(page 5) 



The fisheries analysis is based upon unfounded assumptions that the Plum Creei< HCP will serve to protect habitat 



for and populations of cold water fisheries. The flaws of the Plum Creek HCP include the following: 



The HCP is essentially a bull trout conservation plan that was extended to include other fish species without 



addressing particular species needs and attributes. 



The HCP fails to describe "take" for each candidate species. 



The HCP includes a "no surprises" provision that may prevent actions essential to allowing for the recovery of 



fisheries. 



The HCP lacks sufficient measurable standards to determine whether the HCP is being effective at protecting 



fish populations and habitat. 



The HCP was developed in the absence of a USFWS bull trout recovery plan. 



As the HCP is insufficient to ensure the protection of bull trout, westslope cutthroat trout, and other fish populations, 

 the transfer offish bearing streams to Plum Creek ownership may be detrimental to populations of these species. 

 The DEIS unreasonably relies on the Plum Creek HCP to: 



1 . Reduce sediment delivery from roads to below baseline conditions. 



2. Abandon unneeded roads 



3. Increase canopy cover in timber riparian stands 



4. Provide adequate levels of large woody debris 



5. Restore essentially all fish passage where it is currently restricted by road culyerts 



6. Restore riparian vegetation (EA 4-55). 



We are concerned that the DNRC would exchange parcels to PCT including 4.1 miles of streams supporting 

 westslope cutthroat trout and 1 .3 miles of stream supporting bull trout. In return, the DNRC would only acquire a 

 2. 1 miles supporting populations of WCT and bull trout. 



Appraisal and Economics 



Losses in ecosystem integrity (including species, ability to provide ecosystem services, and levels of biodiversity in 

 the project area) should be incorporated in the economic analysis. We are concerned that even in the absence of 

 considering losses in ecosystem integrity, the total value of DNRC lands proposed for exchange is estimated to be 

 $4,162,000, while those of PCT are estimated at $3,815,000 (EA C-2). 



In summary, while we support the protection of large tracts of core habitat, we fell the consolidation of these large 

 tracts should not be to the detriment of smaller parcels of important habitat. The parcels proposed for exchange 

 provide essential bull trout, WCT, grizzly, lynx, wolf bald eagle, and old growth dependent species habitat. The 

 DNRC should consider offering less biologically crucial parcels to exchange with PCT. Before proceeding with an 

 exchange, it is critical that the DNRC consider the role of the offered parcels in landscape scale populafion dynamics 

 and population needs of species. 



Thank you for considering our comments. 



Sincerely, 



And of behalf of 

 Lauren Buckley Ryan Shaffer 



Ecosystem Defense Alliance for the Wild Rockies 



The Ecology Center PO Box 873 1 



Missoula, MT 59807 



BCWMA Land Exchanges Final Environmental Impact Statement 21 



