1

BIOLOGICAL EVALUATION

Sensitive Plant Species

Smith River Road Management and Route Designation Project

Six Rivers National Forest

Smith River National Recreation Area

2013

Prepared by: ____________ Date: 

John McRae

Assistant Forest Botanist
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I. INTRODUCTION

The objectives of this biological evaluation are (a) to determine the effects of the 

proposed action on any sensitive botanical species and (b) to insure these species receive 

full consideration in the decision-making process to maintain species viability (FSM 

2672.4).

II. CURRENT MANAGEMENT DIRECTION

Current policy for Sensitive plants as stated in the Land Management and Resource Plan 

for Six Rivers National Forest includes the following: After completion of the 

evaluation, proposed actions will be prohibited if they are found likely to jeopardize the 

continued existence of species or the maintenance of viable populations throughout their 

existing range (LRMP S&G 6-2). 

Current policy for Sensitive plants as stated in the Forest Service Manual include the 

following elements:

-Maintain viable populations of all native and desire non-native wildlife, fish, and plant 

species in habitats distributed throughout their geographic range on National Forest 

System lands (FSM 2670.22). 

-Avoid or minimize impacts to species whose viability has been identified as a concern 

(FSM 2670.32).

-If impacts cannot be avoided, analyze the significance of potential adverse effects on the 

population or its habitat within the area of concern and on the species as a whole (FSM 

2670.32) 

III. DESCRIPTION OF PROPOSED ACTIONS

The preferred alternative, Alternative 6, of the Smith River Road Management and Route 

Designation Project (SRRMRD) on Six Rivers National Forest proposes to:

Add 27 inventoried unauthorized routes (UARs) as roads totaling 12 miles to the 

NFTS. 

Add 77 UARs as motorized trails totaling 42.45 miles to the NFTS.

Add seasonal gate closures on 10 roads and 6 motorized trails totaling 34 miles.

Add mixed use to one road, 17N49.

Decommission 76 closed roads totaling 39.40 miles and decommissioning 36 open 

NFTS roads totaling 15 miles.

Restore hydrologic function to 210 UARs totaling 101 miles.

Add 4 parking areas.
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The area affected by the proposal includes Smith River National Recreation Area 

(SRNRA). This action is needed to: provide motor vehicle access to dispersed recreation 

opportunities (camping, hunting, fishing, hiking, horseback riding, etc.) and provide a 

diversity of motorized recreation opportunities (4X4 vehicles, motorcycles, ATVs, SUVs, 

passenger vehicles, etc.). Actions proposed add short inventoried UARs to popular dispersed 

recreation sites to the NFTS; restores hydrologic function on short inventoried UARs to dispersed 

recreation sites not added to the NFTS; barricades inventoried UARs not added to the NFTS; and 

designate parking along road 17N49. 

IV.EXISTING ENVIRONMENT

Background

The SRNRA is located in the Klamath-Siskiyou Ecoregion of Northwest California and 

Southwest Oregon which is recognized as an area of extraordinary biodiversity 

(Whittaker 1961; Kruckeberg 1984; Brooks 1987). The region is regarded as an “area of 

global botanical significance” (one of seven in North America as defined by the World 

Conservation Union [IUCN], a global “centre of plant diversity, and a proposed “world 

heritage site” and UNESCO “biosphere reserve” (Vance-Borland et al. 1995). More than 

3,500 plants, including 225 endemics are known to occur in the Klamath-Siskiyou 

Ecoregion (Sawyer 2006). 

Of the endemism characteristic of the Klamath-Siskiyou Ecoregion, the majority is 

represented within habitats associated with the Josephine ultramafic sheet that extends 

from Northwest California to Southwestern Oregon. This belt of ultramafic parent 

material is one of the largest in North America and has the greatest concentration of 

endemic plant species restricted to this substrate (Kruckeberg 1984). Ultramafic parent 

materials, generically called serpentine, weather into soils that are high in heavy metals 

and low in essential nutrients. This serpentine soil chemistry along with other biological 

and physical factors, gave rise to distinctive plant communities that support a 

preponderance of rare plant species, many of which only occur on serpentine soils, 

resulting in their characterization as serpentine endemics. Serpentine endemics are 

generally confined to serpentine because they require the reduced competition 

characteristic of harsh, open, rocky sites (Brooks 1987). 

The important role serpentine plays in providing habitat to support a significant number 

of rare species in California is exemplified by the fact that only 1.5% of the State is 

underlain by ultramafic rock and yet 13% of the plant species endemic to California are 

serpentine endemics (Safford et. al. 2005). The Centre for Plant Diversity’s tracking of 

endemism notes that within the California Floristic Province the Josephine ultramafic 

sheet is one of the richest in endemics. In addition, serpentine settings support the 

highest number of plant associations described in the Klamath Province which includes 

the Six Rivers and Klamath National Forests (Jimerson 1993). 

Plant Habitats

Habitats within the area that support the highest number and diversity of rare plants 

include seasonally dry serpentine settings and serpentine wetlands. Within these habitats 
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there are at least 27 plants considered rare by the California Native Plant Society, 8 which

are members of the Region 5 Sensitive Plant list, and one Federally Endangered plant 

species. 

Seasonally dry settings include outcrops and bouldery serpentine barrens, Jeffrey pine 

woodlands, and shrub dominated areas. Low vegetative cover, and high bare soil and 

surface rock cover characterize these habitats. Due to their ridge position, gradual slopes, 

and openness, some of the barren and woodland habitats are vulnerable to cross-country 

travel that can result in the loss of plants and vegetative material, habitat fragmentation, 

and potential water diversion. 

Serpentine wetlands have saturated soils or running water year round and are generically 

referred to here as Darlingtonia fens. Wetland habitats are characterized by the presence 

of surface (perennial or intermittent) water or sub-surface water in the form of spring or 

seep flow. Topographically flat serpentine wetlands are generally termed fens and 

composed of rare plant species, sedges, and ericaceous shrubs with a low canopy cover 

dominated by Port-Orford cedar. Fens can be relatively extensive, for example, L.E. 

Horton Research Natural Area (RNA) spans approximately 40,000 square meters (1,560 

acres) (Frost et al. 2004). Serpentine wetland seeps are usually very localized sites 

where sub-surface water intersects the ground surface. Serpentine wetland riparian 

habitats for rare plants are associated with a perennial to intermittent flow of surface 

water across a gradient, boulder-lined stream banks with a low cover of ericaceous shrubs 

(western azalea being a common associate) and a moderate canopy cover dominated by 

Port-Orford cedar. 

Due to the array of Sensitive and rare species and their habitats and diverse plant 

communities in the serpentines of the Josephine ultramafic sheet, 21,370 acres of the 

sheet in the North Fork Smith River watershed was established as a botanical area- the 

North Fork Smith Botanical Area (USDA LRMP 1995). Botanical areas are established 

to protect areas of the Forest with important botanical resources (36 CFR 294.1). Also 

associated with the Josephine ultramafic sheet is the L.E. Horton Research Natural Area 

(RNA). RNAs are established to study and maintain biological diversity on National 

Forest system lands (FSM 4063). L.E. Horton (1305 acres) supports an extensive 

Darlingtonia fen with numerous rare and Sensitive species.

While the serpentine soil chemistry is a primary factor influencing the botanical 

distinctiveness of this area, it is the heavy metals (i.e. chromium, nickel) within the parent 

material that has also driven minerals mining and exploratory mining. As a result, the 

environment has been altered by development of roads, exploratory grids, mining spoil 

sites, mining pits and adits. The most recent exploratory mining occurred approximately 

30-35 years ago. Mining-related disturbance is particularly evident on Gasquet 

Mountain. 

Sensitive Species

Sensitive species are those eligible for listing under the Endangered Species Act, or 

whose viability is of concern. These are protected by USDA Forest Service regulations 

and manual direction. The Region 5 Sensitive Plant List was updated and signed July 3, 
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2013 by the Regional Forester. This new list supersedes earlier lists and is the one used 

for this biological evaluation. 

There are 32 Sensitive botanical species on the SRNRA. Sensitive species considered for 

this analysis are those that the proposed action potentially affects (FSM 2672.42). The 

following Sensitive bryophyte, lichen and fungi species were not include in this analysis 

because critical habitat components, host trees and canopy cover will not be affected by 

the proposed action. Limited vegetation removal will occur at culvert removal sites at 

stream crossings on roads that will be decommissioned, and is not expected to exceed 16 

acres total across the entire District. These species include Boletus pulcherrimus , 

Buxbaumia viridis, Calicium adspersum, Cudonia monticola, Dendrocollybia racemosa, 

Fissidens pauperculus, Leptogium siskiyouensis,Mielichhoferia elongate, Otidea smithii,

Peltigera gowardii, Phaeocollybia olivaceae, Ramalina thrausta, Sulcaria badia,and 

Tricholomopsis fulvescens. The following Sensitive species will not be affected by the 

proposed action because their range does not extend onto the project area nor have 

botanical surveys found them to be present within the project area. These species include 

Cypripedium montanum, Epilobium oreganum, Erigeron maniopotamicus, Eriogonum 

hirtellum, Erythronium hendersonii, Eucephalus vialis, Draba carnosula, Illiamna 

latibracteata, Lewisia kelloggii ssp. kelloggii, Pedicularis howellii, Sanicula tracyi,and 

Tauschia howellii. The nearest location for Cypripedium montanum, Lewisia kelloggii 

ssp. kelloggii and Thermopsis robusta is over 20 miles south in Humboldt County on the 

Orleans Ranger District. Epilobium oreganum, Eriogonum hirtellum, Draba carnosula, 

Eucephalus vialis, Illiamna latibracteata, Pedicularis howellii,Smilax jamesii and 

Tauschia howellii are known to occur several miles east of the project area on the 

Siskiyou and Klamath National Forests. The nearest location of Tauschia howellii is over 

4 miles east of Prescott Mountain in the Siskiyou Wilderness. The closest known sites 

for Lathyrus biflorus, Lupinus constancei, Minuartia decumbens and Aniscocarpus 

scabridus are many miles south of the project area in or adjacent to the Lassics Botanical 

Area in Trinity County. The closest known sites for Erigeron maniopotamicus, Frasera 

umquaensis, Sanicula tracyi,Sedum obtusatum ssp. paradisum and Streptanthus 

oblanceolatus are in Trinity County, a substantial distance from the project area. The 

closest known site for Bensoniella oregana is in Humboldt county over 45 miles from the 

project area. Tracyina rostrata is not known to occur on Six Rivers N.F. and known sites 

are located south of the Forest.

The Forest Service Sensitive species considered in project area that have the potential to 

be affected by the proposed action are as follows:

Howell’s jewelflower – Streptanthus howellii

Koehler’s rockcress- Boechera koeleri

Clustered ladys-slipper – Cypripedium fasciculatum

Opposite-leaved lewisia – Lewisia oppositifolia

Serpentine catchfly – Silene serpentinicola

Siskiyou bells – Prosartes parvifolia

Waldo gentian – Gentiana setigera

Western bog violet – Viola primulifolia ssp. occidentalis

Western ragwort – Packera Hesperia
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Field Survey Results

Analysis of effects of proposed actions to Sensitive plant species and the compellation of 

species occurrence data for California utilized data on known occurrences within the 

project area derived from the California Natural Diversity Database (CNDDB 2013), the 

Six Rivers National Forest (SRNF) botanical database combined with new occurrence 

data obtained from field surveys that took place in 2006, 2011, 2012 and 2013. The 

SRNF botanical database contains occurrence location data derived from field surveys 

that date from the early 1980’s up through 2013. 

Surveys were conducted in those areas where target species could be affected. System 

roads were not surveyed as their highly altered, engineered surfaces are not considered 

suitable habitat for the target species nor are the target species known to occur on these 

surfaces. 

Surveys were performed to determine the presence or absence of Sensitive plant species 

and they also served to validate the risk ratings assigned prior to field reconnaissance. 

Where Sensitive plant species were not found to be present on or adjacent to (within 100 

feet) routes surveyed, moderate to high risk rating associated with these routes are no 

longer valid. Some non-system roads proposed for decommissioning were originally 

assigned a botany risk of moderate because they crossed serpentine habitat. Since 

known sites of the target species were not found on these routes their risk ratings are no 

longer valid.

A total of 25.9 miles of routes were surveyed from May 9 to June 23 2006, 5.0 miles

were surveyed during September 2011, 1.1 miles were surveyed from April – May 2012

and 5.0 miles from May to September 2013 by Forest Service botanists. 2013 surveys 

focused primarily on unauthorized routes to dispersed campsites, proposed parking areas 

on 17N49 and incidental findings associated with inventory of Arabis macdonaldiana

sites prioritized for surveys in 2013. A majority of these route segments are associated 

with old mining roads within the North Fork and main stem Smith River watersheds on

the SRNRA and located on the Gasquet, High Divide, High Plateau, and Hiouchi 7.5 

minute USGS quads. In addition to surveys of non-system route surfaces, surveys were 

also conducted on the non-system route edges out to 100 feet on either side if suitable 

habitat was present to address the illegal incident of vehicles driving off the road. 

Surveys were performed in 2013 on routes to dispursed camp sites and on proposed 

parking areas on 17N49.

It is important to emphasize that surveys associated with this project were not conducted 

at the occurrence level. If surveys had been performed at the occurrence level, extending 

beyond proposed routes, the ratio of plants on routes to plants off routes would likely 

have been lower. Casual observations made on Pine Flat Mountain indicate a number of 

Sensitive plants exist outside the surveyed area. Because of its remoteness High Plateau 

has not been surveyed to any extent and it is likely that there are more Sensitive plants 

there than is currently known. Consequently, the numbers of plants provided in the 

following tables do not present a complete picture of the population size of the 

occurrences, but rather what is known based on limited surveys. In essence the 

population data with regards to the high percentages of plants found on route surfaces is 
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biased by the fact that a majority of the surveys performed for the project occurred within 

100 feet of existing roads.

Sensitive botanical species not found to be present are herein removed from further 

analysis. The following Sensitive botanical species were found to be present within 100 

feet of or on roads:

Howell’s jewelflower – Streptanthus howellii

Opposite-leaved lewisia – Lewisia oppositifolia

Serpentine catchfly – Silene serpentinicola

Waldo gentian – Gentiana setigera

Western bog violet – Viola primulifolia ssp. occidentalis

Species Accounts

Strepthanthus howellii (Howell’s jewelflower) STHO

Strepthanthus howellii (species code = STHO) is a rare herbaceous perennial forb. It is 

often found were large rocks and boulders provide protection and along roads surrounded 

by dense shrub cover. It is often observed in disturbed niches which has led to 

speculation that this is due to such factors as improved conditions for seed germination, 

the reduction in competition from more aggressive plant species, passive avoidence, or 

morphological traits that afford some protection from negative effects and adaption to fire 

disturbance. The role of passive avoidance and protective morphological traits will be 

discussed further in Section V. Effects of the Proposed Action.

STHO is confined to dry, brushy serpentine exposures on the Josephine ophiolite in the 

Siskiyou Mountains of Josephine and Curry counties, Oregon and Del Norte county in 

California. The California Native Plant Society rates it as List 1B.2 - Rare, threatened, or 

endangered in California and elsewhere. It is a Forest Service Region 5 and Region 6 

Sensitive Species and is included on the BLM Oregon State Office Sensitive Species List.

There are 33 element occurrences1known to exist in Curry and Josephine Counties, 

Oregon (OHNPDB 2013). Of the 33 occurrences known from Oregon, 10 have not been 

observed in over 20 years and 15 have not been observed in at least 10 years. Twelve 

have fewer than 12 ramets2, 22 have a “poor estimated viability” rating, 4 lack population 

counts and 5 have “good” to excellent” estimated viability in the Oregon Natural 

Heritage Program database. 

STHO has been assigned a global conservation status rank of G2 (Imperiled) with a high 

risk of extinction due to its very restricted range, very few occurrences, small number of 

individuals, intrinsic vulnerability, and environmental specificity. Federal land 

management agencies (especially the Forest Service and BLM) have placed increasing 

emphasis on NatureServe ranks to prioritize their conservation and planning efforts. 

 

1 The biologically neutral term “occurrence,” as defined by the state Natural Heritage Program, denotes 

geographically distinguishable sites (within 1⁄4 mile of each other) for rare species (NatureServe 2006). 

2 Ramets represent the number of vegetative units or stems produced by a plant. For multi-stemed plants 

that branch below ground they represent what is visible to the observer. 
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Sensitive plant surveys for the Smith River RMRD project found the following number 

of plants of STHO either on or adjacent to the travel surface of unauthorized routes 

proposed for designation as motorized trails. STHO is rhizomatous in nature. An 

underground stem gives rise to one to several shoots making a count of actual plants 

impossible without digging plants up. Excavation of one plant of STHO revealed that it 

produced 3 shoots. Hence an individual plant of STHO may produce 1 to 3 shoots at a 

minimum. Census data displayed herein records the number of shoots observed and are 

recorded as plants. As shown below in Table 1, of the total population of 1561 STHO 

plants known to occur in California, 11% occur on unauthorized routes proposed for 

designation and 2% are adjacent to unauthorized routes proposed for designation as 

motorized trails. No plants were found between 32 ft. and 100 ft. from the proposed 

motorized trails.

Proposed Motorized Trail

Distance in Feet From Center of Trail

0’ to 9’ 9’ to 33’ 33’ to 100’

17N49.104 100 22 0

17N49.107 1 1 0

17N49.108 0 2 0

17N49.11 34 2 0

17N49.4 8 0 0

17N49.7 0 6 0

17N49.8 13 0 0

305.118 8 0 0

305.121B 5 1 0

305.125 0 1 0

Plant Totals 169 35 0

% of CA Population Effected 11% 2%

Table 1 - Number of STHO Plants On or Adjacent to Proposed Motorized Trails

There are 50 occurrences of STHO in Del Norte County, California. These California 

occurrences are all located on Six Rivers NF on the SRNRA which supports the southernmost extension of this taxon. Some of these occurrences do not have census data. These 

occurrences, referred to as legacy occurrences, were recorded in the distant past where 

plants were found to be present but the number of plants observed were not recorded. 19 

of these legacy occurrences that have not been visited since prior to 1985. These 

occurrences and others for which no census data exists were assigned a plant count of 

one. This assumption, in conjuction with the fact that the 2006 field surveys limited the 

survey area to areas within 100 feet of unauthorized routes, has likely resulted in an 

under-respresentation of the actual number of individuals of this species that occurs 

within the project area.
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Table 2 shows that of the 50 known occurrences of STHO in California, 4 are traversed 

by unauthorized routes proposed for designation as motorized trails.

 

Occurrence ProposedMotorized Trail On Surface of Trail Adjacent to 

Trail

STHO_16 305.125 0 1

STHO_017 17N49.104, 17N40.107 

17N49.108, 17N49.11, 17N49.14 156 33

STHO_27 305.121B 5 1

STHO_39 305.118 8 0

Total 169 35

Table 2 – STHO Occurrences On or Adjacent to Proposed Motorized Routes

Lewisia oppositifolia (Opposite-leaved lewisia)

Lewisia oppositifolia (species code = LEOP) is a rare to locally uncommon herbaceous 

perennial forb known only from southwestern Oregon and northwestern California. It 

occurs in barren, gravelly to cobbly soils of serpentine origin in shallow depressions and 

benches that tend to remain saturated or puddled into spring. The California Native Plant 

Society rates it as List 2.2 - Rare, threatened, or endangered in California but more 

common elsewhere. It is a Forest Service Pacific Southwest Region (Region 5) Sensitive 

Species. It is not on the Pacific Northwest Region’s (Region 6) Sensitive species list. 

There are at least 29 element occurrences in Curry, Jackson and Josephine Counties, 

Oregon according to the Oregon Natural Heritage Program (ONHP) which stopped 

tracking this species in 1989 when it was removed from ONHP List 4 (Vrilakas 2005). 

Because this species is not Sensitive in Region 6 surveys are lacking and detailed data is 

not available for occurrences in Oregon. It has been assigned a global conservation status 

rank of G4; apparently secure but factors exist to cause some concern. These factors 

include intrinsic vulnerability and environmental specificity.
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Sensitive plant surveys for the Smith River Road Management and Route Designation 

project found the following number of plants of LEOP growing either on or adjacent to 

the travel surface of unauthorized routes proposed for designation as motorized trails. As 

shown below in Table 3, of the total population of 7681 LEOP plants known to occur in 

California, 1% occur on unauthorized routes and 3% are adjacent to unauthorized routes 

proposed for designation as motorized trails. No plants were found between 32 ft. and 

100 feet from the proposed motorized trails.

Proposed

Motorized Trail

Distance in Feet From Center of Trail

0’ to 8’ 8’ to 33’ 33’ to 100’

18N51.100 0

27 0

305.109 54

179 0

Plant Totals 54 206

0

% of CA Population 

Effected 1% 3% 0%

Table 3 - Number of LEOP Plants On or Adjacent to Proposed Motorized Routes

Table 4 shows that of the 17 known occurrences of LEOP in California, 4 are traversed 

by unauthorized routes proposed for designation as motorized trails. There are 17 

occurrences of LEOP in California. Four, or 24% of the 17 occurrences have the 

potential to be affected by the proposal to designate unathorized routes as motorized 

trails.

Occurrence Name ProposedMotorized Trail

On Surface 

of Trail.

Adjacent to 

Trail

LEOP_011 305.109 12 17

LEOP_012 305.109 42 0

LEOP_013 305.109 0 162

LEOP_014 18N51.100 0 27

Total 54 206

Table 4 - LEOP Occurrences On or Adjacent to Proposed Motorized Routes
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Silene serpentinicola (serpentine catchfly)

Silene serpentinicola (species code = SISE10) is a rare herbaceous perennial forb known 

only from Del Norte county, California. Recent surveys have failed to find it in Oregon. 

It occurs in dry, gravelly to cobbly soils of serpentine origin on flat cross slopes. Little is 

known about the biology of this species although it appears to be early successional in 

nature with a preference for disturbed soils found on or adjacent to roads where 

surrounding shrub cover is fairly dense. Like STHO it is often observed in disturbed 

niches which has led to speculation that this is due to such factors as improved conditions 

for seed germination, the reduction in competition from more aggressive plant species, 

passive avoidence, or morphological traits that afford some protection from negative 

effects. The role of passive avoidance and protective morphological traits will be 

discussed further in Section V. Effects of the Proposed Action.

The California Native Plant Society rates it as List 1B.2 - Rare, threatened, or endangered 

in California and elsewhere. It is a Forest Service Pacific Southwest Region (Region 5) 

Sensitive Species. It is a recently described species (Nelson and Nelson 2004). Because 

it is recently described surveys are lacking and detailed information is not available for 

range wide occurrence data. Data provided here on number of plants is largely a result of

surveys performed for the proposed action. It has been assigned a global conservation 

status rank of G2 (Imperiled) with a high risk of extinction due to its very restricted 

range, very few known occurrences, intrinsic vulnerability, and environmental 

specificity.

Like STHO, SISE10 produces ramets and like STHO, underground stem gives rise to one 

to several shoots making a count of actual plants impossible without digging plants up. 

Excavation of one plant of SISE10 revealed that it produced 5 shoots. Hence an 

individual plant of SISE10 may produce 1 to 5 shoots at a minimum. Census data 

displayed herein records the number of shoots observed and are recorded as plants. 

Sensitive plant surveys for the Smith River RMRD project found the following number 

of plants of SISE10 growing either on or adjacent to the travel surface of unauthorized 

routes proposed for designation as motorized trails. As shown below in Table 3, of the 

total population of 28431 SISE10 plants known to occur in California, 19% occur on 

unauthorized routes and 11% are adjacent to unauthorized routes proposed for 

designation as motorized trails. No plants were found between 32 ft. and 100 ft. from the 

proposed motorized trails.
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Distance in Feet From Center of Trail

Proposed Motorized Trail 0’ to 8’ 8’ to 33’ 33’ to 100’

17N49.101 600 0 0

17N49.102 1000 0 0

17N49.104 746 745 0

17N49.107 281 0 0

17N49.11 480 1236 0

17N49.13 94 18 0

17N49.4 375 375 0

17N49.7 1672 0 0

17N49.7A 0 600 0

17N49.8 58 0 0

305.109 46 249 0

305.121B 420 0 0

Total 5772 3223 0

% of CA Population Effected 20% 11% 0

Table 5 - Number of SISE10 Plants On or Adjacent to Proposed Motorized Routes

There are 11 occurrences of SISE10 in Del Norte County, California on Six Rivers N.F. 

on the Smith River National Recreation Area. There are 29 occurrences of SISE10 in 

California. 14, or 50% of the 29 occurrences have the potential to be affected by the 

proposal to designate unathorized routes as motorized trails.

Occurrence ProposedMotorized 

Trail On Surface of Trail Adjacent to Trail

SISE10_006 17N49.4 375 375

SISE10_007 17N49.101 300 0

SISE10_008 17N49.102 1000 0

SISE10_009 17N49.101 300 0

SISE10_011 17N49.107 281 0

SISE10_012 17N49.104 0 200

SISE10_013 17N49.7

1672 0

SISE10_014 17N49.11 480 1236

SISE10_016 17N49.8

358 350

SISE10_017 17N49.14 0 600

SISE10_018 17N49.104 446 195

SISE10_019 17N49.13 94 18

SISE10_022 17N49.121B 420 0

SISE10_027 17N49.121b 46 249

Total 5772 3223

Table 6 - Occurrences On or Adjacent to Proposed Motorized Routes
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Serpentine Wetlands

Serpentine wetlands are the primary habitat for many rare plant species that occur in the 

Klamath-Siskiyou Ecoregion of northwest California and southwest Oregon. These 

wetlands, dominated by Darlingtonia californica, support one of the most distinctive 

plant communities of the ecoregion and are generally referred to as Darlingtonia fens, 

seeps or bogs. This Darlingtonia/serpentine wetland habitat is characterized by the 

presence of cold surface or sub-surface water in the form of springs or seeps which flow 

over soils derived from ultramafic or “serpentine” parent materials. Darlingtonia

wetlands have a unique flora due to the serpentine geology, the intergradations of 

different floristic regions, as well as the mesic environment of these systems, which are 

surrounded by typical serpentine xeric conditions. This unique habitat restricts a number 

of rare species to a patchy distribution over a small portion of their range. Fens on Six 

Rivers NF occur at higher elevations (2410 feet) and generally exhibit higher water flows 

and soil moisture levels (Frost et. al. 2004) then those occurring to the north.

These wetlands are of particular interest from a conservation perspective because they are 

the primary habitat for five locally rare, endemic species. These taxa are Hastingsia 

bracteosa, Hastingsia atropurpurea, Gentiana setigera, Epilobium oreganum, and Viola 

primulifolia ssp. occidentalis. With the exception of one known occurrence for Gentiana 

setigera in Mendocino County, all of the known occurrences of the species brought 

forward in this analysis occur in Josephine and Curry Counties of southwestern Oregon 

and the northern portion of Del Norte County in adjacent California. Gentiana setigera

and Viola primulifolia ssp. occidentalis are Forest Service Sensitive serpentine wetland 

species that occur in the project area. Small population sizes, isolated occurrences, and 

sensitivity to disturbance (especially affects to hydrological functioning) render these 

taxa vulnerable to local extinction. Concern over this vulnerability motivated the Forest 

Service, the Bureau of Land Management and the U. S. Fish and Wildlife Service to enter 

into a Conservation Agreement (USDA USDI 2006) to coordinate efforts aimed at the 

protection of significant biological and ecological functions and values associated with 

Darlingtonia wetlands and at the conservation of the rare taxa therein. One component

of the Conservation Agreement is the identification of fens that are essential for 

maintaining the viability of the 5 taxa. One of the essential fens designated by the 

agreement, which contains both Gentiana setigera and Viola primulifolia ssp. 

occidentalis is bisected by 17N49.7, a non-system road proposed for designation as a 

motorized trail. However, due to a large in-board ditch and steep fill slope, this fen is not 

accessible by vehicles.

Gentiana setigera (Waldo gentian)

Gentiana setigera is a herbaceous perennial forb that spreads by creeping rhizomes. It is 

known primarily from southwestern Oregon and northwestern California with one 

disjunct occurrence occurring on serpentines in Mendocino county. Most occurrences are 

relatively small and isolated by unsuitable upland habitat. It is most abundant in portions 

of fens with low shrub and tree cover, high graminoid cover, and fine-textured soils with 

moderate moisture content (Frost et. al. 2004). The California Native Plant Society rates 

it as List 1B.2 - Rare, threatened, or endangered in California and elsewhere. It has been 

assigned a global conservation status rank of G2 (Imperiled) with a high risk of extinction 
14

due to its very restricted range, very few known occurrences, intrinsic vulnerability, and

environmental specificity. Gentiana setigera is more abundant in Oregon than in 

California where there is greater concern for its viability. There are 49 element 

occurrences in Curry and Josephine Counties, Oregon and 5 occurrences in Del Norte 

County, California and one occurrence in Mendocino County, California. The 5 

California occurrences in Del Norte County are all located on Six Rivers NF on the Smith 

River National Recreation Area and support approximately 2303 plants. No plants were 

found on routes proposed for designation. Occurrences in Table 7 below are ordered by 

decreasing number of plants. All occurrences in Table 8 are identified as essential 

California Darlingtonia wetland areas (USDA USDI 2006).

 Table 7 – Gentiana setigera Occurrences in California

Occurrence Name

Occurrence 

Number

Plant 

Count

In Bot 

Area

On Pine 

Flat Mtn.

On 

Gasquet 

Mtn. Other

Major Moores GESE2 1 1315 1315

Gasquet Mtn. North GESE2 2 409 409

L. E. Horton GESE2 3 276 276

Gasquet Mtn. South GESE2 4 250 250

Peridotite Creek 5 53 53

Total Number 

of Plants 2303 1368 0 659 276

Percent of 

Total 100% 59% 0% 29% 12%

Viola primulifolia ssp. occidentalis (Western bog violet)

Viola primulifolia ssp. occidentalis is a herbaceous perennial forb that spreads by 

creeping rhizomes. It is associated with flowing water, steep slopes, and coarse textured 

soils, under open canopy conditions with high rock and soil cover (Frost et. al. 2004). It 

is known only from southwestern Oregon and northwestern California. The California 

Native Plant Society rates it as List 1B.2 - Rare, threatened, or endangered in California 

and elsewhere. It has been assigned a global conservation status rank of G5T2 

(Imperiled) with a high risk of extinction due to its very restricted range, very few known 

occurrences, intrinsic vulnerability, and environmental specificity. There are 28 element 

occurrences in Curry and Josephine Counties, Oregon and 9 occurrences in Del Norte. 

All of the occurrences on the Forest are within the Smith Rivers National Recreation 

Area. 

Occurrences are ordered by decreasing number of ramets within. Ramets represent the 

number of vegetative units or stems produced by a plant. For multi-stemed plants that 

branch below ground they represent what is visible to the observer. The number of 

ramets produced by an individual plant is not known so the conversion of ramets to 

individual plants cannot be done. What is important to note is that the number of 

individuals plants is much lower than the count of 9848 ramets. No plants were found on 

routes proposed for designation. All occurrences in Table 8 with the exception of those 

on Stoney Creek, the Gasquet Toll Road, and the site on Gasquet Mtn. Road are 

identified as essential California Darlingtonia wetland areas (USDA USDI 2006).
15

 Table 8 – Viola primulifolia ssp. occidentalis Occurrences in California

Occurrence Name

Occurrence 

Number

Ramet 

Count

In Bot 

Area

On Pine 

Flat Mtn.

On Gasquet 

Mtn. Other

Gasquet Mtn. South VIPRO 1 2575 2575

Major Moores VIPRO 2 2545 2545

Gasquet Mtn. North VIPRO 3 2081 2081

Gasquet Toll Road VIPRO 4 662 662

Pioneer Village 5 650 650

L. E. Horton RNA VIPRO 6 573 573

Stoney Creek VIPRO 7 423 423

Gasquet Mtn. Road VIPRO 8 215 215

Upper Wimer 9 124 124

Total 

Number of 

Ramets 9848 2545 0 4871 2432

Percent of 

Total 100% 26% 0% 49% 25%

 

V. Effects of the Proposed Project

All proposed unauthorized routes on suitable habitat were surveyed. Those routes that 

lacked the presence of Sensitive plants were dropped from analysis due to a lack of 

effects.

As stated earlier, there were shortcomings to road-specific surveys in that in some areas 

(i.e. Pine Flat mountain) population data collected at the occurrence scale are lacking to 

evaluate the significance of potential effects of motorized vehicle use to plants on the 

road surface relative to the plants comprising the occurrence as a whole. For Gasquet 

Mountain, data are available beyond the road based survey efforts accomplished more 

recently. Given the variables associated with the data sets, the following disclosures and 

assumptions apply for purposes of this analysis:

Historic occurrences (not sampled in the last 20-30 years) and occurrences 

sampled within the last 18 years constitute the population for respective species in 

California. 

While historic occurrences are accounted for, data on the number of plants at the 

occurrence level are lacking. This is especially true for STHO for which there are

19 occurrences for which plant counts are lacking. are primarily associated with 

the remote High Plateau area. 

Occurrence data (e.g. number of plants) resulting from surveys within the last 18

years and Smith River RMRD project surveys serve as the baseline for the number 

of plants comprising the respective occurrences and population total. 

In evaluating risk where only road surface data are available, it is assumed based 

upon incidental observations beyond the road surface (i.e. Pine Flat Mountain) and 

observed response of some species to the Biscuit wildfire which extensively 

burned much of the botanical area and serpentine areas west, that a proportion of 

the plants comprising an occurrence have not been accounted for in the baseline.
16

Current Use Patterns

The position of Sensitive plant species on route surfaces in relation to tire tracks indicates 

that under the current level of use many plants are persisting as a result of passive 

avoidance. Observed patterns of use indicated that wheel tracks are, for the most part,

confined to only a portion of the road surface allowing plants to colonize unused 

portions. They have survived in niches on portions of route surfaces that vehicles avoid 

or where tires infrequently track. Additionally plants may be afforded some protection 

from rocks and rock crevices occurring on travel surfaces. Plants also persist because the 

level of use is low and this analysis does not assume increased motorized use associated 

with designation of unauthorized routes.

Table 1 shows the number of individuals, by occurrence, of Streptanthus howellii

(STHO) growing on or adjacent to route surfaces. As noted previously, these data are 

biased by the fact that a majority of Sensitive plant surveys focused on areas within 100 

feet of routes. Table 3 indicates that there is also a large number of individuals of 

SISE10 growing on route surfaces which is not surprising considering that a majority of 

the population data has been derived from road focused surveys. Note that this represents 

population data for the current known extent of the species throughout its entire range. 

For both STHO and SISE10 the extent to which the high percentages of these species on 

or adjacent to proposed motorized routes is a result of road-focused surveys is unknown 

and can only be determined through occurrence level surveys. It is interesting to note 

that no individuals of these species or any others analyzed herein were found to be 

present 33 feet beyond the proposed trails indicating that more than just a tolerance for 

disturbance may be at play.

Direct and Indirect Effects

The direct negative effects to Sensitive species as a result of the proposed action include 

crushing, uprooting, or otherwise damaging individual plants and recruits. Indirect 

negative effects pertain to 1) altering habitat beyond its capacity to support Sensitive 

species which includes soil compaction, reduction of water vapor transport, increases in 

surface temperature, reduction in soil moisture content, and the mobilization and spread 

of dust which blocks photosynthesis (Trombulak 2000), 2) loss of habitat niches for 

recruitment, 3) potential reduction in occurrence size which has implications for the vigor 

of the occurrence over time, and 4) potential for illegal motorized vehicle use off the road 

surface affecting Sensitive plant occurrences. From a beneficial effects standpoint, this 

project will prohibit motorized use within the North Fork Smith Botanical Area on 

unauthorized routes not designated and on routes barricaded (see Tables 9 and 10) 

affording additional protection to known locations of Lewisia oppositifolia, Streptanthus 

howellii, Gentiana setigera and Viola primulifolia ssp. occidentalis therein. Additionally 

the RMRD project will reduce road density across the District by decommissioning 

approximately 54 miles of roads and trails, and provide for improved management of 

motorized recreation on the Smith River National Recreation Area. In addition, the 

RMRD will reduce road miles in the L.E. Horton Research Natural Area (RNA) by 0.93 

miles (only 0.8 miles of road will be kept, along the western boundary of the RNA). 

Within the L. E. Horton RNA is a terrace fen containing an occurrence of both Viola 

primulifolia ssp. occidentalis and Gentiana setigera. This fen has been designated an 
17

essential fen in the Conservation Agreement entered into by the Forest Service, the 

Bureau of Land Management and the U. S. Fish and Wildlife Service (USDA USDI 

2006). The RMRD project will add 42 miles of non-system road to the Forest System, 

the majority of which occurs in the serpentine areas. The serpentine areas contain

suitable habitat for the majority of Sensitive plant species within the project area..

Strepthanthus howellii and Silene serpentinicola do exhibit a tolerance to disturbance by 

virtue of their presence in disturbed settings, including road beds, but there is a threshold 

beyond which plants will be negatively affected. This is evidenced by the relatively 

fewer number of plants found on the segment of non-system roads proximal to a system 

road compared to distal road segments, which receive less disturbance.

The tolerance for disturbed settings noted for Streptanthus howellii and Silene 

serpentinicola is evidenced by the relatively high number of plants (11% and 20% 

respectively) on the surface of routes. Although improved seed bed conditions and poor 

competitive ability may explain to a certain extent their occurrence in disturbed settings, 

also of significance to their survival on travel surfaces is the fact that the over-wintering 

meristematic tissue arising from the crown of an underground root is buried under a 

protective layer of soil. Plant mortality depends on the amount of meristematic tissues 

killed (Brown et. al. 2000). The fact that these species’ meristematic tissue is generated 

3 to 5 inches below ground level affords some protection from direct negative effects. 

The loss of some above ground stems to crushing or grinding would set the plant back, 

perhaps preventing flowering the following season, but it would not necessarily lead to 

the loss of the individual. 

Although over-wintering plants are afforded protection by a soil layer, above ground 

stems remain vulnerable and the ability of individual plants, which are relying on a flow 

of nutrients from these photosynthesizing stems, to survive depends on a number of 

factors. One of these, passive avoidance has been described above. Another factor is the 

ability of mature plants to produce multiple above ground stems. If one stem out of 3 is 

crushed a plant has greater odds of surviving than a plant with a single stem crushed to 

the point where nutrient transport ceases. Odds for survival are improved where more 

than one stem has to be crushed to avoid significant damage leading to loss of an 

individual plant. 

Lewisia oppositifolia is also a herbaceous perennial, however it initiates new spring 

growth from enlarged caudices which are short almost vertical stems located at or just 

below ground level (Hickman 1993). Note that only 1% of Lewisia oppositifolia plants 

were found to occur on route surfaces. Because of the shallow location of the over 

wintering buds it is more vulnerable to the grinding effects of tires than species like 

Streptanthus howellii and Silene serpentinicola which bear their over wintering buds at

greater depths. Lewisia oppositifolia is also prone to adverse effects from dewatering. 

It occurs in shallow depressions and benches that tend to remain saturated or puddled into 

spring. Actions that change the concave micro-topography can dry out occupied sites and 

make them no longer habitable. 

Gentiana setigera and Viola primulifolia ssp. occidentalis are not present on road 

surfaces. They occur in wetland habitats and their preference for saturated soils or 

flowing water precludes their presence on route surfaces with active vehicle use. These 
18

species habitat, Darlingtonia serpentine wetlands, is very sensitive to hydrological 

changes. Altering existing hydrological conditions such as changing culvert inlet or 

outlet conditions or pulling ditches along roads adjacent to occupied habitat can destroy 

roadside populations (USDA USDI 2006). If any roadwork is proposed in the vicinity of 

the site occupied by Gentiana setigera and Viola primulifolia ssp. occidentalis adjacent 

to 17N49.7, in addition to a hydrologist a botanist should be involved in formulating a 

recommendation. This wetland has been identified as an essential fen in the 

“Conservation Agreement for Hastingsia bracteosa, H. atropurpurea, Gentiana setigera, 

Epilobium oreganum, and Viola primulifolia ssp. occidentalis and serpentine 

Darlingtonia wetlands and fens from Southwestern Oregon and Northwestern California” 

(USDA USDI 2006).

The proposed action has a beneficial effect regarding Viola primulifolia ssp. occidentalis. 

Decommissioning routes that directly access wetland areas will prevent motorized traffic 

from affecting the Darlingtonia serpentine wetlands including 17N49.105, a fen that has 

been identified as an essential fen in the “Conservation Agreement for Hastingsia 

bracteosa, H. atropurpurea, Gentiana setigera, Epilobium oreganum, and Viola 

primulifolia ssp. occidentalis and serpentine Darlingtonia wetlands and fens from 

Southwestern Oregon and Northwestern California” (USDA USDI 2006).

Proposed activities associated with system roads would not affect Sensitive species due to 

lack of suitable habitat. In the unlikely event plants did occur on system roads their 

presence in small numbers in highly disturbed settings would contribute little to the 

species viability. Non-system road decommissioning (e.g. culvert removal, road 

outsloping) and barricading activities may impact Sensitive plants through the use of 

heavy equipment and limited vegetation removal, but the risk is ffset by the benefits (e.g. 

deterring illegal use) of barricading and decommissioning the roads. 

While Streptanthus howellii and Silene serpentinicola do occur on some unauthorized 

route segments experiencing use, it is not possible to state emphatically that the current 

level of use is not affecting plants. Nor is it possible to state with any certainty that 

closing these routes will either benefit the species by removing traffic or negatively affect 

the species by causing shrub encroachment. It is conceivable that designating routes with 

Streptanthus howellii and Silene serpentinicola occurring on travel surfaces would have 

both negative and beneficial effects to these species and that the beneficial effects would 

serve to moderate the negative effects.

All roads that will remain open to use will be designated and/or signed. All other roads 

are closed to use, and will be barricaded or decommissioned as necessary. In some cases 

the road will be allowed to revegetate naturally. Table 9 shows unauthorized routes that 

will be barricaded as part of the proposed action. Sensitive plants shown to be present on 

these routes will not be subject to negative effects associated with motorized use.
19

Road_Route SpCode Count_ Occurrence

17N07.2 LEOP 93 LEOP_002

17N49 STHO 1 STHO_017

17N49.100 SISE10 1139 SISE10_020

STHO 52 STHO_014

17N49.103 SISE10 225 SISE10_009

17N49.104 STHO 6 STHO_017

ARMA33 1 ARMA33_001

17N49.105 SISE10 864 SISE10_016

VIPRO2 600 VIPRO2_011

STHO 11 STHO_017

17N49.105A SISE10 310 SISE10_016

17N49.105A STHO 1 STHO_017

17N49.106 STHO 5 STHO_017

17N49.11N STHO 3 STHO_002

17N49.12 SISE10 1610 SISE10_017

STHO 92 STHO_010

17N49.4A ARMA33 1 ARMA33_001

17N49.7 SISE10 800 SISE10_015

305.100 STHO 29 STHO_024

305.107 SISE10 200 SISE10_029

STHO 14 STHO_047

305.109A STHO 155 STHO_041

LEOP 44 LEOP_011

305.115 ARMA33 17 ARMA33_039

305.126 LEOP 16 LEOP_018

STHO 45 STHO_013

305.128 SISE10 171 SISE10_023

STHO 7 STHO_039

305.131 STHO 52 STHO_033

Table 9 – Sensitive Plants on Routes to be Barricaded Under the Proposed Action

Species

Number

of 

Plants

ARMA33 19

LEOP 153

SISE10 5319

STHO 473

VIPRO2 600

Total 6564

Table 10 – Number of Senitive Plants on Routes to be Barricaded
20

Cumulative Effects 

Incremental effects of past, present, and reasonably foreseeable related future actions that 

could affect species analyzed herein include mining, recreation, and competition from 

encroaching vegetation due to both natural succession and fire suppression practices 

which have lengthened fire return intervals. The geographic scope for analyzing 

cumulative effects is based on contiguous habitat and distribution of occurrences of the 6 

species analyzed through out their known range. Given the impacts from mining, 

unmanaged off highway vehicle (OHV) use, and fire suppression, the time scale for 

analyzing past effects corresponds with the past 50 years when it is assumed these 

activities began affecting the species analyzed within the project area. An analysis of 

these past, current and foreseeable future actions follows. 

The Biscuit Fire burned over 28,000 acres on the Smith River National Recreation Area 

on Six Rivers National Forest in 2002. Eriogonum pendulum, Lewisia oppositifolia, 

Silene serpentinicola, Streptanthus howellii are early successional species that are poor 

competitors and as such it is likely that they would respond favorably to low to moderate 

severity fires. Severity mapping of the Biscuit Fire showed that 80% of the area burned 

with low to moderate severity as is characteristic of fires burning in outcrops and 

bouldery serpentine barrens, Jeffrey pine woodlands and shrub dominated areas of low 

vegetative cover and high bare soil and surface rock cover. Biscuit Fire effects to 

Gentiana setigera and Viola primulifolia ssp. occidentalis two years following the fire 

found that populations appeared to be stable throughout their range (Cramer and Frost 

2005). Neither species was unable to tolerate the fire. Therefore, effects from the 

Biscuit Fire on Eriogonum pendulum, Lewisia oppositifolia, Silene serpentinicola, 

Streptanthus howellii, Gentiana setigera and Viola primulifolia ssp. occidentalis were 

likely benign.

Fire Suppression - Frequent low-to-moderate severity fire was one of the more important 

ecological processes in the Klamath Province as well as in the eastside and southern 

Cascades. However, care must be taken in making generalization across all community 

types. The combination of wet winters and hot, dry summers characteristic of the Pacific 

Northwest results in low to moderate severity fire, high frequency fire regimes in the 

wetter areas where there is enough water for fuels to be produced and accumulate. Fire 

suppression has altered the successional dynamics of these types of communities that 

were adapted to frequent, low intensity wildfire (Agee 1993). 

In drier areas where litter is sparse the result is moderate to high severity, low frequency 

fire. (Agee 1993). In the dry Jeffrey pine savannah, where many serpentine endemics 

are found, fuel accumulation is minimal and thus fire intervals may be naturally long 

(Atzet and Wheeler 1982). The influence of fire suppression on rare early successional 

species in both dry upland serpentine habitats and serpentine wetland habitats which have 

evolved under long fire return intervals is not as clear cut as it is in communities where 

biomass production and litter accumulation is higher. What may be more significant for 

sustaining the biodiversity and rich assemblage of rare serpentine endemics within the 
21

Klamath-Siskiyou Ecoregion is temporal variation in fire-return intervals and spatial 

variation in fire intensity and patchiness (pyrodiversity).

Mining - The project area has a mining history that has left scars still visible today. 

Historically, mining has occurred in serpentine areas of flat topography such as Low 

Divide, Pine Flat Mountain, High Plateau and French Hill. Existing mining claims 

constitute the largest threat to rare plant resources in the Smith River Watershed. Roads 

related to past mining exploration have dissected habitat (serpentine barrens) and 

potentially removed individual plants or patches of Eriogonum pendulum, Lewisia 

oppositifolia, Streptanthus howellii, Gentiana setigera and Viola primulifolia ssp. 

occidentalis. Construction of exploratory shafts or pits has also degraded habitat and 

potential habitat at specific sites. With the exception of the Gasquet Mountain 

exploratory mining, there is no population data prior to exploration, so the extent to 

which these activities affected these six species is not known. 

Mining not only directly removes plants and their habitat but triggers indirect and 

cumulative effects in the form of erosion (on slopes of certain gradients, gullies develop), 

water diversion (typically road-intercepted run-off which could affect rare plantsupporting wetlands), toxic mine tailings and scars that can take decades to recover. Any 

future proposal associated with mining on Forest Service lands will require an analysis of 

effects to Sensitive plant species. Effects will be mitigated to ensure that the proposed 

action does not lead to a loss of viability for any Sensitive plant species.

Human Uses - Del Norte County's population increased by roughly 20 percent during 

1989-1991, and may grow as much as 30-40 percent in the next decade. Urban/rural 

interface problems could develop in the future. Subdivision of private property, both 

within and adjacent to the project area, and the encroachment of residential construction 

into the wildland will continue for several years. Additionally, it is being proposed to 

allow dual use, licensed and unlicensed motorized recreation vehicles, on county roads 

within the project area. These demographic processes may increase recreation and other 

resource demands in the Smith River NRA. As use of routes for motorized recreation 

increases so to does the potential for adverse effects to Sensitive plant species growing on 

the road surface, particularly Streptanthus howellii and Silene serpentinicola. Based upon 

the limited 2006 surveys which focused surveys on the roads and what is currently known 

3

these species have a high percentage (over 50%) of the detections in California growing 

on the surface of routes proposed for designation as motorized trails. Monitoring is 

essential for determining when a viability threshold is reached so that corrective action 

can be taken.

Current unmanaged recreational activities, particularly illegal OHV use occurring off 

routes has the potential to affect Eriogonum pendulum, Gentiana setigera, Lewisia 

oppositifolia, Silene serpentinicola, Streptanthus howellii, and Viola primulifolia ssp. 

occidentalis. Effects from this type of activity are expected to diminish following 

implementation of this proposed action. Restricting OHVs to designated routes will 

increase protection for sensitive plants and habitats on the Smith River National 

Recreation Area. 

 

3

Population data for historic occurrences is lacking. 
22

Information gaps exist regarding past, present and foreseeable actions that might occur to 

these species in Oregon creating uncertainty relative to cumulative effects across these 

species range. However, for reasons noted, it is likely that past, present and reasonably 

foreseeable actions associated fire suppression, mining and motorized recreation will not 

adversely effect Eriogonum pendulum, Gentiana setigera, Lewisia oppositifolia, Silene 

serpentinicola, Streptanthus howellii, and Viola primulifolia ssp. occidentalis.

Summary of Effects

The proposal to keep or remove system roads from the system will not affect Sensitive 

species due to the lack of suitable habitat on highly altered heavily disturbed system road 

surfaces. In the unlikely event plants did occur on system roads their presence in small 

numbers in highly disturbed settings would contribute little to the species viability. Nonsystem road decommissioning (e.g. culvert removal, road outsloping) and barricading 

activities may impact Sensitive plants through the use of heavy equipment and limited 

vegetation removal, but the risk is potentially offset by the benefits (e.g. deterring illegal 

use) of barricading and decommissioning the roads.

All roads that will remain open to use will be designated and/or signed. All other roads 

are closed to use, and will be barricaded or decommissioned as necessary. In some cases 

the road will be allowed to revegetate naturally. Closing certain roads or road segments 

will protect known populations of Sensitive plants.

Under the current low level of use the proposal to add non-system routes may affect 

individuals growing on travel surfaces but will not cause a trend towards listing for the 

following reasons.

In spite of the long term use of a number of non-system routes proposed for 

designation high numbers of Streptanthus howellii and Silene serpentinicola do 

occur on segments of these route surfaces due to passive avoidance and the 

species growth habit which infers some level of tolerance.

Implementation of the RMRD project is designed to provide for improved 

management of motorized recreation on the Smith River NRA. This increased 

potential to prevent illegal use and damaged sites diminishes potential negative 

effects to Sensitive plant species. 

No routes will be designated in the North Fork Botanical Area and road miles in 

the LE Horton RNA will be reduced by 0.93 miles.

IV. Determination

For reasons summarized above it is my determination that the Smith River Road 

Management and Route Designation project may affect individuals but is not likely to 

result in a trend toward Federal listing or loss of viability for Eriogonum pendulum, 

Gentiana setigera, Lewisia oppositifolia, Silene serpentinicola, Streptanthus howellii, or 

Viola primulifolia ssp. occidentalis.
23

The RMRD project will not affect any other Forest Service Sensitive plant species.
24

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Correspondence:

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