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ELDORADO NATIONAL FOREST Placerville Ranger District Biological Evaluation – Botanical Resources Sly Park Fuels Reduction Project November 2019 PROJECT LOCATION: El Dorado County, CA T10N, R13 East, Sec. 2, 3, 4, 5, 8, 9, 10, 15, 16, 17, 18, 19, 20; T11N, R13 East, Sec. 31, 32, 33, 34, 35 Prepared By: Sara Reece, Senior Biologist, Janelle Nolan & Associates Environmental Consulting

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Page 1: eldoradorcd.org · 2020. 8. 24. · TABLE OF CONTENTS I. Introduction

ELDORADO NATIONAL FOREST

Placerville Ranger District

Biological Evaluation – Botanical Resources

Sly Park Fuels Reduction Project

November 2019

PROJECT LOCATION:

El Dorado County, CA T10N, R13 East, Sec. 2, 3, 4, 5, 8, 9, 10, 15, 16, 17, 18, 19, 20;

T11N, R13 East, Sec. 31, 32, 33, 34, 35

Prepared By: Sara Reece, Senior Biologist, Janelle Nolan & Associates Environmental Consulting

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TABLE OF CONTENTS

I. Introduction ...................................................................................................................................................................... 3

Species Considered .................................................................................................................................................. 3

II. Current Management Direction ....................................................................................................................................... 6

III. Description of the Project. ............................................................................................................................................... 7

Proposed Action ....................................................................................................................................................... 7

Design Criteria ........................................................................................................................................................ 10

IV. Existing Environment ...................................................................................................................................................... 11

General Habitat Description ................................................................................................................................... 11

Forest Service Sensitive Species Descriptions and Known Occurrences ................................................................ 12

Non-Native Invasive Species .................................................................................................................................. 17

V. Effects Analysis ............................................................................................................................................................... 19

Barren and Grassland Habitat (Including Lava Caps) and Associated Species ....................................................... 19

Chaparral Habitat and Associated Species ............................................................................................................. 20

Forest Habitat ......................................................................................................................................................... 21

Cumulative Effects .................................................................................................................................................. 23

VI. Determination Summary ................................................................................................................................................ 24

VII. Literature Cited ............................................................................................................................................................... 26

TABLES

Table 1. Forest Service Sensitive Plants Potentially Occurring in the Sly Park Fuels Reduction Project Analysis Area (Elevation 3,200 to 4,200 feet msl).

Table 2. Habitat Types within the Treatment Units and Analysis Area.

Table 3. Known Populations of Pleasant Valley Mariposa Lily Occurring within the Treatment Units and Analysis Area.

Table 4. Known Populations of Yellow Bur Navarretia Occurring within the Treatment Units and Analysis Area.

MAPS

Map 1. The Sly Park Fuels Reduction Project.

Map 2. Location of Known Populations of FSS Plants in the Sly Park Fuels Reduction Project Treatment Units and Analysis Area.

Map 3. Location of Non-Native Invasive Plants in the Sly Park Fuels Reduction Project Treatment Units and Analysis Area.

APPENDICES

Appendix A. Priority Non-Native Invasive Plants on the Eldorado National Forest

Appendix B. Non-Native Invasive Plant Risk Assessment.

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I. INTRODUCTION

This document analyzes the potential effects of the Sly Park Fuels Reduction Project (Project or Proposed Project) on special-status plants. Based on the initial analysis of habitat and known occurrences, there are no known occurrences of federally listed plants in the Project vicinity, and the proposed Treatment Units are not within the range of/do not provide suitable habitat for any federally listed plants (refer to Table 1, below). In addition, a species list generated on the U.S. Fish and Wildlife Service Information for Planning and Conservation website indicated that there is no potential for federally listed plants at the site (USFWS 2019). Therefore, a Biological Assessment meeting the requirements of Section 7 of the Endangered Species Act (ESA) was not required for this Project.

Forest Service Manual 2672.42 specifies preparation of a Biological Evaluation (BE) to determine if a project may affect any USDA Forest Service (USDA-FS) sensitive species (FSS). FSS species are designated by the Regional Forester and are species that have known or suspected viability problems due to significant current or predicted downward trends in population numbers or density, and/or significant current or predicted downward trends in habitat quantity or quality for these species. The USDA-FS considers the long-term conservation needs of sensitive species in order to avoid future population declines and the need for federal listing. The purpose of this BE is to review the Project in sufficient detail to determine to what extent the proposed action may affect any FSS species.

Location: The Project is located on the Placerville Ranger District of the Eldorado National Forest (ENF) within the South Fork American River, North Fork Weber Creek, Sly Park Creek, Camp Creek, and Upper and Lower North Fork Cosumnes Creek watersheds, between approximately 3,200 and 4,200 feet above mean sea level (msl).

SPECIES CONSIDERED

There are known occurrences of Pleasant Valley mariposa lily (Calochortus clavatus var. avius), branched collybia (Dendrocollybia racemosa), and yellow bur navarretia (Navarretia prolifera ssp. lutea) within the Analysis Area. In addition, the Analysis Area includes potential habitat for the following species:

1. Big-scale balsamroot (Balsamorhiza macrolepis var. macrolepis) 2. Mountain lady’s slipper (Cypripedium montanum) 3. Yellow-lip pansy monkeyflower (Diplacus pulchellus) 4. Olive phaecollybia (Phaecollybia olivacea) 5. Sierra blue grass (Poa sierrae)

Table 1 lists all plants considered FSS on the ENF; and provides a brief summary of their potential for occurrence in the Project area. Taxa that are not present and for which no suitable habitat is present are not further analyzed in this document.

Table 1. Forest Service Sensitive Plants Potentially Occurring in the Sly Park Fuels Reduction Project Analysis Area (Elevation 3,200 to 4,200 feet msl).

Species Status1 On ENF2

Known in

Project Area

Suitable Habitat in

Project Area

Rationale for Determination of No Suitable Habitat/No Effect

Three-bracted onion (Allium tribracteatum)

S P No No

Grows on open ridges with gravelly lahar soils (lava cap communities) in chaparral and lower & upper montane coniferous forests from ~ 3,300 to 10,000 feet in elevation.

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Species Status1 On ENF2

Known in

Project Area

Suitable Habitat in

Project Area

Rationale for Determination of No Suitable Habitat/No Effect

El Dorado manzanita (Arctostaphylos nissenana)

S K No No Grows on highly acidic slate and shale soils and is often associated with closed-cone conifer forest from about 1,400 to 3,600 feet.

Big-scale balsamroot (Balsamorhiza macrolepis var. macrolepis)

S P No Yes Grows in chaparral, vernally moist meadows & grasslands, grasslands within oak woodland, and ponderosa pine forest below 4,600 feet.

Upswept moonwort (Botrychium ascendens)

S P No No Grows in lower montane coniferous forest, meadows, and seeps from 4,900 to over 7,500 feet in elevation.

Scalloped moonwort (Botrychium crenulatum)

S K No No Grows in fens, lower montane coniferous forest, meadows, seeps, and freshwater marshes from 4,900 feet to 10,500 feet in elevation.

Common moonwort (Botrychium lunaria) S P No No

Grows in meadows, seeps, subalpine and upper montane coniferous forest from 7,450 feet to over 11,000 feet in elevation.

Mingan moonwort (Botrychium minganense)

S K No No Grows in fens, lower and upper montane coniferous forest, meadows, and seeps from 4,900 to 6,750 feet.

Mountain moonwort (Botrychium montanum)

S K No No Grows in lower and upper montane coniferous forest, meadows, and seeps from 4,900 feet to 7,000 feet in elevation.

Paradox moonwort (Botrychium

paradoxum) S K No No

Grows in lower and upper montane coniferous forest, meadows, and seeps from 4,900 feet to 7,000 feet in elevation.

Stalked moonwort (Botrychium

pendunculosum) S P No No

Grows in lower and upper montane coniferous forest, meadows, and seeps from 4,900 feet to 7,000 feet in elevation.

Bolander’s bruchia (Bruchia bolanderi) S K No No

Grows in meadows and fens in montane and subalpine communities from about 5,500 to 9,000 feet. Grows in ephemeral habitats such as erosional ditches or small streamlets through wet meadows.

Pleasant Valley mariposa lily (Calochortus clavatus var. avius)

S K Yes Yes

Grows in openings in mixed conifer & ponderosa pine forest, usually on ridgetops and south-facing slopes from 2,500 to 5,600 feet. There are numerous occurrences along Weber Mill Road and 11N38G.

Mountain lady’s slipper (Cypripedium montanum)

S P (K on inholding) No Yes

Grows in moist areas and upland sites with northerly aspects, loamy soils and shade, from 3,500 to 5,700 feet (generally <5,000 ft).

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Species Status1 On ENF2

Known in

Project Area

Suitable Habitat in

Project Area

Rationale for Determination of No Suitable Habitat/No Effect

Branched collybia (Dendrocollybia racemosa)

S K Yes Yes

Grows on remains of decayed mushrooms or occasionally in duff/leaf litter, in mid-mature to old-growth stands of mixed hardwood-conifer forests. Evidence of timber harvest at some extant occurrences.

Tahoe draba (Draba asterophora var. asterophora)

S H No No Restricted to rocky ledges and talus slopes in subalpine and alpine habitats above 8,200 feet.

Cup Lake draba (Draba asterophora var. macrocarpa)

S K No No Restricted to sandy slopes, rocky ledges, and talus slopes in subalpine and alpine habitats above 8,200 ft.

Tripod buckwheat (Eriogonum tripodum)

S K No No Grows on serpentine soils in foothill and cismontane woodlands below 5,300 feet.

Blandow’s bog-moss (Helodium blandowii) S P No No

Grows in wet meadows, fens, & seeps in subalpine coniferous forest and alpine lakes from 6,100 to 9,000 feet.

Parry’s horkelia (Horkelia parryi) S K No No

Grows on stony, disturbed, slightly acidic soils in open chaparral and cismontane woodland below 3,400 feet.

Hutchison’s lewisia (Lewisia kelloggii ssp. hutchisonii)

S K No No

Grows in openings in upper montane coniferous forest, often on slate soils and on soils that are sandy granitic to erosive volcanic from 4,800 to 7,000 feet.

Kellogg’s lewisia (Lewisia kelloggii ssp. kelloggii)

S K No No Grows on granitic and volcanic balds from about 5,000 to 8,000 feet.

Long-petaled lewisia (Lewisia longipetala) S K No No Restricted to subalpine & alpine slopes or basins

with deep snow accumulations, above 8,200 feet.

Saw-toothed lewisia (Lewisia serrata) S K No No

Restricted to steep, nearly vertical cliffs in inner gorges of perennial streams and rarely near seeps and intermittent streams. Grows between 2,800 and 4,800 feet in the American River watershed.

Broad-nerved hump-moss (Meesia uliginosa)

S P No No Grows in permanently wet, primarily spring-fed meadows and fens in montane to subalpine coniferous forest from 4,200 to 9,200 feet.

Elongate Copper Moss (Mielichhoferia elongata)

S P No No

Grows on metamorphic, sedimentary, limestone, and serpentine rock outcrops that often contain copper or other heavy metals and that are seasonally moist or less commonly on moist soil. Usually in foothill woodland habitats dominated by oaks or chaparral and sometimes with scattered incense cedar, Douglas-fir, and ponderosa pine.

Yellow-lip pansy

monkeyflower (Diplacus pulchellus)

S K No Yes

Habitat is vernally wet to moist sites which are open and flat or slightly sloping. Typically found on lava caps but soils can be clay, volcanic, or granitic. Grows from 2,200 to 6,400 feet.

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Species Status1 On ENF2

Known in

Project Area

Suitable Habitat in

Project Area

Rationale for Determination of No Suitable Habitat/No Effect

Yellow bur navarretia (Navarretia prolifera ssp. lutea)

S K Yes Yes

Grows in openings in or adjacent to mixed conifer forest or cismontane woodland on rocky ridgelines, saddles, or eroding ephemeral drainages from 2,300 to 5,000 feet.

Adder’s tongue (Ophioglossum

pusillum) S P No No Grows in moist habitat including wet meadows and

roadside ditches.

Layne’s ragwort (Packera layneae) T K No No

Grows on rocky, gabbroic or serpentinitic soils in chaparral and cismontane woodland below 3,000 feet.

Veined water lichen (Peltigera gowardii) S K No No

Grows on rocks in cold, unpolluted spring-fed streams without marked seasonal fluctuation. Submerged most of year. Peak flows must not scour the rocks & gravels where this species attaches. Located on the ENF in 2008.

Stebbins’ phacelia (Phacelia stebbinsii) S K No No

Grows on dry, open, rocky sites (bedrock outcrops, rubble or talus) on ledges or moderate to steep slopes and on damp, mossy inner gorges from 2,000 to 6,800 feet.

Olive phaeocollybia (Phaeocollybia olivacea)

S P (K on inholding) Yes Yes

Conifer and hardwood forests where it grows in the humus layer. Logging disturbance, when present, is not intense (e.g. clear-cut or patch-cut).

Whitebark pine (Pinus albicaulis) C, S K No No

Whitebark pine typically occurs on cold and windy high elevation sites in western north America (7,000-12,000 feet).

Sierra blue grass (Poa sierrae) S K No Yes Grows in lower montane coniferous forest on steep,

shady, moist slopes from 1,200 feet to 3,800 feet.

1 T =Federally Listed as Threatened C = Federally Listed as Candidate; S = Forest Service Sensitive 2 K = known to occur on ENF; P = suspected to occur on ENF; H = historic record on ENF

II. CURRENT MANAGEMENT DIRECTION

Current management direction on desired future conditions for federally threatened, endangered, proposed and candidate species on the ENF can be found in the following documents:

• Forest Service Manual (FSM 2670);

• Forest Service Handbook (FSH 2609.26 Botanical Program Management);

• ENF Land and Resource Management Plan (LRMP) (1989), as amended by the Sierra Nevada Forest Plan Amendment (SNFPA) (2004).

In the ENF LRMP (USDA FS 1989), under Management Practice 49, the General Direction is to "provide for protection and habitat needs of sensitive plants so that Forest activities would not jeopardize the continued existence of such species". In the 2004 Sierra Nevada Forest Plan Amendment (SNFPA), standard and guideline 125 for sensitive plant

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surveys is to “Conduct field surveys early enough in the planning process that the project can be designed to conserve and enhance TEPS plants and their habitat. Conduct surveys according to procedures outlined in the Forest Service Handbook (FSH 2609.25.11). If additional field surveys are to be conducted as part of project implementation, survey results must be documented in the project file.”

III. DESCRIPTION OF THE PROJECT.

The Project is located near Pollock Pines in central El Dorado County, California. It is located on ENF lands within T10N, R13 East, Sec. 2, 3, 4, 5, 8, 9, 10, 15, 16, 17, 18, 19, and 20 within the U.S. Geological Service (USGS) 7.5-minute Sly Park Quadrangle and T11N, R13 East, Sec. 31, 32, 33, 34, and 35 within the USGS 7.5-minute Pollock Pines Quadrangle.

Project parcels are adjacent to and surrounded by low-medium density residential properties, forested land owned by Sierra Pacific Industries, El Dorado Irrigation District (EID), non-industrial private landowners, and other NFS land. The Project area surrounds Jenkinson Lake. The lake has a surface area of 645 acres with a storage capacity of 41,000 acre-feet. The primary function of this reservoir is to store water for irrigation, municipal, and industrial purposes within El Dorado County. The Sly Park Recreation Area, which includes the lake and is managed by EID, is an extremely important recreational destination for people from El Dorado County and beyond.

PROPOSED ACTION

The Sly Park Fuels Reduction Project is part of an all-lands approach that will connect fuel breaks on the ENF with fuel breaks on adjacent lands to create resilient forest ecosystems and fire-adapted communities. The Placerville Ranger District is proposing 19 Treatment Units on approximately 3,000 acres of natural stands which are dense with trees of varying size, shrubs, and surface fuels and therefore at risk of loss to wildfire. Treatment areas were strategically placed within the Wildland-Urban Intermix (WUI), as well as in strategic locations that connect to past and future treatment areas on both public and adjacent private lands (refer to Map 1).

The goal of the treatments is to reduce understory ladder and surface fuels to ameliorate wildfire behavior and facilitate the future application of prescribed fire. Following treatment, stands would be less dense, have fewer small trees, and have low surface fuels. Hardwoods, shrubs and ground cover would be retained in canopy openings to the extent that there is minimal connectivity to overstory trees. In the event of a wildfire, flame lengths and fire intensity would be reduced; crown fire potential would be lessened; suppression effectiveness would be increased; and firefighter safety would be improved.

A combination of thinning, chipping/mastication of brush and smaller trees, and hand treatments including brush cutting, hand thinning, and pruning would be used to reduce tree density in selected stands and to change the structure of live and dead material in treated stands. The most cost efficient and effective treatment within each stand would be chosen based on timing, equipment availability, and post treatment results, but would generally be implemented as follows:

• Stands which have an over-abundance of smaller trees and shrubs in the understory would be masticated or chipped. This includes masticating live and dead conifer trees (generally measuring less than 10 inches in diameter at breast height [dbh]) and shrubs. Mastication would generally be applied on slopes up to 45 percent and road edges adjacent to units.

• Residual trees may be pruned to a height of 10 to 12 feet to reduce ladder fuels.

• Stands where mastication is infeasible or restricted (e.g. streamcourse buffers, wildlife Protected Activity Centers [PACs] outside the WUI [SNFPA, 2004]) would be hand thinned.

• All stands are proposed for follow-up prescribed understory burning using ground based or aerial ignition methods after initial mechanical and manual treatments are completed to further reduce fuel loads and reintroduce fire to the ecosystem.

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METHODS

Mastication

Shrubs and small trees (mostly less than 10 inches, but up to 12 inches diameter dbh) would be masticated to reduce the density of understory fuels and small trees. For the purposes of this document, mastication is defined as shredding, mowing, mulching, chipping, and/or grinding vegetative material with the use of machinery. Mastication would reduce stand density, reduce ladder fuels, and rearrange surface fuels such that future prescribed fire could be used to further treat the stands. Masticated vegetative debris would be discontinuous on the forest floor, and generally be less than 4 inches deep with pieces less than 18 inches long. Stump height would generally not exceed 6 inches. Up to 10 percent live shrub cover would be retained in shrub-dominated areas following mastication.

Pruning

Residual trees would be pruned to at least 10 feet from the ground while maintaining a minimum of 33% live crown. The intent is to increase the base height to live crowns in order to reduce the risk of wildfire or prescribed fire moving from the ground into the upper crowns.

Hand Thinning

Shrubs and small trees (mostly less than 10 inches, but up to 12 inches dbh) would be hand cut and lopped, piled or chipped in areas where mechanical treatments are prohibited, areas inaccessible to mastication machinery, or areas most appropriately treated with this method. Any resulting piles would be burned. Within northern goshawk and California spotted owl PACs outside USDA-FS delineated WUI or within 500 feet of activity centers within the WUI, hand thinning of trees generally less than 6 inches dbh would be prescribed in accordance with the SNFPA ROD (SNFPA, 2004, Standards and Guidelines 72, 73, and 74).

Understory Prescribed Fire

All treatment acres identified above are also planned for understory prescribed fire to reduce understory fuels. Prescribed fire would be prioritized in strategic locations to reduce the risk of large fires on the surrounding landscape. Prescribed fire would take place a few years following mastication such that masticated vegetative material would have decomposed to a level where fire effects on residual trees are reduced.

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Map 1. The Sly Park Fuels Reduction Project.

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DESIGN CRITERIA

At the Project level the ENF will implement the following relevant "Design Criteria" to avoid or minimize impacts to botanical resources.

BOTANICAL RESOURCES

B1: To protect unique plant communities and Juncus digitalis (rare plant species with only 3 known occurrences in CA, one of which is in the Sly Park area), lava caps shall be demarcated with flagging, stakes, or similar prior to initiation of work. No mechanical ground-disturbing activities shall occur within the demarcated areas. All project related equipment and vehicles shall remain on existing road corridors within lava caps; including no parking off road, heavy equipment travel, etc.

B2: Currently, there are no federally listed threatened or endangered plant species known or expected to occur within the Analysis Area. Botanical surveys shall be conducted prior to project implementation in areas of potential habitat and/or areas with surveys older than 5 years for FSS plants.

B3: Following completion of surveys, FSS plant occurrences shall be flagged. Mastication would not be implemented within flagged areas. Hand felling of trees and shrub removal may be conducted within occurrences if it is determined effects would be minimal or there will be beneficial effects on the site or habitat conditions. Piles shall be located outside of flagged areas.

B4: Prior to new fire line construction, locations shall be evaluated by a botanist and surveyed as needed. Special status plant occurrences in burn units shall be flagged for avoidance during fire line construction and fire ignition. Prescribed fire will be allowed to back through occurrences if the burning is conducted outside the active growing season.

INVASIVE PLANTS

IP1: Prior to project activities, high-priority invasive plant infestations identified in Map 3 of the Project Biological Evaluation for botanical resources shall be flagged for avoidance and/or treated using integrated pest management techniques in accordance with the design features of the Eradication and Control of Invasive Plants Environmental Assessment (ENF 2013).

IP2: If Project activities cannot be completely avoided within flagged infestations, risk minimization strategies shall be employed, such as working in the infested area last, working in infested areas when propagules are not viable, limiting the number of people or equipment within the infestation, and cleaning mechanical and hand equipment, clothing, boots, etc., before moving to other un-infested NFS lands. These areas shall be identified on Project maps.

IP3: All off-road equipment shall be cleaned to ensure it is free of soil, seeds, vegetative matter or other debris before entering NFS lands to reduce the potential for the introduction or spread of invasive plants. Prior to the start of operations, the Project administrator shall conduct a visual inspection for such debris.

IP4: Straw or mulch used for erosion control shall be certified weed-free. A certificate from the county of origin stating the material was inspected shall be required. On-site material from a weed-free area may also be used.

IP5: Any seed used for erosion control or restoration shall be from a locally collected source and the species shall be approved by a botanist.

PRESCRIBED FIRE

PB2: In all Treatment Units, snags 16 inches in diameter or greater shall be retained during burn preparation and shall not be targeted for ignition, except where they pose a threat to human health and safety, or where they need to be cut for perimeter containment of the prescribed fire.

PB3: In all Treatment Units, downed logs greater than 16 inches diameter shall not be actively lit during implementation of the prescribed burn.

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TERRESTRIAL WILDLIFE

TW3: Dispersed pockets of small trees and understory brush shall be retained during mastication treatments and follow-up prescribed fire treatments, to the extent practicable, to provide cover for wildlife habitat. Downed logs greater than 16 inches in diameter will be retained during mastication treatments and follow-up prescribed fire treatments to the extent practicable.

IV. EXISTING ENVIRONMENT

This section describes the existing environment within the Analysis Area, which is defined by a 1.5-mile buffer surrounding the 19 Treatment Units. Provided below is a general description of habitat in the Analysis Area; a brief description of the natural history and habitat requirements of the eight FSS plants addressed in this document; a summary of surveys and known occurrences of FSS plants in the Analysis Area; and a brief description of non-native invasive plants in the Analysis Area.

GENERAL HABITAT DESCRIPTION

Existing vegetation in the Analysis Area was classified using the California Department of Fish and Wildlife’s (CDFW’s) California Wildlife Habitat Relationship (CWHR) types (CDFW 2014) because the classification takes into account both species composition and stand structure, and because it is considered a standard vegetation classification across forests in the Sierra. While botanical species analyzed vary widely in their ecological requirements and life history characteristics (refer below), many occur in similar general habitat types where the effects of proposed management are similar. Therefore, structurally similar habitats (e.g., shrub- and tree-dominated habitats) have been grouped to support the analysis of potential effects provided in Section VI. Refer to Table 2, below, for the acres of each habitat type present within the Treatment Units and the Analysis Area.

Table 2. Habitat Types within the Treatment Units and Analysis Area. Habitat Group Acres in Treatment Units Acres in Analysis Area Barren/Other 0.22 217.95 Agriculture 0 653.40 Urban 3.34 1,149.79 Water 0 602.03 Grassland (Herbaceous) 29.13 2,851.79 Chaparral (Shrub-dominated) 98.52 1,792.29 Forest (Tree-dominated) 2,861.58 45,102.50

Total Acres 2,992.79 52,373.09

The Treatment Units are predominately characterized by tree-dominated forest habitats (a total of approximately 2,861.58 acres), the large majority of which are Sierran mixed conifer (SMC) (approximately 69 percent), with smaller inclusions of ponderosa pine (PPN) (approximately 13 percent), montane hardwood (MHW) (approximately 8 percent), montane hardwood-conifer (MHC) (approximately 8 percent) and less than approximately 1 percent combined of blue oak woodland (BOW), blue oak-foothill pine (BOP), and douglas-fir (DFR).

Also pertinent to this analysis is chaparral or shrub-dominated habitat, which comprises approximately 98.52 acres or 3.5 percent of the total area of the Treatment Units. Grassland habitat (approximately 29.13 acres) and barren habitat (approximately 0.22 acre) together comprise approximately 1 percent of the total area of the Treatment Units.

Urban areas (approximately 3.34 acres) do not provide suitable habitat for FSS plants and are not address further in this analysis.

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SENSITIVE HABITATS

Lava caps are present in the Project vicinity, typically on ridgetops formed by pre-historic volcanic mudflows (Mehrten formation) (CNPS 2019). Lava caps support unique plant communities, composed primarily of annual herbs and perennial shrubs, and display a higher level of plant diversity than much of the surrounding landscape. Trees, where present, are typically depauperate (i.e., small and stunted) (CNPS 2019). Lava caps were identified, to the degree possible, during early Project planning and, where found, were excluded from the Treatment Units. However, recent USDA-FS data indicate that several additional lava caps are still present within Treatment Units 4, 6, 7, and 8 (Brown, pers. comm., 2019).

There are no known fens, meadows, or other sensitive habitats present within Treatment Units.

FOREST SERVICE SENSITIVE SPECIES DESCRIPTIONS AND KNOWN OCCURRENCES

As described previously, the Analysis Area includes suitable habitat for eight FSS plant species. This section provides a brief description of each species, as well as information on known occurrences obtained through a review of USDA-FS botanical survey records for the Analysis Area dated from 1908 through 2019. Refer to Map 2 for the location of FSS plants in the Analysis Area.

BIG-SCALE BALSAMROOT (BALSAMORHIZA MACROLEPIS VAR. MACROLEPIS)

Big-scale balsamroot is endemic to California and known from records from Shasta County south to Santa Clara County. This species is found on slopes within grasslands, chaparral, and vernally moist meadows, typically below 4,600 feet. The blooming period for this species is March through June.

Known Occurrences

There are no reported populations of big-scale balsamroot within the Analysis Area.

PLEASANT VALLEY MARIPOSA LILY (CALOCHORTUS CLAVATUS VAR. AVIUS)

Pleasant Valley mariposa lily is known almost exclusively from El Dorado and Amador counties in the area between Union Valley Reservoir and the North Fork of the Mokelumne River, with exceptions in Calaveras and Mariposa Counties. The elevation of known occurrences ranges from 900 to 5,800 feet. Pleasant Valley mariposa lily is most often found on lava caps or other openings in shrub-dominated (often manzanita), hardwood-conifer and mixed-conifer communities on south-facing canyon slopes, and along east-west trending ridges spurs, and ridges. The openings typically have rocky soils, with rocks and cobbles apparent at the surface.

This lily may remain dormant in some years, or may emerge vegetatively but then enter dormancy without flowering. Flowering typically occurs May through July.

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Map 2. Location of Known Populations of FSS Plants in the Sly Park Fuels Reduction Project Treatment Units and Analysis Area.

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Known Occurrences

Based on a review of USDA-FS data, there are 13 populations of Pleasant Valley mariposa lily recorded within the Analysis Area. Refer to Map 2 for the location of these populations, and to Table 3, below, for a list of each population (by USDA-FS Occurrence ID), date of last survey, and location within Treatment Unit (where applicable). Three of these populations occur within Treatment Units. CACLA 075 is located in Treatment Unit 14; and CACLA 133 and 151 are location in Treatment Unit 9.

Table 3. Known Populations of Pleasant Valley Mariposa Lily Occurring within the Treatment Units and Analysis Area. USDA-FS Occurrence ID

Date of Last Survey

Treatment Unit

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 CACLA 001 3/7/1995 CACLA 003 4/24/2001 CACLA 017 8/1/1988 CACLA 021 5/14/2001 CACLA 071 6/1/2004 CACLA 074 9/2/1991 CACLA 075 5/24/1999 CACLA 085 6/18/1992 CACLA 128 5/1/2000 CACLA 133 5/21/2003 CACLA 144 6/8/2015 CACLA 150 6/23/2016 CACLA 151 5/24/2015 = population is within or intersecting a Treatment Unit

MOUNTAIN LADY’S SLIPPER (CYPRIPEDIUM MONTANUM)

Mountain lady's slipper is an uncommon orchid in California. It grows throughout the northwest from Alaska to California and east to Montana. In California, it reaches as far south as Santa Cruz County along the coast and Madera County in the Sierra Nevada. The species is known from the Stanislaus and Plumas NF, but has not been documented on the Tahoe NF. On the ENF, one occurrence is located on a private land inholding within the Amador Ranger District.

Mountain lady's slipper grows in both moist and dry conditions at elevations between 600 and 6,700 feet, although it is less common above 4,800 feet. It grows in moist sites near streams or sometimes near the edge of small seeps but also in relatively dry conditions on hillsides in mixed conifer forests. Surveys for this species have been ongoing since 1998 on the ENF, yet no occurrence has been found. Like all orchids, this species requires mycorrhizal fungi for germination and seedling nutrition (Shefferson et al. 2005). Shefferson et al. (2005) determined that mountain lady’s slipper is specifically associated with the mycorrhizal fungi in the family Tulasnellaceae, and may limited by the distribution of this fungi.

High intensity fires are one of the greatest threats to mountain lady’s slippers. This threat ranked highest in the statewide threat analysis (R5 Conservation assessment), and is supported by research and literature. Clustered and mountain lady’s slippers are intolerant to fires that burn through the litter layer above mineral soil. The species may tolerate less intense fires that do not eliminate the duff layer and leave the forest canopy fully or partially intact. Heavy fuel loads may pose a threat to many populations by increasing the risk of intense fire. Large scale fires could result in significant negative effects to multiple populations of these species.

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In addition to fire, mechanical disturbance that affect the rhizomes of these species, duff and litter layer, and the structure of the upper soil horizons may threaten plants and populations, as do those activities that remove the forest canopy. Such mechanical disturbances ranked second statewide in the threat analysis, and include timber harvest activities, construction of fire lines, culvert relocation, and other ground disturbing activities. A high ranking of this disturbance is consistent with information on the species’ responses to rhizome disturbance and forest canopy removal.

Known Occurrences

There are no reported populations of mountain lady’s slipper within the Analysis Area.

BRANCHED COLLYBIA (DENDROCOLLYBIA RACEMOSA)

Branched collybia is a rare mushroom that has been collected from Northern California to British Columbia.

This species usually grows on the decaying fruit bodies of other mushrooms, or occasionally in duff/leaf litter. The host mushroom has been identified as Russula crassotunicata, a widespread species commonly found under conifers (Machnicki st al. 2006). Branched collybia fruit bodies have small pale gray-brown caps up to .25-inch wide and long thins stems covered with short lateral branches. The species is typically found in mid-mature to old-growth stands of mixed hardwood-conifer forests. Fruiting bodies are typically seen in late summer to autumn, after the heavy fruiting period for other mushrooms is over.

Known Occurrences

Based on a review of USDA-FS data, there is one occurrence of branched collybia located at the northern edge of Treatment Unit 16 (refer to Map 2). This occurrence was observed in December 2015 by two mycologists (private citizens) (USDA-FS 2019).

YELLOW-LIP PANSY MONKEYFLOWER (DIPLACUS PULCHELLUS)

Yellow-lip pansy is endemic to California, with records from Calaveras, Mariposa, and Tuolumne County. In addition, the species was discovered on the ENF in 2016. Habitat for this annual plant is vernally wet to moist sites which are open and flat or slightly sloping. The plant is typically found on lava caps, but soils can be clay, volcanic, or granitic. It sometimes grows in disturbed areas within lava caps. Its elevation range is 2,200 to 6,400 feet. The blooming period is April through July. This species is threatened by vehicles, logging, non-native plants, and grazing, and potentially threatened by development.

Known Occurrences

There are no reported populations of yellow-lip pansy monkeyflower within the Analysis Area.

YELLOW BUR NAVARRETIA (NAVARRETIA PROLIFERA SSP. LUTEA)

Yellow bur navarretia is endemic to California where it is known from El Dorado and Placer counties, including the Sly Park, Camino, and Pollock Pines quadrangles (CNPS 2019). Refer below for a detailed discussion of known occurrences of this species in the Project area. Yellow bur navarretia grows on lava caps and other openings in or adjacent to mixed conifer forest or cismontane woodland on rocky ridgelines, saddles, or eroding ephemeral drainages from 2,300 to 5,000 feet. The blooming period is May through July.

Known Occurrences

Based on a review of USDA-FS data, there are 43 populations of yellow bur navarretia recorded within the Analysis Area. Refer to Map 2 for the location of these populations, and to Table 4, below, for a list of each population (by USDA-FS Occurrence ID), date of last survey, and location within Treatment Unit (where applicable). Thirteen of the populations occur within Treatment Units, including Treatment Units 2, 4, 5, 6, 7, 8, 9, 16 and 18. These populations, which range

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between several hundred to more than 10,000 individuals, are found on lava caps, openings, grasslands, and in disturbed areas such as old logging roads and landings. A number of the available written records for these populations indicate a positive response to disturbance, and particularly to openings created by disturbance (USDA-FS 2019). Written records also indicate that non-native invasive species are encroaching on some of the populations.

Table 4. Known Populations of Yellow Bur Navarretia Occurring within the Treatment Units and Analysis Area. USDA-FS Occurrence ID

Date of Last Survey

Treatment Unit

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 NAPRL new 6/5/2019 NAPRL 001 1/1/1979 NAPRL 002 5/22/1982 NAPRL 003 1/1/1979 NAPRL 005 1/1/1979 NAPRL 006 1/1/1979 NAPRL 008 1/1/1979 NAPRL 009 1/1/1979 NAPRL 010 1/1/1979 NAPRL 011 1/1/1979 NAPRL 012 6/11/2019 NAPRL 013 1/1/1979 NAPRL 014 6/6/1980 NAPRL 015 6/6/1980 NAPRL 016 1/1/1979 NAPRL 017 6/10/2019 NAPRL 019 6/1/1980 NAPRL 020 6/6/1981 NAPRL 022 1/1/1980 NAPRL 023 5/31/1962 NAPRL 024 7/20/2010 NAPRL 026 6/29/1921 NAPRL 027 5/19/1982 NAPRL 028 5/20/1982 NAPRL 030 5/18/1982 NAPRL 031 5/20/1982 NAPRL 033 5/20/1982 NAPRL 035 5/21/1982 NAPRL 036 5/21/1982 NAPRL 038 6/5/1982 NAPRL 039 6/22/1982 NAPRL 040 6/10/1982 NAPRL 045 7/5/1982 NAPRL 047 6/30/1982 NAPRL 048 6/30/1982 NAPRL 049 6/10/1982 NAPRL 050 6/16/1982

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Table 4. Known Populations of Yellow Bur Navarretia Occurring within the Treatment Units and Analysis Area. USDA-FS Occurrence ID

Date of Last Survey

Treatment Unit

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 NAPRL 051 7/17/2012 NAPRL 056 6/17/1982 NAPRL 058 6/9/1982 NAPRL 062 7/17/1982 NAPRL 084 7/19/2004 NAPRL 086 5/24/2015 = population is within or intersecting a Treatment Unit

OLIVE PHAECOLLYBIA (PHAECOLLYBIA OLIVACEA)

Olive phaecollybia is a mushroom that inhabits conifer and hardwood forests, where individuals are found scattered or in arcs in the humus layer (Castellano et al. 2003). The species is endemic to the western United States from the central Oregon coast south to Santa Cruz County (Castellano et al. 2003). The cap is uniformly olive and between 40 to 110 millimeters (1.6 to 4.3 inches) in diameter; and the stem is up to 200 millimeters (7.9 inches) long (Castellano et al. 2003). Logging disturbance, when present, is not intense (e.g. clear-cut or patch-cut).

Known Occurrences

There are no reported populations of olive phaecollybia within the Analysis Area.

SIERRA BLUEGRASS (POA SIERRAE)

Sierra bluegrass is a perennial grass that is endemic to California, with records from Butte, El Dorado, Madera, Nevada, Placer, Plumas, and Shasta Counties (CNPS 2019). This species grows in openings in lower montane coniferous forest, often on mossy rocks, from 1,200 feet to 3,800 feet. Sierra bluegrass flowers April through June.

Known Occurrences

There are no reported populations of Sierra bluegrass within the Analysis Area.

NON-NATIVE INVASIVE PLANTS

A list of non-native invasive plants (NNIPs) that are considered a priority on the ENF is provided in Appendix A. Known occurrences of these species are shown in Map 3. Given the proximity of the Treatment Units to urban and recreational developments, additional NNIPs are assumed to be present within developed areas, along roads, and in open or disturbed areas. The number and prevalence of NNIPs is likely reduced within shaded forest habitats. Refer to Appendix B for the Non-Native Invasive Plant Risk Assessment.

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Map 3. Location of Non-Native Invasive Plants in the Sly Park Fuels Reduction Project Treatment Units and Analysis Area.

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V. EFFECTS ANALYSIS

The Proposed Project includes fuels reduction treatments within tree-dominated habitats (i.e., shaded forest and open forest) and shrub-dominated habitats within the 19 Treatment Units. A brief analysis of potential impacts to these habitats, as well as FSS plants associated with these habitats, as provided below.

BARREN AND GRASSLAND HABITAT (INCLUDING LAVA CAPS) AND ASSOCIATED SPECIES

As shown in Table 2, the Treatment Units include grassland habitats (approximately 29.13 acres) and barren habitats (approximately 0.22 acre). In addition, recent data obtained from ENF botanists indicate that several lava caps are present within Treatment Units 4, 6, 7, and 8 (Brown, pers. comm., 2019). The location of these lava caps largely coincides with lands characterized by CWHR as grassland habitat. Four of the eight FSS species addressed in this analysis are associated primarily with grasslands, barren, and lava cap habitats. These are big-scale balsamroot, Pleasant Valley mariposa lily, yellow-lip pansy monkeyflower, and yellow bur navarretia.

EFFECTS TO HABITAT

Barren and grassland habitats, which together comprise less than 1 percent of the total acreage of the Treatment Units, are present in small, scattered patches within the Treatment Units; are only incidentally included within Treatment Unit boundaries; and are not proposed for treatment. Lava cap habitats are specifically protected by Design Criteria B1, which states that any lava caps occurring within (or immediately adjacent) to the Treatment Units would by demarcated with flagging, stakes, or similar materials prior to initiation of work. No mechanical ground-disturbing activities would occur within the demarcated areas, and all Project-related equipment and vehicles would remain on existing road corridors within lava caps. Use of vehicles and mechanical equipment in adjacent work areas could potentially result in the introduction or spread of NNIPs to lava caps. Design Criteria IP1 states that, prior to project activities, high-priority infestations identified in Map 3 would be flagged for avoidance and/or treated using integrated pest management techniques in accordance with the design features of the Eradication and Control of Invasive Plants Environmental Assessment (ENF 2013). If Project activities cannot be completely avoided within flagged infestations, risk minimization strategies shall be employed, such as working in the infested area last, working in infested areas when propagules are not viable, limiting the number of people or equipment within the infestation, and cleaning mechanical and hand equipment, clothing, boots, etc., before moving to other un-infested NFS lands (refer to Design Criteria IP2). Design Criteria IP3 requires cleaning of off-road equipment prior to entering NFS lands; Design Criteria IP4 requires use of certified weed-free erosion control materials; and Design Criteria IP5 requires that only locally sourced, botanist-approved seed be used for erosions control.

Considering that barren and grassland habitats are not proposed for treatment, the Project would have no or minimal effects on these habitats. Any potential effects to lava caps would be minimized through implementation of Design Criteria B1, IP1, IP2, IP3, and IP4 .

EFFECTS TO FSS INDIVIDUALS

Barren, grassland, and lava cap habitats are not proposed for treatment, and therefore there is minimal potential for direct effects to big-scale balsamroot, Pleasant Valley mariposa lily, yellow-lip pansy monkeyflower, and yellow bur navarretia. In addition, these species could potentially benefit from the proposed fuel reduction treatments, which would create openings within chaparral or open forest habitats, promoting an increase in herbaceous species diversity.

Known populations of Pleasant Valley mariposa lily and yellow bur navarretia would be further protected through implementation of Design Criteria B1, B2, B3, and B4. As described previously, Design Criteria B1 requires flagging and avoidance of any lava caps within the Treatment Units. Design Criteria B2 states that botanical surveys would be conducted prior to project implementation in areas of potential habitat and/or areas with surveys older than 5 years for FSS plants. As described in Design Criteria B3 and B4, any FSS plant populations identified during surveys would be flagged for avoidance during implementation of mastication and fire line construction/ignition. Fire would be permitted

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to back into occurrences if burning is outside of the active growing season. Hand felling of trees and shrub removal may be conducted within occurrences if it is determined effects would be minimal or there will be beneficial effects on the site or habitat conditions. Piles shall be located outside of flagged areas. Design Criteria B4 requires consultation with a botanist prior to new fire line construction. With implementation of Design Criteria, the potential for direct effects would be minimized.

CHAPARRAL HABITAT AND ASSOCIATED SPECIES

Chaparral habitat is relatively uncommon in the Analysis Area, comprising only approximately 1,792.29 acres, or about 3 percent of all habitat in the Analysis Area. Approximately 98.52 acres of chaparral habitat would be treated as part of the proposed Project (approximately 3.5 percent of the total acreage proposed to be treated). Chaparral habitat is present as small patches within Treatment Units 1 through 7, 11 and 12, where it occurs primarily along ridgetops and south or southeast-facing slopes. Two of the eight FSS species addressed in this analysis are associated primarily with grasslands, barren, and lava cap habitats, but may also occur in openings within chaparral habitat. These are big-scale balsamroot and Pleasant Valley mariposa lily.

EFFECTS TO HABITAT

Current knowledge on the effects of fuel treatments comes primarily from studies of tree-dominated habitats, and there is limited information on how such treatments affect shrubland ecosystems (Brennan and Keeley 2017). Available research indicates that, while mastication and prescribed fire treatments are generally compatible with the ecology of forested habitats (refer below), such treatment are likely incompatible with the ecology of chaparral habitats (Keeley 2010).

A study by Brennan and Keeley (2017) on masticated shrub communities in southern California found that mastication resulted in a shift in the structure and composition of treated communities in comparison to undisturbed chaparral. The largest change was a substantial increase in density and diversity of annuals and herbaceous perennials, and particularly of non-native species. The predominance of non-native species following mastication has also been documented by other researchers (Potts and Stephens 2009). This change in composition may also reduce soil stability and leave chaparral stands vulnerable to increased erosion. Finally, decomposition in chaparral habitats is slow, and, if subject to a wildfire event, woody debris left in mastication sites may result in prolonged soil heating, with temperatures capable of damaging structures and killing seeds and microorganisms within the soil. This effect was found when depth of woody debris was 7.5 centimeters (approximately 3 inches) or greater (Busse et al. 2005 in Brennan and Keeley 2017).

Prescribed fire may also negatively impact chaparral habitat. Under historical conditions, montane chaparral habitats likely burned every few decades, primarily as a result of lightning strike. Wildfires within chaparral are typically high-intensity crown fires that occur in the late summer and fall during dry conditions (Keeley and Fotheringham 2001 in Knapp et al. 2009). Prescribed fire, on the other hand, is typically of lesser intensity, and conducted earlier in the year than the natural fire regime (Keeley 2010, Knapp et al. 2009). In addition, prescribed fire is often implemented at more frequent intervals than the natural fire regime (Keeley 2010). Alteration in the natural fire regime can result in a reduction in dominant native shrubs due to a lack of resprouting and lack of formant seed banks, which can in turn result in conversion of native shrublands to non-native grass and forb habitats (Keeley 2010).

The proposed fuels reduction treatments could therefore potentially negatively affect chaparral habitats within the Treatment Units by altering stand structure and composition, and increasing the potential for the introduction and spread of NNIPs. Chaparral habitats comprise a very small portion of the land to be treated (approximately 3.5 percent), and are small and patchily distributed within the Treatment Units where they occur. The Project is designed to retain a minimum of 10 percent live shrub cover, so that a portion of the existing root systems would remain as a basis for soil stability. Additionally, the Project includes several Design Criteria to minimize the potential for the introduction and spread of non-native invasive species following treatment of chaparral habitats. Design Criteria IP1 states that, prior to project activities, high-priority infestations identified in Map 3 would be flagged for avoidance and/or treated using

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integrated pest management techniques in accordance with the design features of the Eradication and Control of Invasive Plants Environmental Assessment (ENF 2013). If Project activities cannot be completely avoided within flagged infestations, risk minimization strategies shall be employed, such as working in the infested area last, working in infested areas when propagules are not viable, limiting the number of people or equipment within the infestation, and cleaning mechanical and hand equipment, clothing, boots, etc., before moving to other un-infested NFS lands (refer to Design Criteria IP2). Design Criteria IP3 requires cleaning of off-road equipment prior to entering NFS lands; Design Criteria IP4 requires use of certified weed-free erosion control materials; and Design Criteria IP5 requires that only locally sourced, botanist-approved seed be used for erosions control.

Considering that chaparral comprises only 3.5 percent of the total area to be treated; that habitats proposed for treatment are small and scattered widely over Treatment Units; and with implementation of Design Criteria to minimize the potential for the introduction and spread of noxious weeds, the effects of the Proposed Project on chaparral habitats would be minimal.

EFFECTS TO FSS INDIVIDUALS

Chaparral habitats provide suitable habitat for two FSS species considered in this analysis, big-scale balsamroot and Pleasant Valley mariposa lily. Provided below is a brief analysis of the potential for direct and indirect (habitat-related) effects to these species.

Direct effects to big-scale balsamroot or Pleasant Valley mariposa lily could potentially include crushing from operation of ground-based equipment (e.g., masticators), burial under woody debris placed on the ground post-mastication, or loss of individuals during prescribed fire. Soil could also potentially be disturbed in the event that the grinding head of the masticator comes into contact with the soil/litter layer. As described previously, big-scale balsamroot and Pleasant Valley mariposa lily would be avoided and protected through implementation of Design Criteria B2, B3, and B4. These measures require botanical surveys prior to project implementation in areas of potential habitat and/or areas with surveys older than 5 years; flagging of known populations; and exclusion of mastication and fire line construction/ignition within flagged areas. Fire would be permitted to back into occurrences if burning is outside of the active growing season. Hand felling of trees and shrub removal may be conducted within occurrences if it is determined effects would be minimal or there will be beneficial effects on the site or habitat conditions. Piles shall be located outside of flagged areas. Implementation of these Design Criteria would minimize the potential for direct effects to individuals.

In the case that FSS populations are present in chaparral habitats proposed for treatment, these populations may benefit to some degree from the removal of competing overstory vegetation and increased exposure to sunlight, although this benefit may decrease over time, because post-treatment conditions in chaparral habitats tend to favor annual species, including NNIPs. As described previously, Design Criteria IP1, IP2, IP3, and IP 4 would be implemented to minimize the potential for the introduction or spread of NNIPs.

In summary, the potential for adverse effects to big-scale balsamwood and Pleasant Valley mariposa lily is low considering that only 3.5 percent of acres to be treated support shrub-dominated/chaparral habitats, that these habitats are small and scattered throughout the Treatment Units, that habitat quality is typically po or in areas to be treated, and that treatments are unlikely to affect below-ground plant structures. Furthermore, herbaceous species such as big-scale balsamwood and Pleasant Valley mariposa lily may potentially benefit from thinning of shrubs and exposure to sunlight post-treatment. Implementation of Design Criteria to protect known FSS populations and to minimize the potential for the introduction and spread of noxious weeds would further minimize the potential for effects.

FOREST HABITAT

The Treatment Units are composed primarily of tree-dominated habitats, which comprise approximately 2,861.58 acres or 96 percent of the land within the Treatment Units. Four of the eight FSS species addressed in this analysis are

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associated primarily with forest habitats. These are mountain lady’s slipper, branched collybia, olive phaecollybia, and Sierra bluegrass.

EFFECTS TO HABITAT

Fuels reduction treatments that include thinning of trees and prescribed fire are generally considered compatible with Sierran forest ecosystems (Keeley 2010, Goodwin et al. 2018, Knapp et al. 2009). However, few studies specifically address the impacts of mastication on understory vegetation, including FSS plants. Several studies have shown that thinning treatments (including mastication) enhance understory vegetation, but may also potentially enhance non-native invasive species (Franklin 2010). Wayman and North (2007) found that impacts on understory flora vary based on the nature of treatment, and that thinning (e.g., mastication) increases richness and cover of understory species, but only when followed by fire. A 2010 study of the effects of mastication on forest floor fuels, soil structure, and vegetation composition and diversity in a ponderosa pine forest showed an increase in downed woody debris and duff, no change in soil nutrient levels, and overall greater cover and diversity as compared to control sites (Franklin 2010).

Prior to fire exclusion, forested regions in California burned in low- to mixed-severity fires at approximately 8- to 3-year intervals, depending on forest type (Skinner and Chang in Knapp et al. 2009). While the effects of fire vary based on species, fire intensity, scale, and season, published literature on prescribed fire in western forest ecosystems indicates that most species are resilient to fire (Goodwin et al. 2018, Knapp et al. 2009). In its 2010 special issue on the effects of fire on native plants, the California Native Plant Society stated that “Most forests in our region have evolved along with frequent low intensity surface fires. As a consequence, the use of frequent prescription burning to reduce hazardous fuels is compatible with much of the flora and fauna.” Several studies have indicated an increase in productivity and diversity of understory species following fire (Sackett and Haase 1998 in Knapp et al. 2009; Goodwin 2018). However, the nature and degree of the effects is likely related to how closely prescribed fire mimics the historical fire regime in terms of timing and frequency (Knapp et al. 2009).

EFFECTS TO FSS INDIVIDUALS

Forest habitats provide suitable habitat for four FSS species considered in this analysis, mountain lady’s slipper, branched collybia, olive phaecollybia, and Sierra bluegrass. Provided below is a brief analysis of the potential for direct and indirect (habitat-related) effects to these species.

As described previously, there is a known occurrence of branched collybia located at the northern edge of Treatment Unit 16. Direct effects to this population and any previously unknown populations of mountain lady’s slipper, branched collybia, olive phaecollybia, and Sierra bluegrass resulting from mastication could include crushing from operation of ground-based equipment (e.g., masticators), burial under woody debris placed on the ground post-mastication, or loss of individuals during prescribed fire. The two mushrooms rely on subsurface mycelial structures, and mountain lady’s slipper requires associations with mycorrhizal fungi for carbon and other nutrients throughout several stages in their life cycle. Therefore, these species in particular could be negatively affected by ground disturbance if the grinding head of the masticator comes into contact with the soil/litter layer. Botanical species have variable responses to fire, dependent on fire intensity and scale. Low intensity fire may be tolerated or even beneficial for maintaining suitable habitat for species that utilize mid- to late-seral forest types. Studies suggest that low-intensity prescribed fires in which the organic layer remains largely intact would have little or no impact on fungi (Jonsson et al. 1999, Korb et al. 2003).

Any direct effects resulting from mastication would be avoided, to the extent practicable, through implementation of Design Criteria B2, B3, and B4. These measures require botanical surveys prior to project implementation in areas of potential habitat and/or areas with surveys older than 5 years; flagging of known populations; and exclusion of mastication and fire line construction/ignition within flagged areas. Fire would be permitted to back into occurrences if burning is outside of the active growing season. Hand felling of trees and shrub removal may be conducted within occurrences if it is determined effects would be minimal or there will be beneficial effects on the site or habitat conditions. Piles shall be located outside of flagged areas. With implementation of Design Criteria, the potential for

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direct effects to FSS species would be minimized. Note that mushroom species do not produce fruiting bodies in all years, and therefore surveys may not be a reliable indicator of the presence of this species.

Mountain lady’s slipper, branched collybia, and olive phaecollybia require shade, protected microclimates, and infrequently disturbed substrates. These species could, therefore, potentially be affected by changes in canopy cover, forest structure, or reductions in the presence of litter or woody debris. These indirect impacts would be minimized by the fact that only stands with an over-abundance of smaller trees and shrubs in the understory would be treated. Within these stands, only smaller trees would be removed; trees measuring 10 inches dbh or greater would be generally be retained, so that canopy cover and root structure of the most mature trees would remain. Masticated vegetative debris would be retained on the forest floor, and generally be less than 4 inches deep with pieces less than 18 inches long. Project Design criteria would further minimize adverse changes in forest structure. As required by Design Criteria PB2, snags 16 inches in diameter or greater would be retained during burn preparation and would not be targeted for ignition except where they pose a threat to human health and safety, or where they need to be cut for perimeter containment of the prescribed fire. Design Criteria PB3 states that downed logs greater than 16 inches diameter would not be actively lit during implementation of the prescribed burn. Under Design Criteria TW3, downed logs greater than 16 inches in diameter would be retained both during mastication treatments and follow-up prescribed fire treatments, to the extent practicable.

The remaining species, Sierra bluegrass, occurs in openings within forest habitats, including forest gaps and edge habitats. Project activities such as thinning, mastication, and prescribed burn, will generally create more open habitats throughout the Treatment Units. These conditions will have generally benefit species that prefer forest openings.

CUMULATIVE EFFECTS

The spatial boundary for analyzing the potential cumulative effect to FSS plants is the same as the Analysis Area (i.e., 1.5 mile around the proposed Treatment Units) and encompasses approximately 52,353 acres.

Cumulative effects represent (40 CFR 1508.7) the “impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such actions.” In order to understand the contribution of past actions to the cumulative effects of the proposed action this analysis relies on current environmental conditions as a proxy for the impacts of past actions. Existing conditions reflect the aggregate impact of all prior human actions and natural events that affected the environment and might contribute to cumulative effects.

Land disturbances that have been documented in the cumulative effects area in the past include; timber harvest, road construction and maintenance, fuel treatments, cattle grazing, introduction of non-native species, dispersed camping, developed camping and hiking trails, off highway vehicle (OHV) usage, and the construction of private structures.

Climate change effects on precipitation and mean temperature have been difficult to predict with considerable variation between different models. The most common prediction among the most recent models for California is temperature warming by about 9 degrees F by 2100, with precipitation remaining similar or slightly reduced compared to today. Most models agree that summers would be drier than they are currently, regardless of levels of annual precipitation. Current estimates of predicted climate change on vegetation patterns forecast that forest types and other vegetation dominated by woody plants in California would migrate to higher elevations as warmer temperatures make those areas suitable for colonization and survival (Lenihan et al. 2003). However, rare and uncommon species are expected to experience a number of barriers when adjusting to a rapidly changing climate because of the combination of a small number of occurrences, narrow elevational ranges, and requirements for specific soils types. Some of the FSS plant species (Pleasant Valley Mariposa lily) with potential habitat in project area are restricted to limited areas within the forest. Plants confined to outcrops of special soils are generally expected to have a lower chance of successful dispersal to suitable new sites and thus far greater risks of extinction in the face of climate change, than plants that are soil generalists. Because of the uncertainty in scale, direction, and rate of future climate change, current management of sensitive species on the ENF would focus maintaining viable populations throughout the species known range.

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The following future projects are considered in this analysis:

• ENF Twofer Fuels Reduction Project: This project includes fuels reduction treatments on ENF lands to the south of Union Valley Reservoir. All proposed treatment areas are to the east of the Sly Park Fuel Reduction Project Treatment Units, with only minimal overlap with the Analysis Area.

• EID Vegetation Management Project: This project, implemented by EID, involves mastication, hand-cutting and piling on 370 acres along the north side of Weber Reservoir (a small portion of which falls inside the Analysis Area) and 118.5 in the vicinity of Jenkinson Lake (within 100 feet of the lake and within 75 feet of tributaries to the lake).

• Fire Adapted 50 Projects: This is a collaborative effort between CAL FIRE, and the El Dorado County and Georgetown Divide Resource Conservation Districts (RCD) in collaboration with Federal, State and local agencies and private landowners to form a long-term cohesive strategy to establish a more fire resilient WUI condition with a focus on the Highway 50 corridor. Known as the “Fire Adapted 50” the project includes forest treatments that would connect fuels breaks on both public and private lands to create fire resilient forest ecosystems and fire-adapted communities. Portions of the Fire Adapted 50 planned for 2019 and 2020 include Phase 1a (1,000 acres), Phase II (1,494 acres), and Phase SNC (450 acres).

• PPCFSC Weber Creek Fuels Reduction Project: This project involves approximately 287 acres of fuels reduction treatments to protect communities located within the Weber Creek watershed, in the vicinity (and in several cases immediately adjacent to) Treatment Units included in the Proposed Action.

The Twofer Fuels Reduction Project, EID Vegetation Management Project, Fire Adapted 50 Projects, and PPCFSC Weber Creek Fuels Reduction Projects propose treatments that are very similar to the Proposed Action, but focused in different portions of the Analysis Area. The effects of the treatments on FSS populations and habitat, as well, would be similar to the Proposed Action. Project Design Criteria would limit the potential for direct effects to known populations and minimize the potential for the introduction or spread of non-native invasive. Fuels reduction treatments would have variable effects to habitat, based on treatments implemented, species present, timing and intensity of prescribed fire, and other site-specific factors. Some species are expected to benefit from the reduction in competing vegetation and access to sunlight. For other species, the combined actions of the projects considered may represent a minor cumulative effect on the availability and suitability of habitat.

VI. DETERMINATION SUMMARY

There is no potential habitat for Allium tribracteatum, Arctostaphylos nissenana, Botrychium ascendens, Botrychium crenulatum, Botrychium lunaria, Botrychium minganense, Botrychium montanum, Botrychium paradoxum, Botrycium pendunculosum, Bruchia bolanderi, Draba asterophora var. asterophora, Draba asterophora var. macrocarpa, Eriogonum tripodum, Helodium blandowii, Horkelia parryi, Lewisia kelloggii ssp. hutchisonii, Lewisia kelloggii ssp. kelloggii, Lewisia longipetala, Lewisia serrata, Meesia uliginosa, Mielichhoferia elongate, Ophioglossum pusillum, Packera layneae, Peltigeria gowardii, Phacelia stebbinsii, and Pinus albicaulis in the project area. Therefore the Sly Park Fuels Reduction Project would not affect these species.

Suitable habitat is present for Balsamorhiza macrolepis var. macrolepis, Cypripedium montanum, Diplacus pulchellus, Phaecollybia olivacea, and Poa sierra, and there are known occurrences of Calochortus clavatus var. avius, Dendrocollybia racemosa and Navarretia prolifera ssp. lutea. Direct effects to all of these species would be minimized through implementation of botanical surveys and flagging known populations. Mastication and prescribed fire line construction/ignition would generally be excluded from flagged areas; and implementation of other activities would be implemented only where considered beneficial or otherwise permissible in consultation with a botanist.

B. macrolepis var. macrolepis, C. clavatus var. avius, D. pulchellus, and N. prolifera ssp. lutea are associated primarily with grasslands, barren, and lava cap habitat. Considering that barren and grassland habitats are not proposed for treatment, the Project would have no or minimal effects on these habitats. Any potential effects to lava caps would be minimized through implementation of Design Criteria which require flagging and avoidance of lava caps; and implementation of measures to minimize the potential for the introduction or spread of NNIPs. B. macrolepis var.

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macrolepis and C. clavatus var. avius may also be found within chaparral habitat. Available research indicates that, while mastication and prescribed fire treatments are generally compatible with the ecology of forested habitats (refer below), such treatment are likely incompatible with the ecology of chaparral habitats (Keeley 2010). However, considering that chaparral comprises only 3.5 percent of the total area to be treated; that habitats proposed for treatment are small and scattered widely over Treatment Units; and with implementation of Design Criteria to minimize the potential for the introduction and spread of noxious weeds, the effects of the Proposed Project on chaparral habitats would be minimal. C. montanum, D. racemose, P. olivacea, and P. sierra are associated primarily with forest habitats, which are found on approximately 96 percent of the land within the Treatment Units. Fuels reduction treatments that include thinning of trees and prescribed fire are generally considered compatible with Sierran forest ecosystems (Keeley 2010, Goodwin et al. 2018, Knapp et al. 2009).

Considering that habitat-level effects will be variable; and because surveys cannot positively state the absence of a sensitive plant species it is possible that, even with implementation of Design Criteria, the proposed project could affect B. macrolepis var. macrolepis, C. clavatus var. avius, C. montanum, D. racemose, D. pulchellus, N. prolifera ssp. lutea, P. olivacea, and P. sierra. Therefore, the Sly Park Fuels Reduction Project may affect individuals but is not likely to result in a trend toward Federal listing or loss of viability for the eight species listed above.

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VII. LITERATURE CITED

Brennan, T.J. and J.E. Keeley. 2017. Impacts of Mastication Fuel Treatments on California, USA, Chaparral Vegetation Structure and Composition. Fire Ecology, Vol. 13, 120-138. December 2017.

Brown, Matt. 2019. E-mail communications between/data provided by Matt Brown, ENF botanist, and Sara Reece, senior consultant Janelle Nolan & Associates Environmental Consulting between August 5 and August 8, 2019.

California Native Plant Society, Rare Plant Program. 2019. Inventory of Rare and Endangered Plants of California (online edition, v8-03 0.39). Website http://www.rareplants.cnps.org [accessed 14 August 2019].

https://www.eldoradocnps.org/plant-places/plant-hotspots/lava-caps

Castellano, M.A., E. Cazares, B. Fondrick, and T. Dreisbach. Handbook to Additional Fungal Species of Special Concern in the Northwest Forest Plan. USDA Forest Service, Pacific Northwest Research Station. General Technical Report PNW-GTR-572. January 2003.

Goodwin, M.J., M.P. North, H.S.J. Zald, and M.D. Hurteau. 2018. The 15-year post-treatment response of a mixed-conifer understory plant community to thinning and burning treatments. Forest Ecology and Management 429: 617-624.

Keeley, J.E. Fire on California Landscapes. Fremontia. Volume 38:2/38.3. April/July 2010.

Knapp, E.E., B.L. Estes, C.N.Skinner. Ecological Effects of Prescribed Fire Season: A Literature Review and Synthesis for Managers. USDA Forest Service, Pacific Northwest Research Station. General Technical Report PNW-GTR-224. September 2009.

Lenihan, J.M., R. Drapek, D. Bachelet, and R.P. Neilson. 2003. Climate change effects on vegetation distribution, carbon, and fire in California. Ecological Applications 13: 6, 1667-1681. December 2003.

North, M., P. Stine, K. O’Hara, W. Zielinski, and S. Stephens. 2009. An ecosystem management strategy for Sierran mixed-conifer forests. USDA For. Serv., Gen Tech. Rep. PSWGTR-220, Pacific Southwest Research Station, Albany, CA.

Potts, J.B., and S.L. Stephens. 2009. Invasive and native plant responses to shrubland fuel reduction: comparing prescribed fire, mastication, and treatment season. Biological Conservation 142: 1657–1664.

Shefferson, R.P., M. Weiss, T. Jull, and D.L. Taylor. 2005. High specificity generally characterized mycorrhizal association in rare lady’s slipper orchids, genus Cypridpedium. Molecular Ecology 14, 613-626. 2005.

USDA, Forest Service. 1989. Eldorado National Forest Land and Resource Management Plan.

USDA, Forest Service. 2001. Sierra Nevada Forest Plan Amendment: Final Environmental Impact Statement, vols 1-6, including appendices, and Record of Decision. U.S. Department of Agriculture, Forest Service, Pacific Southwest Region, Vallejo, California.

USDA, Forest Service. 2004. Sierra Nevada Forest Plan Amendment Final Supplemental Environmental Impact Statement Record of Decision. Vallejo, CA: USDA, Forest Service, Pacific Southwest Region, 72.

USDA, Forest Service. 2011. Soil and Water Conservation Handbook, R5 FSH 2509.22. Chapter 10. Water Quality Management Handbook. Vallejo, CA: USDA Forest Service, Pacific Southwest Region, 261.

USDA, Forest Service. 2012. National best management practices for water quality management on National Forest system lands. National Core BMP Technical Guide, Washington, DC: US Department of Agriculture, Forest Service, 165.

Wayman, R.B, and M. North. 2007. Initial response of a mixed-conifer understory plant community to burning and thinning restoration treatments. Forest Ecology and Management 239: 32-44.

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Appendix A

Non-Native Invasive Plant List for the Eldorado National Forest

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Group 1 (Eradicate): Highly invasive species known to occur on the Eldorado National Forest. Species are uncommon and are a priority for inventory, control, and eradication. Acroptilon repens Russian knapweed Aegilops triuncialis barbed goatgrass Ailanthus altissima Chinese tree of heaven Arundo donax Arundo Centaurea calcitrapa purple starthistle Centaurea diffusa diffuse (white) knapweed Centaurea stoebe spotted knapweed

Cirsium arvense Canada thistle Euphorbia oblongata oblong spurge Isatis tinctoria dyer’s woad Lepidium latifolium tall whitetop Lythrum salicaria purple loosestrife Sorghum halepense Johnson grass

Group 2 (Control): Established or widespread species known to occur on the Eldorado National Forest. Inventory all infestations. Annually treat a portion of known infestations, focusing first on eradicating/containing isolated outlying infestations and, over time, reducing the footprint of larger, less isolated infestations. Carduus pycnocephalus Italian thistle Centaurea melitensis tocalote Centaurea solstitialis yellow starthistle Chondrilla juncea rush skeleton weed Cytisus scoparius Scotch broom

Elymus caput-medusae medusahead Foeniculum vulgare Fennel Genista monspessulana French broom Spartium junceum Spanish broom

Group 3 (Control): Established or widespread species known to occur on the Eldorado National Forest. Inventory and treat isolated leading-edge infestations or where concurrent with higher priority infestations. Brassica nigra black mustard Bromus tectorum cheat grass Chenopodium botrys Jerusalem-oak goosefoot Cirsium vulgare bull thistle Hedera helix English Ivy Hypericum perforatum Klamath weed Lathyrus latifolius perennial sweet pea Leucanthemum vulgare Oxeye daisy Melilotus alba white sweet clover

Melilotus officinalis yellow sweet clover Rubus armeniacus Himalayan blackberry Rubus laciniatus cut leaf blackberry Salsola tragus Russian thistle/tumbleweed Silybum marianum milk thistle Torilis arvensis hedge parsley Tribulus terrestris puncture vine Vinca major periwinkle

Group 4 (Manage through education and prevention): Species are well established across forest or have minor economic or ecological impacts. Forest will use appropriate prevention and education measures to limit further spread. Bromus diandrus ripgut brome Bromus madritensis var. rubens red brome Conium maculatum poison hemlock Cynodon dactylon Bermuda grass Cynosurus echinatus spiny dogtail Dactylis glomerata Orchard grass

Festuca arundinacea tall fescue Hirschfeldia incana mustard Lychnis coronaria rose campion/ mullein pink Sisymbrium altissimum Jim Hill mustard Verbascum thapsus mullein

Potential Invasives: Species not yet found on the Eldorado National Forest. If found, infestations should be inventoried and targeted for eradication or control. Aegilops cylindrica Jointed goatgrass Cardaria chalepensis small whitetop Cardaria draba hoarycress Cardaria pubescens whitetop Carduus nutans musk thistle Carthamus lanatus Woolly distaff thistle Centaurea pratensis meadow knapweed Centaurea sulphurea Sicilian starthistle Cortaderia selloana pampas grass Dittrichia graveolens stinkwort Dactylis glomerata Orchard grass Euphorbia esula leafy spurge

Linaria genistifolia ssp. dalmatica dalmatian toadflax Linaria vulgaris yellow toadflax Nicotiana glauca Tree tobacco Onopordum acanthium Scotch thistle Phragmites australis common reed Polygonum cuspidatum Japanese knotweed Polygonum sachalinensis Sakhalin knotweed Potentilla recta Sulfur cinquefoil Sesbania punicea Scarlet wisteria Tamarix chinensis Salt Cedar Tanacetum vulgare tansy Ulex europaeus Gorse

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Appendix B

Non-Native Invasive Plant Risk Assessment

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Eldorado National Forest

Non-Native Invasive Plant Risk Assessment

PROJECT NAME: Sly Park Fuels Reduction Project

PURPOSE: The Sly Park Fuels Reduction Project (Project) is part of an all-lands approach that will connect fuel breaks on the Eldorado National Forest (ENF) with fuel breaks on adjacent lands to create resilient forest ecosystems and fire-adapted communities. The purpose of the treatments is to reduce understory ladder and surface fuels to ameliorate wildfire behavior and facilitate the future application of prescribed fire.

RANGER DISTRICT: Placerville DATE: August 2019

PROJECT DESCRIPTION:

The Placerville Ranger District is proposing 19 Treatment Units on approximately 3,000 acres of natural stands which are dense with trees of varying size, shrubs, and surface fuels and therefore at risk of loss to wildfire. A combination of thinning, chipping/mastication of brush and smaller trees, and hand treatments including brush cutting, hand thinning, and pruning would be used to reduce tree density in selected stands and to change the structure of live and dead material in treated stands. The most cost efficient and effective treatment within each stand would be chosen based on timing, equipment availability, and post treatment results, but would generally be implemented as follows:

• Stands which have an over-abundance of smaller trees and shrubs in the understory would be masticated or chipped. This includes masticating live and dead conifer trees (generally measuring less than 10 inches in diameter at breast height [dbh]) and shrubs. Mastication would generally be applied on slopes up to 45 percent and road edges adjacent to units.

• Residual trees may be pruned to a height of 10 to 12 feet to reduce ladder fuels.

• Stands where mastication is infeasible or restricted (e.g. streamcourse buffers, wildlife Protected Activity Centers [PACs] outside the WUI [SNFPA, 2004]) would be hand thinned.

• All stands are proposed for follow-up prescribed understory burning using ground based or aerial ignition methods after initial mechanical and manual treatments are completed to further reduce fuel loads and reintroduce fire to the ecosystem.

The Project includes Design Criteria to minimize the potential for effects related to Aquatic Wildlife and Water; Botanical Resources; Cultural Resources; Non-Native Invasive Plants (NNIPs); Prescribed Burning; Public Safety, Residences, and Recreation Sites; Soils; and Terrestrial Wildlife.

PROJECT LOCATION: The Project is located on the Placerville Ranger District of the ENF within the Southern Fork American River, Norther Fork Weber Creek, Sly Park Creek, Camp Creek, and Upper and Lower North Fork Consumnes Creek watersheds, between approximately 3,200 and 4,200 feet above mean sea level (msl).

VEGETATION COVER TYPES WITHIN ANALYSIS AREA1: The Treatment Units are predominately characterized by tree-dominated forest habitats, the large majority of which are Sierran mixed conifer (SMC), with smaller inclusions of ponderosa pine (PPN), montane hardwood (MHW), montane hardwood-conifer (MHC) and less than approximately 1 percent combined of blue oak woodland (BOW), blue oak-foothill pine (BOP), and douglas-fir (DFR).

1 The Analysis Area is defined to include all areas within 1.5 miles of the proposed Treatment Units.

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Also pertinent to this analysis is chaparral or shrub-dominated habitat, which comprises approximately 3.5 percent of the total area of the Treatment Units. Grassland habitat, and barren/urban areas together comprise approximately 1 percent of the total area of the Treatment Units.

RISK FACTORS (assuming no NNIP prevention measures)

1. NNIPs Present in the Analysis Area: High Moderate X Low

Explain: ENF data indicate presence of the following species in the Analysis Area:

• Barbed goatgrass (Aegilops triuncialis)

• Yellow-starthistle (Centaurea solstitialis)

• Rush skeletonweed (Chondrilla juncea)

• Medusahead (Elymus caput-medusa)

Refer to Map 3 of the Botanical BE for the location of NNIPs that have been documented in the Project area. Given the proximity of the Treatment Units to urban and recreational developments and the lack of current survey coverage, additional non-native invasive species are assumed to be present within developed areas, along roads, and in open or disturbed areas. The number and prevalence of non-natives is likely reduced within shaded forest habitats. The previous existence of NNIPs in the Analysis Area represents a moderate risk in terms of the spread of NNIPs to previously uninvaded areas.

2. Habitat Vulnerability: High Moderate Low X

Explain: The proposed treatments would thin and remove trees and shrubs within units that are predominantly densely vegetated either with small trees, small trees and shrubs, or sparse understory vegetation with a dense overstory of mixed conifer species. Stands such as the ones identified for this project are common on the ENF. Past experience suggests that the vegetation is composed of native species and the degree of shade under these stands is not conducive to NNIP establishment. The project does propose to temporarily reduce native vegetation cover, which may provide enough sunlight for some NNIPs.

Intact upland forest habitats are largely resilient to invasion of NNIPs. When openings are created (roadways, prescribe fire, thinning projects) annual grasses, bull thistle (Cirsium vulgare), mullein (Verbascum thapsus), and other non-native species often become establish following the disturbance. However, these infestations rarely form dense monocultures and are easily outcompeted by native trees and shrub regeneration. Therefore, the vulnerability of this habitat would be considered low.

Removal of overstory canopy within chaparral/shrub-dominated habitats, would result in an increase in habitat for herbaceous species, including NNIPs. However, only 3.5 percent of the total area to be treated supports chaparral habitat.

Sensitive lava cap communities are known to occur in the Analysis Area. These communities are vulnerable to NNIP invasion if propagules are introduced. The potential for introduction of additional NNIPs as a result of the proposed Project is low, as lava caps will be flagged and excluded from treatment. Unfortunately, non-native annual grasses have already become established as a minor component of many lava cap plant communities on the forest.

Considering that forest habitats would have a relatively low vulnerability to invasion; that lava caps would be avoided and typically already have established NNIPs; and that shrub habitats, while moderately vulnerable, comprise only a very small portion of the land to be treated, the overall vulnerability of habitat to NNIP invasion would be considered low.

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3. Habitat Alteration: High Moderate Low X

Explain: The proposed Project would result in some short-term habitat alteration due to mastication, prescribed fire, and hand thinning. These activities can temporarily increase the amount of light reaching the ground and, in some instances, the exposure of bare mineral soil. This is significant because seeds of potential and known NNIPs all require sunlight and contact with mineral soil for germination and growth, increasing the likelihood for germination following the treatments. However, these effects are expected to be limited in scope and will diminish as native understory species are able to reestablish into the recently disturbed areas.

Long-term habitat alterations associated with the Project are expected to be minimal. Thinning and subsequent prescribed burning within forested habitats will remove smaller trees from the stand while leaving mature conifers in the overstory. As stated above, treatments within chaparral/shrub-dominated habitats would result in an increase in habitat for herbaceous species, including NNIPs. However, only 3.5 percent of the total area to be treated supports chaparral habitat. 10 percent of existing shrub cover would be retained, and, over the longer term, native shrubs have are expected to resprout or geminate in the years immediately following mastication and fire. Thus, long-term habitat alterations conducive to the spread and establishment of NNIPs (i.e. increased bare ground and light) are not expected. During the interim period required for native vegetation to re-establish in the understory it is important to monitor and remove any new noxious weeds that may spread into newly open areas created immediately after the fire.

Considering that the Project will retain mature trees and 10 percent of existing shrub cover, and will not result in long-term habitat alteration, the risk associated with habitat alteration would be considered low.

4. Increased NNIP Vectors Resulting from Project Implementation High Moderate X Low

Explain: There are risks associated with Project as a result of project-related vehicle use (ground-based masticators, trucks). Potential introduction of NNIPs may occur when equipment is first brought into the Project area or if equipment travels or is used within existing infestations in the Project area. Another potential vector for NNIPs to Project activities is the importation of erosion control material such as straw and seeds. The movement of ground-based equipment through infested areas would also pose a moderate short-term risk for vectors allowing for the introduction or spread of NNIPs into the project area.

RECOMMENDED MITIGATION TO MINIMIZE ABOVE RISKS: The following Design Criteria will be implemented to minimize the risk of introduction or spread of NNIPs:

IP1: Prior to project activities, high-priority invasive plant infestations identified in Map 3 of the Project Biological Evaluation for botanical resources shall be flagged for avoidance and/or treated using integrated pest management techniques in accordance with the design features of the Eradication and Control of Invasive Plants Environmental Assessment (ENF 2013).

IP2: If Project activities cannot be completely avoided within flagged infestations, risk minimization strategies shall be employed, such as working in the infested area last, working in infested areas when propagules are not viable, limiting the number of people or equipment within the infestation, and cleaning mechanical and hand equipment, clothing, boots, etc., before moving to other un-infested NFS lands. These areas shall be identified on Project maps.

IP3: All off-road equipment shall be cleaned to ensure it is free of soil, seeds, vegetative matter or other debris before entering NFS lands to reduce the potential for the introduction or spread of invasive plants. Prior to the start of operations, the Project administrator shall conduct a visual inspection for such debris.

IP4: Straw or mulch used for erosion control shall be certified weed-free. A certificate from the county of origin stating the material was inspected shall be required. On-site material from a weed-free area may also be used.

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IP5: Any seed used for erosion control or restoration shall be from a locally collected source and the species shall be approved by a botanist.

OVERALL RISK OF WEED INTRODUCTION AND SPREAD: The proposed Project will moderately increase the risk of NNIPs becoming established and spreading in the project area due to the removal of native vegetation, movement of vehicles and equipment in and out of the Treatment Units, and potential for importation of infested erosion control material. The anticipated NNIP response to the proposed action is moderate if recommended mitigations are not included. With incorporation of Design Criteria, it is anticipated that the risk of spreading and/or introducing noxious weeds would be reduced to a low level within forested habitats, and a moderate level within chaparral habitats.