Jan FauntLeRoy, Interdisciplinary Team Leader

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1 United States Department of Agriculture Forest Service Lewis and Clark National Forest th Street North P.O. Box 869 Great Falls, MT FAX File Code: 1950/2600 Date: November 9, 2011 Route To: Subject: To: Forest-wide Recreation and Administrative Site Hazard Tree Removal Sensitive Plant Report Addendum Whitebark Pine and Hall s Rush Jan FauntLeRoy, Interdisciplinary Team Leader On July 19, 2011, the U.S. Fish and Wildlife Service published in the Federal Register its finding on the petition to list whitebark pine (Pinus albicaulis) under the Endangered Species Act. It (Federal Register 2011) stated that whitebark pine is threatened from loss of habitat from fire suppression and the exacerbating environmental effects of climate change and from mortality from white pine blister rust (Cronartium ribicola) and mountain pine beetle (Dendroctonus ponderosae). After a review of all available information, the U.S. Fish and Wildlife Service concluded that listing the species as threatened or endangered is warranted, but is currently precluded by higher priority actions. Whitebark pine, therefore, is a candidate for listing. Based on this finding, the Regional Forester, Leslie A. C. Weldon, designated it as a sensitive species in the Northern Region (Weldon 2011). Weldon (2011) indicated that this status should not change our approach to management and restoration of whitebark pine, as such activities are clearly needed for the recovery of the species. The sensitive species designation will go into effect on December 24, As a result of whitebark pine s listing as sensitive on the Lewis and Clark National Forest prior to implementation of the Forest-wide Recreation and Administrative Site Hazard Tree Removal Project, this letter will serve as an addendum to the May 5, 2011, sensitive plant report. In addition to the inclusion of whitebark pine to the sensitive plant list, Hall s rush (Juncus hallii) was moved from the Suspected to Occur to the Known to Occur on the Lewis and Clark National Forest list. The change in status does not alter the previous analysis or determination made for Hall s rush; implementation of the project would have no impact on the species. Regulatory Framework Lewis and Clark National Forest Land and Resource Management Plan Management Standard C-2 (2 & 13): Conduct biological evaluations of each program or activity carried out on occupied sensitive species habitat to determine whether the activity may affect sensitive species. Assessments of suitable habitats for sensitive plants will be conducted before surface disturbing activities are permitted. Compliance: This report constitutes the biological evaluation for whitebark pine, a species that will be listed as sensitive prior to project implementation. Sensitive plant surveys will be completed of treatment sites prior to project implementation. Forest Service Manual FSM Ensure that Forest Service actions do not contribute to loss of viability of any native or desired non-native plant or contribute to trends toward Federal listing of any species. Compliance: Whitebark pine does not occur within designated treatment units. Therefore, implementation of the proposed project (Alternatives 1 and 2) would have no impact to the species and would not contribute to loss of species viability. Caring for the Land and Serving People Printed on Recycled Paper

2 Mitigation Measures As stated in the May 5, 2011, sensitive plant report, sensitive plant surveys would be completed in areas with known populations or potentially suitable habitat prior to project implementation. Whitebark pine would be added to the survey list of species. Surveys would be scheduled annually based on the defined project implementation schedule. If whitebark pine of any size is located during the survey, its location would be delineated and the species condition would be evaluated. Mature trees with damage from white pine blister rust infection would be evaluated based on tree location in the site and infection level to determine if they pose a hazard. Trees not deemed to pose a hazard would be retained on site. Implementation crews would be notified of whitebark pine locations to ensure that piles were not created on top of or immediately adjacent to trees. Analysis Area The analysis area for whitebark pine consists of all the treatment units or areas within the project. Methodology and Scientific Accuracy The effects analysis is based on potential habitat and known whitebark pine populations. A preliminary analysis of the Forest-wide Recreation and Administrative Site Hazard Tree Removal treatment areas was conducted using information available from R1-VMap. R1-VMap is a satellite imagery-based map product produced by the Northern Region Geospatial group that contains basic vegetation information for every acre on the Lewis and Clark National Forest. Polygons are based on similar vegetation characteristics and range from one to 25 acres. Each polygon contains lifeform, canopy cover, vegetation type, and size class information. Vegetation classification in R1-VMap is based on relative abundance of canopy cover, basal area, or trees per acre. For this project, treatment units (~630 acres) were spatially overlaid on the R1-VMap product for both the Jefferson and Rocky Mountain Front divisions of the Forest to determine if whitebark pine was present, base on at least 40 percent dominance (Dom_Mid_40). The Dom_Mid_40 classification, which describes the single-most abundant vegetation that has greater than or equal to 40 percent of the total abundance (USDA Forest Service 2009), was used to determine whitebark pine presence. Personal knowledge of vegetation at most of the developed recreation and administrative sites and topographic/elevational location of the sites were also used to determine the presence of whitebark pine. Estimates of overall map accuracy and confidence of individual map classes [in R1-VMap] can be inferred from an error matrix derived from the comparison of known reference sites to mapped data (USDA Forest Service 2010). Based on the accuracy assessment for the Eastside R1-VMap product (USDA Forest Service 2010), the overall area weighted accuracy of the Dom_Mid_40 class was 65 percent, 85 percent, and 43 percent for the entire Lewis and Clark, Island Units (Jefferson Division), and Rocky Mountain Front, respectively. No accuracy is associated with the MX-PIAL (whitebark pine) class on the Forest, Island Units, or Rocky Mountain Front because the class contained less than 30 samples. Across the four Forests (Lewis and Clark, Helena, Custer, and Gallatin National Forest) assessed for the Eastside R1-VMap accuracy assessment, the MX-PIAL class at the greater than 40 percent plurality level was 65 percent accurate. Personal knowledge of vegetation at most of the sites was also used to validate the information provided in R1-VMap. Existing Condition Whitebark pine is a long-lived species that is most commonly found as a major seral species on upper alpine sites (Keane and Parsons 2010, Tomback et al. 2011). At the highest forest elevations or alpine sites, whitebark persists as a climax species in a krummholz form (Keane and Parsons 2010, Tomback et al. 2001, Tomback et al. 2011). The species generally occurs within a narrow elevation range (Tomback et al. 2011). Fire, ranging from small and isolated to large and stand-replacing, is the primary disturbance factor in this forest community that renews the species. In the absence of fire, whitebark pine is eventually replaced by shade-tolerant species (Keane and Parsons 2010). Based on information provided to the U.S. Fish and Wildlife Service, the major threats to whitebark pine s survival across its distribution Page 2 of 5

3 range are fire suppression, climate change, white pine blister rust, and mountain pine beetle (Federal Register 2011). Whitebark on the Lewis and Clark have and are experiencing all of these threats. However, for purposes of this project, only white pine blister rust and mountain pine beetle are discussed because they are the agents directly responsible for current tree mortality or the creation of hazard tree characteristics. On the Lewis and Clark National Forest, whitebark pine is present on all aspects at high elevations in the Rocky Mountain Front (~ ), Castle (~ ), and Crazy (~ ) mountains. Whitebark pine has not been noted in the Highwood, Big Snowy, and Little Snowy mountains. The Little Belt Mountains will be analyzed under a different project. Although whitebark pine is present on the Lewis and Clark National Forest, it was not the dominant vegetation type at the greater than 40 percent plurality level for any of the recreation or administrative sites proposed for treatment in this project. Personal knowledge of the current vegetation at most of the treatment sites would validate that whitebark is absent. Sensitive plant surveys in treatment units are necessary to determine if incidental whitebark (trees occurring merely by chance) are present. Sites to be treated are generally located in valley bottoms or toe slopes that do not support appropriate habitat for whitebark pine establishment and long-term survival. In many instances on the Rocky Mountain Front, whitebark pine is present at the higher elevations above proposed treatment units. White pine blister rust and mountain pine beetle are two agents causing widespread whitebark pine damage and mortality across the Forest. White pine blister rust, present for many decades, has infected trees of all sizes (seedling to mature) across the species range. The infection initially damages the upper crown and cone-bearing branches, and the restriction of nutrient flow eventually girdles the tree s branches and bole leading to mortality. Destruction of cone-bearing branches reduces the tree s ability to reproduce. Infection rates on the Forest are variable, but increasing. However not all trees are infected. Mountain pine beetle populations have increased over the past five to seven years from endemic (natural) to epidemic levels that can kill 80 to 95 percent of suitable host trees (ponderosa, lodgepole, limber, and whitebark pine) (Keane et al. 2010). Although the Little Belt and Castle mountains appear to be more heavily impacted, beetle-caused pine mortality is also present in the other mountain ranges. Due to more favorable environmental conditions, mountain pine beetle have experienced more rapid development in whitebark pine at higher elevations which has facilitated a 1-year versus the historic 2-year life cycle with higher tree mortality rates (Bentz 2011; Federal Register 2011). Mountain pine beetle typically attacks the mature trees within stand. Because these trees are also the cone-bearing trees needed for species reproduction and survival, whitebark pine populations are expected to decline as a result of the beetle epidemic. Based on whitebark pine findings the Federal Register (2011) related to white pine blister rust and mountain pine beetle, [t]here is no known way to control or reduce or eliminate either threat at this time, particularly at the landscape scale White pine blister rust and mountain pine beetle, therefore, have created trees that would be considered hazardous to public safety if they were located within proposed treatment areas. Effects of Alternative 1 Under this alternative, no treatment would occur within recreation and administrative sites on the Forest (excluding sites in the Little Belt Mountains), and no whitebark pine is present within treatment units. As a result, implementation of this alternative would have no impact on whitebark pine. Alternative 1 would also have no impact on the threats (fire suppression, climate change, white pine blister rust, and mountain pine beetle) that have lead to the species listing as sensitive. Cumulative Effects Because Alternative 1 would not directly or indirectly impact whitebark pine and there are no whitebark in treatment units, there would be no cumulative effects to the species from implementation of this alternative. Page 3 of 5

4 Effects of Alternative 2 Based on the analysis described above, whitebark pine does not occur within proposed treatment units; therefore, implementation of the Forest-wide Recreation and Administrative Site Hazard Tree Removal project would have no direct or indirect effects upon the species. Pre-implementation sensitive plant surveys would identify any areas containing incidental whitebark pine (see mitigation section). However, based on treatment unit location and knowledge of current vegetation, it is highly unlikely for the species to occur. If incidental trees are present, dead whitebark pine or trees so heavily infected with white pine blister rust that they are no longer cone-producing would be felled. Whitebark with lower levels of blister rust would be evaluated to determine their hazard status. Attempts would be made to protect incidental seedlings and saplings during implementation activities. Loss (felling or mechanical damage/trampling) of the incidental whitebark pine would have no impact to the species or its viability because treatment sites are not within habitat appropriate for whitebark pine s long-term survival. Implementation of Alternative 2 (removing dead or dying trees that pose a safety hazard) would have no impact on the threats (fire suppression, climate change, white pine blister rust, and mountain pine beetle) that have lead to the species listing as sensitive. Cumulative Effects Because whitebark pine does not occur within treatment units, and Alternative 2 would not directly or indirectly impact whitebark pine, this alternative would have no cumulative effects to whitebark pine. Removal of dead and dying trees within 1 to 70 acre sites totaling 630 acres across six mountain ranges would not affect the current white pine blister rust or mountain pine beetle epidemics, alter climate change, or modify the effects of fire suppression. Determination of Effects It is my determination that implementation of the Forest-wide Recreation and Administrative Site Hazard Tree Removal project, as proposed, would have no impact (NI) on whitebark pine. /s/ Tanya E. Murphy TANYA E. MURPHY Forest Silviculturist References Bentz, B.; E. Campbell; K. Gibson; S. Kegley; J. Logan; and D. Six Mountain pine beetle in highelevation five-needle white pine ecosystems. P In: The future of high-elevation, five-needle white pines in Western North America: Proceedings of the High Five Symposium June 2010, Missoula, MT. Keane, R.E.; D.F, Tomback; M.P. Murray; and C.M. Smith, eds. Proceedings RMRS-P- 63. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 376 p. Federal Register USDI, Fish and Wildlife Service, Endangered and threatened wildlife and plants; 12-month finding on a petition to list Pinus albicaulis as endangered or threatened with critical habitat. Federal Register Vol 76, No. 138, pp Keane, R.E.; and R.A. Parsons Management guide to ecosystem restoration treatments: whitebark pine forests of the northern Rocky Mountains, U.S.A. U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station, Fort Collins, CO. General Technical Report RMRS-GTR p. Keane, R.E.; D. Tomback; C. Aubry; A. Bower; E. Campbell; M. Jenkins; M. Manning; S. McKinney; M. Murray; D. Perkins; D. Reinhart; C. Ryan; A.W. Schoettle; and C.M. Smith A range-wide restoration strategy for whitebark pine (Pinus albicaulis). General Technical Report RMRS GTR XXX. Page 4 of 5

5 Fort Collins, CO. U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 126 pp. + Tables, Figures, and Appendix. Tomback, D.F; S.F. Arno; and R.E. Keane Whitebark pine communities: ecology and restoration. Island Press. 440 p. Tomback, D.F.; P. Achuff; A.W. Schoettle; J.W. Schwandt; and R.J. Mastrogiuseppe The magnificent high-elevation five-needle white pines: ecological roles and future outlook. P In: The future of high-elevation, five-needle white pines in Western North America: Proceedings of the High Five Symposium June 2010, Missoula, MT. Keane, R.E.; D.F, Tomback; M.P. Murray; and C.M. Smith, eds. Proceedings RMRS-P-63. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 376 p. USDA Forest Service The region 1 existing vegetation classification system and its relationship to inventory data and the region 1 existing vegetation map products. Compilers: J. Barber, D. Berglund, and R. Bush. USDA Forest Service, Northern Region, Region 1 Vegetation Classification, Mapping, Inventory and Analysis Report. Numbered Report Version p. USDA Forest Service Eastside R1-VMap accuracy assessment (Lewis and Clark, Helena, Custer and Gallatin National Forests). Compilers: D. Vanderzanden, S. Brown, R. Ahl, and J. Barber. USDA Forest Service, Northern Region, Region 1 Vegetation Classification, Mapping, Inventory and Analysis Report. Numbered Report Version p. Weldon, L.A.C. Letter of August 26, Sensitive species designation for whitebark pine. USDA Forest Service, Northern Region. 1 p. Page 5 of 5