operations, and then eliminated after project activities are complete.

2.6. Create and Maintain DFPZ’s in Strategic Locations to Help Manage Future Wildfires.

Fuels treatment and maintenance would occur on approximately 221 acres within existing and proposed DFPZ’s, 126 acres overlap with other treatments. These areas are 150 feet wide and are located along dominant ridges and terrain features.

Fuels reduction treatments include the use of burning piles and jackpot burning, hand, mechanical (dozer or mastication) and chemical (glyphosate and surfactant R11) treatments. Chemical release treatments are specifically proposed to control woody plants that reestablish from seed and/or re-sprout from the base to keep these areas in a more open condition. These species include: buckbrush (Ceanothus cuneatus), deer brush, mountain whitethorn, chaparral whitethorn (Ceanothus leucodermis), mariposa manzanita (Arctostaphylos viscida ssp. mariposa), green leaf manzanita, and bear clover.

2.7. Cleanup of felled trees along Southern California Edison Company (SCE) Stevenson 12 kilovolt (kV) distribution line right of way.

Fuels treatments within the SCE Stevenson 12 kV distribution line right of way would occur on approximately 285 acres within a 300 foot wide (150 feet on either side of centerline) corridor. The primary fuels reduction treatments would be accomplished by mechanically removing currently downed trees utilizing ground-based logging systems. Other methods to reduce fuels would be piling by machine or hand, burning piles and underburning with jackpots of fuels.

2.8. Invasive Weed Eradication

Medusahead (Elymus caput-medusae) would be controlled using a combination of manual, mechanical, and chemical methods, each timed for maximum efficacy (integrated pest management). Herbicide treatments for invasive weeds would be done with backpack sprayers by workers walking the ground. Medusahead plants and patches would be sprayed with glyphosate with R-11 surfactant. Native and desirable non-native plants would be avoided to the extent practical. Medusahead in SMZs would be controlled with manual methods only. Please see Project Design Criteria for herbicides – invasive weed treatments have been carefully designed to eliminate damaging weeds while protecting native plants, wildlife, and water quality; as well as human health and safety.

Treatments would occur each year until monitoring determines infestations have been eradicated. Medusahead seed is not generally viable for more than 2-3 years thus by 5-6 years eradication is possible. Other invasive weed species (discussed below) encountered during surveys would be treated using a combination of hand pulling and glyphosate applications with surfactant R-11.

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Herbicide and mechanical treatments for invasive weeds would only occur within the following areas (see map in EA):

 Polygons of known medusahead infestations ,  Roadside hazard zone (300’ on either side of roads shown on map in EA),  SCE powerline corridor,  Detailed Analysis Units where salvage logging and reforestation are proposed,  Defensible Fuel Profile Zones (DFPZs).

Invasive weeds occurring outside these locations would be manually controlled only.

The most likely additional invasive weed species to occur in the Project area are: bull thistle (Cirsium vulgare), woolly mullein (Verbascum thapsus), Italian thistle (Carduus pycnocephalus), klamathweed (Hypericum perforatum) tocolote (Centaurea melitensis), stinkwort (Dittrichia graveolens), and smilograss (Stipa miliacea ssp. miliacea). This is based on the presence of these weeds on nearby lands and at the USFS compound in North Fork where fire suppression and road maintenance equipment have been staged prior to traveling to the French Fire area.

Table 1. Summary of Alternative 2 treatment activities.

Activities – Alternative 2 Acres Treated Total Salvage Harvest1 3,371  First entry acres 1984  Secondary entry acres 910  Plantations 477 Total Roadside Hazard Tree Removal (with overlap) 3712  Without overlap 2353 Total Reforestation – (Site Preparation and Tree Planting2) Up to 3,000  Estimated Replanting after initial planting 500  Estimated herbicide site prep treatment 2,600  Estimated herbicide release treatment 450  Estimated hand release treatment (funding dependent) 1,600 DFPZ creation and maintenance (no overlap)(hand, mechanical, chemical) 96 SCE Power Line Fuels treatment (no overlap) 112 Estimated Invasive Weed treatment (chemical and other methods) 32 Transportation  Road maintenance/reconstruction 83  Temporary road construction 2.5 3 Total Footprint of Treatment Areas 5965

Please see the EA for a full listing of Project Design Criteria (DC) for the action alternatives. This effects analysis for FS sensitive plants rests strongly on DC for hydrology, soils, herbicides, and aquatic wildlife – especially the

1 Roadside hazard tree removal overlaps 1,359 acres of the identified salvage harvest and planting areas. 2 The tree planting involves site preparation and chemical release. 3 The total “footprint” acreage figure does not include overlap with other treatment areas. It represents the actual landscape footprint.

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100’ Streamside Management Zones (SMZs) where no heavy equipment may enter and ground disturbance may only occur in a limited fashion (e.g. hazard trees may be dropped but usually would not be moved). Specific DC for FS sensitive plants are listed below to facilitate understanding of the effects analysis and determinations:

PROJECT DESIGN CRITERIA COMMON TO ALL ACTION ALTERNATIVES: Botanical Resources and Invasive Weeds

 Along streams with occurrences of Rawson’s flaming trumpet (Collomia rawsoniana), a riparian- dependent FS sensitive plant; patches of plants will be flagged for avoidance only if they are not protected adequately by SMZs. Flagging would be green lime-glo and white tied together. Streams affected are: Fish Creek, Slide Creek and tributaries, and Rock Creek and tributaries, and an unnamed perennial stream flowing into Mammoth Pool within Detailed Analysis Unit 3. (SNF 1992 LRMP S&G #68 and SNFPA ROD S&G #125 )

 FS sensitive plants of rock outcrops and adjacent sand or gravel that are known to occur in the project area, such as Yosemite lewisia (Lewisia disepala) and Mono Hot Springs evening primrose (Camissonia sierrae ssp. alticola), will be flagged for avoidance with green lime-glo and white flags tied together if necessary to ensure trees are not felled in occupied habitat and that end-lining does not occur through the habitat. (SNF 1992 LRMP S&G #68 and SNFPA 2004 ROD S&G #125 )

 Equipment and vehicles may be driven or parked on granitic rock outcrops and associated gravel and sandy soil pans only after the Sale Administrator consults with the FS botanist. This protects known populations and suitable habitat for the following species: Mono Hot Springs evening primrose Yosemite bitterroot lewisia, and Kellogg’s lewisia (Lewisia kelloggii ssp. kelloggii). Log decks, burn piles and other stacked materials should not be placed on these areas for the same reasons. (Derived from SNF 1992 LRMP S&G#67 and #68 and SNFPA 2004 ROD S&G #125).

 As much native material ground cover should be left on the ground as practicable, not only for erosion control purposes but also as a source for seed and propagules for native vegetation. (FSH 2609.26 – 40.3 Botanical Program Management - Revegetation)

 Any erosion control material that is being brought in from areas outside of the project area needs to be analyzed by appropriate specialists for its efficacy, pertinence and risk of weed spread (this does not include the BAER erosion control that has already been completed; it only applies to erosion control measures for the Project). This includes not only plant material but also manufactured materials, such as geotextiles or rock/fill brought in from other areas. (SNFPA ROD S&G #40, #42 and #45).

 In case new species or occurrences of sensitive plants are found in areas of treatments during the lifespan of this Project, new Controlled Areas will be flagged for avoidance with lime glo and white flagging; locations GPS-ed, and the information promptly provided to the Sale Administrator. (SNF 1992 LRMP S&G #68

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 If additional weed locations are found during botanical field surveys during the lifespan of this Project, they will be GPS-ed, flagged for avoidance with orange tape marked with the words “INVASIVE NOXIOUS WEEDS,” and the locations given promptly to the Sale Administrator who will notify the contractor. (SNFPA 2004 ROD S&G #40 and #48)

 Ensure that all equipment used for removal of trees, skidding and/or road maintenance is clean (free of soil, seeds, plant parts, and propagules) before being brought into the Project area. This would minimize the importation of new weeds into the burned area. (SNFPA 2004 ROD S&G #39).

 If equipment or off-road vehicles are used within the areas of mapped medusahead and other invasive weeds, they would be washed upon exiting those areas and prior to travel to new, uninfested areas. Washing locations will be approved by the Sale Administrator after consultation with Forest Service botany and hydrology specialists. (SNFPA 2004 ROD S&G #39).

Herbicides (these Design Criteria do not apply to Alternative 3, which has no herbicide use proposed) In addition to the following criteria, see the E`A for design criteria for herbicides specific to aquatic and riparian habitats and their associated species.

 All applicable pesticide laws and label restrictions would be followed to ensure human health and safety (BMP 5.8).

 All manufacturers label instructions for glyphosate, R-11, and color fast purple dye shall be followed.

 Herbicide applications would be accomplished using backpack sprayers by workers on foot.

 Spray operations would cease when sustained average wind speeds exceed five miles per hour. Spray operations shall momentarily cease when wind gusts exceed seven miles per hour.

 Spray operations would cease if precipitation is occurring or if it is predicted with 70% certainty within 6 hours. Spraying would not resume after a precipitation event until the target vegetation has dried, typically 24 hours after the end of any precipitation that wets the target species.

 Herbicide applications for invasive weeds would target only the weeds of concern to the extent practical. For example, herbicide would be sprayed on medusahead plants or patches of plants and non- target native or desirable non-native plants would be avoided.

 Non-work areas within herbicide treatment areas would be flagged for avoidance (e.g. SMZs, controlled areas for sensitive plants).

 In order to maintain and recruit oaks in the recovering landscape for wildlife habitat and native plant diversity, seedlings and stump-sprouting oaks would be avoided during spraying as per guidelines

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currently under development by the IDT (guidelines would ensure adequate oak retention and recruitment). (2004 SNFPA ROD, S&Gs 18, 19, 20, 26).

 Plants of special importance to local Native Americans (e.g. deer grass, sourberry, redbud, wormword, elderberry, willow) would be carefully avoided when using both herbicide and manual methods.

 Herbicides would not be sprayed within known Native American gathering sites; these gathering sites would be flagged for avoidance and any invasive weeds would be hand-pulled. Throughout the duration of the Project, the FS botanist and archaeologist (with silviculturist as needed) would continue ongoing field visits to these sites with tribal members to coordinate precise locations that would not be sprayed.

Alternative 3 (No Herbicides)

Alternative 3 differs from alternative 2 in that no herbicides would be applied for any purpose. Management techniques for achieving the purpose and need for reforestation, DFPZs, and invasive weeds would be limited to manual or mechanical methods. All other treatments would remain the same as the proposed action. See Table 2 for treatment acres and the EA for treatment unit areas map of alternative 3.

3.1. Re-establish Forested Conditions

Reforestation strategies would occur as described in the proposed action; however no herbicides would be used to control bear clover, and competing brush that sprouts from roots or stump collar, including deer brush whitethorn , and green leaf manzanita ,during reforestation efforts. Instead competing vegetation would be hand grubbed (hoed) for a radius of 4 to 5 feet around planted trees within a few days of planting. At least two additional hand grubbing treatments would be required; one every two to three years, as bear clover reinvades the planting spot. Replanting would be done in failed planting areas. At least one total replanting treatment is anticipated due to projected poor survival. Bear clover would remain outside of the grubbed planting areas. Bear clover rhizome root systems would continue to compete for moisture within the grubbed areas.

All hand and mechanical piled vegetation would be burned, except where retained for wildlife cover. Maintaining the trees as they grow and protecting them from competing shrubs, grasses, or bear clover would be accomplished by hand (hoes, axes, and chainsaws). See Table2 for a comparison of the differences in acres of site preparation and release treatments.

3.2. Invasive Weed Eradication

Invasive weed control under alternative 3 would use mechanical and/or manual methods. Medusahead would be controlled without the use of herbicides. Methods would be hand-pulling and bagging, hoeing, and string trimming; over a gross area of approximately 32 acres. The known locations of medusahead are identified on a map in Appendix B. It is also expected that new occurrences of this species and possibly other weed species would be discovered within other areas of the Project area. Multiple entries would occur each year to ensure that control methods are adequate, unless the success of manual and mechanical methods is too poor to continue in areas of

dense infestation.

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Other weed species, as described in alternative 2, would be treated with similar techniques described above if found within the Project area Treatments would occur each year until monitoring determines infestations have been eradicated.

Table 2. Summary of Alternative 3 treatment activities.

Activities – Alternative 3 Acres Treated Total Salvage Harvest4 3,371  First entry acres 1984  Secondary entry acres 910  Plantations 477 Total Roadside Hazard Tree Removal (with overlap) 3712  Without overlap 2353 Total Reforestation – (Site Preparation and Tree Planting5) Up to 3,000  Estimated replanting (several replanting efforts) 5,000  Estimated hand release (3 treatments minimum) 9,000  Estimated herbicide site pep treatment 0 DFPZ creation and maintenance (no overlap)(hand, mechanical, chemical) 96 SCE Power Line Fuels treatment (no overlap) 112 Estimated Noxious Weed treatment  Chemical 0  Mechanical & hand 32 Transportation  Road maintenance/reconstruction 83  Temporary road construction 2.5 6 Total Footprint of Treatment Areas 5965

Alternative 4 (Hazard Tree and Plantation Salvage Only)

Alternative 4 reflects the public’s concern for salvage logging in moderate to high burn severities and treatments in proximity to California Spotted Owl Protected Activity Centers (PACs). This alternative differs in salvage treatments from Alternative 2 because it would only remove roadside and developed recreation site hazard trees and harvest salvage trees within plantation units only that are greater than 1.5 kilometer (circular area) from California Spotted Owl PACs.

The other proposed treatments for snag retention, roads, DFPZ, SCE’s power line right-of-way, and noxious weeds would be the same as alternative 2; although the acres of overlapping treatments differ, as shown in Table 3.

4.1. Remove Roadside and Developed Recreation Site Hazard Trees

Under alternative 4, the same amount of miles of roadside hazards would be treated; however, since there would be fewer acres of salvage and secondary salvage being treated, there would be less of an overlap of hazard trees treatment areas. The hazard trees that would have been removed in the salvage treatment areas identified in

4 Roadside hazard tree removal overlaps 1,359 acres of the identified salvage harvest and planting areas. 5 The tree planting involves hand or mechanical site preparation. 6 The total “footprint” acreage figure does not include overlap with other treatment areas. It represents the actual landscape footprint.

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alternative 2 would now be considered under the roadside hazard tree removal treatments, totaling 3513 acres of no overlapping treatments. Methods of hazard tree removal would be the same as alternative 2.

4.2. Recover Economic Value of Fire and Insect-Affected Trees

Alternative 4 differs the most in the location of salvage treatments, as there would be not a first or second entry salvage, except in plantations over 1.5 km from CSO PACs. Fire affected trees would not be removed in approximately 70% (Jody is double checking this number) of high severity outside of these identified plantation units areas and the roadside hazard tree buffer. Approximately 518 acres would be treated within plantation units.

Thirty plantation units would not be treated or portions of units not treated because of areas that overlap the 1.5 km circular area surrounding owl territory centers.

4.3. Re-establish Forested Conditions

Site preparation and planting would still occur as specified in alternative 2. However, the location of the planting would be restricted to areas of high burn severity in the roadside hazard tree treatment and the plantation that do receive salvage treatment.

The same thirty plantation units not salvage logged would not be planted because of areas that overlap the 1.5 km circular area surrounding owl territory centers.

Table 3. Summary of Alternative 4 treatment activities.

Activities – Alternative 4 Acres Treated Total Salvage Harvest7 514  First entry acres 0  Secondary entry acres 0  Plantations 514 Total Roadside Hazard Tree Removal (with overlap) 3712  Without overlap 3513 Total Reforestation – (Site Preparation and Tree Planting8) Estimated 2,400  Estimated replanting 400  Estimated herbicide site prep treatment 2,000  Estimated herbicide release treatment 300  Estimated hand release treatment (funding dependent) 1300 DFPZ creation and maintenance (no overlap)(hand, mechanical, chemical) 138 SCE Power Line Fuels treatment (no overlap) 136 Estimated Noxious Weed treatment (Chemical and other methods) 32 Transportation  Road maintenance/reconstruction 83  Temporary road construction 2.5 9 Total Footprint of Treatment Areas 4333

7 Roadside hazard tree removal overlaps 1,359 acres of the identified salvage harvest and planting areas. 8 The tree planting involves site preparation and chemical release. 9 The total “footprint” acreage figure does not include overlap with other treatment areas. It represents the actual landscape footprint.

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Alternative 5 (No Secondary Entry)

The difference between alternative 5 and alternative 2 is that fire affected trees would be removed and harvested on approximately 1,946 acres in moderate to high burn severity as the only salvage entry. 910 acres of low to moderate burn severity would not be treated. Units u33m (4 acres) and u53m (4 acres) would not be treated so that patches of 10 acres or less would not be treated in high severity areas. Units u47m (5 acres), u453m (23 acres) and portions of u52m (9 acres) would not be treated because they fall within 1 km circular area of CSO PAC MAD45 in which less than 32% of the territory burned at high severity.

The other proposed treatments for snag retention, roads, DFPZ, SCE’s power line right-of-way, and invasive weeds would be the same as alternative 2; although, the acres of overlapping treatments differ, as shown in Table 4.

5.1. Remove Roadside and Developed Recreation Site Hazard Trees

Under alternative 5, the same amount of miles of roadside hazards would be treated; however, since there would be no secondary entry for salvage treatment, there would be less of an overlap of hazard trees treatment areas. The hazard trees that would have been removed in the second entry treatment areas identified in alternative 2 would now be considered under the roadside hazard tree removal treatments, totaling 2773 acres of no overlapping treatments. Methods of hazard tree removal would be the same as alternative 2.

5.2. Recover Economic Value of Fire and Insect-Affected Trees

Alternative 5 differs in that the secondary entry of salvage treatments would not take place, as a means to not treat low to moderate burn severity areas. Fire affected trees would not be removed in approximately 56% of high severity outside of the identified first entry units areas and the roadside hazard tree buffer. Approximately 2461 acres would be treated in this alternative.

5.3. Re-establish Forested Conditions Site preparation and planting would still occur as specified in alternative 2. The location of the planting would be restricted to areas of high burn severity in the roadside hazard tree treatment and salvage treatment areas.

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Table 4. Summary of Alternative 5 treatment activities

Activities – Alternative 5 Acres Treated Total Salvage Harvest10 2464  First entry acres 1934  Secondary entry acres 0  Plantations 5527 Total Roadside Hazard Tree Removal (with overlap) 3712  Without overlap 2773 Total Reforestation – (Site Preparation and Tree Planting)11 Estimated 2,900  Estimated replanting 450  Estimated site prep herbicide treatment 2,500  Estimated herbicide release treatment 400  Estimated hand release (funding dependent) 1,600 DFPZ creation and maintenance (no overlap)(hand, mechanical, chemical) 105 SCE Power Line Fuels treatment (no overlap) (hand, mechanical) 114 Estimated Invasive Weed treatment (chemical and other methods) 32 Transportation  Road maintenance/reconstruction 83  Temporary road construction 2.5 12 Total Footprint of Treatment Areas 5453

V. AFFECTED ENVIRONMENT

The French Fire burned 13,832 acres on the west slope of the central Sierra Nevada in late summer 2014; within an elevation range of 3676 to 7933 feet.

The French Fire was reported 28 July, 2014 in the San Joaquin River canyon along Rock Creek just upslope from its confluence with the San Joaquin River. The fire burned 13,835 acres of chaparral, oak woodland, ponderosa pine forest, mixed conifer forest and a small amount of red-fir forest. No damage was done to FS Sensitive plants during suppression, though the fire did burn through habitat of several FS sensitive plant species that are expected to recover (Engelhardt et al., 2014).

Fire suppression activities resulted in construction of 73.2 miles of fire line - 61.5 miles of dozer line and 12.2 miles of hand line. An additional 38.6 miles of existing fire line occurs within the fire area, most of which was established as contingency line during the adjacent Aspen Fire in 2013. The fire and fire-suppression lines overlapped spatially with known invasive plant infestations. Weed washing was established at the North Fork ICP the following day after initial suppression efforts were initiated. However, suppression equipment and crews are known to have traveled through areas of invasive plant infestations during fire suppression and suppression rehab ; thus rehab and repair work post-fire also has the potential to spread noxious weeds (Engelhardt et al.,

10 Roadside hazard tree removal overlaps 1,359 acres of the identified salvage harvest and planting areas. 11 The tree planting involves site preparation and chemical release. 12 The total “footprint” acreage figure does not include overlap with other treatment areas. It represents the actual landscape footprint.

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2014). Funding was approved for BAER activities to address the invasive weed emergency: surveys and manual/mechanical control of medusahead and other invasive weeds, as found, will occur during 2015.

The project area is within the Sierra Nevada Ecological Section (M261E) with a small portion in Section M261F (Sierra Nevada Foothills) in the USDA Forest Service National Hierarchical Framework of Ecological Units (Miles and Goudey, 1997). M261E is the montane zone through the alpine zone that extends from north to south in the Sierra Nevada. Climate is one of wet, cold winters with 20-80 inches of precipitation falling mostly as snow above 6000 feet; and dry, warm summers. The lowest elevations of the Project area are categorized in Section M261F, Sierra Nevada Foothills. In this belt, precipitation averages 20-40 inches, mostly falling as rain in the winter.

Vegetation varies from foothill woodland and annual grassland at the lower elevations to mixed chaparral, ponderosa pine and mixed conifer forest at low to middle elevations, with montane chaparral and expanses of rock outcrop scattered throughout the area. The northern half of the project area has large areas of rock outcrops, which though often termed “barren” sites on vegetation maps, are characterized by a suite of diverse native species adapted to live in the desert-like conditions of these exposed areas, including rare plant species.

The French Fire Botanical Resources BAER Report (Engelhardt et al., 2014) characterized the vegetation within the French Fire using California Wildlife Habitat Relationship types by soil burn severity as shown in Table 5.

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Table 5. Vegetation types by soil burn severity within the French Fire.

Vegetation type Soil burn severity Acres % of Acres Total acres (CWHR types) Low 5.4 86 Annual grassland 6.3 Moderate 0.9 14 Low 0.03 1 Blue oak/gray pine woodland Moderate 3.1 79 3.9 High 0.8 21 Unburned/Very low 3.9 17 Blue oak woodland Low 12.9 55 23.4 Moderate 6.6 28 Unburned/Very low 243.5 23 Low 356.1 34 Mixed chaparral 1037.7 Moderate 402.5 39 High 35.6 3 Unburned/Very low 69.2 21 Low 101.6 31 Montane chaparral 333.1 Moderate 145.5 44 High 16.8 5 Unburned/Very low 247.1 9 Low 919.4 32 Montane hardwood- conifer 2898.5 Moderate 1399.1 48 High 332.9 11 Unburned/Very low 310.9 7 Low 1391.9 30 Montane hardwood 4671.2 Moderate 2508.9 54 High 459.5 10 Unburned/Very low 151.8 7 Low 692.4 31 Ponderosa pine 2214.1 Moderate 1073.8 48 High 296.1 13 Unburned/Very low 1.5 65 Red fir 2.3 Low 0.8 35 Unburned/Very low 167.6 7 Low 804.4 36 Sierra mixed-conifer 2259.9 Moderate 1005.5 44 High 282.4 12

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The lower elevations of the project area contain elements of foothill chaparral, dominated by mariposa Manzanita (Arctostaphylos visicida ssp. mariposa) buckbrush (Ceanothus cuneatus), mountain mahogany (Cercocarpus betuloides), and foothill pine (Pinus sabiniana), but most of the chaparral in the project area is best classified as montane chaparral, dominated by mariposa manzanita, greenleaf manzanita (Arctostaphylos patula), mountain whitethorn (Ceanothus cordulatus), deerbrush (Ceanothus integerrimus), littleleaf ceanothus (C. parvifolius), bitter cherry (Prunus emarginata) and Sierra gooseberry (Ribes roezlii). Chinquapin (Chrysolepis sempervirens) is found in the uppermost reaches of the project area.

This west slope foothill chaparral is characterized by a rich native herbaceous flora; of which many species are only present or in much greater abundance directly after fire. Some herbaceous chaparral species are present most years, varying in vigor and floral output with annual weather patterns. Others are found only after fire: there is a suite of chaparral annuals that germinates in response to cues such as heat, smoke, or the chemical makeup of rainwater that passes through burned shrubs (Keeley and Keeley, 1987). This unique and temporally sporadic component of the chaparral ecosystem is important to maintain the long term native biological diversity of the chaparral and confers some resistance to invasive non-native plant invasions.

Montane chaparral occurs at higher elevations than foothill chaparral and does not tend to have as specialized of a post-fire herbaceous flora. Montane chaparral either exists on sites where soils are too thin or rocky to support forests, or exists as an early seral stage after disturbance such as burning, timber harvest, or fuels reduction. Often called “brush fields,” areas dominated by montane chaparral that were previously forested can be characterized by a heterogeneous mix of shrub species or they can be quite homogeneous – often dominated by impenetrable stands of mountain whitethorn and greenleaf manzanita between fires.

The lower coniferous forest areas are typically dominated by a mixture of ponderosa pine (Pinus ponderosa), incense cedar (Calocedrus decurrens), and black oak (Quercus kelloggii) with an understory of mariposa manzanita, buckbrush, deerbrush, and canyon live oak (Quercus chrysolepis). Higher in elevation the forest changes to true mixed conifer forest with the addition of sugar pine (Pinus lambertiana) and a higher proportion of white fir. The understory shrubs are more typical of montane chaparral (greenleaf manzanita, chinquapin, mountain whitethorn, bitter cherry).

Riparian vegetation, along stream or in meadows; is comprised of plants of wet or moist conditions.There are no meadows to speak of in the Project area, but there are miles of riparian vegetation along perennial streams, s well as some intermittent streams. Riparian vegetation along streams varies considerably within the project area, ranging from clearly defined bands of riparian forest dominated by white alder (Alnus rhombifolia), mountain alder (A. incana ssp. tenuifolia), willow (Salix spp.), and Oregon ash (Fraxinus latifolia) to simply a strip of shrubby or herbaceous riparian plants with upland forest trees growing next to the stream.

Forest Service Sensitive Plant Species in the Project Area

Sensitive species are those species that have been specifically designated by the Regional Forester as needing special management in order to prevent them from losing long-term viability or becoming federally listed as endangered or threatened; either because they are naturally rare or because their numbers have been reduced

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by human causes. In the Sierra NF the former is generally the case. Much has been written about endemism and rarity in the California flora (e.g. Fiedler, 2001: http://www.cnps.org/cnps/rareplants/inventory/rarity.php; and Shevock (1996: http://ceres.ca.gov/snep/pubs/web/PDF/VII_C24.PDF). Based on a review of these articles and other scientific literature, along with historical collections available through the Consortium of California Herbaria (UC Berkeley, 2015), there is no reason to suspect that the species known or suspected to be present in the French Fire RRP area were considerably more common in the past.

Table 6 shows the Forest Service Sensitive Plants that are known to occur or that may occur within the French Fire RRP area based on the fact that suitable habitat is present. Species known to occur within the overall project boundary are shown in bold text:

Table 6. Forest Service Sensitive Plant Species Known or with Potential to occur within the French Fire Recovery and Restoration Project Area, along with their habitat types.

SPECIES OCCURRENCE IN FRENCH FIRE RRP AREA HABITAT Camissonia sierrae ssp. alticola (CASIA) DETAILED ANALYSIS UNIT 4: Occurrence CASIA-15-14 as currently ROCKY/GRAVELLY. Gravel MONO HOT SPRINGS EVENING PRIMROSE mapped overlaps with logging unit u91m and u12m. Re-mapping and sand pans and ledges in spring 2015 will likely resolve this as the original mapping in associated with outcrops in 1996, before GPS and GIS were as refined as they are today, puts chaparral, ponderosa pine, the boundary of the CASIA population into dense timber, where mixed conifer and red CASIA would not grow. fir/lodgepole forests, 4500 – 8500 feet.

Cinna bolanderi No occurrences known in project area, but suitable habitat RIPARIAN/AQUATIC BOLANDER’S REED GRASS present along perennial streams. Streamsides, wet meadows, moist sites in conifer forest. 6000-8000 feet. Collomia rawsoniana (CORA2) Populations along: RIPARIAN/AQUATIC RAWSON’S FLAMING TRUMPET Fish Creek (mostly moderate soil burn severity) Streamsides and meadow Slide Creek (low soil burn severity) edges, 2500 – 7000 feet. Rock Creek and tributaries (mostly low, some moderate soil burn severity) Unnamed tributary to Mammoth Pool (moderate and high burn severity) Fissidens aphelotaxifolius (FIAP) No occurrences known in project area, but suitable habitat RIPARIAN/AQUATIC Rocky BROOK POCKET –MOSS present along perennial streams below 6400’ substrate in streams, < 6400 feet.

Hulsea brevifolia (HUBR) No occurrences known in project area, but suitable habitat FORESTED. Granitic or SHORT-LEAFED HULSEA present. volcanic soils in openings and under canopy in mixed conifer and red fir forest, 5000 – 9000 feet. Leptosipon serrulatus (LESE18) No occurrences known in project area, but suitable habitat Openings in foothill MADERA LEPTOSIPHON present south of Fish Creek. woodland / annual grassland and montane coniferous forest. 1000- 5000 feet.

Lewisia disepala (LEDI3) DETAILED ANALYSIS UNIT 4: The four occurrences mapped ROCKY/GRAVELLY. Granitic YOSEMITE LEWISIA separately by the Sierra NF are all part of CNDDB EO 17: sand and gravel in LEDI3-15-05 overlaps with logging units u91m and u12m. ponderosa pine, mixed LEDI3-15-06 lies within of logging unit u9m and plantation P902 conifer, and upper

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LEDI3-15-07 montane coniferous forest, 4000 – 7500 feet. Lewisia kellogii ssp. kelloggii (LEKEK) No occurrences known in project area, but may occur where LEDI3 ROCKY/GRAVELLY. Open, KELLOGG’S LEWISIA occurs or in other areas of suitable habitat where rock outcrops gravelly flats in mixed are prominent. conifer and subalpine forest, 6000 – 11,000 feet. Peltigera gowardii 1 occurrence in Slide Creek – low soil burn severity RIPARIAN/(AQUATIC Cold, VEINED WATER LICHEN 1 occurrence in tributary to Rock Creek clear, unpolluted streams in conifer forests, 4000 – 8000 feet.

FIELD SURVEYS: Survey for rare plants and invasive weeds in the French Fire RRP area were conducted in portions of the area in 2013 and 2014 for the then-planned West Chiquito Ecological Restoration Project. During and after the French Fire, botanists serving as Resource Advisers and on the BAER team surveyed known Sensitive plant sites and mapped medusahead over about 19 acres. That 19 gross acres has been expanded to polygons adding up to 32 acres, where there is a high likelihood medusahead might be present and require prompt treatment (see Appendix B). Sensitive plant information is maintained in the Sierra NF GIS database and field survey forms are turned in to the California Natural Diversity Database of the Department of Fish and Game (CNDDB, 2015). The invasive weed data is mapped in GIS so that control efforts may begin prior to (with BAER funding) and continue during Project implementation. Additional Sensitive plant and invasive weed surveys will occur in 2015 for this project; and will continue each year as needed prior to initiation of different phases of the Project (e.g. site prep with herbicides and planting of conifers would be staggered over several years). Detailed results of surveys to date are available by contacting the Forest Botanist at the Bass Lake Ranger District in North Fork.

Species accounts for the Forest Service sensitive plants known and suspected to occur within the project area:

Camissonia sierra ssp. alticola – Mono Hot Springs evening primrose

This diminutive annual plant (Figure 1) is known from fewer than 25 occurrences; ranging from just dozens of plants per occurrence to hundreds of thousands of plants. The number of plants each year varies greatly depending on the rainfall pattern each year.

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Figure 1. Mono Hot Springs evening primrose plants near Florence Lake in Fresno County.

Photo: Joanna Clines.

Most occurrences are in Madera and Fresno Counties, from (3400) 5400 to 7900 feet elevation. A majority of occurrences are in the San Joaquin River drainage, and are generally clustered around Mammoth Pool, Edison Lake, and Florence Lake. In Mariposa County, there is a record for Merced Lake in Yosemite National Park (Collected by Jepson in 1909), but no documentation exists that this occurrence has been seen since then, though it may be extant. In 2010, Taylor and Colwell collected Mono Hot Springs evening primrose a few miles downstream from Jepson’s Merced Lake site, in Little Yosemite Valley, thus there are likely at least two occurrences in Mariposa County in the Merced River drainage.

In French Fire RRP: There is an occurrence of Mono Hot Springs evening primrose on a large granitic dome adjacent to logging units u9m, u12m, u24m, and u91 m.

Cinna bolanderi – Bolander’s woodreed

Bolander’s woodrred is a large, tufted perennial grass (to 2 meters tall), forming large clumps with inflorescences cascading to one side in a fountain-like manner; the leaves are large and can be over 1 cm wide. A key distinguishing feature differentiating C. bolanderi from the more common C. latifolia is that the former has 2 large anthers while the latter has only one anther (Baldwin et al, 2012). See Figure 2.

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Figure 2. (Left to Right) Cinna bolanderi habit, inflorescence, and habitat on Old Big Oak Flat Road behind Crane Flat Gas Station in Yosemite National Park. Photo by Alison E.L. Colwell

Bolander’s woodreed is endemic to the southern and central Sierra Nevada, ranging from Tulare County to Mariposa County, with no occurrences currently confirmed for Madera County. Most occurrences are known from Yosemite and Sequoia/Kings Canyon National Parks. In 2013, several new occurrences were discovered in the Sierra NF along streams north of Huntington Lake in Fresno County. The species is known from 15-20 sites, varying from fewer than 10 to over 250 plants at each site; between elevations of 6000 to 8000 feet.

Within the French Fire RRP: There are no known occurrences of Bolander’s woodreed with the Project area, though suitable habitat along streams is present. The nearest known occurrences are in red fir forest along streams north of Huntington Lake, about 8 miles east of the Project area.

Collomia rawsoniana - Rawson’s flaming trumpet

Rawson’s flaming trumpet is a perennial herb that propagates both by seed and via underground stems (rhizomes). The tubular flowers are bright orange red, pollinated by hummingbirds and several species of bee (Hevron, 1989) (Figure 3). The entire distributional range of this relict species is confined to a 15 by 10 mile area between 2500 and 7000 feet elevation (Map x). All occurrences are within Madera County, and most plants grow on National Forest System lands within the Bass Lake Ranger District. Some occurrences span private lands as well. Populations occur along streams and around meadows within about 12 major drainages (roughly equivalent to "occurrences" as defined by CNDDB), all but one of which flows into the San Joaquin River. The exception is the Nelder Creek occurrence, which flows into the Fresno River. Each of these 12 major drainages may have over 5 miles of patchily occupied flaming trumpet habitat. Estimates of population size are usually given as number of stems, which is a poor indication of number of individuals, since what constitutes a ramet vs. a genet is just beginning to be understood for this rhizomatous perennial herb (Wilson, Clines, and Hipkins, 1999).

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Figure 3. Rawson’s flaming trumpet in flower left; right, thriving in partial shade. Photo: Chris Winchell.

Flaming trumpet populations are found in moist sites in ponderosa pine forest and mixed conifer forest; along streams and occasionally at meadow edges. Research and field observations have shown that there is a balance of light and shade at which flaming trumpet flowers optimally (Liskey, 1993; J. Clines, field observations 1988-2015). Some disturbance can be beneficial, especially if it simulates the loosening of soil and opening of canopy that would be present after natural windfall of forest trees. The populations of flaming trumpet on the Bass Lake Ranger District have been studied and monitored for many years (Taylor et al. 1987; Hevron, 1989; Liskey, 1993; Wilson, Clines, and Hipkins, 1999).

As per the Sierra NF Land and Resource Management Plan (USDA Forest Service, 1992), populations fall within 3 management areas on the Forest: most are in General Forest, where timber management has historically been given priority; some are in Front Country, where wildlife and range management values predominate; and some are in the area around Bass Lake where developed recreation in emphasized. In addition to protection provided by Best Management Practices for streamside management zones, an Interagency Agreement was in place from 1985 to the early 1990s between USFS and USFWS, specifying additional protective guidelines along 13 stream reaches within the range of flaming trumpet. In these zones designated "Essential Habitat," management activities including timber harvest were “restricted” within a zone of 150 feet on either side of the stream centerline. This implied that the 100 foot + SMZ

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was expanded by 50 feet, but what was meant by “restricted” was not specifically defined. The 1992 LRMP incorporated the intent of the Interagency Agreement into S&G # 33, which reads:

“Generally, riparian management areas will extend 100 feet horizontally from the edge of perennial streams, lakes and reservoirs, except along those streams designated as essential habitat in the Interagency Agreement for Collomia rawsoniana, where the zone will be 150 feet.”

Since 1992, much has been learned about flaming trumpet ecology, population biology, and response to disturbance; populations appear to thrive where the canopy cover is less than closed (flowering increases with light availability to a point), colonies respond favorably to some ground disturbance but not to compaction of soil (Liskey, 1993). In addition, through a simple genetics study designed to determine what constitutes an individual vs. a clone, it is now understood that although this is a rhizomatous species that spreads vegetatively; sufficient reproduction occurs from seed that each “patch” is typically made up of many genetic individuals (not all one clone) (Wilson et al., 1999).

Within the French Fire RRP: Rawson’s flaming trumpet occurs extensively, but intermittently, along Fish Creek, Slide Creek, Rock Creek (and tributaries), and an unnamed perennial stream flowing into Mammoth Pool. Approximately 10 percent of all mapped occurrences of flaming trumpet fall within the project perimeter.

Slide Creek and Rock Creek were visited during the BAER botanical field surveys to assess effects to flaming trumpet (Figure 4). No plants were found at Slide Creek, but since some riparian vegetation remained unburned only minor impacts are expected if any at all. Several clusters were observed along Rock Creek upstream of Road 4S81. Most plants were vegetative and were not expected to flower in 2014, possibly due to the ongoing drought and/or lack of light (Liskey 1993). Several plants had already flowered. The fire burned through the area at low to moderate intensity. Some riparian vegetation remained unburned while in other locations the fire burned right up to the stream channel. Some portions of the occurrences were likely burned over and survival will depend on fire severity and rooting depth.

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Figure 4. Rawson’s flaming trumpet location along Rock Creek, above 4S81 - August 2014 BAER survey

Fissidens aphelotaxifolius – brook pocket moss

The brook pocket moss is an exceptionally rare moss, known from only two locations in California, one on the Sierra National Forest in Madera County and one on the Klamath NF in Siskiyou County (Norris and Shevock, 2004). The Sierra National Forest location along Owl Creek was re-confirmed during a field visit by the Forest Botanist and bryophyte experts Jim Shevock and Eve Laeger of the California Academy of Sciences on October 15, 2012 (Figure 5). Prior to that, the site had not been monitored for 12 years, since its discovery in 2000. In 2012, plants were found to be in good condition, occupying between 0.75 and 1.0 square meter on the lower side of a rocky overhang that would normally form a waterfall, but in October 2012, there was very little water in the creek, making it easier to locate the moss and determine its extent.

Brook pocket moss occurs in lower to upper montane coniferous forests. The species grows on wet soil, humus and rocks along narrow streams and in the vicinity of small waterfalls, and in damp or wet crevices of cliffs (Pursell 1976). It is not expected in areas where peak flows wash mosses away. The species grows from sea level to 6300 feet throughout its range, however in the Sierra NF the lower elevation range would be the lower limit of the ponderosa pine zone (around 3000’).

Suitable habitat for brook pocket moss is found throughout the French Fire area. Most streams have not been surveyed for this species, but for the purposes of this analysis, it is assumed that perennial streams below 6400’ elevation are occupied.

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Figure 5. Left: brook pocket moss in waterfall, Right: close-up of plant showing unique flattened appearance of branches. Photo: J. Clines

Within the French Fire RRP: No populations are known to occur; the only Sierra NF brook pocket moss site is in Owl Creek, about 1.8 miles west of the French Fire RRP boundary.

Hulsea brevifolia – short-leaved hulsea

The short-leaved hulsea is a locally endemic perennial herb found in montane forests of the central and southern Sierra Nevada (Figure 6) (Baldwin et al., 2012). Plants are 3 to 6 dm. tall, with alternate, toothed leaves. Stems and leaves are covered with hairs, some of which are glandular, making plants sticky to the touch. Flower heads are bright yellow-orange, less than 20 mm in diameter (Baldwin et al., 2012). Populations are found between 5,000 to 9,000 feet, but most occurrences are found above 6500 feet in the red fir forest type.

There are about 50 occurrences of short-leafed hulsea documented on the Sierra NF, and others on adjacent Forests and in Yosemite National Park totaling about 65 occurrences. The species ranges from Tuolumne County to Tulare County, and encompassing Inyo County.

Habitat for short-leaved hulsea is gravelly or sandy exposed areas as well as canopied sites in coniferous forest, usually red fir forest. Occurrences range in size from a few dozen plants to many thousands of plants. Most occurrences appear to represent a variety of age classes, from the current year’s seedlings to older, well established plants (Clines, field observations). Populations have been observed to flourish after disturbance such as wildfire or hand-clearing (Clines, field observations).

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Figure 6. Short-leafed hulsea: on left – close up of flower and leaves. Right, population growing along a road near Fish Camp in Madera County. Photos: J. Clines

Leptosiphon serrulatus – Madera leptosiphon

Madera leptosiphon is an annual herb that superficially resembles the common mustang clover (Leptosiphon montanus). Madera leptosiphon is generally a shorter plant at 5-18 cm to mustang clvoer’s 10-60 cm. Flowers have a short corolla tube (7-8 mm) and completely white corolla lobes 5-7 mm long. Mustang clover flowers vary from white to light or bright pink, but even when white there is a purple spot at the base of the lobe. See Figure7.

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Figure 7. Madera leptosiphon, compared with the much more common mustang clover.

Madera leptosiphon is documented from about 30 occurrences, few of which have been seen in the last several decades or even 100 years (CNDDB, 2015). Historic locations are documented from southern Mariposa County southward to Kern County, with occurrences in Madera, Fresno, and Tulare Counties. Elevations range from 260 to 5000 feet. Habitat is dry slopes in cismontane woodland and lower montane coniferous forest, mostly in decomposed granite soils, but at one location has serpentine soils. Sites vary from grassy well-vegetated areas in blue oak woodland or mixed chaparral to more open, rocky sites.

This species may be in a declining trend based on unsuccessful attempts to re-locate several historic occurrences (Clines, personal observation). Most occurrences are outside of the Sierra NF on private or State-owned lands.

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Within the French Fire RRP: The nearest occurrences to the French Fire RRP are along a Sierra NF road in Fresno County, across the San Joaquin River about 1.3 miles southeast of the Project boundary. There is suitable habitat in the southern portion of the Project area south of Fish Creek (below 5000’).

Lewisia disepala – Yosemite bitteroot

This early blooming perennial herb (Figure 8) occurs on granitic domes in the Sierra National Forest near Bass Lake, in the San Joaquin River canyon in the French Fire and at Balloon Dome and Piyau Dome; and in the Blue Canyon area of Fresno County. It is locally abundant on the domes surrounding Yosemite Valley: Mt. Watkins, Basket Dome, and on the unnamed domes east and west of Mt. Starr King (Botti, 2001), and on granitic domes as far south as Kern County (CNDDB, 2015). In the 1990s, Sierra NF botanists discovered several additional populations, some consisting of thousands of plants. In 2004, USGS botanists documented approximately 11,000 plants from three populations in Yosemite NP. Occurrences found outside of Yosemite consist of as few as one hundred to over three thousand plants. As of 2015, there were a total of twenty-two occurrences outside of Yosemite. Thirteen occurrences have been located on the Sierra National Forest: eight in Madera County and five in Fresno County. The Sequoia NF has seven occurrences: 3 in the Scodie Mountains of Kern County, 2 in the Dome Land Wilderness and 2 west of the Kern Canyon in Tulare County. There are two Tulare County occurrences on BLM land east of the Sequoia NF boundary and west of Lamont Peak. The Sierra National Forest occurrences are at the lowest elevations for the species and face the most threats (off-highway vehicles, dispersed camping, target shooting, campfires, access for timber harvest, etc.).

Within the French Fire RRP: Four occurrences of Yosemite lewisia occur in the northern part of the project area, east of Road 4S81, north of Shake Flat Creek, and on both sides of Road 6S12X.

Figure 8. Yosemite lewisia. Photo J. Clines.

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Lewisia kelloggii ssp. kelloggi – Kellogg’s lewisia

Kellogg’s lewisia is known from approximately 25 locations from Humboldt County southward to Madera County. In Madera County there are 6 occurrences in the vicinity of Shuteye Peak; the two most recently discovered in 2010 are just to the south of Shuteye Peak; these 2 occurrences were observed to be in good condition. Across the range of the species, some populations are composed of several hundreds of plants, some are smaller. A study published in 2005 clarified that the California members of this species sensu lattu are a separate species from those found in Idaho, and that there is reason to believe that the plants in Madera County and around Yosemite Valley genetically different from other California LEKEK, and upon further study may turn out to be a separate subspecies or possibly even a separate species (Wilson et al, 2005).

These semi-succulent perennial herbs grow on rock outcrops and adjacent gravel or sand (Figure 9). Plants emerge and bloom by June or July and once they have set seed, they wither and become invisible although they are still alive but dormant. Habitat is sunny, open sand or gravel and cracks on granitic outcrops within upper mixed conifer forest and subalpine forest. Occurrences vary from well-protected in Yosemite National Park to vulnerable in Eldorado, Tahoe and Sierra NFs where OHV and other recreation impacts are ongoing. In the Sierra NF, plants that grow along OHV routes and roads are currently experiencing impacts from illegal off-road driving, especially dirt bikes which cause ruts and erosion in the gravelly soil.

Figure 9. Kellogg’s lewisia: left: close-up of one plant, right: habitat southwest of Shuteye Peak. Photos: Rodney Olsen.

Within the French Fire RRP: The nearest Kellogg’s lewisia occurrence to the French Fire RRP is on Shuteye Peak, 1.8 miles to the west of the project area.

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Peltigera gowardii – Western waterfan lichen

Western waterfan lichen is endemic to North America, and occurs from Alaska through the Rocky Mountains to the Appalachians (Peterson 2010). Over the past 20 years, this species has been considered rare and at risk in California. However, recently a number of additional occurrences have been documented in the Sierra NF, bringing the total number to approximately 35. Some of these are robust and composed of many thousands of plants in excellent habitat. This aquatic lichen is a foliose species with a black or brown “leafy” thallus (plant body) (Figure 10). Thalli are found growing on rocks and on stream bottoms, usually submerged but in late summer they may be exposed to air for a time. Clumps range in size from a few centimeters to over a decimeter. Reproductive structures have been observed, and asexual reproduction is possible, but how the lichen actually colonizes new habitats is unknown (Peterson, 2010).

Threats are activities that change the water chemistry, alter the stream channel, signicantly increase water temperature; or drastically increase flows that scour the gravels and rocks on which the lichen is attached. Davis (1999) demonstrated that as temperatures rise above 41°F, photosynthesis declined with increased temperature: at 41°F, photosynthesis continued normally and thalli maintained their weight; at 59°F a decline in photosynthesis was measured after 120 days, at 70°F photosynthesis ceased within 15 days, and at 86°F it ceased within 3 days. Data on response to nutrient concentrations such as nitrates and degree of aeration of the water suggest that western waterfan lichen is negatively affected by eutrophication and thrives with aeration (Davis, 1999).

Within French Fire RRP: The French Fire RRP area contains two known occurrences of western waterfan lichen; both in the Rock Creek drainage. One is in Slide Creek where the southern half of the mapped population is within the inner 150’ zone where roadside hazard logging is planned. The other occurrence is in an unnamed tributary to Rock Creek above Road 7S44, also within the inner 150’ zone for roadside hazard. Additional stretches of perennially flowing water within the project area may contain additional veined water lichen populations. Figure 11 shows the Slide Creek location just after the French Fire in August 2014.

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Figure 10. Western waterfan lichen.

Figure 11. Western waterfan lichen occurrence at Slide Creek during BAER survey

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VI. EFFECTS OF THE PROPOSED ACTION

There are 9 species of Forest Service sensitive plants that may occur in the project area because habitat is present, but only 4 that are known to occur. This analysis will be based on effects by 3 major habitat types for all 9 of these species. Habitat categories are as follows (also see Table X):

 Riparian/Aquatic habitats: Bolander’s woodreed, Rawson’s flaming trumpet, brook pocket moss, and western waterfan lichen.

 Rocky/Gravelly habitats: Mono Hot Springs evening primrose, Yosemite lewisia, Kellogg’s lewisia,

 Forested habitats: Short-leaved hulsea, Madera leptosiphon

Indicators The effects of the alternatives were evaluated using the following two indicators. The indicators were selected as being measurable and relevant for quantifying the effects of proposed activities to sensitive plant occurrences. Increased acres or square feet of invasive weeds can create negative effects on FS sensitive plant species. Treatments can reduce the acres of square feet TES and FSS species.

Indicator 1: Number of FS sensitive plant occurrences and their aerial extent (in square feet, miles of stream, or acres). Ideally, the number of occurrences and their extent would remain the same or increase.

Indicator 2: Number of invasive weed infestations and their aerial extent (in square feet or acres). Ideally, the number of infestations and their extent would decrease as a result of weed treatments proposed in the action alternatives. In addition, evidence of successful Early Detection/Rapid Response would be measured by the number of invasive weed infestations discovered early and controlled rapidly in time for eradication to occur within the life of the Project.

GENERAL DISCUSSION OF EFFECTS TO SENSITIVE PLANTS General direct effects The following direct effects to sensitive Plants are possible during implementation of any of the action alternatives: Direct killing of plants when equipment runs over them or parks on them, when logs are skidded or dragged over them, when slash piles crush plants and block their light, when piles are burned directly over them and the heat intensity is too great for plants or their seeds to survive; when herbicides are directly applied to them.

General indirect effects A possible indirect effect to Forest Service sensitive plants is the degradation or loss of habitat resulting from the introduction or spread of invasive and noxious weeds. These are non-native weeds that are particularly aggressive, and can spread rapidly and compete with native plants for water and other resources, in some cases forming solid stands that may replace or reduce the abundance of sensitive plants. Invasive weeds can be transported to new areas when vehicles and heavy equipment pass through or excavate soil in contaminated areas without being washed before moving to a new area. Noxious weed species known to occur within the

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French Fire ERRP area are medusahead (Elymus caput-caput-medusae) and bull thistle (Cirsium vulgare). At this time, the Project area is not known to have weed infestations aside from medusahead and a few patches of bull thistle (Cirsium vulgare). The most likely additional invasive weed species to occur in the Project area are: woolly mullein (Verbascum thapsus), Italian thistle (Carduus pycnocephalus), klamathweed (Hypericum perforatum) tocolote (Centaurea melitensis), stinkwort (Dittrichia graveolens), and smilograss (Stipa miliacea ssp. miliacea). This is based on the presence of these weeds on nearby lands and at the USFS compound in North Fork where fire suppression and road maintenance equipment have been staged prior to traveling to the French Fire area. Heavy equipment may have brought seeds to the area during the first few days of initial attack prior to arrival of the equipment washing station at fire camp. Invasive weed prevention measures have been incorporated into the Alternatives 2-5, thus these indirect effects should be minimal. Please see the Invasive Weed Risk Assessment for further information (Clines, 2015).

Spatial and Temporal Context for Effects Analysis. The spatial and temporal scale for Cumulative Effects is shown in Table 7.

Table 7. Spatial and Temporal scales for botany and invasive weeds cumulative effects analysis. Resource Area Geographic Scale Temporal Scale Reason

Botanical Project scale for Recent projects within the The project boundary encompasses the entire 13, 832 acre Resources: native plant last 5 to 8 years are now French Fire area, and no alternative proposes to treat more Forest Service recovery, species- considered part of the than 8,000 acres. For native plant recovery there is a sensitive plants dependent scale current condition; present sufficient buffer around treated areas within the Project and native plant for FS sensitive and reasonably foreseeable boundary to serve as a source of native seed that will diversity and plants (usually the projects including this contribute to revegetation of treated areas. The sensitive recovery project scale but Project over the next 10 plant occurrences will be discussed at various scales sometimes the years depending on the species’ range. range of the species or the range within the Sierra Nevada if wider-ranging).

Invasive Weeds Project scale plus Recent projects within the The reason for considering an 8 mile buffer around the an 8 mile buffer last 5 to 8 years are now project boundary is that during fire suppression, equipment considered part of the and vehicles staged from the ICP at North Fork and from the current condition; present “boneyard” at the Bass Lake RD office, where 5 species of and reasonably foreseeable invasive weeds occur. Staging of equipment, obtaining fill projects including this and supplies for BAER road work is ongoing from this Project over the next 10 boneyard, which is just under 8 miles from the project years boundary. The 8 miles includes spike camps, medusahead outside the project, and other weed locations that may have been sources for the French Fire area.

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Incomplete and Unavailable Information Because the French Fire occurred in August 2014, after the blooming period for the vascular plants analyzed in this document, post-fire surveys for sensitive plants or invasive weeds are limited to BAER team field surveys in August 2014 and a few days of survey in March and April 2015. There is suitable habitat for several FS sensitive plants within the Project area that has not been surveyed for. However, the species that occur or might occur in the French Fire ERRP will be surveyed for during the 2015 field season, and protected as necessary upon detection of a new occurrence. Most importantly, Project Design Criteria were written to minimize the potential for damage to any possible undiscovered populations that might exist as well as to existing known populations.

Alternative 1 – No Action

Direct and Indirect Effects SENSITIVE PLANTS OF FORESTED HABITATS: Short-leaved hulsea is not known to occur within the French Fire RRP, but there may be unknown populations, especially above 5000’. Madera leptosiphon occurs within lower montane coniferous forest and there may be undiscovered populations south of Fish Creek. However, for Madera leptosiphon, indirect effects may occur due to the spread of medusahead into suitable habitat because the herbicide treatments for medusahead would not occur over the number of years needed for eradication; and manual and mechanical methods conducted only for one year with BAER funds are not adequate to eradicate this invasive, aggressive grass.

SENSITIVE PLANTS OF RIPARIAN AND AQUATIC HABITATS: While portions of Rawson’s flaming trumpet occurrences burned and there may be some mortality in the hotter areas, recovery will occur from surviving individuals through resprouting and seedlings. In a study of the effects of disturbance after logging, livestock use, and fire (Liskey, 1993); flaming trumpet produced a higher percentage of flowering stems when canopy closure was reduced from 84 and 99% to 70 and 77% respectively. In the same study a clear-cut plot showed a slight increase in percentage of flowering stems when canopy cover went from 82 to 0%. Seedlings were more abundant after logging and fire and were strongly associated with mineral soil, therefore this species could benefit from the reduction in canopy cover as a result of the fire. Some ground disturbance (loosening of soil or clearing of duff as would have happened after wind-blow of timber or fire) may be beneficial but severe disturbance whereby a large tree is felled onto living flaming trumpet plants or is dragged through the soil creating a gouge would be detrimental. The No Action alternative would not involve further direct ground disturbance within flaming trumpet populations beyond what occurred during the fire, thus no direct effects or indirect effects are expected.

The population of western waterfan lichen at Slide Creek was observed to have some debris from the burned slope above during the French Fire BAER reconnaissance, however the stream should clear out and run clear over time. No direct or indirect effects would occur for the western waterfan lichen population at Slide Creek as a result of the No Action alternative as no timber harvest or road reconstruction would occur.

There are no known populations of brook pocket moss or Bolander’s woodreed, but there would be no direct or indirect effects to their habitat under Alternative 1.

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SENSITIVE PLANTS OF ROCKY AND GRAVELLY HABITATS: Populations of Mono Hot Springs evening primrose and Yosemite lewisia occur within the project area and also have a more extensive range in the Sierra Nevada. Kellogg’s lewisia may occur in the same areas, the habitat is suitable. Because no salvage or road reconstruction would occur, no direct or indirect effects would be experienced by plants of rocky/gravelly habitats under the No Action alternative.

Compliance with Forest Plan and Other Relevant Laws, Regulations, Policies and Plans Alternative 1 is in compliance with the Forest Plan, FSM 2670, FSM 2900, and other Regulations, Policies, and Plans relevant for Forest Service Sensitive Plants and Invasive Weeds, although goals stated in these plans and policies would not be reached as quickly.

Alternative 2 – Proposed Action

The French Fire RRP action alternatives have been carefully designed to avoid or minimize direct and indirect effects to FS sensitive plant species and habitats. In addition to protective measures for streamsides, soils, hydrology, and aquatic wildlife; all of which contribute to the protection of sensitive plant habitat, project design criteria for Forest Service sensitive plants have been incorporated into the Proposed Action. Generally they consist of surveying for sensitive plants in areas likely to have undiscovered populations, using flagging around sensitive plant occurrences to indicate areas where activities should not occur during project implementation; and ensuring that habitat for species that might occur but are not yet known to occur are protected from harm (see list of design measures on page 12).

Direct and Indirect Effects SPECIES OF FORESTED HABITATS: Short-leaved hulsea plants, should there be undiscovered populations, could be directly killed by heavy equipment used for timber harvest driving on them, especially while they are leafed out, flowering, or in the process of seed formation. Prescribed burning, especially if conducted outside of the season these plants evolved to tolerate or benefit from fire, could directly kill or impair individual plants. Herbicides would directly kill plants, but this species is not found in areas of dense bearclover, and does not occur at the lower elevations where the medusahead treatments are planned. Any short-leaved hulsea plants discovered during field surveys in 2015 would be flagged for avoidance; thus the likelihood of these direct effects occurring is low. Negative indirect effects are possible but unlikely, given consistent observations that this plant thrives after disturbance such as fire and fuels reduction treatments, and tends to grow vigorously in road corridors.

SPECIES OF RIPARIAN/AQUATIC HABITATS: Fish Creek, Rock Creek, Slide Creek, and an unnamed tributary to Mammoth Pool have populations of Rawson’s flaming trumpet. Direct effects from ground disturbing activities that could harm flaming trumpet populations would not occur if all Design Criteria are followed: streams have a “no entry” zone of 100’ for heavy equipment. Possible indirect effects could be increased sedimentation and runoff into streams where flaming trumpet grows after salvage logging on burned slopes, however as the

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Project has been designed to minimize Cumulative Watershed Effects (see Hydrology Design Criteria in the EA), this is not predicted to be likely.

SPECIES OF ROCKY/GRAVELLY HABITATS: The Project has been designed to avoid direct and indirect effects to rare plants of outcrops. If all Design Criteria are followed, there would be no direct or indirect effects.

DIRECT / INDIRECT EFFECTS OF INVASIVE NON-NATIVE PLANTS FOR ALL HABITAT TYPES: Ecosystem health is threatened by the spread of invasive non-native weeds in a variety of ways. Dense infestations can reduce native biodiversity, compete with FS sensitive plant species, reduce wildlife habitat quality and quantity, modify vegetative structure and species composition, change fire and nutrient cycles, hybridize with native species, and degrade soil structure (Bossard et al., 2000). Because the Project is designed to improve the ecosystems within the project area by eradicating known infestations of invasive weeds and preventing the introduction and spread of new infestations or species of weeds, there would be beneficial direct and indirect effects to ecosystems as a result of Alternative 2.

CUMULATIVE EFFECTS Past, present, and reasonably foreseeable actions within and near the project area are detailed in the EA. For Mono Hot Springs evening primrose, Yosemite lewisia and other plants of rocky/gravelly habitats, ongoing motorized recreation is currently having some impacts (individual plants are sometimes killed when driven over repeatedly based on botanical monitoring over the past 10 years), but the French Fire ERRP would not add to these impacts as the Project has built in Design Criteria to protect rare plants within these types of habitats and has been designed to minimize damage to rocky/gravelly soils. For plants of riparian/aquatic habitats, especially Rawson’s flaming trumpet, which occurs extensively in the project area, the populations within the project area are stable and expected to recover or even benefit from the Fire itself, but there are occasional instances of motorized recreation damage or cattle grazing or trampling. The French Fire RRP would not add to these slight impacts because there of the 100’ no entry SMZs on either side of the streams inhabited by flaming trumpet. For other sensitive plants of riparian and aquatic habitats that may occur within the project area; past, current, or future effects experienced at some level could be from the following activities: motorized recreation use, cattle grazing and trampling, roadside hazard tree removal, and fire/fuels management activities. No negative cumulative effects are expected for plants of aquatic and riparian areas because aquatic and hydrology project Design Criteria along with sensitive plant Design Criteria forestall damage to these habitats. For noxious weeds, just about any activity listed in Appendix E of the EA could have spread weeds in the past and has the potential to spread weeds currently and in the future. Surveys during BAER and for other projects within the French Fire RRP indicate that the area is relatively free of invasive weeds, especially considering the amount of historical and current activity occurring therein. The Project will reduce the number of infestations of invasive weeds and has been designed to minimize the likelihood of weed introduction due to project activities, thus no negative cumulative effects for noxious weeds are expected for sensitive plant species. In summary, no negative cumulative effects are expected for Forest Service sensitive plants as the project has been designed to reduce or eliminate direct and indirect effects to these rare plant species and to avoid the introduction and spread of noxious weeds.

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Compliance with Forest Plan and Other Relevant Laws, Regulations, Policies and Plans Alternative 2 is in compliance with the Forest Plan, FSM 2670, FSM 2900, and other regulations, policies, and plans relevant for Forest Service sensitive plants and invasive weeds because selective botanical field surveys were conducted and more are planned prior to project implementation, a thorough set of Design Criteria are in place to ensure the long-term sustainability of sensitive plants, and a sound IPM plan is in place to eradicate invasive weeds.

Other Relevant Mandatory Disclosures No federally listed plant species occur within the project area. No consultation with US Fish and Wildlife Service is necessary.

Summary of Effects INDICATORS: It is expected that after implementation of Alternative 2, the number of populations of sensitive plant species would remain the same and the aerial extent of each occurrence would remain constant or increase. The number of invasive weed infestations would decrease directly as a result of project activities, ultimately to the point where medusahead is no longer present. The condition of the native vegetation would improve and provide an improved landscape for the long-term persistence of FS sensitive plants.

Alternative 3

Design Features and Mitigation Measures This alternative has been designed to minimize or avoid negative effects to FSS plants and their habitat. (See EA, Design Criteria Common to All Action Alternatives).

Direct Effects The effects are the same as for Alternative 2.

Indirect Effects The effects are the same as for Alternative 2.

Cumulative Effects The effects are the same as for Alternative 2.

Compliance with Forest Plan and Other Relevant Laws, Regulations, Policies and Plans Alternative 3 is in compliance with the Forest Plan, FSM 2670, FSM 2080, and other regulations, policies, and plans relevant for Forest Service Sensitive plants and noxious weeds because selective botanical field surveys were conducted, the project is designed to improve habitat for the Forest Service sensitive Rawson’s flaming

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trumpet and several Sensitive species associated with meadows; and the project has been designed to protect other species of Sensitive plants and to prevent and control noxious weeds.

Other Relevant Mandatory Disclosures No federally listed plant species occur within the project area. No consultation with US Fish and Wildlife Service is necessary.

Summary of Effects It is expected that after implementation of Alternative 3, the number of populations of Sensitive Plant species would remain the same and the number of plants per occurrence would remain constant or increase. The number of noxious weed infestations would decrease directly as a result of project activities. The condition of the native vegetation and of the amounts of montane chaparral and the mosaic of age classes of native plant communities within the project area would be largely comprised of native species; however the amount of forested land will be greatly reduced regardless of whether or not this project is implemented. Under Alternative 3, it would take many more decades to reach forested conditions because without herbicides conifer planting success would be much lower in bear clover dominated sites.

Alternative 4

Design Features and Mitigation Measures This alternative has been designed to minimize or avoid negative effects to FSS plants and their habitat. (See EA, Design Criteria Common to All Action Alternatives).

Direct Effects The effects are the same as for Alternative 2.

Indirect Effects The effects are the same as for Alternative 2.

Cumulative Effects The effects are the same as for Alternative 2.

Compliance with Forest Plan and Other Relevant Laws, Regulations, Policies and Plans Alternative 4 is in compliance with the Forest Plan, FSM 2670, FSM 2080, and other regulations, policies, and plans relevant for Forest Service Sensitive plants and noxious weeds because selective botanical field surveys were conducted, the project is designed to improve habitat for the Forest Service sensitive Rawson’s flaming

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trumpet and several Sensitive species associated with meadows; and the project has been designed to protect other species of Sensitive plants and to prevent and control noxious weeds.

Other Relevant Mandatory Disclosures No federally listed TES plant species occur within the project area. No consultation with US Fish and Wildlife Service is necessary.

Summary of Effects It is expected that after implementation of Alternative 4, the number of populations of Sensitive Plant species would remain the same and the number of plants per occurrence would remain constant or increase. The number of invasive weed infestations would decrease directly as a result of project activities. The condition of the native vegetation and of the amounts of montane chaparral and the mosaic of age classes of native plant communities within the project area would be largely intact, coniferous forest would be slower to reoccupy the landscape over more acres than Alternatives 2 or 5.

Alternative 5

Design Features and Mitigation Measures This alternative has been designed to minimize or avoid negative effects to FSS plants and their habitat. (See EA, Design Criteria Common to All Action Alternatives).

Direct Effects The effects are the same as for Alternative 2.

Indirect Effects The effects are the same as for Alternative 2.

Cumulative Effects The effects are the same as for Alternative 2.

Compliance with Forest Plan and Other Relevant Laws, Regulations, Policies and Plans

Other Relevant Mandatory Disclosures No federally listed plant species occur within the project area. No consultation with US Fish and Wildlife Service is necessary.

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Summary of Effects It is expected that after implementation of Alternative 5, the number of populations of Sensitive Plant species would remain the same and the number of plants per occurrence would remain constant or increase. The number of noxious weed infestations would decrease directly as a result of project activities. The condition of the native vegetation and of the amounts of montane chaparral and the mosaic of age classes of native plant communities within the project area would be largely intact; coniferous forest would be reoccupy the landscape more slowly than under Alternative 2 and more rapidly than Alternatives 1, 3, and 4.

VII. DETERMINATION

Threatened, Endangered, Candidate, and Proposed Plants (BA)

For all alternatives including the No Action: It is my determination that the French Fire RRP on the Bass Lake Ranger District will not affect Calyptridium pulchellum because suitable habitat in foothill woodland vegetation types does not occur in the project area. No consultation with US Fish and Wildlife Service is necessary.

Forest Service Sensitive Plants (BE)

Alternative 1 – No Action: It is my determination that implementation of Alternative 1 of the French Fire RRP on the Bass Lake Ranger District will not affect Forest Service Sensitive Plants; because the project would not occur. There is some chance that without herbicides for invasive weed control, sensitive plant occurrences might begin to be affected over the next 10 years, but most of the worst weed areas are not near sensitive plants.

Alternatives 2, 3, 4, and 5 – All Action Alternatives:

SPECIES OF RIPARIAN AND AQUATIC HABITATS: It is my determination that implementation of Alternatives 2, 3, 4, or 5 of the French Fire RRP on the Bass Lake Ranger District may affect individuals but is not likely to cause a trend to federal listing or a loss of viability to Collomia rawsoniana and Peltigera gowardii. The determination of “may affect” is because although the aquatic, botany, and hydrology project design criteria would prevent most damage that could occur to the populations along the perennial streams within the project area, there is a possibility that a few individual plants may be subject to at least indirect effects during project implementation. The risk is negligible to the long-term viability of any given population or to either species; and for both of these species; the populations across the district are in good health generally speaking.

For other riparian or aquatic species that are not known to occur in the project area, but may simply not have yet been discovered (Cinna bolanderi, Fissidens aphelotaxifolius) it is also my determination that the implementation of the project may affect individuals but will not lead to a trend toward federal listing or a loss of viability. For these species, the project design measures for aquatics, botany, and hydrology would effectively protect riparian and aquatic habitat.

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SPECIES OF ROCKY/GRAVELLY HABITATS: It is my determination that implementation of Alternatives 2, 3, 4, or 5 of the French Fire RRP on the Bass Lake Ranger District may affect individuals but is not likely to cause a trend to federal listing or a loss of viability to Lewisia kelloggii ssp. kelloggii , Camissonia sierrae ssp. alticola, or Lewisia disepala

SPECIES OF FORESTED HABITATS: It is my determination that implementation of Alternatives 2, 3, 4, or 5 of the French Fire RRP on the Bass Lake Ranger District may affect individuals of short-leaved hulsea and Madera leptosiphon, but is not likely to cause a trend to federal listing or a loss of viability. The reason for the “may effect” determination is that if as-yet undiscovered occurrences are present in the project area, they could exist in areas of salvage harvest, fuels clean-up, reforestation activities, and DFPZs, where identification of the plants prior to activities is unlikely. For invasive weed treatments, the Forest Botanist would be involved in implementation, raising the odds that any previously unknown short-leafed hulsea populations would be noticed and protected.

Other Forest Service sensitive do not have habitat within the project area, and therefore will not be affected by the project.

VIII. MANAGEMENT RECOMMENDATIONS

1. Consultation with the Forest Botanist must be made if any aspects of the proposed project changes. Also, if during project implementation additional sensitive plant species are discovered, the botanist must be contacted so that any protection measures necessary can be implemented.

VIII. REFERENCES CITED

Angwin, P., D.R. Cluck, P.J. Zambino, B.W. Oblinger, and W.C. Woodruff 2012. Hazard Tree guidelines for Forest Service Facilities and Roads in the Pacific Southwest Region. USDA Forest Service, Forest Health Protection, April 2012, Report RO-12-01.

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.

Battles, J.J., A.J. Shlisky, R.H. Barrett, R.C. Heald, and B.H. Allen-Diaz. 2001. The effects of forest management on plant species diversity in a Sierran conifer forest. Forest Ecology and Management 146 (2001) 211- 222

Botti, S.J. 2001. An Illustrated Flora of Yosemite National Park. Yosemite Association. 484 pp.

California Natural Diversity Database (CNDDB). 2015. www.dfg.ca.gov/biogeodata/cnddb/mapsanddata.asp. California Department of Fish and Wildlife. BIOS Version 5.

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CNPS, 2015. California Native Plant Society. On-line version of the CNPS Inventory of Rare and Endangered Plants of California. www.cnps.org/inventory

Colwell, A.E.L., 2005. Species summary for Cinna bolanderi (Yosemite National Park).

Davis. W.C. 1999. Ecophysiology of Hydrothyria venosa, an Aquatic Lichen. Unpubl. PhD Thesis, Arizona State University.

Engelhardt, B., J. Tuitele-Lewis, and J.M. Clines. 2014. French Fire – Botanical Resources BAER (Burned Area Emergency Response) Report. USDA Forest Service unpublished report, available project record and in files of Forest Botanist, Sierra National Forest, North Fork, CA.

Guilliams, M. and J. Clines. 2012. Draft Conservation Assessment for Calyptridium pulchellum (Eastw.) Hoover (Mariposa pussypaws). Prepared by: C. Matt Guilliams, University and Jepson Herbaria, University of California, Berkeley; and Joanna Clines, Forest Botanist, Sierra National Forest. Prepared for: USDA Forest Service. Pacific Southwest Region. May 2012

Hevron, W. E. 1989. The reproductive ecology of Collomia rawsoniana. Unpublished M.A. thesis, School of Natural Sciences, California State University Fresno, Fresno, California.

Knight, Marla; M.J. Friend., M.R. Brown, and J.M. Clines. 2012. Region 5 Sensitive Plant Species Evaluation and Documentation Form for Fissidens aphelotaxifolius. USDA Forest Service, unpublished form used for Sensitive Plant list revision.

Liskey, E.N. 1993. Effects of disturbance on Collomia rawsoniana. Unpubl. MA Thesis. California State University, Fresno, California.

McGinnis T.W., J.E. Keeley JE, S.L. Stephens, and G.B. Roller GB. 2010. Fuel buildup and potential fire behavior after stand-replacing fires, logging fire-killed trees and herbicide removal in Sierra Nevada forests. Forest Ecology and Management 260, 22–35. doi:10.1016/J.FORECO.2010.03.026

Miadlikowska, J. and Lutzoni, F. 2000. Phylogenetic revision of the genus Peltigera (lichen-forming ascomycota) based on morphological, chemical, and large subunit nuclear ribosomal DNA data. International Journal of Plant Science 161(6): 925-958.

Miles, S.R, and C.B. Goudey. 1997. Ecological Subregions of California, Section and Subsection Descriptions. USDA, Forest Service. Pacific Southwest Region. Prepared in cooperation with: USDA, Natural Resources, Conservation Service; USDI, Bureau of Land Management. R5-EM-TP-005. http://www.fs.fed.us/land/pubs/ecoregions/ch33.html

Norris, D. & J. Shevock. 2004. Contributions toward a bryoflora of California 1: A specimen based catalogue of mosses. Madroño Vol. 51, No. 1, pp. 1-131.

Peterson, E.B. 2010. Conservation assessment and management guidelines for Peltigera hydrothyria Miadlikowska & Lutzoni (a.k.a. Hydrothyria venosa J. L. Russell). U.S. Forest Service, Region 5. Unpubl.

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Pursell, RA. 1976. Fissidens aphelotaxifolius (Bryopsida; Fissidentaceae), a new species from the Pacific Northwest of North America. Bulletin of the Torrey Botanical Club 103(1):35-38.

Smith, S.L. and D.R. Cluck, 2011. Marking Guidelines for Fire-Injured Trees in California, May 2011, Report #RO- 11-01, US Forest Service, Region 5, Forest Health Protection.

Taylor, D. W., J. C. Stebbins and W. B. Davilla. 1987. Endangerment status of Collomia rawsoniana (Polemoniaceae), western Sierra Nevada, California. pp. 225-231 in: T. Elias [Ed], Conservation and Management of Rare and Endangered Plants. California Native Plant Society, Sacramento, CA.

UC Berkeley, 2015. Data provided by the herbaria of the Consortium of California Herbaria (ucjeps.berkeley.edu/consortium/).

USDA Forest Service. 2015. Bass Lake Ranger District Sensitive Plant GIS Coverage. North Fork, CA

USDA Forest Service. 2013. Letter from Regional Forester Randy Moore to Forest Supervisors: Update to the Regional Forester's Sensitive Species List. July 3, 2013, with attachments.

USDA Forest Service. 2012. Sierra National Forest Sensitive Plant List. Pacific Southwest Region, Vallejo, CA (on file at Sierra National Forest, North Fork District Office).

USDA Forest Service. 2009. Forest Service Manual. FSM 2600 Wildlife, Fish, and Sensitive Plant Habitat Management. Chapter 2670 - Threatened, Endangered, and Sensitive Plants and Animals. 2672.4 – Biological Evaluations.

USDA Forest Service. 2005. Forest Service Manual. FSM 2600 Wildlife, Fish, and Sensitive Plant Habitat Management. Chapter 2670 - Threatened, Endangered, and Sensitive Plants and Animals. 2670.4 – Biological Evaluations.

USDA Forest Service, Pacific Southwest Region, 2004. Sierra Nevada Forest Plan Amendment, Final Supplemental Environmental Impact Statement, Record of Decision R5-MB-046.

USDA Forest Service. 2001. Guide To Noxious Weed Prevention Practices. Washington, D.C

USDA Forest Service. 1992. Forest Land and Resource Management Plan, Sierra National Forest. Pacific Southwest Region, San Francisco, CA. September 24, 1992.

USDA Forest Service. 1987. Management Guide for Rawson’s Flaming Trumpet (Collomia rawsoniana). Unpublished document on file at Bass Lake Ranger District office, North Fork, CA.

USDA Forest Service. 2010. Region 5 Proposed Sensitive Species List for Bryophytes. Notes prepared by the California Bryologist 2010 Working Group. 24 pp.

US Fish and Wildlife Service, 2015. United States Department of Interior, Fish and Wildlife Service. Federal Endangered and Threatened Species that may be affected by Projects in the Sierra National Forest.

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Database last updated March 6, 2015, Report date: March 6, 2015. http://www.fws.gov/sacramento/ES_Species/Lists/es_species_lists_NF-action-page.cfm

U.S. Fish and Wildlife Service, 2012. Sidalcea keckii (Keck’s Checkermallow) 5-Year Review: Summary and Evaluation. U.S. Fish and Wildlife Service Sacramento, California. June 2012. http://ecos.fws.gov/docs/five_year_review/doc4010.pdf

U.S. Fish and Wildlife Service. 2003a. DEPARTMENT OF THE INTERIOR Fish and Wildlife Service 50 CFR Part 17 RIN 1018-AG93 Endangered and Threatened Wildlife and Plants; Final Designation of Critical Habitat for Sidalcea keckii (Keck’s checkermallow). Federal Register; Vol. 68, No. 52, 12863-12879

U.S. Fish and Wildlife Service. 2003b. 50 CFR Part 17 RIN 1018–AI26 Endangered and Threatened Wildlife and Plants; Final Designation of Critical Habitat for Four Vernal Pool Crustaceans and Eleven Vernal Pool Plants in California and Southern Oregon. Federal Register; Vol. 68, No. 151, 46684-46867

Wilson, B.L., V.D. Hipkins, E. Rey-Vizgirdas, and T.N. Kaye. 2005. Variation in Lewisia kelloggii (PORTULACEAE), with description of a new species endemic to Idaho. Western North American Naturalist 65(3), pp. 345– 358

Wilson, B.L., J. Clines, and V.D. Hipkins. 1999. Counting Collomia rawsoniana (Polemoniaceae): Is a patch an individual? Draft manuscript on file at Bass Lake Ranger District, North Fork, CA.

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APPENDIX A

SIERRA NATIONAL FOREST

THREATENED, ENDANGERED, AND SENSITIVE PLANT LIST

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Scientific Name Common Name

Fed Fed List

StateList StateList

CNPS CNPS List

SIERRA SIERRA NF Rank State Global Rank

Allium yosemitense Eastw. Yosemite onion K R G2 1B.3 S2.3 Boechera tularensis Windham & Al-Shehbaz Tulare Rockcress K G2 1B.3 S2 Botrychium ascendens W. H. Wagner upswept moonwort K SC G2G3 2.3 S1.3? Botrychium crenulatum W. H. Wagner (soon to be B. lunaria var. crenulatum) scalloped moonwort K SC G3 2.2 S2.2 Botrychium lineare W. H. Wagner (soon to be B. campestre var. lineare) slender moonwort K G2? 1B.3 S1.3 Botrychium lunaria (L.) Sw. (soon to be B. neolunaria) common moonwort P SC G5 2.3 S2? Botrychium minganense Victorin Mingan moonwort K G4 2.2 S1.2 Botrychium montanum W. H. Wagner mountain moonwort K G3 2.1 S1.1 Botrychium paradoxum W.H. Wagner paradox moonwort P G3G4 2.1 S1 Botrychium tunux Stensvold & Farrar moosewort P G3? 2.1 S1 Botrychium yaaxudakeit Stensvold & Farrar giant moonwort P G3G4 2.1 S1 Bruchia bolanderi Lesq. Bolander's bruchia K G3 2.2 S2 Calyptridium pulchellum (Eastw.) Hoov. Mariposa pussypaws K T G1 1B.1 S1 Calyptridium pygmaeum Parish ex. Rydberg pygmy pussypaws K G2 1B.2 S2 Camissonia sierrae Raven ssp. alticola Raven Mono Hot Springs evening primrose K G3T2 1B.2 S2.2 Carlquistia muirii (Gray) B.G. Baldwin Muir's raillardella K G2 1B.3 S2.3 Carpenteria californica Torr. tree anemone K T G1 1B.2 S1? Cinna bolanderi Scribn. Bolander's woodreed K G2 1B.2 S2 Clarkia biloba (Durand) Nels. & Macbr. ssp. australis Lewis & Lewis Mariposa clarkia K SC G4G5T2 1B.2 S2.2 Clarkia lingulata Lewis & Lewis Merced clarkia K E G1 1B.1 S1 Collomia rawsoniana Greene Rawson's flaming trumpet K G2 1B.2 S2 Cypripedium montanum Lindl. mountain lady's slipper K G4 4.2 S4.2 Delphinium inopinum (Jepson) Lewis & Epl. unexpected larkspur K G3 4.3 S3.3 Dicentra nevadensis Eastw. Tulare County bleedingheart K G3 4.3 S3.3 Draba sharsmithii Roll. & Price Mount Whitney draba K G1 1B.3 S1.3 Eriastrum tracyi Mason Brandegee's wooly-star K R G1Q 1B.2 S1.1 Erigeron aequifolius Hall Hall's daisy K G2 1B.3 S2.3 Eriogonum nudum Dougl. ex Benth. var. regirivum Rev. & J. Stebbins Kings River buckwheat K G5T2 1B.2 S2.2 Eriogonum ovalifolium var. monarchense D.A. York Monarch buckwheat K G5T1 1B.3 S1.3 Eriophyllum congdonii Brandegee Congdon's woolly sunflower K R G2 1B.2 S2.2 Erythronium pluriflorum Shevock, Bartel & Allen manyflower fawnlily K G1 1B.3 S1.3 Fissidens aphelotaxifolius Pursell brook pocket moss K G1G2 2.2 S1 Gilia yorkii Shevock and A.G. Day Monarch Gilia P G1 1B.2 S1 Helodium blandowii (Web. & Mohr) Warnst. Blandow's bog moss P G5 2.3 S1 Heterotheca monarchensis York, Shevock, & Semple monarch goldenaster K G1 1B.3 S1.3 Horkelia parryi Greene Parry's horkelia K SC G2 1B.2 S2.2 Hulsea brevifolia A. Gray short-leaved hulsea K SC G3 1B.2 S3 Leptosiphon serrulatus (Greene) J.M. Porter & L.A. Johnson Madera linanthus K G1 1B.2 S1? Lewisia congdonii (Rydb.) J.T. Howell Congdon's bitterroot K R G1 1B.3 S1.3 Lewisia disepala Rydb. Yosemite lewisia K SC G2 1B.2 S2.2 Lewisia kelloggii (K. Brandeg.) ssp. kelloggii Kellogg's lewisia K G4T4? - Lupinus citrinus Kell. var. citrinus orange lupine K G2T2 1B.2 S2.2 Lupinus lepidus Dougl. ex Lindl. var. culbertsonii (Greene) C.P. Sm. Hockett Meadows lupine P G3?T1 1B.3 S1.3 Meesia uliginosa Hedw. broad-nerved hump-moss K G4 2.2 S2 Mielichhoferia elongata (Hoppe &Hornsch. Ex Hook) Nees & Hornsch. elongate copper moss K G4? 2.2 S2 Mielichhoferia shevockii (A.J. Shaw) A.J. Shaw Shevock's copper moss K G1 1B.2 S1 Mimulus filicaulis Wats. slender-stemmed monkeyflower K G2 1B.2 S2.2 Mimulus gracilipes Robinson slenderstalk monkeyflower K SC G2G3 1B.2 S2S3 Mimulus norrisii Heckard and Shevock Kaweah monkeyflower K G2 1B.3 S2.3 Mimulus pulchellus (E. Greene) A.L. Grant pansy monkeyflower P SC G2G3 1B.2 S2S3 Peltigera gowardii Lendemer & H. O'Brien (formerly P. hydrothyria) Goward's waterfan, aquatic felt lichen K G4 - S3.2 Petrophyton caespitosum (Nutt.) Rydb. ssp. acuminatum Munz marble rockmat P G5T2 1B.3 S2 Pinus albicaulis Engelm whitebark pine K C G3G4 - - Plantanthera yosemitensis Colwell, Sheviak & P.E. Moore Yosemite bog orchid K G2 1B.2 S2.2 Sidalcea keckii Wiggins Keck's checkerbloom P E G! 1B.1 S1 Streptanthus fenestratus (Greene) J. Howell Tehipite Valley jewelflower K G2 1B.3 S2 Tauschia howellii (Coult. & Rose) Macbr. Howell's tauschia K G2 1B.3 S2 Trifolium bolanderi Gray Bolander's clover K G2G3 1B.2 S2S3

K=Known to occur in SNF, P = Potential. Please see SPECIAL VASCULAR PLANTS, BRYOPHYTES, AND LICHENS LIST at http://www.dfg.ca.gov/biogeodata/cnddb/pdfs/spplants.pdf

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APPENDIX B

SIERRA NATIONAL FOREST – Preliminary locations of medusahead within French Fire

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