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USDA Forest Service
Regional Office R5
1323 Club Drive
Vallejo, CA 94592
ToSteve Bishop, Assistant Director, Natural Resource Management (R5), and Jim Shackelford, Range Program Manager (R5)
Recently, it has come to my attention that prominent Forest Service botanists and ecologists will be meeting on March 18-19 2003 at Folsom Lake to discuss possible revisions to the R-5 Range Monitoring Plant Database, perhaps as a precursor to proposed plant indicator classification changes in the R-5 Rangeland Plant List. I wish to have the following comments and recommendations forwarded, discussed and seriously considered prior to (and at) this meeting. I have serious concerns about the R-5 Rangeland Plant List and the associated R-5 Range Monitoring Plant Database.
I am concerned that some of the current seral (or condition class) indicator ratings on these two plant lists may be promoting (or will promote) artificially inflated seral status assessments on Forest Service rangelands in California. Such artificial inflation may have serious consequences, as allowable utilization levels and other management standards are often based upon the supposed seral vegetative condition of the land being assessed. An artificially inflated seral condition designation for a meadow can suggest that recent or current management may have been sufficient to promote and restore late seral native vegetation communities, when, in fact, that management may have been actually promoting less desirable early seral stage (and often times non-native) vegetation communities and discouraging restoration of damaged meadows.
I believe that this “seral inflation” can be inappropriately promoted through the use of two techniques. First, the designation of some widely prevalent non-native grass species (such as Poa pratensis) as mid seral or late seral condition plant indicators when found on wet, moist, and dry meadows would artificially inflate the overall seral condition class of these types of meadows. The increasing (and often widespread) presence of such species on a wet, moist, or dry meadow is almost always an indicator that late seral stage native vegetation indicators are being (or have been) displaced by grazing-tolerant, disturbance-responsive early seral stage non-native vegetation over time. I believe that these types of undesirable, non-native, “disturbance-responsive” grass species (such as Kentucky bluegrass ) should receive, at best, a low (or early) seral indicator rating for wet, moist, and dry meadows.
Second, the designation of some types of “disturbance-responsive” native plant species (such as Carex douglasi , Juncus balticus  and Muhlenbergia richardsoniis ,) as mid or late seral condition indicators on moist and dry meadows that are, in fact, degraded wet or moist meadows also can artificially inflate the overall seral vegetation condition class of the meadows being evaluated. The widespread presence of these plants (especially Carex douglasi, more commonly known as Douglas sedge, and Muhlenbergia richardsoniis, more commonly as mat muhly) on a moist or dry meadow that was previously documented as a natural wet or moist meadow usually indicates that livestock-induced transformation of a wet or moist meadow into an increasingly desiccated meadow has occurred.
Giving a degraded wet meadow site a mid or late seral dry meadow vegetation classification can, in my view, undermine an objective range condition assessment. Such an action will invariably suggest that a historically-damaged site is in a healthier condition than it actually is, and such a distorted view will usually result in a level of allowable livestock grazing pressure that will likely impede restoration of that site. My concern here is not merely a theoretical one. I have observed this phenomenon occur on the Inyo National Forest in the past. And I believe that I have even seen an example of this type of “native seral inflation” (undoubtedly inadvertently generated) in a past USFS Region 5 Range Monitoring Project report. I wish to focus briefly on this latter example, as I believe it to be instructive. It demonstrates the distortion, however inadvertent, that can be generated by use of the current seral rating approach currently adopted by the Pacific Southwest region of the Forest Service.
Region 5 and Inyo NF personnel gathered rooted frequency plot location data from a site on Volcano Meadow on 8-7-99. Much or all of the data is included in the R5 Range Monitoring CD, Year 2001, under the classification of rooted frequency plot number INY9921.
This site on Volcano Meadow was classified as a dry meadow, with a moderate seral vegetation condition dominated by Aster occidentalis (low seral for dry meadow), Carex douglassi (moderate seral for dry meadow) and Muhlenburgia richardsoni (moderate seral for dry meadow), with smaller amounts of Juncus balticus, Trifolium longipipes, and Ivesia lycopodiodes.
If this site was a natural, dry meadow, this rating might be reasonably accurate, as Douglas sedge and matt muhly can occur naturally on an undisturbed, natural dry meadow. (See (USFS Region 5 Range Monitoring Project 2000 Report, Dave Weixelman and Jo Ann Fites, Adaptive Management Services, U.S. Forest Service, Nevada City, CA December 12, 2000, and R5 Range Monitoring CD, Year 2001). However, this area is most likely not a natural dry meadow. The Inyo NF Forest Plan Amendment # 6, Errata #1 (1995) states there is very little natural dry meadow acreage on the Inyo National Forest: “The Inyo National Forest has only a small acreage of true dry meadow vegetation type, which is intermixed with upland vegetation types.” (Inyo NF Forest Plan Amendment #6, - Errata #1, page 1, August 1995). Moreover, the rooted frequency plot location data itself identifies the landform of the sampled site as “floodplain”.
If this area exhibits dry meadow characteristics, this is most likely because the site is a degraded wet meadow floodplain area. Douglas sedge and mat muhly are not natural vegetative components on natural, undisturbed wet meadow floodplains in the Sierra Nevada. Their dominating presence on this site is most likely due to the livestock-grazing-induced degradation of the natural features of this previously wet meadow area.
Additional monitoring information from the Inyo NF reinforces this interpretation. The picture of the sampling area (included in the R5 Range Monitoring CD, Year 2001) reveals that the site (plot number INY9921) is very near the two southern-most reaches of Left Stringer. Both of these reaches (and the associated areas directly adjacent to them) have been severely impacted by livestock grazing for many years. These reaches were assigned functioning at risk, downward trend ratings by the Inyo NF PFC team in August of 1998.
Even before 1998 PFC assessments, the livestock-induced degradation, desiccation, and transformation of this area had been documented. As early as 1994, Inyo NF utilization records noted the existence of declining riparian conditions in Volcano Meadow, including the area very near the INY9921 sampling area. The 1994 post-season utilization record for this meadow (dated 10-12-94) stated that the "upper, drier area [was] well grazed, so are areas near riparian zone . . . noticed the beginnings of bank deterioration." Moreover, severe overgrazing of this area continued simultaneously and after this observation was recorded. The 1994 utilization record (UR) documented that 57 of the 100 sampled, grazed vegetation hit points had been grazed to one inch or below in height. In 1995, the utilization record documented a very high vegetation utilization rate of 70%, with 74 of the 100 sampled, grazed vegetation hits points at heights of 1.5 inches or below (while sampled ungrazed vegetation heights averaged 11 inches!) The 1995 UR noted that the "[l]ower area showed many hoof compaction marks." In the upper area (near the later sampling location for INY9921, the UR noted that the "areas above the bank had evidence of hoof compaction 1/2 to 3 inches." The measured trampling and chiseling rate on this meadow for the 1995 season was a very high 51 percent.
Clearly, this area had experienced severe livestock-related disturbance during the 1990s, and the area seemed to be displaying significant signs of emergent degradation and dessication. However, one would not be able to discern this by relying upon the vegetation-related seral rating for this site in the Weixelman/Fites report. By limiting that assessment to a narrow set of parameters, concluding that the vegetation and dry soil condition made the sampled area a dry meadow, and that the vegetation indicated a moderate seral vegetation condition, the year 2000 report vegetation seral rating for this site could have easily promoted a less restrictive management approach for this seriously-damaged area when, in fact, a far more restrictive approach was needed (and is, in fact, being implemented now).
In short, a focus on the vegetation component of a site without reference to the history of that site can easily obscure the fact that the vegetation community may reflect the severe damage that an area may have absorbed. Such a focus, without reference to the natural vegetation community of the previously undisturbed, untransformed site, can ultimately make an area appear to be in better range condition than it actually is.
To conclude this section, I feel strongly that degraded, dessicated wet meadow sites should be classified as early seral stage sites until such sites have largely regenerated late seral stage characteristics. At the least, reclassification to a higher seral rating should not even be considered until a process that is actually regenerating the site’s natural, wetter, later seral stage characteristics has become evident and has advanced significantly.
I believe that the designation of a mid or late seral indicator rating for a native species such as Douglas sedge is only warranted when the moist or dry meadow is a “natural” or “true” dry meadow, not a livestock-induced degraded wet meadow. In short, species such Carex douglasi should be designated as early seral indicator species for those moist and dry meadows that are, in fact, degraded and desiccated wet meadows.
I believe that use of these seral inflation techniques at the regional level could impede local forest compliance with National Forest Mangement Act (NFMA) requirements that require national forests to provide “ecological conditions that provide a high likelihood of supporting [or contribute to supporting] over time the viability of native and desired non-native species well distributed throughout their ranges” [NFMA 2000 Planning Rule, Section 219.20]. Without regional modification of inappropriate seral condition plant indicator ratings, the CA national forests will likely adopt the techniques and seral indicator designations provided by the regional office and subsequently inflate seral condition ratings on their own rangelands. The ultimate result will likely be one that is distinctly undesirable: lands that should be impacted less by livestock in the future will, instead, be impacted more heavily by livestock in the future, leading to further losses in the native, late seral plant communities that the Forest Service is legally required to promote.
In conclusion, I recommend that the Pacific Southwest Region of the Forest Service eliminate seral plant indicator ratings of mid seral or late seral for all undesirable non-native plant species (including Poa pratensis) on the regional plant list. I also recommend that the region eliminate mid and late seral ratings for certain native plants when those particular plant species site occurrences can be reasonably attributed to the livestock-induced degradation and desiccation of a wet or moist meadow site. (See Appendix A for current ratings of the plants discussed above.) I look forward to a written response to our requests and concerns from the Pacific Southwest Region of the Forest Service.
Todd Shuman, March 6, 2003
49515 Brett Avenue
Tehachapi, CA 93561 661-823-9369
As background, I wish to note that the R5 Rangeland Plant List assigns Moderate ratings for Kentucky bluegrass in wet and moist meadows and a Late rating for Poa pratensis in dry meadows. The R-5 Range Monitoring Plant Database assign an Early rating for Poa pratensis in wet meadows, Moderate in moist meadows, and Late in dry meadows.
The R5 plant list assigns an Early seral rating for Douglas sedge in moist meadows and a Moderate rating when in dry meadows. The R-5 Range Monitoring Plant Database assign an Early seral rating for Douglas sedge in wet meadows and Moderate ratings for Douglas sedge in both moist and dry meadows.
The R-5 Range Monitoring Plant Database assign a moderate rating for Juncus balticus in wet meadows, Moderate when in moist meadows, and moderate when in dry meadows
The R-5 Range Monitoring Plant Database assign an moderate rating for Muhlenbergia richardsoniis in moist meadows, and moderate when in dry meadows
 For a persuasive review that documents the undesirability of the non-native grass, Poa pratensis (Kentucky bluegrass), see the sections below (without the footnotes) of a report taken from the Forest Service’s own fire effects information website at http://www.fs.fed.us/database/feis/index.html
Grazing: The desirability of Kentucky bluegrass on rangeland is limitedbecause of low production, summer dormancy, and propensity to invadenative grasslands. This grass is highly resistant to grazing becausegrowing points remain belowground throughout the growing season, and ithas a low ratio of reproductive to vegetative stems . Few grassesare able to withstand heavy grazing as well as Kentucky bluegrass. Itincreases rapidly on overgrazed pastures and ranges, and its presence isusually an indication of poor grazing management in the past.
On tallgrass prairie rangeland, Kentucky bluegrass density is best keptin check by a combination of grazing management and prescribed burning.It was effectively controlled in eastern Kansas with either season-longor intensive early season grazing combined with late spring prescribedburning . Kentucky bluegrass also decreases with a combination oflate spring mowing and raking, which simulates burning .
In the Mountain West, Kentucky bluegrass is well adapted to meadowswhich have seasonally high water tables and midsummer drought . Ithas become naturalized and dominates many meadows once dominated bytufted hairgrass (Deschampsia cespitosa) and sedges. Replacement ofKentucky bluegrass with the original natives is impractical because ofits competitive ability. Even after 11 years of rest from livestock
grazing, a Kentucky bluegrass meadow in central Oregon did not advancetoward dominance by tufted hairgrass . For livestock use, thesesites are best managed under a grazing system other than season longuse. . . .
Soil stability: Because of its shallow root system, Kentucky bluegrassis generally not as good a soil stabilizer as the native grasses andforbs it replaces. In riparian settings, it is ineffective instabilizing streambanks. Erosion and channel downcutting may occur,
Flood resistance: Kentucky bluegrass is intolerant of prolongedflooding, high water tables, or poor drainage .
Kentucky bluegrass is extremely competitive. Due to past grazing andlowering of water tables in western riparian habitats, Kentuckybluegrass now dominates many sites once occupied by tufted hairgrass,woolly sedge (Carex lanuginosa), widefruit sedge (C. eurycarpa), aquaticsedge (C. aquatilis), bluejoint reedgrass (Calamagrostis canadensis),
In the Intermountain West, aspen/Kentucky bluegrass communities aregrazing-induced seral stages which have replaced the following climax ornear climax communities [80,82]: aspen/mountain snowberry/Fendlermeadowrue (Thalictrum fendleri), aspen/mountain snowberry/pinegrass(Calamagrostis rubescens), aspen/Fendler meadowrue, aspen/pinegrass,aspen/mountain snowberry/elk sedge (Carex geyeri), and aspen/elk sedge.
In ponderosa pine and bunchgrass habitat types, Kentucky bluegrass isoften the herbaceous layer dominant on sites with a history of pastgrazing abuse. Daubenmire  called such sites a "zootic climax"because even after the grazing disturbance has been stopped for manyyears, there is no indication that Kentucky bluegrass will give way tothe native climax species.
From fire effects information website (with references):
U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory (2003, January). Fire Effects Information System,
See also “Restoring degraded riparian meadows: Biomass and species responses”,
by David W. Martin and Jeanne C. Chambers , Journal of Range Management, May 2001, Volume 54:284–291
The authors wrote, in the abstract, this regarding Kentucky bluegrass: “Examination of the key graminoids showed that Kentucky bluegrass (Poa pratensis ssp. pratensis L.), an increaser species, did not increase in response to release from grazing, but increased in response to clipping and nitrogen addition.”
 The SNEP Rangeland Assessment had this to say about Douglas sedge : "Carex douglassi is a classic invader species and often indicates severly disturbed, dry, denuded areas, meadow borders, and other semi-moist [soils] . . . (p. 24, p 924, of overall SNEP
 The SNEP Range Assessment had this to say about these two: Juncus balticus "is
a poor forage value species growing in dry, dewatered areas . . . [p 25, 925]". For a persuasive review that documents the disturbance-responsive nature of Juncus balticus, see the section below (without the footnotes) of a report taken from the Forest Service’s own fire effects information website at http://www.fs.fed.us/database/feis/index.html
Baltic rush is a perennial, native, cool-season species . It is a climax component of several western community types and plant associations. However, it is usually grazing induced and an indicator of disturbed sites [7,24,28]. In Montana pure stands of Baltic rush can indicate disturbance or wetter phases of the Baltic rush community type
. In overgrazed areas Baltic rush will replace Kentucky bluegrass, tufted hairgrass, and Nebraska sedge (Carex nebraskensis) [24,28]. On sandy, subirrigated rangelands Baltic rush can be replaced by balsam poplar (Populus balsamifera), quaking aspen (P. tremuloides), and willow (Salix spp.) .
 For a persuasive review that documents the disturbance-responsive nature of Muhlenbergia richardsoniis, see the section below (without the footnotes) of a report taken from the Forest Service’s own fire effects information website at http://www.fs.fed.us/database/feis/index.html
Mat muhly is common on disturbed sites, persisting but becoming less important in late seral stages. The relative abundance of mat muhly increased with the deterioration of tufted hairgrass (Deschampsia caespitosa) on overgrazed mountain rangeland in Wyoming and the Sierra Nevada[3,33]. On subirrigated and saline lowlands Montana, mat muhly increases in relative abundance with cattle grazing . Mat muhly tolerates competition but not dense shade. It is usually a minor constituent of undisturbed mountain meadows in the Sierra Nevada .
From fire effects information website (with references):
U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory (2003, January). Fire Effects Information System,
Response from USDA, USFS Pacific Southwest Region, Regional Office, R5, 1323 Club Drive, Vallejo, CA 94592, 707-562-8737:
File Code: 2200
Date May 14, 2003
Mr Todd Schuman, 49515 Brett Ave, Tehachapi, CA 93561
Dear Mr Schuman:
Thank you for your letter of concern over current seral indicator ratings for specific plant species in Forest Service rangelands in California.
Rather than speak to the individual species that you have concern over, I believe that I could better answer your questions and concerns by discussing what we are doing at a broader level.
In evaluating rangelands, and especially meadow systems, we are finding that the old theories of seral response due to changes in management are not providing us with reliable results. An example might be the presence of a Veratrum californicum dominated plant community considered a mid seral plant for most meadows. We know that by eliminating grazing and any other disturbance factor, Veratrum will not decrease and be replaced by late seral species. So in many cases the assumption that seral status will transition from stage to stage based on management changes just isn’t true.
Rather than looking at a species specific disturbance-response relationship, we are looking more at a plant community basis and using the data that we have collected over the past four (4) years to evaluate how these plant communities (rather than species) respond to management. Once we have identified natural breaks in plant community types, we can then look at how they respond on a functionality basis. If we understand how the community functions, then we can better understand whether it is a stable or unstable plant community and whether it will respond to changes in management.
There has been a lot of recent research on “State and Transition” modeling systems. We believe that the data we have gathered over the past 4 years can provide us with the basis for developing state and transition models for the Sierra Nevada meadow systems. Thru [sic] the development and use of these state and transition models, the arguments over whether one or two separate species are correctly placed in a seral stage will become mute [sic].
Again, thank you for your comments. I hope that this letter has answer [sic] your concerns.
Donald K Golnick, for Brent Handley, Director, Natural Resource Management
Response from Todd Shuman to Donald Golnick’s letter (on behalf of Region 5, USFS) above:
I consider the R-5 response that I received a “non-response”. The R-5 response refused to address the issues I raised in my letter and clearly refused to consider any modifications to the existing, indefensible system that will likely be even further enshrined in Sierra Nevada national forest plans. R-5 even refused to consider short-term modifications until a more defensible, scientifically-valid seral classification system is developed and incorporated into local R-5 area national forest plans. I was especially insulted by the claim implied in the letter that meadow areas with significant concentrations of increasers and exotics, categorically speaking, do not respond positively to reduced livestock grazing pressure. While this may be the case with Veratrum californicus, no documentary references or information were provided to bolster an argument that this claim applies broadly to meadows that are impacted negatively by significant concentrations of the plant species discussed above (at a level less than total or dominant colonization). I also wish to note that I have never exclusively focused my discussion of seral inflation on, or even primarily about, meadows completely or nearly totally dominated by the plant species I discuss above, in Appendix A, and the footnotes below. I am most concerned about undesirable plant concentrations in meadows that are less than total and which are more likely to be responsive to more restrictive grazing levels. R-5 USFS utterly failed to address these primary concerns in its reply.
Finally, I want to make one more point concerning the R-5 USFS response to the March 2003 seral inflation letter that I sent to R-5 USFS. In that letter, R-5 USFS implies that meadows dominated by increasers and exotics almost never regain a late seral, perennial, native species component, even if livestock grazing (which has usually caused the increaser/exotic dominance in the first place) is removed. (Such an implication appears to be R-5 justification for its unwillingness to revise its plant seral indicator list to remove seral inflationary biases). I wish to respond to this claim simply: wounds heal from the edges inward, and such healing may take a long time, but, in many cases, it can and does occur. In one case with which I am familiar, the perennial species line on an exotic plant-dominated area moved inward from the edge over a thirty year period after livestock grazing had been eliminated from the area. In other words, the cessation of livestock grazing in this area allowed the native perennials to start re-colonizing an area, as the native perennials slowly worked their way from the edges back toward the center of the area. (This was noted in a document written by a BLM biologist concerning an eastern Oregon BLM allotment, know as the Keating Highway Allotment*). I believe that the same type of phenomenon can happen on Sierra Nevada meadows increasingly (and unnaturally) dominated by Kentucky Blue Grass, Douglass Sedge, and other such species. However, this recovery process may often take a longer time frame to show results than the time frames used in the studies upon which R-5 USFS presumably relies to support its implied claim.
* The full quote and reference concerning this phenomenon is below and is quoted from Keating Highway Allotment #2108 Allotment Evaluation, Claude Treanor, Range Technician, 2/6/87:
"The 'perennial species line', or that point beyond which it is almost solid annuals, has slowly been moving into the annual area in the Lower pasture. Almost 30 years ago I visited the old gravel pit in the Lower pasture and this line was pointed out to me. At that time it was south of the pit and now it is at or beyond the pit, an advance of about 100 yards."
Again, this is one of the few documented references I know of that clearly illustrates a cheatgrass monoculture healing from the edges inwards, like any wound. I believe that the mechanism of succession outlined in this note (i.e. exotics replaced by native perennials over time) is relevant and likely to be similar in annual-increaser-exotic
dominated-range areas in the Sierra Nevada as livestock grazing pressures on such areas are decreased and eliminated altogether.