BIOLOGICAL ASSESSMENT
Assessment of activities that may affect the federally listed plant species,
Gentner’s Fritillary, Cook’s Lomatium, and Large-flowered Woolly Meadowfoam,
on Bureau of Land Management, Medford District and Cascade Siskiyou National
Monument
Bureau of Land Management
Medford District
September 30, 2013
Prepared by Bryan Wender, Bureau of Land Management, Medford District, in consultation with Sam
Friedman, US Fish and Wildlife Service, Roseburg, OR.
CONTENTS
I. INTRODUCTION ......................................................................................................................................... 4
ACTION AREA ............................................................................................................................................ 5
LAND OWNERSHIP .................................................................................................................................... 5
II. PROPOSED ACTIONS .................................................................................................................................. 6
PROJECT TYPES ADDRESSED UNDER THIS BA ............................................................................................ 7
PROJECT TYPES NOT ADDRESSED UNDER THIS BA .................................................................................... 8
PROJECT DESCRIPTIONS ............................................................................................................................ 8
A. Abandoned Mine Land Remediation ................................................................................................ 9
B. Cultural Resource Projects ............................................................................................................... 9
C. Fuels Management and Wildfire Suppression ............................................................................... 10
D. Mining and Exploration Activities .................................................................................................. 11
E. Quarry Operations ........................................................................................................................... 12
F. Range Operations ............................................................................................................................ 12
G. Recovery Actions............................................................................................................................. 12
H. Recreation Projects and Administrative Site Maintenance ........................................................... 13
I. Research, Inventory, and Monitoring .............................................................................................. 13
J. Road Maintenance and Construction ............................................................................................. 13
K. ROW Permitting for Roads ............................................................................................................. 14
L. ROW Permitting for Other Uses ..................................................................................................... 15
M. Silvicultural Treatments ................................................................................................................ 15
N. Special Forest Product Harvesting ................................................................................................. 16
O. Tree Harvesting .............................................................................................................................. 16
P. Watershed Restoration .................................................................................................................. 17
Q. Weed Control................................................................................................................................. 17
III. PROJECT DESIGN CRITERIA ..................................................................................................................... 24
1
GENERAL PROJECT DESIGN CRITERIA ...................................................................................................... 24
Project Notifications ............................................................................................................................ 24
Clearance Surveys ............................................................................................................................... 24
Inconclusive Surveys ........................................................................................................................... 25
Marking and Buffering ........................................................................................................................ 25
Project Activities during Dormancy ..................................................................................................... 25
Use of Heavy Equipment ..................................................................................................................... 26
Emergency Exemptions ....................................................................................................................... 26
SPECIFIC PROJECT DESIGN CRITERIA ....................................................................................................... 26
A. Abandoned Mine Land Actions ....................................................................................................... 26
B. Cultural Resources Projects ............................................................................................................ 26
C. Fuels Management and Wildfire Suppression ................................................................................ 27
D. Mining Operations .......................................................................................................................... 28
E. Quarry Operations ........................................................................................................................... 28
F. Range Operations ............................................................................................................................ 28
G. Recovery Actions............................................................................................................................. 29
H. Recreation Projects and Administrative Site Maintenance ............................................................ 29
I. Research and Monitoring Actions .................................................................................................... 30
J. Road and Bridge Maintenance and Construction ............................................................................ 30
K. ROW Permitting for Roads .............................................................................................................. 30
L. ROW Permitting for Other Uses ...................................................................................................... 30
M. Silvicultural Treatments ................................................................................................................. 31
N. Special Forest Product Harvesting .................................................................................................. 31
O. Tree Harvesting............................................................................................................................... 32
P. Watershed Restoration ................................................................................................................... 32
Q. Non-native Invasive Plant Control .................................................................................................. 33
2
IV. ENVIRONMENTAL BASELINE .................................................................................................................. 35
COOK’S LOMATIUM and DESIGNATED CRITICAL HABITAT ...................................................................... 35
Long-term Demographic Monitoring .................................................................................................. 36
Cook’s Lomatium Outlook ................................................................................................................... 36
GENTNER’S FRITILLARY ............................................................................................................................ 37
Long-term Demographic Monitoring .................................................................................................. 39
Modeling Demographic Response to Climate Variables ..................................................................... 39
Long-term Population Monitoring at 57 Sites ..................................................................................... 39
Gentner’s Fritillary Outlook ................................................................................................................. 40
LARGE-FLOWERED WOOLLY MEADOWFOAM ......................................................................................... 40
Large-flowered Woolly Meadowfoam Outlook .................................................................................. 41
V. EFFECTS OF THE PROPOSED ACTIONS .................................................................................................... 42
DIRECT AND INDIRECT EFFECTS .............................................................................................................. 42
Effect to Listed Plants .......................................................................................................................... 42
Effects to Critical Habitat .................................................................................................................... 50
INTERRELATED AND INTERDEPENDENT EFFECTS .................................................................................... 55
CUMULATIVE EFFECTS............................................................................................................................. 55
VI. BIOLOGICAL ASSESSMENT CONCLUSIONS ............................................................................................. 56
VII. LITERATURE CITED................................................................................................................................. 58
VIII. PERSONAL COMMUNICATIONS ........................................................................................................... 60
APPENDIX A. LISTED PLANT SURVEY PROTOCOLS ....................................................................................... 62
Cook’s lomatium and large-flowered meadowfoam survey protocol ................................................ 62
Gentner’s lily survey protocol ............................................................................................................. 62
3
I. INTRODUCTION
This is a programmatic consultation of management activities that may affect federally listed plant
species on lands managed by the Bureau of Land Management (BLM) on the Medford District and
Cascade-Siskiyou National Monument (CSNM). Resources on the Medford District and its management
direction are described in the Medford District Record of Decision and Resource Management Plan
(Bureau of Land Management 1995). This plan was amended by the Record of Decision for Amendments
to Planning Documents within the Range of the Northern Spotted Owl (USDA Forest Service and USDI
Bureau of Land Management 1994), hereafter referred to as the Northwest Forest Plan (NWFP).
Management direction for CSNM is described in the Cascade-Siskiyou National Monument Record of
Decision and Resource Management Plan (Bureau of Land Management 2008).
The area of consideration includes Medford District in Jackson, Josephine, Douglas, Coos, and Curry
Counties. Most of the federal land in the Medford District is distributed in a checkerboard pattern
consisting of alternating sections of public and private land. CSNM is contained entirely within Jackson
County. Some of CSNM exhibits a checkerboard ownership pattern, but the monument also includes
larger contiguous blocks of federal land.
In order to meet the requirements of the Endangered Species Act of 1973, as amended (ESA), this
biological assessment (BA) describes and evaluates the potential effects of proposed BLM management
activities on three listed endangered plant species and designated critical habitat. All three species
addressed in this BA are listed as endangered: Gentner’s fritillary (Fritillaria gentneri), Cook’s lomatium
(Lomatium cookii), and large-flowered woolly meadowfoam (Limnanthes pumila ssp. grandiflora). This
BA also addresses critical habitat, which has been designated for Cook’s lomatium on BLM lands.
Federally listed fish and wildlife are not included in this BA.
Medford District BLM and the Roseburg Field Office of US Fish and Wildlife Service (USFWS) will annually
review proposed actions and the status of listed species to determine whether significant changes
warrant initiation of additional consultation. In the absence of significant changes, this BA will remain
valid.
In order to reduce or eliminate negative effects of proposed actions on listed plants or critical habitat,
Project Design Criteria (PCD) are prescribed for each project type. PDC typically include pre-disturbance
surveys and protection buffers, but may also include other protection measures and restrictions.
This BA was completed jointly by Bryan Wender, Medford District Botanist, and Sam Friedman, Botanist
for the Roseburg Field Office of U.S. Fish and Wildlife Service. Other specialists from the BLM also
contributed to the content and analysis of this document. Much of the information was carried forward
from previous programmatic BAs (Bureau of Land Management 2008, Bureau of Land Management
2011); however, the environmental baseline and proposed action information was updated to reflect
current information.
4
ACTION AREA
The action area is defined as all areas to be affected directly or indirectly by the Federal action and not
merely the immediate area involved in the action. For the purposes of this BA, the action area includes
all lands managed by the Medford District and CSNM, and all activities that occur on adjacent nonfederal lands as a consequence of BLM (i.e., lands on which a federal nexus exists).
The proposed actions are located mostly within the Rogue River sub-basin, the Cow Creek drainage of
the Umpqua River sub-basin, and the Klamath River sub-basin. Medford District and CSNM are located
within the Klamath Mountains Ecoregion and Western Cascades Ecoregion. The Klamath Mountains
Ecoregion of northwestern California and southwestern Oregon is distinctive because of its variable
topography, unique geology, abundant watercourses, rare plant habitats, and endemic plant
communities. A complex fire, logging, and mining history further affect vegetation patterns and
structure across the landscape.
Natural plant community types within Medford District are diverse. Oregon white oak (Quercus
garryana) woodlands, grasslands, chaparral, ponderosa pine, and Douglas-fir occur up to about 2,400
feet in the interior valleys. Above this elevation, on the Klamath Mountains side of the Rogue Valley, a
mixed-evergreen zone dominated by Douglas-fir (Pseudotsuga menziesii) and madrone (Arbutus
menzeisii) occurs up to about 4,500 feet. In the Cascades, a mixed-conifer zone is dominated by
ponderosa pine (Pinus ponderosa), Douglas-fir, and incense cedar (Calocedrus decurrens), with white fir
(Abies concolor) in more mesic sites. In both regions, dense chaparral (sclerophyllous type)
communities, composed primarily of wedge-leaf ceanothus (Ceanothus cuneatus) and manzanita
(Arctostaphylos species), can occupy large patches. Above 4,500 feet is the white fir zone, grading into a
Shasta red-fir (Abies procera x magnifica) zone up to timberline. The elevations of the Medford District
range from 400 feet along the Rogue River near Mariel to 6,500 near Big Sugarloaf peak. The Medford
District manages very little land above 6000 feet.
Within CSNM, plant communities include Oregon white oak woodlands, California black oak (Quercus
kelloggii) woodlands, oak-juniper woodlands, ponderosa pine and sugar pine (Pinus lambertiana) forests,
dry mixed-conifer forests, white fir forests, dry grasslands and shrublands, and wet meadows. Stream
bottoms support deciduous riparian trees and shrubs.
The ecological diversity of natural communities and plant species in the region is attributed to its
physiographic setting at the confluence of the Klamath Mountains and Cascades. This confluence of
ecoregions also allows for a confluence of species whose distributions are centered south into the Sierras
of California, east into the Great Basin, or north along the Cascades and the Coast Range.
LAND OWNERSHIP
Medford District lands are highly intermingled with non-federal lands. Human populations are centered
in the cities of Medford, Grants Pass, Cave Junction, and Ashland. For the approximately 3.1 million
acres within the official boundary of the Medford District, 42% are private lands, 28% are BLM lands,
29% are other federal lands (predominately US Forest Service), and < 1% are owned by the state, county,
5
or city municipalities. Similarly, CSNM lands are intermingled with private lands. Of the approximately
85,000 acres within the greater monument boundary, over 24,000 acres remain private.
Federally listed plants are protected on federal lands by ESA and are protected on state, county, and city
lands under Oregon state law. However, federal and state laws do not protect listed plants on private
lands; thus, private lands are typically not expected to provide sustainable habitat for listed plants. An
estimated 40% of private lands have already been converted from natural woodlands, wetlands, and
forests to other uses (pastures, woodlots, and urban centers) and likely no longer support listed plants.
The conversion of intact suitable habitat in the low elevation woodlands and grasslands into pastures,
vineyards, orchards, and home sites is increasing throughout the Rogue Valley as its human population
continues to grow. Nonetheless, some private lands do offer protection for listed plant populations. For
example, The Nature Conservancy has lands in the Agate Desert, near Medford, which are managed to
benefit Cook’s lomatium and large-flowered woolly meadowfoam under agreements with USFWS.
Oregon Wildlands own private wetland habitat within the Agate Desert north of Medford, Oregon,
containing populations of large flowered woolly meadowfoam. Conservation easements also protect
some listed plant populations, including Southern Oregon Land Conservancy easements that protect
Cook’s lomatium in the Agate Desert and Gentner’s fritillary in Sam’s Valley.
II. PROPOSED ACTIONS
Proposed actions analyzed in this BA are for projects that are anticipated to occur from October 1, 2013
until significant changes occur, such as new management direction provided in a revised Medford
District Resource Management Plan (currently scheduled for completion in fall 2015). BLM and USFWS
will meet annually to review proposed actions and the status of listed species to determine whether
significant changes warrant reinitiation of this consultation. In the absence of significant changes, this
BA will remain valid.
The signing of the decision document (decision notice, memo, or record of decision) marks the point in
time at which a project is covered by this BA. Listed plant surveys and environmental analysis must be
complete prior to the decision document and the effects of the proposed actions must be documented in
an appropriate NEPA document (CE, EA, or EIS). Rare plant clearance surveys completed up to 10 years
prior to the signing of the decision document are valid, even if project implementation does not occur
immediately.
Project design criteria (PDC) are conservation measures developed to reduce impacts to listed species.
Mandatory PDC are prescribed in this BA for each proposed project type. If the prescribed PDC cannot be
implemented for a project, then the project is not in compliance with this BA; consequently, additional
consultation with the USFWS is required (if the project has potential to affect listed plants). PDC are
necessary for the BLM to comply with their responsibilities to conserve listed species under ESA Section
7 (a) (1) and Section 9 (a) (2). To further reduce effects of the proposed actions, additional discretionary
PDC may be proposed during the interdisciplinary team project planning process.
This BA analyzes actions that will be implemented under the Medford District Record of Decision and
Resource Management Plan (RMP). A revision to the district’s RMP is currently underway and projected
6
to be complete by the end of FY 2015. Upon its completion, BLM will review and modify this BA as
needed to ensure compliance with new management directions prescribed under the revised RMP.
The projects addressed in this BA are grouped into the general action categories described below. The
predicted scope and amount of disturbance (e.g., acres, miles, number of projects) of these activities are
reported both as an estimated average annual quantity and an allowable five-year maximum cumulative
quantity.
PROJECT TYPES ADDRESSED UNDER THIS BA
A. Abandoned mine land remediation: closure of mine adits and shafts.
B. Cultural resource projects: excavations and cultural site maintenance/restoration.
C. Fuels management and wildfire suppression: fuel breaks, piling, pile burning, broadcast
burning, thinning, brush treatments (includes fuels activities within timber sales), and wildfire
suppression.
D. Mining and exploration activities: casual-use mining activities, notice-level mining activities,
plan-of-operation mining activities, mineral material disposal, and mine-site remediation.
E. Quarry operations: rock extraction and future site expansion.
F. Range operations: livestock allotment renewals, fence construction and maintenance,
monitoring, spring improvements and maintenance.
G. Recovery actions: habitat restoration/maintenance, seed/bulb collection, growing, and outplanting.
H. Recreation projects and administrative site maintenance: recreation permitting (commercial
and private), trail construction/maintenance, campground development/maintenance, and
other recreation facility development/maintenance, administrative site maintenance, utility and
communication site maintenance.
I.
Research and monitoring: vegetation monitoring (e.g., long-term vegetation change, forest
production, fuels, and weed treatments) and research on listed plants.
J.
Road maintenance and construction: road maintenance, road decommissioning, site
restoration, culvert replacement/repair, bridge maintenance/repair, road realignment.
K. ROW permitting for roads: discretionary FLPMA and O&C road-use permits, maintenance, and
new construction.
L. ROW permitting for other uses: permitting for utility ROW construction/maintenance, special
events, and minimum impact permits.
M. Silvicultural treatments: vegetation management activities, such as stand density management,
conversion, fertilization, pruning, pre-commercial thinning of managed and natural stands, Port7
Orford-cedar sanitation, riparian thinning, animal damage control (gopher trapping), slash piling,
and burning.
N. Special forest product harvesting: Christmas trees, firewood, boughs, cones, mushrooms,
lichens, shrub cuttings, bear grass cuttings, edible/medicinal plants, transplants, shakes, rails,
poles, miscellaneous sawtimber, and burls.
O. Tree harvesting: various levels of regeneration harvests, commercial thinning, restoration
thinning, selective harvest, density management, commercial firewood, hazard tree removal,
stewardship harvest, and opportunistic salvage.
P. Watershed restoration: culvert repair/replacement, road restoration, road decommissioning,
slope stabilization, habitat improvement projects, stream improvement projects (e.g., tree
lining/felling, down wood, and snag creation).
Q. Weed control: manual, mechanical, biological, and chemical treatments.
PROJECT TYPES NOT ADDRESSED UNDER THIS BA
Some management activities are not covered under this BA. Impacts resulting from these activities are
too variable to predict or the impacts too broad; consequently, these activities may require projectspecific consultation.
1. Recreational off-highway vehicle use including designating OHV areas.
2. Land exchange and other realty actions.
3. Some research projects that are likely to adversely affect listed species (other than the
recovery actions described herein).
4. Suppression activities for large severe fires.
5. Treatments to mitigate catastrophic insect or disease outbreak (e.g. Sudden Oak Death).
6. Management activities that are prescribed following completion of a revised Medford District
Resource Management Plan (anticipated completion in late 2015) and that differ
substantially from those analyzed in this BA. When this new plan is complete, BLM and
USFWS will discuss the need to reinitiate consultation.
PROJECT DESCRIPTIONS
The following descriptions are for project types that have the potential to affect listed plant species and
critical habitat as a result of implementing the 1995 Medford District RMP and 2008 CSNM RMP. As
described in the NWFP, the BLM practices adaptive management, which allows minor project variations
to meet site-specific conditions or landscape objectives. Therefore, there may be minor deviations in the
description of projects over the life of this BA. This consultation will cover these minor project
alterations if the following conditions are met:
8






Project activities comply with the NWFP.
Project activities comply with the 1995 Medford District RMP or the 2008 CSNM RMP (or
subsequent plan revisions or amendments).
Impacts and extent of the project activities are within parameters described in this BA.
Questionable deviations are reviewed by the Level 1 Team to ensure impacts to listed species
remain the same or less than those described within this BA.
Protection measures proposed for the project are consistent with the intent and impacts
described in this BA.
All monitoring results and project impacts to listed plants are reported to USFWS in annual
monitoring reports.
If these conditions are not met and the project cannot be revised to comply with this BA, then additional
consultation will be required to meet ESA requirements.
Project activities are described in terms of type of activity, disturbance amounts, extent, duration, and
timing. For each project type, average annual action amounts and five-year cumulative allowable action
amounts are provided (Table 1). If action amounts exceed the five-year maximum amount, then
consultation with USFWS may need to be reinitiated. The Level 1 Team will evaluate these cases as they
arise. Additional action amounts may not always change the net effects to the species; thus, reinitiating
consultation may not be warranted. The effects of project activities are evaluated in Section V, Effects
of Proposed Actions. Final determination of effects of these projects is summarized in Section VI,
Biological Assessment Conclusions.
A. Abandoned Mine Land Remediation
Mine adits (horizontal tunnels) and shafts (vertical tunnels) are closed to reduce public exposure to falls,
mine collapses, and low-oxygen atmospheres. Adits may be closed with steel bat gates or filled with
rock and soil with heavy machinery. Shafts may be filled with rock and soil by heavy machinery or filled
with polyurethane foam applied by backpack sprayer. Rock and soil fill materials are brought from offsite commercial sources, rather than excavated from the project area. Site access for heavy equipment
is only on existing useable roads; otherwise, alternative closure methods (gates or foam) are selected.
Pickup trucks or ATVs may be driven off road to supply materials to the site for constructing bat gates.
Disturbance is restricted to the access corridor and the area immediately surrounding the adit or shaft.
Activities may occur any time during the year.
B. Cultural Resource Projects
Cultural resource projects include small excavations, cultural site maintenance, and cultural site
restoration. Excavations involve one to several-person crews excavating by hand in small areas, with
minimal disturbance to vegetation. Many of these excavations are undertaken in areas that have been
heavily disturbed in the past. Cultural site maintenance rarely involves ground disturbance, but may
include disturbance to above-ground vegetation. Restoration of cultural sites, such as historic
graveyards, could include rebuilding fences, righting stones, and removing overgrown vegetation.
9
Occasional heavy equipment could be used to replace artifacts, such as historic grave markers, or to
install protective barriers or fences around sensitive areas.
C. Fuels Management and Wildfire Suppression
Fuels management has three primary purposes: (1) fuels reduction to reduce wildfire hazard, (2) site
preparation and slash reduction for improving conifer planting (see M. Silvicultural Treatments), and (3)
restoration of ecosystem function where wildfire has been suppressed. Much of the land in Medford
District historically had short natural fire-return intervals, but years of fire suppression have resulted in
habitat conditions much brushier and denser than those that occurred historically. Many natural
communities also now include substantial non-native vegetation components, which may affect fire
regimes and fuels management objectives and approaches. Fuels management treatments may
complement weed control efforts (see Q. Weed Control) or rare plant habitat improvement objectives
(see G. Recovery Actions), if used at the right time under the correct conditions.
Fuels management includes manual and/or mechanical treatments using chainsaws and/or heavy
equipment, often followed by prescribed fire (pile burning or broadcast burning). Broadcast burning
without pre-treatment may also occur. Manual and mechanical treatments are designed to convert
abnormally high amounts of shrubs and ladder fuels so that subsequent prescribed burning or wildfire
would be less severe. For manual treatments, vegetation is cut and piled by hand, to be burned after the
material has dried. Piles range in size from 25-50 ft2 and typically cover, on average, about 5% of a
treated acre in conifer communities. In heavy fire-suppressed shrublands, piles may cover 10% of a
treated acre. Cut vegetation may be scattered, rather than piled, for small projects. Mechanical
treatments involve heavy machinery that cuts and pulverizes vegetation, leaving all material on site in a
masticated layer. A small percentage of acres treated by masticating equipment may also be later
burned to remove treated material. Manual and mechanical treatments can occur at any time of the
year.
Prescribed fire use is dependent upon management objectives. The primary role of prescribed fire on
the Medford District has traditionally been for site preparation and fuels reduction. Recently, ecological
objectives have become end goals of prescribed fire. Prescribed burning is generally restricted to spring
or a small window in the fall, due to risks of escapes, smoke concerns, and weather.
Natural and created fuel breaks across the landscape may be developed to help with the suppression of
large-scale wildfires. In this case, treatment of fuels along a ridge or topographic break would occur to
reduce the fuels and facilitate suppression activities. Fire line construction, road grading, and blasting
may occur as a tool to help create fire lines.
Projects on private lands are not covered by this BA, except where BLM authorizes treatment along
property boundaries to protect structures on private lands to meet county requirements for fire safety
protection. In these cases, BLM may permit small treatment buffers along property lines. Buffers are
typically < 100 feet wide.
10
D. Mining and Exploration Activities
Mining actions are divided into three levels: casual-use activities, notice-level activities, and plans of
operation. All levels of mining require reclamation, adherence to the BLM surface regulations, and for
the claimant to acquire all necessary state and federal permits.
Casual use means activities ordinarily resulting in no or negligible disturbance of the public lands or
resources. This level of mining includes the collection of geochemical, rock, soil, or mineral specimens
using hand tools; the use of metal detectors; hand panning; non-motorized sluicing; and some types of
suction dredging. The claimant does not need to notify the BLM of these activities.
For notice-level activities, a claimant must submit a complete notice of their operation fifteen calendar
days before commencing exploration. Notice-level activities may not cause surface disturbance of more
than five acres or process more than 1,000 tons of presumed ore. The notice is non-discretionary, not
approved by BLM, and does not require NEPA analysis. BLM has fifteen days to review a notice and a
bond is required.
In any of the following special areas, a proposal must be submitted as a plan of operations, rather than a
notice:






Areas in the National Wild and Scenic Rivers System, and areas designated for potential addition
to the system.
Designated Areas of Critical Environmental Concern (ACEC).
Areas designated as part of the National Wilderness Preservation System and administered by
BLM.
Areas designated as closed to off-road vehicle use, as defined in the Code of Federal Regulations
(43 CFR 8340.0–5).
Any lands or waters known to contain federally proposed or listed threatened or endangered
species or their proposed or designated critical habitat, unless BLM allows for other action under
a formal land-use plan or threatened or endangered species recovery plan.
National Monuments and National Conservation Areas administered by BLM.
A claimant must also submit a plan of operations and obtain BLM approval when a project will cause
surface disturbance greater than five acres or for bulk sampling in which 1,000 tons or more of
presumed ore will be removed. These activities are defined as actual mining, not exploration. The BLM
has thirty days to review a plan for completeness. A bond is required from the claimant. Unlike a notice,
approval of a plan of operations is a discretionary action and requires NEPA analysis and a decision by
the BLM.
Mining sites may be reclaimed either by the claimant or BLM. Reclamation would involve the use of
heavy machinery for surface reconstruction and stabilization, site preparation, and repairing surface
hydrology. Additional reclamation activities would involve revegetation, weed management, and longterm monitoring.
11
E. Quarry Operations
Rock is extracted from existing quarries by drilling, blasting, crushing, and hauling. Damage to
vegetation is minimal because disturbance occurs only within the quarry boundary and road corridors.
Medford District infrequently authorizes quarry expansions, which results in removal of vegetation
within the expanded footprint.
Permits are also issued for personal and commercial landscape rock, which is removed from previously
existing quarries by hand. These activities do not disturb existing vegetation.
F. Range Operations
Livestock grazing occurs in the eastern portions of Medford District, including on three active allotments
in CSNM. At this time, grazing is not active (vacant) in the western portions of the district. Medford
District has 97 grazing allotments identified in the 1995 RMP, covering 352,000 acres, of which 35
allotments are currently vacant (106,064 acres). The three active allotments in CSNM include 49,424
acres. Of the three active CSNM allotments, only one is under management of Medford District (Ashland
Resource Area); the remaining two are managed by Lakeview District (Klamath Resource Area). Existing
allotments carry 13,416 animal unit months (AUMs), including 2,714 AUMs in CSNM. Allotments range
in size from 40 acres (3 AUMs authorized) to 35,471 acres (2,694 AUMs authorized).
Vacant allotments are still valid allotments that could be applied for and utilized; however, allotments
that have been vacant for more than five years tend to have issues that reduce public interest in leasing
them, making their re-authorization unlikely. In any given year, an allotment may also be in non-use
status, depending on the permit holder’s needs, the market, or cooperative agreements between the
BLM and the permit holder on rangeland health issues and forage recovery.
Range improvements on allotments can occur in any year and may include fence building and repair, the
installation or maintenance of cattleguards, water developments (spring boxes, stock tanks, piping, and
pond improvements), riparian fencing, and forage enhancement (e.g. grass seeding, shrub plantings).
No more than three improvement projects are likely in any year given current funding trends.
Rehabilitation after fire may pose special circumstances or opportunities. Most annual activities involve
the maintenance of existing fences, cattleguards, and water developments.
G. Recovery Actions
Recovery Plans provide direction to Medford District for implementing recovery actions for Gentner’s
fritillary, Cook’s lomatium, and large-flowered woolly meadowfoam. Because large-flowered woolly
meadowfoam does not occur on BLM land, recovery actions will focus only on Gentner’s fritillary and
Cook’s lomatium, with special emphasis on designated critical habitat for the latter.
For Gentner’s fritillary, recovery actions will include (1) experimental habitat management treatments,
(2) protection of occurrences from OHVs and livestock, (3) seed and bulb collection, (4) growing plants in
greenhouses and field plots, and (5) out-planting of bulbs to augment existing population sizes and
create new populations in management areas. Habitat management treatments may include manual
woody vegetation removal; chemical control of woody vegetation, using cut-stump, hack-and-squirt, and
12
direct-inject methods; prescribed fire; and chemical control of non-native invasive plants, including
annual grasses.
Similarly, recovery actions for Cook’s lomatium will focus on site protection, habitat management,
population augmentation, and population reintroduction. Preventing the disturbance of wet meadow
habitats from OHVs is a primary concern. Again, habitat management treatments may include reduction
of encroaching woody vegetation from wet meadows (using manual and the above-described chemical
methods), prescribed fire, and chemical control of non-native invasive plants.
H. Recreation Projects and Administrative Site Maintenance
Recreation projects on the Medford District include construction and maintenance of trails, trailheads,
parking lots, campgrounds, restrooms, boat landings, observation decks, foot bridges, guard rails, signs,
fences, and other physical facilities. Heavy equipment may be used during construction. Maintenance
activities may occur any time during the year and at a variable frequency that depends on level of use,
accessibility, weather conditions, and other factors. Trees may be felled in developed areas or along
trails where public safety is a concern (typically an annual activity). Medford District also issues
commercial and private permits for recreation activities, such as rafting, boating, equestrian events, and
bicycle rides and races.
Administrative site maintenance includes primarily those facilities associated with recreation sites, but
also includes radio repeaters, RAWS weather stations, and some utility infrastructure.
I. Research, Inventory, and Monitoring
Vegetation research, inventory, and monitoring on Medford District occurs for many programs, including
timber, range, recreation, hydrology, fuels, wildfire, weeds, rare plants, site restoration, and special
management areas (e.g., Research Natural Areas). Most monitoring is non-destructive, involving fixed or
random plots/transects designed to collect data on the abundance, structure, and composition of
vegetation and fuels. Some monitoring may involve removal and weighing of vegetation biomass.
Often, plant specimens are collected for identification. Monitoring is done by botanists, ecologists, range
conservationists, foresters, or contractors who are familiar with regional vegetation and listed plant
species.
Existing research and monitoring actions related specifically to federally listed plant species include (1)
annual demographic monitoring of Gentner’s fritillary at Pickett Creek, (2) annual monitoring of 57 other
Gentner’s fritillary sites across the district, (3) research of techniques for propagating, cultivating, and
transplanting Gentner’s fritillary and Cook’s lomatium, (4) annual monitoring of outplanted Gentner’s
fritillary at five sites across the district, and (5) annual demographic monitoring of Cook’s lomatium at
three locations in the Illinois Valley.
J. Road Maintenance and Construction
Road construction (which includes culvert and bridge installations) involves ground disturbance, removal
of vegetation, grading, road paving and surfacing, and occasional blasting. Activities are associated with
tree harvesting, recreation, rights-of-way (ROW), and other project categories. Road maintenance
13
consists of grading, brushing, culvert and bridge maintenance and repair, water bars installation and
repair, minor road paving and resurfacing, and occasional hazard tree removal or minor re-routing.
Medford District maintains roads, culverts, and bridges on a schedule, but also responds to
unanticipated repairs due to weather, accident, or landslide. Most activity is limited to short periods of
time. Road grading generally affects the ditch and a few feet or so of the cut-slope, with some loose
material spilling over the fill-slope. Maintenance brushing generally entails mechanically cutting brush
down to less than a foot high within four feet of the edge of road tread. Brush more than four feet from
the edge of the road tread is not treated. Some blasting may be required to remove unstable portions of
the cut-slope, often at rock faces.
Road decommissioning is usually tied to Watershed Restoration and covers activities that reduce or
eliminate traffic use on the road by installing gates, barriers, rocks, ripping the tread, pulling culverts,
and seeding grasses and forbs. Full obliteration of the road returns the road back to natural contour
levels using excavators. Full obliteration also can remove intact vegetation along the top of the cut slope
to create a stable slope.
K. ROW Permitting for Roads
Private landowners are required to obtain ROW Permits to build or use roads across BLM managed land.
These ROW permits are usually authorized under the Federal Land Policy and Management Act of 1976
and are often referred to as FLPMA permits. For the purpose of this BA, private lands refer to privately
owned or other government non-federal parcels, located as in-holdings or adjoining property through
which access is granted across federally managed lands. Maintenance of the road also can be included in
these permits.
Medford District also issues O&C ROW permits for commercial purposes and/or to haul commercial
products on BLM maintained road systems if these permits are not already in place. Road construction
and/or maintenance can be part of these permits, as well as non-linear features like landings or turnaround areas. Federal discretion to influence the implementation of recovery efforts for threatened or
endangered species may be limited or non-existent where certain pre-existing Road Use or Reciprocal
Right-of-Way agreements exist between private landowners and the BLM. Many older existing road
activities in the Action Area are already covered by reciprocal rights of ways with private parties and the
BLM no longer has discretion. Section 9 prohibitions (ESA) are the responsibility of the applicant in
situations when federal discretion is not retained; however, this does not apply to plants (only
vertebrates). This BA does not address non-discretionary activities. All new O&C permits issued are
subject to ESA and NEPA analysis and the BLM can stipulate PDC to reduce or negate impacts.
Road building (construction or reconstruction) will be authorized on BLM land under the terms of
individual FLPMA or O&C road permits. These activities are equivalent to those described under project
type J. Road Maintenance and Construction.
On 30 January 2003, a new multi-agency Road Use Permit policy (Application of the Endangered Species
Act to proposals for access to non-federal lands across lands administered by the Bureau of Land
Management and the Forest Service) was instituted. BLM, US Forest Service (USFS), USFWS, and NOAA
(National Oceanic and Atmospheric Administration) Fisheries are signatories to this policy. The
14
provisions of this agreement apply only when a BLM right-of-way grant is required for the reconstruction
or construction of a road, for either private or commercial purposes (see O&C permits below), to secure
access to a parcel of non-federal land. The key components of the interagency agreement are:




The agreement applies to grants of rights-of-way across BLM and/or public lands administered
by USFS under their respective authorities, for purposes of access to non-federal lands.
The proposed federal action to which the agreement applies is the authorization for access
across federal land and subsequent activities on federal land; it does not include any actions on
non-federal lands.
The agreement clarifies that USFS and BLM will not include terms and conditions in access
authorizations that will regulate activities on non-federal land.
At the applicant’s discretion, the agreement provides applicants an option to include the effects
of those activities that will be facilitated by the proposed access and conducted on the
applicant’s non-federal lands as part of a federal agency ESA consultation on the access
application.
L. ROW Permitting for Other Uses
Medford District also authorizes ROW and permits for various uses of federal land for private and
commercial utilities, water and power lines, public works, canals, dams, non-profit and commercial
gatherings, cell or radio towers, group gatherings, etc. Construction or maintenance of power lines, pipe
lines, or cellular towers can result in the removal of vegetation and soil disturbance. Other permitted
activities (e.g. Native American gatherings, festivals, and other group events) can effect vegetation from
trampling and camping. These permits are discretionary and the BLM can re-route activity locations and
stipulate PDC to reduce or negate impacts. Minimum impact permits are ones given where there is
minimal or no impact (e.g., equipment parking for electric tower maintenance on previously disturbed
ROW).
M. Silvicultural Treatments
Silviculture projects involve tree plantation maintenance and the removal of trees and shrubs to enhance
growth, and can include pre-commercial thinning, maintenance brushing (release), prescribed burning
for site preparation, tree planting, sanitation to control Phytophthora lateralis in Port Orford cedar
stands, animal damage control, fertilization, and pruning. Most pre-commercial thinning occurs in
plantations (stands inter-planted or planted following harvest); however, natural stands may also be
similarly thinned. Projects can include non-commercial vegetation thinning to benefit wildlife or rare
plant species or habitat. Thinning may also occur in stewardship projects where the purpose is to reduce
stocking, adjust species composition, reduce susceptibility to insect and disease, or alter stand structure
for other objectives. Thinning is typically done with hand crews, but mechanized equipment may be
used. Controlling gophers where they have been identified as a cause of plantation failure or
unacceptable conifer stocking is accomplished with underground traps placed in holes and runs created
by the gopher. Fertilizer is applied to accelerate growth of young trees or to improve native plant
restoration outcomes. Fertilizer is applied at a rate of no more than 200 lbs of nitrogen per acre.
Application is by hand or ground equipment; aerial applications are unlikely. Fertilizer may be broadcast
15
or packets may be inserted into the ground during planting. Herbicides may be used for control of nonnative invasive plants, but not for other site preparation treatments.
N. Special Forest Product Harvesting
Special forest products include boughs, Christmas trees, burls (madrone and maple), edible mushrooms,
lichens, moss, shrub cuttings, bear grass cuttings, edible and medicinal plants, whipstock
(seedlings/cuttings of willow, aspen, etc.), fence and corral rails, firewood, post and poles, pulpwood,
roundwood, and individual tree or incidental sawtimber sales. These activities require personal and
commercial use permits issued by BLM. Most harvesting occurs by hand on small sites, typically less
than two acres. Some activities are designated as concentrated use, such as designated firewood cutting
areas within timber sale areas. Other harvests, such as edible plants and mushrooms, are dispersed
across the landscape.
Excluding Christmas trees, Medford District issues approximately 600 special forest product permits per
year, nearly half of which are for firewood. The District issues 1,200 Christmas tree permits per year.
Pulpwood, roundwood, and sawtimber permits (< $2,500 in value) average about 55 permits per year,
accounting for 45,000 cubic feet per year. On average about 50 permits per year are issued for fencing,
posts, and poles, accounting for 900,000 cubic feet per year, mostly from timber sale or pre-commercial
thinning sites. A limited average number of annual permits are issued for other products: 40 permits for
mushrooms, 10 permits for burls, and < 10 permits for edible and medicinal plants.
O. Tree Harvesting
Tree harvest includes commercial and non-commercial removal of mature overstory and/or understory
trees and can include regeneration harvest, seed-tree cuts, selective harvest, salvage, density
management, commercial thinning, restoration thinning, and individual tree removal. Commercial
timber is generally classified as trees > 8 inches diameter at breast height (dbh). Tree harvest also covers
miscellaneous projects, including the removal of hazard trees for public safety, commercial firewood,
stewardship sales, and opportunistic salvage sales. Opportunistic salvage sales result from blow-down
(other than hazard trees), disease, or wildfires. Typically, a salvage project is less than a few hundred
acres but can be as much as 10,000 acres for large wildfire salvages or catastrophic wind events.
Harvest can result in the removal of a few trees within a stand or can result in removal of all trees.
Openings may occur in an even or patchy distribution, depending on objectives of the treatment and
constraints of the land use allocation. Trees are harvested by individual sawyers, or machine-mounted
saws. Harvest includes the layout, marking, falling, limbing, yarding, and decking of trees to be removed
from the site. Tree tops and limbs (slash) may be lopped, scattered, and allowed to decompose within
the project area. Where slash is heavy, it may be piled and burned, or in the case of regeneration
harvests, slash may be broadcast burned. Slash can also be removed and sold as biomass, which
generally includes material < 8 inches dbh. Trees are yarded to landings by cable or skidded by
tractors/skidders. Helicopter logging involves picking up logs in bunches and taking to a designated
landing to be loaded onto trucks. Soil disturbance from yarding and skidding in thinning and partial
harvests is focused along corridors, which can make up between 7% of the area for skyline cable yarding,
and 21% of the area for tractor logging (Landsberg et al. 2003). Helicopter logging has shown deep
16
disturbance on only 2% of the area (Clayton 1981). Higher levels of soil disturbance with ground
methods tend to be focused in areas close to the landings and radiating outward.
Access to the timber sale involves the use of existing roads in areas where roads already occur;
otherwise, access may require design and construction of new roads. New roads involve the total
removal of all vegetation within a corridor, creation of the road prism (cut, bench, and fill), grading,
laying gravel, installing culverts and water bars, and stabilizing adjacent areas. Small temporary road
spurs can be built off of existing roads to facilitate logging activities. These temporary roads are ripped
(to reduce compaction) and revegetated after the sale. Trees removed from road prisms are often
decked for inclusion in the timber sale, or could be sold in unrelated sales, or could occasionally be used
on-site or off-site for watershed restoration, down wood supplementation, or in-stream structures.
The size of the harvest and the disturbance to the soil and understory vegetation in a project area is
related to the intensity of activity. Regeneration harvest units, which remove the majority of trees, occur
on fewer acres than density management or selective harvest, which removes fewer trees, maintains
more residual trees, but covers more acres to obtain the same volume. Selective harvest techniques can
result in project areas that often cover large acreages (several thousand acres), and contain stands with
120-140 feet of basal area per acre, 40-50 trees per acre, and average canopy coverage of 40-60 percent.
P. Watershed Restoration
Watershed restoration projects anticipated in the Medford District include road decommissioning, road
obliteration, storm-proofing roads, erosion rehabilitation, in-stream habitat improvement, snag creation,
riparian restoration, floodplain restoration, and meadow restoration. Projects may occur across the
Medford District in response to wind events, snowstorms, flooding, and fish management objectives.
Roads no longer essential for forest management may be gated, closed, or obliterated (ripped, seeded or
put back to natural contours). Roads with the potential to fail or deliver large amounts of sediment to
stream segments may be improved, closed, or decommissioned. Improvements include repairing road
drainage facilities (culverts, drain dips, etc.) and surfacing (to reduce sediment). The installation and
maintenance of culverts and bridges occurs across the road system.
Riparian, floodplain, and meadow restoration can involve the creation and placement of down wood or
boulders, thinning, fencing, native plant seeding, woody vegetation planting, and weed control. Projects
are limited to a few per year and project areas are typically small.
Q. Weed Control
Noxious weeds, as defined by the State of Oregon, are the only current targets for weed treatment.
Treatments occur during periods of the year when targeted weeds are most susceptible to a particular
treatment. Currently, over 20 designated noxious weeds are targeted on the district and new species
will likely be added to the list within the life of this BA. Weed control treatments include manual,
mechanical, biological, and chemical methods. In most operations, work crews walk through infested
areas spraying or hand-pulling weeds. Chemical treatments are usually done with backpack sprayers,
but may also use vehicle-mounted sprayers with wands or booms. Targeted herbicide application
methods, such as wicking, cut-stump, hack-and-squirt, and basal spray, are preferred when there is a
17
need to minimize incidental spray to adjacent vegetation. Aerial herbicide applications are not
permitted. Treatments may occur in nearly all plant community types across the district, including
habitat for federally listed species. Herbicide use may be conducted—with restrictions—in close
proximity to Gentner’s fritillary and Cook’s lomatium by Medford District staff and cooperators.
Currently, per the Medford District Integrated Weed Management Plan and Environmental Assessment
(Bureau of Land Management 1998), Medford District uses only four herbicides: glyphosate, picloram,
dicamba, and 2,4-D. A new site-specific planning effort and analysis that tiers to the Vegetation
Treatments Using Herbicides on BLM Lands in Oregon FEIS and Record of Decision (Bureau of Land
Management 2010) would allow the use of additional herbicides for weed and other vegetation control.
18
Table 1. Estimated annual action amounts and cumulative five-year allowable action amounts for project
types on Medford District, Bureau of Land Management, starting October 1, 2014.
Project Type
Management Action (measure/yr)
A. Abandoned mine land
actions
Shaft or adit closures by heavy equipment (sites/yr)
B. Cultural resource
projects
Excavations (acres/yr)
B. Cultural resource
projects
Historic cemetery restoration (acres/yr)
C. Fuels management &
wildfire suppression
Estimated
Cumulative 5-yr
Annual Action Allowable Action
Amount
Amount
10
50
5
25
<1
5
Mechanical fuel reduction (acres/yr)
1,500
7,500
C. Fuels management &
wildfire suppression
Manual fuel reduction and hand piles (acres/yr)
2,500
12,500
C. Fuels management &
wildfire suppression
Prescribed burning (acres/yr)
3,500
17,500
C. Fuels management &
wildfire suppression
Fuels reduction by private along property lines (acres/yr)
2,500
12,500
D. Mining operations
Notice-level operations, average < 0.25 acres each
(acres/yr)
2
10
D. Mining operations
Plan-level operations, average < 2 acres each (acres/yr)
4
20
D. Mining operations
Mining occupancy reclamations (acres/yr)
<1
5
E. Quarry operations
New quarries or expansion of existing quarries (acres/yr)
<1
5
F. Range operations
Allotments (acres)
352,000
1,760,000
F. Range operations
AUMs (count)
13,416
67,080
F. Range operations
Fence construction and repair (miles/yr)
<1
5
F. Range operations
Forage enhancement planting (acres/yr)
10
50
F. Range operations
Water impoundment and spring box construction and
repair (features/yr)
5
25
G. Recovery actions
Manual control of woody vegetation(acres/yr)
50
250
Estimated
Cumulative 5-yr
Annual Action Allowable Action
Amount
Amount
Project Type
Management Action (measure/yr)
G. Recovery actions
Chemical control of woody vegetation with cut-stump,
hack-and-squirt, or direct-inject methods (acres/yr)
10
50
G. Recovery actions
Prescribed burning in listed plant habitat (acres/yr)
50
250
G. Recovery actions
Non-native invasive plant control with herbicides in and
immediately around listed plant sites (acres/yr)
50
250
G. Recovery actions
Seed or bulblet collection (sites/yr)
5
25
G. Recovery actions
Planting bulbs or seedlings (sites/yr)
10
50
H. Recreation/Admin
Facility construction or reconstruction (acres/yr)
50
250
H. Recreation/Admin
River Recreation Permits, commercial (permits/yr)
110
550
H. Recreation/Admin
River Recreation Permits, private (permits/yr)
1,100
5,500
H. Recreation/Admin
Misc. Recreation permits (permits/yr)
15
75
H. Recreation/Admin
Trail Maintenance (miles/yr)
100
500
H. Recreation/Admin
Campground, facility, utility site maintenance (acres/yr)
2,500
12,500
H. Recreation/Admin
Trail construction or reroutes (miles/yr)
10
50
I. Research, inventory, &
monitoring
Annual monitoring of Lomatium cookii (sites/yr)
5
25
I. Research, inventory, &
monitoring
Annual monitoring of Fritillaria gentneri (sites/yr)
65
325
J. Road maintenance &
construction
Road maintenance or repair (miles/yr)
2,500
12,500
J. Road maintenance &
construction
Road construction, including timber sale roads (miles/yr)
100
500
J. Road maintenance &
construction
Bridge construction (bridges/yr)
10
50
K. ROW permitting for
roads
FLPMA road maintenance (miles/yr)
1,200
6,000
K. ROW permitting for
roads
FLPMA new construction (miles/yr)
25
125
20
Estimated
Cumulative 5-yr
Annual Action Allowable Action
Amount
Amount
Project Type
Management Action (measure/yr)
K. ROW permitting for
roads
O&C Linear construction (miles/yr)
20
100
K. ROW permitting for
roads
O&C Non-linear construction (acres/yr)
25
125
K. ROW permitting for
roads
O&C Linear maintenance (miles/yr)
1,000
5,000
K. ROW permitting for
roads
O&C Non-linear maintenance (acres/yr)
50
250
L. ROW permitting for
other uses
Maintenance of existing waterlines, power lines, and
utilities (miles/yr)
40
200
L. ROW permitting for
other uses
New construction of waterlines, power lines, and utilities
(miles/yr)
30
150
L. ROW permitting for
other uses
Maintenance of communication sites (acres/yr)
18
90
L. ROW permitting for
other uses
Construction of communication sites (acres/yr)
1
5
L. ROW permitting for
other uses
Non-Linear permits for events (acres/yr)
1
5
L. ROW permitting for
other uses
Minimum Impact Permits for events, such as filming
river, equipment parking, etc (miles/yr)
1
5
M. Silvicultural treatments Pre-commercial thinning in managed stands (acres/yr)
1,500
7,500
M. Silvicultural treatments Pre-commercial thinning in natural stands (acres/yr)
1,000
5,000
M. Silvicultural treatments Maintenance/protection of existing stands (acres/yr)
2,800
14,000
M. Silvicultural treatments Fertilization (acres/yr)
400
2,000
M. Silvicultural treatments Pruning (acres/yr)
300
1,500
M. Silvicultural treatments Reforestation/planting (acres/yr)
700
3,500
1,000
5,000
M. Silvicultural treatments Maintenance/protection of new stands (acres/yr)
21
Project Type
Management Action (measure/yr)
N. Special forest product
harvesting
Boughs (lbs/yr)
N. Special forest product
harvesting
Christmas trees (trees/yr)
N. Special forest product
harvesting
Burls (lbs/yr)
N. Special forest product
harvesting
Edibles and Medicinal plants (lbs/yr)
N. Special forest product
harvesting
Floral greenery (lbs/yr)
N. Special forest product
harvesting
Mushrooms (lbs/yr)
N. Special forest product
harvesting
Whipstock/bolts/rails/fencing/post/poles (cubic feet/yr)
N. Special forest product
harvesting
Pulpwood/Roundwood/Sawtimber (cubic feet/yr)
N. Special forest product
harvesting
Fuelwood (green tons/yr)
N. Special forest product
harvesting
Mosses/Lichens (lbs/yr)
N. Special forest product
harvesting
Transplants (plants/yr)
N. Special forest product
harvesting
Seeds/Cones (bushels/yr)
O. Tree harvesting
Current Allowable Sale Quantity (million board feet and
acres/yr)
P. Watershed restoration
Estimated
Cumulative 5-yr
Annual Action Allowable Action
Amount
Amount
190,000
950,000
1,750
8,750
5,000
25,000
2,000
10,000
25,000
125,000
2,000
10,000
7,000
35,000
45,000
225,000
5,000
25,000
500
2,500
40
200
1,500
7,500
57 MMBF and
10,000 acres
285 MMBF and
50,000 acres
Meadow or floodplain restoration (acres/yr)
25
125
P. Watershed restoration
Stream structure placement (structures/yr)
200
1,000
P. Watershed restoration
Large fish passage culvert replacement or repair
(culverts/yr)
10
50
22
Estimated
Cumulative 5-yr
Annual Action Allowable Action
Amount
Amount
Project Type
Management Action (measure/yr)
P. Watershed restoration
Cross culvert replacement or repair (culverts/yr)
75
375
P. Watershed restoration
Road obliteration (miles/yr)
10
50
P. Watershed restoration
Road closure (miles/yr)
25
125
Q. Non-native invasive
plant control
Biological treatments (release sites/yr)
3
15
Q. Non-native invasive
plant control
Manual/mechanical treatments ( net acres/yr)
100
500
Q. Non-native invasive
plant control
Herbicide spot spraying (net acres/yr)
1,500
7,500
23
III. PROJECT DESIGN CRITERIA
Project Design Criteria (PDC) are conservation measures incorporated into a project to minimize or avoid
negative effects to listed plants and designated critical habitat. If a project area is outside of a listed
species’ range or does not include listed plant sites, suitable habitat, or designated critical habitat, then
PDC are not required. PDC may include modifying the prescription or activity method, changing the
timing of the action, establishing no-activity buffers around plant sites, or dropping portions of project
units. Additional discretionary PDC can be proposed during the interdisciplinary team process to further
reduce effects. BLM also has discretion to halt or modify projects, anywhere in the process, should
adverse impacts to federally listed species appear imminent. Implementation of prescribed PDC is
mandatory. If mandatory PCD cannot be incorporated for a project that has the potential to adversely
affect listed plants or critical habitat, then the project must be analyzed under separate consultation and
will not be covered under this programmatic BA.
For project decisions already made in compliance with the 2009-2013 BA, regardless of implementation
stage, incorporation of new PDC in this current BA is not required. In those cases, PDC in place under the
previous consultation will apply. New PDC found in this BA will be incorporated into new decisions after
September 30, 2013.
GENERAL PROJECT DESIGN CRITERIA
Project Notifications
Communication between project leaders, botanists, planners, and line officers is essential to completing
projects that are in compliance with this BA and associated Biological Opinion (BO). The following
notification procedures will contribute to this goal:
1. Project leaders will notify project botanists of the intent to initiate a project, allowing for
sufficient time to plan and complete clearance surveys.
2. Project planners and line officers will ensure that procedures clearing projects for
implementation include direct notification of all prescribed PDC to the project leader.
3. Project leaders will notify project botanists of the intent to begin the project, allowing for
sufficient time to plan and implement applicable PDC.
4. The project botanist will coordinate with the project leader to ensure that all parties—including
contractors and agency work crews—clearly understand all prescribed PDC, including the
locations of buffered plant sites and a description of how the sites are marked on the ground.
5. All parties will be notified that departures from clearance survey protocols and other PDC are
not permitted and could trigger emergency consultation.
Clearance Surveys
Unless otherwise noted, for activities in suitable habitat and within the known ranges of listed plant
species, qualified botany personnel must complete pre-disturbance surveys for listed plant species
following the protocols described in Appendix A. The project botanist is responsible for determining
whether a project is within a listed species’ range or near known occurrences. The project botanist will
review the BLM geographic biotic observations database (GeoBOB); the Natural Heritage Data System,
managed by the Oregon Biodiversity Information Center (ORBIC); and other relevant sources. Surveys
must occur prior to signing a decision document for an action. Effects of the action will be documented
in the NEPA document (CE, EA, or EIS). Once the decision is signed, the clearance surveys for that project
and those acres are valid, even if implementation does not occur immediately. Clearance surveys are
valid for 10 years following the year of survey. If any other BLM special status plant species are listed
under ESA during the life of this BA, then all existing survey data for those species are also valid for 10
years. If a project area is not within a listed species’ range or does not contain suitable habitat (as
determined by the project botanist), then clearance surveys are not required.
Inconclusive Surveys
If indeterminate vegetative leaves strongly resembling a listed species are found during a survey in
suitable habitat or near other occurrences of that species, then one or more of the following
discretionary PDC are recommended:
1. Buffering the vegetative plants through the life of the project or until a species determination is
made.
2. Changing the prescription or timing of the action to reduce potential impacts.
3. Monitoring of the site during and after the action, with documentation of impacts if a
determination is made that the affected species was listed.
Marking and Buffering
Prior to project implementation, listed plant sites (unique occurrences of plants, separated by > 300 feet)
must be marked on the ground using the Medford District’s standard marking protocol. Buffers of
various sizes are required for specific project types. Listed in the project-specific PDC below are
minimum distances used to protect the occupied site from various activities. For certain activities,
prescribed buffers may be larger than those listed, depending on site-specific recommendations made to
the line officer from the project botanist. Buffers are a set distance that extends from the perimeter of
the hypothetical polygon boundary of an occurrence. For a single plant, a buffer would extend the
prescribed distance from that point. For a patch of closely spaced plants, the buffer would extend from
a polygon that delineates the boundary of the patch. In cases where there is a scattered distribution of
patches of plants in suitable habitat, these patches may all be delineated and buffered as separate
occurrences, or they may be aggregated and buffered accordingly. This determination will be made by
the project botanist, with consideration for the project type, the spatial arrangement of patches, and the
separation distance between patches. Patches more than 150 feet apart will typically not be buffered as
a single patch unless the project involves heavy equipment.
Project Activities during Dormancy
Certain activities that are excluded from critical habitat or plant sites during the growing season may be
allowed during the dormancy period for the affected species, if the resulting activity is deemed neutral
or beneficial to the species. Use of heavy equipment will not be allowed within plant sites, regardless of
season. Relevant PDC will still apply as deemed necessary by the project botanist.
25
Use of Heavy Equipment
For all projects involving the use of heavy equipment, plant sites must be protected by a 100-foot radius
buffer. The use of heavy equipment is not permitted within this buffer. Heavy equipment includes
tractors, dozers, loaders, graders, excavators, cranes, skid steers, and similar equipment. Pick-up trucks,
ATVs, UTVs, and similar soft-wheeled vehicles may be permitted within a plant site on a limited basis in
dry conditions in the dormant season, if authorized by the project botanist.
All projects involving heavy equipment use near plant sites require pre-disturbance surveys for nonnative invasive plants. Project botanists will prescribe appropriate invasive plant treatments.
All heavy equipment used within Cook’s desert parsley critical habitat or near listed plant sites will be
cleaned prior to entering BLM lands. All dirt and vegetation must be washed from the equipment
exterior, including any unattached accessory equipment, such as augers, scoops, and blades.
Projects involving heavy equipment in Cook’s desert parsley critical habitat must be evaluated by a
hydrologist prior to implementation. The hydrologist will evaluate potential effects of the proposed
actions on site hydrology and prescribe appropriate PDC, which may include (1) seasonal entry
restrictions, (2) limiting the extent of disturbance, (3) temporary engineered solutions to reduce
compaction and erosion, and (4) restoration of vegetation and hydrologic function.
Emergency Exemptions
In emergency situations, PDC may be waived at the discretion of the decision-maker, if necessary to
protect public safety. USFWS will be notified of all such occurrences, and the Level 1 Team will
determine if emergency consultation is required. In the event that emergency consultation is initiated,
Medford District will act prudently and efficiently to complete consultation in a timely manner,
preferably within 6 months of the emergency action.
SPECIFIC PROJECT DESIGN CRITERIA
A. Abandoned Mine Land Actions



Conduct one-year surveys of suitable habitat for projects that involve excavation or use of heavy
equipment. Surveys are not required if a site is heavily disturbed and mostly free of vegetation.
Protect all plant occurrences with site-specific PDC prescribed by the project botanist in
cooperation with the project leader.
Follow general PDC for Use of Heavy Equipment.
B. Cultural Resources Projects

Conduct one-year surveys of suitable habitat for projects that involve excavation or use of heavy
equipment. Surveys are not required if a site is heavily looted or otherwise disturbed and mostly
free of vegetation.
26


Protect all plant occurrences with site-specific PDC prescribed by the project botanist in
cooperation with the project leader.
Follow general PDC for Use of Heavy Equipment.
C. Fuels Management and Wildfire Suppression
Private land fuels reduction
 Recommend to landowners to treat fuels outside of the March 15 to July 1 growing season,
when Gentner’s fritillary is mostly dormant or conduct one year of pretreatment surveys if
treating during the growing season.
 For treatments that include or are immediately adjacent to Cook’s desert parsley critical habitat,
encourage the implementation of PDC listed under Manual fuel reduction and hand piles, below.
Prescribed burning
 Conduct one-year surveys for broadcast burning.
 Restrict broadcast burning within plant sites to the dormant season.
 Conduct one-year surveys for pile burning. If there is a documented Gentner’s fritillary
occurrence within 1500 feet or indeterminate fritillary leaves within the pile burn area, then an
additional year of surveys will be performed.
 Pile material at least 25 feet away from plant sites.
 Rehabilitate pile burn scars with native seed and mulch when adjacent to listed plant sites or in
critical habitat.
Manual fuel reduction
 Conduct one-year surveys for manual thinning; however, if thinning will be followed by pile
burning in Gentner’s fritillary habitat, then follow survey requirement for pile burning under
Prescribed burning above.
 Maintain 25-foot no-treatment buffers around plant sites during the growing season. Treatment
inside of buffers is allowed in the dormant season.
 For Gentner’s fritillary, retain 40 % combined canopy coverage of trees and shrubs within 25foot plant site buffers.
Mechanical fuel reduction
 Conduct two-year surveys for Gentner’s fritillary.
 Follow general PDC for Use of Heavy Equipment.
Wildfire Suppression
 Account for public and firefighter safety prior to applying PDC. Line officers should waive PDC if
implementation would cause unnecessary risk. The Level 1 Team will determine if adverse
effects have resulted from waiving PDC, thereby triggering the need for emergency consultation.
 Resource Advisors/Environmental Specialists will advise Line Officers and Incident Commanders
to minimize impact to listed species and their habitat during suppression activities.
 Have updated plant site and critical habitat locations readily accessible to fire staff in GIS format
and in Resource Information Books.
27



Follow general PDC for Use of Heavy Equipment, whenever possible, after accounting for safety
concerns.
Coordinate with the Level 1 Team, who will inform USFWS of impacts to listed species. Medford
District will initiate emergency consultation if necessary as soon as possible following the event.
Rehabilitate fire lines and staging areas with native seed and mulch, where needed to reduce
non-native plant invasion, erosion, and other issues that could affect listed plant sites.
D. Mining Operations
Notice-level mining activities
 Notify the operator that a Plan of Operation is required when the proposed activities are within
designated critical habitat or when the proposed activities may affect listed plant sites.
Plan-of-operation mining activities
 Limit operations to reprocessing old mine tailings.
 Restrict project area access to existing official roads.
 Follow general PDC for Use of Heavy Equipment.
E. Quarry Operations



Conduct one-year Gentner’s fritillary surveys for expansion of existing rock quarries into suitable
habitat.
Conduct two-year Gentner’s fritillary surveys for development of new rock quarries.
See Use of Heavy Equipment.
F. Range Operations







Protect known occurrences if grazing is occurring within plant sites during the growing season.
Protection measures may include changing the timing of release or the grazing system, fencing
small populations, or modifying the allotment boundaries.
Allow grazing during the dormant season without surveys or protection measures.
Periodically monitor grazed sites.
For new allotments or renewals for which two-year surveys have not previously been completed,
conduct one-year surveys in suitable habitat. If there is a documented Gentner’s fritillary
occurrence within 1,500 feet of the allotment area, an additional year of surveys will be
performed in suitable habitat.
For renewal of allotments in which two-year surveys have previously been completed, conduct
one-year surveys around known plant sites only. Project botanists will define the extent of the
survey area based on past survey results, knowledge of the site, and knowledge of livestock use
patterns.
Conduct one-year surveys for construction of range improvements if the action has the potential
to affect listed plants.
Protect known sites during maintenance of existing improvements. Surveys are not required.
28

Consult with permittee and USFWS prior to augmenting existing populations or creating new
populations of listed plants within allotments.
G. Recovery Actions
Research or recovery collections
 Allow the collection of listed plants (seeds, bulbs, and plants) on Medford District only if the
collector has obtained a permit from USFWS and agrees to coordinate all actions with BLM.
 Allow collections of listed plants only for the purposes of research or recovery actions.
 Report all collection activities annually to USFWS.
Augmentation of existing populations or creation of new populations
 Coordinate all population creation and augmentation activities with USFWS.
 Report all population creation and augmentation activities and subsequent monitoring results
annually to USFWS.
Habitat improvement
 For projects that involve manual fuel removal, follow PDC for C. Fuels Management and Wildfire
Suppression, subpart Manual Fuel Treatments.
 For projects that involve prescribed fire, follow PDC for C. Fuels Management and Wildfire
Suppression, subpart Prescribed Fire.
 For projects that involve the use of herbicides within and around listed plant sites:
o The actions must be allowable under Medford District’s most current NEPA document
that covers the use of herbicides to treat vegetation.
o Treat non-native invasive plants and native woody vegetation primarily during the
dormant season using post-emergent herbicides applied by backpack sprayers, spray
bottles, wicks, and other selective equipment and techniques (e.g., cut-stump, hack-andsquirt, direct inject).
o Use post-emergent herbicides during the growing season only if adequate protection of
listed plants can be assured through the use of highly selective techniques or protective
measures, such as covering listed plants with tarps or buckets during application.
o Use pre-emergent herbicides only in controlled experiments coordinated with USFWS.
o Monitor the effects of all herbicide use for a period of two growing seasons and report
findings annually to USFWS.
H. Recreation Projects and Administrative Site Maintenance





Conduct one-year surveys for construction or expansion of trails, campgrounds, parking lots,
toilets, or other recreational facilities.
Follow general PDC for Use of Heavy Equipment.
Project botanists will cooperate with project leads to prescribe site-specific protection measures
to protect plant sites from project actions.
Surveys are not required for maintenance activities, sign installation, fence installation, hazard
tree falling, and closing illegal trails.
For projects that involve the use of herbicides near listed plant sites, apply the following PDC:
29
o
o
The actions must be allowable under Medford District’s most current NEPA document
that covers the use of herbicides to treat vegetation.
Treat vegetation only during the dormant season (of the listed plant species) using postemergent herbicides. The use of pre-emergent herbicides for recreation purposes is not
covered.
I. Research and Monitoring Actions


Balance the value of research or monitoring data against potential site impacts associated with
repeated site entry, particularly for intensive plot designs. Adjust designs and schedules
accordingly.
Report monitoring data and research results annually to USFWS.
J. Road and Bridge Maintenance and Construction
New construction
 Conduct one-year surveys along the proposed corridor. If there is a documented Gentner’s
fritillary occurrence within 1500 feet of the corridor or indeterminate leaves are located, an
additional year of surveys will be performed.
 New road construction is not allowed within Cook’s desert parsley critical habitat.
 Follow general PDC for Use of Heavy Equipment.
 Protect known plant sites by aligning road prisms to maintain 100-foot buffers.
Maintenance
 Surveys are not required.
 Follow general PDC for Use of Heavy Equipment.
 Protect all plant occurrences with site-specific PDC prescribed by the project botanist in
cooperation with the project leader.
K. ROW Permitting for Roads
New construction for FLPMA and O&C permits
 Follow PDC listed above for Road and Bridge Maintenance and Construction, subpart New
construction.
Road maintenance for FLPMA and O&C permits
 Follow PDC listed above for Road and Bridge Maintenance and Construction, subpart
Maintenance.
L. ROW Permitting for Other Uses
Utility and communication site construction
 Conduct one-year surveys along the proposed corridor or site.
 New construction is not allowed within suitable dispersal or germination habitat for Cook’s
desert parsley.
 Follow general PDC for Use of Heavy Equipment.
30

Protect known plant sites by aligning utility or site footprints to maintain 100-foot buffers.
Utility and communication site maintenance
 Surveys are not required.
 Follow general PDC for Use of Heavy Equipment.
 Protect all plant occurrences with site-specific PDC prescribed by the project botanist in
cooperation with the project leader.
ROW Permits for events or other uses
 Conduct one-year surveys along the proposed use corridor or site, except minimum impact
permits, for which surveys are not required.
 Do not issue event permits in suitable dispersal or germination habitat for Cook’s desert parsley
with the exception of minimum impact permits.
 Protect all plant occurrences with site-specific PDC prescribed by the project botanist in
cooperation with the project leader.
M. Silvicultural Treatments










Conduct one-year surveys for all silvicultural projects.
No reforestation in suitable dispersal or germination habitat for Cook’s desert parsley.
Do not plant trees within 100 feet of plant sites.
Do not apply fertilizer within 25 feet of plant sites.
Do not trap gophers within 25 feet of plant sites.
Restrict manual thinning and brushing within 25 feet of plant sites to the dormant season.
For Gentner’s fritillary, retain 40 % combined canopy coverage of trees and shrubs within 25foot plant site buffers.
Pile material from thinning, brushing, and pruning at least 25 feet away from plant sites.
For mechanical work, follow general PDC for Use of Heavy Equipment.
For non-native invasive plant treatments with herbicide, follow PDC for Non-native Invasive Plant
Control. Other chemical site preparation is not permitted.
N. Special Forest Product Harvesting




Surveys are not required.
When possible, send harvesters to areas that have previously been cleared for listed plants.
No burl harvesting within 100 feet of known occurrences or in suitable dispersal or germination
habitat for Cook’s desert parsley.
Project botanists must review firewood cutting areas and commercial permits for special forest
product harvesting and assign site-specific PDC to protect plant sites and critical habitat. .
Firewood Permits: No firewood permit gathering allowed within known occurrences. Road
segments close to known occurrences may need to be closed to prevent incidental impacts.
31
O. Tree Harvesting









Conduct two-year surveys, except for salvage sales and incidental tree harvests under permit,
which only require a one-year survey for both commercial and non-commercial harvests.
No tree harvest activities in suitable dispersal and germination habitat for Cook’s desert parsley.
Permit felling of hazard trees; however, the trees must be left on site unless they can be
accessed by a self-loader from a roadway.
Exclude harvest activities, including falling, skidding, and yarding, from within 25 feet of plant
sites.
For Gentner’s fritillary, retain 40 % combined canopy coverage of trees and shrubs within 25foot plant site buffers.
Do not locate anchor trees within plant sites.
Do not burn landing slash within 100 feet of plant sites.
Construct landings at least 300 feet from plant sites. Permit use of previously existing landings
when more than 100 feet away from plant sites.
Realign new proposed logging road corridors, truck turn-arounds, and staging areas to maintain
100-foot buffers. Permit use of existing roads, even when located less than 100 feet from plant
sites.
Follow general PDC for Use of Heavy Equipment.
P. Watershed Restoration
Road closures
 No surveys are required for actions within the existing road prism.
 Follow general PDC for Use of Heavy Equipment.
Road obliteration
 Conduct one-year surveys if the action will involve disturbance of intact natural habitat outside
of the road prism; otherwise, no surveys required.
 Follow general PDC for Use of Heavy Equipment.
Cross-drainage culvert replacement or repair
 No surveys are required for actions within the existing road prism; otherwise, conduct one-year
surveys.
 Follow general PDC for Use of Heavy Equipment.
Stream structure and culvert placement/repair
 Conduct one-year surveys if the action will involve disturbance of intact natural habitat outside
of the stream channel; otherwise, no surveys required.
 No tree falling within plant sites.
 Follow general PDC for Use of Heavy Equipment.
Meadow and floodplain restoration
 For projects that involve manual woody vegetation removal, follow PDC for C. Fuels
Management and Wildfire Suppression, subpart Manual Fuel Treatments.
32



For projects that involve prescribed fire, follow PDC for C. Fuels Management and Wildfire
Suppression, subpart Prescribed Fire.
Do not plant trees or shrubs within 100 feet of plant sites.
No tree falling within plant sites.
Q. Non-native Invasive Plant Control
Roadside herbicide application
 Surveys are not required within existing road prisms.
 Follow Medford District’s most current NEPA document that covers the use of herbicides to treat
vegetation.
 When spraying within 1500 feet of known plant sites, treat only during the dormant season or
otherwise protect listed plants by:
o Instructing contract crews on identification of listed plants that may occur within project
areas.
o Maintaining a minimum 50-foot buffer around known plant sites.
o Limiting spraying to when there is no measurable wind.
o Using only spot treatments (no broadcast treatments).
o Using selective equipment (backpack sprayers, hand bottles, wicks) and techniques (cutstump, hack-and-squirt, direct inject, foliar spot spray).
Herbicide application in natural communities and plantations
 Surveys are not required when work is being conducted by trained BLM botanists and
cooperators; however, one-year surveys are required for treatments performed by contract
weed crews (excluding direct-inject and hack-and-squirt methods), unless the workers will be
accompanied by a trained botanist.
 Follow Medford District’s most current NEPA document that covers the use of herbicides to treat
vegetation.
 For treatments within or immediately adjacent to plant sites:
o Work will be supervised by a trained BLM botanist with weed treatment experience.
o Treat primarily during the dormant season using spot treatments of post-emergent
herbicides applied by backpack sprayers, spray bottles, wicks, and other selective
equipment and techniques (e.g., cut-stump, hack-and-squirt, direct inject).
o Use post-emergent herbicides during the growing season only if dormant season
treatments are not effective and when there is no measurable wind. Protect listed
plants by implementing these types of protective measures:
 Within the treatment site, visibly mark all listed plants or patches with pin flags
or similar markers.
 Use only spot treatments (no broadcast treatments).
 Use selective equipment (backpack sprayers, hand bottles, wicks) and
techniques (cut-stump, hack-and-squirt, direct inject, foliar spot spray).
 In the case of foliar spot treatments, use spray shields or cover listed plants with
tarps or buckets during application.
33
o
o
Use pre-emergent herbicides only in controlled experiments coordinated with USFWS
until effects are fully known and full-scale implementation is approved by USFWS.
Monitor the effects of all herbicide use for a period of two growing seasons and report
findings annually to USFWS.
34
IV. ENVIRONMENTAL BASELINE
COOK’S LOMATIUM and DESIGNATED CRITICAL HABITAT
Cook’s lomatium was federally listed as endangered in 2002 (Federal Register 67:68004-68015). Critical
habitat was designated in 2010 (Federal Register 75:42490-42570). Recovery actions were detailed in
2013 in the Recovery Plan for Rogue and Illinois Valley Vernal Pool and Wet Meadow Ecosystems (U.S.
Fish and Wildlife Service 2012).
A perennial forb in the carrot family (Apiaceae), Cook’s lomatium grows 15-50 cm tall, from a slender,
twisted taproot. Leaves are smooth, finely dissected, and strictly basal (growing directly above the
taproot on the ground, not along the stems). One to four groups of clustered, pale yellow flowers
produce boat-shaped fruits 8-13 mm long with thickened margins. The taproot can often branch at
ground level to produce multiple stems. The branching taproot distinguishes Cook’s lomatium from
Bradshaw’s lomatium (Lomatium bradshawii) that is indigenous to wet prairies from southern
Willamette Valley, Oregon to southwest Washington, and foothill lomatium (L. humile) that is found in
vernal pools in northern California (Kagan 1986).
Flowering stems emerge from a rosette of leaves in late February, with flowers appearing in mid-march
and blooming until mid-May. As with many Lomatium species, the earliest flowers are usually
staminate, while the later umbels have both staminate and hermaphroditic flowers. Plants that produce
only one umbel produce few, if any, seeds (Kaye and Kirkland 1994).
The distribution of the species is disjunct, occurring in the Agate Desert of Jackson County on the edge of
vernal pools and 40 miles to the southwest in the Illinois Valley in seasonally wet grassy meadows, oak
woodlands, and serpentine meadow and shrub habitats. The species is known from 13 occurrences in
the Agate Desert and 24 occurrences in the Illinois Valley. The largest occurrence is at French Flat ACEC
which is estimated to have 132,615 plants (Pfingsten et al. 2012). No populations have ever been found
between the Illinois Valley and Agate Desert populations either along the Rogue River or in alluvial areas
along the lower Applegate River. Most of the habitat between these populations is on non-federal lands,
and have been heavily modified by rural development. Undiscovered populations between the Agate
Desert and the Illinois Valley occurrences are unlikely.
The habitats of the species are slightly different between the Agate Desert and Illinois Valley sites. In the
Agate desert, its habitat is along the margins and bottoms of vernal pools. These pools, within swale and
mound topography, form during the winter rains in shallow clayey-gravelly soils over an impervious
hardpan. The Illinois Valley habitats are mostly alluvial silts and clays within serpentine soils. The soils
consist of floodplain bench deposits that also have a clay hardpan 60-90 cm below the soil surface. This
creates seasonally wet areas similar to vernal pools in the Agate Desert, but lacks the swale and mound
topography. The Illinois Valley sites are alluvial in nature within serpentine substrates and are within the
serpentine valley bottom communities. The meadows are dominated by California oat-grass (Danthonia
californica) and occur within Oregon white oak – ponderosa pine/Jeffery pine (Pinus jeffreyi) savanna.
An open shrub layer comprised of wedge-leaf ceanothus and manzanita is interspersed with native and
35
introduced grasses and herbs. One Illinois Valley site occurs in a dry Oregon white oak savannah on a
shallow slope.
Cook’s lomatium habitat in the Illinois Valley is threatened by rural development, illegal dumping, and
recreational use. Both the French Flat and Rough and Ready Creek sites have been occasionally
damaged by OHV use and illegal dumping, although the use of barricades and law enforcement efforts
have successfully reduced impacts in recent years (R. Showalter, personal communication, 2013).
Mining activities threaten Cook’s lomatium populations and critical habitat. Placer gold mining has
already restricted the population at French Flat and permanently altered much of the natural hydrologic
patterns through the meadows. Some of the French Flat subpopulations monitored and discussed in this
report are located on BLM managed lands adjacent to placer mines owned and operated by a local
resident. A proposed mining plan filed in 1993 would involve destruction of a significant portion of this
subpopulation. Because of the ACEC status, BLM regulations require the operator to complete a Plan of
Operations prior to mining. In such cases, BLM has the ability to mitigate actions to protect listed
species.
Long-term Demographic Monitoring
Annual monitoring of three populations (Indian Hill, Rough and Ready Botanical Wayside, and French
Flat ACEC) on BLM lands since 1994 has revealed an overall stable population with increases at some
sites and decreases at others (Pfingsten et al. 2012). For example, the Indian Hill population increased
from 2007 to 2011, and then decreased in 2012. Similarly, the French Flat South population increased
each year from 2007 to 2010, and then declined in 2011 and 2012. French Flat Middle, in contrast, has
steadily declined since 2009, reaching in 2012 an all-time low since monitoring began in 1993. There
have been large variations in population densities and reproduction over time and among the three
sites.
Cook’s Lomatium Outlook
In the Rogue Valley, most populations are small and some are experiencing steady declines (U.S. Fish and
Wildlife Service 2012). The exception is a population of approximately 500,000 individuals observed in
2001 on private property in White City (Oregon Natural Heritage Information Center 2008); however, the
long-term protection of these plants is not assured.
The future of Cook’s lomatium in the Illinois Valley appears more secure than in the Rogue Valley,
because Illinois Valley occurrences appear more robust and are protected on public lands. Nonetheless,
population viability analyses conducted at French Flat South and French Flat Middle populations predict
a high probability (98% and 78%, respectively) of a 50% population decline in the next 20 years. Given
that possibility, Medford District and the Institute for Applied Ecology continue to evaluate the potential
to establish new populations or augment existing populations of Cook’s lomatium through direct seeding
and transplanting of greenhouse-grown seedlings. Monitoring results suggest that the optimal approach
would use a combination of direct seeding and transplanted plugs to establish large numbers of plants
while simultaneously establishing bigger plants that will reproduce quickly (Kaye et al. 2012).
36
To further help in the recovery of this species, Medford District has also proposed the designation of
Reeves Creek ACEC in the Illinois Valley. Although small (88 acres), this proposed ACEC would include an
important population of Cook’s lomatium growing on a non-serpentine dry oak woodland that contrasts
sharply with the wet meadow habitats of French Flat ACEC. Medford District is also planning habitat
improvement projects (e.g., invasive plant treatments, reducing encroaching woody vegetation in wet
meadows) at French Flat ACEC and Indian Hill. Finally, starting in 2014, a cooperative research project
with Oregon Parks and Recreation Department and the Institute for Applied Ecology will investigate
techniques for controlling invasive grasses in Cook’s lomatium habitat.
Species recovery on BLM may further be aided by designation of critical habitat in 2010 (Federal Register
Vol. 75 (139): 42490-42570), which included BLM lands in the Illinois Valley. No critical habitat was
designated on BLM land in the Rogue Valley. The final rule describes the primary constituent elements
(PCEs) of the Illinois Valley critical habitat:




Wet meadows in oak and pine forests, sloped mixed-conifer openings, and shrubby plant
communities that are seasonally inundated and support native plant populations and are a
minimum of 20 acres in size.
The hydrologically and ecologically functional system of streams, slopes, and wooded systems
that surround and maintain seasonally wet alluvial meadows underlain by relatively undisturbed
ultramafic soils within the greater watershed.
Silt, loam and clay soils that are ultramafic and nonultramific alluvial origin, with a 0-40 percent
slope.
No or negligible presence of competitive, nonnative invasive plant species. Negligible is defined
as the minimal level of nonnative plant species that will still allow Cook’s lomatium to continue
to survive and recover.
GENTNER’S FRITILLARY
Gentner’s fritillary was federally listed as Endangered in 1999 (Federal Register 64:69195-69203). A final
recovery plan was published in 2003 (U.S. Fish and Wildlife Service 2003). Critical habitat has not been
designated.
Gentner’s fritillary is a perennial herb arising from a fleshy bulb that has a wide axis and is flattened
vertically in older specimens, with several large scales surrounded by numerous small rice-grained
bulblets. Non-flowering plants vastly outnumber flowering plants in natural populations, and are
recognizable only by their single ovate to lanceolate basal leaf that is indistinguishable from several
other common related fritillaries. The species has dull to bright, red- to maroon-colored flowers mottled
or streaked with yellow. The flowers are solitary, or in bracted racemes, 1 - 5 (rarely more) on long
slender pedicels. The 25-40 mm bell-shaped perianth has segments that bend more or less outward, but
are not strongly recurved; the nectary glands extend about ½ its length. The style is divided about half of
its length, with widely spreading branches. The whorled, lanceolate to linear leaves on the flowering
stalks, are 70-150 mm in length.
37
Vegetative leaves appear in late February and early March (Gamon 1984, Knight 1991). Most
occurrences of this species contain few flowering plants. Blooms have been documented from early
April through late May, and as late as June 15, depending on precipitation, temperature, elevation, and
herbivory. The blooms can persist into June, often wilting on the stems. Fruits, if produced, are
persistent into early July and can be differentiated from the common scarlet fritillary (Gilkey 1951).
This rare lily is endemic to the Rogue River basin in Jackson and Josephine County, and in the upper
drainages of the Klamath River basin in the Cascade-Siskiyou National Monument, Jackson County,
Oregon. The species also occurs on BLM and State lands in Siskiyou County, California about 2 miles
south of the Oregon border and CSNM. Nearly 200 occurrences are now documented on the Medford
District, with a few additional occurrences known from National Forest lands, county lands, and private
lands near Jacksonville and Grants Pass.
Gentner’s fritillary is known from a wide variety of habitats and soil types across its range. The recovery
plan identifies over 25 soil types and 16 different plant communities that this species can occupy.
Because of the extreme variation in habitats, the attempt to develop habitat prediction models has not
proved useful. This species prefers situations where it can receive at least partial light (Brock and
Callagan 2002). It is rarely found under a dense conifer canopy, although a few populations along
riparian ecotones have a high cover of mixed conifer and deciduous trees. Plants have been found
growing on the edges of grasslands and chaparral and in partially open mixed-evergreen forest and
woodland openings. The species is most often found in forest ecotones or transitional areas, especially
along ridgelines or aspect changes.
Gentner’s fritillary frequently grows in close proximity to scarlet fritillary (Fritillaria recurva) and
sometimes close to checker lily (F. affinis), all related species. Gentner’s fritillary can be easily confused
with scarlet fritillary. While all three may occur together, checker lily tends toward the moist shady
habitats, scarlet fritillary toward the dry exposed habitats, and Gentner’s fritillary occurs fully within the
amplitude of the other two species (Brock and Callagan 2002).
The elevations of known occurrences range from 600 feet, near the Rogue River, to nearly 5,000 feet
near Soda Mountain, and sites occur on nearly all aspects if the right habitat conditions are present.
Gentner’s fritillary does not appear to be an early colonizer of recently disturbed habitat, nor a latesuccessional species found in old growth or closed-canopy forests. The species appears to be long-lived
and its relationship with disturbance is not clear, although it exists in communities that have had fairly
frequent fire return intervals historically. Evidence suggests that the species is adapted to fire, especially
later in the summer when the plants are dormant.
Gentner’s fritillary is most likely pollinated by hummingbirds (MacFarlane, personal communication
1980), and by andrinid and halictid bees (Donham 2002). Several researchers (Donham 2002; Amsberry
and Meinke 2002; Kaye, personal communication 2003) have documented hummingbirds visiting
Gentner’s fritillary. Foraging areas of a hummingbird are reported to be about 2.5 miles, which is likely
the breeding distance for Gentner’s fritillary (A. Robinson, personal communication 2002).
Reproduction is mostly asexual. Small plants often arise from near the base of larger flowering plants,
presumably from underground clonal bulblets formed from a mother bulb. Amsberrry and Meinke
38
(2002) documented between 10 – 200 rice-grain-sized bulblets attached to mature mother bulbs on 25
excavated plants. The percentage of plants that set fruit is very low (Knight 1991) and fruits tend to
abort or not contain viable seed (Guerrant 1991). Both Gentner’s fritillary and the common scarlet
fritillary have low pollen germination rates (Amsberry and Meinke 2002). However, recent fertility
studies by the Oregon Department of Agriculture have found that Gentner’s fritillary is not sterile and
produces seed best when pollen from a separate distinct population is used (Amsberry and Meinke
2007). Seed production has been observed in the Brushy Creek and Pilot Rock populations (K. Amsberry,
personal communication 2013). Successful natural sexual reproduction is likely episodic, perhaps
occurring only in certain climate conditions and if pollen from other populations is able move to a
population and fertilize flowers. Pollinator movement and the distance between populations may limit
sexual reproduction.
Long-term Demographic Monitoring
Long-term monitoring of at the Pickett Creek fritillary site from 2002 to 2012 reveals that population size
has remained mostly stable, but has fluctuated considerably, from a low of 6,715 plants to a high of
17,684 (Table 2) (Giles-Johnson et al. 2012). Number of flowering plants has generally declined over the
same period. Most Gentner’s fritillary plants at Pickett Creek are growing from very small bulblets, while
plants of larger size classes and flowering stages are much less frequent. In all years, the majority (>97%)
of the plants in the population have been vegetative, while fewer than 3% produce flowers. In 2012, only
0.5% of the plants observed in the density plots were flowering, which is the lowest estimate across all
years. Because flowering plants do not produce seed at this site, the decline in the number of flowering
plants is not expected to have an effect on population trend. However, if sexual reproduction is restored
to the site by crossing to or augmenting with bulbs from other populations, then this loss of flowering
could limit reproductive potential.
Modeling Demographic Response to Climate Variables
Institute for Applied Ecology found that warmer winter temperature positively affected the number of
vegetative and flowering plants at Pickett Creek (Giles-Johnson et al. 2012). In addition, vegetative plants
were positively affected by a dry fall, whereas flowering plants were positively affected by intermediate
levels of precipitation. Thus, a dry fall followed by warm winter temperatures is associated with
increased vegetative Gentner’s fritillary, with flowering promoted by a fall precipitation of around 2
inches, followed by a warm winter.
Long-term Population Monitoring at 57 Sites
Since 2008, BLM has been annually monitoring the number of flowering plants occurring at 57 sites. In
2012, there was a mean of 27.0 flowering plants per site, up from 21.2 plants in 2011, continuing a 5year upward trend (Siskiyou Biosurvey 2013). However, a majority of sites (67%) had fewer than 10
flowering plants, including 22 sites with zero flowering plants. Threats observed during monitoring
include (1) deep litter accumulation, (2) leaf and flower herbivory by deer and insects, (3) encroaching
conifer cover, (4) non-native invasive plants, (5) off-highway vehicle traffic, and (6) road and trail
maintenance.
39
Table 2. Estimated population size of Gentner’s fritillary at Picket Creek, Medford District, BLM, 20022012.
Year
Estimated Vegetative
Estimated Flowering
Total Estimated Population
2002
13,294
272
13,566
2003
17,344
340
17,684
2004
13,337
183
13,519
2005
12,682
230
12,912
2006
6,626
89
6,715
2007
10,561
72
10,634
2008
8,772
196
8,968
2009
11,887
162
12,049
2010
14,803
123
14,926
2011
12,737
153
12,890
2012
13,337
64
13,400
Gentner’s Fritillary Outlook
Because of small population sizes, a lack of within-population variation, and widely scattered
populations, viability may be in question for some Gentner’s fritillary occurrences. As a result, the
recovery plan calls for augmentation of populations with nursery grown plants. Transplanting bulblets
collected from donor mother bulbs into the greenhouse for several years and growing and harvesting
bulbs for transplanting back into the field has proved to be a viable way to increase population sizes
(Amsberry and Meinke 2005, Amsberry and Meinke 2007).
To further help in the recovery of this species, Medford District has proposed the designation of Cobleigh
Road ACEC and Pickett Creek ACEC, each of which would include important Gentner’s fritillary
occurrences and habitat. Cobleigh Road would encompass over 1,000 acres of oak woodland and dry
conifer forest and include a population augmentation site. Pickett Creek would be only 89 acres in size,
but would also include a population augmentation site as well as long-term demographic monitoring
plots. Given the success of population augmentation and creation, and the additional management and
protection emphasis for Gentner’s fritillary on BLM ACECs, the projected trend for this species is positive.
LARGE-FLOWERED WOOLLY MEADOWFOAM
Large-flowered woolly meadowfoam is a delicate annual in the meadowfoam, or false mermaid, family
(Limnanthaceae). The plant grows 5-15 cm tall, with 5-cm leaves divided into 5 to 9 segments. The
stems and leaves are sparsely covered with short, fuzzy hairs. The flowers, and especially the calyx
(outer whorl of floral parts), are densely covered with woolly hairs. Each of the 5 yellowish to white
40
petals is relatively long compared to other meadowfoams, 6-13 mm, and has 2 rows of hairs near its
base.
Large-flowered woolly meadowfoam was federally listed as endangered in 2002 (Federal Register
67:68004-68015). As with Cook’s lomatium, critical habitat was designated in 2010 (Federal Register
75:42490-42570) and recovery actions were detailed in 2013 in the Recovery Plan for Rogue and Illinois
Valley Vernal Pool and Wet Meadow Ecosystems (U.S. Fish and Wildlife Service 2012).
The current range of the species extends along the floor of the Rogue River from south of Shady Cove,
down river to Gold Hill, along the historical floodplain of the Rogue River. Mapped occupied habitat for
this species in the Agate Desert totals approximately 500 acres. Like Cook’s lomatium in the Agate
Desert, large-flowered woolly meadowfoam is associated with vernal pools in swale and mound
topography, except that large-flowered woolly meadowfoam grows on the wetter inner fringes of vernal
pools and is not known from wet meadows. One area with vernal pools on federal lands (Table Rocks
ACEC) has been extensively surveyed and does not have this species, even though it is within a few miles
of existing occurrences and contains populations of a closely related species Limnanthes pumila spp.
pumila. All suitable habitats on BLM lands have been surveyed without success.
Only 18 occurrences of large-flowered woolly meadowfoam are known, on fewer than 500 acres.
Numbers of plants can fluctuate dramatically from year to year, but probably do not exceed 100,000
plants in a typical year. Critical habitat was designated on 1,500 acres, only 10% of which is in federal
ownership (on Bureau of Reclamation).
Large-flowered Woolly Meadowfoam Outlook
Development and road construction in the Agate Desert has continued since this species was listed in
2002. Additional threats include non-native annual grasses, OHV damage, herbicide spraying, and poorly
managed livestock grazing (U.S. Fish and Wildlife Service 2012). Because of the existing threats to
habitat, and the small amount of occupied habitat, the current trend for the species is downward.
41
V. EFFECTS OF THE PROPOSED ACTIONS
The following effects apply to Gentner’s fritillary and Cook’s lomatium and its critical habitat. Largeflowered woolly meadowfoam has not been documented on BLM lands, despite years of surveys, and
the presence of what appears to be suitable habitat; therefore, proposed actions will have no effect on
that species.
DIRECT AND INDIRECT EFFECTS
For the listed plants analyzed in this BA, direct effects are the physical disturbance to individual plants
and populations that affect growth, survival, and reproduction. Indirect effects are changes in habitat or
environment that can affect the plants over time, such as increases or decreases in competition from
other plants, the introduction of noxious weeds, or increasing light or available precipitation to plants
from thinning. Effects may be negated (no effect) or strongly reduced (not likely to adversely affect—
NLAA) by implementing PDC.
Effect to Listed Plants
Pre-disturbance surveys from 2008-2012 suggest that there is a low probability of unmapped listed
plants occurring within a project area (Table 3). Furthermore, the prescribed PDC have effectively
eliminated or minimized direct and indirect effects to insignificant levels for listed plants (Table 4). From
2009 to present, the suite of management activities covered by the programmatic BA resulted in very
few impacts to listed plants. Similarly, with the PDC prescribed herein, Medford BLM management
actions are expected to maintain or improve species’ status in the future. Pre-disturbance surveys in
suitable habitat, site buffers, and seasonal restrictions are the primary PDC prescribed for most project
types. PDC reduce adverse effects such that a NLAA determination is made for most actions.
Table 3. Annual pre-disturbance survey acres and number of new rare plant sites discovered on
Medford District, BLM, 2008-2012.
Year
Acres Surveyed
New Gentner’s fritillary sites
New Cook’s lomatium sites
2008
38,518
4
0
2009
44,009
3
0
2010
64,719
24
0
2011
34,287
7
0
2012
27,948
8
0
Total
209,481
40
0
Direct physical ground disturbance from bulldozers, skidders, excavators, and other equipment
associated with timber harvesting, silvicultural treatments, fuel reduction, road construction, mining
42
operations, recreational development, and watershed restoration can have adverse effects to listed
plants. Plants can be crushed, broken, dug up, buried and killed, and their growing substrate can be
compacted, displaced, or removed. The implementation of PDC will remove these direct effects. Physical
impacts from humans walking through listed plant populations during the growing season, in the course
of authorized BLM activities (e.g., timber harvesting, fuels reduction, silvicultural practices, weed
treatment, recreation, monitoring, and research), can also damage above-ground plant structures
including flowers, but population-level effects are minimal because, with implementation of PDC, the
below-ground perennial structures remain protected.
Ground disturbance from timber sales, fuels projects, watershed restoration, road construction, and
other projects can fragment habitat and facilitate the introduction and movement of noxious weeds such
as yellow starthistle, dyer’s woad, Scotch broom, false brome, and Canada thistle, to name a few. Weeds
can have an indirect effect by competing with listed plants for light, space, water, and nutrients.
Recently, monitoring for Cook’s lomatium has seen an increase in non-native annual grasses in occupied
habitat (Kaye and Thorpe 2007). Populations of Gentner’s fritillary have documented competition from
yellow starthistle and Scotch broom in the Jacksonville woodlands and the Jacksonville Cemetery
(Amsberry and Meinke 2005). Currently, approximately 10,000 acres on Medford District are infested by
noxious weeds, with no reliable estimates of other non-native invasive plants. Existing infestations will
continue to spread along roads and in other areas of disturbance. Non-native invasive plants are
expected to increase in abundance and distribution.
The modification of listed plant habitat from actions like partial thinning of the canopy, that increase
solar radiation and available precipitation, can have a beneficial effect for listed species over time. These
activities likely mimic the role that wildfire historically played in these habitats by periodically opening
the canopy. Based on existing data from known populations, it appears that partial light (40 - 60 percent
canopy cover) is optimum for species like Gentner’s fritillary. However, the removal of all understory
vegetation led to a short-term increase in browsing of Gentner’s fritillary flowering plants by deer in the
Jacksonville Woodlands. Shrubs and saplings can provide some protection of flowering plants from deer
that seem to favor fritillary flowers. Cook’s lomatium and large-flowered woolly meadowfoam similarly
can benefit from activities that reduce competition from encroaching woody vegetation. Tree and shrub
encroachment into wet meadows supporting Cook’s lomatium was historically regulated by periodic
wildfires. The removal of encroaching trees and shrubs would benefit this species, as this plant prefers
full sun.
Project activities that reduce fuel loads can have a beneficial effect on listed plants. Because of high fuel
loads resulting from decades of fire suppression, wildfires can now burn with more severity. High
sustained heat can kill bulbs and roots that may have survived a less intense fire. Soil chemistry and
structure and below-ground organisms may also be altered in ways that negatively affect listed plants.
The effects of severe fire on rare plants were observed in the Biscuit Fire that occurred in southwest
Oregon in 2002, burning through several populations of the rare Umpqua swertia (Frasera umquaensis)
(Kaye 2005). In areas where the fire burned with light to moderate severity, the populations survived
and benefited from the open habitat created by the fire. In areas where the fire was more severe,
43
Table 4. Summary of direct and indirect effects of projects on listed plant species, given implementation
of prescribed PDC.
Project Type
Direct Effects
Indirect Effects
A. Abandoned
mine land actions
Implementation of PDC results in
no direct effects
Implementation of PDC results in no indirect effects.
B. Cultural
resource projects
Implementation of PDC results in
no direct effects.
Implementation of PDC results in no indirect effects.
C. Fuels
management and
wildfire
suppression
Implementation of PDC reduces
direct effects to an insignificant
level. Individual Gentner’s
fritillary plants could be
disturbed (above ground portion)
but not likely killed. Seasonal
restrictions on broadcast burning
are not likely to hurt
underground bulbs/roots and
should improve habitat. Two year
surveys of suitable habitat will
document existing populations
for Gentner’s fritillary. PDC will
eliminate direct effects from pile
burning.
Canopy cover modification (increased light),
increased temperature, and decreased humidity can
indirectly affect populations. Increase in weeds as a
result of disturbance can increase competition with
listed plants. Fuels treatments, thinning and burning
can improve habitat in the long term.
D. Mining
operations
Implementation of PDC results in
minimal direct effects.
Documented listed plants in
existing claims will be protected.
Surveys for plan-level mining will
document and protect plants.
Indirect effects from changes in hydrology and
subsurface drainage; increases in noxious weeds
from disturbance. Any canopy removal associated
with claims could change light regimes and
microclimate of adjacent populations.
E. Quarry
operations
Implementation of PDC results in
no direct effects.
Implementation of PDC results in no indirect effects.
F. Range
operations
Implementation of PDC reduces
direct effects (incidental
trampling/grazing).
Risk of increased competition from weeds and
annual grasses, particularly around areas of high
cattle concentration, such as water holes.
Otherwise, effects likely to be minor because current
authorized use levels are light and result in less
disturbance.
44
Project Type
Direct Effects
Indirect Effects
G. Recovery
actions
Implementation of PDC results in
minimal direct effects. Recovery
actions designed to improve
species population and habitat in
the long run.
Long-term beneficial effects leading toward
recovery.
H. Recreation
projects and
administrative site
maintenance
Implementation of PDC results in
no direct effects.
No effect from maintenance activities given PDC to
protect existing occurrences. New developments
and increased recreation use near existing sites can
result in physical impacts through time, incidental
trampling, and increases in weeds. PDC reduce
effects.
I. Research,
inventory, and
monitoring
Implementation of PDC results in
no direct effects.
Beneficial effects from research.
J. Road
maintenance and
construction
Implementation of PDC results in
no direct effects for new road
construction. PDC result in no
direct effects for road
maintenance, decommissioning,
PDC will reduce effects for road
obliteration.
Increased competition from weeds as a result of
disturbance; indirect effects to species and habitat
from changes in hydrology. PDC reduce effects.
K. ROW permitting
for roads
Implementation of PDC results in
no direct effects on federal lands.
Implementation of PDC reduces indirect effects on
federal lands. Increased competition from weeds as
a result of disturbance; changes in hydrology.
L. ROW permitting
for other uses
Implementation of PDC results in
minimal direct effects for new
construction and maintenance.
Implementation of PDC result in
no direct effects on federal lands
Implementation of PDC reduces likelihood of indirect
effects on federal lands. Canopy cover modification
(increased light), increased temperature and
decreased humidity can indirectly affect populations.
Unintentional increase in weeds as a result of
disturbance can increase competition with listed
plants.
45
Project Type
Direct Effects
Indirect Effects
M. Silvicultural
actions
Implementation of PDC results in
minimal direct effects.
Canopy cover modification (increased light),
increased temperature and decreased humidity,
changes in site hydrology can indirectly affect
populations. Increase in weeds as a result of
disturbance can increase competition with listed
plants. Thinning can benefit Gentner’s fritillary by
increasing light, but may make the plants more
vulnerable to browsing. Fertilization can increase
growth of listed plants and increase competition
from other species.
N. Special forest
product harvesting
The likelihood of direct effects
PDC reduce the likelihood of indirect effects.
from plant and burl harvesting is
reduced by PDC. Incidental direct
effects from trampling would be
limited in scope and scale for
Gentner’s fritillary or Cook’s
lomatium.
O.Tree harvesting
Implementation of PDC results in
no direct effects. Two-year
surveys of suitable habitat will
locate existing populations of
Gentner’s fritillary prior to timber
sales. PDC for salvage sales will
reduce direct effects.
Canopy cover modification (increased light),
increased temperature, and decreased humidity can
indirectly affect populations as well as changes in
site hydrology. Increase in weeds as a result of
disturbance can increase competition with listed
plants. Light commercial thinning through
populations during the dormant period could result
in long-term beneficial effects for Gentner’s fritillary.
P. Watershed
restoration
Implementation of PDC results in
no direct effects.
PDC reduce indirect effects from equipment.
Restoration of natural site hydrology would likely be
a beneficial effect in the long run to vernal pool and
wet meadow species.
Q. Non-native
invasive plant
control
Implementation of PDC
eliminates direct effects for weed
control.
Treatments would generally provide long-term
benefits to species habitat.
46
because of dense fuels that caused a hot sustained burn over the plants, the populations were lost.
Excavations of underground plant structures at these sites revealed that tubers were baked from the
sustained heat. Areas with listed plants that have had fuels treatment are likely to burn with less
intensity in the future increasing the probability of survival, and potentially helping with recovery.
Fuels reduction projects can also have a long term beneficial effect by creating open habitat that is more
suitable to Gentner’s fritillary and Cook’s lomatium, although for Gentner’s fritillary, positive effects may
be offset by increased deer browse, presumably because plants are more exposed and visible. Fuels
projects may also increase non-native plant cover by opening canopies and altering soil properties.
Prescribed burning of meadows could benefit Cook’s lomatium by removing thatch build up and
increasing soil patches where seed germination can occur. Burning has helped increase Cook’s lomatium
plants on the Agate desert on the Nature Conservancy Preserve.
Pile burning of slash, broadcast understory, or maintenance burning within plant sites in timber sales can
affect occurrences and habitats of listed plants, especially Gentner’s fritillary. Spring or early summer
burning could directly kill growing Gentner’s fritillary plants, although it may also improve habitat
conditions. This species is likely adapted to fire in the summer and early fall when it is dormant
underground. Burning occupied habitat during the dormant period is likely a beneficial effect for listed
plants. The use of drip torch fuel to ignite fire in occupied habitat is unlikely to hurt the plants as the fuel
quickly burns, with little sustained heat (C. Martin, personal communication, 2008). Fire can be used to
promote, enhance, or maintain these habitats and create suitable habitat. The burning of piles of slash
can bake listed plants if the piles are within close proximity or on top of plants. The radiant heat can
penetrate the soil and kill the roots and bulbs, depending on the size of pile, and the duration of the
event. Piles can sometimes occupy as much as 10% of an acre, depending on the plant community and
the fuel loads. Where Cook’s lomatium occurs in wet meadows and at the edge of vernal pools, fire may
have been infrequent and may have had a limited role in the maintenance of these communities.
However, grassland habitats in the Illinois Valley are currently being invaded by shrubs. Fire in these sites
in the late summer or fall could benefit these communities and Cook’s lomatium. Thinning, slashing, and
burning activities may occur in riparian reserves and could affect Cook’s lomatium if present at those
sites. For both Cook’s lomatium and Gentner’s fritillary, burning could improve conditions in the shortterm by removing competing vegetation and increasing available nutrients, resulting in an increase in
blooming plants, but be detrimental over the long-term due to an increase in non-native invasive plants.
PDC will reduce or negate effects from fuels activities on the listed plants and the indirect effects are
discountable or beneficial. Fuel reduction and prescribed burning is not likely to adversely affect any
listed plant populations.
BLM does not authorize grazing of any habitats containing Cook’s lomatium, so there is no effect from
grazing on this species or its critical habitat. Cattle grazing allotments are authorized within known
Gentner’s fritillary habitat. Under current utilization rates, direct impacts of cattle on Gentner’s fritillary
appear to be very minor from either trampling (S. Slavik, personal communication) or grazing (M.
Wineteer, personal communication, 2013). Because mature Gentner’s fritillary have substantial
carbohydrate reserves in the form of bulbs, they are likely to be tolerant of periodic trampling or
herbivory. However, repeated defoliation of Liliaceae family plants is demonstrated to affect
subsequent leaf area, biomass, carbohydrate reserves, and nutrient reserves (LaPointe et al. 2010); thus,
47
concentrations of cattle over consecutive years within fritillary sites could cause long-term local
population decline.
Indirect effects of cattle utilization may be more significant than direct effects. Historic high livestock
utilization in CSNM has been implicated in increased bare soil, reduced cover of native perennial grasses,
and increased cover of non-native annual grasses (Frost and Hosten 2007). Further, annual grasses
were negatively correlated with population size of a rare Mariposa lily, Calochortus greenei, and may
help to explain its distribution across the landscape. The effects of exotic annual grasses on Gentner’s
fritillary have not been demonstrated, but exotic annual grasses have been associated with aggressive
competition early in the growing season, the accumulation of thatch, and the potential to alter fire
regimes, each of which could negatively affect native forbs. Although, because of currently low
utilization rates within Medford District, the effects historic heavy livestock use are moderating over time
at the landscape scale, they may persist at water points and other areas of cattle concentration (Hosten
et al. 2007). Similarly, historic and recent moderate to high livestock utilization rates help to explain the
distribution of Canada thistle (Cirsium arvense) and yellow starthistle (Centaurea solstitialis) across
CSNM (Hosten 2007). Many authors have observed a similar relationship between exotic plant invasion
and chronic native and domestic ungulate disturbance (e.g., see review by Vavra et al. 2007), a
correlation attributed to effective colonization of disturbed sites by exotic plants, selective herbivory of
native plants over less palatable exotic plants, and effective dispersal of exotic plant propagules in the
fur, hooves, and gut of ungulates to disturbed sites. Protection measures will eliminate direct effects of
range operations. More importantly, PDC that detect and control exotic plant invasions will reduce
indirect effects such that range operations are not likely to adversely affect listed plants.
High concentrations of recreation use near listed plant sites can cause adverse effects. Soil compaction,
incidental trampling, and flower picking can, in time, reduce population size. The likelihood of sustained
trampling plants is low, unless plants are growing within a trail corridor. Noxious weeds also can be
introduced into areas of high use (trailheads, developed recreation sites) and can spread to other areas
and compete with listed plants. The implementation of PDC will negate direct and reduce indirect
effects to discountable levels for listed plants. Recreation actions are not likely to adversely affect listed
species.
Road maintenance within a road prism can bury or otherwise injure Gentner’s fritillary or Cook’s
lomatium growing along road shoulders. Roadside plants may also benefit from maintenance activities
that increase solar radiation. However, roadside disturbance can facilitate the introduction and spread
of weeds that can compete with listed plants. In response, much of the Medford District’s current weed
treatment program (hand-pulling and spot spraying) focuses on roadside infestations. PDC for road
maintenance and weed treatment will reduce or negate effects. Road maintenance actions are not likely
to cause adverse effects because known sites will be protected.
Numerous ROW permits are authorized for telecommunication sites, powerlines, pipelines, and other
uses. Effects are variable from such varied activities, but the PDC will eliminate direct effects. Surveys for
and protection of listed plant populations from ground disturbing activities for construction will protect
populations. Even large permitted activities, such as commercial pipelines or large power lines, have PDC
to eliminate or reduce direct and indirect effects to discountable levels. Maintenance activities of
48
permitted sites that trigger a NEPA review, including vegetation maintenance along power lines, would
also be subject to surveys in suitable habitat and buffering requirements.
The issuance of special forest product harvesting permits in suitable habitat also has PDC to reduce
effects. The likelihood of effects given the scope and scale of these activities is very small. The issuance
of special permits is not likely to adversely affect listed plants and PDC will reduce effects to discountable
levels.
Silvicultural treatments, such as thinning, planting, and fertilizing can have variable effects on Gentner’s
fritillary. Cook’s lomatium is unlikely to occupy silviculture project areas. The probability of occurrence
of Gentner’s fritillary in managed stands needing pre-commercial thinning (previously harvested and
planted) is also low. Often these stands were commercially harvested 20 or more years ago, then
burned and planted. These habitats generally are no longer suitable for Gentner’s fritillary. Precommercial thinning of natural stands can directly injure above-ground plant structures, although the
number of acres treated annually is small (<1,000 acres/year). Gentner’s fritillary plants that are growing
within managed stands could benefit from canopy gaps through increased solar radiation and other
resources. In contrast, planting conifer seedlings within rare plant sites would increase competition and
reduce habitat quality. Potential direct effects are eliminated by implementing the PDC, and adverse
indirect effects are reduced to discountable levels. Thinning of natural stands and reducing fuel loads can
provide a beneficial long-term effect to Gentner’s fritillary populations. Herbicides are not used for
preparation of planting sites, but they may be used for control of non-native invasive plants in planting
sites or established plantations. PDC prescribed to protect listed plants in natural communities will also
be used in plantations, thereby preventing adverse effects.
Road decommissioning, installation of drainage structures, and other watershed restoration activities
can alter hydrologic patterns within wet meadows that could support Cook’s lomatium and largeflowered woolly meadowfoam. Watershed restoration activities that restore hydrology in wet meadow
habitats can benefit Cook’s lomatium and large-flowered woolly meadowfoam. Protection of listed
plants through heavy equipment restrictions and other PDC would minimize direct effects and reduce
indirect effects to discountable levels for watershed restoration.
Non-native invasive plant treatments with herbicides can kill plants if direct contact occurs with
herbicides. In particular, contract crews—which focus primarily on the district’s roadside invasive plant
infestations—are often not trained in the identification of non-target plants, including federally listed
species. However, treatment with post-emergent herbicides, such as glyphosate, after senescence (the
above ground portion is dead or gone) is unlikely to harm Gentner’s fritillary or Cook’s lomatium as the
chemical is not active in the soil and will not be absorbed by bulb or roots. Non-native invasive plant
control can benefit listed plant populations by reducing competition for space, light, water and nutrients.
Seasonal restrictions, buffers, selective treatment methods, and other protective measures will prevent
adverse effects to listed plants. Non-native invasive plant treatments are not likely to adversely affect
any listed plant.
49
Effects to Critical Habitat
The analysis of effects to Cook’s lomatium critical habitat focuses on the primary constituent elements
(PCEs): (1) space for individual and population growth, germination, and seed dispersal; (2) water,
nutritional, or physiological requirements; and (3) habitat that is protected from disturbance. The
function of these elements must be maintained or the action would be likely to adversely affect critical
habitat and not meet the standards for this BA. The prescribed PDC eliminate or minimize direct and
indirect effects to insignificant levels for critical habitat (Table 5). PDC reduce adverse effects in all cases
such that a determination of may effect, not likely to adversely affect--NLAA is the call for most actions.
Suitable habitat can be affected by physically removing the vegetative components, such as the
dominate vegetation listed in the final designation for Cook’s lomatium critical habitat. This can occur by
a variety of activities including, but not limited to constructing permanent roads or trails, building
infrastructure for recreation, developing or expanding quarries, or reforestation practices that may
convert hardwood stands to conifer dominated stands.
Activities may affect the hydrologic function of critical habitat by redirecting surface or subsurface water
flow. Activities include those listed above plus temporary road construction and culvert placement.
Many of these projects can be designed to reduce or eliminate the effect on hydrology, such as placing
coffer dams on the out-flow end of culverts to spread water across the land scape instead of channeling
it. Skidding and cable yarding associated with tree harvest may affect the hydrology by compacting soils,
which may cause routing of surface water or disruption of subsurface flow down to 18-24 inches.
Soils provide rooting medium and nutrients to plants. Heavy equipment can compact soil causing soil
porosity changes that adversely affect root growth and hydrologic function. Activities affect soils if the
soil is physically removed from the site, such as quarry construction or expansion. Mining activities may
also affect soils by removing ten or more feet of soil. This soil is processed, which mixes up the soil
structure and is then returned to the mined area during reclamation. Soil structure is unlikely to be
restored to its pre-disturbance condition during reclamation.
All activities that are ground disturbing pose a risk for invasive plant introduction. The scope, location,
and scale of the activity will dictate the level of risk of invasion and spread. Activities such as planting
Cook’s lomatium seedlings is a low risk because the area of disturbance is measured in square feet,
whereas regeneration harvest, the associated broadcast burning, and reforestation activities may be the
most disturbing because the ground disturbance is measured in acres, canopy cover is removed,
competitive native vegetation may be consumed in broadcast burns, and the disturbance of bare ground
from maintenance activities such as scalping. Requiring the cleaning of equipment and seeding of
disturbed areas greatly reduces these risks, and for many activities the effects are indiscernible from the
natural spread of weeds by animals and wind. By monitoring project areas disturbed by heavy
equipment, invasive plants will be detected and treated early to minimize their effects.
Tree harvest and associated activities such as log decks and truck turn-arounds will not be allowed in
suitable dispersal and germination habitat for Cook’s lomatium, this will maintain the habitat and soils
associated with critical habitat. The use of log decks, heavy equipment for yarding, and opening the
canopy in unsuitable dispersal and germination habitat can all contribute to the introduction and spread
50
of noxious weeds and nonnative competitive vegetation. PDC, such as equipment washing, dry condition
yarding, no new log decks, and seeding of skid trails have been developed to reduce that risk to a level
that is indistinguishable from vectors we cannot control such as animal and wind spread and vehicle
traffic not associated with tree harvest. Activities associated with tree harvest that would affect
hydrology are road construction and yarding systems. PDC for no new permanent or temporary road
construction or new log desks in critical habitat and reducing compaction from yarding will allow water
to spread across the landscape and return the hydrology to pre-project condition. Given that the Illinois
Valley receives 60 inches of rainfall per year on average, it is likely that where the terrain is flat and the
soils have a strong clay component, rainfall is the main water contribution to the system, while surface
and subsurface flows play a lesser role.
Silvicultural practices would cause no change to hydrology or soils that would affect critical habitat
because the amount of ground disturbance by planting is indiscernible and planting would not occur in
suitable dispersal and germination habitat. The PDC to prohibit reforestation in suitable dispersal and
germination habitat and prohibit habitat conversion in critical habitat would retain the habitat necessary
for the growth and reproduction of Cook’s lomatium. Activities such as site prep for reforestation,
reforestation, and scalping offer opportunities for the introduction and colonization of noxious weeds
because of the large amount of bare ground created by those activities. Additionally if weed seed exists
in the soil, disturbance such as those described for silvicultural practices can stimulate the germination
of that seed. Monitoring for and treating noxious weeds would reduce the risk of nonnative plant
competition in critical habitat.
Burl harvest will not be allowed in critical habitat and the harvest of most special forest products is done
with manual methods and without vehicles leaving existing roadways. As a result there is no effect to
the PCEs. The activities that may cause disturbance to PCEs are firewood cutting areas, hauling of fence
and corral rails, post and poles, pulpwood, roundcuts, and incidental saw timber sales if vehicles are
allowed to leave the roadways. PDC have been designed to reduce these potentially adverse effects to
insignificant adverse effects.
Activities to improve watershed function typically would have a beneficial effect to critical habitat in the
long term. These types of activities often repair poor drainage of roads, add structure to streams, and
improve meadow habitat. With the inclusion of PDC these projects have little risk of introducing noxious
weeds. Road work and culvert replacement are analyzed in the road maintenance section.
Fuel reduction projects may have a long term beneficial affect by creating more open habitat that is
better suited for Cook’s lomatium. The burning of meadows may benefit critical habitat by removing
thatch build up to create areas where seed germination can occur. Burning has helped increase the
health and vigor of Cook’s lomatium plants on The Nature Conservancy preserve on the Agate desert
(Borgias 2004). Areas that receive fuels treatments are likely to burn with less intensity during a wildfire,
increasing the recovery time for the vegetative component of the critical habitat following a wildfire.
51
Table 5. Summary of effects of projects on Cook’s lomatium critical habitat, given implementation of
prescribed PDC.
Project Type
Direct Effects
A. Abandoned mine land
actions
Implementation of PDC results in no changes to PCE.
B. Cultural resource
projects
The hydrologic condition of critical habitat may improve after assessment and
restoration of looted cultural sites. Activities would cause indiscernible changes
to PCEs with the implementation of PDCs.
C. Fuels management
and wildfire suppression
Fuels treatments may have a short-term impact to habitat, but in the long-term
they will be beneficial because reduced fuels loads create open canopy layers
and improve the quality of habitat for Cook’s lomatium. Fuels treatments
would also reduce the effects of wildfires by creating conditions that burn with
less severity and allow vegetation to recover faster.
D. Mining operations
Mining operations are limited to previously disturbed areas and are seasonally
restricted, resulting in minimal impacts that would not alter the function of
critical habitat.
E. Quarry operations
Implementation of PDC results in no changes to PCEs.
F. Range operations
No range operations occur within critical habitat.
G. Recovery actions
Recovery actions have a beneficial effect on critical habitat by improving
meadows and increasing the number and size of Cook’s lomatium populations.
H. Recreation projects
and administrative site
maintenance
Recreation and maintenance activities would have no effect to habitat,
hydrology, or soils with implementation of PDCs. These activities would not
increase the risk of noxious weed introduction above the level already occurring
for activities that do not require special permits.
I. Research, inventory,
and monitoring
Implementation of PDC results in no changes to PCEs.
J. Road maintenance and
construction
New road construction is not permitted within critical habitat. Road
maintenance would have a beneficial effect to critical habitat by reducing
undesirable erosion and improving hydrology.
K. ROW permitting for
roads
New road construction is not permitted within critical habitat. Road
maintenance would have a beneficial effect to critical habitat by reducing
undesirable erosion and improving hydrology.
52
Project Type
Direct Effects
L. ROW permitting for
other uses
Implementation of PDC would cause no measurable change to the function of
critical habitat because no new construction permits are allowed in suitable
dispersal and germination habitat and event permits will not cause ground
disturbance.
M. Silvicultural actions
PDC prohibit reforestation in suitable dispersal and germination habitat and
conversion of hardwood stands to conifer stands. Projects will be monitored for
noxious weeds and treated as needed.
N. Special forest product
harvesting
Implementation of PDC will minimize the effect from extraction of special forest
products and prohibit burl harvest from critical habitat. These activities would
cause no significant changes to PCEs.
O. Tree harvesting
Implementation of PDC would reduce the effects of tree harvesting to
hydrology, soils, and invasive plants. With implementation of PDC, timber
harvest would have minimal effect on habitat.
P. Watershed
restoration
Road decommissioning would be beneficial to critical habitat by improving the
hydrology, reducing soil compaction, establishing native vegetation, and
reducing weed spread. Other activities would have a beneficial effect on critical
habitat by improving hydrology and meadow habitats. Implementation of PDC
would reduce the risk of weed introduction.
Q. Non-native invasive
plant control
Weed control treatments would be applied as necessary to prevent the spread
of noxious weeds. These treatments have a beneficial effect on critical habitat.
53
Pile burning of slash does create a black ring on the landscape that is devoid of vegetation in the shortterm. Larger piles would burn longer, exposing the soil to more heat which could increase the amount of
time it takes to vegetate. The amount of area covered with burn piles will not exceed 10%, leaving a
majority of ground undisturbed. Fuels specialists on the Medford District have observed that burn scars
are quickly colonized by early successional vegetation; however, this sometimes includes non-native
annual grasses and forbs. Pile burning would not disrupt function critical habitat function or PCEs. By
implementing PDC, such as seeding burn piles near known weed sites and rehabilitating fire lines, the
risk of increasing weeds through these actions is reduced in critical habitat.
Recreation activities would cause no new soil damage and PDC would limit the impacts to hydrology and
habitat, to insignificant levels. With the implementation of PDC the risk of introducing noxious weeds
would not be discernible from activities that do not require permits.
Road maintenance and ROW road maintenance would occur within the road prism, an area of existing
disturbance. Road maintenance often improves hydrology by fixing washouts that channel water. Road
decommissioning will benefit critical habitat by reducing vehicle traffic that could introduce and spread
noxious weeds, restore hydrology to natural systems, and create areas for native vegetation to establish.
Other ROW/land use permits allow for activities such as maintenance of existing power and water lines,
utilities and communication sites and occur in previously disturbed areas. Washing of equipment would
reduce the risk of weed introduction and spread. Permits for new construction would be allowed in
unsuitable dispersal and germination habitat but would be designed to maintain the hydrologic
condition. Implementation of PDC would reduce the introduction or spread of weeds. Only minimum
impact permits would be allowed in suitable dispersal and germination habitat and would have no effect
on critical habitat. Other event permits would be allowed on unsuitable dispersal and germination
habitat, but would not allow ground disturbance so as to have no effect on hydrology or weed
introduction.
Cultural resource excavations may benefit hydrologic condition by restoring looted sites. Fences and
other barriers would discourage further disturbance, and revegetation of project sites with native
vegetation would keep noxious weeds from establishing. Historic cemetery restoration projects have
little to no impact on critical habitat PCEs. Vegetation cut would be similar to a fuels maintenance
project, but more selective and on a much smaller scale, not much greater than one acre. This would not
affect the function of the habitat in the critical habitat.
With the PDC, mining activities in critical habitat are limited to reworking old mine tailing. These are
areas that are already disturbed so there is no anticipated new disturbance of critical habitat.
Additionally operations cannot alter hydrologic systems during the wet season when
grasslands/meadows become seasonally inundated.
The establishment and spread of noxious weeds in critical habitat can cause competition with the native
vegetation and create a monoculture of undesirable vegetation that does not maintain the function of
the critical habitat. Control of noxious weeds through manual, cultural, biological, and chemical
methods can control and eliminate noxious weeds in critical habitat and adjacent lands, which provides a
beneficial effect to critical habitat.
54
OHV use in wet soils may alter the hydrology by creating ruts that channel water; they also create
disturbed areas that lend to the establishment of noxious weeds and other competitive nonnative
vegetation. Area closures have an overall beneficial effect to critical habitat by helping to maintain the
function of the PCEs through the exclusion of OHV activity. There may be some minor short term ground
disturbance due to placement of boulders and digging post holes, but personnel observations of these
activities show the disturbed area vegetate naturally in one year. Placement of permanent structures
does remove a very small portion of the critical habitat, but the amount removed is measured in square
feet and would be less than 10,000 square feet, which is 0.2 acres, and will not exceed one percent of
the total area of the Critical Habitat Unit for which the structures are being placed. The PDC to limit
trench development to areas where hydrology would not be disturbed was developed to maintain the
hydrologic function of the critical habitat.
Meadow improvements as part of recovery actions such as removal of encroaching conifers and shrubs,
and burning of excess thatch improve the condition of critical habitat. Planting of Cook’s lomatium
seedlings creates minor ground disturbance as a small hole needs to be dug for each plant. The
disturbance for each hole would be no greater than two square inches. Planting 1,000 plants would
create less than 1/10,000 of an acre of disturbance. Direct seeding of Cook’s lomatium creates no
ground disturbance.
INTERRELATED AND INTERDEPENDENT EFFECTS
Interrelated actions are part of the larger action and depend on the larger action for their justification,
and Interdependent actions are ones having no independent utility apart from the proposed action.
Timber harvest projects often have activities that are interrelated and interdependent (I & I). Surveys,
fuels projects, associated road building, restoration actions within timber sales are all examples, and
these affects are addressed above. Surveying for and protecting known occurrences will result in
negligible effects. Similarly, protecting Cook’s lomatium critical habitat and monitoring for threats and
disturbance will prevent adverse effects on critical habitat.
The issuance of road building permits is one of the main I & I actions. It can be addressed by using the
“but for” test. For example: But for the issuance of a BLM road construction permit to access private
lands, timber harvesting activities would not occur; therefore, the action is I & I. However, in this
example, if other access is reasonably available (the access must only be reasonable, not economical), or
if another way to accomplish the private land objectives exists, then the action is not I & I. The BLM and
the FWS have agreed that the issuance of a ROW permit on an existing road is not I & I and, therefore,
that consultation for actions on private lands is not required. See 10 March 2003 2670 memo
Endangered Species Act and Access to Nonfederal Lands Across National Forest System Land and 30
March 2003 Interagency Agreement Application of the Endangered Species Act to proposals for access to
non-federal lands across lands administered by the Bureau of Land Management and the Forest Service.
CUMULATIVE EFFECTS
Cumulative effects are those effects of future tribal, county, state or private activities, not involving a
Federal nexus, that are reasonably certain to occur within the area of the federal action subject to
consultation (50 CFR 402.2). The effects of future federal actions will be evaluated during future Section
55
7 consultations and are not included in cumulative effects under ESA. Cumulative effects analysis of
foreseeable state and private actions provide the FWS and the BLM an accurate environmental baseline
to assess impacts of federal actions. Although ESA applies to federal lands within the action area, it is
assumed that other federal agencies are meeting ESA requirements. It is also assumed that existing State
laws that apply to State, County and City public lands, are protecting federally listed plants and critical
habitat. ESA does not apply to private lands, which is the largest ownership in the Rogue River basin
(approximately 1.3 million acres). Cumulative effects on these lands are assumed to be adverse because
suitable habitat is being modified and converted to other uses and intentional protection is provided on
very limited acres. Through time, existing critical habitat on private lands will lose their function.
For the listed plants addressed in this BA, populations and suitable habitat on non-federal lands have
likely experienced negative impacts over the last 150 years from resource extraction (mining, grazing,
and logging) and the conversion of low-elevation natural areas to pastures, agricultural lands, and urban
centers. Habitat and populations of Gentner’s fritillary and Cook’s lomatium on non-federal lands will
continue to be affected, or lost, as the human population of the Rogue River basin expands (except for
protected private lands such as the Agate Desert). Populations may survive if located within green belts,
parks, and incidental refuges, but the ability of these populations to persist across an ever-increasing
fragmented landscape is unknown. Several populations of Gentner’s fritillary exist in private woodlands
around the city of Jacksonville, and are currently under the stewardship of concerned and ecologically
minded citizens, but this a small percentage of the total population. The likelihood of persistence on
these sites for the next 100 years is unknown, and will depend upon future landowners, or revised state
laws that would require protection. Thus, populations, critical habitat, and other suitable habitat
occurring on federal lands, where the ESA specifically mandates conservation, provide the best
opportunities for species recovery.
VI. BIOLOGICAL ASSESSMENT CONCLUSIONS
The determination of effects table (Table 6) includes all effects of each proposed project type, including
interrelated/interdependent and cumulative effects. These determinations are dependent on
implementation of all prescribed PDC; otherwise, the effects of a project may be more adverse and lead
to a likely to adversely affect (LAA) determination. LAA actions are not covered by this BA; thus,
incorporating prescribed PDC into project design is imperative.
Based on this biological assessment, Medford District concludes that proposed actions may affect listed
plant species or their designated critical habitat as documented above. The BLM requests concurrence
on may affect, not likely to adversely affect (NLAA) determinations made for all actions included in this
assessment.
56
Table 6. Effects determination for 17 project categories that may occur on Medford BLM starting in fiscal
year 2014.
Project Type
Cook’s
lomatium
Cook’s lomatium
Critical Habitat
Gentner’s
fritillary
Large-flowered
woolly
meadowfoam
A. Abandoned mine land actions
NLAA
NLAA
NLAA
NE
B. Cultural resource projects
NE
NE
NLAA
NE
C. Fuels management & wildfire suppression
NLAA
NLAA
NLAA
NE
D. Mining operations
NLAA
NLAA
NLAA
NE
E. Quarry operations
NLAA
NE
NLAA
NE
F. Range operations
NE
NE
NLAA
NE
G. Recovery actions
NLAA
NLAA
NLAA
NE
H. Recreation/Administrative sites
NLAA
NE
NLAA
NE
I. Research, inventory, and monitoring
NLAA
NE
NLAA
NE
J. Road maintenance & construction
NLAA
NLAA
NLAA
NE
K. ROW permitting for roads
NLAA
NLAA
NLAA
NE
L. ROW permitting for other uses
NLAA
NLAA
NLAA
NE
M. Silvicultural treatments
NLAA
NE
NLAA
NE
N. Special forest product harvesting
NE
NE
NLAA
NE
O. Tree harvesting
NLAA
NLAA
NLAA
NE
P. Watershed restoration
NLAA
NLAA
NLAA
NE
Q. Non-native invasive plant control
NLAA
NLAA
NLAA
NE
57
VII. LITERATURE CITED
Amsberry, K., and R. J. Meinke. 2002. Reproductive ecology of Fritillaria gentneri. Unpublished report
prepared for the US Fish and Wildlife Service. 40 pp.
Amsberry, K., and R.J. Meinke. 2005. Transplanting nursery grown bulbs of Fritillaria gentneri into three
sites in southern Oregon. Oregon Department of Agriculture, Native Plant Conservation Program. 26 pp.
Amsberry, K., and R.J. Meinke. 2007. Continuing investigations of hybridization and fertility of Fritillaria
gentneri through cytological evaluations and pollen viability analysis. Oregon Department of Agriculture,
Native plant Conservation Program. 48 pp.
Borgias, D. 2004. Effects of livestock grazing and the development of grazing best management practices
for the vernal pool-mounded prairies of the Agate Desert, Jackson County, Oregon. Report prepared for
the U.S. Fish and Wildlife Service. Portland, Oregon.
Brock, R., and R. Callagan. 2002. Site Review of Fritillaria gentneri on Bureau of Land Management lands
in 2002. Siskiyou Biosurvey LLC. Internal report prepared for Medford District, BLM.
Bureau of Land Management. 1995. Medford District Record of Decision and Resource Management
Plan. Medford, Oregon.
Bureau of Land Management. 1998. Medford District Integrated Weed Management Plan and
Environmental Assessment OR-110-98-14.
Bureau of Land Management. 2008. Cascade Siskiyou National Monument Resource Management Plan
and Record of Decision. Medford District BLM.
Bureau of Land Management. 2010. Record of Decision, Vegetation Treatments Using Herbicides on BLM
Lands in Oregon.
Bureau of Land Management. 2011. FY 2012-2013 Programmatic Assessment for Activities that May
Affect the Designated Critical Habitat for the Endangered Plant Species Cook’s Lomatium. Medford
District BLM.
Clayton, J.L. 1981. Soil Disturbance Caused by Clearcutting and Helicopter Yarding in the Idaho Batholith.
Intermountain Forest and Experiment Station. Research Notes INT-305.
Donham, K. 2002. Report on pollination of Fritillaria gentneri. Unpublished report prepared for Bureau
of Land Management, Medford Oregon.
Frost, E. and P. Hosten. 2007. Habitat and landscape distribution of Calochortus greenei S. Watson
(Liliaceae) across the Cascade-Siskiyou National Monument, southwest Oregon. U.S. Department of the
Interior, Bureau of Land Management.
Gamon, J. 1984. Element Abstract. Oregon Natural Heritage Program. Portland, Oregon.
58
Giles-Johnson D.E.L., E.C. Gray, and T.N. Kaye. 2012. Fritillaria gentneri population monitoring at Pickett
Creek, Josephine County, Oregon. Institute for Applied Ecology, Corvallis, Oregon and USDI Bureau of
Land Management, Medford District. 20 pp.
Gilkey, H. 1951. A new Fritillaria for Oregon. Oregon State College, Corvallis Oregon. Madrono 11
(2):137-141.
Guerrant, E.O. 1991. An electrophoretic investigation into the status of Fritillaria gentneri (Liliaceae): Is
it a “Good” Species or Not? Oregon State Department of Agriculture. Internal report. Medford District,
Bureau of Land Management. Medford, Oregon.
Hosten, P. 2007. Factors controlling patterns of Canada thistle (Cirsium arvense) and Yellow starthistle
(Centaurea solstitialis) across the Cascade-Siskiyou National Monument. U.S. Department of the Interior,
Bureau of Land Management.
Hosten, P., G. Hickman, and D. Schuster. 2007. Recent and historic changes (5 to 30 years) in plant
community composition in the Cascade-Siskiyou National Monument, southwest Oregon. U.S.
Department of the Interior, Bureau of Land Management.
Kagan, J. 1986. A new species of Lomatium (Apiaceae), from southwest Oregon. Madrono 33 (1): 71-75.
Kaye, T. and M. Kirkland. 1994. Population biology of Lomatium bradshawii. Unpublished report for the
Eugene Bureau of Land Management and the Oregon Department of Agriculture, Eugene, Oregon.
Kaye, T.N. 2005. Effects on the Biscuit Fire on Frasera umpquaensis on the Medford BLM. Institute for
Applied Ecology. Corvallis, Oregon. 34 pp.
Kaye, T.N., and Thorpe, A.S. 2007. Lomatium cookii monitoring in the Illinois Valley, Josephine County,
Oregon. 2007 Progress Report. Institute for Applied Ecology, Corvallis, Oregon. 37 pp.
Kaye, T.N., I.A. Pfingsten, D.E.L. Giles-Johnson, and I.S. Silvernail. 2012. Developing reintroduction
techniques for Lomatium cookii. Institute for Applied Ecology, Corvallis, Oregon and USDI Bureau of Land
Management, Medford District. 63 pp.
Knight, L. 1991. Baseline monitoring of Fritillaria gentneri. Unpublished report prepared for the
Medford District, Bureau of Land Management. Medford, Oregon.
Landsberg, J.D., Miller, R.E., Anderson, H.W., and Tepp, J.S. 2003. Bulk density and Soil Resistance to
Penetration as affected by Commercial Thinning in Northeastern Washington. Pacific Northwest
Research Station. Research Paper PNW-RP-551.
LaPointe, L., J. Bussieres, M. Crete, and J. Ouellet. 2010. Impact of growth form and carbohydrate
reserves on tolerance to simulated deer herbivory and subsequent recovery in Liliaceae. American
Journal of Botany 97: 913-924.
59
Oregon Natural Heritage Information Center. 2008. Element Occurrence Records for Lomatium cookii
and Limnanthes floccosa ssp. grandiflora. Database. Oregon Natural Heritage Information Center,
Portland, Oregon.
Pfingsten, I., D. Giles-Johnson, and T. Kaye. 2012. Lomatium cookii population monitoring in the Illinois
Valley, Josephine County, Oregon. Institute for Applied Ecology, Corvallis, Oregon and USDI Bureau of
Land Management, Medford District. 38 pp.
Siskiyou Biosurvey. 2013. Annual review of Fritillaria gentneri on BLM lands: 2012 report. Siskiyou
Biosurvey, LLC, Eagle Point, Oregon. 72 pp.
USDA Forest Service and USDI Bureau of Land Management. 1994. Record of decision for amendments
to Forest Service and Bureau of Land Management planning documents within the range of the northern
spotted owl. Portland, OR. Includes standards and guidelines for management of late-successional –
old-growth dependent species within the range of the northern spotted owl. US Government Printing
Office, Portland, Oregon.
U.S. Fish and Wildlife Service. 2003. Recovery plan for Fritillaria gentneri. Portland, Oregon, 89 pp.
U.S. Fish and Wildlife Service. 2012. Recovery Plan for Rogue and Illinois Valley Vernal Pool and Wet
Meadow Ecosystems. Region 1, Portland, Oregon. xvii + 240 pages.
Vavra, M., C. Parks, and M. Wisdom. 2007. Biodiversity, exotic plant species, and herbivory: The good,
the bad, and the ungulate. Forest Ecology and Management 246: 66-72.
VIII. PERSONAL COMMUNICATIONS
Amsberry, K. 2013. Conservation Botanist, Native Plant Conservation Program, Oregon Department of
Agriculture. Personal communication with Sam Friedman about reproduction of Fritillaria gentneri by
seed.
Kaye, T. 2003. Executive Director, Institute for Applied Ecology. Personal communication with Mark
Mousseaux of observations of hummingbirds visiting Fritillaria gentneri. Bureau of Land Management,
Medford, Oregon.
MacFarlane, R. 1980. Department of Botany, California Academy of Science. Documented telephone
conversation with Wayne Rolle, Botanist US Forest Service.
Martin, C. 2008. Former Fire Ecologist, Medford District, Bureau of Land Management. Personal
communication with Mark Mousseaux about the likelihood of drip torch oil affecting occupied habitat.
Meinke, R. 2001. Botanist, Oregon Department of Agriculture. Personal communication with Mark
Mousseaux on pollination studies, bulb depth, and general information for Fritillaria gentneri.
60
Robinson, A. 2002. Botanist, US Fish and Wildlife Service, Portland, Oregon. Personal communication
with Mark Mousseaux on foraging distance for hummingbirds as it relates to breeding population size for
Gentner’s fritillary.
Showalter, R. 2013. Botanist, Grants Pass Resource Area, Medford District, Bureau of Land
Management. Personal communication with Bryan Wender about the success of efforts to reduce OHV
use and illegal dumping in BLM ACECs in the Illinois Valley.
Slavik, S. 2013. Range Specialist, Medford District, Bureau of Land Management. Personal
communication with Bryan Wender about the effects of current livestock utilization levels on Fritillaria
gentneri in Medford District.
Wineteer, M. 2013. Botanist, Butte Falls Resource Area, Medford District, Bureau of Land Management.
Personal communication with Bryan Wender on the impacts of grazing on Fritillaria gentneri in Medford
District grazing allotments.
61
APPENDIX A. LISTED PLANT SURVEY PROTOCOLS
The following survey protocols are required for clearance of projects occurring within range of listed
plants and in suitable habitat. Surveys are not required in project areas that do not support listed plant
species, because these are no effect projects. Surveys are not required for projects in which the scope,
scale, timing, or intensity is such that there would be no effect to any listed species, as determined and
documented by the project botanist. If listed plant species are not found in surveys, then the project
area is considered cleared for a period of 10 years.
Cook’s lomatium and large-flowered meadowfoam survey protocol
Surveyor qualifications
Surveys will be conducted by trained, qualified botanists familiar with the listed species and its habitat
and ecology. The surveyor should also be familiar with related and look-a-like species.
Timing
Surveys must be conducted when target plants are accessible, visible, and identifiable, preferably when
the species is likely to be flowering or fruiting within the project area. Surveys not performed at optimal
timing cannot be used to evaluate presence or absence of the listed species, but can be used to evaluate
the suitability of the habitat to support the species.
Frequency
For all project types, single-season surveys are adequate for these species.
Intensity
Surveyors are to use an intuitive controlled plant survey methodology as described in BLM Manual
Supplement, H-6840-1, Special Status Plant Management (Bureau of Land Management 1996). Walking
routes should cover representative (80%) cross sections of major topographic features (e.g., slopes,
draws, benches, ridges) and suitable habitats within the survey unit. When areas of highly suitable
habitat or existing populations are encountered, a more thorough and intensive examination should be
made of nearly 100% of the area.
Gentner’s lily survey protocol
Surveyor qualifications
Surveys must be conducted by trained, qualified botanists familiar with the listed species and its habitat
and ecology. The surveyor should also be familiar with related and look-a-like species.
Timing
Surveys must be conducted when target plants are accessible, visible, and identifiable, which means
when plants are flowering, because distinguishing this species from similar Fritillaria species is not
possible based on vegetative characteristics alone. Surveys not performed at optimal timing cannot be
used to evaluate presence or absence of the listed species, but can be used to evaluate the suitability of
the habitat to support the species.
62
Frequency
Depending on the project type, either a one-year survey or a two-year survey is required.
One-year surveys are adequate for projects that are small in scope and scale, have a low likelihood of
rare plant sites, or have a low probability of impact. Two-year surveys for small projects are unlikely to
increase the number of populations found.
When patches of vegetative fritillary plants (non-flowering) are located in a one-year survey, one of two
actions is recommended: (1) a second-year survey to determine if the species is Gentner’s fritillary or the
more common Scarlet fritillary (Fritillaria recurva), or (2) implementation of other mitigation measures
to protect the plant sites from the proposed activities (e.g., buffers, seasonal restrictions, monitoring).
Two-year surveys are required for Gentner’s fritillary for the following projects, when the project area is
within range and includes suitable habitat:







Tree harvesting including stewardship projects. This does not include small sales sold as Special
Forest Products or salvage sales for wildfires or catastrophic events like windstorms or tornados
(single-season surveys are adequate for those actions).
Road construction if indeterminate fritillary leaves are observed within the project area or if
there is a documented plant site within 1500 feet of the proposed corridor.
Pile burning if indeterminate fritillary leaves are observed within the pile burn area or if there is
a documented plant site within 1500 feet of the pile burn area.
Mechanical fuel reduction (involving heavy equipment).
New livestock grazing allotments or renewals for which two-year surveys have not previously
been completed, conduct two-year surveys if there is a documented Gentner’s fritillary
occurrence within 1500 feet of the allotment area.
New rock quarries.
New construction of large interregional commercial power lines and pipelines (does not include
local utilities or lines for private homes).
Two-year surveys do not have to be concurrent years, but there must be two surveys within a ten-year
interval. If surveys are not concurrent, they are recommended to be within 5 years of each other.
Intensity
For single-season Gentner’s fritillary surveys, surveyors are to use an intuitive controlled plant survey
methodology. Walking routes should cover representative cross sections of major topographic features
(e.g., slopes, draws, benches, ridges) and suitable habitats within the survey unit. When areas of highly
suitable habitat or existing populations are encountered, a more thorough and intensive examination
should be made of nearly 100% of the area.
For two-year Gentner’s fritillary surveys, the first-year survey should examine all suitable habitat and all
known sites, documenting all flowering plants and occurrences of vegetative fritillary leaves
(indeterminate sites). Areas of high habitat suitability and indeterminate sites are the focus of secondyear surveys. If, after two years of surveys, flowering plants are not observed, then the survey area is
considered cleared for project implementation.
63