(page 3) 



The DEIS fails to adequately consider the exchanges impacts on demographics, habitat, and disturbance for each 

 affected species. Particularly, lacking is a discussion of population demographics (i.e. population trends over time). 

 An understanding of population demographics in essential to meeting the wildlife requirements of the SFLMP. 



The DEIS fails to analyze the impacts of the project on exacerbating forest fragmentation. The EIS should analyze 

 the impacts of the proposed project on wildlife core habitat and connectivity. Habitat fragmentation may result in 

 smaller and more isolated wildife populations, particularly for species such as lynx and gray wolves with demanding 

 habitat needs. Smaller populations are more vulnerable to local extinction, due to stochastic events (Gilpin and 

 Soule 1986). Smaller populations are also more susceptible to the negative effects of inbreeding depression. Hence, 

 maintaining landscape connectivity is essential to allowing for the replenishing of populations and expansion of the 

 gene pool (Noss 1983, 1987, 1992, Noss and Harris 1986, Craighead and Vyse 1995, Paetkau et. al. 1997, Beir 

 1993). 



The DEIS does not adequately analyze the value to old growth species from mature stands on DNRC lands. The 

 DNRC parcels likely contain many of the structural characteristics of old growth, the presence of which determine 

 the ability of an area to provide habitat to old-growth dependent species. Old growth attributes that may be present 

 on the parcels and imperiled by the exchange include high levels of structural complexity, abundant snags and down 

 woody debris, and nutrient rich and lush soils. 



The DEIS fails to adequately consider the impacts of the proposed project on the ability of the area to serve as a 

 biological corridor for wildlife species. A court ruling, Marble Mountain Audubon v. Ricey (No. 90-15389, D.C. 

 No. CV89-170-EJG, Sept. 13, 1990) interprets NEPA to require the Forest Service to consider biological corridors. 

 The standard for such a review is the same "hard look" NFPA requires of other environmental effects. 



Population viability analysis has suggested that each of the core ecosystems of the Northern Rockies is not 

 sufficiently large to support viable populations of many wildlife species, including grizzly bears, independently. 

 Thus, the presence of wildlife movement corridors is essential for the long term population viability of grizzly bears, 

 and the many other species for which their strict habitat requirements serve as an umbrella (Bader 2000a; Bader 

 2000b). 



The DEIS analysis of the exchange's impacts on grizzly habitat and movement corridors is inadequate. Habitat 

 fragmentation throughout the Northern Rockies has forced grizzlies to assume a metapopulation structure, where a 

 network of habitat patches undergo local extinction and recolinization while the network of patches retains a viable 

 population (Bader 2000a). Due to the grizzly metapopulation structure, infrequently utilized patches of habitat, such 

 as those in some of the Phase II land exchange parcels may be essential to the population viability of grizzlies. 

 Recently, a study of grizzly spatial needs has found that a viable population of grizzlies in the Northern Rockies 

 requires 147,883 km" - 184, 919 km" of habitat. These spatial requirements far exceed those provided for by the 

 USFWS recovery strategy for grizzly bears (Bader 2000b). Hence, any projects that degrade bear habitat should be 

 considered a threat to population viability for grizzly bears. 



The lynx analysis in the DEIS is inadequate and in violation of the Lynx conservation assessment and strategy. A 

 Lynx LAU attempts to reflect habitat use by lynx. The fact that the parcels do not overlap a formal lynx LAU does 

 not preclude the project from impacting lynx. The Lynx BO explicitly states that even if a project area is located 

 outside of a LAU, the lynx conservation strategy and agreement requires that habitat connectivity between lynx 

 analysis units be maintained. Thus, the EIS must analyze project effects on lynx connectivity in order to comply 

 with the LCAS. 



(page 4) 



We are concerned with the high number of sensitive, threatened, and endangered species that are present on parcels 

 offered to PCT by the DNRC. Species with the potential of being detrimented include bald eagle, lynx, gray wolf 

 grizzly bear, flammulated owl, boreal owl, black-backed woodpecker, pileated woodpecker, fisher, peregrine falcon, 

 and townsend's big-eared bat (EA 4-43). The EIS should analyze the impacts to these species that would result from 



BCWMA Land Exchanges Final Environmental Impact Statement 19 



