extensive Plum Creek logging of these lands at a landscape scale, granting carefully consideration to habitat needs 

 and population structure. 



We are concerned that the transfer of the Lost Horse Parcels to PCT may detriment a myriad of wildlife species. 

 The Lost Horse Parcels would be likely to loose their mature forest, which provides critical habitat for many species, 

 under PCT ownership. The mature forests may be particularly important as PCT ownership surrounds the parcels. 

 The EA states that "these old and mature stands also provide remnants of potential habitat for pileated woodpecker 

 (EA 4-47). We are also concerned about the potential loss of lynx and bear habitat and travel corridors on the 

 Stanley Creek Parcels. Despite their small size, the parcels may provide critical habitat among a sea of heavily 

 logged PCT lands. 



The EA summarizes the effects of the alternatives by stating: 



Alternatives A and C may help one or more locally valued populations of sensitive species persist for 

 longer in the future outside the BCWMA than they might under alternative B or D. However, the duration 

 of their persistence would be dictated to a greater degree by the future management of siurounding private 

 lands (EA 4-49). 



While it is essential that the DNRC strive to protect large sections of core habitat that will provide long term 

 viability of species, the DNRC should not abandon the viability smaller populations for the integrity of larger, core 

 populations. It is essential to have geographically varied populations of species in order to retain genetic integrity 

 and protect against stochastic population crashes due to natural disturbance processes. 



Water Quality and Fisheries 



We are concerned with the potential for the water quality of 303(d) listed streams to be degraded if exchanged to 

 PCT ownership. We are particularly concerned with the DNRC's intent to transfer ownership of the headwaters of a 

 303(d) listed WQLS of Bianchard Creek to PCT (EA4-50). A watershed analysis has determined: 



Existing levels of water yield increase in the North Fork and the mainstem of Bianchard Creek resulting 

 from past harvest activities were above recommended threshold levels. Chaimel conditions in the North 

 Fork of Bianchard Creek and portions of the mainstem are considered relatively imstable (EA 4-53). 



We are concerned that transfer of the DNRC's 40 acre parcel on Chamberlain Creek may augment the already high 

 water yield and degrade water quality in the recently de-listed 303(d) creek that supports bull trout and westslope 

 cutthroat trout (EA 4-55). 



The DEIS relies on proper implementation on BMPs by Plum Creek to avoid water quality impacts: 



It is likely that future timber harvest activities would be more intensive on the DNRC parcels acquired by 

 Plum Creek. However, the risk of direct and indirect impacts to water quality would be similar to current 

 conditions, due to Plum Creek's commitment to implementation of BMPs, strict adherence to the Montana 

 Streamside Management Zone Law and Rules, and implementation of its Native Fish Habitat Conservation 

 Plan (EA 4-51). 



The EIS must provide support that PCT has properly implemented BMPs and that these BMPs have been effective 

 at protecting water quality. We suspect that BMP failures and lack of proper implementation have led to degraded 

 water quality in the past. Further, the Plum Creek HCP has major shortcomings that fail to ensure the long-term 

 protection of native fishes and water quality. 



L 



BCWMA Land Exchanges Final Environmental Impact Statement 20 



