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Chapter 3 – Affected Environment and Environmental Consequences 232 Elk Rice Environmental Assessment PTES Plants Introduction Activities associated with timber harvesting, site preparation, fuels reduction, and prescribed burning have the potential to affect Proposed, Threatened, Endangered and Sensitive (PTES) plant populations. The purpose of this analysis is to: Determine if the alternatives would adversely affect any of the PTES plant species that have potential to occur in the analysis area, and if so, list mitigation measures; Insure that the alternatives do not contribute to the loss of viability of any sensitive plant species or cause a trend toward federal listing; Comply with USDA Forest Service Northern Region (R1) policy to insure that sensitive plant species receive full consideration in the decision-making process; and Comply with the Endangered Species Act (ESA). This analysis considers the short- and long-term management of the project area because management activities: may affect existing and potential habitat, may affect welfare of existing plants, have potential for human disturbance, and/or have potential cumulative effects. Proposed Activities Vegetation management, fuel management, road management and watershed improvement activities proposed for this project are depicted in Table 1 in Chapter 2. Vegetation management activities include commercial and precommercial thinning, improvement cuts and regeneration harvests. These activities result in ground disturbance and alterations in light, moisture, and nutrient availability as well as changes in symbiotic associates. These changes can positively or negatively affect rare plant species. Fuel treatment associated with timber harvest activities would occur and would include underburning, grapple piling, slashing, hand piling, lop and scatter. Natural fuels/ecosystem burning not associated with timber harvest is also proposed to benefit wildlife habitat. Road management activities are needed to implement the project (e.g. maintenance, reconditioning, and construction). Some roads in the project area that are not needed for project implementation would have restoration work conducted. This restoration road work would reduce sediment contribution to streams (accomplished through road maintenance or reconstruction) or make system roads hydrologically inert if they are no longer needed (decommissioning) or until needed for future use (storage). About 1 mile of road would be relocated out of a riparian area to reduce sedimentation. Comparisons of the activities for the alternatives can be found in Chapter 2. PTES plants are not directly related to the purpose and need or any scoping issues of the Elk Rice project. 2015 Forest Plan and Other Regulatory Framework Table 70 shows the documents that guide the analysis of Proposed, Threatened, Endangered and Sensitive species of plants.
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Chapter 3 – Affected Environment and Environmental Consequences

232 Elk Rice Environmental Assessment

PTES Plants

Introduction

Activities associated with timber harvesting, site preparation, fuels reduction, and prescribed burning

have the potential to affect Proposed, Threatened, Endangered and Sensitive (PTES) plant populations.

The purpose of this analysis is to:

Determine if the alternatives would adversely affect any of the PTES plant species that have

potential to occur in the analysis area, and if so, list mitigation measures;

Insure that the alternatives do not contribute to the loss of viability of any sensitive plant species

or cause a trend toward federal listing;

Comply with USDA Forest Service Northern Region (R1) policy to insure that sensitive plant

species receive full consideration in the decision-making process; and

Comply with the Endangered Species Act (ESA).

This analysis considers the short- and long-term management of the project area because

management activities:

◦ may affect existing and potential habitat,

◦ may affect welfare of existing plants,

◦ have potential for human disturbance, and/or

◦ have potential cumulative effects.

Proposed Activities

Vegetation management, fuel management, road management and watershed improvement activities

proposed for this project are depicted in Table 1 in Chapter 2. Vegetation management activities include

commercial and precommercial thinning, improvement cuts and regeneration harvests. These activities

result in ground disturbance and alterations in light, moisture, and nutrient availability as well as changes

in symbiotic associates. These changes can positively or negatively affect rare plant species.

Fuel treatment associated with timber harvest activities would occur and would include underburning,

grapple piling, slashing, hand piling, lop and scatter. Natural fuels/ecosystem burning not associated with

timber harvest is also proposed to benefit wildlife habitat.

Road management activities are needed to implement the project (e.g. maintenance, reconditioning, and

construction). Some roads in the project area that are not needed for project implementation would have

restoration work conducted. This restoration road work would reduce sediment contribution to streams

(accomplished through road maintenance or reconstruction) or make system roads hydrologically inert if

they are no longer needed (decommissioning) or until needed for future use (storage). About 1 mile of

road would be relocated out of a riparian area to reduce sedimentation.

Comparisons of the activities for the alternatives can be found in Chapter 2.

PTES plants are not directly related to the purpose and need or any scoping issues of the Elk Rice project.

2015 Forest Plan and Other Regulatory Framework

Table 70 shows the documents that guide the analysis of Proposed, Threatened, Endangered and Sensitive

species of plants.

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Chapter 3 – Affected Environment and Environmental Consequences

Elk Rice Environmental Assessment 233

Table 70. PTES Guiding Documents

Guiding Document Direction

1973 Endangered Species Act

Directs agencies to carry out specific actions for the

conservation of endangered and threatened species of

plants and animals.

2015 Forest Plan

The 2015 Forest Plan details the direction for

managing Forest land and resources on the Kootenai

National Forest.

1976 National Forest Management Act

Directs the Forest Service to “provide for diversity of

plant and animal communities based on the suitability

and capability of the specific land area in order to

meet overall multiple-use objectives”

2015 Forest Plan

Goals

GOAL-VEG-01. Plant communities are trending toward the desired conditions for composition,

structure, patterns, and processes. The ecological integrity of the communities is high and they exhibit

resistance and resiliency to natural and man-caused disturbances and stressors, including climate change.

Desired Conditions

FW-DC-VEG-09. Habitat for plant species listed under the Endangered Species Act (ESA) is maintained

or restored on NFS lands, thus contributing to species recovery or delisting. Ecological conditions and

processes that sustain the habitats currently or potentially occupied by sensitive plant species are retained

or restored. The geographic distributions of sensitive plant species in the Forest Plan area are maintained.

FW-DC-VEG-12. Peatlands support natural unique plant and animal communities and provide habitat for

rare plant and animal species. Peatland waterflows, water quality, water chemistry, soil organic substrate

and plant communities function under conditions characteristic of how they evolved. Upland areas

surrounding peatlands that have the most direct influence on peatland characteristics, and stream

segments that flow directly into peatlands, are managed to sustain the natural characteristics and diversity

of those peatlands.

Guidelines

FW-GDL-VEG-07. Evaluate proposed management activities and project areas for the presence of

occupied or suitable habitat for any plant species listed under the Endangered Species Act or on the

regional sensitive species list. If needed, based on pre-field review, conduct field surveys and provide

mitigation or protection to maintain occurrences or habitats that are important for species sustainability.

FW-GDL-VEG-09. Peatlands/bogs should be buffered by at least 660 feet from management activities

that may degrade this habitat.

Laws, Regulations, and Policy

The Endangered Species Act (ESA) of 1973 declares that all federal agencies “utilize their authorities in

furtherance of the purposes of this Act by carrying out programs for the conservation of endangered

species and threatened species listed pursuant to section 4 of this Act.” The ESA requires federal agencies

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Chapter 3 – Affected Environment and Environmental Consequences

234 Elk Rice Environmental Assessment

to ensure that any agency action (any action authorized, funded, or carried out by the agency) is not likely

to jeopardize the continued existence of any threatened, endangered, or proposed species. Agencies are

further required to develop and carry out conservation programs for these species.

The National Forest Management Act (NFMA) directs the Forest Service to “provide for diversity of

plant and animal communities based on the suitability and capability of the specific land area in order to

meet overall multiple-use objectives.”

Sensitive species are administratively designated by the Regional Forester (FSM 2670.5) and managed

under the authority of the NFMA. FSM 2670.5 Section 19 defines sensitive species as "those plant and

animal species identified by a Regional Forester for which population viability is a concern, as evidenced

by:

Significant current or predicted downward trends in population numbers or density.

Significant current or predicted downward trends in habitat capability that would reduce a

species' existing distribution.”

No proposed, threatened, or endangered plant species are known to occur on the Kootenai NF. Silene

spaldingii (Spalding’s catchfly) is known to occur on private land in the Tobacco Valley near USDA

Forest Service System lands. Spalding’s catchfly, a threatened plant species, is suspected for the Kootenai

NF. Note: “suspected” means that this species are believed to have potential to occur but, to date, have not

been found on the Kootenai NF. One candidate plant species Pinus albicaulis (whitebark pine) is known

to occur on the Kootenai NF.

Within the Elk Rice project area, one candidate species is known to occur, five sensitive species are

known to occur, and 4 additional sensitive species are believed to have moderate/high potential to occur.

These plant species, plus Silene spaldingii, are listed in the PTES Plant Species Biological Assessment.

Table 71 summarizes the biological assessment/evaluation for the plants considered in this analysis. The

effects analysis provided in this document meet the requirements for a biological evaluation as outlined in

FSM 2672.42. Silene spaldingii is included because it is a listed threatened species though there is no

suitable habitat for it in the Elk-Rice project area. There will be No Effect on Spalding’s Catchfly.

Table 71. PTES Plant Species Biological Evaluation Summary for the Elk Rice Project Area

Species Habitat Conclusion Justification

Threatened, and Candidate Species

Silene spaldingii (Spalding’s catchfly)

Palouse Prairie grassland No effect Habitat absent from activity areas

Pinus albicaulis (whitebark pine)

High elevation forest sites near

timberline

May impact

individuals*

Surveys have been completed, and the

project design would protect the known

individuals.

Affected area is a small amount of

marginal habitat.

Sensitive Species

Botrychium

crenulatum (wavy moonwort)

Riparian forests, open wet

meadows, and roadsides

May impact

individuals*

Proposed activity in suitable habitat is

limited to road relocation out of a

riparian area and stream restoration

work

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Chapter 3 – Affected Environment and Environmental Consequences

Elk Rice Environmental Assessment 235

Species Habitat Conclusion Justification

Botrychium

pedunculosum (stalked moonwort)

Old growth western redcedar in

floodplains and meadows

May impact

individuals*

Proposed activity in suitable habitat is

limited to road relocation out of a

riparian area and stream restoration

work. Both these activities would

improve suitable habitat for this species.

Carex amplifolia

(Big-leaf sedge)

Open areas of moist riparian

forests in valleys

No Impact Suitable habitat does not occur in areas

of proposed activity

Clarkia rhomboidea

(diamond clarkia)

Dry, open, Douglas-

fir/ponderosa pine forest slopes

May impact

individuals*

Surveys have been completed, and the

project design would protect the known

populations

Project activities would improve habitat

for this species

Collema curtisporum

(jelly lichen)

Moist riparian forest in narrow

sheltered valleys, generally on

cottonwood bark

May impact

individuals*

Proposed activity in suitable habitat is

limited to road relocation out of a

riparian area and stream restoration

work. Both these activities would

improve suitable habitat for this species.

Cypripedium

fasciculatum

(clustered ladyslipper)

Douglas-fir/ninebark, grand

fir/ninebark and western red

cedar habitat types

No Impact Surveys have been completed, and this

species is not known to occur within the

project area

Grimmia brittoniae

(mouse moss)

Verticle to overhanging

calcareous cliffs

No Impact No suitable habitat in proposed activity

areas

Heterocodon

rariflorum (western pearl-flower)

Road shoulders and trails in

moist habitat types, open soil

areas near talus slopes and

submaritime bedrock meadows

May impact

individuals*

Surveys have been completed, and the

project design would protect known

populations

Project activities would create suitable

habitat for this species

Mimulus ampliatus (stalk-leaved

monkeyflower)

Road shoulders, open soil areas

near talus slopes, vernally moist

submaritime bedrock meadows

No impact Surveys have been completed, and this

species is not known to occur within the

project area

Psilocarphus

brevissimus

(dwarf wooly heads)

Drying mud of ponds and other

vernally wet soil in valley

bottom

No impact Surveys have been completed and

species and suitable habitat are not

known to occur in areas or proposed

activities.

* May impact individuals or habitat but would not likely contribute to a trend towards federal listing or cause a loss of viability to

the population or species.

Ranks and Definitions used by the Natural Heritage Program

Table 72 below shows the PTES plant species known or suspected in the Elk Rice project area.

G1/S1 - At very high risk of extinction or extirpation in the state due to extremely limited and/or

rapidly declining population numbers, range, and/or habitat or extirpation in the state.

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Chapter 3 – Affected Environment and Environmental Consequences

236 Elk Rice Environmental Assessment

G2/S2 - At high risk of extinction or extirpation in the state due to very limited and/or declining

population numbers, range, and/or habitat or extirpation in the state.

G3/S3 - At risk of extinction or extirpation in the state due to limited and/or declining numbers,

range and/or habitat, even though it may be abundant in some areas.

G4/S4 - Apparently secure, though it may be quite rare in parts of its range, and/or suspected to

be declining.

G5/S5 - Common, widespread, and abundant (although it may be rare in parts of its range). Not

vulnerable in most of its range.

GX/SX - Presumed Extinct or Extirpated - Species is believed to be extinct throughout its range

or extirpated in Montana. Not located, despite intensive searches of historical sites, and other

appropriate habitat, and small likelihood that it will ever be rediscovered.

GH/SH - Historical, known only from records usually 40 or more years old; may be rediscovered.

GNR/SNR - Not Ranked as of yet.

GU/SU - Unrankable - Species currently unrankable due to lack of information or due to

substantially conflicting information about status or trends.

Table 72. PTES Plant Species Known or Suspected in the Elk Rice Project Area

PTES Plant Species Known or with High / Moderate Potential to Occur within the

Elk-Rice Project Area

Current Global and State Rankings (MTNHP Plant Field

Guide 2015)

Botrychium crenulatum (wavy moonwort) G4 – S3

Botrychium pedunculosum (stalked moonwort) G2/G3 – S2

Carex amplifolia (Big Leaf Sedge) G4 – S4

Clarkia rhomboidia G5 – S3

Collema curtisporum (lelly lichen) G3 – S1

Cypripedium fasciculatum (clustered ladyslipper) G4 – S3

Grimmia brittoniae (mouse moss) G2 – S2

Heterocodon rariflorum (western pearl-flower) G5 – S2

Mimulus ampliatus (stalk-leaved monkeyflower) G3 – S3

Pinus albicaulis (whitebark pine) G3/G4 – S3

Psilocarphus brevissimus (dwarf woolyheads) G4 – S2/S3

G#G# or S#S#: Indicates a range of uncertainty about the status of the species (example - G1G3 = Global Rank Ranges between

G1 and G3 inclusive)

?: Inexact Numeric Rank – denotes uncertainty

PTES plant habitat guilds present in the Elk Rice project area include:

Aquatic

Peatland/fen

Riparian forest

Moist forest

Dry forest

Moist/vernally moist meadow

Subalpine

Spruce forest

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Chapter 3 – Affected Environment and Environmental Consequences

Elk Rice Environmental Assessment 237

Calcareous cliff Valley bottom mudbeds

No aquatic, peatland/fen, calcareous cliff, spruce forest or valley bottom mudbed habitat guilds were

identified in areas with proposed activity. PTES plants associated with these guilds were not considered

further in this analysis. Only PTES plant species with a moderate to high probability of occurring in Elk

Rice project activity areas are discussed here. The determination of probability of occurrence was made

by the district botanist based on the presence of suitable habitat, distribution of known populations and

results of local surveys. Table 73 addresses those species with a moderate to high probability of occurring

in an area with proposed activity.

Resource Indicators and Measures

Table 73. Resource Indicators and Measures for Assessing Effects

Resource Element

(PTES plant species)

Resource Indicator Measure Source

Botrychium spp.

Riparian forest

Soil disturbance

Herbicide application

Non-native competition

Activity acres

Acres treated

Acres infested

2015 Forest Plan

GOAL-VEG-01

FW-DC-VEG-09

FW-GDL-VEG-07

Heterocodon rariflorum

Riparian forest/Moist forest

guilds (disturbed soil)

Canopy cover

Soil disturbance

Herbicide application

Non-native competition

Activity acres

Activity acres

Acres treated

Acres infested

2015 Forest Plan

GOAL-VEG-01

FW-DC-VEG-09

FW-GDL-VEG-07

Clarkia rhomboidea

Dry, open forest guild

Canopy cover

Soil disturbance

Herbicide application

Non-native competition

Activity acres

Activity acres

Acres treated

Acres infested

2015 Forest Plan

GOAL-VEG-01

FW-DC-VEG-09

FW-GDL-VEG-07

Collema curtisporum

Riparian forest guild, on mature

cottonwood trees

Canopy cover

Mature riparian

cottonwoods

Activity acres

Abundance

and

Distribution

2015 Forest Plan

GOAL-VEG-01

FW-DC-VEG-09

FW-GDL-VEG-07

Pinus albicaulis

Subalpine guild, early

successional establishment

Canopy cover Activity acres 2015 Forest Plan

GOAL-VEG-01

FW-DC-VEG-09

FW-GDL-VEG-07

Analysis Methods

The following steps were taken to complete this analysis for PTES plants:

Pre-field analysis included a review of known PTES plant locations (from district and Montana

Natural Heritage Program records) and suitable habitat data (i.e. landtype, soils, topography,

habitat type, existing vegetation, and land use history). Much of this data is available from maps

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Chapter 3 – Affected Environment and Environmental Consequences

238 Elk Rice Environmental Assessment

and stand exam records. Microsite data is not generally available from existing records and is best

identified by aerial imagery and site visits in high potential landtypes.

Field surveys were conducted for proposed harvest units, burns, and temporary roads, with

emphasis on areas with moderate to high potential to provide habitat for PTES plants. In general,

these areas included streams, wetlands, riparian zones, mesic coniferous forest with a component

of mature western redcedar, moist cliffs, talus slopes, and dry meadows. Unique landscape

features have more potential to provide habitat for rare plants than more common landscape

features. These areas were emphasized during surveys. Surveys were completed in the high

probability areas during the field season of 2015 and 2016 for the Elk Rice project, as well as for

past projects within this analysis area. No PTES plant species were found in any activity area. If

any PTES populations are found during the layout phase of the project, mitigation measures

would be applied to protect any new occurrences that may be found.

Analysis Area

The analysis area for PTES plants is the project area. The location of PTES plant populations outside the

project area does however influence the probability of occurrence within the project area and the survey

effort implemented.

Spatial and Temporal Context for Effect Analysis

Temporal

This analysis considered both immediate and long term effects of activities. Canopy removal, high

intensity burning and soil disturbance can have long lived effects through increased light exposure,

decreased humidity, changes in soil biota and organic matter, and the establishment of non-natives. Road

construction in particular can have very long lasting effects as it changes soil structure and drainage

patterns, can completely eliminate microsites and can be an ongoing entry point for invasive non-natives.

Some of these effects may benefit some PTES plant species while harming others.

Spatial

Spatial considerations for this analysis include the proximity of proposed activities to known PTES

populations and the area (acres) of activity proposed in potential suitable habitats.

Affected Environment/ Existing Condition

PETS Plant Species

One candidate plant species Pinus albicaulis (whitebark pine) is known to occur within the project area. It

is also included on the Northern Region (R1) Sensitive Plant List. Whitebark pine is known to occur in

the Ulm Peak RNA and along the ridgeline on the Idaho-Montana border. A small segment of this

population has also been found in harvest unit 64 and these individuals will be identified and protected

from damage. Incidental loss of trees during harvesting and slash reduction operations is still possible.

Habitat quality is expected to improve from the canopy reduction in this unit (Keane 2012). The Elk Rice

project may affect individual whitebark pine or habitat but would not likely contribute to a trend

towards federal listing or cause a loss of viability to the population or species.

Other sensitive species known to occur in the project area are Clarkia rhomboidea (diamond clarkia),

Collema curtisporum (jelly lichen), Grimmia brittoniae (mouse moss), Heterocodon rariflorum (western

pearl-flower), and Psilocarphus brevissimus (dwarf wooly heads). Five additional sensitive species are

believed to have a moderate to high potential for occurrence in the analysis area. These plant species are

listed in Table 72 in the Ranks and Definitions section.

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Chapter 3 – Affected Environment and Environmental Consequences

Elk Rice Environmental Assessment 239

Diamond clarkia is known to occur on the open forested slopes below units 42 and 42A but none was

found in the units. The proposed activity for these units (canopy reduction and burning) could be

beneficial to this early successional species (Vanderhorst, J. 1997). Incidental loss of individuals and the

spread of competing invasive species is also possible from the proposed activities. The Elk Rice project

may impact diamond clarkia individuals or habitat but would not likely contribute to a trend

towards federal listing or cause a loss of viability to the population or species.

The epiphytic jelly lichen is known to grow on cottonwoods along the East Fork Elk Creek. The

relocation of NFSR 2273 could disturb a small number of mature riparian cottonwoods and this may

impact individuals or habitat but would not likely contribute to a trend towards federal listing or

cause a loss of viability to the population or species.

A population of western pearl-flower was found on NFSR 2295A during 2016 surveys. Proposed

activities for this road are consistent with past maintenance activities which have allowed this species to

grow on the site. Locations of pearl-flower on this road would be marked and avoided by destructive

activities, particularly weed spraying. Western pearl-flower is well distributed on the Cabinet Ranger

District and this small population is not critical to its survival. Activities of the Elk-Rice may impact

individuals or habitat but would not likely contribute to a trend towards federal listing or cause a

loss of viability to the population or species.

Wavy moonwort (Botrychium crenulatum) and stalked moonwort (B. pedunculosum) are sensitive species

that are not known to occur in the Elk-Rice project area but have a moderate to high probability of

occurrence based on other local occurrences, suitable riparian habitat, and the presence of indicator

species (ie.other Botrychium species). Surveys for wavy and stalked moonworts will be completed when

the exact location of riparian activities is determined. Activities in the riparian zone (NFSR 2273

relocation and East Fork Elk restoration) could disturb existing plants should they exist undetected, or

alter the microsite they are growing in. The potential area of disturbance is small however. The proposed

Elk Rice project may impact individuals or habitat but would not likely contribute to a trend

towards federal listing or cause a loss of viability to the population or species.

Resource Indicators by Alternative

Table 74 displays the resource indicators for each alternative.

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240 Elk Rice Environmental Assessment

Table 74. Resource Indicators and Measures for the Alternatives

Resource Element (PTES plant species)

Resource Indicator

Measure Alt 1 (Existing Condition/No Action)

Alt 2 (Proposed Action) Alt 3

Riparian Species and Habitats

Botrychium spp.

Riparian forest

Soil disturbance Activity acres* 0 <1 acre in riparian <1 acre in riparian

Herbicide

application

Acres treated <1 acre in restoration sites <1 acres in restoration sites <1 acres in restoration sites

Non-native

competition

Acres infested No change (not quantified) Increase due to road

relocation and stream work

Increase due to road

relocation and stream work

Collema curtisporum

Riparian forest, on

mature cottonwood trees

Canopy cover Activity acres* 0 <1 acre in riparian <1 acre in riparian

Mature riparian

cottonwoods

Abundance and

Distribution

No change (not quantified) No change (not quantified) No change (not quantified)

Early Successional Species and Habitats

Clarkia rhomboidea

Dry, open forest guild

Canopy cover Activity acres* 0 318 acres 301 acres

Soil disturbance Activity acres* 0 318 acres 301 acres

Herbicide

application

Acres treated No change (open roads

sprayed)

No change (open roads

sprayed)

No change (open roads

sprayed)

Non-native

competition

Acres infested No change (not quantified) Increase due to 458 acres

tractor harvesting and 6.0

miles road construction

Increase due to 439 acres

tractor harvesting and 3.1

miles road construction

Heterocodon rariflorum

Riparian forest/Moist

forest guilds (disturbed

soil)

Canopy cover Activity acres* 0 1,517 acres 1,096 acres

Soil disturbance Activity acres* 0 1,517 acres 1,096 acres

Herbicide

application

Acres treated No change (open roads

sprayed)

No change (open roads

sprayed)

No change (open roads

sprayed)

Non-native

competition

Acres infested No change (not quantified) Increase due to 458 acres

tractor harvesting and 6.0

miles road construction

Increase due to 439 acres

tractor harvesting and 3.1

miles road construction

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Elk Rice Environmental Assessment 241

Resource Element (PTES plant species)

Resource Indicator

Measure Alt 1 (Existing Condition/No Action)

Alt 2 (Proposed Action) Alt 3

Subalpine Species and Habitats

Pinus albicaulis

Subalpine guild, early

successional

establishment

Canopy cover Activity acres* 0 322 acres 287 acres

Soil disturbance Activity acres* 0 322 acres 287 acres

*Activity acres in potential habitat based on Vegetative Response Unit (VRU)

< = less than

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Chapter 3 – Affected Environment and Environmental Consequences

242 Elk Rice Environmental Assessment

Canopy cover

Canopy cover affects the amount and intensity of sunlight that reaches the grass/forb layer. The forest

canopy also affects micro climate attributes including temperature and humidity. The reduction of canopy

cover is beneficial for some PTES plant species and harmful to others. Activity acres is a measure of the

amount of canopy affected by the alternatives.

Soil disturbance

Soil disturbance results from harvesting, road building, burning and stream channel improvement work.

As with canopy cover, soil disturbance is beneficial to some PTES plants and harmful to others. Exposed

mineral soil provides a needed seedbed for early successional species (e.g. diamond clarkia, western

pearl-flower) and damaging to other species that benefit from an intact litter and duff layers and later

successional soil biota.

Herbicide use

The effects of herbicide use on PTES plants is highly variable. In the Elk-Rice project, herbicides would

primarily be used along roads and would only have the potential to harm the plant species that would

grow there – western pearl-flower, moonworts, and to some degree diamond clarkia.

Non-native competition

Invasive weeds can out compete PTES plants for water, nutrients and sunlight and alter the soil chemistry

to suppress the natives. They have the potential to displace rare natives on large acreages, particularly on

dry sites but in riparian areas as well. The most vulnerable PTES plants in the Elk-Rice project area are

diamond clarkia, western pearl-flower, and the moonworts.

Monitoring

District personnel (botanist) is responsible for monitoring sensitive plant occurrences within the project

area during and after project implementation. Any newly discovered sensitive species individual or group

would be avoided or otherwise protected, as allowed by use of specific contract provisions.

Environmental Consequences

Alternative 1 – No Action

This alternative proposes no change in ongoing activities including weed spraying under the Forest-wide

Weed EIS, road maintenance, firewood gathering, hunting, fishing, etc. These ongoing activities could

potentially destroy individual or small groups of PTES plants.

Direct and Indirect Effects

Canopy cover

Riparian Species and Habitats

In the absence of wildfire or catastrophic flooding, natural forest succession would lead to increased

coverage of late succession conifers (cedar and western hemlock) in riparian habitats. This would have no

effect on moonwort species. Cottonwoods, an early successional species, would be crowded out by

conifers and this critical habitat component for jelly lichen would decline.

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Early Successional Species and Habitats

With continued fire suppression, the No Action Alternative would allow shrub and tree encroachment on

natural openings. Diamond clarkia and western pearl-flower are early successional, annual species and

require open habitats. In the absence of wildfire, the No Action Alternative would likely result in

continued degradation of habitats for these two species.

Ongoing weed spraying could damage populations of western pearl-flower.

Subalpine Species and Habitats

Whitebark pine is moderately shade tolerant but does not regenerate well under an existing closed canopy

(Keane 2012). Wildfire can and has provided suitable habitat for this species to regenerate in the project

area (Ulm Peak fire in 2006). Mountain pine beetle has and would continue to open the canopy where

lodgepole pine is a significant stand component. Ongoing fire suppression activity has and would

continue to encourage denser, later successional forest development in potential habitat. The No Action

Alternative would likely have no net effect on canopy densities in potential whitebark pine habitats of the

project area.

Soil disturbance

Riparian Species and Habitats

In the absence of wildfire or catastrophic flooding, there would be very little soil disturbance in riparian

habitats. This would have no effect on moonwort species. Cottonwoods, an early successional species,

would not have suitable disturbed habitat for establishment and this critical habitat component for jelly

lichen will likely decline (Hutchinson 1999).

Early Successional Species and Habitats

With continued fire suppression, the No Action Alternative will result in minimal exposed mineral soil

that is the seedbed for diamond clarkia (Vanderhorst, J. 1997) and western pearl-flower (personal

observation). In the absence of wildfire, the No Action Alternative would likely result in continued

degradation of habitats for these two species.

Subalpine Species and Habitats

Whitebark pine seed is disbursed primarily by Clark’s nutcrackers who cache the seed in suitable areas,

effectively planting the seeds (Keane 2012). Because of this, exposed mineral soil is not required for the

establishment of whitebark pine. The No Action Alternative’s lack of soil disturbance will not affect

whitebark pine.

Herbicide use

Under the No Action Alternative, weed spraying would continue on open roads. The indirect effect of this

activity is potentially slowing the spread of invasive species in PTES plant habitats. The direct effect of

this activity is the potential to destroy individual PTES plants that may be growing on the road or at its

edge.

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Non-native competition

Riparian Species and Habitats

Weeds, particularly reed canarygrass and Canada thistle, would continue to affect riparian habitats at

current or possibly increasing levels with the No Action Alternative.

Early Successional Species and Habitats

The No Action Alternative would result in continued weed encroachment on diamond clarkia and western

pearl-flower habitats at current rates resulting in continued degradation of habitats for these two species.

Subalpine Species and Habitats

Whitebark pine and its habitats are not as vulnerable to the negative effect of invasive weeds as lower

elevation habitats. The No Action Alternative would have no effect on whitebark pine through weed

establishment and spread.

Alternative 2 (Proposed Action) and Alternative 3

Project Design Features and Mitigation Measures

Riparian Species and Habitats

Many rare moonwort (Botrychium) species including wavy and stalked moonworts, occur in bottomland

habitats with a riparian influence (Vanderhorst, J.P. 1997, MNHP Rare Plant Guide). The jelly lichen

(Collema curtisporum) is also found exclusively in riparian areas (MNHP). All riparian areas associated

with streams and wetlands would be buffered (see Chapter 2 and the Hydrology section of Chapter 3),

avoiding potential impacts to riparian habitats that have potential for the occurrence of sensitive plant

species. Areas where activity would take place in the riparian zone will be surveyed for these species prior

to ground disturbance and should a population be found it will be buffered to avoid damage. These design

features are common to both Alternative 2 and 3.

Early Successional Species and Habitats

Diamond clarkia (Clarkia rhomboidea) and western pearl-flower (Heterocodon rariflorum) populations

would not likely be harmed by normal harvesting and fuel reduction activities. The soil disturbance and

canopy reduction associated with these activities would likely improve habitat conditions for these

species (Vanderhorst, J. 1997, personal observation). There is one known population of western pearl-

flower on NFSR 2295A and this population will be identified on the ground for avoidance by weed

spraying and destructive road maintenance activity.

The introduction of invasive weeds, also associated with harvesting activities, would degrade habitat

quality for both species and herbicide treatment and equipment washing will be required (see Chapter 2

and Chapter 3 Invasive Species). These measures are not perfect, however, and weed introduction and

spread is expected to occur, particularly where heavy equipment is used. Herbicide use, while necessary

to control weed spread is also potentially damaging to rare plants. Known populations of PTES plants are

mapped and a suitable buffer will be flagged out on the ground to ensure avoidance by weeds crews.

Additional populations, if found, would likewise be protected. These design features are common to both

Alternative 2 and 3.

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Subalpine Species and Habitats

Whitebark pine has been found in Unit 64 in the East Fork area. This is a tractor unit with machine piled

slash so the ground disturbance would be high. The canopy reduction prescribed for this unit may be

beneficial to this species but there is risk of mechanical damage to individual whitebark trees. To avoid

this, individual whitebarks would be fenced and it would be written into the sale contract that these

enclosures would not be damaged. This design feature is common to both Alternative 2 and 3.

Direct and Indirect Effects

Direct effects occur at the time and place the action is implemented while indirect effects occur off-site or

later in time. Direct and indirect effects for Alternative 2 and 3 are similar in nature with the difference

being the acreage affected. The area affected by the Alternatives in potentially suitable PTES plant

habitats can be seen in Table 74 above.

Canopy cover

Riparian Species and Habitats

Neither Alternative 2 nor 3 propose canopy openings in riparian zones so there are no direct effects and

the indirect effects are the same as the No Action Alternative.

Early Successional Species and Habitats

Alternative 2 and 3 would open the canopy in potential habitats for diamond clarkia and western pearl-

flower and this is likely beneficial for these two species (Vanderhorst, J. 1997, personal observation).

Alternative 2 would open about 17 acres more in potential clarkia habitat and about 421 acres more in

potential pearl-flower habitat and for this reason Alternative 2 could benefit these species more than

Alternative 3. Both alternatives would benefit these species more than the No Action Alternative.

Subalpine Species and Habitats

Alternative 2 would open approximately 35 more acres in potential whitebark pine habitat than

Alternative 3. Both Alternative 2 and 3 could be beneficial to whitebark pine in some proposed units

through opening the canopy while protecting existing whitebark trees.

Soil disturbance

Riparian Species and Habitats

Both Alternatives 2 and 3 would have very little soil disturbance in riparian habitats. Both proposals

include the road relocation and the stream restoration work and would have less than an acre of riparian

disturbance. A direct effect of these activities could be the destruction of individual plants or small

subpopulations. Pre-activity surveys to locate and protect any existing PTES plants would reduce the

chance of a negative effect on moonworts or jelly lichen. Indirect effects of the action alternatives on

riparian habitats and species are the same as the No Action Alternative.

Early Successional Species and Habitats

Harvesting, road building and slash disposal activities in Alternatives 2 and 3 would cause varying

degrees of soil disturbance. A direct effect of this disturbance would be the destruction of individuals or

populations of clarkia or pearl-flower should they exist undetected in a unit.

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246 Elk Rice Environmental Assessment

An important indirect effect would be the exposure of a mineral soil seedbed for the potential

establishment and spread of these PTES species. This benefit would likely last for 1 to 5 years after the

activity depending on the site. This same exposed mineral soil is also an ideal seedbed for invasive weed

species (see Non-Native Competition section below).

Alternative 2 would disturb about 17 more acres in potential clarkia habitat and about 421 more acres in

potential pearl-flower habitat than Alternative 3. For this reason Alternative 2 could benefit these species

more than Alternative 3 if invasive weed spread doesn’t negate this benefit. Both action alternatives have

the potential to benefit clarkia and pearl-flower more than the No Action Alternative.

Subalpine Species and Habitats

Mechanical damage to existing whitebark pine is a potential direct effect of soil disturbing activity.

Disturbance of ectomycorrhizal fungi associated with the white barks is another risk (Keane 2012).

Mitigation measures to avoid this where whitebarks are known to exist are described in the project design

section above. Both Alternatives 2 and 3 include the unit 64 that is known to contain whitebark pine.

Should undetected whitebark pine exist undetected in a unit individuals may be lost but the population as

a whole in the project area would not be threatened.

Alternative 2 has 32 more acres of soil disturbing activity planned in potential whitebark pine habitat than

Alternative 3. Both action alternatives include approximately 300 acres of activity in potential whitebark

pine habitat.

Herbicide use

For both action alternatives, weed spraying would continue on open roads as is currently done. A

potential direct effect of this activity is killing PTES species growing at the road edge. A positive indirect

effect of herbicide use is the slower spread of invasive weeds into PTES plants habitats.

Riparian Species and Habitats

Moonwort species are known to grow on roadsides in suitable habitat and would be vulnerable

(Vanderhorst, J.P. 1997). No PTES moonworts have been found in the project area but if found in

roadside habitat their location would be identified on the ground to be avoided by herbicide applicators.

Jelly lichen has also been known to grow on cottonwood trees in riparian roadside habitat. Due to its

position above the ground (the herbicide application zone), it is less vulnerable to herbicide damage.

Mature cottonwood tree foliage is generally also, well above ground and the chemicals used in a riparian

areas would not affect them through root uptake.

Early Successional Species and Habitats

Clarkia is known to grow on roadsides where roads cut through existing populations. This is generally

very weed infested habitat and weed spraying has likely been done in these areas. This activity has likely

directly affected individual yet the populations persist away from the road edge. Herbicide application in

these areas would continue to occur under all alternatives.

Western pearl-flower is known to grow on seldom used roadbeds in suitable habitats. There is a known

population on NFSR 2295A which has been sprayed in the past. Timing of the past applications (after

seed set in July) may be a factor in their persistence on this site. Concentrations of pearl-flower on this

road, and other populations if found, will be identified on the ground and avoided by herbicide

applicators.

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Subalpine Species and Habitats

Whitebark pine is not particularly vulnerable to herbicide mortality. Although individuals growing at the

road edge may be damaged, there would be no effect on the population as a whole.

Non-native competition

The direct effect of non-native weed introduction is the crowding out, through competition and

allelopathic substances, of PTES plants on the site. The indirect effects of weed introduction is the spread

to adjacent habitats and their persistence in the plant community indefinitely.

Riparian Species and Habitats

Weeds, particularly reed canarygrass, Canada thistle, and potentially hounds tongue, will continue to

effect riparian habitats at current or possibly increasing levels with the both action alternatives. The small

amount of ground disturbing activity proposed for riparian areas is the same under both Alternatives 2 and

3. Weeds at the stream restoration sites would be monitored and controlled as prescribed in the restoration

plan.

Early Successional Species and Habitats

Harvesting, road building and slash disposal activities in Alternatives 2 and 3 would cause varying

degrees of soil disturbance. An indirect effect of this disturbance would be the establishment and spread

of invasive non-native plants which can out compete PTES and other native plant species. Once

established, these invasive species seem to be a permanent part of the plant community, as they already

are particularly near existing roads. New road construction is particularly damaging in this regard as it has

the likelihood of introducing invasive weeds into natural plant communities. Mitigation measures as

previously described are very helpful but not perfect in preventing this.

Alternative 2 proposes approximately three miles of new road construction as compared to zero in

Alternative 3 (see Table 12) and therefor has a higher risk of introducing invasives into uninfested

habitats.

Subalpine Species and Habitats

Whitebark pine and its habitats are not as vulnerable to the negative effect of invasive weeds as lower

elevation habitats. Both action alternatives have similar activity acreages in potential whitebark habitat

and neither would have an effect on this species due to the spread of invasives.

Cumulative Effects

Spatial and Temporal Context for Cumulative Effects Analysis

The cumulative effects area for this analysis is limited to the Elk rice project area where effects on PTES

plant populations from timber harvest, prescribed burning, and road work could potentially be discernible.

The time frame for cumulative effects is about 100 years, roughly the time for affected forests to

regenerate and mature.

Past, Present, and Reasonably Foreseeable Activities Relevant to Cumulative Effects Analysis

The Elk Rice project area experienced stand replacing fires around 1910. Ninety-eight percent of the area

was burned and current plant communities and PTES plant populations have naturally recovered. While

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248 Elk Rice Environmental Assessment

there are no records of extirpations of any PTES plant species within the analysis area, that event shaped

the current vegetative landscape. The dominance of mature, even-aged conifer is a result of those fires.

There may have been effects to sensitive plant species in the project area due to past harvest activities,

fire suppression, recreational activities, an introduced pathogen, and both the introduction of noxious

weeds and the use of herbicides for their control. A comprehensive summary of activities in the Elk Rice

project area is found in the Cumulative Effects Catalog. Though no known PTES plant populations have

been impacted by past events and activities, there is potential that undetected populations may have been

effected.

Canopy cover

Riparian Species and Habitats

Large wildfires have eliminated almost all riparian old growth forest cover from the project area. Some

riparian areas, particularly on private land, have been logged and in some cases converted to pasture/hay.

Since the INFISH amendment (1995) to the Forest Plan, riparian buffers are left intact, thus limiting the

effects of harvest activity on riparian habitat on federal land. There is currently little canopy disturbance

in riparian areas and this is expected to continue for the foreseeable future. There are also recent and

proposed reforestation efforts on both federal and private lands along the East Fork of Elk Creek.

Both Alternatives 2 and 3 would contribute to riparian reforestation.

Early Successional Species and Habitats

Effective fire suppression has reduced canopy opening wildfires over the past 50 years. This past and

ongoing activity is somewhat offset by harvesting (approximately 5,932 acres since the 1950s). Still, the

trend has been toward fewer and smaller openings in dry habitats suitable for diamond clarkia. Logging

and road building have been more effective at increasing openings in moist habitats suitable for western

pearl-flower colonization.

Alternatives 2 and 3 would both slow the trend towards higher canopy cover in clarkia and pearl-flower

habitats.

Subalpine Species and Habitats

Since the stand replacing fires of 1910 there have been smaller fires and harvesting activity in whitebark

pine habitat in the Elk Rice project area. The Ulm Peak fire in 2006 killed numerous mature whitebark

pine in and adjacent to the project area but it also opened up 150 acres suitable habitat for whitebark

regeneration in the project area. (whitebarkfound.org).

Past logging activity in the upper East Fork of Elk Creek did effectively open the canopy in potential

whitebark habitat but it is unknown to what extent the species occupied this habitat, if white bark were

harvested or to what extent it has regenerated there.

Mountain pine beetle infestation of the higher elevation lodgepole stands also has opened the canopy in

potential whitebark habitat. The beetle likely also have killed some mature whitebark in this area.

A Google Earth review of forest canopy density through time in the higher elevations of the project area

show no clear trend. The 300 acres or so of canopy reduction in potential habitat for Alternatives 2 and 3

would have little effect on whitebark habitat in the Elk Rice project area as a whole.

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Soil disturbance

Riparian Species and Habitats

Past wildfires, logging, roadbuilding and flood events have caused riparian soil disturbance in the project

area. These disturbances disrupted plant communities and possibly effected PTES species. Riparian

disturbance also allowed for the establishment of the cottonwood trees that now support the growth of

jelly lichen and created the alluvium deposit microsites where moonworts are often found. (Hutchinson

1999, Vanderhorst, J.P. 1997). Infrequent riparian disturbance can be beneficial for PTES plants.

More recently, riparian areas have been protected from disturbance through fire suppression and stream

protection buffers. Both action alternatives would follow stream protection guidelines (see Aquatic

Habitat and Species report in Chapter 3) and they would not result in significant soil disturbance in

riparian areas.

Early Successional Species and Habitats

Historically, wildfires would be the primary mechanism for exposing a mineral soil seedbed for pioneer

plant species in diamond clarkia and western pearl-flower habitats. Clarkia habitat often includes

naturally loose, unstable, rocky soil. To a lesser extent, storm events (blowdown) and animal activity

(digging, trails, etc.) create this type of disturbance. Fire suppression has reduced soil exposure from

wildfires over the past 50 years. This reduction in soil disturbance is somewhat offset by harvesting

activities (approximately 5,932 acres since the 1950s). Logging and road building have effectively created

suitable conditions for western pearl-flower colonization in moist habitats. The benefit of soil disturbance

from past logging in dry, clarkia habitat is unsure due to the negative effect of weed infestations that also

resulted from that activity.

Past, ongoing and future recreational activities can also provide suitable soil disturbance for pearl-flower

and this species is frequently found in hiking and lightly used motorized trails in other parts of the

Cabinet Ranger District. The activities in both Alternative 2 and 3 are consistent with past activities that

have created habitat for western pearl-flower. Both action alternatives would create soil disturbance that

has the potential to benefit diamond clarkia and western pearl-flower.

Subalpine Species and Habitats

Wildfire has been the primary natural soil disturbing process in whitebark pine habitats. Past logging has

also effected this habitat. Both of these mechanisms of disturbance have likely killed whitebark trees

while at the same time created habitat for re-establishment. The activities in both Alternatives 2 and 3

would likely do the same. Measures to protect existing whitebark trees are described in the Design

Features section.

Herbicide use

Weed control with herbicides began in the project area in 1991 to control numerous sites where rush

skeleton weed had gotten established as a result of logging activity. Starting in 2013 a general road

spraying program went into effect. For all alternatives, weed spraying will continue on open and gated

roads as needed. For more detail on this activity see the Weeds section of Chapter 3.

Non-native competition

Noxious weed establishment in the project area dates back to at least the 1950s. More recent introductions

include rush skeleton weed and meadow knapweed in the early 1990s. Currently, hounds tongue is a

notable threat in the project area.

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Riparian Species and Habitats

Invasive plant species have been less damaging to riparian forest communities than to riparian grass/forb

communities. Moonworts and jelly lichen in forested riparian habitats are unlikely to have been affected

by weed competition. Moonworts in open riparian habitats could have been, and could continue to be

impacted by non-natives competition. The stream restoration component of both action alternatives would

convert a small amount of open riparian to forested riparian habitat that would be less vulnerable to

invasive weeds.

Early Successional Species and Habitats

Invasive weeds have had a significant impact on open, dry grass/forb communities in the project area. St

Johnswort, spotted knapweed and cheatgrass have moved into much of the suitable habitat for diamond

clarkia. Rush skeletonweed, present but currently controlled in the project area, is another threat to this

habitat.

St. Johnswort, oxeye daisy, meadow and yellow hawkweeds are significant threats to western pearl-flower

habitats. Rush skeleton weed and hounds tongue are also potential invaders in these areas.

Both action alternatives carry the threat of further weed spread and new invaders. Alternative 2 with more

new roads proposed and about 20 acres more tractor harvesting is slightly higher risk than Alternative 3.

Subalpine Species and Habitats

Non-native invasive plants are not a significant factor in whitebark pine survival. Non-native fungal

pathogen is however. White pine blister rust (Cronartium ribicola), a pathogen from Eurasia, has

devastated whitebark pine populations in much of the species range (Keane 2012). No activities in either

action alternative would have an effect on blister rust mortality in whitebark pine.

Cumulative Effects Summary

Implementation of this project in conjunction with the past and ongoing activities in the project area

would not measurably affect PTES plant populations.

Regulatory Framework Findings

Compliance with 2015 Forest Plan

The 2015 Forest Plan provides desired conditions, objectives, standards, and guidelines for PTES plants.

The following are applicable to the actions in this project:

Response: All action alternatives would trend sensitive plant habitat towards the 2015 Forest Plan

(FW-DC-VEG-09) desired condition: “Habitat for plant species listed under the Endangered Species

Act (ESA) is maintained or restored on NFS lands, thus contributing to species recovery or delisting.

Ecological conditions and processes that sustain the habitats currently or potentially occupied by

sensitive plant species are retained or restored.” The geographic distributions of sensitive plant

species in the 2015 Forest Plan would be maintained.

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Compliance with Other Laws, Regulations, and Policies

Federal Law

Response: All alternatives would comply with Forest Service policy on sensitive species (FSM

2670.32) and the ESA. Clause B(T) 6.25 - "Protection of Threatened, Endangered, and Sensitive

Species", would be used in the timber sale contract to modify the action as necessary to protect PTES

plant populations if missed by field surveys and found after the timber sale contract is awarded.

Endangered Species Act (ESA)

Response: No Proposed, Threatened, or Endangered plant species are known to occur in the Elk Rice

project area. The Elk Rice project may affect individual whitebark pine (a candidate species) or

habitat but would not likely contribute to a trend towards federal listing or cause a loss of viability to

the population or species. Elk Rice project will not jeopardize the continued existence of any

threatened, endangered, or proposed species and so it is compliant with the ESA.

National Forest Management Act (NFMA)

Response: The Elk Rice project will “provide for diversity of plant and animal communities based on

the suitability and capability of the specific land area in order to meet overall multiple-use

objectives.” The Elk Rice project may impact individuals or habitat of Region one sensitive species

but would not likely contribute to a trend towards federal listing or cause a loss of viability to the

population or species. The Elk Rice project is compliant with the NFMA.

Monitoring

2015 Forest Plan Monitoring

Kootenai NF direction is to inventory and manage sensitive plants so that no new species have to be listed

as threatened or endangered. Suitable sensitive plant habitat in project areas is surveyed and projects

modified as necessary to achieve this objective. Sensitive plants are protected according to site-specific

management plans developed by Forest and district botanists.

Project Monitoring

Monitoring of rare plant populations where the proposed activity was modified by buffering rare plant

individuals, populations, or habitats to avoid adverse effects would be conducted by qualified Botanists to

validate the effectiveness of design features and mitigation measures during and following the activity.

Summary of Environmental Effects

All alternatives including Alternative 1 (the No Action Alternative) may impact individuals or habitat but

would not likely contribute to a trend towards federal listing or cause a loss of viability to the population

or species for PTES plant species. Alternatives 2 and 3 could improve habitat for diamond clarkia,

western pearl-flower and whitebark pine by reversing a negative trend of vegetation encroachment on

openings as a result of fire suppression. It is believed that the potential loss of a few individuals would be

offset by the benefits of returning disturbance, through harvesting activity and burning, to the project area.

PTES plant surveys have been conducted. To provide for inadvertent discovery, protection measures

needed for proposed, threatened, endangered, and sensitive plants would be included in the timber sale

contract to provide for the protection of sensitive plants found during implementation and harvest

activities (B6.24). If a population or individual is located during any phase of implementation these

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252 Elk Rice Environmental Assessment

avoidance provisions in the contract would be invoked to ensure protection. Table 75 displays the

summary comparison of environmental effects to PTES plants by alternative.

Table 75. Summary Comparison of Environmental Effects to PTES Plant Resources

Resource Element Alt 1 (No Action)

Alt 2 (Proposed Action)

Alt 3

Riparian Species and Habitats

Botrychium spp.

Riparian forest

May impact individuals* May impact individuals* May impact individuals*

Collema curtisporum

Riparian forest, on mature

cottonwood trees

May impact individuals* May impact individuals* May impact individuals*

Early Successional Species and Habitats

Clarkia rhomboidea

Dry, open forest guild

May impact individuals* May impact individuals* May impact individuals*

Heterocodon rariflorum

Riparian forest/Moist forest

guilds (disturbed soil)

May impact individuals* May impact individuals* May impact individuals*

Subalpine Species and Habitats

Pinus albicaulis

Subalpine guild, early

successional establishment

May impact individuals* May impact individuals* May impact individuals*

* May impact individuals or habitat but would not likely contribute to a trend towards federal listing or cause a loss of viability to

the population or species.