California Native Plant Society

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CNPS Joins Litigation to Protect Public Lands in the Sierra Nevada

The Board of Directors voted in September to join the California Oak Foundation and the California Indian Basketweavers Association in litigation to prevent the Stanislaus National Forest from proceeding with its Larson Project. The Plan would convert biologically diverse, post-fire vegetation communities to conifer tree plantations, 16 years after wildfire in the area. The plan proposes aerial spraying within 1 mile of Yosemite National Park and threatens Miwok gathering areas, the Yosemite deer herd’s winter food supply, and habitat for migratory and resident birds. Thousands of acres of hardwood forest and montane chaparral would be eliminated along with rare plant populations through repeated applications of herbicides, burning, and mechanical crushing to remove native vegetation.

In July, the Board voted to join the Forest Issues Group, South Yuba River Citizens League, California Indian Basketweavers Association, Sierra Club, and Sierra Foothills Audubon Society in litigation of the Tahoe National Forest’s Cottonwood Project, which also proposes converting native vegetation to tree farms through the use of herbicides.

The Larson Project: National Forest Tree Farming Threatens Native Plant Diversity

In July 2004, the Groveland Ranger District in the Stanislaus National Forest released the Larson Reforestation and Fuels Reduction Project Environmental Impact Statement and Record of Decision. The decision was made by the Forest Service to aerially spray herbicides via helicopter on 1,200 acres bordering the southwest corner of Yosemite National Park. In the seventeen years since the 1987 Stanislaus Complex fires, the area has naturally grown into a healthy and diverse forest.

In 1986, ecologist Todd Keeler-Wolf identified the area as containing one of the most exemplary black oak stands in the Sierra Nevada. This area was subsequently designated as the Big Grizzly Research Natural Area by the Forest Service. Adjacent stands of similar black oak woodlands are slated for conversion to tree farms. Much of the Larson project area is predominately oak woodland forest, especially black oak (Quercus kelloggii).

Montane hardwood/black oak dominated forest community in the Larson Project area. These forests will be aerially sprayed with herbicides, bulldozed, burned, and replanted with even-aged, uniform pine tree seedlings, then re-sprayed. The loss of black oak from "brown and burn" intensive forestry regimes such as this has contributed to severe declines in wildlife diversity throughout the Sierra Nevada.

The Forest Service plans to use herbicides to kill native hardwoods and montane chaparral species to accelerate the growth of tree plantations for timber production. The agency also claims herbicides are essential to reduce fire hazard. The need for herbicides to accomplish these objectives is disputed widely by the public, including CNPS. Type conversion from oak woodlands to conifer plantations as proposed violates the Sierra Framework, which requires protection of oaks. Ironically, state and federal agencies are pouring funds into Sudden Oak Death research to protect oaks, while the Stanislaus National Forest plans to intentionally kill oaks to grow conifers for timber.

The plan to convert 4,000 acres of native montane oak and early successional forest to commercial conifer plantations calls for ground-based spraying of the herbicide triclopyr followed by bulldozing the sprayed brush, burning the crushed plants, and dense planting of conifers. Further spraying is proposed one year after planting, three years after planting, and in the fifth, sixth, and eighth years after planting, to kill competing native wildflowers, shrubs, and non-commercial tree species.

Under the proposal, several rare endemic plants that the Forest Service is required to protect under the agency’s Sensitive Plant Program will not be protected from aerial herbicide applications. Other rare plant populations may be harmed from drifting chemicals and ground-based spraying in areas where no recent surveys have been conducted to determine whether rare plants are present.

“Sensitive” is a term used by the USFS to designate plant species that are considered valid candidates for federal threatened or endangered classification under the Endangered Species Act. The USFS is mandated to avoid or minimize impacts to these species, and to implement management objectives for sensitive plant populations and their habitats. Entire populations of the narrow endemic Clarkia australis may be directly impacted by the Larson Project.

The 5 endemic List 1B species known to occur within the proposed spray areas are:

  • Clarkia australis (Small’s southern clarkia)
  • Mimulus filicaulis (Slender-stemmed monkeyflower)
  • Mimulus pulchellus (Pansy monkeyflower)
  • Eriophyllum congdonii (Congdon’s woolly sunflower)
  • Eriophyllum nubigenum (Yosemite woolly sunflower)

Of particular concern are potential impacts to “Clarkia bees.” Monica Geber of Cornell University and Martha Groom at the University of Washington have studied the close relationship between the native solitary bees that are Clarkia specialists, and the reproductive success of Clarkia. According to Dr. Geber, who has been exploring these interactions in the nearby Sequoia National Forest, eradication or suppression of Clarkia could have negative impacts on populations of native specialist bees, which in turn, can further endanger the rare endemic wildflowers by reducing seed set. The bees provision their nests only with Clarkia pollen, and cannot travel long distances between fragmented Clarkia populations. Clarkia seed output and pollinator abundance were both found to be related to high Clarkia community diversity.

After half a century of using potent herbicides to kill native shrubs and hardwood species, today the forest products industry and U.S. Forest Service claim herbicides are now needed to reduce fire risk. In reality, heavy use of herbicides to manage vegetation can actually increase fire risk in tree plantations, as seen in this photo of the St. Pauli Fire, El Dorado county, July 2002. Prior to the fire, this plantation had been heavily managed with weed killer.

Suitable habitat also exists for several other rare plants known to occur in or near the area. They include Clarkia lingulata (Merced clarkia), Clarkia virgata (Sierra clarkia), Clarkia biloba ssp. australis (Mariposa clarkia), Clarkia rostrata (beaked clarkia), Erythronium tuolumnense (Tuolomne fawn lily), and Horkelia parryi (Parry’s horkelia). Impacts to suitable habitat for these species from conversion to tree farms was not addressed by the agency, even though the 1987 fire increased the likelihood that they may now occur in the project area. The project area was not surveyed for any of these species, so potential impacts to these species cannot be adequately assessed.

CNPS is opposed to the use of herbicides on native vegetation, on sensitive species, or on sensitive species‘ habitat. CNPS disagrees with the USFS view that timber production in this area is so urgent that aerial and ground-based herbicide application is necessary. These actions are out of step with the Sierra Framework (the 2001 Sierra Nevada Forest Plan Amendment, as amended in 2004), which contains the current direction for management of the Sierra Nevada’s national forest lands. The agency failed to conduct landscape analysis prior to proposing activities in westside montane hardwood forest. Under the new direction, the Forest Service is required to manage westside montane hardwood forests in order to promote oaks while reintroducing the natural fire regime. These new management standards incorporate fire ecology and an understanding of the linkages between early seral forests and biodiversity. Further installation of thousands of acres of tree farms in this region virtually guarantees a rapid return of the unnaturally dense stands of small trees that existed at the time of the 1987 fires. These conditions are generally thought to increase fire risk.

In September 2004, CNPS filed a formal appeal of the flawed project. The appeal was filed jointly with the California Oak Foundation and the California Indian Basketweavers Association (CIBA). The Forest Service denied the appeal in October, and we are currently examining our options to decide how best to protect these sensitive plant populations, the oak woodlands of the area, and the species that depend on them. For more information, contact Vivian Parker, CNPS conservation coordinator for the Sierra Nevada region’s national forests, at or Jennifer Kalt, State Forest Issues Coordinator, at

For more information about the USFS Sensitive Plant Management program, see Bradley E. Powell’s “Rare Plant Management on the National Forests and Grasslands in California” (PDF, 36k) in the CNPS Inventory, Sixth Edition (2001). For more information on the Sierra Framework, see Vivian Parker’s “Update on the Sierra Nevada—Still in Peril” in the October 2003 issue of Fremontia.

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