WRITTEN COMMENT #6: 



The Ecology Center, Inc. 



801 Sherwood Street, Suite B 

 Missoula. MX 59802 



(406) 728-5733 



(406) 728-9432 fax 



ecocenter(a),wildrockies.org 



March 13, 2001 



Kathy O'Connor Mike Thompson 



DNRC FWP 



2705 Spurgin Road 3201 Spurgin Road 



Missoula, MT 59804 Missoula, MT 59804 



Koconnor(astate.mt.us mthompson(5)state.mt.us 



Re: Blackfoot-Clearwater Wildlife Management Area Phase 1 1 Land Exchanges DEIS 



Dear Ms. O'Connor and Mr. Thompson; 



1 appreciate the oppormnity to comment on the Blackfoot-Clearwater Wildlife Management Area Phase II Land 

 Exchanges DEIS, on behalf of the Ecology Center and the Alliance for the Wild Rockies. While we support the 

 DNRC's initiative in consolidating ownership in order to protect large core areas of wildlife habitat, we are 

 concerned that this initiative will result in critical old-growth and fisheries habitat being turned over to Plum Creek 

 Timber (PCT) Company for extensive logging. The DNRC must act extremely cautiously in turning over DNRC 

 lands to private ownership. The ecological importance of these lands must be carefully considered, and monetary 

 land acquisition should be favored over land exchanges. 



Generally, we feel that the DNRC parcels are not optimal for exchange given the role they are providing for critical 

 wildlife habitat, water quality, and old-growth ecosystem attributes. The DNRC should consider offering alternative 

 parcels for exchange. Potential exchange parcels should not include water quality limited streams or cold water 

 fisheries. 



The DEIS fails to adequately detail the impacts of past logging on the PCT parcels in the cumulative effects 

 analysis. We are concerned with the soil compaction and erosion that may result from PCT logging the steep 

 parcels in the parcels proposed for exchange. The steep soils are a particular concern given the water quality limited 

 stream segments in the analysis area. The DEIS discloses the presence of steep soils: 



These DNRC parcels have more moderate to steep ground than the Plum Creek parcels offered for 

 exchange. These area moderately productive soils. Areas of steep slopes limit ground based equipment... 

 On all sites, the more sensitive soils have steep slopes >40%. (DEIS 3-36). 



Old Growth 



The DNRC proposes to exchange parcels including old growth forests despite the fact that these acres may be 

 needed to meet the SFLMP old-growth requirements (RMS-6). The DEIS present numbers for minimum DNRC 

 old-growth retention based on Lowensky data (1997) and subsequently concludes that the DNRC units involved in 

 the exchange currently possess old growth levels well above SFLMP requirements. The analysis is extremely 

 misleading in its failure to disclose that the adoption of historic old growth abundance levels in order to specify 

 means of complying with the SFLMP is currently being considered by the land board and DNRC and is a subject of 

 much public debate. The Lowensky (1997) conclusions regarding historic old growth levels lack consensus. 



BCWMA Land Exchanges Final Environmental Impact Statement 17 



