(16 USF 1539 [a] and 1533 [d]). It is to be discouraged except to initially document 

 new county records at large populations, or for approved non-destructive collection 

 in conjunction with priority research. 



The largest one-time collecting of this species in Montana took place for collecting 

 five plants for chromosome counts (inflorescence and stalk). This initial Jefferson 

 County collection is documented by specimens at NYS and MONTU. The largest 

 Madison County occurrence was documented by a specimen at MONTU. The only 

 Beaverhead County occurrence is documented by a specimen at MONT. There is 

 only one Gallatin Co. occurrence which might be considered adequately large for 

 collecting a voucher specimen in the future, in keeping with conservation-minded 

 collecting guidelines (Montana Native Plant Society 1993), but it has not been 

 collected. Collecting of the Jefferson, Madison, and Beaverhead voucher specimens 

 was conducted under subpermit 95-39. 



Collection labels should not include location information beyond the township. 

 Location information for this species is treated as sensitive in Montana to protect the 

 species, its readily-accessible habitat, and the private property owners. Its element 

 occurrence printouts do not include location information beyond the tovmship, and 

 fine-scale GIS map products simply note its presence on the area of consideration 

 without showing location. 



This species is the showiest and among the most conspicuous in the local late-season 

 flora. Any activities which draw local attention to the Montana sites may elevate 

 collection pressure however innocent the motives. 



C. Disease, predation, or grazing: Almost all sites are currently used for cattle 

 grazing as part of a pasture rotation, and it appears that the persistence of the species 

 in Montana hinged on the presence of private rangeland. However, livestock were 

 not found in the pastures during the time of flowering, and grazing is considered to 

 have a potential impact under certain conditions. Late-season grazing and season- 

 long grazing correlate with low flower production (Arft 1995a), and any intense 

 grazing when soils are saturated has the potential to trample the species if not convert 

 the vegetation cover and intensify competition. The sites of two occurrences are idle; 

 one is a roadside right-of-way disturbance setting that is somewhat analogous to the 

 natural habitat, and the other is a small pocket of natural habitat surrounded by roads 

 and tamegrass plantings. 



Information on the nest requirements of the bumblebee pollinator is seriously needed, 

 along with consideration of the potential affects of grazing on the bimiblebee. 



D. Inadequacy of existing regulatory mechanisms: Only one of the ten populations 

 has statutory protection because it occurs on state lands administered in part with 

 federal highway fluids. 



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