BIOLOGICAL EVALUATION (B.E.) FOR 

THREATENED, ENDANGERED, AND 

SENSITIVE VASCULAR PLANTS, 

BRYOPHYTES, LICHENS AND FUNGI 

AND 

SUPPLEMENTARY INVASIVE PLANT ANALYSIS 

AND INFORMATION FOR OTHER RARE SPECIES 

(ATTACHMENT A. & B. OF THIS B.E.) 

FOR 

BUTCHERKNIFE-SLATE VEGETATION MANAGEMENT 

PREPARED BY: Maureen Jules DATE: 08/25/2008 

MAUREEN J. JULES 

District Botanist, 

Wild Rivers Ranger District 
 Butcherknife-Slate Maureen Jules 

PROJECT PROPOSAL

The proposed action includes 2093 acres of density management, 619 acres small 

vegetation density management and 4524 acres of underburning (this number includes 

underburns following density management plus 1812 underburn only acres). For more 

details about the proposed action including details regarding planned road work and 

landing construction, refer to the EA.

FOREST SERVICE POLICY 

THREATENED & ENDANGERED SPECIES 

The USDI Fish and Wildlife Service designates proposed, endangered or threatened 

species under authority of the Endangered Species Act (ESA) of 1973, as amended 

(Public Law 93-205, 16 U.S.C. 1531 et seq). The ESA requires the Forest Service to 

develop information about the potential impacts of its proposed activities on threatened 

and endangered species before the agency commits itself to a particular course of action. 

Section 7(a)(2) of the ESA obligates all Federal agencies to: “ensure that any action 

authorized, funded, or carried out by such agency ... is not likely to jeopardize the 

continued existence of any endangered species or threatened species or result in the 

destruction or adverse modification of critical habitat of such species...” 

FS SENSITIVE SPECIES 

For Region 6 of the Forest Service, Sensitive Species are defined as those plant and 

animal species identified by a Regional Forester for which population viability is a 

concern, as evidenced by significant current or predicted downward trends in population 

numbers or density and habitat capability that would reduce a species’ existing 

distribution (FSM 2670.5). Management of sensitive species “must not result in a loss of 

species viability or create significant trends toward federal listing” (FSM 2670.32). 

INVASIVE PLANT MANAGEMENT 

For any ground disturbing activity on the Rogue River-Siskiyou National Forest (ROR-SIS 

NF) it is required to determine the risk of introducing and/or spreading invasive plant 

species. If it is determined that a project has a moderate to high risk of introducing invasive 

plant species the project decision document must identify invasive plant species control 

measures to be undertaken during project implementation (FSM 2080, Amendment No. 

2000-95-5, effective November 29, 1995). The manual allows for the use of contract and 

permit clauses to prevent the introduction or spread of invasive plant species by contractors 

and permit holders (FSM 2081.3). The list of standards from the 2005 Record of Decision 

for Invasive Plant Standards from the Pacific Northwest Region Invasive Plant Program, 

Preventing and Managing Invasive Plants will be applied to contracts. 

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PRE-FIELD REVIEW FOR TES PRESENCE OR SUITABLE 

HABITAT 

REVIEW OF DATABASES 

Databases were reviewed for known plant sites. Positive findings for T&E, S&M & FS 

Sensitive plants are archived within the Rogue River- Siskiyou rare plants database and/or 

the ISMS database which is now available through the GeoBOB database. These databases 

and the original paper site forms were checked to identify known rare plant locations 

documented within the proposed project area. 

TES PLANT SPECIES WITH POTENTIAL HABITAT 

Previously-collected plant inventory data, personal observations and scientific references 

were used to determine which species from the Regional Forester’s Sensitive Species List 

(2008) have potential suitable habitat within the project area. The Rogue River/South 

Coast Biological Assessment FY04-08 for Activities that may affect listed species in the 

Rogue River/South Coast Province for Medford District BLM, Rogue River and Siskiyou 

National Forests document was used to determine which Federally listed species have 

suitable habitat within the project area. 

Federally Listed Threatened and Endangered species

Fritillaria gentneri and Arabis macdonaldiana are the only two federally listed species 

known to occur on the Rogue River-Siskiyou National Forest. Lomatium cookii is suspected 

to occur but is not documented on the Rogue River-Siskiyou National Forest. No listed or 

proposed species in addition to these 3 are known or suspected to occur on the forest (Sam 

Friedman personal communication 11/08/07). The proposed project area is outside the range 

of Arabis macdonaldiana. However, the entire proposed project is within the range of 

Fritillaria gentneri and suitable habitat is present (USDI USFWS BA/BO 2003). 

Forest Service Sensitive species 

Vascular Plants: 

Workers surveyed for the potential occurrence of all Sensitive vascular plants suspected or 

documented on the Rogue River-Siskiyou National Forest. Yet surveys were primarily 

focused on the following species: Cypripedium fasciculatum, Epilobium oreganum, 

Eschscholzia caespitosa, Eucephalus vialis, Gentiana setigera, Lewisia leana, Limnanthes 

gracilis var. gracilis, Lomatium engelmannii, Lotus stipularis, Perideridia erythrorhiza, 

Solanum parishii, Sophora leachiana, and Streptanthus howellii. These are the most likely 

species from the Regional Forester’s Sensitive Species list 2008 to have affected habitat 

within the project area (Mullens and Showalter 2007, USDA Rare Plant Guide 2000, Jules 

personal observation). 

Bryophytes: 

Bryum calobryoides, Cryptomitrium tenerum, Entosthodon fascicularis, Porella 

bolanderi and Tayloria serrata are suspected or documented on the Rogue RiverSiskiyou National Forest (Regional Forester’s Sensitive Species list 2008) and have 

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potential habitat within the project area (Interagency Special Status/Sensitive Species 

Program website, NatureServe Explorer website). 

Lichens: 

Chaenotheca subroscida, Neprhoma occultum and Usnea longissima are suspected or 

documented on the Rogue River-Siskiyou National Forest (Regional Forester’s Sensitive 

Species list 2008) and have potential habitat within the proposed project area 

(Interagency Special Status/Sensitive Species Program website, NatureServe Explorer 

website). 

Fungi: 

Arcangeliella camphorata,, Boletus pulcherrimus, Chamonixia caespitosa, Cudonia 

monticola, Destunzia rubra, Gomphus kaufmanii, Leucogaster citrinus, Otidea smithii, 

Phaeocollybia attenuata, Phaeocollybia californica, Phaeocollybia olivacea, 

Phaeocollybia pseudofestiva, Phaeocollybia spadicea, Pseudorhizina californica, 

Ramaria amyloidea, Ramaria aurantiisiccescens, Ramaria largentii, Ramaria spinulosa 

var. diminutiva, Rhizopogon chamaleontinus, Rhizopogon ellipsosporus, Rhizopogon 

exiguous, and Sowerbyella rhenana have potential habitat within the planning area. The 

Interagency Special Status/Sensitive Species Program Habitat Summary for Sensitive 

Fungi Species (Dewey and Ferriel 2007) was used to determine which species, 

documented or suspected on the RRS, have potential habitat. Dewey and Ferriel’s habitat 

summary includes a list of all occurrences of Sensitive fungi and associated tree and 

shrub species as documented in the GeoBOB database and the Pacific Northwest Fungus 

lab dataset. Furthermore, they overlaid the occurrence dataset over a vegetation GIS 

layer to derive a vegetation zone for each occurrence (Dewey and Ferriel 2007). I used 

commonly associated tree species and vegetation zone from Dewey and Ferriel’s table to 

determine which fungi might have habitat within the Butcherknife/Slate planning area. 

Within the Butcherknife-Slate planning area I considered the entire Douglas-fir mixed 

hardwood vegetation type to be habitat for each fungal species suspected to occur within 

the area (this constitutes approximately 3900 of the 5834 acres within the planning area). 

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FIELD SURVEYS; A SUMMARY

Field surveys occurred over a 6 year period and were conducted by 4 different botanists. 

With the exception of the 2002 non-vascular field surveys, field work was conducted in 

spring and summer when the vascular plants were identifiable, rather than in the fall when 

fungi would most likely be detected. Field surveys were not conducted for fungi due to the 

unreliable above-ground presence of fruiting bodies from year to year. The mycelium (the 

non-fruiting portion of the fungus) is generally underground and remains undetected until it 

develops visible reproductive structures (fruiting bodies such as mushrooms, truffles, corals, 

puffballs, cups), or the substrate is disturbed, exposing the usually white mycelial mats 

(Cushman and Huff 2007). Even with above-ground fruiting bodies present, their correlation 

with the extent and abundance of the fungal organisms underground is unknown (Straatsma 

and Krisai-Greilhuber 2003 cited in Cushman and Huff 2007). Fungal colonies can range in 

size from microscopic to many acres and can persist for years or decades (Smith et al. 1992, 

De la Bastide et al. 1994, Bonello 1998 cited in Cushman and Huff 2007). 

Year 

surveyed 

Who conducted 

 survey? 

Which groups of organisms were surveyed for? 

2002 Contract botanist 

Richard Brock 

910 acres non-vascular plant surveys (lichens & 

bryophytes) 

2002- 

2003 

FS botanists Cecile 

Shohet and Karen 

McCullough 

1353 acres non-vascular (lichens & bryophytes) and 

vascular plant surveys 

2004 Contract botanist 

Richard Brock 

90 acres vascular plants and invasive plants 

2008 FS botanists Karen 

McCullough and 

Mary Bell 

Habitat specific, intuitive control surveys for Fritillaria 

gentneri and Sensitive plants (vascular and non-vascular) 

throughout entire planning area. 

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EFFECTS ANALYSIS 

NO ACTION ALTERNATIVE 

No direct or indirect impacts are clearly identifiable from the no action alternative for any 

TES vascular plant, lichen, bryophyte or fungus species. An intense stand-replacing fire 

event across the planning area may have an especially detrimental effect to Sensitive fungi (if 

present), but it can not be determined if the no action alternative would directly result in such 

an event. 

PROPOSED ACTION: 

ESA-Listed Endangered species:

Fritillaria gentneri (Gentner’s fritillary) 

The proposed project area is within the range of F. gentneri (USDI USFWS BA/BO 

2003). The following information is a summary from the 2003 USDI Fish and Wildlife 

Recovery Plan. F. gentneri is documented from 16 different habitat types (elevation 

range 1004-5064 feet) in Jackson and Josephine Counties of Oregon. The species is most 

often found in Oregon white oak woodlands and Oregon white oak/dry Douglas fir 

ecotone/edge habitats and there is a significant association between occurrence and the 

Vannoy soil series. In 2003, only 1% of known sites were documented on lands managed 

by the U.S. Forest Service. Although not well documented, the mid-successional nature 

of occurrences suggests that the loss of openings and subsequent encroachment of habitat 

by dense shrubs and trees will lead to the loss and extirpation of F. gentneri and its 

associated understory species. 

Surveys for this species were conducted by Forest Service botanists during the springs of 

2002, 2003 and 2008. In preparation for the 2008 surveys, a GIS analysis was used to 

identify all soils in the Vannoy series. In total 83 acres of Vannoy soils were identified 

and intensively surveyed within the project area; oak woodlands and edge habitats were 

also concentrated on during field surveys. No F. gentneri occurrences were identified 

anywhere within the project area. Furthermore, a primary objective of the proposed 

action is to reduce conifer density and release white oaks and black oaks from competing 

vegetation. Lack of canopy gaps and light reaching the understory in dry Douglas fir and 

loss of oak woodland habitat types are thought to be a primary threat to F. gentneri (Sam 

Friedman, personal communication 08/08/2008, USDI USFWS Recovery Plan 2003). 

Thus, the proposed density reduction may improve habitat conditions for this species 

throughout the project area. No critical habitat has been identified for this species (USDI 

USFWS Recovery Plan 2003), hence unoccupied habitat can undergo management 

activities with a no effect determination (Mark Mousseux, personal communication

08/11/08). Thus, the project is expected to have no effect to this federally listed species. 

Forest Service Sensitive Species:

VASCULAR PLANTS: Five Sensitive vascular plant species were found to occupy the 

proposed project area. 

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Carex serratodens (saw-tooth sedge): 

C. serratodens range is restricted to Douglas, Jackson and Josephine Counties of Oregon 

and the Sierra Nevada and Coast Ranges of California. It occurs in moist meadows and 

rocky places near streams and seepages often associated with serpentine soils (Mullens 

and Showalter 2007). There is one known site along Anderson Creek in the far southern 

portion of the project area. No activities are planned within the block of forest 

surrounding this section of Anderson Creek so this population will remain unaffected. 

Additional populations which might go undetected are most likely to occur along streams 

and will be protected by riparian management guidelines. The proposed action does 

include 2 miles of fish habitat improvement along Slate Creek where approximately 

1,000 non-contiguous feet of streamside could potentially be disturbed. Thus, there is a 

chance individuals, if present, might be disturbed by fish habitat improvement activities. 

However the effects would be highly localized and short term; limited to areas of log 

placement where vegetation will recover rapidly. Thus, the proposed action may impact 

individuals or habitat, but will not likely contribute to a trend towards federal 

listing or, cause a loss of viability to the species.

Cypripedium fasciculatum (clustered lady’s slipper): 

C. fasciculatum is widely distributed across 8 western states in the U.S., but has narrow 

and complex habitat requirements. Because of its affiliation with mycorrhizal fungi and a 

pollinator which preys on fungal gnats, habitat characteristics include overstory shade, 

and a rich organic layer that supports microflora. Threats include activities that alter the 

moisture or temperature regime, actions that disturb the soil and litter layer, or decrease 

vegetation cover (Seevers et al., 2005). Seven populations were located during field 

surveys. All 7 sites will be buffered to exclude all management activities including fire 

unless an administrative study is set up to monitor impacts of fire. Protection of known 

C. fasciculatum sites aligns with management recommendations for the species: 

“Maintain/secure known sites from prescribed burns except in Adaptive Management 

Areas (AMA) where research should be conducted to determine the role of fire in C. 

fasciculatum habitat (Seevers and Lang 1998, Seevers et al. 2005). 

Although only 7 populations were located, additional habitat exists and there is a 

relatively high probability that some populations were not detected. Hence, the proposed 

activities may negatively impact some C. fasciculatum individuals and/or habitat. Due to 

this species’ widespread distribution and high number of known occurrences both locally 

and across its range, impacts to undiscovered individuals or populations in the 

Butcherknife-Slate planning area will not lead to federal listing. Thus, the proposed 

action may impact individuals or habitat, but will not likely contribute to a trend 

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

Epilobium oreganum (Oregon fireweed): 

E. oreganum is a narrow endemic; its range is restricted to serpentine wetlands and 

streamsides at low elevations in northwestern California and southwestern Oregon. In 

Oregon, known occurrences are restricted to Josephine County from Cedar Log fen 

(included in the proposed project area) south to Oregon Mountain road (Wildwood 

Consulting, 2007). E. oreganum occurs within the far north end of the project area within 

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the Cedar Log Research Natural Area (RNA). The current proposed action includes a 

broadcast burn which encompasses the E. oreganum population within Cedar Log RNA. 

A 1997 prescribed fire occurred at this same site and The Nature Conservancy (TNC) of 

Oregon monitored E. oregonum’s response for three years following the fire. After 3 

years, TNC recorded a ten-fold increase of E. oreganum stems in the burned plots and 

only a two-fold increase in their unburned control plots (Borgias and Biegel 1998, 

Borgias et al.. 2004). Although monitoring was limited to one fire and a single E. 

oreganum population, their work suggests that E. oreganum may benefit from fire 

(Wildwood Consulting, 2007). Although some individual plants and stems may be 

harmed or killed by fire, an overall net benefit to the population may occur over time. 

Thus, the proposed action may impact individuals or habitat, but will not likely 

contribute to a trend towards federal listing or, cause a loss of viability to the 

species; may have a net beneficial impact over time. 

Gentiana setigera (Mendocino gentian): 

G. setigera is a narrow endemic; its range is restricted to serpentine wetlands in far 

northwestern California and southwestern Oregon. In Oregon, most of the 52 recorded 

occurrences fall within Wild Rivers Ranger District on the Rogue River-Siskiyou 

National Forest (Wildwood Consulting, 2007). During field surveys, one new population 

of G. setigera was found in a newly discovered Darlingtonia fen near Ramsey Creek. A 

broadcast burn is proposed for this site. The following excerpt is a summary of what is 

currently known about fire in regards to G. setigera. This excerpt is from the Draft 

Conservation Stategy for Rare Fen Species in Serpentine Darlingtonia Wetlands of 

southwest Oregon and northwest California (one of the five rare species addressed in the 

document is G. setigera): 

Large numbers of serpentine wetlands burned during the ~500,000 acre Biscuit 

Fire in 2002, and burn severity varied greatly among the wetlands (E. Frost and E. 

Jules, personal observation)...In 2002, the Biscuit Fire burned a number of 

serpentine wetlands and rare plant populations that had been sampled previously 

by Frost et al.. (2002). In an attempt to capitalize on this baseline data, a post-fire 

study conducted in 2004 compared overall species composition and abundance of 

the five rare taxa in burned versus unburned wetlands (Cramer et al.. 2005). 

Results suggest that, for the 26 sites sampled, fire had little or no significant 

adverse effect on individual rare species, but did influence several structural 

attributes of the habitat (e.g., reduced litter and shrub cover) and the relative 

abundance of some of the more common species associated with this community. 

For example, Darlingtonia californica showed a trend of reduced cover in 35 

burned fens while several graminoid species appeared to be more abundant in 

burned fens. Overall, it was difficult to detect trends in rare species population 

due to the lack of permanent plot locations (Cramer et al.. 2005)[Wildwood 

Consulting, 2007]. 

As this summary suggests, extensive data lack regarding the specific response of G. 

setigera to fire. Nonetheless, the best available information suggests that G. setigera is 

unlikely to have a significant adverse response to fire. In the proposed action it is 

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undetermined whether the broadcast burn will occur in the spring or fall. Historically this 

habitat would likely only have burned in the summer or fall. However, if a spring burn is 

prescribed, the surrounding habitat for this plant will likely be so wet that it won’t ignite 

during spring burn conditions and so G. setigera would likely be unaffected by a spring 

burn. Although some individual plants and stems may be harmed or killed by a fall burn, 

the population is not expected to significantly decline as a result of the prescribed fire. 

Thus, the proposed action may impact individuals or habitat, but will not likely 

contribute to a trend towards federal listing or, cause a loss of viability to the 

species. 

Lotus stipularis (stipuled trefoil) 

L. stipularis is a perennial legume which is restricted in distribution to Josephine County, 

Oregon and the state of California where it occurs throughout. Habitat ranges from open 

forest, streamsides, ditches, chapparal, roads, roadsides and logged areas at lower 

elevations (Mullens and Showalter 2007). The Josephine County occurrences are limited 

to the Waters Creek/Butcherknife Slate watersheds and an area north of the Rogue River 

(south and west of Roseburg). Fifteen populations occur throughout the proposed project 

area along ridges mostly at old landings and roadsides; populations stop at the forest 

edge. Little is known about specific requirements for this species, but based on habitat, 

it is likely a disturbance dependant species and habitat will increase following 

implementation of the proposed activities. To protect the L. stipularis, only certain 

activities will be restricted, i.e., road/landing construction and slash piling. Other 

disturbances such as vehicle trampling and fire may damage individual plants, but won’t 

destroy entire populations. Thus, the proposed action may impact individuals or 

habitat, but will not likely contribute to a trend towards federal listing or, cause a 

loss of viability to the species; may have a net beneficial impact over time.

LICHENS: No Sensitive lichens were found during field surveys and no effect is expected. 

BRYOPHYTES: No Sensitive bryophytes were found during field surveys and no effect is 

expected. 

FUNGI: Field surveys were not conducted for fungi due to the unreliable above-ground 

presence of fruiting bodies from year to year. The mycelium (the non-fruiting portion of 

the fungus) is generally underground and remains undetected until it develops visible 

reproductive structures (fruiting bodies such as mushrooms, truffles, corals, puffballs, 

cups), or the substrate is disturbed, exposing the usually white mycelial mats (Cushman 

and Huff 2007). Even with above-ground fruiting bodies present, their correlation with 

the extent and abundance of the fungal organisms underground is unknown (Straatsma 

and Krisai-Greilhuber 2003 cited in Cushman and Huff 2007). Fungal colonies can range 

in size from microscopic to many acres and can persist for years or decades (Smith et al. 

1992, De la Bastide et al. 1994, Bonello 1998 cited in Cushman and Huff 2007). 

No Sensitive fungi are known to occur within the planning area, but habitat is present. 

The species suspected to occur are associated with forest floor litter, down woody 

material, host tree/shrub species, or a combination thereof. While these associations are 

known, details about the requirements for forest floor litter or down woody material for 

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most fungal species are not well understood, and host specificity is not often known 

beyond the broad categories of conifers, hardwoods, or plant families within these 

categories (Cushman and Huff 2007). Hence, for the purpose of this B.E., the entire 

Douglas-fir mixed hardwood vegetation type is considered habitat for each fungal species 

suspected to occur within the area (this constitutes approximately 3900 of the 5834 acres 

within the planning area). 

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Table 1. Effects to Sensitive fungi within the Butcherknife/Slate planning area. 

Attachment 4. “Potential Impacts” from the ISSSSP website found under the 

Conservation Planning Tools section was used a reference to determine potential effects 

to fungi (Interagency Special Status/Sensitive Species Program website). The “Potential 

Impacts” document cites primary literature which supports these effects determinations. 

Activity An estimate 

of habitat 

impacted 

Potential direct effects to Sensitive 

fungi 

Potential indirect effects to sensitive 

fungi 

Broadcast 

burn 

2712 acres 

(4524 acres 

are planned 

for 

underburn, 

but only 

2712 

constitutes 

fungi 

habitat) 

Low intensity fire likely only affects 

the upper 5 cm of litter and its 

inhabitants. The majority of fungal 

species diversity resides in the mineral 

soil. Potential impacts include damage 

to the mycelial network, damage to 

host plants and changes in species 

diversity following fire. Degree of 

impact depends on the fire intensity 

and spatial extent of impact. 

The more intensely a fire burns, the 

greater the indirect impacts to overstory 

shade and quantity of litter, organic 

matter and large woody debris. Specific 

requirements for shade, litter, organic 

matter and woody debris aren’t known 

for each sensitive fungal species. High 

levels are probably more important to 

saprobic vs. mycorrhizal fungi. Loss of 

organics likely limits moisture retention 

capability for most fungal species. 

Pile 

burning 

1291 acres 

(actual burn 

piles would 

only occur 

upon a small 

portion of 

these acres) 

Concentrated burning can result in high 

burn intensity and greater changes in 

fungal diversity. Direct impacts 

include damage to the mycelial 

network occurring in the litter to depths 

w/in the mineral soil. Because the 

majority of fungal diversity resides in 

the mineral soil, more species have the 

potential to be negatively affected by 

pile burning than broadcast burn, 

however effects of piles are more 

localized. 

Loss of litter, organic matter and 

overstory shade will impact site, over the 

long-term resulting in reduced moisture 

retention and reduced likelihood of 

recolonization by non-weedy fungi. 

Road, and 

landing 

construction 

5 miles of 

temporary 

road 

construction

3 miles of 

reconstruction. ~45 

acres of 

landing 

construction 

Extent of impact typically localized. 

Direct impacts include damage to 

mycelial network, loss of host plants 

and loss of organic materials needed by 

fungi. 

Soil compaction typically results in 

reduced host root growth, reduced root 

tip availability for mycorrhizal fungi, and 

reduced organics needed by saprobic 

fungi. Over the long-term resulting in 

reduced moisture retention and reduced 

likelihood of colonization by non-weedy 

fungi. 

Machine 

chipping/ 

mastication 

200 acres May damage mycelial networks. May damage or destroy duff and 

substrate layers on which fungi depend. 

Deposition of chipped material may 

result in an excessive increase in organic 

matter potentially altering duff and 

substrate chemistry (Cushman and Huff 

2007). 

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Thinning 2712 acres Host trees and shrubs may be removed 

which could impact mycelial networks 

of mycorrhizal fungi. 

Solar radiation may increase resulting in 

a loss of moisture retention capability, 

thus altering fungal diversity. Changes in 

light reaching the understory may result 

seral stage changes which might affect 

fungal diversity and composition. 

A number of project design criteria inherent to the proposed action will minimize the 

above mentioned direct and indirect impacts to Sensitive fungi (if present). For example, 

low intensity vs. high intensity broadcast burns are planned for the project area. In 

addition, many of the prescribed fires will likely be spring burns which are recommended 

for maintaining fungal diversity because they tend to be less intense (Cushman and Huff 

2007). Old previously compacted roadbeds will be reopened in lieu of new temporary 

road construction, thus limiting the actual net increase of effects associated with roads. 

Most landings created will consist of a series of road widenings vs. construction of large 

landings away from roads. Small widened areas along currently existing roads will 

confine these disturbances to areas which are already partially compacted and disturbed. 

Chipping and mastication will occur in early to mid-seral forest stands which probably do 

not provide prime habitat for Sensitive fungi to start with (Attachment 4, Potential 

Impacts to Fungi, Interagency Special Status/Sensitive Species Program website). 

Proposed thinning prescriptions retain old and large trees and promote tree and shrub 

species diversity. Maintaining a diverse array of host species of varying size and age 

classes will tend to promote fungal diversity. Additionally, 1310 acres (22% of the 

planning area) will remain untreated. For the most part, untreated areas tend to be 

composed of mature to old growth forest habitat and represent the highest potential for 

Sensitive fungi occurrence. Thus the proposed action will retain refugia for Sensitive 

fungi throughout the project area. Hence, although the proposed action may impact 

individuals or habitat, it will not likely contribute to a trend towards federal listing 

or, cause a loss of viability to any Sensitive fungal species.

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BOTANY MITIGATIONS

• For any sale, service or stewardship contract prepared for this project, a provision 

will be included that provides for modification and/or termination of the contract, 

in part or in whole, to protect Proposed, Endangered, Threatened and Sensitive 

(PETS) plants from impacts created by the project. Additional Sensitive plant 

populations may be located during project implementation. Regardless of when 

Sensitive plants are located. 

• The Forest Service will identify areas of known Sensitive plant populations on 

sale area maps, as well as on the ground with flagging, stakes and/or signs. 

Identification and location of known populations would be coordinated with the 

Botanist. 

• All 7 Cypripedium fasciculatum sites will be buffered. Four of the 7 sites occur in 

a 1⁄4 mile stretch between the forest road 2100.20 and Slate Creek. In this area 

density management and fire will be excluded from 100 feet below the road to 

Slate Creek. The three other sites will be buffered by 100 feet on all sides and all 

management activities excluded unless an administrative study is designed to 

assess the effects of fire. Coordination with the botanist during contract 

preparation will be necessary for mapping and flagging of buffers. 

• High intensity spot fires from pile burning represent the greatest risk to C. 

fasciculatum habitat and/or undiscovered individuals. If C. fasciculatum is 

discovered during implementation, piles will not be placed in areas which will 

harm individual plants. Known C. fasciculatum sites should be given at least a 

50 foot buffer from pile burning and canopy should be maintained at 60% or 

greater at the site (Seevers and Lang 1998, Seevers et al. 2005). 

• High intensity spot fires from pile burning represent the greatest risk to C. 

fasciculatum habitat and/or undiscovered individuals. Pile burning may occur 

across 434 of the 2,630 project area acres. If C. fasciculatum is discovered 

during implementation, piles will not be placed in areas which will harm 

individual plants. Known C. fasciculatum sites should be given at least a 50 foot 

buffer from pile burning and canopy should be maintained at 60% or greater at the 

site (Seevers and Lang 1998, Seevers et al. 2005). 

• For the 15 L. stipularis populations, all proposed activities will be allowed, with 

the exception of road/landing construction and slash-piling (small hand-piles 

would be allowed). Coordination with the botanist during contract preparation 

will be necessary. 

• Broadcast fire is the only activity planned where Gentiana setigera and Epilobium 

oreganum occur. Both species occur in two separate Darlingtonia fens, which are 

wetlands. Fire will be allowed to burn through the fens. No hand-line will be 

allowed within 200 feet of these wetland features and no drip torches will be used 

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within the wetlands. If the broadcast fire doesn’t naturally spread into the fen 

habitat, ignition should not be forced by directed drip torching. 

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LITERATURE CITED 

Borgais, D. and J. Biegal. 1998. Cedar Log Flat Research Natural Area prescribed fire 

effects monitoring. Second year report: preburn vegetation data summaries, and 

fire and weather observations. Report submitted to the Siskiyou National Forest, 

Grants Pass, OR. 

Borgias, D., N. Rudd and L. Eisenberg. 2004. Effects of fire on rare plants and vegetation 

in serpentine savanna and fen communities in southern Oregon. Pp. 149-50in: 

Mergenthaler, K.L., J.E. Williams and E.S. Jules, eds. Proceedings of the second 

conference on Klamath-Siskiyou ecology. Siskiyou Field Institute, Cave Junction, 

OR. 

Cushman, K. and R. Huff 2007. Conservation assessment for fungi included in Forest 

Service Regions 5 and 6 Sensitive and BLM California, Oregon and Washington 

Special Status Species Programs. Prepared for the Interagency Special 

Status/Sensitive Species Program (ISSSSP) website. Located: 

http://www.fs.fed.us/r6/sfpnw/issssp/planning-documents/

Dewey, R., and J. Ferriel 2007. Habitat summary for sensitive fungi species. Prepared 

for the Interagency Special Status/Sensitive Species Program (ISSSSP) website. 

Located: http://www.fs.fed.us/r6/sfpnw/issssp/planning-documents/

Friedman, S., Botanist, USFWS, Roseburg Field Office (USFWS Level 1 team 

Representative), personal communication via email 11/08/2007. 

Friedman, S., Botanist, USFWS, Roseburg Field Office (USFWS Level 1 team 

Representative), personal communication via phone conversation 08/08/2008. 

Interagency Special Status/Sensitive Species Program (ISSSSP) website: 

http://www.fs.fed.us/r6/sfpnw/issssp/planning-documents/

Mullens, Linda and Rachel Showalter, 2007. Rare plants of Southwest Oregon. A 

collaborative effort between U.S. Department of Agriculture Forest Service, 

Bureau of Land Management, Oregon Flora Project and The Nature Conservancy. 

Mousseux Mark, Medford District BLM lead botanist (level 1 Team BLM 

Representative), Medford Office, personal communication via phone 

conversation 08/11/2008. 

NatureServe Explorer website: 

http://www.natureserve.org/explorer/

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Seevers, J., Lang, F. reconfigured N. Vance, 2005. Conservation Assessment for 

Cypripedium fasciculatum Kellogg ex S. Watson 

U.S. Department of the Interior Fish and Wildlife Service 2003. Rogue River/South 

Coast Biological Assessment FY04-08 for Activities that may affect listed species 

in the Rogue River/South Coast Province for Medford District BLM, Rogue River 

and Siskiyou National Forests 11 July 2003 Biological Opinion (FWS) 1-14-03-F511 20 October 2003. 

U.S. Department of the Interior Fish Region 1 Fish and Wildlife Service 2003. U.S. Fish 

and Wildlife Service Recovery Plan for Fritillaria gentneri (Gentner’s fritillary). 

U.S. Department of Agriculture Forest Service 2000. A Guide to Rare Plants of the 

Siskiyou National Forest. 

U.S. Department of Agriculture Forest Service, FSM 2000 National Forest Resource 

Management, Chapters 2080 Noxious Weed Management and 2670 Threatened, 

Endangered and Sensitive Plants and Animals. 

U.S. Department of Agriculture Forest Service Region 6. 2008 Regional Forester’s 

 Sensitive Plant Species List. 

Wildwood Consulting, 2007. Draft Conservation Strategy for Oregon fireweed 

(Epilobium oreganum), Mendocino gentian (Gentiana setigera), Large-flowered 

rush-lily (Hastingsia bracteosa var. bracteosa), purple-flowered rush lily (H. 

bracteosa var. atropurpurea), western bog violet (Viola lanceolata ssp. 

occidentalis) in serpentine Darlingtonia wetlands of southwest Oregon and 

northwest California. Prepared by Wildwood Consulting for USDI Medford 

District BLM and USDA Rogue River-Siskiyou National Forest. 

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ATTACHMENT A.

INVASIVE PLANT ANALYSIS 

INVASIVE PLANT INFORMATION TRACKED ON THE RR-S NF

Through inventory and mapping, FS personnel can assess infestation levels, however 

only target invasive plant species have been treated and mapped over the years on the 

Rogue River-Siskiyou National Forest (RR-S NF). I.e., some ubiquitous (St. Johnswort) 

and/or difficult to control species (i.e. require extensive use of herbicides and/or are 

readily spread by birds) such as Himalayan and cut-leaf blackberry have not been 

mapped or treated. Similarly, a variety of non-native species which are not aggressive 

invaders have not been mapped (silver hairgrass, rat-tail fescue etc.). Thus, only species 

currently tracked and treated will be thoroughly addressed in this invasive plant analysis. 

The effects of project related activities upon the spread of species not tracked or treated 

by the RR-S NF will be unknown. 

PROPOSED ACTION; IMPACTS FROM INVASIVE PLANTS 

In 2008, invasive plant survey and treatment (hand-grubbing and/or solarizing with black 

plastic) occurred throughout the proposed planning area. Workers found infestation 

levels to be low relative to other watersheds on Wild Rivers Ranger District. However, 

the following ODA listed invasive plants are documented: meadow knapweed 

(Centaurea debeauxii), Scotch broom (Cytisus scoparius), Himalayan blackberry (Rubus 

armeniacus), cutleaf blackberry (Rubus laciniatus), diffuse knapweed (Centaurea

diffusa), St. Johnswort/ Klamath weed (Hypericum perforatum), Dyer’s woad (Isatis 

tinctoria), everlasting peavine (Lathyrus latifolius) and rush skeletonweed (Chondrilla 

juncea). None of these species have been successfully eradicated locally, but careful 

mapping and control of select species has occurred over the last decade. Of the 9 abovenamed species, only 4 are presently targets for active control efforts by Wild Rivers 

Ranger District (meadow knapweed, diffuse knapweed, Scotch broom, and Dyer’s woad). 

The other 4 species are either too well established (ie, St. Johnswort) or ineffective to 

control without herbicides (ie, Himalayan, cutleaf blackberry rush skeletonweed and 

everlasting peavine). The Siskiyou portion of the Rogue River-Siskiyou National Forest 

is not currently authorized for herbicide use. 

Most documented infestations are currently restricted to the roadsides and similarly 

disturbed habitats such as old landings; no invasive plants are documented within the 

interior of old plantations or unmanaged stands (with the exception of Himalayan and 

cutleaf blackberry which are prevalent at the lowest elevations and close to boundaries 

with private land). Well enforced and well implemented mitigations including equipment 

washing and avoiding spread from known sites will greatly minimize the risk of invasive 

plant introduction and establishment within the currently uninfested habitats. Likewise, 

well implemented road work mitigations such as blading into vs. through known sites, 

use of weed free gravel and coordinated disposal sites will minimize the risk of spread 

along roadsides during road maintenance, construction and reconstruction. 

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Overall, implementation of the proposed activities will result in a net increase in highly 

disturbed habitats, such as newly maintained roads, new temporary roads, skid trails and 

landings. The result of creating more highly disturbed habitats, is a measurable increase 

in vulnerability to invasion and establishment by invasive plant species. Vulnerability 

will lessen over time following native grass seeding by the Forest Service, and natural 

revegetation processes. However, monitoring is the activity most critical to preventing 

invasion. Monitoring allows workers to identify and remove infestations while they are 

small and easily treated. If infestations are left undetected and untreated it is likely they 

will become established, build a soil seed bank and become increasingly difficult to 

control. In turn, establishment of invasive plants across an increasingly large area may 

disrupt herbivore/plant ecological relationships, alter mychorrhizal fungi/plant 

interactions, alter fire behavior, create cascading effects on plant and wildlife, and 

damage ecosystem function through alteration of soil and hydrologic properties (USDA 

Chapter 3 FEIS 2005). 

NO ACTION ALTERNATIVE 

A wide variety of mechanisms unrelated to the proposed project activities are expected to 

introduce and spread invasive species throughout the analysis area. I.e., the roads are 

used regularly by the public (often coming from highly weed infested valleys) during 

both dry and wet season conditions (seeds are most readily transported on muddy tires). 

Thus weed seed is expected to spread readily as it is transported on vehicles and 

deposited along roads. Additionally, a certain level of off road vehicle use is expected 

and is a common cause of invasive plant introduction and spread beyond the road prism. 

Finally, introduction and spread of invasive species by animals, wind, water and gravity 

may also occur. Nonetheless, because the proposed action would result in a net increase 

of freshly maintained roads, new temporary roads, skid trails and landings, risk of 

invasion is greater under the proposed action vs. the no action alternative. 

INVASIVE PLANT MITIGATIONS 

• There is a historic brickyard off forest road 162 with a legal of T37S, R08W, in 

the NE of the SW corner of section 24. This site is heavily infested by Himalayan 

blackberry, everlasting peavine and there is a small meadow knapweed 

infestation. Without the use of herbicides, the Himalayan blackberry and 

everlasting peavine are currently untreatable. To avoid spread from this site into 

adjacent interior forest lands, this site should not be used for equipment staging 

area or a landing unless flattened and buried by 12” compacted gravel. 

• In the Hayes Hill vicinity, there is a scotch broom infestation a few acres in size, 

extending between forest road 162, the powerline and hwy 199. If this site is 

treated for density, all heavy equipment will need to be washed prior to moving to 

the next management area. 

• Along the Slate Creek Road 2100.020 there is a meadow knapweed infestation 

which begins 0.7 miles out the 020 spur, and extends to 2.1 miles up the 020 spur. 

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The densest population is 1.4 miles out the 020 spur. This portion of the road will 

likely be reconstructed prior to implementation. Reconstruction and roadwork 

would be carefully coordinated with the invasive plant coordinator to avoid 

spread from this site. 

• Where road maintenance or reconstruction activities take place, the following 

measures would be used: 

• Roadside invasive plant sites would be flagged and/or staked by the 

Invasive Plant Coordinator. Infested sites will be avoided or the 

Contracting Officer’s Representative would direct contractor to blade 

or ditch in a manner that reduces the potential spread from infested to 

uninfested sites (e.g. blading into instead of through from infestations). 

• Soil moved from an infested site would be disposed of at designated 

site coordinated by engineers and the invasive plant coordinator. 

• Where gravel, sand or fill is hauled from an on- or off-forest site to 

complete designed roadwork, the invasive plant coordinator would be 

consulted. In order to be in compliance with the 2005 R.O.D. for 

managing invasive plants, these materials need to be determined weed 

free by the invasive plant coordinator. 

• All off-road equipment, defined as logging and construction equipment, used in 

conjunction with harvest treatments would be power scrubbed or steam cleaned 

on the undercarriage and chassis to remove plant material and soil, before 

transport to the project area. This is to reduce the potential for spreading invasive 

plants. In addition, the Forest Service would inspect all off-road equipment prior 

to entry onto NFS lands. 

• All off-road equipment would be cleaned, prior to leaving the project site, if 

operating in infested areas (as instructed by a designated government 

representative. F.S. Reps. Include COR/ER/FSR/SA, etc. Above F.S. Reps. will 

coordinate with Unit’s Invasive Plant Coordinator). 

• Native seed selected by the botanist, wood straw, silt fences or slashed material 

from on-site would be used for erosion control. 

• Monitor newly disturbed areas the year after an activity occurs. Continue 

monitoring for 2-3 years depending on the need. Monitoring will result in early 

detection and treatment of invasive plant sites, thus reducing the cost of treatment 

and the long-term environmental impacts of invasion. 

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LITERATURE CITED 

U.S. Department of Agriculture Forest Service 2005. Pacific Northwest Region Invasive 

Plant Program, Preventing and Managing Invasive Plants, Final Environmental 

Impact Statement Vol. 1-3 and Record of Decision. 

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ATTACHMENT B.

REVIEW OF OTHER RARE OR UNCOMMON SPECIES 

REVIEW OF PREVIOUSLY DOCUMENTED SPECIES 

Databases were reviewed for known plant sites. Positive findings for T&E, S&M & FS 

Sensitive plants are archived within the Rogue River- Siskiyou rare plants database and/or 

the ISMS database which is now available through the GeoBOB database. These databases 

and the original paper site forms were checked to identify known rare plant locations 

documented within the proposed project area. 

EFFECTS TO OTHER RARE OR UNCOMMON SPECIES 

 

Leptogium rivale (skin lichen) 

Three populations of L. rivale were discovered on tributaries of Butcherknife Creek by 

Richard Brock in 2002. This rare aquatic lichen is found on rocks submerged by water or in 

the splash zone of creeks. Threats to this species include upstream impacts which may alter 

stream conditions such as water quality, chemistry, temperature, light regime, level, opacity, 

sediment level or changing micro-climatic conditions (Lesher et al., 2003). The proposed 

action will be in compliance with the Aquatic Conservation Strategy and will maintain water 

quality on Butcherknife Creek which will also be carefully be managed as a fish bearing 

stream. The resulting measures taken to protect water quality will maintain habitat for L. 

rivale. Thus, the project is expected to have no effect on this species. 

Dendriscocaulon intricatulum (dendriscocaulon lichen) 

Thirteen populations of D. intricatulum were discovered by Richard Brock in 2002. This 

species is endemic to the Pacific Northwest and is an epiphyte on a wide variety of tree 

species (Lesher et al., 2003). In the Butcherknife-Slate planning area it was found growing 

on black oak (Quercus kellogii) which ranged in size from 3-12 inches diameter at breast 

height. In 2001 the status of this species was undetermined for Coos, Curry, Douglas, 

Josephine and Jackson Counties (USDA, June 2002). By 2003, the status no longer met 

Survey and Manage criteria for the above listed counties in Oregon, where it was found to be 

quite common (USDA, December 2003). A-ll oak species will be favored (thinned around) 

and not cut during thinning prescriptions which will allow this lichen to persist throughout 

the forests there. Thus, the project is expected to have no effect on this species. 

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LITERATURE CITED

Lesher, R.D., Derr, C.C, and L.H. Geiser, 2003. Natural history and management 

considerations for Northwest Forest Plan Survey and Manage Lichens. A 

collaborative effort between U.S. Department of Agriculture Forest Service, 

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

U.S. Department of Agriculture Forest Service, June 2002. Annual Species Review; 

Species included in Survey and Manage Standards and Guidelines and Category 

Assignment. 

U.S. Department of Agriculture Forest Service, December 2003. Annual Species 

Review; Species included in Survey and Manage Standards and Guidelines and 

Category Assignment.