Comment: The Bull subarea is situated many miles from the rest of the lands being considered for exchange. It should be considered on its own merits. No matter how environmental impacts balance out throughout the proposed exchange area, the draft environmental impact statement makes clear that they would be decidedly harmful to wildlife in the Bull subarea (351-3).
- Response: The effects to the various wildlife species, LOS, and mule deer winter range were analyzed on a subwatershed basis. While the Proposed Action would result in conveyance of habitat to CP in the Bull subwatershed, the Proposed Action is not expected to reduce species viability. Additional discussion is included in the Final EIS (Chapter 3 - LOS and Mule Deer Winter Range). The intermixed ownership pattern in this area is inconsistent with the purpose and need (DEIS, p. 5).
Comment: It is of great concern that wildlife management has been limited to reactions to declining populations of specific species. In other words, nothing is done until a problem is noted. It seems a better approach would be to prevent wildlife reductions expected by human activities and interference. In spite of the presumption in the DEIS that expanded land holdings will enable better ecosystem management, I question the costs to wildlife when adapting to new patterns. Common sense dictates that traditional logging activities in the area that for decades has not been subjected to them will shock wildlife (379- 4).
- Response: Natural resource management (including wildlife) has shifted the emphasis from single species management to managing ecosystems or landscapes. The intent of the proposed land exchange is to consolidate public ownership to better enable the NFS to manage broader areas in a consistent manner to meet resource needs. One of the primary objectives is to prevent wildlife reductions caused by human activities and interference. In the short term, conveyance of land to CP may have detrimental effects to certain species (see the effects discussion in Chapter 3 of the FEIS). Over the long term, NFS management is expected to better meet habitat requirements of wildlife species by providing consistent management strategies over larger areas of the landscape. The consolidation of land in public ownership would be more effective in moving forest conditions to a more desirable pattern of forest structural stages and composition. Both the Forest Service and Crown Pacific conduct logging activities.
Comment: Numbers reflecting net "gains" in habitat are misleading. The document shows a net gain in habitat for the northern goshawk of 702 acres (p. 49). We find this hard to believe considering that the northern goshawk is a MIS for ponderosa pine (p. 48) and the net loss of public LOS ponderosa pine by this exchange is 2,380 acres (p. 25). Net gain for the northern three-toed woodpecker is described as 1,032 acres (p. 49). The northern three-toed woodpecker is a MIS for LOS lodgepole pine (p. 48) of which the public will lose a net 973 acres of (p. 25) by this proposed exchange. (3126- 2)
- Response: Explanations of acreage figures are found in the Draft EIS (pp. 21 and 48-49). To interpret the numbers reflecting net gain or loss in public ownership of habitat, it is important to understand the source of the data and what the numbers represent. Habitat acreage figures for LOS associated species were obtained from the Wildlife Report prepared by Norman L. Behrens and Edward W. Styskel. Behrens and Styskel estimated habitat suitability based on timber volume and tree species composition.. The figures in the Draft EIS include all habitat types (seral stage and tree series) that these species may use during the course of their life history, not just the amount of a particular tree series (i.e. ponderosa or lodgepole pine) that meet the criteria for LOS. The LOS stand data was obtained from several sources including the Deschutes National Forest large tree mapping project, the Fremont National Forest old growth mapping project, timber cruise data, and suspected old growth tables provided by Styskel and Behrens. LOS stand data represents only the stands that have the structural characteristics (number of trees of a specified diameter) of each tree series to be considered LOS. Using the northern goshawk to illustrate the difference: the goshawk is used as a management indicator species for ponderosa pine because it commonly utilizes ponderosa pine. The goshawk is also found in mixed conifer and lodgepole pine forest types. The acreage figures for potential goshawk habitat include all the forest types and seral stages that the goshawk would utilize (ponderosa pine, mixed conifer, lodgepole pine) while the LOS structure figures only include the acreage of each of these forest types that have the number of trees per acre meeting the specified diameter.
Bald Eagle Comment: My concerns are based on the fact that bald eagles are known to use the Tumalo Reservoir area year-round and that there could be a nest site or communal roost on those lands. Consequently, I believe it is inappropriate to conclude that there is no effect on the bald eagle as is done on pages 3 and 14 of the Biological Evaluation. I have studied bald eagles in Oregon since 1979 and have collected many reports of bald eagles within 10 miles of Tumalo Reservoir (1058-1). Other comments discussing bald eagle sightings: 2017-2, 2026-1.
- Response: The Biological Evaluation (BE) has been revised to reflect that there have been sightings of bald eagles year-round in the Tumalo Reservoir area. The conclusion of the BE is that the Proposed Action MAY EFFECT BUT IS NOT LIKELY TO ADVERSELY EFFECT the bald eagle. The conclusion is consistent with the Deschutes National Forest 1997 programmatic Biological Assessment (BA) in which formal consultation with the U.S. Fish and Wildlife Service was conducted. Informal discussions with the USFWS regarding the reported sightings support the conclusions of the BE and BA.
Comment: Historically, bald eagles nested at Shevlin Park. That site has not been used since 1987. Reports since 1987 suggest that the pair may have moved to an unknown location within the Tumalo Creek drainage. The Tumalo Reservoir area would be a likely nesting site based on observations of bald eagles nesting at other locations in Central Oregon. Since nest sites can be several miles from foraging areas, a nest could be located on any of the lands proposed for exchange. I suggest that the Tumalo Reservoir area be searched thoroughly for bald eagle nest or communal roost sites before land within 5 miles of the reservoir is exchanged (1058- 2).
- Response: A biological evaluation was completed. The conclusion is that the proposed action may effect but is not likely to adversely affect the bald eagle. Field surveys are not needed to make a finding of effect.
Comment: Page 14 of "Appendix C Biological Evaluation for Wildlife" indicates that there are "no current nests or sightings" of bald eagles recorded. This statement is incorrect. There have been sightings of bald eagles at Tumalo Reservoir. These observations indicate the need to conduct field studies of the threatened or endangered wildlife that may use the publicly owned lands affected by this exchange- including bald eagles. I ask that these field studies be completed and the results taken into account before the exchange is implemented (2005- 1).
- Response: The Biological Evaluation (BE) has been revised to reflect that there have been sightings of bald eagles year-round in the Tumalo Reservoir area. Formal consultation was conducted with the USFWS for the Deschutes National Forest Programmatic Biological Assessment, which included the land exchange. Informal discussions with the USFWS regarding the reported sightings support the conclusions of the BE and BA. Field surveys are not needed to make a finding of effect.
County Zoning Comment: I do not understand how an area can be a migration area protected by the Forest Service one day and logged by a timber company the next! We were only allowed to build on the front 1/3 of the property to protect this area. Will we be allowed to build at the back now? (114-2)
- Response: The Forest Service does not provide special protection of migration areas in the LaPine migration corridor. This area is within the General Forest land allocation described in the Deschutes NF Forest Plan. The General Forest land allocation emphasizes timber production while providing some other uses. Retaining this area in public ownership would not guarantee that timber harvest would not occur. The lands around the Ponderosa Pines subdivision are zoned by the county as Forest Use F-1 and have an overlying Wildlife Area combining zone, as described in the Deschutes County Comprehensive Plan. Zoning provisions include dimensional standards for land divisions and lot sizes; siting standards for dwellings; and fence standards to allow for wildlife passage. County zoning provisions would apply to lands acquired by CP just as they do to lands in the Ponderosa Pines subdivision.
Comment: I cannot put buildings on the back portion of my ten acres because of the wildlife migration route. I also cannot erect any type of fence that could be a barrier to wildlife migration (1066-4, 253- 3, 145-1, 1048- 1)
- Response: The lands around the Ponderosa Pines subdivision are zoned by the county as Forest Use F-1 with an overlying Wildlife Area combining zone. Zoning provisions include dimensional standards for land divisions and lot sizes; siting standards for dwellings; and fence standards to allow for wildlife passage (chapter 18.88 Deschutes County Comprehensive Plan). County zoning provisions would apply to lands acquired by CP just as they do to lands in the Ponderosa Pines subdivision.
Comment: In the Toast and Sellers subwatersheds there would be a net loss of 19,743 acres of publicly owned migration corridors. Nowhere does the Draft EIS discuss the relative importance of these corridors, nor the level of mortality that would result. (376-7)
- Response: The Final EIS (Mule Deer Winter Range section) contains additional discussion regarding the importance of migration corridors in the Sellers and Toast subwatersheds and the anticipated effects of the Proposed Action. Regardless of ownership, mule deer are expected to continue using these areas.
Elk Comment: The DEIS, p. 72, states the indirect and cumulative effects of the NFS acquiring significant elk habitat, but does not address the indirect and cumulative effects of the loss of significant elk habitat. (2008-15)
- Response: The indirect and cumulative effects of the loss of significant elk habitat are discussed in the Final EIS (Chapter 3 - wildlife).
Comment: What impact would Crown's uneven-aged management philosophy have on elk and elk habitat? The same question applies to deer. (1069-15)
- Response: The effects of CP's management, including their uneven-age management philosophy, on deer and elk are discussed in the Final EIS (Chapter 3 - Mule Deer Winter Range and Wildlife sections).
Comment: Elk movement on the rest of the exchange does not disclose the effects to elk movement across the landscape, calving, thermal, hiding and foraging habitats. Acres exchanged do not equate to effects to the animals. (342-7)
- Response: Additional qualitative discussion describing the effects to elk and elk habitat is provided in the Final EIS (Chapter 3 - significant elk habitat).
Fencing Comment: It is very likely that Ponderosa Pines will be fenced out of the surrounding timberland which includes affecting deer and other animal migration. (27-3, 390-3, 430-2, 1035-3)
- Response: Crown Pacific has publicly stated that they do not intend to fence their lands. In addition, they recently developed a proposed "Ponderosa Pines Community Interface Management Area" plan. This plan states that CP would not build fences within or adjoining the CP/Ponderosa Pines interface area.
Comment: Fencing would keep wildlife from their natural habitat. (41-4, 155- 3, 253-3, 1024-1, 3123-2, 93-5, 101-2, 120-2, 144-1, 142-1, 1041-1, 1053-1, 317- 1, 298-3, 279-2, 60-2, 1020-1, 1054-1)
- Response: Fences can, and sometimes do, injure or kill wildlife. They can also be a barrier that some wildlife species cannot or will not cross. Pronghorn antelope are a good example. However, most wildlife species are able to go under, through, or over fences. Although fences would hinder the movement and possibly injure some wildlife they are not expected to keep wildlife from their habitat. Crown Pacific has publicly stated that they do not intend to fence their lands. In addition, they recently developed a proposed "Ponderosa Pines Community Interface Management Area" plan. This plan states that CP would not build fences within or adjoining the CP/Ponderosa Pines interface area. Crown Pacific has also proposed a similar management area plan for lands near Jack Pine Village.
Comment: The fencing of private land interrupts the migration of mule deer (68- 1, 53- 3, 45- 2, 79-1, 96- 3, 107-3, 112- 2, 133- 2, 139-4, 145-1, 1010- 1, 1034- 4, 1040-3, 1054-1, 3119-4, 1035-3)
- Response: Deer readily jump over fences. Fences may cause occasional injuries but they would not interrupt or deter migration. In the Wildlife Combining Area (migration corridor near LaPine), county zoning restricts the type of fences that can be built on private lands.
Guzzlers Comment: There are several guzzlers on the Crescent Ranger District which will become Crown's if the exchange goes through. Will Crown continue to maintain these guzzlers or will they not be maintained? The impacts need to be disclosed in the FEIS (maintaining or not maintaining). Please disclose what Crown intends to do with conveyed guzzlers and the impacts to wildlife species, especially big-eared bat. (370-9)
- Response: CP intends to maintain the acquired guzzlers and discuss habitat protection measures around guzzlers with the Oregon Department of Fish and Wildlife (pers. comm. Ted Young). Currently, wildlife guzzlers within the Crescent Ranger District boundary, including guzzlers on CP lands, are maintained by volunteers of the NFS. Assuming that guzzlers will be maintained by CP or volunteers of the NFS, the effects to wildlife including the big-eared bat are expected to be negligible. Guzzlers would continue to provide a source of water for wildlife species.
Habitat Comment: The issue around old growth ponderosa pines is greatly exaggerated. Even with the errors that can be challenged, the amount of acres or board feet involved is less than 1% of the total old growth ponderosa pines in the Deschutes National Forest. (267-4)
- Response: Old growth (LOS) stands are a valuable habitat type that cannot be accurately represented by board foot estimates. Board foot or volume figures do not represent stand structure or measure important old growth characteristics such as snags or down logs. A stand with abundant small diameter trees could have the same number of board feet or volume as another stand meeting LOS criteria. While the board foot estimates might be the same, the habitat characteristics would not. The Proposed Action would convey to CP approximately 2% of the LOS ponderosa pine on the Deschutes NF.
Comment: Crown Pacific tends to practice uneven-aged management so while the densities of large size class trees might by less than under Forest Service management, the overall structural characteristics will continue to be present and therefore much of the potential for diverse wildlife habitat will remain intact as well. (305-5)
- Response: It's agreed that uneven-aged management by CP would provide diverse wildlife habitat. Timber management does reduce stand structural characteristics preferred by many species of wildlife, particularly those associated with LOS conditions. The FEIS contains additional discussion on the anticipated effects to wildlife (Chapter 3).
Comment: Crown Pacific routinely addresses the needs of wildlife when conducting forest operations. Crown Pacific's management activities with regard to sensitive birds and threatened and endangered species are regulated under the Oregon Forest Practices Act. (312-4)
- Response: It was acknowledged in the DEIS that CP management is regulated by the Oregon Forest Practices Act. The Oregon Forest Practices Act provides much less protection than Forest Plan standards and guidelines and management policies that the NFS operates under.
Comment: The impact on wildlife habitat and migration corridors is greatly misrepresented. The wildlife could care less if it is owned by the NFS or Crown Pacific. (267-6, 367-1, 169-2, 286-4)
- Response: The FEIS contains additional discussion regarding the effects to wildlife habitat, migration corridors (Chapter 3 - Mule Deer Winter Range), and significant elk habitat (Chapter 3 - Wildlife).
Comment: Why should Deschutes National Forest suffer a loss of 10,665 acres of migration corridor and Dorrance 2938 acres around Ponderosa Pines?(388-12, 389- 12)
- Response: On a landscape scale, the Proposed Action would result in a net loss in public ownership of 481 acres identified by ODFW as migration corridors. When viewed at the local scale, the direct effect of the Proposed Action is a net loss in public ownership of 10,665 acres of migration corridors on the Deschutes NF; a net gain in public ownership of 4,122 acres on the Fremont NF; and a net gain in public ownership of 6,062 acres on the Winema NF. The Winema NF would only acquire land in this exchange.
- The loss in public ownership of migration corridor habitat in the Sellers and Toast subwatersheds is not expected to adversely affect mule deer migration. Mule deer currently utilize both NFS and CP lands in this area during both migration and summer periods.
- Loss in public ownership of lands in the La Pine migration corridor (Dorrance subwatershed) would eliminate the ability of the NFS to manage public lands in order to provide migration corridors for big game. Currently, dense lodgepole and ponderosa pine stands provide potential pathways and refugia for big game during migration and summer periods. Elimination of public lands from these areas could result in land management activities which reduce hiding cover abundance and quality, and big game use of these areas. Loss of hiding cover in combination with the residential development on adjacent lands would have an adverse effect to migrating big game animals in this area.
- The modifications to the Proposed Action alternative described in the ROOOD respond, in part, to comments received from ODF&W, by retaining some higher quality big game winter range for the Tumalo herd.
Comment: Page 29 Migration Corridors: Paragraph one describes "net loss" as the real effect. I believe this term isn't accurate since deer won't stop using the lands/corridor just because of ownership changes. (1069-10, 1069-13)
- Response: The use of the terms "net loss" and "net gain" throughout the Draft EIS refers to loss or gain of land in public ownership. It is agreed that deer will not stop using lands or corridors because of ownership changes. Refer to the Mule Deer Winter Range section of the Final EIS for a more thorough discussion of the effects.
Comment: In regards to LOS stands, much of the discussion seems to center on the reduction of habitat for wildlife species on the lands to be acquired by Crown Pacific, with little attention being paid to the conversion of the lands acquired by the NFS to those with LOS characteristics. Simultaneously, no one seems to have paid much attention to the flourishing population of these wildlife species on the Crown Pacific lands as they currently exist under their management scheme. (17-3, 1069-12)
- Response: CP lands are expected to provide diverse habitat for many wildlife species. However, uneven-aged management by CP is not expected to provide the habitat preferred by LOS associated species. Timber management by CP is expected to reduce stand density and structure preferred by this group of species. Individual tree selection is expected to reduce the abundance of declining trees and potential snags and down wood utilized by these species for nesting, roosting, and foraging. The conversion of lands acquired by the NFS to stands meeting LOS criteria was identified as a beneficial effect (Draft EIS, p. 24) of the proposed exchange.
Comment: Wildlife need a combination of habitat types for food, shelter, escape, etc.. This combination is well served by the intermixing of public land and private tree farms. Although the math appears that wildlife are gaining acreage by this swap, in reality the parcels removed to private ownership are now open for human development. By maintaining the present mix of private and public lands, the available habitat is not the net change, but the sum of acreages. (13-6)
- Response: It is generally true that wildlife need a combination of habitat types and this is served by the intermingled nature of public and private lands. This combination can also be provided on lands with single ownership. The variety of plant associations and seral stages on both private and public lands can meet the habitat requirements of many species. The problem with intermixed ownership is that it is not possible to achieve habitat objectives for some wildlife species, particularly those associated with LOS stands or that have large home ranges. Differing management practices on private and public lands sometimes reduce the effectiveness of habitat for these species by increasing fragmentation and decreasing connectivity. Intermixed ownership can isolate particular habitat types and reduce the effectiveness of this area for species. Mixed ownership also makes it necessary to maintain higher open road densities than would be required under a single ownership, increasing disturbance and vulnerability of wildlife species. The available habitat is the sum of the ownerships, both now and if the exchange occurs.
Comment: This area is home to deer, elk, bear, raccoon, coyote, and many other animals. The transfer of this area to private ownership would surely mean it would be logged and the loss of this habitat. (80-1, 81-1, 320-2, 274-1, 275- 1, 334-1, 1020-1, 285-1, 284-1, 1037-2, 1030-1)
- Response: Lands acquired by CP would most likely be harvested at some time in the future. Timber harvest would most likely return late seral stands in the area surrounding Ponderosa Pines to an early or mid seral condition, with some large trees. While timber harvest would reduce the suitability for species of wildlife that prefer or require late seral conditions (northern goshawk, great gray owl, black-backed woodpecker) these areas would be utilized by species that prefer early or mid seral conditions (deer, elk, coyotes).
Comment: The document does not disclose the environmental consequences for the action alternative on Crown Pacific lands. What will be the impact on wildlife habitat and biodiversity? (380-9)
- Response: The Draft EIS (Chapter 3) discloses the expected effects to wildlife habitat based on the assumption that CP would continue to manage for timber production as guided by the State Forest Practices Act. The Final EIS contains additional discussion of the anticipated effects.
Comment: The Confederated Tribes of Warm Springs Reservation of Oregon (CTWSRO) have reviewed the above proposal for the exchange of lands, a portion of which are within the CTWSRO's ceded area. We believe that the exchange should be structured to avoid any net loss of old-growth habitat, big game habitat, and wildlife corridors. (369-1)
- Response: The current proposal is a result of negotiations between the Forest Service and CP. It has 30,000 fewer total acres: 4,214 fewer acres of old growth (LOS); and 5,292 fewer acres of mule deer winter range than the original proposal. The conveyance of old growth and LOS habitat were considered to be key issues and part of the reason for preparing an EIS.
Comment: We are concerned about the loss of big game habitat values in the Bull and Dorrance subwatersheds through private timber practices or residential development. (338-3, 338-9)
- Response: Big game habitat values and the effects of the Proposed Action in the Bull and Dorrance subwatersheds are discussed in the Draft EIS (pp. 28-29) Additional discussion of effects is provided in the Final EIS (Chapter 3 - Mule Deer Winter Range).
Comment: We are concerned about the loss of wildlife habitat in general due to less vegetative vertical structure, snags, and down woody material on Crown Pacific lands, along with more habitat fragmentation caused by roading. We recommend the FS reassess the wildlife habitat values (DEIS 3-WL-5 p.50 and 3- WL-6 p. 53) of the exchange lands, particularly the large tree and snag components. (338-7, 338-10)
- Response: The large tree component was re-evaluated. The current information is included in the Final EIS (Chapter 3 - LOS section). Data on snag and down wood levels is not available. It was assumed when analyzing the effects of the Proposed Action that CP lands had low levels of snags and down wood as a result of intensive timber management. Likewise, it was assumed that CP management of acquired parcels would result in lower levels of snags and down wood.
Comment: We are concerned about the increase in road densities resulting in loss of mule deer habitat, loss of mule deer through poaching, reduced mule deer escapement and survival, reduced habitat effectiveness, increased forest fragmentation, and ultimately reduced recreational use. (338-5)
- Response: The acquisition of CP lands would result in localized areas of high open road densities which would increase disturbance and vulnerability of wildlife species and increase habitat fragmentation. Overall, the Proposed Action would result in a slight increase in open road densities on NFS lands within most subwatersheds, showing an average increase of 0.1 to 0.2 miles per square mile (Draft EIS, pp. 89-90). Under a consolidated ownership pattern, the Forest Service will be better able to manage its transportation system and reduce road densities. In addition, the Forest Service is in the process of developing a new road policy. The long-term objective is to provide the minimum forest road system that best serves the current and anticipated future management objectives and public uses of the NFS.
Winter Range Comment: Page 26 Mule Deer Winter Range No Action: Paragraph one implies Crown Pacific won't or doesn't cooperate with Oregon Department of Fish and Wildlife. A more accurate depiction of the past history of private forest land owners work with the Department is in order. (1069-9)
- Response: The Draft EIS (p. 26) acknowledged that CP cooperates with the Oregon Department of Fish and Wildlife for the closure of roads during winter periods. Other cooperative work between CP and ODFW, such as the green dot road closure system during big game hunting seasons, was not discussed because it is outside the scope of the mule deer winter range issue.
Comment: A statement in the Draft EIS (p. 29, paragraph 1) referring to " quality of winter range in the Bull subwatershed is expected to decrease as a result of intensive timber management by Crown Pacific" is entirely false in my opinion. (352-4)
- Response: The Final EIS contains additional discussion regarding mule deer winter range. In general, timber management reduces the quantity and quality of hiding and thermal cover by reducing stand densities and structure. Reduced cover places higher energetic demands on deer during harsh weather conditions. Skidding and slash disposal activities also reduce the amount of bitterbrush while increasing the production of herbaceous species. Bitterbrush is a critical forage species during the winter period as it maintains higher nutritional value than herbaceous species.
Comment: Just because the land changes ownership does not mean the mule deer are going to switch where they habitat. Those animals are going to continue to stay where they are no matter who owns the acres they are dwelling on. The NFS is not the only land owner who has done extensive cooperative work to improve winter range and the populations that inhabit them! Specifically, a major part of the Bull subwatershed is currently owned by Crown Pacific and supports a vibrant winter range habitat now. Intensive timber management has occurred here for years, with no significant adverse effects on the deer populations. (17-4)
- Response: The FEIS contains additional discussion on mule deer winter range (Chapter 3 - Mule Deer Winter Range).
Comment: NFS land in the Bull subwatershed is very important to wintering mule deer, particularly during severe winters since it is some of the low elevation land that remains within the Tumalo winter range. Trading or selling this land to a private party could result in the loss of these habitat values. The State Forest Practices Act, which Crown Pacific operates under, does not provide standards for elk and mule deer habitat protection. (338-8, 339-8, 1055-6, 3124-3, 2008-14, 2028-2)
- Response: The Draft EIS acknowledged the importance of the winter range in the Bull subwatershed and that private ownership could result in the loss of some of these habitat values (pp. 28-29). The Final EIS contains additional discussion on mule deer winter range (Chapter 3 - Mule Deer Winter Range). CP cooperates with the Oregon Department of Fish and Wildlife for the closure of roads during winter periods; Other cooperative work between CP and ODFW includes the green dot road closure system during big game hunting seasons.
Comment: Page 28 - Winter Range - There is no discussion on habitat quality and the effects to wintering animals. Acreage exchanged does not equate to effects on the animals. Page 29 - "Crown Pacific management of winter range included in the County Comprehensive Plans would comply with state and
local ordinances". Timber management does not equate to suitable winter habitat. (342-3)
- Response: The quality of winter range in the Bull subwatershed was discussed in the Draft EIS (p. 28). The quality in the Bull subwatershed was discussed because of the large quantity (3,594 acres) of winter range being conveyed to CP this area. The quality of winter range in the other affected subwatersheds was not discussed because 1) lands within the winter range were only being acquired, 2) the lands to be conveyed to CP made up only a small percentage of the respective winter range, and 3) the quality of the winter range is not known in the other areas. It was assumed that the acquisition of winter range would be beneficial in the long term. Knowing the quality of winter range in the other parcels to be conveyed would not have made a difference in describing the effects to wintering animals since these areas make up only a small portion of the respective winter range.
Wolverine Comment: Page 64 - The land exchange does not disclose the effects of connectivity on wolverine and their desire for remote habitats. (342-6)
- Response: The Biological Evaluation discusses the expected effects to the California wolverine and its habitat; implementation of either alternative is not expected to impact the wolverine or its habitat. Given the wolverines large home range and habitat requirements, it is suspected that the direct effects of the land exchange on wolverines will not impact the species. However, short-term effects to habitat connectivity because of the open road density may impact wolverine movement. The cumulative effects by consolidating land ownership, may provide more continuous habitat for species movement.
- Two wolverine sightings have occurred within the project area; both sightings were located on Crown Pacific lands.
White-headed Woodpecker Comment: The Oregon Department of Fish and Wildlife (ODFW) is greatly concerned about the loss of 3,500 plus acres of Late and Old Structured (LOS) ponderosa pine wildlife habitat as proposed by the land exchange. ODFW contends that viability of the white-headed woodpecker, a ponderosa pine LOS dependent species listed as Sensitive - Critical by ODFW, will be affected by the proposed land exchange. This concern is based at least in part on findings of the Interior Columbia Basin Ecosystem Management Project's Science Integration Team's findings. (no number assigned because comment was received after Jan. 9, 1998)
- Response: The white-headed woodpecker is not a listed species under the ESA, nor is it proposed to be listed under the ESA. It is not a Regional Forester Sensitive Species. Also, it does not represent a management indicator species. These various ";status" lists are indicators of concern over viability.
- The Science Integration Team (SIT) conducted a risk assessment to evaluate the alternatives proposed in the Draft Eastside EIS. The evaluation was not a quantitative analysis of viable populations, because it was not an explicit model of genetic or demographic risk to species persistence. Rather it was a reasoned series of judgements about projected amounts and distributions of habitat and the likelihood that such habitat would allow populations to persist over 100 years. Evaluations were based on expert opinions from professional panels concerning the likely outcome for species and their habitats under the proposed management alternatives. The analysis meets the criterion of an analysis of viable populations, to provide an estimate of the likelihood that a population will persist over the long run, generally 100 years.
- The SIT considered the white headed woodpecker as a species at risk of extirpation (DEIS pg. 4-105, table 4-41). In addition, other research indicates that there have been severe declines in white headed woodpecker population numbers throughout its range (Wisdom in press), Dixon). The expert panels rated the current condition of white-headed woodpecker habitat as A4 - habitat is typically distributed as isolated patches, with strong limitation in interactions of populations among patches and limited opportunity for dispersal among patches. Some local populations may be extirpated, and rate of recolonization will likely be slow. The white-headed woodpecker is considered by the Science Integration Team as an increaser - one in which species habitats would improve in the Eastside planning area in the future (DEIS pg. 4-107 table 4-42). So, while it is thought that there may be local extirpations, the likelihood of species viability is expected to increase in the future.
- Habitat quantities and risk assessments were based on large mapping units (pixel size of 100 ha or 247 acres) and broad scale methods of spacial analysis. Based on this scale of analysis, the expert panel concluded that there is a high likelihood of white headed woodpecker viability. This scale of analysis would not have included smaller stands of LOS ponderosa pine such as the stands to be conveyed to CP. LOS ponderosa pine stands to be conveyed to CP range from approximately 60-200 acres in size. The majority of LOS ponderosa pine stands to be conveyed to CP would not have been mapped and therefore considered in the risk assessment. The majority of ponderosa pine stands to be conveyed to CP would not have been mapped using this scale of analysis.
- This response is based on the following assumptions:
- In the judgment of current condition, there was uncertainty surrounding the habitat maps and current distribution and condition of species' populations (DEIS pg. 4-100).
- There would be little change in overall outcomes for the majority of species analyzed under any alternative. This result is based on current and projected future populations and habitat conditions, and on the fact that most species responde to habitat changes at finer scales than this evaluation portrays.
- Actions that could reduce scarce or poorly distributed habitats will be carefully analyzed to ensure that they will still meet species requirements.
- assessed effects on species from a variety of influences including habitat changes at the broad scale.
- Although, much of the data collection for this project seems deterministic (unvarying), it is collected and interpreted with the full understanding that ecosystems and populations are inherently inconstant (Assessment of ecosystem components pg 1515).
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