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: January 5, 2012 Route To: Subject: To: Little Belt Mountains Recreation/Administrative/Recreation Residence Sites and Roadside 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 under the Endangered Species Act. 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. The 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 and mountain pine beetle. Based on the finding that whitebark pine is a candidate for listing, the Regional Forester, Leslie A. C. Weldon (August 26, 2011) designated it as a sensitive species in the Northern Region. Leslie Weldon 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 became effective 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 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 listed as sensitive in the Northern Region on December 24, 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. Caring for the Land and Serving People Printed on Recycled Paper

2 Compliance: Although some live whitebark pine would be removed as a result of this project, the analysis indicated that the project would not likely result in a trend toward federal listing or reduced viability for the population or species. Mitigation Measures Complete whitebark pine sensitive plant surveys in areas with known populations or potentially suitable habitat prior to project implementation. Within units containing whitebark pine, trees would be assessed to determine condition (overall health and hazard) and appropriate treatment methods. No designated whitebark pine plus-trees in the Northern Region s tree improvement program would be felled or damaged during implementation of the project. The Forest s Tree Improvement Coordinator would assist with location and identification of these trees. Analysis Area The analysis area for whitebark pine consists of the potential treatment units containing whitebark pine. Effects Analysis Methods The effects analysis is based on potential habitat and known whitebark pine populations. A preliminary analysis of the Little Belt Mountains Recreation/Administrative/Recreation Residence sites and Roadside Hazard Tree Removal treatment areas was conducted using information available from Region 1 Existing Vegetation Map Products (R1-VMap). R1-VMap is a satellite imagery-based map product produced by the Northern Region Geospatial Staff 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 in size in the analysis area. Each polygon contains lifeform, canopy cover, vegetation type, and size class information. Vegetation classification in R1-VMap is based on relative abundance (canopy cover, basal area, or trees per acre). For this project, proposed treatment units in the Little Belt Mountains were spatially overlaid on the R1-VMap product to determine if whitebark pine was present based 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. Although the Dom_Mid_40 classification was used for analysis, all of the treatment acres intersecting whitebark pine are also within the Dom_Mid_60 classification (whitebark pine has greater than or equal to 60 percent of the total abundance). 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 and 85 percent for the entire Lewis and Clark and Island Units (Jefferson Division), respectively. No accuracy is associated with the MX-PIAL (whitebark pine) class on the Forest or Island Units 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 (USDA Forest Service 2010). 2

3 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 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. Whitebark pine in the Little Belt Mountains is present on all aspects at high elevations between about 7200 and 8600 feet and occurs in pure to mixed stands with subalpine fir, Engelmann spruce, and lodgepole pine. In this mountain range, whitebark is the dominant vegetation type on approximately 15,033 and 13,510 acres in the Dom_Mid_40 and Dom_Mid_60 classes, respectively. This equates to 1.66 and 1.5 percent of all land ownership in the Little Belt Mountains. When the R1-VMap whitebark pine dominance layer was intersected with the proposed treatment units, about 235 acres of whitebark in both the Dom_Mid_40 and Dom_Mid_60 classes were selected for hazard tree removal. Table 1 displays the proposed treatment units that contain whitebark pine. Although these acres are classified as whitebark pine, forest conditions are variable. The intersected polygons vary from 10 to greater than 60 percent canopy cover, unburned to previously burned in a wildfire, and continuous forest to a mosaic of forest and meadow. Whitebark pine in the treatment areas generally average less than 50 feet tall which means the analysis buffer of 150 feet either side of the road is twice as wide as necessary for implementation. As a result, less than 235 acres of whitebark pine would potentially be treated. In addition, only areas containing tree mortality or damage, as supplied in the proposed action s hazard tree definition, would actually be treated. Prior to treatment of these and other units, sensitive plant surveys would be completed to determine the presence of sensitive species and appropriate management practices. In some units, whitebark pine may be present at incidental levels (tree occurring merely by chance). Table 1. Proposed treatment units that contain whitebark pine in both the Dom_Mid_40 and Dom_Mid_60 R1-VMap classes. Site/Road Road Number Approx. Acres Porphyry Lookout n/a 2.7 Kings Hill Campground/Cabin n/a Scattered trees Porphyry Road Adam s Creek Road Lion Creek Road Higgin s Park Road Deadman Creek Road Memorial Way Road

4 Site/Road Road Number Approx. Acres Dry Wolf Road Yogo Creek Road 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 and 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). Whitebark pine across its range in the Little Belt Mountains has been heavily impacted by mountain pine beetle. 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 trees meeting the characteristics or conditions of a hazard tree would be felled or removed within recreation/administrative/recreation residence sites or along designated roads in the Little Belt Mountains. Implementation of this alternative would, therefore, not produce negative or positive impacts to whitebark pine or affect the threats (fire suppression, climate change, white pine blister rust, and mountain pine beetle) that have lead to the species listing as sensitive. White pine blister rust would continue to infect new trees of all sizes and existing infection would intensify. As a result, cone production on infected trees would decline. In addition, trees stressed from infection would be more susceptible to mountain pine beetle infestation and subsequent mortality. Mountain pine beetle-caused tree mortality (greater than endemic levels) would continue throughout the epidemic. Both mountain pine beetle and white pine blister rust would kill mature whitebark, thus reducing seed availability for reforestation. Although natural agents are threats to whitebark pine s viability, Alternative 1 would have no impact upon the species or its habitat. Cumulative Effects of Alternative 1 Although 235 acres of whitebark pine-dominated forest are within proposed treatment units, Alternative 1 would not directly or indirectly impact whitebark pine or its habitat. Therefore, there would be no cumulative effects to the species. 4

5 Effects of Alternative 2 Alternative 2 would fell whitebark pine possessing characteristics or conditions defined as a hazard tree on about 235 acres. The characteristics or conditions that would pertain to whitebark pine in the Little Belt Mountains are: dead tree, dead top, bark beetle infested green trees (copious amounts of frass or pitch tubes), dead/dying crown, bole cankers (>50% of circumference girdled), and forked or multiple tops. Felling dead whitebark pine would not affect the species viability because these trees are not contributing to the next generation. Likewise, bark beetle infested green trees would be dead within the next year. Although these trees may be capable of producing cones prior to their death, their removal would not detrimentally impact the species. A dead top, dead/dying crown, and cankers are most likely the result of white pine blister rust infection and would require careful consideration prior to selection for removal. The loss of a tree s upper crown positively correlates to the loss of cone production. An unhealthy tree incapable of producing cones would not contribute to species survival. In addition, Clark s nutcracker and other predators may consume seed produced from heavily blister rust infected trees (low quantity of live crown) producing a low quantity of cones prior to seed germination. If adequate crown is present to produce cones and bole cankers are less than 50 percent of the circumference, a whitebark would be considered for retention. Although removal of infected mature trees would reduce the source of blister rust infection for smaller, adjacent whitebark, this effect would be negligible given the abundant source of infection in the adjacent, untreated landscape. Structurally weak trees with the potential to cause property damage or personal injury if they fail would be felled regardless of the tree s capability to produce cones. Very few whitebark pine with forked or multiple tops would be selected for felling since this is the natural growth form of whitebark, especially at high elevations. Felling and removing dead, dying, and hazardous whitebark pine would not produce a noticeable reduction in the landscape-level mountain pine beetle epidemic population in the Little Belt Mountains due to the small extent (scattered, linear units less than 300-feet wide on less than 235 acres) of treatment compared to the acres of suitable and susceptible pine beetle host. Removal of newly infested trees prior to beetle flight, however, could reduce localized beetle populations and may make some residual trees less susceptible to beetle-caused mortality. Alternative 2 would fell hazardous trees and either whole-tree yard them to landings or leave them on site to meet resource objectives. Tree felling, especially if mechanized, and whole-tree yarding have the potential to detrimentally damage existing whitebark pine seedlings and saplings. Extensive damage would inhibit the tree s ability to survive to cone-bearing age. Depending upon landing location, pile burning also has the potential to damage residual whitebark of all sizes. If site surveys indicate the presence of a healthy whitebark pine understory, tree would be manually felled and left in place or removed in such a way (e.g. endline or grapple yard) as to minimize potential resource damage. This alternative has the potential to fell cone-bearing whitebark pine, thereby removing a future seed source that would contribute to species survival. In addition, harvest operations have the potential to damage existing regeneration or residual mature trees. However, a majority of trees to be removed would be dead or dying from mountain pine beetle. This alternative would not impact the current mountain pine beetle epidemic or white pine blister rust infection rate across the Little Belt Mountains. 5

6 Cumulative Effects of Alternative 2 Carbaryl, an insecticide to prevent mountain pine beetle infestation, was applied to whitebark and lodgepole pine trees in the Kings Hill Campground and Cabin site in 2009 and This treatment would occur again in Although a few whitebark pine were lost in the campground prior to spraying, this treatment has been effective in maintaining healthy, live whitebark pine. Verbenone, an anti-aggregation pheromone, and carbaryl have been applied to 33 whitebark pine plus-trees (trees with some level of natural white pine blister rust resistance) in or adjacent to treatment units for the past 5 years to maintain healthy, live whitebark to contribute to the Northern Region s tree improvement program. Cones have been collected from these trees when available. In addition, an operational whitebark pine cone collection was completed in or near the treatment units in 2011 to assist with future whitebark pine restoration projects. The mountain pine beetle prevention treatments have successfully protected valuable whitebark pine. Implementation of Alternative 2 would have no cumulative effects with the carbaryl and verbenone treatments or cone collection since it would remove generally unhealthy, non-cone-bearing whitebark pine that pose a safety hazard. Several wildfires have burned within areas proposed for hazard tree removal. The Adam s Creek fire in 1961 burned approximately one-half (3-4 acres) of the acres containing whitebark along the Adam s Creek Road (#6414). The Lost Fork and Ant Park wildfires in 2001 and 2003 burned approximately 1 and 3 acres adjacent to the Memorial Way Road (#487). Although these acres are included in the R1-VMap class for whitebark pine, they currently contain an overstory of dead trees that would be felled due to their hazardous nature. Removal of trees killed during past wildfires would not cumulatively affect whitebark pine s viability or its habitat because these trees are currently dead and the habitat has not been unsuitably modified. Porphyry Lookout is situated within a whitebark pine forest at nearly 8200 feet elevation with mountain pine beetle-caused tree mortality and heavy white pine blister rust infection. Dead, dying, or hazardous trees were fell, hand-piled, and burned at this location in 2010 under the Showdown Hazard Tree Removal decision. Due to the manual nature of the treatment, very little understory vegetation was damaged. Alternative 2 would remove additional hazard trees from the site. Mechanized treatment, however, could cause damage to existing whitebark pine seedlings and saplings. Alternative 2, in addition to the previous activity, would cumulatively result in fewer live whitebark pine. However, the cumulative effects would occur on less than 3 acres (<0.02%) of whitebark in the Little Belt Mountains. The Deadman-Memorial Way Road Capital Investment Project, with decisions in September 2009 and April 2011, proposes to construct (re-route) about one mile of road through whitebark pine dominated forest. All trees, regardless of species, size, or condition, would be felled and removed for 25 feet either side of centerline. This action would permanently remove about 6 acres of whitebark pine and its habitat. The current road alignment (#487) is also situated within whitebark pine and would have hazard trees felled. Implementation of Alternative 2 along this road would remove unhealthy, mature whitebark and could damage seedlings and saplings. However, once the Deadman-Memorial Way project is completed, the re-routed segment of road would be rehabilitated. Although implementation of these projects would cumulatively reduce the number of whitebark pine and the acres of suitable habitat in the short-term, the rehabilitated road would provide suitable whitebark pine habitat in the long-term. 6

7 Determination of Effects It is my determination that implementation of the proposed Little Belt Mountain Recreation/Administrative/Recreation Residence Sites and Roadside Hazard Tree Removal project may impact whitebark pine individuals or habitat, but will not likely result in a trend toward federal listing or reduced viability for the population or species (MIIH). /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 high-elevation five-needle white pine ecosystems. P In: The future of highelevation, 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. 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. 7

8 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 Lewis and Clark national forest plan, as amended USDA Forest Service, Lewis and Clark National Forest. USDA Forest Service Lewis and Clark national forest plan, decision notice and forest plan amendment number 12. USDA Forest Service, Lewis and Clark National Forest. USDA Forest Service Forest Service manual wildlife, fish, sensitive plant habitat management, amendment , chapter 2670 threatened, endangered, and sensitive plants and animals. USDA Forest Service, Washington Office. 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. 8