Biological Assessment I Biological Evaluation 

Prepared for 

Black Hills Resilient Landscapes Project 

Environmental Impact Statement 

Black Hills National Forest 

2017 

Prepared By j?J..:.M ~' M Date Id'-/ 7 / 1 7 

Rylan Sprag e 

Northern Hills Ranger District Botanist 

1 
2

Contents

I. INTRODUCTION....................................................................................................................... 4

II. DESCRIPTION OF THE PROPOSAL ..................................................................................... 4

Purpose and Need ....................................................................................................................... 4

Project Area Description............................................................................................................. 5

Proposed Action (Alternative A) ................................................................................................ 5

Fuel Reduction and Prescribed Fire........................................................................................ 5

Enhancement of Hardwoods and Grasslands.......................................................................... 5

Pine Structural Stage Modification......................................................................................... 5

Summary Table....................................................................................................................... 6

No Action Alternative (Alternative B) ....................................................................................... 7

Affected Environment................................................................................................................. 7

III. THREATENED, ENDANGERED, AND PROPOSED SPECIES CONSIDERED AND 

ANALYZED................................................................................................................................... 8

IV. SPECIES INFORMATION...................................................................................................... 9

Prairie Moonwort (Botrychium campestre) .............................................................................. 15

Narrowleaf Grapefern (Botrychium lineare) ............................................................................ 16

Foxtail Sedge (Carex alopecoidea) .......................................................................................... 17

Mountain Lady’s Slipper (Cypripedium montanum)................................................................ 18

Yellow Lady’s Slipper (Cypripedium parviflorum) ................................................................. 19

Trailing Clubmoss (Lycopodium complanatum) ...................................................................... 20

Large Round-Leaf Orchid (Platanthera orbiculata) ................................................................ 20

Sage Willow (Salix candida) .................................................................................................... 21

Autumn Willow (Salix serissima)............................................................................................. 22

Bloodroot (Sanguinaria canadensis)........................................................................................ 23

Narrowleaf Peatmoss (Sphagnum angustifolium)..................................................................... 23

Highbush Cranberry (Viburnum opulus var. americanum) ...................................................... 24

Great-Spurred Violet (Viola selkirkii) ...................................................................................... 25

Suitable Sensitive Plant Habitat................................................................................................ 25

White Spruce Habitat................................................................................................................ 26

Hardwood Habitat Including Paper Birch and Bur Oak ........................................................... 26

Riparian Habitat Including Wetlands and Fens........................................................................ 26

Fens....................................................................................................................................... 26

Meadows................................................................................................................................... 27
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V. EFFECTS OF THE ALTERNATIVES ................................................................................... 27

Assumption for Analysis........................................................................................................... 28

Design Criteria for Botanical Resources................................................................................... 28

Analysis of Effects of the Proposed Action (Alternative A) .................................................... 30

Analysis of Effects for the No Action Alternative (Alternative B) .......................................... 36

VI. DETERMINATIONS OF EFFECT AND RATIONALE...................................................... 36

Literature Cited ............................................................................................................................. 39
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I. INTRODUCTION

The purpose of this biological evaluation is to analyze and determine the likely effects of the 

Black Hills Resilient Landscapes (BHRL) project alternatives on federally listed plant species 

(endangered, threatened, and proposed) and Forest Service sensitive species (2672.11 – Exhibit 

01; Plants). 

This Biological Evaluation (BE) conforms to legal requirements set forth under section 7 of the 

Endangered Species Act (ESA) (19 U.S.C. 1536 (c), 50 CFR 402.12 (f) and 402.14). Section 7(a) 

(1) of the ESA requires federal agencies to use their authorities to further the conservation of 

listed species. Section 7(a) (2) requires that federal agencies ensure any action they authorize, 

fund, or carry out is not likely to jeopardize the existence of federally listed species, or destroy or 

adversely modify designated critical habitat. 

Forest Service policy requires that a review of programs and activities, through a biological 

evaluation (BE), be conducted to determine their potential effect on threatened and endangered 

species, species proposed for listing, and sensitive species (FSM 2670.3). Under the ESA, a 

biological assessment (BA) must be prepared for federal actions that are “major construction 

activities” to evaluate the potential effects of the proposal on listed or proposed species. The 

contents of the BA are at the discretion of the federal agency, and will depend on the nature of 

the federal action (50 CFR 402.12(f)). A BE may be used to satisfy the ESA requirement to 

prepare a biological assessment. Preparation of a Biological Evaluation as part of the NEPA 

process ensures that TEPS species receive full consideration in the decision-making process. 

This document tiers directly to the Black Hills National Forest Land and Resource Management 

Plan (Forest Plan, as amended) and incorporates the analysis conducted for the BA/BE prepared 

for the Phase II Amendment (USDA Forest Service 2005). 

This BA/BE evaluates management activities of all action alternatives and associated mitigation 

measures as set forth in the Black Hills Resilient Landscapes Project Draft Environmental 

Impact Statement. Any actions in addition to or outside the scope of these activities will require 

further analysis and documentation. 

II. DESCRIPTION OF THE PROPOSAL

Purpose and Need

The Black Hills National Forest is proposing action to move landscape-level vegetation 

conditions in the project area toward Forest Plan objectives in order to increase ecosystem 

resilience to insect infestation and other natural disturbances, contribute to public safety and the 

local economy, and reduce risk of wildfire to landscapes and communities. Due to epidemic 

levels of mountain pine beetle activity in the project area over the past decade, the Forest has 

moved away from vegetation objectives identified in the Forest Plan. The epidemic now appears 

to be slowing in most parts of the Forest, and the Black Hills Resilient Landscapes Project 

intends to re-align Forest conditions with Forest Plan objectives.

The Black Hills Resilient Landscapes Project considers a proposed action (Alternative A) and a 

no action alternative (Alternative B). 
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Project Area Description

The project area includes National Forest System lands that are managed by the Black Hills 

National Forest within the areas designated by the Secretary of Agriculture under the amended 

Healthy Forests Restoration Act (HFRA, 16 U.S.C. 6591), excluding Inventoried Roadless Areas 

and certain management areas. The project area includes approximately 1,098,000 acres of NFS 

lands. 

The project area includes the following management areas (MAs):

Table 1: Management Areas

MA Emphasis Acres* Proposed activities

3.31 Backcountry motorized recreation 6,870 Fuels/hazard trees

3.32 Backcountry non-motorized recreation 8,948 Fuels/hazard trees

3.7 Late succession landscapes 18,484 Fuels/hazard trees

4.1 Limited motorized use and forest products 41,374 All

5.1 Resource production 558,520 All

5.1A Southern Hills forest and grassland 27,845 Fuels/hazard trees

5.2A Fort Meade VA Hospital watershed 3,299 Fuels/hazard trees

5.4 Big game winter range 388,950 All

5.43 Big game and resource production 10,083 All

5.6 Forest products, recreation, and big game 34,043 All

*MA acres in project area Total 1,098,425

Proposed Action (Alternative A)

The Forest Service is proposing to conduct the following land management activities in the 

project area, beginning in approximately 2018 and continuing for about 10 years. 

Fuel Reduction and Prescribed Fire

To increase ecosystem resilience and reduce wildfire hazard to landscapes and communities, the 

proposal includes mechanical fuel treatments (up to 7,000 acres per year), prescribed fire (up to 

10,000 acres per year), and hazard tree removal. Total acres implemented annually would depend 

on budget constraints and, for prescribed burning, weather conditions. 

Enhancement of Hardwoods and Grasslands 

The project would cut encroaching pine from areas of hardwoods and grasslands. Pine and 

spruce removal from aspen stands would take place on up to 2,400 acres. On up to 30,900 acres 

of pine stands, pine and spruce would be removed from aspen inclusions. Regeneration of 

declining aspen stands would occur on up to 4,000 acres. Pine removal from oak stands would 

take place on up to 5,400 acres. Pine would be cut from encroached grasslands on up to 14,200 

acres. 

Pine Structural Stage Modification

The following activities would occur in MAs 4.1, 5.1, 5.4, 5.43, and 5.6.
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Table 2: Structural stage totals – All relevant management areas combined

SS

Objective Existing Deviation 

from obj. Acres Percent Acres Percent

1 44,522 5% 78,306 9% +33,785

2 44,522 5% 54,102 6% +9,581

3A 89,043 10% 65,712 7% -23,331

3B 133,565 15% 42,273 5% -91,292

3C 44,522 5% 23,934 3% -20,588

4A 222,608 25% 423,388 48% +200,781

4B 222,608 25% 145,641 16% -76,967

4C 44,522 5% 53,088 6% +8,567

5 44,522 5% 3,987 <1% -40,536

Total 890,430 100% 890,430 100%

Overstory removal or uneven-age management would occur on up to 187,000 acres of SS 4A 

stands. These treatments would decrease 4A and increase younger structural stages, which are 

generally below Forest Plan objectives. Pre-commercial and/or POL thin would occur on up to 

25,000 acres per year to increase SS 3A and 3B and to promote growth toward 4B.

Patch cuts would occur on up to 1,300 acres in MA 4.1 and 600 acres in MA 5.6. This treatment 

would produce SS 1, which is below Forest Plan objectives in these MAs. Tree planting would 

occur on up to 5,000 acres per year in large burned areas in the southern Black Hills. Without 

planting, reforestation of these areas may require decades of growing. 

Mechanical site preparation would occur in open, mature pine stands on up to 4,000 acres in the 

western Black Hills where thick sod hinders establishment of pine seedlings. This action would 

expose soil, creating conditions favorable for establishment of pine.

Summary Table

Maximum activity acres and miles are displayed below. The amount implemented may be less.

Table 3: Treatment Summary

Fuel and hazard tree treatments

Mechanical and manual fuel treatments (shaded fuel break 

construction; thin, pile, and burn fuels; scatter, shred, or chip 

fuels; cut, lop, and scatter fuels); includes up to 4,000 acres of 

shaded fuel breaks with commercial removal

70,000 acres (7,000 acres 

per year)

Prescribed fire (broadcast; piles) 100,000 acres (10,000 acres 

per year)

Hazard tree treatments (cut; push; explosives; other) As needed and funded

Hardwood and grassland enhancement

Removal of pine/spruce from aspen stands 2,400 acres

Regeneration of aspen stands 4,000 acres

Removal of pine/spruce from aspen inclusions (possibly 

commercial) 22,500 acres

Removal of pine/spruce from aspen inclusions (non-commercial) 8,400 acres
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Removal of encroaching pine from oak stands 5,400 acres

Removal of encroaching pine from grasslands 14,200 acres

Pine structural stage modification

Overstory removal and uneven-age individual tree selection

By management area:

MA 4.1: Approximately 8,970 acres 

MA 5.1: Approximately 129,890 acres 

MA 5.4: Approximately 41,210 acres 

MA 5.43: Approximately 250 acres

MA 5.6: Approximately 6,790 acres 

187,000 acres

Precommercial and/or POL thin 250,000 acres (25,000 acres 

per year)

Patch cut

By management area: 

MA 4.1: 1,300 acres

MA 5.6: 600 acres

1,900 acres

Tree planting (MAs 5.1, 5.4, and 5.43) 5,000 acres

Mechanical site preparation 4,000 acres

Connected actions

Road construction – Specified 17 miles (expected: 7-10 miles)

Road construction – Temporary 39 miles (expected: 20-30 miles)

Temporary roads on existing templates 182 miles (expected: 120-150 miles)

Road conversion (unclassified to system) 20 miles

No Action Alternative (Alternative B) 

The National Environmental Policy Act (NEPA) requires the study of the No Action Alternative 

and it will be used as a basis for comparing the effects of the proposed action. 

The No Action Alternative assumes that no implementation of any elements of the action 

alternative will take place within the project area. This alternative represents no attempt to 

actively respond to the purpose and need for action or the issues, concerns, or comments 

identified during scoping. There would be no effort to modify existing vegetation and related 

fuels conditions in the project area. Vegetation structure would change over time through natural 

growth and mortality and events such as wildfires, storms, insects, and disease. None of the 

actions associated with the project would occur.

Actions such as ongoing and planned Forest protection efforts, fire suppression, noxious weed 

treatment, and recurring road maintenance on system roads would continue as directed by the 

Forest Plan. Vegetation management would not take place unless authorized by other decisions 

(see cumulative effects). 

Affected Environment

The BHNF is situated within the Middle Rockies ecoregion, surrounded on all sides by the Great 

Plains ecoregion (Omernik & Griffith 2014). Referred to as an Island in the Plains, the Black 

Hills encompass an area of 5,121 square miles (approximately three million acres). The varied 

topography, geology, and climate result in a corresponding variety in plant communities, 

including such diverse elements as ponderosa pine (Pinus ponderosa) forests typical of the 

western mountains, grasslands typical of the Great Plains, and white spruce (Picea glauca) 
8

forests typical of the boreal north. Midwest hardwood types are represented by stands dominated 

by oak, ash, and elm. Approximately 30 percent of the plant taxa in the Black Hills have their 

primary ranges to the west, though Midwestern, eastern, and northern associated taxa are also 

significantly represented in the local flora (McIntosh 1931). 

The Black Hills Community Inventory by the Nature Conservancy’s Midwest Conservation 

Science Center and the Midwestern Resources Center was the first systematic classification to 

describe the vegetation of the Black Hills by adopting the standardized National Vegetation 

Classification (Marriott et al. 1999, Marriott and Faber-Langendoen 2000). Although further 

refinement of the Black Hills Community Inventory is needed, approximately 70 native plant 

communities have been described in the Black Hills. 

Because the potential treatment areas for the Black Hills Resilient Landscapes (BHRL) Project 

span across much of the Forest, the Black Hills National Forest in its entirety is considered the 

affected environment for this discussion. 

The majority of plant species considered rare in the Black Hills are best described as boreal 

disjuncts (species that became isolated in the cooler, moister forest and riparian areas of the 

Black Hills as glaciers retreated and the Great Plains environment became established). The next 

closest populations of these species to the populations located in the Black Hills are generally 

found in Canada and the northeastern United States. 

No Botanical Areas or Research Natural Areas are included in the Black Hills Resilient 

Landscapes Project Area. However, Botanical Areas and Research Natural Areas are located 

adjacent to the project area boundary and have potential to be impacted by the proposed 

treatments. Potential impacts to these special designation areas are addressed in the Black Hills 

Resilient Landscapes Project Botany Report (contained in the project record). 

There are eight sites (comprising approximately 550 acres) identified as montane grasslands 

which are recommended for conservation in the Survey and Mapping of Black Hills Montane 

Grasslands report (Marriott 2012). Approximately 440 of the 550 acres recommended for 

conservation are co-located with areas identified for treatment in the Black Hills Resilient 

Landscapes Project. Treatments proposed in these areas include commercial timber harvest, noncommercial thinning and pine removal from grasslands and aspen/oak stands, and fuels 

reduction. Potential impacts to these special designation areas are addressed in the Black Hills 

Resilient Landscapes Project Botany Report (contained in the project record).

III. THREATENED, ENDANGERED, AND PROPOSED SPECIES CONSIDERED AND 

ANALYZED

Consultations To Date

The U.S. Fish and Wildlife Service (USFWS) lists for Threatened and Endangered species were

accessed on December 7, 2017 for the states of South Dakota and Wyoming. As of this date, 

there is one federally listed Threatened plant species (Leedy’s roseroot) known to occur in one 

county within the Black Hills National Forest (USDI Fish & Wildlife Service 2015, 2017a,

2017b, 2017c, 2017d, 2017e). The Threatened plant species occurs in a county included in the 
9

project area. There are no documented occurrences of the species within the project area, and 

habitat suitable for supporting Leedy’s roseroot is not likely to occur beyond the currently 

occupied area. Habitat consists of moist and shaded granitic cliffs at an elevation of 

approximately 7,000 feet.

Leedy’s roseroot (Rhodiola integrifolia subsp. leedyi) is the sole Threatened plant species known 

to occur in the Black Hills National Forest. It is documented from a single site in Pennington 

County, SD. The known population of Leedy’s roseroot is located in the Black Elk Wilderness 

(Management Area 1.1A) which is not included in the project area. Leedy’s roseroot occurrences 

and/or suitable habitat are not located within or in the vicinity of the project area, resulting in no 

effects (direct, indirect, or cumulative) to the species. A determination of “no effect” (FSM 

2671.44) to the Threatened species has been confirmed. 

Another Threatened species, Ute lady’s tresses (Spiranthes diluvialis), is identified as having 

potential to occur in the Black Hills in Wyoming (USDI Fish & Wildlife Service 2015). The 

species is associated with alluvial banks, point bars, floodplains, or ox-bows along perennial 

streams. Numerous surveys for botanical resources have been conducted in the project area and 

no occurrences of Ute lady’s tresses have been observed (USDA Forest Service 2016). Project 

area habitat is considered marginally suitable for the species (i.e. no alluvial banks, point bars, 

floodplains, or ox-bows associated with perennial streams (USDI Fish & Wildlife Service 

2015)). Ute lady’s tresses occurrences and/or suitable habitat are not located within or in the 

vicinity of the project area, resulting in no effects (direct, indirect, or cumulative) to the species. 

A determination of “no effect” (FSM 2671.44) to the Threatened species has been confirmed. 

Threatened, endangered, and proposed plant species which could potentially occur on the Black 

Hills National Forest were identified and addressed through informal consultation with the South 

Dakota and Wyoming Field Offices of USFWS during the Phase II Amendment development 

(USDA Forest Service 2005). 

Candidate species have sufficient information on their biological status and threats to warrant a 

proposal to list as endangered or threatened, but development of a listing regulation is precluded 

by other higher priority listing activities. Species which are candidates for listing under the 

Endangered Species Act (ESA) are automatically placed on the Region 2 Forester’s sensitive 

species list. The analysis and determination of effects for candidate species are included as part 

of the Biological Evaluation for sensitive species. No current candidate plant species are known 

to occur on the Black Hills National Forest (USDI Fish & Wildlife 2014). No further analysis is 

required for species not known or suspected to occur in the project area. 

It is my determination that implementation of either of the two alternatives as described will not 

affect any threatened or endangered plant species or designated critical habitat. 

IV. SPECIES INFORMATION

The sensitive species list for the Rocky Mountain Region was published as a Regional 

Supplement (2600-2017-1) effective July 13, 2017. The list of sensitive species was verified by 

visiting the Region 2 Threatened, Endangered and Sensitive Species Program website (USDA 
10

Forest Service 2017). 

There are 14 plant species on the Forest Service Region 2 sensitive species list that are known or 

suspected to occur, or for which suitable habitat is suspected to occur, on the Black Hills 

National Forest. These species are shown in Table 4. There are 2 plant species designated 

Threatened by the US Fish & Wildlife Service which are either known to occur or for which the 

species’ area of influence extends onto the Black Hills National Forest. These species are shown 

in Table 5.
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TABLE 4: REGION 2 SENSITVE PLANT SPECIES

Common 

Name 

Scientific 

Name Black Hills Habitat

Species Known 

To Occur in 

Project Area1

Suitable Habitat 

Present in 

Project Area

Rationale for Further Analysis Analyzed 

Further3

Prairie 

moonwort

Botrychium 

campestre

Black Hills sites occur on limestone substrates and are 

primarily in open grassland habitats with high to moderate 

forb diversity. Little bluestem (Schizachyrium scoparium) 

occurs at several of the sites. Black Hills occurrences range in 

elevation from approximately 3,850 to 6,700 ft.

Yes Yes

Species and suitable habitat located 

within project area. Occurrences 

and/or habitat have potential to be 

impacted by proposed activities.

Yes

Narrowleaf 

grapefern

Botrychium 

lineare

Black Hills sites occur on limestone substrates in open 

grassland habitats (both high elevation montane grasslands and 

lower elevation little bluestem dominated habitats), on old 

(estimated 15-25 years) native surface roadbeds and in 

openings along perennial streams. Elsewhere in its range, this 

species has often been documented in areas of road 

disturbances and other human and natural disturbances. Black 

Hills occurrences range in elevation from approximately 4,200 

(in Wind Cave national Park) to 6,700 ft.

Yes Yes

Species and suitable habitat located 

within project area. Occurrences 

and/or habitat have potential to be 

impacted by proposed activities.

Yes

Foxtail sedge Carex 

alopecoidea

In the Black Hills, foxtail sedge is currently known from two 

general areas: The Cement Ridge area along the South 

Dakota–Wyoming border, and the Bear Lodge Mountains of 

Wyoming. Foxtail sedge is primarily found along open, 

perennial streams, often with old beaver dams or ponds. 

Occurrences have also been found in spruce dominated 

riparian areas and in drainages with dense shrub cover. Plants 

are primarily documented in the transitional areas between 

saturated soils and the more mesic upland areas. Black Hills 

occurrences range in elevation from approximately 3,800 to 

5,900 ft..

Yes Yes

Species and suitable habitat located 

within project area. Occurrences 

and/or habitat have potential to be 

impacted by proposed activities.

Yes

Mountain 

lady’s slipper

Cypripedium 

montanum

Mountain lady’s slipper is known from a single population in 

the Black Hills, located on a shady, sheltered mid-slope under 

white spruce (Picea glauca) on an east-facing slope at an 

elevation of approximately 5,500 ft. 

No Yes

Suitable habitat located within project 

area has potential to be impacted by 

proposed activities.

Yes

Yellow lady’s 

slipper

Cypripedium 

parviflorum

Habitat in the Black Hills includes stream banks under both 

white spruce (Picea glauca) and deciduous overstories, moist 

cliffs (usually north-facing), and moist areas/seeps under white 

spruce or mixed conifer forest. Occasionally, it is found on 

upper mesic forest slopes. Black Hills occurrences range in 

elevation from approximately 3,500 to 6,500 ft.

Yes Yes

Species and suitable habitat located 

within project area. Occurrences 

and/or habitat have potential to be 

impacted by proposed activities.

Yes

Giant 

helleborine

Epipactis 

gigantea

In the Black Hills, giant helleborine is known only from 

Cascade Springs in Fall River County, South Dakota at 

approximately 3,400 ft. It is likely dependent upon the 

constant moisture and warmth provided by the springs. No 

other warm springs are known on Forest Service administered 

No No

There are no warm springs within the 

Project Area and the influence zone 

for the known population is outside of 

the Project Area.

No
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TABLE 4: REGION 2 SENSITVE PLANT SPECIES

Common 

Name 

Scientific 

Name Black Hills Habitat

Species Known 

To Occur in 

Project Area1

Suitable Habitat 

Present in 

Project Area

Rationale for Further Analysis Analyzed 

Further3

land in the Black Hills. 

Trailing 

clubmoss

Lycopodium 

complanatum

Black Hills occurrences are located in the northern portion of 

the forest on shaded, north-facing, white spruce dominated 

slopes often with paper birch (Betula papyrifera) or quaking 

aspen (Populus tremuloides). Black Hills occurrences range in 

elevation from approximately 4,900 to 6,350 ft.

Yes Yes

Species and suitable habitat located 

within project area. Occurrences 

and/or habitat have potential to be 

impacted by proposed activities.

Yes

Large roundleaf orchidPlatanthera 

orbiculata

Black Hills occurrences are found primarily on shady, northfacing slopes in paper birch/hardwood or white spruce forests 

on moist, rich, humus soil. Black Hills occurrences range in 

elevation from approximately 4,300 to 6,200 ft.

Yes Yes

Species and suitable habitat located 

within project area. Occurrences 

and/or habitat have potential to be 

impacted by proposed activities.

Yes

Sage willow Salix candida In the Black Hills, sage willow is limited to one natural 

verified extant occurrence west of Deerfield (McIntosh Fen, 

6,000 ft.). In addition there is a historical collection for the 

general area “from Loring Siding to Minnekahta” (unknown if 

on BKF or private land) and an experimental site planted on 

the Mystic district in 2007. Habitat includes cold seep or 

spring-fed saturated substrates produced by unusual 

hydrologic conditions where sedimentary layers of the 

Limestone Plateau intersect impermeable schist or shale of the 

crystalline Central Core. Community type associated with the 

natural occurrence is wet meadow/fen.

Yes Yes

Species and suitable habitat located 

within project area. Occurrences 

and/or habitat have potential to be 

impacted by proposed activities.

Yes

Autumn 

willow

Salix 

serissima

Black Hills occurrences are documented from the central to 

north-central Black Hills in fens and wet meadows often 

dominated by Carex spp. and other Salix spp. It appears to 

occur in the same unique hydrologic conditions as Salix 

candida. Black Hills occurrences range in elevation from 

approximately 5,600 to 6,000 ft.

Yes Yes

Species and suitable habitat located 

within project area. Occurrences 

and/or habitat have potential to be 

impacted by proposed activities.

Yes

Bloodroot Sanguinaria 

canadensis

In the Black Hills, bloodroot occupies floodplains, forested 

terraces, drainage bottoms, and north-facing footslopes in 

open, rich hardwood plant communities. It is currently known 

only from the northeast portion of the Black Hills, from the 

east side of Spearfish Canyon to west of Tilford. Black Hills 

occurrences range in elevation from approximately 3,900 to 

5,000 ft.

Yes Yes

Species and suitable habitat located 

within project area. Occurrences 

and/or habitat have potential to be 

impacted by proposed activities.

Yes

Narrowleaf 

peatmoss

Sphagnum 

angustifolium

Narrowleaf peatmoss has recently been confirmed in one 

central Black Hills fen site on BKF land. Information on local 

distribution and habitat is limited. This plant is widely 

distributed throughout northern North America and is 

Yes Yes

Species and suitable habitat located 

within project area. Occurrences 

and/or habitat have potential to be 

impacted by proposed activities.

Yes
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TABLE 4: REGION 2 SENSITVE PLANT SPECIES

Common 

Name 

Scientific 

Name Black Hills Habitat

Species Known 

To Occur in 

Project Area1

Suitable Habitat 

Present in 

Project Area

Rationale for Further Analysis Analyzed 

Further3

restricted to fens, open mires, sedge fens and muskeg habitats 

throughout its range (McQueen & Andrus 2007). In Region 2 

Narrowleaf peatmoss is not known outside of fen habitats.

Highbush 

cranberry

Viburnum 

opulus var. 

americanum

In the Black Hills, highbush cranberry occurs at midelevations in wet, shaded habitats along streams, springs and 

canyon bottoms. The majority of documented Black Hills 

occurrences are in drainage bottoms or low slopes with moist 

soil conditions and partial shade. Sites are primarily 

associated with paper birch/ironwood (Ostrya virginiana) and 

paper birch/hazelnut (Corylus cornuta) communities, with or 

without white spruce or quaking aspen. A few sites are in 

ponderosa pine/bur oak (Pinus ponderosa/Quercus 

macrocarpa) communities. Paper birch is present at almost all 

currently known sites. Black Hills occurrences range in 

elevation from approximately 3,800 to 5,700 ft. 

Yes Yes

Species and suitable habitat located 

within project area. Occurrences 

and/or habitat have potential to be 

impacted by proposed activities.

Yes

Great-spurred 

violet

Viola

selkirkii

Black Hills occurrences are known from BKF lands, Custer 

State Park and Mt. Rushmore National Monument and are 

restricted to a concentrated area (ca. 36 square miles) of the 

central core on igneous or metamorphic bedrock. 

Microhabitats are often moist, cold air drainages, in shaded to 

open areas, and often in the vicinity of granitic rock outcrops. 

White spruce is usually the dominant overstory with a variable 

understory. Currently known occurrences on BKF lands are 

located within the Black Elk Wilderness and/or the Norbeck 

Wildlife Preserve. One site extends outside of Black Elk 

Wilderness. Black Hills occurrences range in elevation from 

approximately 5,200 to 7,000 ft.

Yes Yes

Species and suitable habitat located 

within project area. Occurrences 

and/or habitat have potential to be 

impacted by proposed activities.

Yes

TABLE 5: Federally Listed Threatened Plant Species

Common 

Name 

Scientific 

Name Black Hills Habitat

Species Known 

To Occur in 

Project Area1

Suitable Habitat 

Present in 

Project Area

Rationale for Further Analysis Analyzed 

Further3

Leedy’s 

roseroot

Rhodiola 

integrifolia 

subsp. leedyi 

Black Hills population is located in the vicinity of Black Elk 

Peak at an elevation of approximately 7,000 feet. Individuals 

are found on moist north-facing granite cliff habitat. 

No No

Project area is outside of known 

geographic range and does not 

contain moist granitic cliffs at 

No
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TABLE 5: Federally Listed Threatened Plant Species

Common 

Name 

Scientific 

Name Black Hills Habitat

Species Known 

To Occur in 

Project Area1

Suitable Habitat 

Present in 

Project Area

Rationale for Further Analysis Analyzed 

Further3

comparable elevations. 

Hooded lady’s 

tresses

Spiranthes 

diluvialis

There are no known populations of Hooded lady’s tresses in 

the Black Hills, despite extensive focused surveys. It is 

associated with alluvial banks, point bars, floodplains, and oxbows within close proximity to perennial streams at elevations 

less than 7,000 feet. The nearest confirmed population is 

located in Niobrara County, Wyoming. 

No No No known populations or suitable 

habitat are present in the Project Area. No

1

Species presence known or suspected in or immediately adjacent to the project area.

2Suitable habitat present in or immediately adjacent to the project area.

3Species not known or suspected to be present and with no suitable habitat present in the project area are not further evaluated because they would not be affected by project 

activities.
15

No further analysis is required for species not known or suspected to occur in the project area, 

and for which no suitable habitat is present. Tables 4 and 5 above document the rationale for 

excluding a species from further analysis. Determinations for all other species are documented 

below in the Determinations section. 

Analysis was conducted on the effects of the proposed action on Region 2 sensitive species 

known to occur, or for which potentially suitable habitat occurs, in the Black Hills Resilient 

Landscapes project area. This analysis considers management activities of the action alternative 

(Alternative A) and associated mitigation measures as set forth in the Black Hills Resilient 

Landscapes Project Environmental Impact Statement.

The following analysis is derived from surveys, professional knowledge, and the best available 

science. An effects analysis has been completed for species (and associated habitats) which have 

potential to be impacted by the proposed project. Twelve Region 2 sensitive plant species are 

known to occur within the project area, and one additional species is not documented within the 

project area but has potential for suitable habitat presence. Effects have been analyzed for known 

Region 2 sensitive plant populations and corresponding suitable habitat, as well as occurrences 

which may be present but have not been detected during survey. Extensive species accounts were 

prepared for the Black Hills National Forest Land and Resource Management Plant (Phase II 

Amendment) Final Environmental Impact Statement (USDA Forest Service 2005). This 

document tiers to the FEIS and information included in the following species accounts is 

partially derived from it. Due to the size of the project area, complexity of analysis, and the short 

time allotted in which to conduct analysis, the site specificity for analysis purposes was defined 

at the stand size. If Region 2 sensitive plant species occur within a potential treatment area, or 

stand, actions are assumed to directly impact the species present. 

Prairie Moonwort (Botrychium campestre)

Habitat: Prairie moonwort is considered a grassland species, associated with sandy grassland 

habitats in prairies, dunes, railroad sidings, and fields over limestone. All known Black Hills 

prairie moonwort occurrences are found on limestone substrate and are associated with varying 

levels of previous disturbance (USDA Forest Service 2014). Limestone substrates are found in a 

band circling the granitic central core of the central part of the Black Hills (USDA Soil 

Conservation Service 1990). 

Species Distribution, Status, and Trend: Prairie moonwort is a North American endemic that 

ranges from the Canadian provinces of Alberta, Ontario, and Saskatchewan to Montana,

Wyoming, Colorado, Nebraska, Iowa, Minnesota, North Dakota, South Dakota, Michigan, 

Wisconsin, and New York. It is considered an uncommon species with a patchy widespread 

distribution, but is likely more widespread and abundant across its range than is recorded. There 

are twenty-six known occurrences of prairie moonwort on the Black Hills National Forest, with 

several additional occurrences from lands adjacent to National Forest (USDA Forest Service 

2014). The twenty-six Black Hills National Forest occurrences span a wide range with the 

northern-most occurrence found in the Sundance Trails area (Bearlodge RD) and the southernmost occurrence found southwest of Hot Springs (Hell Canyon RD). All Black Hills occurrences 

have been confirmed through genetic analysis by Dr. Don Farrar of Iowa State University. 
16

Prairie moonwort is currently assigned a rank of S1, critically imperiled, in Wyoming (Heidel 

2012a, Heidel 2012b). South Dakota has designated the rank of S2S3, imperiled because of rarity 

or only found locally (SDGFP 2016). Global rank is G3G4, apparently secure, with locally 

abundant, disjunct populations (NatureServe 2015).

Four of the core prairie moonwort sites have been established for annual monitoring. According 

to the 2013 / 2014 monitoring report, the known populations of prairie moonwort are generally 

stable with no changes in the disturbance regime. However, some populations had decreased in 

number most likely due to changes in the local nutrient regime, including correlations to drought 

conditions experienced in 2012 (USDA Forest Service 2014). Moonwort species do not produce 

above ground parts every year and may remain alive but dormant in the soil for years (JohnsonGroh 1998). The production of above ground parts is believed to respond to weather of the 

previous spring and summer (Farrar 2006). Although observed numbers of plants were lower at 

some of the sites visited in 2013 and 2014 compared to previous years, a trend cannot be 

confirmed until more monitoring has occurred, particularly in years not following a drought

(USDA Forest Service 2014).

Project Review: Three stands identified in Alternative A for potential commercial treatment are 

co-located with prairie moonwort sites. One of the three sites co-occurs with narrowleaf 

grapefern and highbush cranberry, and another site co-occurs with narrowleaf grapefern. 

Approximately eight other prairie moonwort sites are located adjacent to, or within close 

proximity of, potential commercial treatment areas. Prairie moonwort sites are also co-located 

with areas identified as grasslands, where encroaching pine could potentially be removed, and 

areas identified for potential fuel reduction and prescribed fire. The project area includes 

grasslands over limestone substrate, which are elements of identified suitable habitat for prairie 

moonwort. Since specific habitat relationships for this species are not well understood and the 

species can be difficult to detect, a conservative approach assumes that potentially suitable 

habitat does support other undocumented individuals within the project area, which could be 

impacted by actions associated with Alternative A.

Narrowleaf Grapefern (Botrychium lineare)

Habitat: Narrowleaf grapefern is associated with a wide variety of ecological conditions making 

it difficult to describe suitable habitat. Generally it is found in areas of open canopy over 

calcareous soils with a history of disturbance. All known Black Hills narrowleaf grapefern 

populations occur on limestone substrate in open grassland habitats (USDA Forest Service 2014, 

USDA Forest Service 2016). Limestone substrates are found in a band circling the granitic 

central core in the central part of the Black Hills (USDA Soil Conservation Service 1990). 

Species Distribution, Status, and Trend: Narrowleaf grapefern ranges from across Canada 

south into the western half of the United States, extending east to Minnesota. In Region 2, 

narrowleaf grapefern is known from Colorado, Wyoming, and South Dakota. It is considered an 

uncommon species with a patchy widespread distribution, but is likely more widespread and 

abundant across its range than is recorded. There are fifteen known occurrences of narrowleaf 

grapefern on the Black Hills National Forest with one additional occurrence from Wind Cave 

National Park lands adjacent to National Forest (USDA Forest Service 2014, USDA Forest 

Service 2016). The fifteen Black Hills National Forest occurrences are on the west side of the 
17

forest spanning from the northern-most occurrence in the vicinity of Sand Creek to the southernmost located southwest of Pringle (Hell Canyon RD). 

Narrowleaf grapefern is currently ranked S1, critically imperiled, in both Wyoming and South 

Dakota (Heidel 2012a, Heidel2012b, SDFGP 2016) and has a global rank of G2G3, imperiled. It 

had been a candidate for Federal listing, but was officially removed from the candidate list by the 

U.S. Fish and Wildlife Service (USDI Fish & Wildlife 2007). 

Sites visited in 2013 and 2014 reported apparently stable populations with some disturbance and 

presence of invasive species. Fewer individuals were observed at one site (Boles Canyon) than in 

previous years, but further monitoring is necessary to make any trend determinations (USDA 

Forest Service 2014). 

Project Review: Two narrowleaf grapefern sites are co-located with stands identified in 

Alternative A for potential commercial treatment. One of these sites co-occurs with prairie 

moonwort, and the other site co-occurs with highbush cranberry. Six additional narrowleaf 

grapefern sites are located adjacent to, or within close proximity of, potential treatment areas. 

Narrowleaf grapefern sites are also co-located with areas identified as grasslands, where 

encroaching pine could potentially be removed, and areas identified for potential fuel reduction 

and prescribed fire. The project area includes grasslands occurring over limestone substrate, 

which are elements of identified suitable habitat for narrowleaf grapefern. Since habitat 

relationships for this species are not well understood and the species can be difficult to detect, a 

conservative approach assumes that potentially suitable habitat does support other undocumented 

individuals within the project area, which could be impacted by actions associated with 

Alternative A. 

Foxtail Sedge (Carex alopecoidea)

Habitat: Foxtail sedge is generally located in open areas along perennial streams, often with old 

beaver dams or ponds. It is usually associated with calcareous substrates (Standley 2002). 

Occurrences are primarily documented in the transitional areas between saturated soils and more 

mesic uplands, but can be associated with many different wetland, riparian, and upland 

communities. This habitat is found throughout the project area, but is concentrated in the 

northern part of the Forest (USDA Forest Service 2014, USDA Forest Service 2016). 

Species Distribution, Status, and Trend: Foxtail sedge is widely distributed from eastern to 

central Canada, the Northeastern United States through the Great Lakes region, south to 

Tennessee, and west to Wyoming. In the Black Hills, foxtail sedge is currently known from two 

general areas, the Cement Ridge area along the South Dakota – Wyoming border, and in the Bear 

Lodge Mountains in Wyoming. There are thirty-four occurrences of foxtail sedge known to 

occur on the Black Hills National Forest between the Bearlodge and Northern Hills Ranger 

Districts (USDA Forest Service 2014). 

Foxtail sedge is currently ranked as S2, imperiled, in Wyoming (Heidel 2012a, Heidel 2012b) 

and S2S3, imperiled to vulnerable, in South Dakota (SDGFP 2016). It currently holds a global 

rank of G5, secure (NatureServe 2015). 
18

Foxtail sedge sites visited in 2013 and 2014 appear stable and have persisted, though nearly all 

sites displayed varying levels of livestock impacts and invasive plant presence. Modified grazing 

practices and additional fencing have been implemented at several sites to address previous 

years’ livestock concerns. None of the 2013 or 2014 visited sites displayed impacts from timber 

management activities (USDA Forest Service 2014). 

Project Review: Approximately six foxtail sedge sites are co-located with areas identified in 

Alternative A for potential commercial treatment. No other Region 2 sensitive plant species cooccur with foxtail sedge at these sites. Approximately ten additional foxtail sedge sites are 

located adjacent to, or within close proximity of, potential treatment areas. Sites co-located with 

potential treatment areas generally consist of a portion of the documented occurrences 

overlapping with the stand, not any entire sites. Other potential treatment areas are identified in 

the vicinity of riparian areas, wetlands, and meadows, which would present the possibility of 

impacts to foxtail sedge suitable habitat. Foxtail sedge sites are also co-located with areas 

identified as grasslands, mixed pine and aspen, and mixed aspen and oak; all areas with potential 

to receive treatments removing pine. Other areas of suitable habitat for foxtail sedge, and 

possibly undocumented individuals, may occur within the project area and have potential to be 

impacted by actions associated with Alternative A.

Mountain Lady’s Slipper (Cypripedium montanum)

Habitat: Across its range, mountain lady’s slipper is known to occur in a wide variety of 

habitats including mesic to dry coniferous and deciduous forests, openings, and thickets (Sheviak 

2002). In the Black Hills the species is documented on a shaded east-facing slope dominated by a 

fairly dense white spruce overstory with moist to mesic-moist soil conditions. This habitat is 

found throughout the project area, with highest concentrations in the northern part of the Forest 

(USDA Forest Service 2014, USDA Forest Service 2016). 

Species Distribution, Status, and Trend: Mountain lady’s slipper occurs in the northwestern 

United States (including Alaska) from Oregon south to California, east to Montana, Wyoming, 

and South Dakota, and in Canada from British Columbia to Saskatchewan. It is known from a 

single site in the Black Hills, on the south end of Spearfish Canyon in the northern part of the 

Forest. Approximately twenty individuals are recorded from the site (USDA Forest Service 

2014). 

Mountain lady’s slipper is currently unranked in South Dakota (SDGFP 2016), and ranked S1, 

critically imperiled, in Wyoming (Heidel 2012a, Heidel 2012b). It holds a global rank of G4, 

apparently secure (NatureServe 2015). 

The mountain lady’s slipper population was documented in 2012, with baseline data collected in 

2013. The site is revisited annually to develop population trends, but trend data has not yet been 

established. The population appears stable. Potential concerns at the mountain lady’s slipper site 

include observed wildlife trailing in close proximity to individuals and invasive plant species in 

the vicinity of occurrences. No impacts have been observed from livestock activity, recreational 

use, or timber management. With all known occurrences on the forest located at one site, the 

population is susceptible to a single event removing the species from the Planning Area (USDA 

Forest Service 2014).
19

Project Review: The single known occurrence of mountain lady’s slipper in the Black Hills is 

located on the southern end of Spearfish Canyon, Management Area 4.2A. This management 

area is not included in the project area boundary, resulting in no impacts to the site from actions 

associated with the project. Despite no other occurrences recorded of mountain lady’s slipper 

during multiple surveys (some focused solely on the species), suitable habitat for the species is 

present in other areas where potential treatments are identified in Alternative A. Suitable habitat 

and possibly undocumented individuals have potential to be impacted by actions associated with 

Alternative A, including commercial treatments, hardwood enhancement, and fuel treatments. 

Yellow Lady’s Slipper (Cypripedium parviflorum)

Habitat: Currently known locations in the Black Hills indicate this species is generally 

associated with mesic conditions on limestone rock outcrop areas, often on north-facing slopes, 

and on mesic to saturated soils in and adjacent to riparian areas and drainages. Yellow lady’s 

slipper is often associated with hardwoods, conifer-deciduous communties, deciduous 

communities, and confier communities (mostly white spruce, Picea glauca). Limestone 

substrates are found in a band circling the granitic central core in the central Black Hills (USDA 

Soil Conservation Service 1990) and the conifer-deciduous community on limestone is largely 

located in the northern part of the limestone band. Yellow lady’s slipper has also been found 

outside of this habitat type in the Black Hills, so suitable habitat for the species could occur 

outside of this described geographic area (USDA Forest Service 2014, USDA Forest Service 

2016).

Species Distribution, Status, and Trend: Primarily circumboreal in distribution, yellow lady’s 

slipper ranges from Canada south into most of the United States, and is known to occur in all 

states within Region 2. There are at least fifty known occurrences of yellow lady’s slipper on the 

Black Hills National Forest (USDA Forest Service 2014). Occurrences are located on three of 

the Black Hills National Forest Ranger Districts (Bearlodge, Northern Hills, and Mystic). 

Yellow lady’s slipper is currently ranked S2, imperiled, in Wyoming (Heidel 2012a, Heidel

2012b) and S3S4, vulnerable to apparently secure, in South Dakota (SDGFP 2016). It has a 

global rank of G5, secure (NatureServe 2015). 

Nine yellow lady’s slipper sites were visited during the 2013 / 2014 monitoring period. Due to 

limited years of monitoring, trend information is not available for six of the sites. Observations 

report each of the populations as persisting and showing little impact from management 

activities. No impacts from livestock grazing, timber management, or road construction and 

maintenance were reported from sites visited between 2013-2014. Invasive plant species were 

reported within the vicinity of occurrences at eight of the nine sites visited. The species is 

considered stable and persisting on the Forest (USDA Forest Service 2014).

Project Review: Approximately eight yellow lady’s slipper sites are co-located with areas 

identified in Alternative A for potential commercial treatment. One site co-occurs with 

bloodroot, and another site with highbush cranberry. Approximately 15 additional yellow lady’s 

slipper sites are located adjacent to, or within close proximity of, potential treatment areas. 

Yellow lady’s slipper sites are also co-located with areas identified as grasslands, and mixed 
20

aspen and oak; areas with potential to receive treatments removing pine. Several yellow lady’s 

slipper sites are located within areas identified for potential fuel treatments and prescribed 

burning. Other areas of suitable habitat for yellow lady’s slipper, and possibly undocumented 

individuals, may occur within the project area and have potential to be impacted by actions 

associated with Alternative A.

 

Trailing Clubmoss (Lycopodium complanatum)

Habitat: In the Black Hills, trailing clubmoss is restricted to moist microhabitats within boreal 

plant communities in ravines, steep drainages, steep slopes within white spruce stands, and on 

moist streamside benches from 5,000 to 6,340 feet. Documented occurrences are associated with 

a canopy of white spruce, paper birch (Betula papyrifera), and ponderosa pine. Suitable habitat 

for trailing clubmoss is concentrated in the northern part of the Forest (USDA Forest Service 

2014, USDA Forest Service 2016). 

Species Distribution, Status, and Trend: Trailing clubmoss is circumboreal and common 

across northern latitudes but disjunct or sparse at the southern limits of the species’ distribution, 

such as in the Black Hills. In the Black Hills, trailing clubmoss is disjunct from the nearest 

occurrences in the Rocky Mountains. There are ten known occurrences of trailing clubmoss on 

the Black Hills National Forest (USDA Forest Service 2014). Occurrences are located on 

Bearlodge and Northern Hills Ranger Districts. 

Trailing clubmoss is currently unranked in Wyoming (Heidel 2012a, Heidel 2012b), and ranked 

S2, imperiled, in South Dakota (SDGFP 2016). It has a global rank of G5, secure (NatureServe 

2015). 

Trailing clubmoss sites visited during the 2013 / 2014 monitoring period are persisting and 

appear stable, similar in size and extent to previous years’ observations. Evidence of livestock 

trailing and non-native or invasive plants were present in the vicinity of 2013/2014 monitor sites. 

Impacts from these disturbances were not observed directly affecting individual trailing 

clubmoss plants, though they were identified as appearing to be the most significant potential 

threats to the species (USDA Forest Service 2014).

Project Review: There are no trailing clubmoss sites co-located with areas identified in 

Alternative A for potential commercial treatment. Approximately 5 sites are located adjacent to, 

or within close proximity of, potential treatment areas. Two trailing clubmoss sites are co-located 

with areas identified for potential fuel treatments, and other sites are near areas of grasslands, 

and mixed aspen and oak; areas with potential to receive treatments removing pine. Other areas 

of suitable habitat for trailing clubmoss, and possibly undocumented individuals, may occur 

within the project area and have potential to be impacted by actions associated with Alternative 

A.

Large Round-Leaf Orchid (Platanthera orbiculata)

Habitat: Large round-leaved orchids are found in dense to partially open canopy with filtered 

light, dense understory vegetation, and damp, humic soil with a thick litter layer. Elevated soil 

moisture appears to be a key component of its habitat. It occupies boreal hardwood habitats 

associated with paper birch/hazelnut/white spruce forest. Suitable habitat for large round-leaved 
21

orchid is concentrated in the northern part of the Forest (USDA Forest Service 2014, USDA 

Forest Service 2016). 

Species Distribution, Status, and Trend: Large round-leaved orchids are found in boreal 

regions of North America including Canada, the Appalachians, Great Lakes region, and the 

Black Hills. There are more than thirty known occurrences of large round-leaf orchid

documented on the Black Hills National Forest. Black Hills occurrences are found in cool, mesic 

areas of the Black Hills on the Bearlodge, Northern Hills, and Hell Canyon Ranger Districts 

(USDA Forest Service 2014). 

Large round-leaf orchid is currently ranked S1, critically imperiled, in Wyoming (Heidel 2012a, 

Heidel 2012b) and S3, vulnerable, in South Dakota (SDGFP 2016). It has a global rank of G5, 

secure (NatureServe 2015). 

Twenty-four large round-leaf orchid sites were visited during the 2013 / 2014 monitoring report

period. Occurrence observations from the monitored sites included increased numbers, 

apparantly stable populations, and noticeable decline in observed individuals. Sites displaying 

decrease in number of individuals generally provided little indication as to a cause, other than 

assumptions on effects of drought and, in some cases, direct and indirect impacts from mountain 

pine beetle activity. Impacts associated with livestock activity and presence of non-native or 

invasive plant species were noted from several sites. These types of impacts, along with longterm drought and dramatic climate changes, are regarded as presenting the greatest threats to 

large round-leaf orchids and their habitat. Overall, populations have persisted, with a few of the 

smaller populations appearing to be in decline. Large round-leaf orchid populations are reported 

to be secure on Black Hills National Forest based on the large number of occurrences distributed 

across three geographically separate areas (USDA Forest Service 2014). 

Project Review: Four large round-leaf orchid sites are co-located with areas identified in 

Alternative A for potential commercial treatment. Approximately eleven additional large roundleaf orchid sites are located adjacent to, or within close proximity of, potential treatment areas. 

Large round-leaf orchid sites are also co-located with areas identified as mixed pine and aspen, 

and mixed aspen and oak; areas with potential to receive treatments removing pine. Several sites 

are located within areas identified for potential fuel treatments. Other areas of suitable habitat for 

large round-leaf orchid, and possibly undocumented individuals, may occur within the project 

area and have potential to be impacted by actions associated with Alternative A.

Sage Willow (Salix candida)

Habitat: Sage willow is generally found in cold seep or spring-fed saturated substrates produced 

by unusual hydrologic conditions where sedimentary layers of the Limestone Plateau intersect 

impermeable schist or shale of the Crystalline Central Core. It is a wetland obligate species and 

is commonly associated with wet meadows and fens (Argus 2010). Suitable habitat for sage 

willow is concentrated in the northern part of the Mystic Ranger District and southern part of the 

Northern Hills Ranger District (USDA Forest Service 2014, USDA Forest Service 2016). 

Species Distribution, Status, and Trend: Sage willow occurs across Canada, the northern 

continental United States, and Alaska. It is considered secure throughout its range, but locally 
22

rare in some areas. There are two known sites of sage willow in the Black Hills, located at 

McIntosh Fen and an experimental transplant near Heely Creek, both on the Mystic Ranger 

District (USDA Forest Service 2014). 

Sage willow is currently ranked S2, imperiled, in Wyoming (Heidel 2012a, Heidel 2012b) and 

S1, critically imperiled, in South Dakota (SDGFP 2016). It has a global rank of G5, secure 

(NatureServe 2015). 

Sage willow in the Black Hills has been negatively affected in past years by stem boring insects, 

disease, and drought. Non-native or invasive plants are documented from the vicinity of both 

sage willow sites. The 2013 / 2014 monitoring report describes the populations as stable, with 

evidence of mortality observed both years. Mortality is more commonly noted during drought 

years and/or the year following drought, with disease and insect activity likely correlated and 

increasing in drier conditions (USDA Forest Service 2014). 

Project Review: The sage willow occurrence at McIntosh Fen is not located within the project 

area boundary, though areas identified in Alternative A for potential commercial treatment are 

located on both sides of the drainage surrounding the occurrence. The other sage willow site, 

Heely Creek, is near to areas identified for potential commercial treatment. It is also located 

within an area identified as grassland, with potential for pine removal treatments. Other areas of 

suitable habitat for sage willow, and possibly undocumented individuals, may occur within the 

project area and have potential to be impacted by actions associated with Alternative A.

Autumn Willow (Salix serissima)

Habitat: Like sage willow, autumn willow is found in rich calcareous fen habitats with high 

mineral content, along stream banks near fens, and in wet meadows with high concentrations of 

calcium and minerals. Suitable habitat for sage willow is concentrated in the northern part of the 

Mystic District and southern portion of the Northern Hills District (USDA Forest Service 2014, 

USDA Forest Service 2016). 

Species Distribution, Status, and Trend: Autumn willow occurs across Canada and the 

northern continental United States. There are five natural known sites of autumn willow on the 

Black Hills National Forest, located on the Mystic and Northern Hills Ranger Districts. A sixth 

site near Heely Creek contains experimental plantings of autumn willow (USDA Forest Service 

2014). 

Autumn willow is currently ranked S1, critically imperiled, in both Wyoming and South Dakota 

(Heidel 2012a, Heidel 2012b, SDGFP 2016). It has a global rank of G5, secure (NatureServe 

2015). 

The 2013 / 2014 monitoring report identified all six autumn willow sites as persisting and stable. 

Drought and impacts from stem boring insects are reported to present the greatest threats to the 

species on the Black Hills National Forest, both of which have affected observed vigor of 

individuals in various years since monitoring began. Non-native and invasive plant species were 

observed within the vicinity of all but one autumn willow site (USDA Forest Service 2014). 
23

Project Review: There are no autumn willow sites co-located with areas identified in 

Alternative A for potential commercial treatment. Four sites are located adjacent to, or within 

close proximity of, potential treatment areas. Autumn willow sites are co-located with areas 

identified for potential fuel treatments and grasslands, and near areas identified as mixed aspen 

and oak; areas with potential to receive treatments removing pine. Other areas of suitable habitat 

for autumn willow, and possibly undocumented individuals, may occur within the project area 

and have potential to be impacted by actions associated with Alternative A.

Bloodroot (Sanguinaria canadensis)

Habitat: Bloodroot generally occurs in floodplains, forested terraces, drainage bottoms, and 

north-facing foot slopes in open, rich hardwood plant communities. Suitable habitat for 

bloodroot is concentrated in the northern portion of the Forest (USDA Forest Service 2014, 

USDA Forest Service 2016). 

Species Distribution, Status, and Trend: Bloodroot occurs in moist forests from Nova Scotia 

to Florida and west to Manitoba and Kansas, with the Black Hills supporting the western-most, 

outlying population. There are over twenty known occurrences of bloodroot on the Black Hills 

National Forest located in the northeast portion of the Forest, on the Northern Hills Ranger 

District (USDA Forest Service 2014). 

Bloodroot is currently unranked in Wyoming (Heidel 2012a, Heidel 2012b) and ranked S4?, 

apparently secure, in South Dakota (SDGFP 2016). The global rank is G5, globally secure 

(NatureServe 2015). 

Monitoring over the 2013 / 2014 period resulted in twelve bloodroot site visists. Observations 

from sites noted similar conditions to previous years and the population on the Black Hills is 

reported to be persisting and apparently stable. Based on monitoring observations, threats to 

bloodroot include presence of non-native or invasive plants and impacts from livestock trailing. 

Competition with non-native and invasive plants is reported to be the greatest threat to bloodroot, 

resulting in a general decline in suitability of habitat at several sites (USDA Forest Service 

2014). 

Project Review: Three bloodroot sites are co-located with areas identified in Alternative A for 

potential commercial treatment, one of which co-occurs with highbush cranberry. Approximately 

eight additional bloodroot sites are located adjacent to, or within close proximity of, potential 

treatment areas. Bloodroot sites are also co-located with areas identified as mixed aspen and oak, 

and near areas of mixed pine and aspen; areas with potential to receive treatments removing pine. 

Several sites are located within areas identified for potential fuel treatments. Other areas of 

suitable habitat for bloodroot, and possibly undocumented individuals, may occur within the 

project area and have potential to be impacted by actions associated with Alternative A.

Narrowleaf Peatmoss (Sphagnum angustifolium)

Habitat: Rangewide, narrowleaf peatmoss is known to occur in a wide range of habitats, from 

bogs to rich (high pH) fens (McQueen & Andrus 2007). Suitable habitat for narrowleaf peatmoss 

in the Black Hills is not yet fully understood and described; therefore it is assumed that any rich 

fens or areas with known populations of other Sphagnum spp. have potential to support 
24

narrowleaf peatmoss. These habitats are concentrated along the contact between the limestone 

and central core, as well as wetlands in the northern part of the Forest (USDA Forest Service 

2014, USDA Forest Service 2016). 

Species Distribution, Status, and Trend: Narrowleaf peatmoss is found across North America

from Alaska and the Yukon to Nova Scotia, with its southern extent from California to North 

Carolina. On the Black Hills National Forest, narrowleaf peatmoss has only been positively 

identified from one site, in the Rochford Cemetary Fen (RCU_001) on the Mystic Ranger 

District (USDA Forest Service 2014). 

Narrowleaf peatmoss is currently unranked in Wyoming (Heidel 2012a, Heidel 2012b) and 

South Dakota (SDGFP 2016). The global rank is G5, globally secure (NatureServe 2015). 

The 2013 / 2014 monitoring report noted similar conditions to previous years’ observations at the 

single known narrowleaf peatmoss site (USDA Forest Service 2014). Non-native or invasive 

plant species observed at the site included Canada thistle (Cirsium arvense) and common mullein 

(Verbascum thapsus). No livestock impacts were reported from the site during the most recent 

monitoring period. The site is reported to be apparently stable, but highly susceptible to impacts 

associated with road maintenance and improvements. 

Project Review: The single known narrowleaf peatmoss site is located adjacent to areas 

identified in Alternative A for potential commercial treatment. It is co-located with an area 

identified as grassland, where pine removal could potentially occur, and within an area identified 

for potential fuel treatments. Other areas of suitable habitat for narrowleaf peatmoss, and 

possibly undocumented individuals, may occur within the project area and have potential to be 

impacted by actions associated with Alternative A.

Highbush Cranberry (Viburnum opulus var. americanum)

Habitat: Highbush cranberry is generally found in wet, shaded habitats along streams, springs, 

and canyon bottoms. Suitable habitat for highbush cranberry is concentrated in the northern part 

of the Forest (USDA Forest Service 2014, USDA Forest Service 2016).

Species Distribution, Status, and Trend: Highbush cranberry is found in Canada from British 

Columbia to New Brunswick, and south to Idaho across to West Virginia (Nellessen 2006). 

There are more than sixty known occurrences of highbush cranberry on the Black Hills National 

Forest, all on the Bearlodge and Northern Hills Ranger Districts (USDA Forest Service 2014). 

Highbush cranberry is currently ranked S2, imperiled, in Wyoming (Heidel 2012a, Heidel 

2012b) and unranked in South Dakota (SDGFP 2016). The global rank is G5T5, the variety is 

globally secure (NatureServe 2015). 

The 2013 / 2014 monitoring report describes the monitored populations as stable, noting some 

ungulate herbivory on individual shrubs. Non-native or invasive plant species competition and 

impacts from livestock use appear to be the largest threats to highbush cranberry on the Black 

Hills National Forest (USDA Forest Service 2014). 
25

Project Review: Four highbush cranberry sites are co-located with areas identified in 

Alternative A for potential commercial treatment. One site co-occurs with narrowleaf grapefern, 

and another site co-occurs with bloodroot. Approximately ten additional highbush cranberry sites 

are located adjacent to, or within close proximity of, potential treatment areas. Highbush 

cranberry sites are co-located with areas identified as mixed aspen and oak; areas with potential 

to receive treatments removing pine. Several sites are located within areas identified for potential 

fuel treatments. Other areas of suitable habitat for highbush cranberry, and possibly 

undocumented individuals, may occur within the project area and have potential to be impacted 

by actions associated with Alternative A. 

Great-Spurred Violet (Viola selkirkii)

Habitat: Great spurred violet is usually found in cold, moist, shaded microhabitats associated 

with vegetated granitic rock outcrops or white spruce forest with a highly variable understory. 

Suitable habitat for great spurred violet is concentrated in the high elevation granites of the eastcentral part of the Forest (USDA Forest Service 2014, USDA Forest Service 2016).

Species Distribution, Status, and Trend: Great spurred violet is a circumboreal species found 

in Canada, northern United States, Eurasia, and Japan. On the Black Hills National Forest, 

currently known occurrences are located within the Black Elk Wilderness or Norbeck Wildlife 

Preserve, with one site extending south outside of the Norbeck boundary. There are nineteen

known sites of great spurred violet on the Black Hills National Forest, all on the Hell Canyon 

Ranger District. Additional occurrences are known from Custer State Park and Mt. Rushmore 

National Memorial (USDA Forest Service 2014).

Great spurred violet is currently unranked in Wyoming (Heidel 2012a, Heidel 2012b) and ranked 

S2S3, imperiled to vulnerable, in South Dakota (SDGFP 2016). The global rank is G5?, globally 

secure (NatureServe 2015). 

The 2013 / 2014 monitoring report describes the six sites visited in 2013 and the four sites in 

2014 as persisting and apparently stable (USDA Forest Service 2014). Due to the limited actions 

permitted in the Black Elk Wilderness and Norbeck Wildlife Preserve, occurrences of great 

spurred violet are not considered to be at risk from management activities. Public use of these 

areas, along with periodic flooding, climate change, wildfire, and presence of non-native or 

invasive plants could potentially threaten the future persistence of the species on the Forest. 

Project Review: One great spurred violet site extends into the project area and is located 

adjacent to an area identified in Alternative A for potential commercial treatment. The site is also 

located near an area identified for potential fuel treatments. Other areas of suitable habitat for 

great spurred violet, and possibly undocumented individuals, may occur within the project area 

and have potential to be impacted by actions associated with Alternative A.

Suitable Sensitive Plant Habitat

Although a majority of treatment areas identified in the Black Hills Resilient Landscapes Project 

are primarily ponderosa pine forests, treatments are also proposed in areas containing spruce, 

hardwoods, and grasslands. Associated activities, including road construction and maintenance, 

log decking, and debris piles, have potential to occur outside of identified treatment areas. The 
26

Design Criteria for the Black Hills Resilient Landscapes Project include a requirement to consult 

with a qualified (0430 series) botanist for review of any activities occurring beyond treatment 

areas if the activities will impact suitable sensitive plant habitat. Following is a general 

description of suitable sensitive plant habitat. 

White Spruce Habitat

The Black Hills has one of the southern-most populations of white spruce (Picea glauca) in the 

United States. White spruce is the most shade-tolerant of the Black Hills tree species, enabling 

regeneration and growth under closed canopy conditions. The cool, moist environments of white 

spruce stands provide habitat diversity in an otherwise ponderosa pine dominated landscape. 

Several Region 2 sensitive plant species are associated with white spruce communities. 

Hardwood Habitat Including Paper Birch and Bur Oak

Paper birch/Hazelnut (Betula papyrifera/Corylus cornuta) Forest occurs in drainage bottoms 

with and without streams and on northerly slopes. In the northern Black Hills where precipitation 

is higher and temperatures are cooler, Paper birch/Hazelnut Forest extends to lower elevations. 

Stands of this type are found in mesic habitats such as shaded, narrow gulches and north-facing 

slopes. Paper birch/Hazelnut Forest often transitions into Bur oak/Ironwood (Quercus 

macrocarpa/Ostrya virginiana) Forest in Black Hills drainages at lower elevations. A number of 

boreal disjunct plant species, including some Region 2 sensitive plant species, occur in stands of 

cool, moist Paper birch/Hazelnut Forest and Bur oak/Ironwood Forest. 

Riparian Habitat Including Wetlands and Fens

Riparian areas are lands which interface between water and drier uplands. They are an 

ecologically diverse habitat and provide bank stability, sediment filtering, streamside shading, 

and nutrient input into streams and lakes. Riparian areas are generally located along perennial 

and intermittent streams. Approximately 2,108 miles of intermittent and perennial streams occur 

on Black Hills National Forest lands (BHRL Watershed Report 2017). 

More than half of the Region 2 sensitive plant species in the Black Hills are associated with 

wetland and/or riparian areas. Consequently, management protective of general riparian and 

wetland habitat and processes is an important component of protection for native plant species 

and communities, including Region 2 sensitive plant species. Inventory completed by the US 

Fish and Wildlife Service has documented approximately 3,981 acres of wetlands occurring on 

Black Hills National Forest lands (USDI Fish and Wildlife Service 1995).

Fens

In Region 2, a fen is defined as an ancient wetland with continuous organic soil accumulation of 

16 inches or more, with perennial support from ground water, and consistent saturation 

throughout the year (Austin 2005). They are classified as groundwater dependent ecosystems and 

are an important element of biological diversity due to their water-holding capability, unique 

characteristics and species assemblages, and support of several globally rare plant and 

invertebrate species. Fens occur where settings provide a highly specific balance between 

climatic conditions, bedrock lithology, constant ground water flow, and where natural barriers 

contribute to maintaining saturated conditions (Bedford & Godwin 2003). In the Black Hills, 

peat develops primarily from mosses (particularly Sphagnum spp.), the roots of sedges, and to a 
27

lesser extent from grasses. 

The Forest Service Handbook 2509.25 directs managers to avoid any loss of rare wetlands such 

as fens and springs because these areas cannot be replaced in-kind. Many fens in Region 2 are 

known to be 6,000 to 10,000 years old, and often support sensitive plant species. Due to the slow 

rate of peat accumulation and specificity of ecological requirements, fens are difficult to reclaim 

and deemed essentially irreplaceable (USDA Forest Service 2011). Black Hills National Forest is 

in the process of performing fen resource inventory as part of the national effort to catalogue 

Groundwater Dependent Ecosystems. Approximately 25 fens are believed to have been verified 

on the Black Hills National Forest, largely occurring on the Mystic Ranger District but also 

located on Northern Hills and Hell Canyon Ranger Districts (USDA Forest Service 2010). Other 

areas have been identified as potential fens and have yet to be surveyed to confirm or deny the 

classification. 

The Regional Watershed Conservation Practices (WCP) Handbook contains standards used when 

conducting activities in riparian, water influence zones, and wetlands as does the Forest Plan 

(Standards 1306 and 3106).

Meadows

A meadow is a tract of grassland or a low area near a river. Meadows can be considered riparian 

habitat, but not all riparian habitat is classified as a meadow. Meadows occur across the Forest at 

various elevations. A unique type of meadow endemic to the Black Hills is the Montane 

Grassland, ranked G1S1 (“critically imperiled” on a global and local basis) in South Dakota and 

Wyoming. Protections and potential impacts to Black Hills Montane Grasslands are discussed in 

the Black Hills Resilient Landscapes Project Botany Report. Several Region 2 sensitive plant 

species, including, but not limited to, prairie moonwort, narrowleaf grapefern, foxtail sedge, sage 

willow, and autumn willow occur in meadow habitats. 

Guideline 4111 in the Forest Plan recommends slash piles scheduled for burning to be located 

outside of meadows that contribute to the Waters of the United States and that a buffer should be 

established to keep sediment, ash, and debris out of these channels. 

V. EFFECTS OF THE ALTERNATIVES

For the purpose of this analysis, cumulative effects are bound in space by the Forest boundary 

since this is the area affected by Forest Service management decisions and which contains 

actions proposed by the project. Cumulative effects are bound in time by twenty years (ten years 

prior and ten years into the future), from the time of BHRL project implementation. This time 

frame encompasses the impacts related to the most recent planning efforts and the foreseeable 

impact of the Black Hills Resilient Landscapes Project. 

Past, present, and foreseeable vegetation projects include timber sales which have occurred over 

the past ten years, those currently in progress, and those which are in the planning phase across 

all districts of the Forest. The Forest contains 133 grazing allotments located with the project 

area (BHRL Project Range Report). 
28

There was no field reconnaissance or survey performed specifically for this project, though all 

botanical survey data available on the Black Hills National Forest were considered. Forest-wide 

survey specifically for Region 2 sensitive plant species and Black Hills National Forest species 

of local concern (SOLC) has occurred since 2001. Since this time, the list of Region 2 sensitive 

species has been revised several times and some current listed species may not have been 

considered in earlier surveys. The most recent list was effective as of July 13, 2017 (USDA 

Forest Service 2017). The information collected during botanical surveys has provided 

information on distribution and habitat associations for targeted species and has contributed to 

the effects analysis of the project alternatives. The focus of botanical surveys includes 

identifying and mapping community types and determining the probability of an area for 

supporting sensitive plant species, in addition to locating and recording sensitive plant species 

occurrences. Botanical surveys often occur in forested habitats, but also cover other habitats with 

high potential to support sensitive plant species, including riparian areas, wetlands, and 

meadows. Areas identified for focus during surveys have been determined by a combination of 

aerial imagery, topographic maps, local knowledge, and professional judgement during field 

reconnaissance. Less intensive surveys are also conducted in habitats with lower potential for 

supporting sensitive species. All botanical survey data is stored in the Black Hills National 

Forest plants database (USDA Forest Service 2016). Impacts and risks to sensitive plant species 

on the Forest were evaluated using the best available science and data. 

The majority of forested landscapes on BHNF have received survey for botanical resources, 

either through contracted survey, Forest Service botanist survey, or field review in support of 

projects occurring across all Forest districts. It is recognized that Region 2 sensitive plants are 

not always observed when present, even in areas where botanical survey has occurred. In some 

cases, plants may not be in an identifiable growth stage, they may be in dormancy, or may be 

difficult to see among surrounding vegetation. 

Assumption for Analysis

• All figures are approximate

• Actual acres/miles implemented would depend on weather, priorities, funding, and other 

factors

• Mapped stand boundary locations are approximate. Stand structure determinations are 

preliminary. Stand delineation and structure are subject to corrections based on field 

review.

• Areas that have not been surveyed for botanical resources are occupied (as directed in 

FSM_R2_2670_2017-1)

Design Criteria for Botanical Resources

Table 3: Design Criteria for Botanical Resources

All Activities All activity areas would be reviewed to determine presence and location of 

botanical resources prior to contract or permit issuance.

Any Region 2 sensitive plant species or plant species of local concern located after

contract or permit issuance will be appropriately managed by active coordination

between permittee, contractor or purchaser, Forest Service line officer, project

administrator, and botanist. (Standard 3115)

Riparian areas or wetlands where populations of Region 2 sensitive plants are 

located

would be avoided during surface disturbing activities (Standard 3106).
29

Surface disturbing activities, such as skid trails, landings, road construction, etc., 

would be avoided in meadows, wetlands, and riparian areas (suitable rare plant 

habitat, Standard 1306). If, during implementation, activities such as these cannot 

be located outside of meadows, a qualified (0430 series) botanist would be 

contacted prior to implementation to determine if special requirements are 

warranted to protect site integrity.

For areas outside of designated treatment areas, surface disturbing activities

including, but not limited to skid trail designation, landing creation, pile 

construction,

road construction or reconstruction/conversion, would be evaluated for risk

to rare plants and their habitat by a qualified (0430 series) botanist prior to

implementation.

Rehabilitation of pile sites would include site preparation and seeding to return the 

sites to productivity and control the spread of noxious weeds.

No wheeled or tracked equipment would be allowed within 100 feet of fens.

Temporary roads, skid trails, landings, or piles would not be located within 100 feet 

of fens.

Treatment within fens would be limited to hand felling of trees and would require

assessment by a qualified (0430 series) botanist prior to implementation. All woody

material (chips, piles, cut and chunk, logs, etc.) would be removed from the fen 

area with as little impact to the fen as possible (i.e. hand carrying out via a single

trail/disturbance).

Treatments within or adjacent to Black Hills Montane Grasslands will require 

assessment by qualified (0430 series) botanist prior to implementation. 

When logging in previously disturbed stands, existing skid trails and landings 

would be used whenever possible.

Treatment would not occur within Research Natural Areas.

Treatment would not occur within Botanical Areas.

Road Construction / 

Maintenance

New road construction would require consultation with a qualified (0430 series) 

botanist prior to implementation.

No road construction or reconstruction/conversion would be allowed if proposed 

site is located over 40% slope and up- or downslope of a known rare plant 

population in order to avoid the effects of mass movement.

Neither magnesium chloride nor calcium chloride would be used for dust 

abatement

within 500 feet of fens or known rare plant sites.

New road construction would not occur within 100 feet of fens.

Herbicide

Spraying

Areas of exposed soil associated with Mechanical Site Preparation would be 

monitored and treated as needed to prevent spread of noxious weeds.

Spraying treatments would not occur within 200 feet of fens.

Hardwood / Grassland 

Enhancement

Proposed treatment areas would be reviewed for rare plants and/or suitable habitat 

prior to contract or permit issuance. 

Pine Structural Stage 

Modification

Mechanical site preparation would not occur within 100 feet of fens or known rare 

plant sites. 

Cable logging in areas known to contain rare plants would only occur when there is 

a

foot of snow on the ground to avoid soil disturbance and impacts to rare plants.
30

Analysis of Effects of the Proposed Action (Alternative A)

Direct and Indirect Effects: Twelve Region 2 sensitive plant species were located in the area 

designated for treatment in Alternative A (action alternative), and one other species was 

determined to have suitable habitat within designated treatment areas (Table 4). Habitats most 

likely to support the species analyzed for in this project include moist and shaded white sprucedominated slopes, moist to mesic hardwood stands, drainages with spruce and/or hardwoods, 

grasslands, and riparian areas. Some species are known to occur beyond these areas, but 

generally as outlier individuals. 

Fuel Reduction and Prescribed Fire

Locations identified for potential fuel reduction and/or prescribed fire to occur include portions 

of most of the types of habitat with higher suitability for supporting Region 2 sensitive plants.

Areas identified as aspen, oak, pine/aspen mix, aspen/oak mix, and grasslands for the BHRL 

project analysis equal around 250,000 acres in the project area. Fuel treatments could occur 

across approximately 1/3 (82,000 acres) of these communities. Identification and extent of 

hardwoods, grasslands, and fuels GIS files are preliminary and approximate, but this provides 

some estimates on the acres of these habitats potentially subject to fuel treatments.

Actions associated with fuel treatments involve thinning tree densities (generally ponderosa 

pine) and assorted methods of addressing the produced woody material, including piling, lop and 

scatter, and shredding or chipping. Objectives may be achieved manually (by hand) or through 

the use of mechanized equipment. Mechanical fuel treatments, prescribed fire, and hazard tree 

removal as proposed in Alternative A would increase ecosystem resilience and reduce the 

potential for landscape-level wildfires. Fuel treatments have the potential to negatively impact 

Region 2 sensitive plants by direct contact with fire or indirectly by increased exposure to 

sediment and ash via runoff. The effects of these impacts are largely determined by the 

frequency, intensity, and season of the fire, along with climatic patterns to include moisture 

availability and any other pre-fire stressors to vegetation. Areas supporting Region 2 sensitive 

plants in the Black Hills are often associated with drainage bottoms, north-facing slopes, and 

spruce and/or hardwood overstories; typically areas with a higher soil moisture content where 

lower intensity burning would be expected. Lower intensity fire related impacts to vegetation are 

considered short-term, present from the time burning occurs until approximately the following 

growing season. However, higher intensity burns have the potential to affect below-ground 

biomass and alter species composition, including a possibility of Region 2 sensitive plant 

mortality. Aside from short-term negative impacts, prescribed fire can provide long-term benefits 

for understory vegetation, including Region 2 sensitive plants. Long-term benefits may become 

apparent within several months of treatment implementation, by removal of non-native and/or 

invasive plant species, reduction in surrounding competetion for resources, and removal of 

decadent growth-inhibiting grass and other vegetation. These benefits persist until the 

ecosystems again reach pre-implementation conditions, a time-frame which can be highly 

variable and driven by many factors (Neary et al. 1999). Fuel treatments help maintain a healthy 

amount of fuels on landscapes, reducing the risk of catastrophic wildfires. With heavier fuel 

loads, fire tends to smolder and move more slowly through affected areas, resulting in greater 

vegetative mortality than lower intensity fires (Neary et al. 1999). Fuel treatments provide the 

benefits of nutrient cycling, removal of decadent growth, and natural disturbance through a 
31

managed process. So, although proposed fuel treatments could impact individual Region 2 

sensitive plants and their habitat, the negative effects are determined to be short-term (generally 

one season), with more long-term benefits (5-15 years) becoming apparent soon after treatments 

occur. 

Enhancement of Hardwoods and Grasslands

The project would cut encroaching pine from areas of hardwoods and grasslands to enhance 

these areas. Region 2 sensitive species with higher potential to occur in hardwoods and 

grasslands include prairie moonwort, narrowleaf grapefern, foxtail sedge, yellow lady’s slipper, 

large round-leaf orchid, sage willow, autumn willow, bloodroot, and highbush cranberry. The 

other four species analyzed for this project have lower potential to occur in these areas, though 

presence remains a possibility. 

The action of removing pine and spruce from hardwood stands is capable of providing a benefit 

of retaining these stands as more suitable sensitive plant habitat. The impacts to sensitive plant 

species associated with the action depend on the method used to achieve the result. Hand falling 

pine and/or spruce in these areas would cause the least amount of disturbance, still presenting the 

possibility of sensitive plants being crushed by falling trees or covered by dropped trees and

debris. 

Mechanical treatments to remove pine and/or spruce from hardwoods would result in more 

extensive impacts to the understory vegetation from wheeled or tracked heavy equipment passing 

through, as well as soil compaction and exposure of bare soil. These impacts have the potential 

to lower the suitability of the habitat for sensitive plants by altering the understory/forb 

community during the process of enhancing the overstory. Areas where pine and/or spruce are 

removed from the overstory will result in more sunlight reaching the understory, potentially 

creating a change in micro-habitats by increasing temperature and evapotranspiration. Impacts to 

mycorrhizal fungi in the soil could impact sensitive species dependent upon relationships with 

these organisms. 

An increase in sunlight and exposure of bare soil creates favorable conditions for non-native 

and/or invasive plant species migration to new areas. These species have potential to outcompete native and sensitive plant species for resources and can alter species composition in 

areas to a point where it is no longer considered suitable sensitive plant habitat. 

Removal of encroaching pine from grasslands would provide the benefit of retaining a site as a 

grassland, offering more habitat suitable for supporting certain sensitive plants. Impacts of the 

action to sensitive plants are similar to those discussed above (for hardwood enhancement), and 

would depend upon the method by which the result is achieved. Potential impacts from the action 

include crushing sensitive plant occurrences, covering sensitive plants with debris, and 

introduction or spread of non-native or invasive plant species. 

Pine Structural Stage Modification

Actions included with pine structural stage modification include overstory removal, 

precommercial and/or POL thinning, patch cuts, tree planting, and mechanical site preparation. 

In general, pine forests are not considered highly suitable for supporting Region 2 sensitive 
32

plants in the Black Hills. Some species are known to occupy pine stands, usually consisting of 

individuals on the periphery of the core occurrences located nearby within an inclusion of more 

suitable habitat (white spruce, aspen/birch, etc.). These inclusions of spruce and hardwoods 

within pine stands have potential to be impacted by activities occurring in surrounding or 

adjacent areas. 

Heavy equipment associated with mechanical treatments can directly impact understory plants 

by crushing or uprooting, or by compacting soil or otherwise altering the forest floor. The 

equipment can also loosen and diplace soil, which can then collect in drainages and other lowlying areas suitable for supporting Region 2 sensitive plant species. Microsite hydrology and 

fungal communities can be affected by heavy equipment to a point where Region 2 sensitive 

species (such as prairie moonwort, narrowleaf grapefern, yellow lady’s slipper, mountain lady’s 

slipper, and large round-leaf orchid) could be inhibited from establishing. 

Mechanical site preparation to promote the establishment of pine seedlings would result in 

exposing bare soil on up to 4,000 acres in open, mature pine stands. Although the action creates 

conditions favorable for pine establishment, it also provides opportunity for establishment and 

spread of non-native and/or invasive plant species. Once established in the mechanically 

prepared areas, these species have potential to spread into other nearby areas of suitable sensitive 

plant habitat. 

Other potential indirect effects result from greater use of existing roads for hauling, resulting in 

an increase in erosion and dust pollution. Sensitive plant individuals that are not documented 

which occur along roads could experience reduced photosynthetic capacity due to a coating of 

dust on the leaves. Also, removal of timber may open access to areas previously protected from 

impacts by livestock and illegal off-road vehicle use. New use in areas increases not only the 

potential for unauthorized collecting, trampling, and other losses of individuals, but also 

increases the susceptibility of non-native or invasive plant species invasion. 

Connected Actions

Supporting actions associated with proposed action include road construction (Specified: up to 

17 miles, Temporary: up to 39 miles), reconstruction and/or maintenance for use of temporary 

roads on existing templates, road conversion (from unclassified to system designation), and 

creation of skid trails and slash piles. Roads and skid trails have the potential to alter ground 

surface by crushing and/or uprooting vegetation, compacting or otherwise altering soil, exposing 

bare soil, and introducing non-native and/or invasive plant species to an area. New road 

construction is not proposed within 500 feet of any known Region 2 sensitive plant occurrences. 

Use of existing Unclassified roads could occur within 500 feet of 4 sites supporting Region 2 

sensitive plants (foxtail sedge, large round-leaf orchid, bloodroot, highbush cranberry), and one 

temporary road is proposed within 500 feet of another site (trailing clubmoss). 

A potential beneficial indirect effect of the proposed action is the introduction of disturbance, 

such as use of temporary roads and skid trails. These disturbed areas, if decommissioned, treated 

for invasive species, and left undisturbed for a decade could become suitable habitat for Region 2 

sensitive species such as narrowleaf grapefern and prairie moonwort, as these species are 

associated with historically disturbed areas. 
33

Slash piles are often situated outside of pine stands, in open areas, or on the periphery of 

grasslands/meadows. Multiple passings to these areas by heavy equipment can compact soil and 

devegetate pathways. Piles have the potential to be placed upon Region 2 sensitive plant species, 

most notably prairie moonwort and narrowleaf grapefern. Undocumented individuals of these 

species have the potential to be buried by debris. Piling of unused forest materials results in 

alteration of the site below via increased temperatures, blocking of sunlight and other resources, 

and general surface disturbance. Piles planned for burning result in high temperatures below and 

surrounding piles, and further surface disturbance. Although an approved seed mix is distributed 

across the affected area, non-native and/or invasive plant species commonly colonize these areas 

after burning (Haskins & Gehring 2004). 

Dust Abatement

Use of dust abatement (water, magnesium chloride, calcium chloride, etc.) causes a decrease in 

airborne dust. Airborne dust can adhere to photosynthetic surfaces ultimately causing a decrease 

in the ability of an individual plant to grow. The addition of salt to dust abatement treatments 

allows the treatment to be effective for a longer period of time; however, high concentrations of 

ions in the soil matrix caused by the addition of magnesium chloride or calcium chloride can 

decrease plant growth and survival (Goodrich et al. 2009). These ions usually move down slope 

from treated roads, but impacts can be observed up slope and relate to application rate (Goodrich 

et al. 2008, Piatt and Krause 1974). The distance from treated road surface causing impacts to

vegetation would increase with an increase in the surface area to which the treatment was 

applied, the application rate, and average precipitation (Goodrich et al. 2008, Goodrich et al. 

2009). On average, chloride ions can move down slope from the site of application

approximately six meters and magnesium can move three meters from application site regardless 

of the soil type (Goodrich et al. 2009).

Aspen (Populus tremuloides) growing down slope from application sites could show necrosis of 

leaf margins, crown damage, and mortality depending on the application rate and surface area 

treated upslope from the tree (Goodrich et al. 2009). In coniferous tree species, high

concentrations of ions in needle tissue can cause an increase in susceptibility to agents such as 

fungus, insects, and mechanical damage caused by frost and snow (Goodrich et al. 2009). In

grasses, germination generally decreases with increased concentration of magnesium ions 

present in the soil (Ryan et al. 1975). 

Impacts to Habitat

Design Criteria require that consultation with a qualified, professional series botanist occur prior 

to ground disturbance in suitable sensitive plant habitat. The intent is that this consultation would 

minimize impacts to the habitat and any occurrences of Region 2 sensitive plant species located 

in the potential habitat. If impacts of ground disturbance on suitable habitat cannot be avoided, 

the possible impacts to the habitat itself are discussed below. Impacts to Region 2 sensitive

species are discussed separately.

White Spruce

Impacts to white spruce stands should be minimal because the treatment areas target ponderosa 

pine stands, hardwoods, and grasslands, although white spruce may be targeted for removal from 
34

hardwood stands. Impacts to white spruce stands outside of treatment areas could occur if 

landings, log decks, roads, or debris piles need to be constructed in order to facilitate timber 

harvest. Ponderosa pine could potentially be removed from white spruce stands that are found 

within larger ponderosa stands. If either of these potential impacts to white spruce stands occurs, 

impacts to the habitat include removal of white spruce and damage to standing white spruce, 

including damage to root structures, during felling and removal of ponderosa pine. Road 

construction in white spruce habitat could alter the local hydrology, create a vector for nonnative or invasive plant introduction, and create a source of erosion. In addition to the impacts

discussed in the Dust Abatement section, use of chemicals can cause needle burn or mortality of 

white spruce along the road, particularly down slope and the risk increases with area treated, 

application rate and frequency, and distance from the treated surface (Goodrich et al. 2009). 

Changes in the overstory of white spruce stands would cause changes to the under and midstory, 

which in turn impact the habitat which certain Region 2 sensitive species require to survive.

Hardwood Habitat Including Paper Birch, Aspen, and Bur Oak

Impacts to hardwood habitats are discussed in the above section Enhancement of Hardwoods and 

Grasslands. Beyond what is noted there, impacts to this habitat include damage to standing 

hardwoods, including damage to root structures, during felling and removal of ponderosa pine. 

Changes in the overstory of hardwood stands would cause changes to the under and midstory, 

which in turn impact the habitat which certain Region 2 sensitive species plant SOLC require to

survive.

Riparian Habitat Including Wetlands and Fens

Plant species in wetlands, riparian areas, and seeps could be impacted by changes in hydrology 

and water quality. Roads that currently exist in the water influence zone of wetlands can cause 

increased erosion, which can modify stream bank geometry and cause an increase in overland 

flow. Increases in overland flow will have the net effect of maximizing runoff and minimizing 

infiltration. While the increased runoff results in overall greater water yield, the storm water is 

delivered relatively quickly through surface processes rather than through sustained subsurface 

flows, which are often critical to wetland hydrology (Moore et al. 2006). Impacts to fens 

specifically are discussed in the Black Hills Resilient Landscapes Project Botany Report.

While direct impacts to riparian habitat are possible, moist soils and riparian areas are protected 

during timber harvest and new road-building on National Forest land under Best Management 

Practices and Forest Service Manual 2509.25. In addition to the impacts discussed in the Dust 

Abatement section, use of these chemicals can cause leaf necrosis or mortality of forbs and 

grasses along the road (Ryan et al. 1975), particularly down slope and the risk increases with 

area treated, application rate and frequency, and distance from the treated surface (Goodrich et 

al. 2009). Design Criteria prohibit the use of these chemicals within 500 feet of fens, which will 

decrease the impact on these wetlands.

Meadows

Impacts to meadows are discussed in the above section Enhancement of Hardwoods and 

Grasslands. In general, landings, log decks, roads, or debris piles have potential to impact 

meadows and Region 2 sensitive species within the habitat. Impacts to suitable plant habitat if 

these activities occur within meadows include loss of habitat, alteration of local hydrology, and 
35

introduction of non-native or invasive plant species. If ponderosa pine trees are removed from 

meadows, equipment used during harvest could crush or uproot vegetation as well as cause 

varying degrees of soil compaction. Road construction, conversion, or maintenance in meadows 

could crush, bury, remove, or uproot vegetation. Roads can also create erosion channels that 

further impact soil structure and moisture, both of which are qualities that make meadows habitat 

for some Region 2 sensitive plants. In addition to the impacts discussed in the Dust Abatement 

section, use of these chemicals can cause leaf necrosis or mortality of forbs and grasses along the 

road (Ryan et al. 1975), particularly down slope and the risk increases with area treated, 

application rate and frequency, and distance from the treated surface (Goodrich et al. 2009). 

Changes in meadow habitat could alter the habitat quality such that certain Region 2 sensitive 

species and plant SOLC would no longer be able to survive.

Cumulative Effects: Past, current, and reasonably foreseeable actions within the Black Hills 

Resilient Landscapes Project Area are discussed in this section. 

Activities such as vegetation management, fuels management, livestock grazing, recreational 

activities, and other management activities have occurred and will continue on the Forest. These 

activities will likely occur on private land as well. All may affect Region 2 sensitive plant 

species through direct mortality, habitat alteration, or spread of invasive species.

The annual impact to botanical resources on the Forest from timber harvest activities would 

remain comparable to previous years. Cumulative effects to botanical resources have the 

potential to increase with all new or recurring actions on the Forest, with effects ranging from 

null or minimal to significant. Stands are identified for treatment across the Black Hills National 

Forest in Management Areas identified in Table 1 (Management Areas). Most notably for 

botanical resources, treatments will not occur in Botanical Areas, Research Natural Areas, or 

Wilderness Areas, locations of higher density Region 2 sensitive plant occurrences and suitable 

habitat. 

Actions associated with mechanical site preparation have the potential to increase the presence of 

non-native and/or invasive plants in the western portion of the Black Hills. Establishment of 

invasive species across the proposed acreage (up to 4,000 acres) may result in these species 

spreading to other areas where they would not have otherwise been as likely to reach. Non-native 

and/or invasive plant species are capable of outcompeting native vegetation for resources and 

often are known to produce high quantities of seed which can be easily (and widely) dispersed 

with general requirements for propagation. The spread of non-native and/or invasive plant 

species can result in the alteration of plant communities and reduction in suitability of sensitive 

plant habitat. 

Management of national and state parks adjacent to the Forest is assumed to have a similar effect

on Region 2 sensitive plant populations. Other federal, state, and private lands offer suitable 

habitat for Region 2 sensitive plant species. Only sage willow, autumn willow, and narrowleaf 

peatmoss have not been confirmed from other federal, state, and/or private lands adjacent to 

Black Hills National Forest. 
36

Privately owned lands within the Black Hills Ecoregion may also provide suitable habitat, but 

resource management by companies and private citizens depends on a number of factors (e.g., 

desired goals, market prices, development potential) making it difficult to predict future trends in 

private habitat diversity and quality. Suitable habitat for Region 2 sensitive plants may occur on 

private lands across the Black Hills. Further urban development in the Black Hills will likely 

continue to affect habitat, including white spruce communities and paper birch/hazelnut forest, 

thereby increasing the importance of stands on Forest Service lands.

Analysis of Effects for the No Action Alternative (Alternative B)

Direct and Indirect: Under Alternative B (no action) there would be no direct effects to

botanical resources since implementation of elements of the proposed action would not occur. 

Ongoing forest management and recurring road maintenance on system roads would continue as 

directed by the Forest Plan. Timber harvest project areas generated by each District would 

continue as planned, as would analysis of future planned timber projects. 

Alternative B would maintain Region 2 sensitive plants and suitable habitat and protect 

biodiversity by not implementing actions with potential to impact these resources, though over 

time the forest would experience an increase in ponderosa pine, including further encroachment 

into stands of hardwoods, riparian areas, and grasslands. Structural stage objectives outlined in 

the Forest Plan may be addressed through other management, but not likely to the extent as 

proposed with the BHRL project. 

Cumulative: If no action is taken, it is unlikely that Forest structural stage conditions will 

become aligned with the goals outlined in the Forest Plan. Managing for specific structural stage 

conditions had not been a primary focus during the mountain pine beetle epidemic. Cumulative 

impacts associated with no action include retention of large areas of monotypic stands which 

could become susceptible to mountain pine beetle epidemic in the future. Alternative B would 

also result in a decrease in landscape diversity, reduced health of hardwood stands, and a 

decrease in areas of grasslands unless these items were addressed through another management 

action. 

VI. DETERMINATIONS OF EFFECT AND RATIONALE 

The determination of effects on Region 2 sensitive plant species in the BA/BE were made as a 

result of the information gathered in the pre-field review, field reconnaissance, survey results, 

and effects analysis for the action alternative. The determinations were based on effects of 

proposed activities on known populations and impacts to populations that could occur in areas 

that are unsurveyed for all Region 2 sensitive plant species. The determination language is set 

forth in Forest Service Manual 2670.

Determinations consider the extent of each plant species’ distribution on the Forest and within 

the project area. Species may be limited in documented occurrences, located within a restricted 

range, have highly specific habitat requirements, or have a significant percentage of known sites 

located within, or within close proximity to, areas identified for potential treatment in Alternative 

A. 
37

Objectives, standards, and guidelines have been identified in the Forest Plan Phase II to conserve 

Region 2 sensitive species located on the Black Hills National Forest. This project will follow 

the objectives, standards, and guidelines applicable to those species and habitats found in the 

Black Hills Resilient Landscapes Project Area.

Most Region 2 sensitive plant species and plant species of local concern on the Black Hills 

National Forest are globally secure, with the exception of prairie moonwort and narrowleaf 

grapefern (NatureServe 2015). This, in combination with the rangewide presence of these 

species, can be interpreted to mean that if all of the occurrences of these species on the Forest 

were extirpated, the species would most likely survive and most likely not cause a trend to 

Federal listing.

Design criteria are described at the beginning of the Effects of the Alternatives section and are 

integral to the effects determination. Any deviation from these criteria will require further 

analysis and a revised effects determination. Some mitigation measures not included here are 

Forest Service standard operating procedures. Other mitigation measures not included here are 

additional Forest Plan Standards and Guidelines (including those relating to water, soils, riparian 

areas, travel and transportation, noxious weeds, and livestock grazing). Project implementation 

will incorporate all Forest Plan Standards and Guidelines. 

The expected determinations of effects for each species are contingent upon, to varying degrees, 

implementation of the design criteria and mitigation. With mitigation measures fully 

implemented, a determination of “May adversely impact individuals, but not likely to result in a 

loss of viability in the planning area, nor cause a trend to federal listing or a loss of species 

viability range-wide” is made for the following Region 2 sensitive plant species for the proposed 

action:

Prairie moonwort Botrychium campestre

Narrowleaf grapefern Botrychium lineare

Foxtail sedge Carex alopecoidea

Mountain lady’s slipper Cypripedium montanum

Yellow lady’s slipper Cypripedium parviflorum

Trailing clubmoss Lycopodium complanatum

Large round-leaf orchid Platanthera orbiculata

Sage willow Salix candida

Autumn willow Salix serissima

Bloodroot Sanguinaria canadensis

Narrowleaf peatmoss Sphagnum angustifolium

Highbush cranberry Viburnum opulus var. americanum

Great-spurred violet Viola selkirkii
38

Table 4 summarizes determinations for all analyzed Region 2 sensitive plant species for both 

alternatives identified in the BHRL project.

Table 4: Determination Summary by Alternative for Analyzed Species

Species Alternative A 

(proposed action)

Alternative B 

(no action)

Prairie moonwort MAII3 NI1

Narrowleaf grapefern MAII NI

Foxtail sedge MAII NI

Mountain lady’s slipper MAII NI

Yellow lady’s slipper MAII NI

Trailing clubmoss MAII NI

Large round-leaf orchid MAII NI

Sage willow MAII NI

Autumn willow MAII NI

Bloodroot MAII NI

Narrowleaf peatmoss MAII NI

Highbush cranberry MAII NI

Great-spurred violet MAII NI

1 - No Impact

2 - Beneficial Impact

3 - May adversely impact individuals, but not likely to result in a loss of viability in the Planning 

 Area, nor cause a trend toward federal listing.

4 - Likely to result in a loss of viability in the Planning Area, or in a trend toward federal listing. 
39

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