(page 2) 



The FEIS should more thoroughly address the fact that the amount of old-growth retention required under SFLMP is 

 currently being decided and that the Green et al. old growth within the project area could potentially be necessary to 

 meet the SFLMP requirements. While we appreciate the DEIS's discussion of the role of the parcels proposed for 

 exchange in a spatially explicit old growth distribution, we feet that the dismissal of their importance in an old- 

 growth reserve network is premature. 



While the parcels proposed for exchange to PCX by the DNRC include 633 acres of old stands and 150.3 acres of 

 Green et al. old-growth, the parcels proposed for exchange by PCT contain no old growth and 79.5 acres of old 

 stands (DEIS 4-29). Appendix D reveals the degraded nature of PCT offered lands: "Most old growth was logged 

 over 50 years ago and more recent selective cutting has occurred"(Appendix D-2). The discrepancy between the 

 DNRC and PCT offered lands is also apparent in the excess timber figures compiled in the summary of land 

 appraisal results (Appendix C-2). While the PCT offered lands have 0.8 MBF excess/acre and 2,458 MBF excess 

 overall, the DNRC lands have 3.7 MBF excess/acre and 10,236 MBF excess overall. These discrepancies resuh in 

 the total excess timber volume of DNRC lands having a value of $1,922,131 and those of PCT lands having a value 

 of $58 1 ,496. While we do not hold that the figure for "excess timber" is a reasonable categorization or that the 

 stumpage value of these trees should be considered in the absence of their ecological value, these figures do provide 

 a sense of the heavily logged nature of the forest on the PCT offered lands. 



The DEIS fails to analyze forest characteristics of the parcels proposed for exchange that are essential to wildlife 

 populations such as snags, structural complexity, and coarse woody debris. TTie FEIS must address whether any of 

 the proposed exchange parcels are within either inventoried or uninventoried roadless areas. 



Wildlife 



Given the dispersed nature and relatively small individual sizes of the parcels that the DNRC intends to transfer to 

 Plum Creek, it is critical that the DNRC analyze the ecological importance of these parcels on a landscape scale. 

 While some species may not use the analysis area extensively, the project area may provide habitat that is critical to 

 population viability of these species. Populations in the vicinity of the project area may ftinction as a 

 metapopulation; a population in which viability is maintained through the migration of individuals between patches 

 of habitat. While the individual patches may not be utilized as habitat consistently, their habitat integrity is essential 

 to the long term viability of the population (Hanski and Gilpin 1997, Hanski 1994). By failing to address the 

 importance of the parcels to landscape scale viability of species, the DEIS is in violation of the wildlife provisions of 

 the SFLMP 



It is essential to understand whether any of the parcel serve as either source or sink populations of wildlife species of 

 concern: 



The focus of viability analyses should be on biological populations; however, it is also important to 

 remember that few populations exist in demographic isolation. Some populations act as sources by 

 contributing immigrants to less stable populations, whereas others act as sinks by attracting individuals that 

 will be unable to survive. A collection of interacting populations, linked through dispersal, is known as a 

 metapopulation. It is especially important that cumulative effects analyses, which extend beyond the direct 

 effects of individual management actions, examine ecological consequences within the metapopulation. By 

 considering how management actions affect metapopulation structure, the analysis will further explore how 

 a proposed action affects the persistence of local populations (Ruggerio et al 1 994). 



Consideration of source/sink population dynamics is particularly important as Plum Creek lands encompass many of 

 the DNRC parcels proposed for exchange. As these surrounding PCT lands may be heavily logged and roaded and 

 contain degraded habitat, the intact DNRC lands may be an important source population allowing for the viability of 

 wildlife in the area. 



BCWMA Land Exchanges Final Environmental Impact Statement 18 



