considered and results of these evaluations are contained in Appendix F. Evaluating specific future 

 logging activities for specific parcels was not done, because there is uncertainty in where, when and how 

 such activities could occur in the future. Thus, any analysis of this nature would have been quite 

 speculative and unhelpful. However we recognized in the analysis that Plum Creek is a private 

 corporation that manages timberlands for wood fiber production (DEIS p. 4-23 para. 7), and that 

 increased rates of harvest and forest canopy removal would be anticipated (DEIS p. 4-38 para. 3 and p. 

 4-42 para. 2). Evaluation of population structure for each of these species again, would be informative, 

 but was beyond the scope of this analysis. 



p. 4, para. 2 



In the Sensitive, Threatened and Endangered Wildlife Species analysis (Table 4. 7-1), potential for direct 

 or indirect effects was identified for four species deemed likely to be associated with the Lost Horse 

 parcels. These included the lynx, gray wolf, flammulated owl and boreal owl. We believe that the wildlife 

 analysis contained in the DEIS accurately portrays expected impacts to specialist species most likely to 

 be associated with habitats found on these parcels. Habitat values and corridor considerations were 

 evaluated for the Shanley Creek parcels, and we believe the effects assessments contained in Chapter 4 

 of the DEIS and Appendix F accurately portray the anticipated effects of the proposed alternatives. 

 Habitat evaluations and individual effects assessments for all species considered regarding the Lost 

 Horse and Shanley Creek parcels are contained in Appendix F (DEIS pp. F-39 to F-47). 



p. 4, para. 3 



There are some obvious and varying tradeoffs in the context of wildlife habitat under each of the 

 alternatives proposed for this project. Alternative A would block and protect the least amount of habitat 

 for a number of species. Alternative D would block up the most habitat and provide the greatest measure 

 of long-term habitat protection. Alternatives B and C lie in between. These are important considerations 

 that FWP and DNRC decision-makers must evaluate before a formal decision is released. Alternative D. 

 the preferred alternative, would provide greater habitat protection to multiple species at the cost of giving 

 up smaller habitat patches occurring on scattered parcels that would be exchanged. However small, 

 scattered habitat patches are more likely to serve as sink sources, have greater extinction rates, 

 contribute disproportionately to edge effect and increase detrimental effects risk to wildlife populations 

 attributable to inbreeding depression. Populations persisting in smaller isolated habitat patches are 

 generally those least likely to survive stochastic population crashes due to natural disturbance processes. 

 Habitat patches of ample size and populations well-distributed geographically are desirable and promote 

 population stability. However, in this case habitat patches on DNRC lands considered for exchange are 

 generally too small individually to provide for the life requisites of many species of concern. Expected 

 benefits of blocking up habitat with greater management emphasis for wildlife habitat into the future would 

 exceed the loss that would be realized due to exchange of the subject DNRC scattered parcels. We 

 believe that maintaining integrity of larger preferentially located habitat patches should be given strong 

 consideration over retention of small, isolated patches in managed landscapes. 



p. 5, para. 4 



We appreciate the support for the protection of large tracts of habitat. However, we also believe it is 

 important to objectively consider tradeoffs associated with exchanging small isolated parcels with lower 

 inherent probability of habitat function. None of the scattered DNRC parcels identified for exchange with 

 Plum Creek were identified as being crucial for any species of concern. We believe that we have given 

 the habitat values contained on these parcels an accurate and appropriate level of review that is required 

 for informed decision making. 



Reference: 



Ruediger, B., J. Claar, S. Gniadek, B., Holt, L. Lewis, S. Mighton, B. Naney, G. Patton. T, Rinaldi. J. 

 Trick, A. Vandehey, F. What, N. Warren, D. Wenger, and A. Williamson. Canada lynx conservation 

 assessment and strategy. USDA Forest Service, USDI Fish and Wildlife Service, USDI Bureau of Land 



BCWMA Land Exchanges Final Environmental Impact Statement 26 



