no. 3061068 for a ten year term through February 28, 2006 (3.10.1, chapter 3- 38). Although the description of 

 grazing leases and licenses falls under the category of "social concerns", no accommodation is made for the 

 continuation of the grazing lease. In fact, the Department has expressly notified that landowner rights are limited to 

 the ability to apply for grazing leases with Plum Creek and that any leasehold would be subject to Plum Creek's 

 standard procedures for review for renewal and their grazing rate per AUM (4.10.1, chapter 4-59). This is contrary 

 to the original understanding of Monroe Property at the outset of the proposed exchange when it was advised that it 

 was likely that Plum Creek would be required to honor the remaining term of the leases. Apparently the "social 

 concern" was not of sufficient value to compel the state to negotiate such an arrangement with Plum Creek as the 

 proposed handling of renewal of future leaseholds now appears to be at Plum Creek's sole discretion. Nevertheless, 

 the property has been and is subject to a grazing lease which does generate income for the State Trust. Additionally, 

 this tract was apparently last logged in the 1930s. And the appraisal of the property suggests the presence of 

 significant timber and commercial excess timber value. See Table C-2, Parcel 6, Appendix C-2. Monroe Property 

 submits that the Woodchuck 



(page 7) 



Tract has the capacity to provide greater income to the trust on a stand-alone basis. In other words, Monroe 

 Property Company respectfully submits that if a future timber harvest is undertaken by the State itself, coupled with 

 grazing revenue - particularly on a tract with recreational potential and appreciating value, your Department is truly 

 hard-pressed to justify that it is going to do as well or better from a fmancial standpoint by including this tract in the 

 exchange. Consequently, for the foregoing reasons, the Woodchuck Tract should be excluded from the Blackfoot- 

 Clearwater Exchange. 



4. While the Woodchuck Parcel does not appear to teem with wildlife or rare and endangered 



species, the parcel is nevertheless not insignificant in that regard. The DEIS clearly documents that whitetail deer 

 occur on the parcel and that the parcel provides winter habitat (§3.2.3, page 3-5). Additionally, the property is 

 identified as habitat for the flammulated owl and the pileated woodpecker(§4.7, page 4-39). The DEIS notes that 

 "The greatest risk to flammulated owl and pileated woodpecker habitat on this parcel would occur under 

 Alternatives B and D, which would be likely to result in the greatest levels of commercial logging activity over time. 

 Future development of large trees and snags would likely not be prioritized in future management under these 

 alternatives. " While the State seeks to minimize the adverse localized and cumulative effects upon flammulated 

 owls and the pileated woodpeckers, there should be no question but that there should be no adverse effect upon 

 wildlife if the State maintains the property and properly manages it, balancing commercial harvest with habitat 

 needs. Again, Monroe Property Company is not trying to overplay the significance of the wildlife. Nevertheless. 

 coupled with the aforementioned reasons numbered 1 -3 for maintaining the tract as is and excluding it from the 

 exchange, the presence of wildlife worthy of preservation and/or protection provides further justification for leaving 

 this tract out of the exchange. 



For all of the foregoing reasons, Monroe Property Company respectfully submits that it is inappropriate to include 

 the Woodchuck Tract in the Blackfoot-Clearwater Wildlife Management Exchange. The tract should continue to be 

 owned by the State, enjoyed by the public, and grazed by Monroe Property Company. As noted, these statements 

 are submitted without waiving, in any respect, the claim of Mom^oe Property Company that it has been afforded 

 inadequate and inappropriate notice with regard to this Draft Environmental Impact Statement. Our client, Monroe 

 Property Company, as an interested person, asks that you respond in writing advising precisely how the Department 

 of Natural Resources and Conservation intends to treat these comments in terms of their application to the DEIS. If 

 you are not authorized to provide that written response, please forward my request to the 



BCWMA Land Exchanges Final Environmental Impact Statement 33 



