Plant Species at Risk, Helena-Lewis & Clark National Forest

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Botany Supplemental Report – Plant Species At Risk, Helena-Lewis & Clark National Forest

Introduction This specialist report provides supporting information to the effects analysis for at-risk plants in the Environmental Impact Statement (EIS) for the revised forest plan on the Helena-Lewis and Clark National Forest and the species of conservation concern selection. The analysis and conclusions in the EIS are based in part on the information provided here. Included below is the complete list of plant species that were evaluated as potential species of conservation concern in the plan area. Habitat, life history, distribution, threats, rare status ranks and pertinent plan components are considered as a part of this supplemental document.

At-Risk Species The process for the identification of at-risk species in the plan revision process is outlined in the 2012 planning rule directives (FSH 1909.12, Ch. 10). At-risk species include those federally listed under the Endangered Species Act (ESA), proposed and candidate species under the ESA, and species of conservation concern. All action alternatives considered in the EIS share a common list of at-risk plants. There are no federally listed threatened and endangered plant species currently known to occur in the plan area, but there is one candidate species that is included as a federal at-risk species. The candidate plant species that occurs in the planning area is whitebark pine.

A total of 31 species of conservation concern (SCC) and one candidate species are included as at-risk plant species for the Helena-Lewis & Clark National Forest plan revision. The majority are flowering plants, but ferns, mosses, and one conifer are also included on the list. Species of conservation concern and habitat occur in all ecosystem types and in all geographic areas, as shown in the EIS. The species that were considered but not recommended as SCC because they are not known to occur in the Plan Area are shown in Appendix A below. All species that were considered and occurred in the Plan Area are addressed in the body of this supplemental report.

Species of conservation concern Compared to Forest Service Sensitive species Under the current Forest plans, rare plants are provided for according to the national manual direction (FSM 2670) for Regional Forester’s Sensitive species (RFSS). There are a total of 35 species previously identified as sensitive in the plan area; 1 species is a federal candidate species (Whitebark pine) that will not be carried over as an SCC; 12 species from the R1SS list will not be designated by the Regional Forester as SCC for the Draft EIS and 9 additional species will be added that were not previously identified as at-risk species. The total proposed SCC species for the HLCNF is 31, excluding whitebark pine. The 12 RFSS were also addressed in this at-risk plant report.

Unlike the Regional Forester’s Sensitive species list, the species of conservation concern lists are specific to each Forest, and species of conservation concern designated on a Forest must be known to occur there. For that reason, some at-risk species were identified as species of conservation concern on one Forest, but not another. If Regional Forester’s sensitive species were not carried forward as species of conservation concern, it was for one or more of the following reasons, as documented in the project record:

1) The species does not occur on the Forest.

2) Previous occurrence records were determined to be incorrect identifications of the species and/or could not be re-located.

3) Natureserve, Montana Natural Heritage Program (MTNHP), or other local data sources indicated the threats to the species in the plan area were not substantial.

4) Recent surveys indicated the species is more common than originally thought.

5) There was no information about threats to the species. This was a relatively uncommon circumstance, because information about threats could be inferred from threats to the ecosystems upon which the species depend. Lack of information generally only limited species inclusion on the list if the species had not been observed for decades or more, leading to uncertainty about the condition of its specific habitat and occurrences. Procedure and Rationale for Evaluation of Botanical Species of conservation concern

Identification of initial list of species to consider The initial list included all known or potential rare plants within or near the administrative boundaries of the three Forests, providing a comprehensive list for evaluation of other criteria. The list was based on a compilation of 1) all Montana Natural Heritage Program, (MTNHP 2017) polygons from the March 2017 dataset that intersect the Forest boundaries, 2) Montana state lists of threatened and endangered species that occur in Counties that intersect the Forest boundaries, 3) plant species documented in the US Forest Service Natural Resource Information System (NRIS) for the Forest, 4) species on previous Region 1 Forest Sensitive species lists, Watch lists, or species recommended as SCC on adjacent Forests 5) Consortium of Pacific Northwest Herbaria records (http://www.pnwherbaria.org/) for species which are in or near the Forest administrative boundaries, and 6) local Forest datasets indicating which species occur in or near the Forests.

In addition, we considered species listed by federally recognized Tribes, or which have been petitioned for Federal listing and for which a positive “90-day finding” has been made by a regulatory agency, or those for which the best available scientific information indicates there is a local conservation concern about the species’ capability to persist over the long-term in the Plan Area. No species were identified in the latter categories which were not already identified in the lists under items 1-6 above.

This initial list consisted of 127 plant species including flowering plants, conifers, ferns, mosses, and lichens.

Creation of spreadsheet (XL) template All species identified above were entered into a spreadsheet format to enable the evaluation of the following criteria, according to FS Directives (see DEIS Ch. 3 Introduction for explanation). The original template is available at the Regional SCC webpage.

Verification of species occurrence within planning area Some of the species included from the previous step were based upon over-estimated delineations of map areas. Consortium of Pacific Northwest Herbaria records, Montana Natural Heritage database records, and Helena-Lewis and Clark National Forest (HLC NF) rare plant data files were used to identify which

2 species have positive documentation within Forest administrative boundaries. Only species with reliable documentation for presence within the Plan Area, such as specimen vouchers, were carried forward for further consideration.

Assignment of Natureserve ranks The November 2017 Natureserve ranks were entered into the spreadsheet, including G and T ranks, and S ranks for Montana. Conservation categories considered during the SCC evaluation were also entered into the table.

All species that met the following criteria were carried forward for further evaluation: Federally threatened, endangered, or candidate species; G/T 1 or 2; G3, S1, or S2. Natureserve data and ranks are available at: http://www.natureserve.org/, with global rank definitions in Table 1.

Table 1. Natureserve global rank definitions.

Presumed Extinct (species)/Eliminated (ecological communities and systems) — Species not located despite intensive searches and virtually no likelihood of GX rediscovery. Ecological community or system eliminated throughout its range, with no restoration potential.

Possibly Extinct (species)/ Eliminated (ecological communities and systems) — Known from only historical occurrences but still some hope of rediscovery. There is GH evidence that the species may be extinct or the ecosystem may be eliminated throughout its range, but not enough to state this with certainty.

Critically Imperiled—At very high risk of extinction due to extreme rarity (often G1 5 or fewer populations), very steep declines, or other factors.

G2 Imperiled—At high risk of extinction or elimination due to very restricted range, very few populations, steep declines, or other factors.

Vulnerable—At moderate risk of extinction or elimination due to a restricted G3 range, relatively few populations, recent and widespread declines, or other factors.

Apparently Secure—Uncommon but not rare; some cause for long-term concern G4 due to declines or other factors.

G5 Secure—Common; widespread and abundant.

G? Unknown – some uncertainty regarding rank

Table 2. Conservation Categories

Conservation Category Definition

G1 See above.

G2 See above.

G3 See above.

MNHP state rank 1: At high risk because of extremely limited S1 and/or rapidly declining population numbers, range and/or habitat, making it highly vulnerable to extirpation in the state. MNHP State rank 2: At risk because of very limited and/or S2 potentially declining population numbers, range and/or habitat, making it vulnerable to extirpation in the state.

Adjacent SCC species of conservation concern on an adjacent National Forest unit

RFSS regional forester sensitive species Montana Species of Concern: All species with MNHP state ranks of SOC 1, 2 and 3 Delisted (removed) from the Endangered Species Act list within the DM last five years, or delisted and still monitored by the regulatory agency TC Tribal concern

LC Local concern

The Montana Coefficient of Conservatism (C-) value measures a plant species' tolerance to disturbance (natural and/or human derived) and its fidelity to a specific habitat in Montana. A process for assigning C-values to Montana plants was developed in 2005 and revised in 2015 and 2016. A panel of Montana's botany experts determined the plant's C-value using a dichotomous key and definitions published by Zomlefer, et al. (2013), in addition to expertise, literature, and herbarium records.

Table 3. Montana Coefficient of Conservatism Values (C-value) C-value Species disturbance tolerance and habitat fidelity Non-Native Species 0 invasive 1 relatively benign Native Montana Species 2 Opportunistic, Broad Ecological Tolerance exhibits a broad range of ecological tolerance and is more or less restricted to areas of human disturbance 3 Non-Opportunistic, Intermediate Ecological Tolerance exhibits an intermediate range of ecological tolerance, typifies a stable phase of a native community, and thrives and/or persists under natural or human disturbance 4 Non-Opportunistic, Intermediate Ecological Tolerance exhibits an intermediate range of ecological tolerance, typifies a stable phase of a native community, and persists but does not thrive with some natural or human disturbance

5 Non-Opportunistic, Intermediate Ecological Tolerance exhibits an intermediate range of ecological tolerance, typifies a stable phase of a native community, and persists but does not thrive with a little natural or human disturbance 6 Non-Opportunistic, Narrow Ecological Tolerance exhibits a moderate fidelity to a more or less narrow range of ecological tolerance, typifies a stable or near climax community, and tolerates limited natural or human disturbance (unless surrogate for fire or other natural disturbance) 7 Non-Opportunistic, Narrow Ecological Tolerance exhibits a moderate fidelity to a somewhat narrow range of ecological tolerance, typifies a stable or near climax community, and does not tolerate disturbance 8 Non-Opportunistic, Narrow Ecological Tolerance exhibits a moderate fidelity to a narrow range of ecological tolerance, typifies a stable or near climax community, and does not tolerate disturbance 9 Non-Opportunistic, Narrow Ecological Tolerance exhibits a high fidelity to a narrow range of ecological tolerance, typifies a stable or near climax community, and does not tolerate disturbance 10 Non-Opportunistic, Narrow Ecological Tolerance exhibits a very high fidelity to a very narrow range of ecological tolerance that typifies a stable or near climax community and does not tolerate disturbance

Table 4. Montana Native Plant Society Threat Category Category 1 The viability of the species in the state is Highly Threatened by one or more activities. Associated threats have caused or are likely to cause a major reduction of the state population or its habitat that will require 50 years or more for recovery, 20% or more of the state population has been or will be affected, and the negative impact is occurring or is likely to occur within the next 5 years. Category 2 The viability of the species or a portion of the species habitat in the state is Threatened by one or more activities, though impacts to the species are expected to be less severe than those in Category 1. Associated threats exist but are not as severe, wide-ranging or immediate as for Category 1, though negative impacts are occurring or are likely to occur. Category 3 The viability of the species in the state is Not Threatened or the Threats are Insignificant. Associated threats are either not known to exist, are not likely to occur in the near future or are not known to be having adverse impacts that will severely affect the species viability in the state. Category 4 Assessment not possible due to insufficient and/or conflicting information on potential threats to the species.

Evaluating the concerns for each species

Several sources of information were considered in evaluating the ecological conditions and risk factors for each species.

 Natureserve, MTNHP threat ranks and/or descriptions of trends and threats  Published literature  Forest Service monitoring  Forest Service inventory, project level NEPA  Herbarium label descriptions  Forest Service specialist/expert opinion

The existence of one or more of the threats did not necessarily constitute a substantial concern for species persistence. Rather, the context in which each species occurs was considered to determine if damage to individuals or to reproduction caused by the threat constitutes a substantial concern for the loss of viability for one or more populations. This determination, or viability evaluation, was a judgement and not based on a specific threshold (e.g. X% of the population would be damaged by the threat).

The number of populations of each species within the planning area and extent of habitat (approximation based on best available information) were important information pieces that contributed to the judgement of whether a substantial concern existed for the persistence of a given taxon. Similar to the determinations for threats, no set number was used as a threshold, but rather the context in which each species occurs in the plan area was considered. Fundamental principles of conservation biology related to minimum population sizes to maintain viable populations and causes of rarity were considered in these determinations (e.g. Rabinowitz 1981; Shaffer 1981; Wiens & Slaton 2012). Extensive literature, including the few citations provided here, has been evaluated to understand if and how extrinsic and intrinsic factors contribute to species rarity. Plan components were evaluated to determine the level of protection provided to occurrences and habitat in the Plan Area and how that contribute to risk from threats present. Additional detail is provided on each supporting plan components in the Botanist Specialist report for the EIS. Species carried forward to the list of SCC are those for which the identified threats were considered to, at least in part, affect species viability, thus contributing to the substantial concern for species persistence.

If no information on threats or concern for persistence in the planning area was available, the species was flagged as having ‘insufficient information available to conclude there is a substantial concern about the species capability to persist in the Plan Area over the long term’, and the species was not carried forward for further consideration. Literature used for all species is listed below in the literature section. Any additional best available science for individual species was listed under each species’ section.

Recommendations regarding Species of conservation concern, Helena- Lewis and Clark National Forest

Adoxa moschatellina Proposed Species of conservation concern: Yes

Known threats to species persistence: This species occurs in one location in the Plan Area that overlaps with a known recreation site. Threats to this occurrence and habitat in the Plan Area include recreation, livestock grazing, road construction, timber harvest and noxious weeds in the Plan Area.

6 experiences a moderate level of project activity including but not limited to prescribed burns, vegetation treatments, grazing allotments, and both motorized and non motorized recreation. Some habitat is difficult to access and would be less impacted by Plan Area activities. The forest project activity and the lack of plan components specific to this species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest- wide plan components.

Rationale for musk-root: Musk-root occurs in vernally moist places in the mountains at the bottom of undisturbed, open rock slides that have cold air drainage. Populations elsewhere in Montana are generally small, though some populations occur in habitat not generally impacted by human disturbance, such as building of roads and trails, or invasive weeds, though other threats occur. It is currently on the RFSS list and has not been documented elsewhere in the Plan Area despite surveys conducted for project activities. It has a c-value of 9, which exhibits a high fidelity to a narrow range of ecological tolerance, typifies a stable or near climax community, and does not tolerate disturbance. There is limited habitat available in the Plan Area and only a single known occurrence with threats present. This species is recommended to be a SCC species.

Agoseris lackschweitizii Proposed Species of conservation concern: No

Known threats to species persistence: The threats to this species in the Plan Area are changes in the hydrologic conditions required to maintain wet meadow habitat and direct trampling. These are primarily caused by cattle grazing, recreation and noxious weeds.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Aquatic Ecosystems, Vegetation, and Soil plan components protect the wetland-riparian habitat guild of this species. Recreation, Livestock Grazing, Timber and Fire and Fuels plan components prevent damages from occurring during project activities to wetland-riparian habitats, though some impacts may still occur. This species habitat often overlaps with areas protected by plan components, but habitat is not expected to always be within protected areas during project activities. Pink agoseris is impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for pink agoseris: This species is a regional endemic of southwest Montana, east-central Idaho, and northern Wyoming. It occurs in montane to subalpine open moist meadows on various substrates where soil is saturated throughout the season. In the moist meadows, soils are shallow and gravelly to loamy, with high amounts of organic matter present. This species does not appear to be restricted to a specific geologic stratum, physical or chemical characteristic of the soil. It has a C-value of 6 (table 3). Some floras consider this species to be a pink form of Agoseris aurantica and not a distinct species. Pink agoseris is ranked as a G4G? indicating some uncertainty in the ‘apparently secure’ rank definition, and state rank of S3S4 . There are threats present in the Plan Area, particularly in grazing allotments, but the majority of known occurrences are considered to have reduced risk due to high elevation populations and habitat protection for its riparian habitat by forestwide plan components for wetland-riparian habitats during project activities (Pavek and Schassberger 1990). There is insufficient information to conclude that there is substantial concern for this species viability in the Plan Area.

Amerorchis rotundifolia Proposed Species of conservation concern: Yes

Known threats to species persistence: The greatest threat to this species in the Plan Area is a change in hydrologic conditions which could eliminate entire occurrences. This can be caused by project activity, livestock grazing, noxious weeds, and both motorized and non-motorized recreation. This species can also be impacted by direct trampling, changes in canopy cover, and non-native species competition. Populations of this species can be numerous in the Plan Area (1000’s of plants), but often cover only small geographic areas and are supported by specific habitat requirements, increasing the potential impact of single disturbance events.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species and would continue to as a species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC- 02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Aquatic Ecosystems, Vegetation, and Soil plan components protect the wetland-riparian habitat guild of this species. Recreation, Livestock Grazing, Timber and Fire and Fuels plan components prevent damages from occurring during project activities to known populations and wetland-riparian habitats, though some impacts may still occur. This species habitat often overlaps with areas protected by plan components, but habitat is not expected to always be within protected areas during project activities. Round-leaved orchis is impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for Round-leaved orchis: Amerorchis rotundifolia has a global rank of G5 and a state rank of S3. In addition it has a C value of 10 (Table 3). In Montana, this species is restricted to the Rocky Mountain Front, Bob Marshall Wilderness Complex, Swan Valley, and the northwest corner of the state, which includes the Flathead, Kootenai and Helena-Lewis and Clark National Forest. On the Helena- Lewis and Clark, round-leaved orchis generally occurs around mossy seeps, sphagnum bogs, ponds, or along streams in wet to moist spruce forests with limestone-derived soils and it is only found in the Rocky Mountain Front ranger district. There are 40 known occurrences in the Plan Area out of 69 total occurrences in Montana. There is only minimal suitable habitat available on the forest in other districts and no known occurrences.

This species exhibits high fidelity to a very narrow range of ecological tolerance that typifies a stable or near climax community and does not tolerate disturbance. Habitat for this species is limited in the Plan Area and threats are present at many of the known occurrences for this species (Handley and Heidel 2005; Shelly 1988b; Schassberger 1988a). The populations known on the HLC NF represent a significant percentage of known occurrences in Montana. This species is recommended to be a SCC species.

Aquilegia brevistyla Proposed Species of conservation concern: Yes

Known threats to species persistence: Across this species’ range, the most immediate threat to short- styled columbine is habitat loss and modification of hydrologic conditions that support habitat from recreation activities, livestock grazing, noxious weeds, timber harvest, and rural development. Based on Ladyman’s (2006) assessment of short-styled columbine in the Rocky Mountain Region, small, disjunct

8 occurrences such as those in Montana are the most vulnerable to loss from threats described above and genetic loss through hybridization.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species and would continue to as a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC- 02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Aquatic Ecosystems, Vegetation, and Soil plan components protect the wetland-riparian habitat guild of this species, though these plan components only protect portions of this species’ habitat because of its tendency to grow in mesic forest ecotones away from riparian areas specifically protected, such as Riparian Management Zones (RMZs) and Groundwater-Dependent Ecosystems. Recreation, Livestock Grazing, Timber and Fire and Fuels plan components prevent damages from occurring during project activities to known populations in wetland-riparian habitats, though impacts are likely to still occur to the majority of populations outside of plan component protection. The lack of plan components specific to this species’ habitat increases the threats for this species in the plan are relative to other species’ and habitats which are more thoroughly covered by forest-wide plan components.

Rationale for short-styled columbine: Short-styled columbine has a global rank of G5 and a state rank of S2S3. This species’ occurrences are generally small and Montana populations are highly disjunct from the main portion of the species’ range in Canada and Alaska. This species is on the Regional Forester Sensitive species list (USFS 2011). There are 51 known occurrences of short-styled columbine populations in Montana that occur in the Little Belt Mountains and three unverified populations in the Big Snowies, also on the Helena-Lewis and Clark National Forest. Occurrences in the Little Snowies and in Sweetgrass County had been previously misidentified. Short-styled columbine is locally common in specific geographic locations, but is not abundant on the Forest overall or in Montana. Occurrences within a single geographic area tend to be distributed in clumps based on suitable habitat. Short-styled columbine typically grows in semi-open, moist drainage bottoms or toe slopes on alluvial or colluvial limestone substrates at mid-elevations (5000-6200’) in the montane zone. Populations can be located along streambanks within RMZs in mesic forest under partial overstory shade from common conifer species (Engelmann spruce, Douglas-fir, lodgepole pine, ponderosa pine) where it competes with under canopy cover; or can also be found in more open locations, such as meadow edges. It can be a common understory component in locations that it occurs, though many populations are small (Ladyman 2006; Mathews 1989; Row 1992).

Habitat for this species is limited in the Plan Area and threats are present at many of the known occurrences for this species. Occurrences and suitable habitat consistently overlap with project areas, such as vegetation treatment projects and recreation sites, and forest wide plan components do not protect this species habitat without SCC status. There is limited habitat in the Plan Area and the known Montana occurrences almost entirely occur on the eastern side of the Little Belt range, which is disjunct occurrence from main occurrence in Canada and Alaska. This species is recommended to be a SCC species.

Aquilegia jonesii Proposed Species of conservation concern: No

Known threats to species persistence: The threats to this species in the Plan Area are motorized and non-motorized recreation and noxious weeds. There is some risk of overlap with forest project activities, but generally there are few activities occurring in this species’ habitat.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Vegetation, Soil, Designated Wilderness and Livestock grazing plan components support native plant species in the Plan Area, but alpine habitat is only minimally protected by plan components. Alpine habitats are considered to have reduced threats to at-risk species due to inaccessibility, the large percentage of available habitat overlaps with wilderness, and has infrequent project activity, which mainly includes radio tower access and recreation. The effects of climate change are generally expected to have a relatively larger impact on high elevation native habitats compared to lower elevation native habitats; however, the precise effects of the greatest factors, precipitation and water availability, are mainly speculative at this time for the Plan Area.

Rationale for Jones’ columbine: This species is a regional endemic of Southern Alberta, northwest and central Montana, northern Wyoming. Its global rank is G4 and state rank is S3S4. It occurs in stony, calcareous soil of ridges, outcrops, talus slopes, often in cushion plant communities in the alpine zone, occasionally occurring down to the montane zone in exposed sites. Much of this species’ habitat throughout its range is inaccessible, though there are several easily accessible populations on the Helena- Lewis and Clark NF. It is likely that there are additional populations of this species in the Plan Area that have not yet been documented. This species flowers early in the season, shortly after snow recedes. There is insufficient information on this species’ range and present threats in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area.

Astragalus convallarius Proposed Species of conservation concern: Yes

Known threats to species persistence: Threats include development, noxious weed invasion, livestock grazing, recreation, project activities, conifer encroachment, and unknown impacts from prescribed fire and wildfire. This species has limited range in the Plan Area; most of its habitat occurs in the Helena Valley and lower elevation grasslands that are subject to increased threats from development, grazing practices and other human activities. There are threats present at all known occurrences in the Plan Area, which are limited to two general locations in the Plan Area. MNPS threat rank is C2 meaning that viability of the species or a portion of the species habitat in the state is threatened by one or more activities. Though impacts to the species are expected to be less severe than those in Category 1, negative impacts are occurring or are likely to occur.

10 recreation. The high level of forest project activity and the lack of plan components specific to this species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest-wide plan components.

Rationale for lesser rushy milkvetch: Astragalus convallarius has a global rank of G5, and a state rank of S3. The distribution of this species in Montana is limited to two disjunct localities in the state: the Helena Valley vicinity and an area in extreme southwest Montana in Beaverhead County. There are 59 known occurrences in the state and 19 occurrences (3 not yet recorded in MTNHP) on the Helena-Lewis and Clark NF. The species has been and continues to be negatively impacted by development in the Helena area. Past development in the Helena Valley likely eliminated extensive areas of previously occupied habitat resulting in the more fragmented distribution seen today. The grassland habitats this species occupies are also being invaded by several noxious weeds, particularly in the Helena vicinity. However, the species appears to tolerate some levels of disturbance and degradation of habitat quality. Several large occurrences are presently known and some areas of potentially suitable habitat remain unsurveyed. This species occurs in grasslands and open ponderosa pine woodlands in the valley and foothills where threats are common (Barton & Crispin, 2002; Poole & Heidel, 1993; Heidel and Cooper 1998).

Habitat for this disjunct species is limited in the Plan Area to low elevation grasslands surrounding the Helena Valley. This species has been and continues to be highly impacted from development in the Helena valley, which represents a disjunct population – one of only two in the state. There is a high level of threats present both in and outside of the Plan Area at known occurrences. Many of the known occurrences for this species outside of the Plan Area are threatened by development, making the known occurrences on NFS land more important to the maintained viability of this species in the Plan Area. This species is recommended to be a SCC species.

Astragalus lackschewitzii Proposed Species of conservation concern: Yes

Known threats to species persistence: Lackschewitz’ milkvetch is generally vulnerable to very few threats because of its high elevation and remote habitat. However, this species is endemic to Rocky Mountain Front GA with an extremely narrow range, increasing the threat small disturbances can pose to the entire population. There are approximately 29 occurrences known and nearly all are at least in part within trail prism or the Teton Pass ski resort, and many of these occurrences are found outside of wilderness. Several occurrences have been impacted by recreation activities.

11 on high elevation native habitats; however, the precise effects of the greatest factors, precipitation and water availability, are mainly speculative at this time for the Plan Area.

Rationale for Lackschewitz’ Milkvetch: Due to uncertainty about Lackschewitz’ milkvetch’s status, the species is ranked both globally and in Montana as G2G3 S2S3. With the G2 and S2 rank, the species is vulnerable to global extinction or state extirpation. This species is on the Regional Forester Sensitive species list. Lackschewitz’ milkvetch is a Montana endemic restricted to sites in the Rocky Mountain Front Range on the Lewis and Clark National Forest in Teton County. This species has not been found elsewhere in North America.

In Montana, Lackschewitz’ milkvetch is known from 28 (29 according to HLC botany records) documented occurrences on the Helena-Lewis and Clark National Forest. Populations range from a few to over 10,000 plants based on surveys between 1989 and 1992. Some locations sizes were noted as a few to hundreds of plants, but the actual size was difficult to estimate due to the fact that few plants were flowering or fruiting. Our Lake supports a population that ranges from 1,000 to 10,000 individuals. The largest population, with over 10,000 plants, was documented at the Teton Ski Area Peak. Many of the populations were spreading primarily from vegetative reproduction. Schassberger and Shelly (1990) found the populations in the Plan Area to be self-sustaining and most to be in areas that receive little human impact. The species is generally restricted to gravelly and rocky slopes and ridges in the subalpine to alpine zone between 7250 and 8120 feet elevation. Lackschewitz’ milkvetch is often found growing in vegetative mats made up primarily of high elevation species with nearly complete vegetation cover, but it can also grow on sites with less plant cover, such as scree slopes or bare ground. Limestone is the primary substrate at most all documented sites (Lavin and Marriott 1997; Schassberger and Shelly 1990; Schassberger 1998a).

This species has a very narrow range and moderate vulnerability to extirpation from stochastic events or other adverse impacts to its habitat and it is slow to recover. Habitat for this species is limited in the Plan Area and despite its high elevation habitat that can be inaccessible, recreation use and threats are present at many of the known occurrences for this species. This species is recommended to be a SCC species.

Botrychium crenulatum Proposed Species of conservation concern: Yes

Known threats to species persistence: Potential impacts include livestock grazing, noxious weeds, timber management, hydrologic changes and recreation uses. Populations are generally small in size and occupy roadsides or other similarly open or disturbed habitats. As such, it is vulnerable to activities such as weed invasion, weed spraying, road maintenance, and other ground disturbing activities.

12 habitat is not expected to always be within protected areas during project activities. Wavy moonwort is impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for wavy moonwort: There are only two occurrences that are known to occur on the HLCNF. There are additional Botrychium spp occurrences that are not identified to species and these could potentially be B. crenulatum, but no other occurrences are known despite frequent surveys. One occurrence is currently impacted by livestock trampling and grazing on individual plants, and the second occurrence was not relocated in 2016. Wavy moonwort is a G3 and S3 rank globally and statewide respectively. It is currently a RFSS and given a threat rank of 2, meaning that the viability of the species or a portion of the species habitat in the state is threatened by one or more activities. Though impacts to the species are expected to be less severe than those in Category 1, negative impacts are occurring or are likely to occur. It has a C-value of 4 (Table 3).

Botrychium spores germinate underground where development of the gametophyte is dependent upon early infection by an endophytic fungus. The sporophyte generation (roots lack root hair) is also dependent on the fungal symbiont for absorption of water and minerals. The presence or absence of the fungi likely affects where the plant is found. Management activities (road building, harvest, development) upstream and climate change could potentially affect the hydrology of the sites. Plants are vulnerable to catastrophic flooding based on preferred habitat. Herbivory of Botrychium crenulatum has been observed, and nibbled plants of other Botrychium species are reported. This species is tolerant of some disturbance and requires disturbance on the landscape to populate new sites, which it is observed to colonize 10-30 years following disturbance. Level of disturbance can promote or inhibit growth depending on type and intensity. It is advised to maintain source populations on the landscape while satellite populations can appear and disappear with disturbance (Barton and Crispin 2002; Farrar 2011; Lesica and Ahlenslager 1993; Vanderhorst 1997; Wagner and Wagner 1986; personal communication with Steve Popovich and Steve Shelly).

Extremely low numbers at known locations across Montana raise questions about population viability even under unaltered conditions. There are extensive survey records for this species and it is rare in the Plan Area, potentially due to infrequently occurring site conditions for the mycorrhizal fungi required to support this species. Due to low numbers, difficulty relocating plants, threats present at each known occurrence, damaged plants at 50% of known occurrence and seasonal plant disappearance, entire vegetation communities that support wavy moonwort should be considered for protection. This species is recommended to be a SCC species.

Botrychium paradoxum Proposed Species of conservation concern: Yes

Known threats to species persistence: Potential impacts include livestock grazing, noxious weeds, timber management, hydrologic changes and recreation uses. Many occurrences are small in size and occupy mesic meadows and bunchgrass communities. As such, it is vulnerable to activities such as weed invasion, weed spraying, road maintenance, and other ground disturbing activities.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species and would continue to as

13 a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC- 02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Aquatic Ecosystems, Vegetation, and Soil plan components protect the wetland-riparian habitat guild of this species. Recreation, Livestock Grazing, Timber and Fire and Fuels plan components prevent damages from occurring during project activities to known populations and wetland-riparian habitats, though some impacts may still occur. This species’ habitat often overlaps with areas protected by plan components, but habitat is not expected to always be within protected areas during project activities. Peculiar moonwort is impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for peculiar moonwort: Peculiar moonwort has about 56 occurrences known to occur in western Montana, almost all of which are on federally-managed lands. Many occurrences are small in size. The HLC NF supports four peculiar moonwort populations. This species is ranked as a G3G4 and S3 with a threat value of 2. Peculiar moonwort tends to occupy mesic meadows and bunchgrass communities often associated with spruce and lodgepole pine forests in the montane and subalpine zones. In Montana, Botrychium paradoxum grows on glaciated slopes and ridgetops, and in glaciated lake basins, stream bottoms and draws at elevations ranging from 3,700 to 8,400 feet. In a demographic monitoring study in Waterton Lakes Park, Canada (Lesica and Ahlenslager 1993), it was determined that peculiar moonwort has the most volatile demographic regime and suggests that, of all three [Botrychium] species, it is the most adapted to ephemeral habitats and is the most prone to cycles of extinction and recolonization. This species is tolerant of some disturbance and requires disturbance on the landscape to colonize new sites. Level of disturbance can promote or inhibit growth depending on type and intensity. It is advised to maintain source populations on the landscape while satellite populations can appear and disappear with disturbance (Barton and Crispin 2002; Farrar 2011; Vanderhorst 1993; Vanderhorst 1997; Wagner and Wagner 1986). (personal communication with Steve Popovich and Steve Shelly)

Extremely low numbers at known locations across Montana raise questions about population viability even under unaltered conditions. Low numbers, difficulty relocating plants, threats present at all four known occurrences and seasonal plant disappearance, entire vegetation communities that support peculiar moonwort should be considered for protection. This species is recommended to be a SCC species.

Botrychium simplex Proposed Species of conservation concern: No

Known threats to species persistence: Potential impacts include livestock grazing, noxious weed establishment, timber management, hydrologic changes and recreation uses. Many occurrences are small in size and occupy mesic meadows and bunchgrass communities. As such, it is vulnerable to activities such as weed invasion, weed spraying, road maintenance, and other ground disturbing activities. There are no specific threats known at the single occurrence in the Plan Area.

14 overlaps with areas protected by plan components, but habitat is not expected to always be within protected areas during project activities. Least moonwort is impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for least moonwort: This species has a global rank of G5 and state rank of S2. It occurs in various mesic sites from low to moderate elevations, including roadsides and other disturbed habitats. Sites are generally open with montane meadows and grasslands being the most common habitats occupied by the species (Farrar 2011; Wagner and Wagner 1986). There is only one known occurrence in the Plan Area, and no threats are known to occur at this site. It is likely that there are additional populations of this species in the Plan Area that have not yet been documented. There is insufficient information on this species in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area. There are some questions on this species’ rarity range wide that indicate it may not require SCC status. (personal communication with Steve Popovich and Steve Shelly)

Braya humilis (Neotorularia humilis) Proposed Species of conservation concern: Yes

Known threats to species persistence: Threats include noxious weed invasion, livestock grazing, recreation, and management activities. This species has limited range in Plan Area and small population sizes at those known locations. There are threats present at all known occurrences in the Plan Area, which are limited to two locations in the Plan Area.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species but would as a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC- 02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Vegetation, Soil, and Livestock grazing plan components protect the native species composition of the mesic-montane-disturbance-talus habitat guild of this species. The sparsely vegetated, vernally moist, calcareous soil in the montane to alpine zone and similar sites with sparse vegetation cover in montane settings within the mesic-montane-disturbance-talus guild typically experiences a high level of project activity including but not limited to prescribed burns, vegetation treatment, grazing allotments, and both motorized and non motorized recreation. The high level of forest project activity and the lack of plan components specific to this species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest-wide plan components.

Rationale for low braya: This species is known from five occurrences in the state, including one in which only one plant was observed. It is ranked G5 and S2. It is found on sparsely vegetated, vernally moist, calcareous soil in the alpine zone and similar sites with sparse vegetation cover dominated by Potentilla fruticosa, Carex scirpoidea, Phlox kelseyi and Zigadenus elegans in montane settings along the Rocky Mountain Front and the Big Snowies. Its Montana populations are one of three disjunct populations, which also include Wyoming and Colorado. Most of its known range is from Alaska to Greenland.

This species has very few occurrences in Montana and preliminary data at one site indicates that population levels may be in decline. Habitat for this species is limited in the Plan Area and threats are

15 present at many of the known occurrences for this species. This species is recommended to be a SCC species.

Cardamine rupicola Proposed Species of conservation concern: No

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Vegetation, Soil, Designated Wilderness and Livestock Grazing plan components support native plant species in the Plan Area, but alpine habitat is only minimally protected by plan components. Alpine habitats are considered to have reduced threats to at-risk species due to inaccessibility, large percentage of available habitat overlaps with wilderness, and infrequent project activity, which mainly includes radio tower access and recreation. The effects of climate change are generally expected to have a larger impact on high elevation native habitats; however the precise effects of the greatest factors, precipitation and water availability, are mainly speculative at this time for the Plan Area.

Rationale for cliff toothwort: This species has a global rank of G3 and state rank of S3. It is a globally rare species and a Montana endemic. Populations are generally in more remote locations and in habitats that typically are not subject to heavy human use. There are nine documented occurrences in the Plan Area, nearly all within wilderness areas with few threats. Four additional occurrences are documented in the Little Belt mountain range. These could potentially have additional threats, but the majority of habitat and known occurrences are in wilderness in the Plan Area. There are some questions on this species’ rarity range wide in Montana due to incomplete survey data. There is no trend data available. There is insufficient information on this species in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area.

Carex incurviformis Proposed Species of conservation concern: No

Known threats to species persistence: The only identified threat to this species in the Plan Area are recreation. The only known occurrence of this species in the Plan Area occurs at Our Lake, a popular recreation site in wilderness. There is some risk of overlap with forest project activities, but generally there are few activities occurring in this species’ habitat.

16 available habitat overlaps with wilderness, and infrequent project activity, which mainly includes radio tower access and recreation. The effects of climate change are generally expected to have a larger impact on high elevation native habitats; however the precise effects of the greatest factors, precipitation and water availability, are mainly speculative at this time for the Plan Area.

Rationale for coastal sand sedge: This species has a global rank of G4G5 and state rank of S2?. This species grows on wet rock ledges and moist tundra in the alpine zone. Populations are generally in more remote locations and in habitats that typically are not subject to heavy human use. The only known occurrence in the Plan Area is susceptible to impacts from recreation activities. There is limited survey data available for this species in the Plan Area and it is likely that there are additional populations of this species in the Plan Area that have not yet been documented, generally in wilderness habitats that are not expected to be impacted. There is insufficient information on this species in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area.

Carex rostrata Proposed Species of conservation concern: No

Known threats to species persistence: Potential impacts include livestock grazing, noxious weed establishment, timber management, hydrologic changes and recreation uses. This species occurs in fens and fen habitat is typically omitted from ground disturbance during project activities, such as vegetation treatments. This species habitat is extremely sensitive to impacts from grazing, noxious weeds and hydrologic changes.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species but would not as a Species of conservation concern. Various Aquatic Ecosystems, Vegetation, Soil plan components protect the peatland habitat guild of this species, including the groundwater dependent ecosystems plan components and the RMZ plan components. Recreation, Livestock Grazing, Timber and Fire and Fuels plan components include habitat protections to prevent damages from occurring as a result of project activities to known populations and peatland habitats, though some impacts may still occur. This species’ habitat often overlaps with areas protected by plan components, but small areas of habitat may not occur within protected areas during project activities. Unknown occurrences of glaucus beaked sedge in small over-looked patches of suitable habitat can be impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for glaucus beaked sedge: This species has a global rank of G5 and state rank of S2S3. It grows in the wet organic soils of fens, which are often protected from ground disturbance. There is limited survey data available for this species and only 5 occurrences documented in Montana, in addition to the two found in the Plan Area. There is insufficient information on the full extent of this species in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area.

Carex stenoptila Proposed Species of conservation concern: No

17 motorized trail in designated wilderness. There is some risk of overlap with forest project activities, but generally there are few activities occurring in this species’ habitat.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC- 02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Vegetation, Soil, and Livestock grazing plan components protect the native species composition of the mesic-montane-disturbance-talus habitat guild of this species. The dry, often rocky soil of open forests and moist soil along streams in montane and subalpine habitats where this species occurs within the mesic-montane-disturbance-talus guild can typically experience a high level of project activity including but not limited to prescribed burns, vegetation treatments, grazing allotments, motorized and non motorized recreation. The only known occurrence of this species occurs in designated wilderness and there are very minimal threats present. This site would be protected by Wilderness and RMZ plan components, though other undiscovered occurrences could overlap with project disturbance due to this species broad habitat requirements.

Rationale for small-winged sedge: This species has a global rank of G3 and state rank of S2S3. It is a globally rare species, which is known from several widely scattered locations in Montana. There is very little data available for the species in Montana, as the sites are known only from specimen collections with sparse information. Populations are generally in more remote locations and in habitats that typically are not subject to heavy human use. Most documented occurrences are from trail-sides, though this is likely a result of opportunistic collections being made rather than it being representative of its true distribution across the landscape.

There is only one known occurrence in the Plan Area, and there is a non-motorized trail known to occur along this site which poses a minimal threat to this species. It is likely that there are additional populations of this species in the Plan Area that have not yet been documented. There is insufficient information on this species in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area. There are some questions on this species’ rarity across its range in Montana due to incomplete survey data.

Carex stevenii Proposed Species of conservation concern: No

Known threats to species persistence: The threats to this species in the Plan Area are recreation and noxious weeds. The only known occurrence of this species in the Plan Area occurs at the end of a non- motorized trail in designated wilderness (McNeill 2011). There is some risk of overlap with forest project activities, but generally there are few activities occurring in this species’ habitat.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Vegetation, Soil, Designated Wilderness and Livestock grazing plan components support native plant species in the Plan Area, but alpine habitat is only minimally protected by plan components. Alpine habitats are considered to have reduced threats to at-risk species due to inaccessibility, the large percentage of available habitat that overlaps with wilderness, and

18 infrequent project activity, which mainly includes radio tower access and recreation. The effects of climate change are generally expected to have a larger impact on high elevation native habitats; however, the precise effects of the greatest factors, precipitation and water availability, are mainly speculative at this time for the Plan Area. This species is also known to occur in wetland riparian habitat in montane and subalpine habitats. These areas would be generally protected by forest wide Aquatic Ecosystem plan components.

Rationale for Steven’s Scandinavian sedge: This species has a global rank of G5T4? and state rank of S2?, which indicates that there is incomplete information available about this species range and rank. It is found along streams and in wet meadows in the montane and subalpine and growing in moist turf in the alpine. It has a C-value of 8 (Table 3). It is considered rare in Montana, where it is currently known from a few scattered sites in mountainous areas across the southern half of the state. There are some questions on this species’ rarity across its range in Montana due to incomplete survey data. Additional data on population levels and surveys are needed; it is likely that there are additional populations of this species in the Plan Area that have not yet been documented. There is insufficient information on this species in statewide records and in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area.

Castilleja kerryana Proposed Species of conservation concern: Yes

Known threats to species persistence: The threats to this species in the Plan Area are recreation and livestock grazing. The only known occurrences of this species in the Plan Area, and also in the world, occurs in the Scapegoat wilderness in the Sun Rover drainage. There is some risk of overlap with forest project activities, but generally there are few activities occurring in this species’ habitat.

Rationale for Kerry’s paintbrush: Castilleja kerryana is a recently recognized species that grows in alpine habitat in a portion of the Scapegoat Wilderness in Montana. It is ranked as G3 and S3. Populations tend to be small and scattered on slopes and ridges, on rocky or gravelly limestone substrates of Cambrian origin on slopes and ridges from upper subalpine krummholz or turf communities in upper alpine fell fields, and apparently absent on broad, fairly flat alpine terrain. It is endemic to Montana on the Scapegoat Plateau in the Straight Creek and South Fork of the Sun River watersheds, each a tributary of the Sun River (Egger 2013).

Although Castilleja species in general have brittle stems that are easily damaged by livestock, grazing is not known to occur where Kerry's Paintbrush grows. The plant appears to be limited geographically in Montana, and surveys were recently completed by prominent Montana botanists in the surrounding area. This species is bright red and easily viewable during appropriate times of year. The lack of additional mapped occurrences following surveys is an indication that this species habitat is very limited. This species has an extremely narrow range and occurrences tend to be small. As a result, this species has vulnerability to extirpation from stochastic events or other adverse impacts to its habitat. It is recommended to be a SCC species.

Cirsium longistylum Proposed Species of conservation concern: No

Known threats to species persistence: Potential impacts include livestock grazing, noxious weed establishment, noxious weed treatment including an introduced biocontrol species that targets this genus, timber management, hybridization, and recreation uses. Occurrences are common across the forest and often overlap with multiple threats. As such, it is vulnerable to activities such as weed invasion, weed spraying, road maintenance, and other ground disturbing activities. Its occurrences appear to be stable despite common disturbance.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. This species was previously on the RFSS list but was removed following an MNHP assessment in 2004 (Mincemoyer 2004). Various Vegetation, Soil, and Livestock grazing plan components protect the native species composition of the mesic-montane-disturbance-talus habitat guild of this species. The variety of open habitats that receive full to partial sun in montane to subalpine meadows within the mesic-montane-disturbance-talus guild typically experience a high level of project activity including but not limited to prescribed burns, vegetation treatments, grazing allotments, and both motorized and non motorized recreation. The high level of forest project activity and the lack of plan components specific to this species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest- wide plan components.

Rationale for long-styled thistle: This species has a global rank of G2G3 and state rank of S2S3. It has a threat rank of 1 and is endemic to central Montana with extant populations in Broadwater, Cascade, Judith Basin, Lewis & Clark, Meagher and Wheatland counties. There are seven high quality populations scattered over four mountain ranges that are promising for the long-term viability of the species. This species is common in parts of the Plan Area and all 145 known occurrences of this species occur on the Plan Area or adjacent private land. Habitat in the largest populations is generally of high quality with few if any problem weeds posing significant and immediate threats. In the near future, little change in habitat quality is expected in these populations. Long- and short-term population trends are difficult to gauge due to the lack of good survey data over many years. However, available data and observations provide some evidence that population levels have at least remained fairly stable over the past decade, with significant yearly fluctuations possible. Threats posed by invasive weeds and the introduced bio-control agent do provide reason for concern (Barton and Crispin 2002; Brunsfeld and Baldwain 1994; Mathews 1990; Roe 1992; Schassberger 1991; Schassberger and Achuff 1993; Heidel 1994; Mincemoyer 2004).

Long-styled thistle has threats present at many of the occurrences in the Plan Area; however, it is relatively common and there is no clear evidence of decline in this species, though monitoring would be beneficial to provide trend data and determine impacts of introduced bio-control. There is insufficient information on this species in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area.

Cypripedium parviflorum Proposed Species of conservation concern: Yes

Known threats to species persistence: A variety of land uses and activities, including development, noxious weed infestation and treatment, road construction, livestock grazing, and timber harvesting, may have detrimental impacts to populations. Although the species appears to tolerate some disturbances at low levels, activities such as road construction and timber harvest which impede or reduce groundwater flow at population sites are considered a threat to population survival. Small yellow lady slipper appears to be capable of recolonizing some disturbed sites such as skid trails. Although grazing pressure may not be an issue, inference from the Kootenai and Custer indicate that suitable habitats which are grazed have few or no lady’s-slipper and the areas which support the species have little to no evidence of cattle use. Lady’s-slipper’s succulent foliage is palatable, and livestock trampling can be detrimental to the species’ fragile rhizomatous habitat. A population of small yellow lady’s-slipper grows in the Wagner Basin RNA where it is protected from management activities that would disturb the site. However, invasive weed species have become established within the RNA and noxious weed treatments will continue until spotted knapweed, Canada thistle, and cheatgrass are removed or reduced to a manageable size.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester’s Sensitive species and would continue to as a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT- DC-02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Aquatic Ecosystems, Vegetation, and Soil plan components protect the wetland-riparian habitat guild of this species. Recreation, Livestock Grazing, Timber and Fire and Fuels plan components prevent damages from occurring during project activities to known populations and wetland-riparian habitats, though some impacts may still occur. This species habitat often overlaps with areas protected by plan components, but habitat is not expected to always be within protected areas during project activities. Small yellow lady slipper can be impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for small yellow lady slipper: This species is a G5 and S3S4 rank with 132 occurrences in Montana. Fifteen occurrences are found on the Helena-Lewis and Clark, and these are restricted to a single watershed. This species has a c-value of 9 (Table 3) and a threat value of 2 (Table 4). It also occurs in moist forest ecotones that overlap with areas proposed for vegetation treatments. Grazing seems to have limited much of the suitable habitat in the Plan Area. Many of the populations are small in number and reproductive success may be limited, although there are some large populations known from the Rocky Mountain Front. In Montana, small yellow lady’s-slipper grows along ecotonal margins of spruce habitat types (damp mossy woods) with wetland features, such as fens, seeps, springs, and streamsides from the valley to lower montane zone. It also occurs in less typical habitats such as in aspen stands, Douglas-fir habitat types, brushy river bottoms, willow stringers, and disturbed roadsides with other wet

21 site plants associated with high water table features that provide stable, cool, groundwater discharge to meet the species moisture requirements. The high water table features also compensate for macroclimatic differences that are found across the state (east versus west of the Continental Divide and between north and south Montana) (Vanderhorst 1996).

This species occurs in one on watershed area on HLC that is not in designated wilderness; additional habitat occurs in Plan Area that is susceptible to management activities and appears to have been limited in the Plan Area by livestock grazing. Occurrences of this species typically has low occurrence numbers and the HLC NF is the edge of this species known range in Montana. Habitat for this species is limited in the Plan Area and threats are present at many of the known occurrences for this species. This species is recommended to be a SCC species.

Cypripedium passerinum Proposed Species of conservation concern: Yes

Known threats to species persistence: The greatest threats to this species’ survival are activities which impede or reduce groundwater flow at population sites. Livestock grazing, recreation, timber harvest, noxious weed infestations and management activities that change hydrologic flow can also impact this species. Four of the Lewis and Clark occurrences are located adjacent to trails that have the potential to introduce invasive weeds which can outcompete sensitive species for available resources. Grazing impacts appeared to be greatest in drought years when livestock were seeking available water. Populations can recover after disturbance, such as timber harvest, but recovery is slowest in areas with dense overstory canopy cover.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species and would continue to as a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC- 02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Aquatic Ecosystems, Vegetation, and Soil plan components protect the wetland-riparian habitat guild of this species. Recreation, Livestock Grazing, Timber and Fire and Fuels plan components prevent damages from occurring during project activities to known populations and wetland-riparian habitats, though some impacts may still occur. This species habitat often overlaps with areas protected by plan components, but habitat is not expected to always be within protected areas during project activities. Sparrow’s egg lady slipper is impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for sparrow’s egg lady slipper: This species is ranked G5 and S2S3 and it has a threat rank of 2 and a C-value of 8 (Table 3). Sparrow’s egg lady slipper is relatively abundant from Alaska through Canada. However, in the lower 48 states it is only found in the northwest corner of Montana. Of the 51 known occurrences, several are afforded a high level of protection by being located within designated wilderness or Glacier National Park. Nineteen occurrences are found on the Rocky Mountain Ranger District of the HLC NF.

Sparrow’s egg lady slipper occurs in moist, mossy, seepage areas; riparian zones; and in ecotonal margins of sphagnum bogs, often in full or partial shade of conifers. Although preferred habitat is often associated with spruce, it can also be associated with lodgepole pine. Sites on the HLC NF are typically on

22 calcareous substrates and the most important feature at every site on the Forest appears to be a semi- permanent water seepage near the surface. In a monitoring summary written by Dana Fields (1993), it was noted that sparrow’s egg lady slipper is “[o]ne of the rarest orchids in the Front Range, having a very narrow range of habitat requirements. These requirements include limestone substrate, cool sites at mid- elevations, seeps or springs, a moderate amount of rotting wood on the forest floor, and at least partial shade. Even where these requirements are met the plant is uncommon” (Schassberger 1988; Shelly 1988; Vanderhorst 1996).

This species has a limited amount of habitat available in Plan Area due to its narrow habitat requirements and the habitat available is susceptible to management activities. The Plan Area is at the edge of the species' range in Montana. This species is recommended to be a SCC species.

Delphinium bicolor ssp. calcicola Proposed Species of conservation concern: Yes

Known threats to species persistence: Threats present include noxious weeds, recreation and livestock grazing. This species occurs on a rocky slope in the big belts at one known location. It occurs with mountain mahogany. Any ground disturbance could potentially greatly reduce or extirpate this occurrence from the area, reducing its known range in Montana. It is susceptible to impacts from recreation and livestock grazing because it is in an allotment and near a road used for access to the Gates of the Mountains wilderness.

Rationale for limestone larkspur: There is some uncertainty in the ranking of this Montana endemic subspecies which is ranked as G4G5T3T4 S3S4. Its state threat rank indicates that it is Category 3. While the state rank applies to the state wide population, the outlying occurrence in the Plan Area is disjunct from the rest of the statewide occurrences. The threats present at this site, the limited habitat in the Plan Area, and the outlying position of this occurrence representing the northeastern most known occurrence of this Montana endemic is significant (Heidel 1995). This species is recommended to be a SCC species.

Draba densifolia Proposed Species of conservation concern: Yes

Known threats to species persistence: This species is small and can be impacted by trampling, compaction and ground disturbance. Some threats at known occurrences include recreation, livestock

23 grazing, motorized and non-motorized travel, and noxious weeds are often present. These threats are present at each known occurrence in the Plan Area and have the potential to affect individuals and entire populations.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species but would as a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC- 02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Vegetation, Soil, Designated Wilderness and Livestock grazing plan components support native plant species in the Plan Area, but alpine habitat is only minimally protected by plan components. Alpine habitats are considered to have reduced threats to at-risk species due to inaccessibility, large percentage of available habitat overlaps with wilderness, and infrequent project activity, which mainly includes radio tower access and recreation. The effects of climate change are generally expected to have a larger impact on high elevation native habitats; however, the precise effects of the greatest factors, precipitation and water availability, are mainly speculative at this time for the Plan Area. Many of the occurrences of this species are found at lower elevations in the montane zone on gravelly, exposed soil of rocky slopes. The ridgelines where is occurs can be impacted by roads and motorized travel, noxious weeds, recreation, and be within project areas. Much of this species habitat is not protected by plan components in the Plan Area.

Rationale for dense-leaf draba: Dense-leaf draba has a global rank of G5, and a state rank of S2. In addition it has a threat rank of 2 (Table 4). In Montana, this species is distributed in the western half of the state in nineteen occurrences; four moderate to large occurrences, six small occurrences and nine historical or poorly documented occurrences. Occupied habitats are at moderate to high elevation which helps to minimize disturbance to some of the populations. However, livestock grazing, invasive weeds and off-road ATV use impact some populations. In the Plan Area it is known from the Rocky Mountain Front, Blackfoot, and Divide GA’s (Barton and Crispin 2002).

This species is in the alpine guild, but suitable habitat and known occurrences are found in areas that are generally lower elevation than many alpine species in the Plan Area and therefore overlap with more threats than is usually expected for alpine species. Habitat for this species is susceptible to impact because there are significant threats present at each of the 14 known occurrences in the Plan Area. This species is recommended to be a SCC species.

Drosera anglica/Drosera linearis Proposed Species of conservation concern: Yes

Known threats to species persistence: Globally, English and linear-leaf sundew are identified as being stable due to the species’ preference for remote peatlands. The primary threat to these species is loss of peatland (bog/fen) habitat through drainage, alteration of the hydrologic system, or peat mining. Alteration of the hydrologic system could occur due to timber harvest, livestock grazing, recreation, noxious weeds, road construction, and some evidence for impacts from wildfire. The only known occurrences in the Plan Area occur in the Indian Meadows Research Natural Area (RNA), which reduces some of the risk from potential threats, though habitat occurs in areas outside of the RNA that is subject to threats.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects these species as Regional Forester Sensitive species and would continue to as Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC- 02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Aquatic Ecosystems, Vegetation, and Soil plan components protect the peatland habitat guild of this species, including the ground water dependent ecosystems plan components. Recreation, Livestock Grazing, Timber and Fire and Fuels plan components prevent damages from occurring during project activities to known populations and peatland habitats, though some impacts may still occur. These species habitat often overlaps with areas protected by plan components, but small areas of habitat may not occur within protected areas during project activities. Unknown occurrences of English and linear-leaf sundews can be impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for English and linear-leaf sundew: English sundew has ranks of G5 and S3 and occurs in across Canada and the northern US. Montana contains 39 English sundew occurrences which are predominantly on federally-managed lands west of the Continental Divide in the northwest corner of the state, but several populations occur in south-central Montana. Linear-leaf sundew has ranks of G4G5 and S2 and has a similar state wide and global distribution, though it is rarer in Montana. Both of these species have limited suitable habitat in the Plan Area and a c-value of 10 (Table 3). The occurrences are mostly moderate to large-sized and healthy. Though these species occur more commonly in western Montana, there is extremely limited habitat available for them species in the Plan Area.

Although it is suspected that additional potential habitat occurs in the Plan Area to support English and linear-leaved sundew, no populations have been located. These species are dependent on narrow ecological conditions (fens), which are fragile habitats. Habitat for these species is limited in the Plan Area, there are low occurrences numbers present in the Plan Area, and habitat for these species is highly susceptible to hydrologic changes which could alter the suitability of the habitat for both sundews. These species are recommended to be SCC species.

Dryas integrifolia Proposed Species of conservation concern: No

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Vegetation, Soil, Designated Wilderness and Livestock grazing plan components support native plant species in the Plan Area, but alpine habitat is only minimally protected by plan components. Alpine habitats are considered to have reduced threats to at-risk species due to inaccessibility, the large percentage of available habitat that overlaps with wilderness, and infrequent project activity, which mainly includes radio tower access and recreation. The effects of climate change are generally expected to have a larger impact on high elevation native habitats; however the precise effects of the greatest factors, precipitation and water availability, are mainly speculative at this time for the Plan Area.

Rationale for entire-leaf avens: This species has a global rank of G5 and state rank is S2S3. It is only known to occur in the Big Snowy Mountains and there is a historic collection from the Tobacco Root Mountains in Montana. It occurs on stony, limestone-derived soil of exposed ridges and plateaus in the alpine zone and much of this species’ habitat throughout its range is inaccessible (Bamberg and Major 1968). There is incomplete survey data on entire-leaf avens and it is likely that there are additional populations of this species in the Plan Area that have not yet been documented. The known occurrences in the Plan Area are difficult to access and occur in a wilderness study area. There is insufficient information on this species range in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area.

Eleocharis rostellata Proposed Species of conservation concern: Yes

Known threats to species persistence: This species is vulnerable to hydrologic alteration and development. Threats include recreation, travel impacts associated with adjacent roads, livestock grazing, noxious weeds, timber harvest and other management activities. These threats have the potential to affect individuals and entire populations. This species occurs outside of wilderness protection in areas that commonly overlap with project activities.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species and would continue to as a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC- 02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Aquatic Ecosystems, Vegetation, and Soil plan components protect the peatland habitat guild of this species, including the ground water dependent ecosystems plan components. Recreation, Livestock Grazing, Timber and Fire and Fuels plan components prevent damages from occurring during project activities to known populations and peatland habitats, though some impacts may still occur. This species habitat often overlaps with areas protected by plan components, but small areas of habitat may not occur within protected areas during project activities. Unknown occurrences of beaked spikerush can be impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for beaked spikerush: This species has a global rank of G5, and a state rank of S3. In addition it has a C value of 9 (Table 3), which indicates a very high fidelity to a very narrow range of ecological tolerance that typifies a stable or near climax community and does not tolerate disturbance. This species occurs in wet, often alkaline soils associated with warm springs or fens in valleys or foothills. It occurs in elevations that frequently overlap with project activity in the Plan Area. It is only known to occur in two locations in the Little Belts on the HLC. There are 21 known total occurrences in Montana. There is only minimal suitable habitat available on the forest in other districts and no known occurrences.

This species has a high fidelity to a very narrow range of ecological tolerance and does not tolerate disturbance. Habitat for this species is limited in the Plan Area and threats are present at the known occurrences for this species. Trends are undocumented, though some declines from habitat loss/alteration seem likely, but it does not appear that the declines have been severe. This species is recommended to be a SCC species.

Elymus innovatus Proposed Species of conservation concern: Yes

Known threats to species persistence: This species is vulnerable to displacement by nonnative grasses, such as timothy or Kentucky bluegrass, in the Plan Area, and threats include livestock grazing, noxious weeds, recreation, project activities. Where northern wildrye is a dominant species it may be grazed by wildlife and livestock, but it is not very palatable and has a moderate to low nutritional value. Northern wildrye does not seem to be seriously injured by fire and may increase with burning. It is reportedly common in post-fire stands ranging from four to 100 years.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species and would continue to as a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC- 02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Vegetation, Soil, and Livestock Grazing plan components protect the native species composition of the grassland habitat guild of this species but do not prevent project level disturbance in this habitat guild. The grassland habitat guild typically experiences a high level of project activity including but not limited to prescribed burns, vegetation treatments, grazing allotments, and both motorized and non motorized recreation. The high level of forest project activity and the lack of plan components specific to this species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest-wide plan components.

Rationale for northern wildrye: This species has a global rank of G5, and a state rank of S2. It is rare in Montana, where it is currently known from a few scattered sites east of the Divide. There are six known occurrences on the HLCNF in two general locations. Northern wildrye grows primarily in sandy meadows, along stream banks, on rock hillsides with partial shade and in open stands of lodgepole or spruce. Northern wildrye has been described as a major component in the lodgepole pine/buffaloberry community type in parts of Canada, but Montana is the southern extent of its range. In Canada it occurs primarily in the upper montane on slopes adjoining the major valley bottoms and dominates the understory in many stands forming a thick sward than conceals lower growing plants. Stands are even aged or multi-aged and of fire origin. Northern wildrye seems ecologically equivalent to pinegrass (Calamagrostis rubescens) outside the range of the latter (roi and Hnatiuk 1980; Williams 1990). This species is rare in the Plan Area and threats are present at each site due to its easily accessible habitat. This species is recommended to be a SCC species.

Epipactis gigantea Proposed Species of conservation concern: Yes

Known threats to species persistence: Threats include recreation, changes in hydrologic conditions, grazing, and noxious weeds. There is only one known location of this species in the Plan Area; habitat is limited in the Plan Area and supported by specific habitat requirements. The threats have the potential to affect individuals and entire populations, despite its location within a research natural area. The most significant threat to giant helleborine viability is the loss of suitable habitat through alteration of the hydrologic system, specifically lowering the water table. The loss and modification of riparian areas, seeps, and springs globally has led to local decline or extirpation of many populations. The HLC NF

27 population of giant helleborine in the Wagner Basin RNA is protected from management activities that would disturb the site. Within the RNA, however, invasive weed species have become established. A spotted knapweed (Centaurea stoebe) infestation has grown to over 135 acres, and small populations of Canada thistle (Cirsium arvense) and cheatgrass (Bromus tectorum) have established. In order to protect the RNA’s characteristics and sensitive plant populations, the HLC NF will continue treating the invasive weed infestations through herbicide application and biological controls. Treatments will be designed to prevent detrimental effects to the wetland and giant helleborine and small yellow lady slipper sensitive plant populations.

Rationale for giant helleborine: This species is ranked as G4 and S2S3. It is known from occurrences in British Columbia and the western United States. Although the species’ distribution is broad, populations are not common within the range due to the rarity of habitat that meets the species’ needs. In Montana, the species is known from several dozen occurrences across western and southern Montana where it is associated with seeps and springs, fens, and thermal waters. Several sites are likely extirpated, while others are known only from historical collections. Giant helleborine is found from northwest to southcentral Montana.

Nature Serve indicates that globally there are greater than 300 occurrences of giant helleborine. In Montana, the species is known from about 45 observations, predominantly in northwestern Montana. Several populations, however, are also located in south and southwest Montana. Globally and in Montana, giant helleborine populations are generally small (10-200 individuals), but some may exceed 5000 stems. The only recorded giant helleborine population in the Plan Area is located in the Wagner Basin Research Natural Area (USDA Forest Service 1994). This population also boasts of being one of the largest populations recorded with up to 10,000 individuals. Giant helleborine can be found in a wide variety of habitats. However, the one consistent requirement of the species is a permanent source of thermally-influenced water at the root level. At its northern range, such as in Montana, populations are associated with thermal waters which may allow it to persist in the colder climate. This species generally occurs on streambanks, lake margins, fens with springs, and seeps. The Wagner Basin population on the Lewis and Clark is located within a wetland complex consisting of beaver dams and a large spring that provides a year-round supply of alkaline water (Schassberger 1988b).

This species has a high fidelity to a very narrow range of ecological tolerance that typifies a stable or near climax community and does not tolerate disturbance with a C-value of 8 (Table 3). Habitat for this species is limited in the Plan Area and threats are present at the known occurrence for this species. This species is recommended to be a SCC species.

Erigeron flabellifolius Proposed Species of conservation concern: Yes

Known threats to species persistence: Threats include recreation, grazing, noxious weeds, and management activities. There is a single occurrence known in the Plan Area that is found directly along a trail that is used by off road vehicles. These threats have the potential to affect individuals and the entire population.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species but would as a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC- 02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Vegetation, Soil, and Livestock Grazing plan components protect the native species composition of the mesic-montane-disturbance-talus habitat guild of this species. The gravelly soil or talus in the subalpine and alpine zone habitat of this species classified within the mesic-montane-disturbance-talus guild typically experiences a high level of project activity including but not limited to prescribed burns, vegetation treatments, grazing allotments, and both motorized and non motorized recreation. Alpine habitats are considered to have reduced threats to at-risk species due to inaccessibility, large percentage of available habitat overlaps with wilderness, and infrequent project activity, which mainly includes radio tower access and recreation. The area in which this species occurs, however, has relatively easy access. The effects of climate change are generally expected to have a larger impact on high elevation native habitats; however, the precise effects of the greatest factors, precipitation and water availability, are mainly speculative at this time for the Plan Area. The lack of plan components specific to this species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest-wide plan components.

Rationale for fan-leaved fleabane: This species has a global rank of G3, and a state rank of S3. This species is a regional endemic and its range extends from southwest Montana to northwest Wyoming and it is restricted to rocky, alpine habitats in the mountains of south-central Montana. On the Helena-Lewis and Clark, it is known from a single occurrence in the Crazy GA and there is minimal suitable habitat suspected to be available on the forest in other districts.

Fan-leaved fleabane grows in gravelly soil or talus in the subalpine and alpine zones. Although it often occurs in high elevation habitat, its single occurrence on HLC NF overlaps with a recreational trail and a grazing allotment. Habitat for this species is limited in the Plan Area and threats are present at the known occurrence for this species. This species is recommended to be a SCC species.

Erigeron formosissimus Proposed Species of conservation concern: No

Known threats to species persistence: Threats include noxious weed invasion, livestock grazing, recreation, hydrologic changes and project activities.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Vegetation, Soil, and Livestock Grazing plan components protect the native species composition of the mesic-montane-disturbance-talus habitat guild of this species. The meadows and forest openings in the montane and subalpine zones that this species occurs within the mesic-montane-disturbance-talus guild typically experiences a high level of project activity

29 including but not limited to prescribed burns, vegetation treatments, grazing allotments, motorized and non motorized recreation. The high level of forest project activity and the lack of plan components specific to this species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest-wide plan components.

Rationale for beautiful fleabane: This species is known from four occurrences in the Plan Area, and it is ranked G5 and S1S3, indicating some uncertainly with rank. Species has been documented for southern Montana from a few collections. Additional data are needed for this species to more precisely determine its conservation status and need. It is found in meadows and forest openings in the montane and subalpine zones (Mathews 1989).

This species has very few known occurrences in Montana, but additional data on population levels is needed and the current known occurrences may not reflect true numbers across its range in the state. Survey of suitable habitats will likely document additional occurrences. It is likely that there are additional populations of this species in the Plan Area that have not yet been documented. There is insufficient information on this species in statewide records and in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area. There are some questions on this species’ rarity range wide in Montana due to incomplete survey data.

Erigeron grandifloras Proposed Species of conservation concern: No

Known threats to species persistence: The threats to this species in the Plan Area are recreation and climate change. There are a number of unverified occurrences of this species in the Plan Area that are near FS roads in the Little Belts and the Rocky Mountain Front. There is some risk of overlap with forest project activities, but generally there are few activities occurring in this species’ habitat.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Vegetation, Soil, Designated Wilderness and Livestock Grazing plan components support native plant species in the Plan Area, but alpine habitat is only minimally protected by plan components. Alpine habitats are considered to have reduced threats to at-risk species due to inaccessibility, large percentage of available habitat overlaps with wilderness, and infrequent project activity, which mainly includes radio tower access and recreation. The effects of climate change are generally expected to have a larger impact on high elevation native habitats; however the precise effects of the greatest factors, precipitation and water availability, are mainly speculative at this time for the Plan Area.

Rationale for large flower fleabane: This species is known from a number of unverified occurrences in the Plan Area, and it is ranked G5 and S1S3, indicating some uncertainly with rank. It has been documented from only a few scattered collections in Montana. This species was previously classified as Erigeron simplex and there is some confusion regarding identification in herbarium records. As a result, there is need for additional verification of the occurrences in the Plan Area. The habitat for this species tends to be stony soil of fellfields in the alpine zone, however the potential occurrences of this species are within a short distance of drivable roads, increasing the chance of impacts from motorized travel and

30 other recreation and project activities. Much of this species’ habitat, which is largely unsurveyed, occurs further from threats in the alpine zone. Additional data are needed for this species to more precisely determine its conservation status and need.

This species has very few known occurrences in Montana, however additional data on population levels are needed. Survey of suitable habitats will likely document additional occurrences. It is likely that there are additional populations of this species in the Plan Area that have not yet been documented. There is insufficient information on this species in statewide records and in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area. There are some questions on this species’ rarity across its range in Montana due to incomplete survey data.

No Additional Sources

Erigeron lackschweitizii Proposed Species of conservation concern: No

Known threats to species persistence: The threats to this species in the Plan Area are recreation and climate change. The only known occurrences of this species in the Plan Area occur on the Rocky Mountain Front in wilderness. There is some risk of overlap with forest project activities, but generally there are few activities occurring in this species’ habitat. This species mostly occurs within existing wilderness areas.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species but it would not as a Species of conservation concern. Various Vegetation, Designated Wilderness Soil, and Livestock Grazing plan components support native plant species in the Plan Area, but alpine habitat is only minimally protected by plan components. Alpine habitats are considered to have reduced threats to at-risk species due to inaccessibility, the large percentage of available habitat that overlaps with wilderness, and infrequent project activity, which mainly includes radio tower access and recreation. The effects of climate change are generally expected to have a larger impact on high elevation native habitats; however the precise effects of the greatest factors, precipitation and water availability, are mainly speculative at this time for the Plan Area.

Rationale for Lackschewitz' fleabane: This species has a global rank of G3 and state rank of S3. It is endemic to Montana and adjacent Alberta, though the large majority of the species' range is in Montana. Though many of the individual occurrences are small in size, the species is distributed over a relatively wide area along the Rocky Mountain Front south to the Flint Creek Range. The high elevation habitat reduces the potential for detrimental impacts. This plant grows on open, gravelly, calcareous soil and talus on ridgetops in the alpine and subalpine zones (Schassberger 1988a; Heidel 1993; Kerstetter 1994).

Populations are generally in more remote locations and in habitats that typically are not subject to heavy human use. Though there is limited habitat in the Plan Area for this species, and this Plan Area accounts for a significant portion of the range of this local endemic species, these occurrences generally are found in wilderness habitats that are not expected to be threatened.

Gentianopsis macounii Proposed Species of conservation concern: Yes

Known threats to species persistence: The major threat to Montana’s Macoun’s gentian populations is loss of habitat or alteration of the hydrologic system. Establishment of noxious weeds within the HLC NF Wagner Basin RNA has the potential to impact Macoun’s gentian. In order to maintain the RNA’s wetland characteristics and sensitive plant populations, the Forest began treating noxious weeds in 2011 through herbicide and biologic control methods. Treatments will be designed to minimize impact to sensitive plant populations. Other threats to habitat in the Plan Area include livestock grazing, noxious weeds, noxious weeds herbicide treatment and recreation.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species and would continue to as a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC- 02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Aquatic Ecosystems, Vegetation, and Soil plan components protect the peatland habitat guild of this species, including the ground water dependent ecosystems plan components. Recreation, Livestock Grazing, Timber and Fire and Fuels plan components prevent damages from occurring during project activities to known populations and peatland habitats, though some impacts may still occur. This species’ habitat often overlaps with areas protected by plan components, but small areas of habitat may not occur within protected areas during project activities. Unknown occurrences of Macoun’s gentian can be impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes. The two known occurrences of this species occur within a designated RNA that protects it from project activities; however the presence of noxious weeds at those sites and the associated treatment could impact populations.

Rationale for Macoun’s gentian: This species has a global rank of G5, and a state rank of S2. In addition it has a threat rank of 2, which indicates that the viability of the species or a portion of the species’ habitat in the state is threatened by one or more activities, though impacts to the species are expected to be less severe than those in Category 1 (Table 4). Macoun’s gentian’s preferred habitat is wet, organic soil of calcareous fens or wet meadows with standing water in valleys and foothills. The species is known from eight Montana occurrences located just east of the Continental Divide. Two occurrences are within the Lewis and Clark’s Wagner Basin RNA, which drains into the Sun River below Gibson USDA Forest Service 1994). Although the RNA is undisturbed, Macoun’s gentian occurrences in the hanging fen are relatively small (less than 100 plants) with fair reproductive success. This species has limited habitat in the Plan Area and threats are present at the known occurrences for this species. This species is recommended to be a SCC species.

Goodyera repens Proposed Species of conservation concern: Yes

Known threats to species persistence: Northern rattlesnake plantain viability in Montana is vulnerable to disturbances that open the mature stand structure or remove the overstory canopy that creates suitable micro-sites for species survival. Detrimental disturbances include timber harvest, wildfire, road

32 construction, and development. Approximately 1,610 acres of known or suspected northern rattlesnake- plantain habitat had been impacted by timber harvest or fire.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species and would continue to as a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC- 02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Vegetation, Soil, and Livestock Grazing plan components protect the native species composition of the mesic-montane-disturbance-talus habitat guild of this species. The north-facing, mossy, forested slopes in the montane zone habitat for northern rattlesnake plantain within the mesic-montane-disturbance-talus guild typically experiences a high level of project activity including but not limited to prescribed burns, vegetation treatments, grazing allotments, and both motorized and non motorized recreation. The high level of forest project activity and the lack of plan components specific to this species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland- riparian) that are more thoroughly covered by forest-wide plan components.

Rationale for northern rattlesnake plantain: Within Montana, 143 northern rattlesnake-plantain occurrences are located almost entirely in the Little Belt Mountains in the Plan Area. One occurrence is documented in Glacier National Park and a population also occurs in the Little Snowy Mountains. Northern rattlesnake-plantain on the Lewis and Clark National Forest usually grows on cool, north-facing sites consisting of Engelmann spruce/twinflower or subalpine fir/twinflower habitat types with a well- developed organic duff and moss layer at mid-elevations, although it can also occur in Douglas fir and ponderosa pine forest types. Northern rattlesnake-plantain prefers sites containing overstory shade provided by a late successional forest. Most populations are found on sites with limestone substrate, although plants have been found on shale and sandstone as well. Northern rattlesnake-plantain’s habitat is more restricted in the southern portion of the Little Belts compared to the northern portion due to mesoclimatic differences.

Northern rattlesnake-plantain is detrimentally affected by activities that open the stand structure, remove overstory shade, or physically disturb or remove the forest floor organic matter. Timber harvest or severe stand-replacement wildfire are often associated with these detrimental effects. Observations of populations after disturbances in Sage Creek and the Judith River drainage indicated that Northern rattlesnake-plantain will extend up to the boundary, but not into recent clearcuts or severely burned forest. As with other members of the Orchid family, rattlesnake-plantain relies on mycorrhizal fungi for growth and reproduction. It takes about five years for a rattlesnake-plantain seed to produce a rosette of evergreen leaves. Therefore, activities that impact the site’s mycorrhizal fungi will impact rattlesnake- plantain. It is assumed that Northern rattlesnake-plantain has the ability to recolonize disturbed sites after suitable duff, moss, and shade develop. However, the recolonization phase is slow in arriving due to the time required for stand development. The youngest stand with known northern rattlesnake-plantain populations was 80 years old (Achuff 1992; Achuff and Schassberger 1991; Phillips 1995).

This species is found almost entirely in the Little Belts GA in Montana and it frequently overlaps with land recommended for timber suitability and other project threats. This species habitat has been previously impacted by fire and timber activity. No occurrences overlap with existing wilderness, however some occurrences overlap with a wilderness study area which provides some reduction in

33 threats. Habitat for this species is limited in the Plan Area and threats are present at many of the known occurrences for this species. This species is recommended to be a SCC species.

Grindelia howellii Proposed Species of conservation concern: Yes

Known threats to species persistence: Threats include recreation, changes in hydrologic conditions, grazing, noxious weeds, and management activities. This species prefers disturbed habitat and as a result, it is commonly threatened by project activities, noxious weed treatments, road maintenance, and various other threats that have the potential to affect individuals and entire populations despite its tolerance for disturbance. It is known to occur in only one location in the Plan Area.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species and would continue to as a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC- 02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Vegetation, Soil, and Livestock Grazing plan components protect the native species composition of the grassland habitat guild of this species but do not prevent project level disturbance in this habitat guild. The grassland habitat guild typically experiences a high level of project activity including but not limited to prescribed burns, vegetation treatments, grazing allotments, and both motorized and non motorized recreation. The high level of forest project activity and the lack of plan components specific to this species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest-wide plan components.

Rationale for Howell’s gum weed: This species has a global rank of G3, and a state rank of S2S3. This species has a threat rank of 1, which indicates that the viability of the species in the state is highly threatened by one or more activities (Table 4). Associated threats have caused or are likely to cause a major reduction of the state population or its habitat that will require 50 years or more for recovery. 20% or more of the state population has been or will be affected, and the negative impact is occurring or is likely to occur within the next 5 years.

In Montana, Grindelia howellii is known from over 100 mapped occurrences. However, most populations are small and many occur on roadsides or other similarly disturbed habitat. This species is known from only a single location in the Plan Area. This habitat preference, in conjunction with the short-lived nature of the species, means occurrences may drift from place to place or from year to year and as a result many occurrences may be ephemeral. These attributes make determination of population numbers as well as the number of extant populations at any given time difficult to assess (Pavek 1991; Shelly 1986; Barton and Crispin 2002). This species is subject to high level of threats throughout its range and have limited habitat available in the Plan Area. This species is recommended to be a SCC species.

Juncus hallii Proposed Species of conservation concern: No

34 in the Plan Area are cattle grazing, recreation and noxious weeds, though this species has been documented as being tolerant of disturbance.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species but would not as a Species of conservation concern. Various Aquatic Ecosystems, Vegetation, and Soil plan components protect the wetland-riparian habitat guild of this species. Recreation, Livestock Grazing, Timber and Fire and Fuels plan components prevent damages from occurring during project activities to known populations and wetland-riparian habitats, though some impacts may still occur. This species habitat often overlaps with areas protected by plan components, but habitat is not expected to always be within protected areas during project activities. Hall’s rush is impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes, however, the impacts of these activities is reduced by Hall’s Juncus’ tolerance of disturbance.

Rationale for Hall’s rush: This species is rare, though widespread across the mountainous portions of southwest and central Montana. It occurs in subalpine parklands and moist meadows and slopes in the montane zone. It is ranked as a G4G5 and S4, indicating lack of concern for this species in Montana despite relatively rarity, and has a C-value of 6 (Table 3). The lack of concern for this species in Montana and the Plan Area relates to its tolerance for disturbance (Poole and Heidel 1993). Threats and potential negative impacts to most known occurrences appear to be minimal and are further reduced by aquatic ecosystems plan components. There are threats present in the Plan Area, particularly in grazing allotments, but the majority of known occurrences are considered to have reduced risk due to habitat protection for its riparian habitat by forest-wide plan components and this species’ tolerance for distance. There is sufficient information to conclude that there is not a substantial concern for this species viability in the Plan Area.

Kelseya uniflora Proposed Species of conservation concern: No

Known threats to species persistence: Threats are limited to recreation (rock climbing) due to this species’ largely inaccessible habitat.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Vegetation, Soil, and Livestock Grazing plan components protect the native species composition of the mesic-montane-disturbance-talus habitat guild of this species. The crevices of vertical limestone cliffs in montane and subalpine habitats that this species occurs within the mesic-montane-disturbance-talus guild typically experiences a low level of project activity due to inaccessibility. The lack of plan components specific to this species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest-wide plan components, but threats are considered to be minimal.

Rationale for one-flowered kelseya: This species is known from the Plan Area, and it is ranked G5 and S4, indicating that populations are generally secure within Montana. The habitat is relatively inaccessible and there is sufficient information to conclude that there is not a substantial concern for this species viability in the Plan Area.

Listera borealis Proposed Species of conservation concern: No

Known threats to species persistence: This species is vulnerable to livestock grazing, noxious weeds, recreation, hydrologic changes and project activities. This species and habitat is relatively common, though populations are generally small, with many occurrences noting only a few plants at each site.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently does not protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Aquatic Ecosystems, Vegetation, and Soil plan components protect the wetland-riparian habitat guild of this species. Recreation, Livestock Grazing, Timber and Fire and Fuels plan components prevent damages from occurring during project activities to known populations and wetland-riparian habitats, though some impacts may still occur. This species habitat often overlaps with areas protected by plan components, but habitat is not expected to always be within protected areas during project activities. Northern twayblade is impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for northern twayblade: This species is ranked G5 and S4, indicating that populations are generally secure within Montana, though there are few occurrences documented for the state. Population numbers are typically to be quite small, as observations for the species thus far have only noted a few plants at each site, increasing the each occurrence’s vulnerability to stochastic events or other adverse impacts to its habitat. It appears likely, however, that this species is more abundant than current observations document. Habitat for the species does not appear to be uncommon, nor particularly threatened. The species is probably overlooked and under-collected. Northern twayblade grows in seepy, marshy places along cold-air drainages, often at calcareous sites. This species is considered common in Montana and parts of the Plan Area and there is sufficient information to conclude that there is not a substantial concern for this species viability in the Plan Area.

Lycopodium dendroideum Proposed Species of conservation concern: Yes

Known threats to species persistence: Rare in Montana where the species has been documented from only a few sites in the northwest corner of the state and one occurrence on the Lincoln Ranger District in the Plan Area, which is an outlier from typical expected range. Threats include recreation, changes in hydrologic conditions, grazing, noxious weeds, fire, and management activities. This species occurs on land proposed as suitable for timber production. It is known to occur in only one location in the Plan Area. This species also overlaps with a large mining reclamation project area.

36 experiences a high level of project activity including but not limited to prescribed burns, vegetation treatments, grazing allotments, and both motorized and non motorized recreation. The high level of forest project activity and the lack of plan components specific to this species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest-wide plan components.

Rationale for tree-like clubmoss: This species has a global rank of G5, and a state rank of S2. This species is known from only 7 occurrences in Montana, and the recently discovered occurrence in the Plan Area is the only site that is not in the central portion of the state. This species is rhizomatous, like other members of the genus, and the rhizome is located above or just beneath the surface of the ground. The appearance resembling a miniature evergreen tree is distinctive. It grows in moist, coniferous forest in the valley and lower montane zones. This puts it at risk of overlapping with project activities in the Plan Area, most notably timber harvest. The single occurrence and the suitable habitat in the Plan Area has multiple threats. The occurrence on the HLCNF represents the most eastern occurrence of this species known in Montana. This species is recommended to be a SCC species.

Noccaea parviflora Proposed Species of conservation concern: No

Known threats to species persistence: Threats include noxious weed invasion, livestock grazing, recreation, hydrologic changes and project activities. There is one unverified occurrence of this species with threats present.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Vegetation, Soil, and Livestock Grazing plan components protect the native species composition of the mesic-montane-disturbance-talus habitat guild of this species. The various montane to alpine meadows in which this species occurs are found within the mesic- montane-disturbance-talus guild that typically experiences a high level of project activity including but not limited to prescribed burns, vegetation treatments, grazing allotments, and both motorized and non motorized recreation. The high level of forest project activity and the lack of plan components specific to this species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest-wide plan components.

Rationale for small-flowered pennycress: This species is known from one unverified occurrence in the Plan Area that overlaps with a similar species, Noccaea fendleri, which is common in the Plan Area. It is ranked G3 and S3, and most of its known range is in southwest Montana. It is found in a range of habitats from mid-elevation grasslands to alpine turf. It most often inhabits sagebrush steppe occupied by several moisture-loving species. Small-flowered pennycress has also been found occasionally in alpine turf communities, ranging from moist habitats to drier sites.

This species has very few known occurrences in Montana, however additional data are needed for this species to more precisely determine its conservation status and need in the Plan Area. There is insufficient information on this species in statewide records and in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area. There are some questions on this species’ rarity across its range in Montana due to incomplete survey data.

Oxytropis podocarpa Proposed Species of conservation concern: No

Known threats to species persistence: The threats to this species in the Plan Area are recreation and climate change. The only known occurrences of this species in the Plan Area occur within existing wilderness areas. There is some risk of overlap with forest project activities, but generally there are few activities occurring in this species’ habitat.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species but it would not as a Species of conservation concern. Various Vegetation, Soil, Designated Wilderness and Livestock Grazing plan components support native plant species in the Plan Area, but alpine habitat is only minimally protected by plan components. Alpine habitats are considered to have reduced threats to at-risk species due to inaccessibility, large percentage of available habitat overlaps with wilderness, and infrequent project activity, which mainly includes radio tower access and recreation. The effects of climate change are generally expected to have a larger impact on high elevation native habitats; however the precise effects of the greatest factors, precipitation and water availability, are mainly speculative at this time for the Plan Area.

Rationale for stalked-pod locoweed: This species has a global rank of G4G5 and state rank of S1. It is known to only a small area in Montana in the Rocky Mountain Front. This species grows on gravelly ridges and slopes, often on limestone, in the alpine zone. The high elevation habitat reduces the potential for detrimental impacts. Populations are generally in more remote locations and in habitats that typically are not subject to heavy human use (Schassberger 1988a). Though there is limited habitat in the Plan Area for this species, and this Plan Area accounts for the entire Montana state populations, these occurrences generally are found in wilderness habitats that are not expected to be threatened.

Papaver pygmaem Proposed Species of conservation concern: No

Known threats to species persistence: The threats to this species in the Plan Area are recreation and climate change. The only known occurrence of this species in the Plan Area occurs in the Scapegoat wilderness and this species’ suitable habitat mostly occurs within existing wilderness areas. There is some risk of overlap with forest project activities, but generally there are few activities occurring in this species’ habitat.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Vegetation, Soil, Designated Wilderness and Livestock Grazing plan components support native plant species in the Plan Area, but alpine habitat is only minimally protected by plan components. Alpine habitats are considered to have reduced threats to at-risk species due to inaccessibility, large percentage of available habitat overlaps with wilderness, and infrequent project activity, which mainly includes radio tower access and recreation. The effects of climate change are generally expected to have a larger impact on high elevation native habitats; however the precise effects of the greatest factors, precipitation and water availability, are mainly speculative at this time for the Plan Area.

Rationale for alpine glacier poppy: This species has a global rank of G3, a state rank of S2S3 and a threat rank of 3. It grows on sparsely vegetated, stony soil of exposed slopes and ridge tops in the alpine zone. There is only one known occurrence in the Plan Area, though additional habitat is available and it is likely that additional occurrences would be found following surveys. Populations of this species are generally in more remote locations and in habitats that typically are not subject to heavy human use. This occurrence and any additional occurrences that could be discovered in the Plan Area are generally found in wilderness habitats that are not expected to be threatened.

Phacelia lyallii Proposed Species of conservation concern: No

Known threats to species persistence: The threats to this species in the Plan Area are recreation and climate change. The only known occurrence of this species in the Plan Area occurs at Our Lake, a popular recreation site on the Rocky Mountain Front in wilderness. There is some risk of overlap with forest project activities, but generally there are few activities occurring in this species’ habitat.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Vegetation, Soil, Designated Wilderness and Livestock Grazing plan components support native plant species in the Plan Area, but alpine habitat is only minimally protected by plan components. Alpine habitats are considered to have reduced threats to at-risk species due to inaccessibility, large percentage of available habitat overlaps with wilderness, and infrequent project activity, which mainly includes radio tower access and recreation. The effects of climate change are generally expected to have a larger impact on high elevation native habitats; however the precise effects of the greatest factors, precipitation and water availability, are mainly speculative at this time for the Plan Area.

Rationale for Lyall phacelia: This species has a global rank of G3G4 and state rank of S3S4. Phacelia lyallii is known from most major mountain ranges in western Montana. The number of occurrences in Montana plus its habitat preference (high elevation, alpine sites) significantly reduce any concerns for the species viability, despite only having a single known occurrence in the Plan Area. Additional suitable habitat occurs in existing wilderness. There is insufficient information on this species in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area.

Phlox albomarginata Proposed Species of conservation concern: No

Known threats to species persistence: Threats include recreation, noxious weeds, and management activities. Populations of this species often overlap with project areas and areas at risk of impact from project activities and recreation. These threats have the potential to affect individuals and entire populations. This species is a regional endemic with most of its population in Montana. It seems capable of occupying disturbed sites such as old roads and heavily grazed pastures. Livestock grazing does not appear to be an issue due to white-margined phlox’s unpalatable woodiness, small size and hard, pointed leaves, though excessive trampling could be an issue. This species is relatively common in the Plan Area though there is limited spatial data.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Vegetation, Soil, and Livestock Grazing plan components protect the native species composition of the grassland habitat guild of this species but do not prevent project level disturbance in this habitat guild. The grassland habitat guild typically experiences a high level of project activity including but not limited to prescribed burns, vegetation treatments, grazing allotments, and both motorized and non motorized recreation. The high level of forest project activity and the lack of plan components specific to this species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest-wide plan components, though this species seems tolerant of disturbance and many of the activities would not negatively impact occurrences.

Rationale for white-margined phlox: This species has a global rank of G4, and a state rank of S4, indicating that this species is secure in Montana. It grows on stoney calcareous soil of grasslands, rock outcrops from valleys to occasionally alpine. This species occurs widely across the Plan Area, but there is incomplete data on white-margined phlox’ true extent. It is likely that focused surveys would reveal additional populations. This species has forest activities present at known locations but there is insufficient evidence that these threats could lead to a loss of viability in the Plan Area.

Phlox kelseyi var. missoulensis Proposed Species of conservation concern: Yes

Known threats to species persistence: Threats include recreation, grazing, noxious weeds, development, fire suppression techniques, conifer encroachment, and management activities. Populations of this species can be numerous in the Plan Area (1000’s of plants), but often overlap with project area and areas at risk of impact from project activities and recreation. These threats have the potential to affect individuals and entire populations. This species is a local endemic to Montana. Although there is limited information concerning Missoula phlox’s response to management actions, it does seem capable of occupying disturbed sites such as old roads and heavily grazed pastures. Invasive weed infestation, recreational activities, and development are the most significant threats to Missoula phlox on the Lewis and Clark. Livestock trampling could pose a threat to populations, especially small ones, though livestock grazing does not appear to be an issue due to Missoula phlox’s unpalatable woodiness and hard, pointed leaves. On the HLC NF, known populations are adjacent to open system roads that have the potential for invasive weed establishment, exposure to herbicide use, and damage from road maintenance or off-road vehicle use (Barton and Crispin 2002).

40 species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest-wide plan components.

Rationale for Missoula phlox: This species has a global rank of G3, and a state rank of S3. In addition it has threat rank of 2 (Table 4), indicating that the viability of the species or a portion of the species’ habitat in the state is threatened by one or more activities, though impacts to the species are expected to be less severe than those in Category 1. The HLC NF supports 53 Missoula phlox occurrences in the Little Belt Mountains, Divde GA and Blackfoot GA. Populations in Montana, most of which are moderate to large-sized, range from a few to 10,000 plants and occur on a variety of ownerships (Schassberger and Achuff 1991).

Missoula phlox typically grows from open, exposed, limestone-derived slopes in the foothills to windswept ridges and crests in the subalpine zone. Occupied sites span a wide altitudinal range, but are predominantly between 3600 and 8100 feet. Habitat ranges from sparsely vegetated grass and forb communities to high elevation krummholz communities. Missoula phlox, a slow growing perennial with a low recruitment rate, appears to be very intolerant of competition from other plants, especially overstory shade. This species has threats present at nearly all of the known occurrences for this species. This species is recommended to be a SCC species.

Physaria didymocarpa var. lanata Proposed Species of conservation concern: No

Known threats to species persistence: Threats include recreation, noxious weeds, and management activities. Populations of this species often overlap with project area and areas at risk of impact from project activities and recreation. These threats have the potential to affect individuals and entire populations. Much of this species’ suitable habitat occurs on BLM and private lands.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Vegetation, Soil, and Livestock Grazing plan components protect the native species composition of the grassland habitat guild of this species but do not prevent project level disturbance in this habitat guild. The grassland habitat guild typically experiences a high level of project activity including but not limited to prescribed burns, vegetation treatments, grazing allotments, and both motorized and non motorized recreation. The high level of forest project activity and the lack of plan components specific to this species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest-wide plan components, though this species seems tolerant of disturbance.

Rationale for woolly twinpod: This species has a global rank of G5T2, and a state rank of S2S3. There are four known occurrences in the Plan Area, but there are large areas of unsurveyed suitable habitat in the Plan Area. This species grows on sandy, often calcareous soil of open grassland or shrubland slopes in the plains. There are only a few known occurrences in Montana, including two potentially large populations; however, lots of unsurveyed potential habitat exists statewide (Taylor and Caners 2002). There is incomplete data on woolly twinpod’s true extent. It is likely that focused surveys would reveal additional populations. This species has forest activities present at known locations but there is insufficient evidence that these threats could lead to a loss of viability in the Plan Area.

Physaria saximontana var. dentata Proposed Species of conservation concern: No

Known threats to species persistence: Threats include recreation, noxious weeds, and management activities. Populations of this species often occur in rocky habitats that are infrequently accessed by the public or overlap with project activities. There is some risk of overlap with forest project activities, but generally there are few activities occurring in this species’ habitat.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Vegetation, Soil, and Livestock Grazing plan components protect the native species composition of the mesic-montane-disturbance-talus habitat guild of this species. The limestone-derived talus, fellfields, and gravelly slopes at moderate to high elevations are within the mesic-montane-disturbance-talus guild that typically experiences a high level of project activity including but not limited to prescribed burns, vegetation treatments, grazing allotments, and both motorized and non motorized recreation. Since this species’ range reaches into higher elevation, much of its habitat does not overlap with the threats typical to this habitat guild. The lack of plan components specific to this species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest-wide plan components.

Rationale for mountain twinpod: This species has a global rank of G3T3, and a state rank of S3. It is a Montana endemic with occurrences scattered across several counties in the central and western parts of the state.There are twelve known occurrences in the Plan Area, but there are large areas of unsurveyed suitable habitat. This species grows on limestone-derived talus, fellfields, and gravelly slopes at moderate to high elevations with minimal threats present (Mincemoyer 2005). It is likely that focused surveys would reveal additional populations. There is insufficient information on this species in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area.

Physaria klausii Proposed Species of conservation concern: No

Known threats to species persistence: Threats include recreation, noxious weeds, livestock grazing, and management activities. Populations of this species often occur in rocky habitats that are infrequently accessed by the public or overlap with project activities, though there is some risk of overlap with forest project activities.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Vegetation, Soil, and Livestock Grazing plan components protect the native species composition of the grassland habitat guild of this species but do not prevent project level disturbance in this habitat guild. The grassland habitat guild typically experiences a high level of project activity including but not limited to prescribed burns, vegetation treatment, grazing allotments, and both motorized and non motorized recreation. The high level of forest project activity and the lack of plan components specific to this species’ habitat increases the threats for the species in this

42 habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest-wide plan components, though this species seems tolerant of disturbance.

Rationale for divide bladderpod: This species has a global rank of G3, and a state rank of S3. It grows on open shale slopes and gravelly areas, typically in bunchgrass communities in the montane to subalpine zone. It is a state endemic restricted to central-Montana with the majority of populations occurring in the Big Belt Mountains and extending north to the southern end of the Rocky Mountain Front. Many large populations exist and the species typically occurs on gravelly slopes that are not usually subject to human disturbance. Even though the majority of this species’ range is in the Plan Area, there are minimal threats present at many of the populations (Shelly 1988c; Heidel and Cooper 1998). There is sufficient information on this species in the Plan Area to conclude that there is not a substantial concern for this species viability in the Plan Area.

Polygonum austiniae Proposed Species of conservation concern: Yes

Known threats to species persistence: This species is susceptible to weed invasion, noxious weed control, and ground disturbing project activity. Livestock trampling has been reported, but many known locations are too steep and rocky to be used by cattle. Some populations of Austin’s knotweed are generally not impacted by human activity due to the nature of the common location (sparsely-vegetated slopes with shale-derived soils, but many known occurrences are located along forest roads or are subject to other disturbance.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species and would as a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC-02, and FW- PRISK-GO-01) protect known populations and habitats of at-risk species. Various Vegetation, Soil, and Livestock Grazing plan components protect the native species composition of the mesic-montane- disturbance-talus habitat guild of this species. The gravelly, often shale-derived soil of open slopes and banks in the montane zone that support this species in the Plan Area are within the mesic-montane- disturbance-talus guild that typically experiences a high level of project activity including but not limited to prescribed burns, vegetation treatments, grazing allotments, and both motorized and non motorized recreation. The high level of forest project activity and the lack of plan components specific to this species’ habitat increases the threats for the species in this habitat guild above the habitat guilds (peatlands, aquatic, wetland-riparian) that are more thoroughly covered by forest-wide plan components.

Rationale for Austin’s knotweed: This species has a global rank of G5T4, and a state rank of S3S4. Austin’s knotweed is sparsely known from the Rocky Mountain Front on the Helena-Lewis and Clark to the Madison and Gallatin Ranges. The species is known from 40 occurrences in Montana with population numbers ranging from as few as six to over 10,000 individuals. The probability of finding additional occurrences statewide appears to be good, but large areas of the Helena-Lewis and Clark have been surveyed and there are only limited areas with suitable habitat away from disturbance. Phenology and population numbers of annuals often fluctuate drastically from year to year following climatic cycles. Throughout its range, Austin’s knotweed is often associated with ponderosa pine and bluebunch (Pseudoroegneria spicatum) wheatgrass habitat types with little vegetative cover. In Montana, Austin’s

43 knotweed often grows in mountainous areas with soils derived from shale or in the shale itself, but is also found on limestone and mixed parent material. The shale substrates are mostly barren and are easily eroded, providing an early successional habitat in which some annuals are adapted. Populations are typically situated on south-facing slopes between 4300 and 8000 feet elevation, but can be found on all aspects in variety of habitats including wooded to open meadows with subalpine fir and lodgepole, logged lodgepole stands, and along streams (Barton and Crispin 2002; McNeill 2011; Poole and Heidel 1993).

This species is only found in limited areas of the Plan Area despite surveys and threats are present at the majority of occurrences. Habitat for this species is easily eroded and susceptible to damage. This species is recommended to be a SCC species.

Pinus albicaulis Proposed Species of conservation concern: No; this species is federally designated as a candidate species

Known threats to species persistence: This species is susceptible to blister rust, climate change, encroachment of other conifer species, fire exclusion, and bark beetles. It is in decline range wide.

Rationale for whitebark pine: This species is a candidate for federal listing, has a global rank of G3G4, and a state rank of S3. Whitebark pine is a common component of subalpine forests and a dominant species of treeline and krummholtz habitats. It occurs in almost all major mountain ranges of western and central Montana. Populations of whitebark pine in Montana and across most of western North America have been severely impacted by past mountain pine beetle outbreaks and by the introduced pathogen, white pine blister rust. The results of which have been major declines in whitebark pine populations across large areas of its range. Additionally, negative impacts associated with encroachment and increased competition from other trees, primarily subalpine fir, have occurred as a result of fire suppression in subalpine habitats (Keane et al 2012; Tomback, Arno and Keane 2001; USDI 2011; USDI 2015). This species is already listed as a candidate for federal listing and SCC designation is redundant and not required.

Pinus flexilis Proposed Species of conservation concern: No

Known threats to species persistence: This species is susceptible to blister rust, climate change, encroachment of other conifer species, fire exclusion, bark beetles.

44 composition in the Plan Area and the terrestrial vegetation report and Appendix C of the at-risk plants report specifically addresses limber pine in the Plan Area.

Rationale for limber pine: This species has a global rank of G4, and a state rank of S5. It is present throughout much of Montana excluding the northwestern and eastern counties, particularly east of the continental divide. Limber pine is present throughout the Plan Area and there is some evidence that limber pine is in decline (USDA 2003; Burns et al 2008; Means 2011; Tomback et al 2016), but more information is needed, which is reflected in the state ranking. This species is common in the Plan Area. It faces similar threats as whitebark pine, but there is less information available on species trend. There is insufficient information on this species in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area.

Potamogeton obtusifolius Proposed Species of conservation concern: Yes

Known threats to species persistence: This species is vulnerable to impacts associated with development, recreation, and increased sediment and nutrient loads. No condition or trend data is available for the pondweed population on the HLC NF, however, due to the occurrences’ adjacency to a heavily traveled highway, railroad track, and private land there is a potential that development could alter the hydrologic system. Blunt-leaf pondweed habitat is fragile and should be protected from pollution and other forms of disturbance.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species and would as a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC-02, and FW- PRISK-GO-01) protect known populations and habitats of at-risk species. Various Aquatic Ecosystems plan components protect the aquatic habitat guild of this species. Recreation, Livestock Grazing, Timber and Fire and Fuels plan components prevent damages from occurring during project activities to known populations and aquatic habitats, though some impacts may still occur. This species’ habitat often overlaps with areas protected by plan components, but habitat is not expected to always be within protected areas during project activities. This species is impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for blunt leaf pondweed: This species has a global rank of G5, a state rank of S3 and a C value of 8 (Table 3), which exhibits a moderate fidelity to a narrow range of ecological tolerance, typifies a stable or near climax community, and does not tolerate disturbance. In Montana, the species is recorded from 16 locations on various ownerships in Flathead, Glacier, Lake, and Missoula counties (Pip 1987). The Plan Area contains two pondweed occurrences east along Highway 2 at the very northern edge of the Rocky Mountain Ranger District.

There are significant threats to occurrences on and off the Plan Area from stressors including responses to management, low occurrences, and restricted habitat in the Plan Area. Habitat for this species is limited in the Plan Area and threats are present at many of the known occurrences for this species. This species is recommended to be a SCC species.

Potentilla nivea var. pentaphylla Proposed Species of conservation concern: No

Known threats to species persistence: Threats to five-leaf cinquefoil may include recreation and climate change, but most populations as well as the species’ habitat are not being negatively impacted. One occurrence is at the end of a non motorized trail, but impacts to this population have not been documented.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species but it would not as a Species of conservation concern. Various Vegetation, Soil, Designated Wilderness and Livestock Grazing plan components support native plant species in the Plan Area, but alpine habitat is only minimally protected by plan components. Alpine habitats are considered to have reduced threats to at-risk species due to inaccessibility, large percentage of available habitat overlaps with wilderness, and infrequent project activity, which mainly includes radio tower access and recreation. The effects of climate change are generally expected to have a larger impact on high elevation native habitats; however the precise effects of the greatest factors, precipitation and water availability, are mainly speculative at this time for the Plan Area.

Rationale for five-leaf cinquefoil: This species has a global rank of G5T4 and state rank of S3. This species is considered rare in Montana, but there are several large populations and much of this species’ habitat is not being negatively impacted by human activity. The probability of finding additional occurrences appears to be good since it has not been searched for extensively in suitable habitats in central and western Montana. This species grows in dry gravelly exposed soil of ridges and slopes in the montane to alpine zones. It is likely that there are additional populations of this species in the Plan Area that have not yet been documented, and most of the suitable habitat for this species is found in wilderness area or inaccessible alpine habitat, although some suitable habitat overlaps with project areas. There is insufficient information on this species’ range in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area.

Ranunculus pedatifidus Proposed Species of conservation concern: Yes

Known threats to species persistence: Threats include recreation, hydrologic changes, livestock grazing, noxious weeds and management activities. There are only two occurrences known in the Plan Area and these threats have the potential to affect individuals and entire populations.

46 impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for northern buttercup: This species has a global rank of G5, a state rank of S3, and a C value of 9 (Table 3) with a threat rank of 2 Table 4). This species occurs in moist meadows and open woodlands in the montane to alpine zone (Heidel 1994). This species has a high fidelity to a very narrow range of ecological tolerance that typifies a stable or near climax community and does not tolerate disturbance. Habitat for this species is limited in the Plan Area and threats are present at many of the known occurrences for this species. This species is recommended to be a SCC species.

Saussurea densa Proposed Species of conservation concern: No

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Vegetation, Soil, Designated Wilderness and Livestock Grazing plan components support native plant species in the Plan Area, but alpine habitat is only minimally protected by plan components. Alpine habitats are considered to have reduced threats to at-risk species due to inaccessibility, the large percentage of available that habitat overlaps with wilderness, and infrequent project activity, which mainly includes radio tower access and recreation. The effects of climate change are generally expected to have a larger impact on high elevation native habitats; however the precise effects of the greatest factors, precipitation and water availability, are mainly speculative at this time for the Plan Area.

Rationale for dwarf saw-wort: This species has a global rank of G4Q and a state rank of S2S3. It grows on calcareous soil of talus slopes and rocky, open slopes in the alpine zone. Dwarf saw-wort is only know from a handful of occurrences along the Rocky Mountain Front, but it’s primarily in wilderness areas (Schassberger 1988a). Much of this species habitat throughout its range is inaccessible, though there are several easily accessible populations on the HLC NF near trails. It is likely that there are additional populations of this species in the Plan Area that have not yet been documented. There is insufficient information on this species’ range in the Plan Area and to conclude that there is substantial concern for this species viability in the Plan Area.

Schoenoplectus subterminalis Proposed Species of conservation concern: Yes

Known threats to species persistence: Populations are potentially vulnerable to changes in water levels or increases in nutrient and sediment loads associated with development or timber harvest. Drainage of wetlands through beaver pond removal is one form of disturbance that threatens some populations.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species and would continue to as

47 a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC- 02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Aquatic Ecosystems plan components protect the aquatic habitat guild of this species. Recreation, Livestock Grazing, Timber and Fire and Fuels plan components prevent damages from occurring during project activities to known populations and aquatic habitats, though some impacts may still occur. This species habitat often overlaps with areas protected by plan components, but habitat is not expected to always be within protected areas during project activities. This species is impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for water bulrush: This species has a global rank of G5, and a state rank of S3. In addition it has a C value of 9 (Tble 3), which indicates a high fidelity to a very narrow range of ecological tolerance that typifies a stable or near climax community and does not tolerate disturbance. There are over a dozen known occurrences in western Montana, most of which are moderate to large-sized populations primarily on National Forest lands. Populations are potentially vulnerable to changes in water levels or increases in nutrient and sediment loads associated with development, agriculture or adjacent timber harvesting. There is only one occurrence known in the Plan Area. Water bulrush’s preferred habitat is shallow, open water or boggy margins of ponds, lakes, and sloughs less than 10 feet deep in valley, foothill, and montane zones. Habitat for this species is limited in the Plan Area and threats are present at many of the known occurrences for this species. This species is recommended to be a SCC species.

Scorpidium scorpioides Proposed Species of conservation concern: Yes

Known threats to species persistence: Threats include occurrence within livestock grazing allotment, noxious weeds, recreation, hydrologic changes to streamside and meadow habitats, and management activities.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently protects this species as a Regional Forester Sensitive species and would continue to as a Species of conservation concern. At-Risk Plants plan components (FW-PRISK-DC-01, FW-VEGT-DC- 02, and FW-PRISK-GO-01) protect known populations and habitats of at-risk species. Various Aquatic Ecosystems, Vegetation, and Soil plan components protect the peatland habitat guild of this species, including the ground water dependent ecosystems plan components. Recreation, Livestock Grazing, Timber and Fire and Fuels plan components prevent damages from occurring during project activities to known populations and peatland habitats, though some impacts may still occur. This species habitat often overlaps with areas protected by plan components, but small areas of habitat may not occur within protected areas during project activities. Unknown occurrences of scorpidium moss can be impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for scorpidium moss: This species has a global rank of G5, and a state rank of S2. This species grows on exposed or submerged rocks in rivers and streams, but it can also be found on wet soil in calcareous seeps and fens, and the soil of bogs, ponds, and other wetlands from low elevations to about 10,000 feet. There is only one occurrence in the Plan Area. Habitat for this species is limited in the Plan Area and threats are present at the single known occurrences for this species. There are low occurrence numbers in the Plan Area. This species is recommended to be a SCC species.

Solorina spongiosa Proposed Species of conservation concern: No

Known threats to species persistence: The threats to this species in the Plan Area are recreation and climate change. The only known occurrences of this species in the Plan Area occurs in the Gates of the Mountains wilderness in the Big Belts GA. There is some risk of overlap with forest project activities, but generally there are few activities occurring in this species’ habitat.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction does not currently protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Vegetation, Soil, Designated Wilderness and Livestock Grazing plan components support native plant species in the Plan Area, but alpine habitat is only minimally protected by plan components. Alpine habitats are considered to have reduced threats to at-risk species due to inaccessibility, large percentage of available habitat overlaps with wilderness, and infrequent project activity, which mainly includes radio tower access and recreation. The effects of climate change are generally expected to have a larger impact on high elevation native habitats; however the precise effects of the greatest factors, precipitation and water availability, are mainly speculative at this time for the Plan Area.

Rationale for fringed chocolate chip lichen: This species has a global rank of G4G5 and state rank of S1S2. It is known from only a few locations in western and central Montana. There is one occurrence in the Plan Area. This species grows in moist moss mats on soil adjacent to spring, seeps, waterfalls, and creeks in alpine/subalpine zones. The high elevation habitat reduces the potential for detrimental impacts because populations are generally in more remote locations and in habitats that typically are not subject to heavy human use. It is uncertain how extensive this species is in the Plan Area and more surveys are needed. Though there is limited information on this species distribution in the Plan Area, its habitat is generally found in wilderness areas that are not expected to be threatened.

Sphagnum fimbriatum Proposed Species of conservation concern: Yes

Known threats to species persistence: This species grows in sensitive peatland habitats and threats to habitat include recreation, changes in hydrologic conditions, grazing, noxious weeds, and management activities. This species is only documented at one location in the entire state on the HLC NF, though it is likely that additional undocumented populations exist in Montana. This occurrence is located on a large mine reclamation project, adjacent to a road, and approximately half of this population occurs on private land.

49 overlaps with areas protected by plan components, but small areas of habitat may not occur within protected areas during project activities. Unknown occurrences of fringed bogmoss can be impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for fringed bogmoss: This species has a global rank of G5, and a state rank of S1. The only currently know location for this species is on the Lincoln Ranger District and its habitat requirements are nutrient-rich wet soil and peat. It typically occurs at the edges of bogs and poor fens on mineral soil, somewhat exposed to wooded fens. Fringed bogmoss occurs at varying elevations.

Habitat for this species is limited in the Plan Area and threats are present at the single known occurrences for this species. There are low occurrence numbers in the Plan Area. Threats to this occurrence have the potential to affect individuals and entire populations. This species is recommended to be a SCC species.

Sphenopholis intermedia Proposed Species of conservation concern: No

Known threats to species persistence: Potential impacts include livestock grazing, noxious weed establishment, timber management, hydrologic changes and recreation uses. This species often occupies disturbance prone settings, and as such, it is vulnerable to activities such as weed invasion, weed spraying, road maintenance, and other ground disturbing activities.

Plan Components and Specific Requirements Addressed in New Plan: Forest Service Manual direction currently does not protect this species as a Regional Forester Sensitive species and would not as a Species of conservation concern. Various Aquatic Ecosystems, Vegetation, and Soil plan components protect the wetland-riparian habitat guild of this species. Recreation, Livestock Grazing, Timber and Fire and Fuels plan components prevent damages from occurring during project activities to known populations and wetland-riparian habitats, though some impacts may still occur. This species habitat often overlaps with areas protected by plan components, but habitat is not expected to always be within protected areas during project activities. Slender wedgegrass is impacted by other activities not covered by plan components, such as livestock trampling, recreationalists, climate change, and hydrologic changes.

Rationale for slender wedgegrass: This species has a global rank of G5 and state rank of S3S4. It occurs in various wet sites from low to moderate elevations, including roadsides and other disturbed habitats. There is only one known occurrence in the Plan Area, but it is likely that there are additional populations of this species in the Plan Area that have not yet been documented. There is insufficient information on this species in the Plan Area to conclude that there is substantial concern for this species viability in the Plan Area.

Stipa lettermanii Proposed Species of conservation concern: Yes

Known threats to species persistence: Threats include livestock grazing allotment, recreation impacts including a trail running through the single known occurrence, noxious weeds, weed treatment, persistent

50 nonnative grasses replacing natives (timothy, Kentucky bluegrass), and management activities. These threats have the potential to affect individuals and the entire population.

Rationale for Letterman’s needlegrass: This species has a global rank of G5, and a state rank of S1S3, indicating some uncertainty about this species state rank. This species is documented from several locations in the southern portion of the state. However, population levels, site characteristics and related information needed to determine the species' status are lacking. There is only one occurrence known in the Plan Area despite abundant information on species within grazing allotments.

Habitat for this species is limited in the Plan Area by nonnative grasses, such as timothy and Kentucky bluegrass and threats are present at the known occurrence for this species. This species is recommended to be a SCC species.

Literature used for All Species:

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Achuff, P., and Schassberger, L.A. 1991. Status review of Goodyera repens, USDA Forest Service, Region 1, Lewis and Clark National Forest. Unpublished report to the Lewis and Clark National Forest. Montana Natural Heritage Program, Helena, MT. 52 pp.

Bamberg, S. A., and J. Major. 1968. Ecology of the vegetation and soils associated with calcareous parent materials in three alpine regions of Montana. Ecological Monographs 38(2):127-167.

Barton, D., and Crispin, S. 2002. Sensitive plant species in weed management areas on the Helena National Forest. Unpublished report. Montana Natural Heritage Program. 17 pp.

Brunsfeld, S.J. and C.T. Baldwin. 1994. Preliminary genetic analysis of Cirsium longistylum (Long-styled thistle), a candidate threatened species. Unpublished report prepared for the U.S. Fish and Wildlife Service, Region 4. Wildland Plant Ecogenetics Cooperative, in cooperation with the Montana Natural Heritage Program, Helena. 20 pp. plus appendices.

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Heidel, B.L. 1993. Report on the conservation status of Erigeron lackschewitzii, a candidate threatened species. Unpublished report to U.S. Fish and Wildlife Service. Montana Natural Heritage Program, Helena, MT. 57 pp.

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Pavek, D.S. 1991. Update to the Report on the Conservation status of Grindelia howellii, a candidate threatened species. Unpuhl. Rep., USDI Fish and Wildlife Service, and Montana Natural Heritage Program, Helena. 66 pp.

Phillips, H.W. 1995. Conservation strategy for northern rattlesnake-plantain (Goodyera repens), Lewis and Clark National Forest. Unpublished report. Lewis and Clark National Forest. 6 pp plus maps.

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Schassberger, L.A.; and Achuff, P. 1991. Status review of Phlox kelseyi var. missoulensis. USDA Forest Service – Region 1, Lewis and Clark National Forest, Montana. Unpublished report for the Lewis and Clark National Forest. Montana Natural Heritage Program, Helena, MT. Order No. 40-03K0-0-0314.

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Appendix A. Species considered but are not known to occur on the Helena-Lewis and Clark National Forest

Plants Evaluated for Species of conservation concern - Is the species for the Helena-Lewis and known to Clark National Forest's Conservation occur in the Rationale for SCC Revised Forest Plan Categories Plan Area? Habitat Description Relevant Threats in the Plan Area Determination Shallow, seasonally Noxious weeds, livestock grazing, moist soils in the project activities, and recreation are Not known to occur in the Plan Allium fibrillum none NO montane zone potential threats Area. Vernally moist, alkaline No known extant populations in soil around ponds and Plan Area; insufficient Historical along streams in the Noxious weeds, livestock grazing, information to conclude that occurrence valleys. project activities, and recreation are significant threats are present in Atriplex truncata SOC only potential threats potential habitats in Plan Area Insufficient information to conclude that significant threats Timber management, livestock are present or that species grazing, recreation, climate change, occurs in the Plan Area; Wet, organic soil of noxious weeds, and noxious weed insufficient information to Betula pumila var. swamps, fens; valleys herbicide treatment are potential determine species' range in the glandulifera none NO to lower montane threats Plan Area Various mesic sites NO; one from low to moderate historical elevations, including Grazing, recreation, noxious weeds, occurrence roadsides and other and hydrologic changes are potential No extant occurrence known Botrychium ascendens SOC, G3 from 1948 disturbed habitats. threats within Plan Area. Various mesic sites from low to moderate Grazing, recreation, noxious weeds, elevations, including noxious weed treatment, hydrologic roadsides and other changes, and timber harvest are Not known to occur in the Plan Botrychium campestre SOC, S1S2 NO disturbed habitats. potential threats Area. Grazing, recreation, noxious weeds, noxious weed treatment, hydrologic Botrychium SOC, G1G2, changes, and timber harvest are Not known to occur in the Plan gallicomontanum S1S2 NO Fescue grasslands. potential threats Area. Various dry to mesic sites from valley bottoms to the Grazing, recreation, noxious weeds, subalpine, including noxious weed treatment, hydrologic roadsides and other changes, and timber harvest are Not known to occur in the Plan Botrychium hesperium RFSS, SOC NO disturbed habitats potential threats Area. A variety of habitats, including mid-height grasslands, grazed rangelands, a limestone shelf on a steep slope, a Grazing, recreation, noxious weeds, woodland trail, noxious weed treatment, hydrologic SOC, G2?, roadside gravels and in changes, and timber harvest are Not known to occur in the Plan Botrychium lineare S1S2 NO grass under conifers. potential threats Area. Various mesic habitat, including mesic grasslands and Grazing, recreation, noxious weeds, meadows, roadsides noxious weed treatment, hydrologic SOC, RFSS, and moist forest changes, and timber harvest are Not known to occur in the Plan Botrychium michiganense G3, S2 NO bottoms. potential threats Area. A broad variety of habitats including grasslands, old growth and second growth deciduous and Grazing, recreation, noxious weeds, coniferous forests, and noxious weed treatment, hydrologic Not known to occur in the Plan Botrychium minganense None NO riparian zones. changes, and timber harvest Area. Various mesic sites from valley bottoms to SOC, G2G3, the montane zone. The Grazing, recreation, noxious weeds, S2, RFSS, most common habitats noxious weed treatment, hydrologic Adjacent are western redcedar changes, and timber harvest are Not known to occur in the Plan Botrychium pedunculosum SCC NO bottomlands. potential threats Area. Meadows and open forests, often in areas of moderate disturbance Grazing, recreation, noxious weeds, or sparsely vegetated noxious weed treatment, hydrologic soil in the valley and changes, and timber harvest are Not known to occur in the Plan Botrychium spathulatum SOC, G3, S1 NO montane zones. potential threats Area. Grazing, recreation, noxious weeds, Sparsely vegetated noxious weed treatment, hydrologic erosional slopes and changes, and timber harvest are Not known to occur in the Plan Botrychium tunux SOC, G3?, S1 NO rocky stream terraces. potential threats Area. Grazing, recreation, noxious weeds, noxious weed treatment, hydrologic SOC, G3G4, Various open, mesic changes, and timber harvest are Not known to occur in the Plan Botrychium yaaxudakeit S1 NO habitats potential threats Area.

Shallow water of lakes, sloughs, and slow- SOC, RFSS, moving rivers in the hydrological changes, grazing, and Not known to occur in the Plan Brasenia schreberi S1S2 NO valley zone. project activities are potential threats Area. Grows on rock outcrops, talus and scree, and on dry, recreation, noxious weeds, noxious sparsely-vegetated, weed treatment, and project activities Not known to occur in the Plan Brickellia oblongifolia SOC, S1S2 NO southerly slopes. are potential threats Area. Dry meadows and grasslands in the recreation, noxious weeds, noxious foothills or montane weed treatment, and project activities Not known to occur in the Plan Calochortus bruneaunis SOC, S1S3 NO zones. are potential threats Area. NO; within 600 meters of Wet, organic soil of RFSS, SOC, the National fens in the montane recreation, hydrologic changes, Adjacent Forest zone. livestock grazing, and noxious weeds Not known to occur in the Plan Carex chordorrhiza SCC boundary are potential threats Area. Crawe's sedge grows in wet, gravelly or sandy soil along streams or pond margins, often where there is some natural wave or flow Livestock grazing, hydrologic disturbance. It occurs in changes, recreation, noxious weeds, the valleys and and weed treatments (herbicide) are montane foothills, potential threats. The viability of the especially where the species or a portion of the species dominant parent habitat in the state is threatened by Not known to occur in the Plan Carex crawei SOC, S2S3 NO material is calcareous. one or more activities. Area. SOC, S1S2, Grazing, recreation, noxious weeds, RFSS, noxious weed treatment, hydrologic Adjacent changes, and timber harvest are Not known to occur in the Plan Carex lacustris SCC NO Marshes and fens potential threats Area. Shallow, wet, stony soil around streams in the Recreation and climate change are Not known to occur in the Plan Carex plectocarpa SOC, G3 NO alpine zone. potential threats Area. Rich fens with alluvium Grazing, recreation, noxious weeds, derived from noxious weed treatment, hydrologic calcareous glacial till in changes, and timber harvest are Not known to occur in the Plan Carex prairea SOC, RFSS NO the valley zone. potential threats Area. Grazing, recreation, noxious weeds, Moist alkaline noxious weed treatment, hydrologic meadows in the valley changes, and timber harvest are Not known to occur in the Plan Castilleja exilis SOC, S2 NO zone potential threats Area. Alpine tundra and Recreation and climate change are Not known to occur in the Plan Castilleja nivea SOC, G3 NO fellfields. potential threats. Area. Grazing, recreation, noxious weeds, Circumboreal species noxious weed treatment, hydrologic restricted to rich, changes, and timber harvest are Not known to occur in the Plan Catoscopium nigritum SOC, S1 NO calcareous fens. potential threats Area. Grows in extremely loose, sandy soils and tends to occupy early successional, sparsely vegetated habitats. The unconsolidated sandy substrate is nutrient poor and droughty. In Montana, it inhabits Grazing, recreation, noxious weeds, sand dunes and river noxious weed treatment, and SOC, G3G4, sandbars or sandy hydrologic changes are potential Not known to occur in the Plan Chenopodium subglabrum S2 NO terraces. threats Area. Grazing, recreation, noxious weeds, Restricted to rich, noxious weed treatment, hydrologic calcareous fens and changes, and timber harvest are Not known to occur in the Plan Cinclidium stygium SOC, S1 NO seeps potential threats Area. Habitat: Moist riparian forests, often in narrow sheltered valleys. SOC, G3, S1, Substate: Trunk (bark) RFSS, of Populus trichocarpa; Adjacent occasionally on conifer recreation, hydrologic changes, and Not known to occur in the Plan Collema curtisporum SCC NO twigs. timber harvest are potential threats Area. Dry grasslands and rocky, open slopes Grazing, recreation, noxious weeds, from the valley to and noxious weed treatment are Not known to occur in the Plan Collomia tinctoria None NO montane zones. potential threats Area. Montane; rocky, disturbed or eroding SOC, RFSS, soil of steep slopes in Grazing, recreation, noxious weeds, S2, Adjacent open forest, often noxious weed treatment, and timber Not known to occur in the Plan Corydalis sempervirens SCC NO appearing after fire harvest are potential threats Area.

Insufficient information on Open soil of sagebrush Grazing, recreation, noxious weeds, species' range in Montana. Not steppe and woodlands noxious weed treatment, and timber known to occur in the Plan Cryptantha humilis SOC NO in the valleys. harvest are potential threats Area. Montana occurrences are mostly in warm, dry mid-seral montane forest in the Douglas fir/ninebark and grand fir/ninebark habitat SOC, RFSS, types. Elsewhere in its Potential habitat not expected in Adjacent range, it is in western the Plan Area; not known to Cypripedium fasciculatum SCC NO redcedar habitat types. Timber harvest is a potential threat occur in the Plan Area. Moist meadows in the valley and lower montane zone. Usually where soils are saturated in spring, Grazing and hydrologic changes are Not known to occur in the Plan Delphinium burkei SOC, S1S2 NO desiccated in summer. potential threats Area. Grazing, recreation, noxious weeds, Meadows, grasslands, noxious weed treatment, and steppe; montane to near hydrologic changes are potential Not known to occur in the Plan Delphinium glaucescens G3G4 NO treeline threats Area. Sandy pinelands, near the border between Grazing, noxious weeds, noxious Dichanthelium oligosanthes woodland and weed treatment, and timber harvest Not known to occur in the Plan var. scribnerianum SOC, S1S2 NO grassland are potential threats Area. Wet rock ledges and Recreation,climate change, and SOC, G3G4, moist tundra in the hydrologic changes are potential Not known to occur in the Plan Draba macounii S2S3 NO alpine zone. threats Area. Moist to wet, often organic soils at the SOC, RFSS, forest margins of fens Adjacent and swamps in the Grazing, hydrologic changes, and Not known to occur in the Plan Dryopteris cristata SCC NO montane zone. timber harvest are potential threats Area. Dry, often rocky soil from the foothills up to moderate elevations, frequently with sagebrush (Heidel and Cooper 1998). Dominant species in its habitat include bluebunch wheatgrass and mountain big sagebrush (Artemisia tridentata ssp. vaseyana). Associated species and habitats vary widely. In the Scratchgravel Hills near Helena, it occupies two distinct habitats - one a midslope opening on a steep east-facing timbered hillside, and the other a gently southwest-facing lower Grazing, recreation, noxious weeds, slope in open rolling noxious weed treatment, and timber Not known to occur in the Plan Erigeron linearis SOC, S2 NO plains. harvest are potential threats Area. Occurs on skeletal, limestone-derived soils of ridge crests, slopes and outcrops at 4,500- 7,000 feet. Associated vegetation is sparse and dominated by cushion plants, other low forbs and bluebunch wheatgrass. Dominant vegetation in nearby areas with more developed soils is sagebrush steppe or juniper woodland. Grazing, recreation, noxious weeds, SOC, G2G3, Endemic to southwest and noxious weed treatment are Not known to occur in the Plan Erigeron parryi S2S3 NO Montana. potential threats Area. Dry, stony limestone Grazing, recreation, noxious weeds, areas in sagebrush and noxious weed treatment are Not known to occur in the Plan Eriogonum caespitosum SOC, S2S3 NO steppe potential threats Area. Grazing, recreation, noxious weeds, SOC, RFSS, Wet, organic soil of noxious weed treatment, hydrologic Adjacent fens from low to changes, and timber harvest are Not known to occur in the Plan Eriophorum gracile SCC NO moderate elevations. potential threats Area.

Wet, organic soil of (often calcareous) fens Eriophorum in the valleys and Common species, no significant Common species, no significant viridicarinatum None NO montane zone threats known threats known Open soil in grasslands, meadows, and tundra in Grazing, recreation, and climate Not known to occur in the Plan Euphrasia subarctica SOC, S2 NO the alpine zone. change are potential threats Area. A pioneer species occurring in open habitats such as among widely-spaced clumps of grass and disturbed sites, damp soil, humus; Grazing, recreation, noxious weeds, Insufficient information on calciphilic; occurring at noxious weed treatment, and species' status in Montana. Not medium elevations or hydrologic changes are potential known to occur in the Plan Funaria americana G3? NO lower threats Area. Recreation, climate change, and Wet, boggy tundra in hydrologic changes are potential Not known to occur in the Plan Gentiana glauca SOC, S2S3 NO the alpine zone. threats Area. Drying mud around Grazing, recreation, noxious weeds, Not known to occur in the Plan ponds and lakes in the noxious weed treatment, and Area. Found directly adjacent to foothills and on the hydrologic changes are potential Plan Area along Rocky Gratiola ebracteata SOC, S2 NO plains. threats Mountain Front. Vertical faces of shaded, calcareous cliffs. Moderate elevations (1,640 – 2,300 feet). It grows in warm, dry but climatically moist SOC, RFSS, valley bottoms or G2, S2, piedmont forests Adjacent dominated by Douglas- Cliff habitat generally not susceptible Not known to occur in the Plan Grimmia brittoniae SCC NO fir. to threats Area. Wet, acidic rocks in alpine to boreal habitats. Moderate to high elevations (3,280 – 13,450 feet). This is an arctic-alpine species and often grows near glacial streams. Species is widespread, but Recreation and climate change are Not known to occur in the Plan Grimmia mollis G3G5 NO never commonly found. potential threats Area. Gravels bars, moist Grazing, recreation, noxious weeds, meadows of aspen noxious weed treatment, hydrologic parkland; plains, changes, and timber harvest are Not known to occur in the Plan Hedysarum alpinum None NO valleys, montane potential threats Area. Vernally moist grassland slopes, mossy ledges, and riparian Grazing, recreation, noxious weeds, swales in valley, noxious weed treatment, hydrologic RFSS, SOC, foothills and montane changes, and timber harvest are Not known to occur in the Plan Heterocodon rariflorum S2 NO zones. potential threats Area. Vernally moist, alkaline Grazing, recreation, noxious weeds, soil of sagebrush steppe noxious weed treatment, and in the valley to lower hydrologic changes are potential Not known to occur in the Plan Hornungia procumbens SOC, S2 NO montane zones. threats Area. SOC, S1S2, Vernally moist, open RFSS, soil on rock ledges in Noxious weeds, noxious weed Potential habitat not expected in Adjacent the lower montane treatment, hydrologic changes, and the Plan Area; not known to Idahoa scapigera SCC NO zone. timber harvest are potential threats occur in the Plan Area. Wet soil on the margins of ponds and marshes Grazing, noxious weeds, noxious in the valley zone and weed treatment, and hydrologic Not known to occur in the Plan Juncus acuminatus SOC, S1 NO on the plains. changes are potential threats Area. Wet, organic soils and Juncus triglumis var. moist, well-developed Recreation and climate change are Not known to occur in the Plan albescens SOC NO turf in the alpine zone. potential threats Area. Montane fens to moist tundra in the alpine Recreation and climate change are Not known to occur in the Plan Kobresia simpliciuscula SOC NO zone. potential threats Area. SOC, S2, Wet, organic soils of RFSS, calcareous fens in the Adjacent valley and montane Grazing, hydrologic changes, and Not known to occur in the Plan Liparis loeselii SCC NO zones. timber harvest are potential threats Area. Grows in seepy, marshy places along cold-air drainages, Common species, no significant Common species, no significant Listera borealis None NO often where calcareous threats known threats known SOC, S2, Wet, organic soil of Grazing, noxious weeds, noxious RFSS, nutrient-poor fens in weed treatment, hydrologic changes, Adjacent the valley and lower and timber harvest are potential Not known to occur in the Plan Lycopodiella inundata SCC NO montane zones. threats Area.

Turf along drainages SOC, RFSS, and moist slopes in Recreation and climate change are Not known to occur in the Plan Lycopodium lagopus S2 NO alpine zone. potential threats Area. Wet soil and peat in Grazing, noxious weeds, noxious SOC, RFSS, fens and bogs (Elliott weed treatment, hydrologic changes, S2, Adjacent 2016), soil in wet and timber harvest are potential Not known to occur in the Plan Meesia triquetra SCC NO woods. threats Area. Soil and humus at high elevations. Also on banks, thin soil over boulders in open woods, and moist shaded cliffs. Occurs Grazing, recreation, hydrologic from 3200 to 10,800 changes, and timber harvest are Not known to occur in the Plan Meiotrichum lyallii SOC, S1 NO feet potential threats Area. Vernally moist, open soil in meadows and on rock ledges in the Recreation, climate change and SOC, G2G3, subalpine and alpine hydrologic changes are potential Not known to occur in the Plan Micranthes tempestiva S2S3, RFSS NO zones. threats Area. Open seeps and vernally moist soil along slopes, cliffs and Grazing, recreation, noxious weeds, streams from the noxious weed treatment, hydrologic SOC, G3, valleys to the subalpine changes, and timber harvest are Not known to occur in the Plan Mimulus ampliatus RFSS NO zone. potential threats Area. Shallow, vernally moist SOC, S1S2, soil among rock Grazing, recreation, noxious weeds, RFSS, outcrops in coniferous noxious weed treatment, hydrologic Adjacent forests or grasslands in changes, and timber harvest are Not known to occur in the Plan Mimulus breviflorus SCC NO the montane zone. potential threats Area. Grazing, recreation, noxious weeds, noxious weed treatment, hydrologic Vernally moist cliffs, changes, and timber harvest are Not known to occur in the Plan Mimulus floribundus SOC NO streambanks; valleys potential threats Area. SOC, G2, Cool, moist cliffs; Climate change and hydrologic Not known to occur in the Plan Mimulus hymenophyllus S1S2 NO montane changes are potential threats Area. Vernally moist soil of Grazing, recreation, noxious weeds, grasslands and rocky noxious weed treatment, and slopes in the foothills hydrologic changes are potential Not known to occur in the Plan Mimulus suksdorfii None NO and montane zones. threats Area. Wet meadows, margins Grazing, recreation, noxious weeds, of fens, and gravelly noxious weed treatment, hydrologic moist soil in the valley changes, and timber harvest are Not known to occur in the Plan Ophioglossum pusillum SOC, RFSS NO and montane zones. potential threats Area. Grazing, recreation, noxious weeds, Oxytropis lagopus var. Sagebrush plains to noxious weed treatment, and timber Not known to occur in the Plan conjugans None NO lower mountains harvest are potential threats Area. Open, rocky slopes Papaver radicatum ssp. SOC, T3T4, with delayed snowmelt Recreation and climate change are Not known to occur in the Plan kluanensis S2S3 NO in the alpine zone. potential threats Area. Aquatic, in mountain streams and springs, especially those without marked seasonal fluctuations. Grows on rock and Hydrological changes and climate Not known to occur in the Plan Peltigera hydrothyria SOC, S1 NO gravel, rarely on wood. change are potential threats Area. Insufficient information on species' status in the Plan Area. Open or wooded, often Occurrence in Plan Area is rocky slopes well up in unverified and well outside Penstemon flavescens SOC, G3 Unverified the mountains. unknown expected range. Swamps, fen margins, SOC, S2, and riparian seeps Grazing, recreation, noxious weeds, RFSS, within open forest and noxious weed treatment, hydrologic Petasites frigidus var. Adjacent meadows in the valley changes, and timber harvest are Not known to occur in the Plan frigidus SCC NO and foothill zones. potential threats Area. Cliff crevices and talus Recreation, hydrologic changes, slopes in montane to noxious weeds, and climate change Not known to occur in the Plan Polystichum kruckebergii SOC, S2S3 NO alpine zones. are potential threats Area. Grazing, noxious weeds, noxious Streambanks and moist weed treatment, hydrologic changes, meadows in the and timber harvest are potential Not known to occur in the Plan Ranunculus orthorhynchus SOC, S1S2 NO montane zone threats Area. Moist, shaded cliffs in Recreation and climate change are Not known to occur in the Plan Sagina nivalis SOC, S2S3 NO the alpine zone. potential threats Area. SOC, S2, Cold, moist soil in the Recreation and climate change are Not known to occur in the Plan Salix barrattiana RFSS NO alpine zone. potential threats Area. Moist cliffs, talus slopes, and tundra in the upper subalpine and Recreation and climate change are Not known to occur in the Plan Salix cascadensis SOC, S2 NO alpine zones. potential threats Area.

Grazing, noxious weeds, noxious Fens and swamps in the weed treatment, hydrologic changes, Insufficient information valley and foothill and timber harvest are potential available to determine status Salix serissima SOC NO zones. threats and threats in the Plan Area. Wet, mossy soil of seep areas and moss-covered soil of meadows and rock outcrops in the montane and subalpine Climate change and hydrologic Not known to occur in the Plan Selaginella selaginoides SOC, S2S3 NO zones. changes are potential threats Area. Moist streambanks and Grazing, noxious weeds, noxious riparian forests in the weed treatment, hydrologic changes, valley and montane and timber harvest are potential Not known to occur in the Plan Senecio eremophilus SOC, S1S2 NO zones. threats Area. Grasslands in the valley Grazing, noxious weeds, and noxious Not known to occur in the Plan Sidalcea oregana SOC, S2S3 NO and montane zones. weed treatment are potential threats Area. On calcareous soil or humus on moist sites in SOC, G3G5, alpine to subalpine Climate change and hydrologic Not known to occur in the Plan Solorina bispora S1S2 NO habitats. changes are potential threats Area. Found on top of older, less saturated hummocks, on wet soil and peat, often in rain- fed mires and high mountain tops (developing mounds several feet tall), less often in slightly minerotrophic muddy Grazing and hydrologic changes are Not known to occur in the Plan Sphagnum fuscum SOC, S2 NO ground and richer fens potential threats Area. From low- to high- nutrient fens and peatlands, frequently in areas of higher acidity (in older and drier edges and on tops of hillocks), seeping SOC, S1, mountain inclines, Adjacent pocosins. Elevations: Grazing and hydrologic changes are Not known to occur in the Plan Sphagnum magellanicum SCC NO low to high potential threats Area. Alkaline wetlands, swales and old, meander channels often on the edge of the wetland or in areas that are dry by mid- summer. Habitat is limited to areas within major river drainages. In areas that are ungrazed, Spiranthes may occur among taller, relatively dense Federally herbaceous vegetation Not known to occur in the Plan listed as making detection Grazing and hydrologic changes are Area; already Federally listed as Spiranthes diluvialis Threatened NO difficult. potential threats Threatened. Humus and carnivore dung, skeletons, including those in owl pellets; dry habitats of Not known to occur in the Plan Tetraplodon angustatus None NO the north, montane unknown Area. Caribou antlers, carnivore scat, skeletons, including those in owl pellets; boreal, high altitude, Not known to occur in the Plan Tetraplodon mnioides None NO and arctic habitats unknown Area. Alpine meadowrue typically grows in moist montane and lower subalpine areas. In southwestern Montana, it occurs in moist alkaline meadows dominated by Potentilla fruticosa (shrubby cinquefoil) and Juncus balticus (Baltic rush), sometimes along stream channels. RFSS, S2, Frequent associates Grazing and hydrologic changes are Not known to occur in the Plan Thalictrum alpinum SOC NO include Deschampsia potential threats Area.

cespitosa, Dodecatheon pulchellum, Salix brachycarpa, Arctostaphylos uva- ursi, and Muhlenbergia richardsonis. The substrate varies from peat to marl, calcareous silt, silty clay or clay loam, often on limestone parent material. Moist tundra in the Recreation and climate change are Not known to occur in the Plan Tofieldia pusilla SOC, S2 NO alpine zone. potential threats Area. The species inhabits open, rocky, often limestone-derived soil of exposed ridges and slopes near or above treeline. In Glacier National Park, it grows on the shingle of exposed ridges and slopes; reported associates include Eriogonum androsaceum and Recreation and climate change are Not known to occur in the Plan Townsendia condensata SOC, S1S3 NO Dryas octopetala. potential threats Area. Wet, cold organic soil of fens and slopes in the montane and Recreation and climate change are Not known to occur in the Plan Trichophorum alpinum SOC, S2 NO subalpine zones. potential threats Area. Wet meadows and SOC, RFSS, sphagnum-dominated S2, Adjacent fens in the montane to Recreation and climate change are Not known to occur in the Plan Trichophorum cespitosum SCC NO alpine zones. potential threats Area. Calcareous fens in the Grazing and hydrologic changes are Not known to occur in the Plan Trichophorum pumilum SOC NO foothills. potential threats Area. Shallow water of SOC, S2, peatlands in the valley Grazing and hydrologic changes are Not known to occur in the Plan Utricularia intermedia RFSS NO to montane zones. potential threats Area. Hydrologic changes are potential Not known to occur in the Plan Utricularia ochroleuca SOC, S1 NO Aquatic species threats Area. Wet meadows and streambanks in the SOC, S2, montane and subalpine Grazing and hydrologic changes are Not known to occur in the Plan Veratrum californicum RFSS NO zones. potential threats Area.