 |
Protect Our
Woods
Working to preserve our rural heritage and quality of life in southern Indiana since 1985 |
Home Site Map Contact Us |
Home News & ALERTS Issues Forum Archives Conservationist's Alternative Klawitter Memorial Downloads Join Us About Us Contact Us Site Map Links |
ALERT - December 4, 2006: Protect Our Woods joins allies to submit a response to the Draft Supplement to the Final Environmental Impact Statement (FEIS) for the German Ridge Restoration Project in Hoosier National ForestPart 20a. Indiana bat (Part 1 of 5)We hereby incorporate everything that was written in the comments on the HNF and German Ridge DEIS, as well as the HNF Plan Appeal and German Ridge Appeal, and the Hoosier LRMP, by Heartwood and Protect Our Woods, on the Indiana Bat.It is our contention that the plan does not adequately protect roosts, both primary and secondary, for maternity colonies, doesn’t protect male roosting habitat, and doesn’t protect Indiana bat foraging habitat adequately. We believe the plan jeopardizes the continued existence of the Indiana bat, counter to the findings of the US Fish and Wildlife Service. USFWS Aug. 25, 2005: “We also concur that the proposed project is not likely to jeopardize the continued existence of the Indiana bat and that the anticipated effects and resulting level of incidental take are consistent with those analyzed within the programmatic BO.” We believe the proposed project is likely to jeopardize the continued existence of the bat because much of the German Ridge Plan proposes projects that the USFWS states will “adversely affect the Indiana bat.” Our question to the Forest Service is, how can actions that adversely affect the Indiana bat not place the bat’s existence in jeopardy? Below we see that the Fish and Wildlife has determined that taking 2965 acres per year or 1.6 percent of the affected habitat is somehow O.K. However, we do not see an adequate rationale for this determination in the 2006 B.O. If the Forest Service had requested twice the amount, for example, 3.2 percent of habitat destruction, would the USFWS have accepted this? What about 6.4 percent? In other words, how does the USFWS know when the threshold to a jeopardy determination has been reached or surpassed? At what point does the species collapse? Taking into account that “no jeopardy” findings are now the only determination coming out of the present USFWS on every national forest plan in the region, at what point does the cumulative effect of all these determinations result in jeopardy? What are the cumulative effects of these decisions on a regional level? Isn’t this the important question to ask if the USFWS and Forest Service really concerned about the specie’s existence? USFWS BO 2006: EFFECT OF THE TAKE In the accompanying biological opinion, the Service determined that this level of expected take is not likely to result in jeopardy to the species or destruction or adverse modification of critical habitat. The amount of incidental take allowed here (2956-acres per year), as expressed in acres of habitat lost or altered, spread out over the forested portion of the HNF (187,201-acres) represents only 1.6% of affected habitat per year. One of the key issues in the German Ridge Project is the presence of the endangered Indiana bat. The Indiana bat was found in one of the pine trees in the proposed project area back in the 1990s. The Forest Service had to retract the sale after this finding. Then, the DEIS and FEIS were issued with a Biological Opinion (BO) 2001 referenced in the text. From the German Ridge FEIS: “The Forest completed a Biological Assessment (BA) in 2000 to document potential effects of continued implementation of the Forest Plan (as amended) on Federally threatened and endangered species and their respective habitats, in particular the Indiana bat. The BA helped ensure that forest management decisions be made with the benefit of the latest knowledge concerning Federally listed species. A USDI Fish and Wildlife Service Biological Opinion, issued in 2001 and based on information in the BA and the Forest Plan (as amended), indicated implementation of the Forest Plan would not adversely affect three of four threatened and endangered species and would not be likely to jeopardize the continued existence of the Indiana bat. That document provided terms and conditions for protection of Indiana bat and its habitat, and in July 2003 that direction was incorporated into amendment 7 to the Forest Plan.” Above the Forest Service does not explicitly include bats in when stating that 3 out of 4 species would not be adversely affected, and they say they are not jeopardized. Below, they explicitly admit that the Indiana bat would be adversely affected: (FEIS p. 8) “The predicted effects on threatened and endangered species disclosed in the DEIS have not changed, but the USDI Fish and Wildlife Service has indicated how that agency interprets the Endangered Species Act. Based on this, the Hoosier updated the BA for the proposed project (USDA FS 2005). Although it is unlikely that a tree with Indiana bats in it would be harvested or damaged from implementation of any of the action alternatives, this remains a possibility. The restoration of native hardwood forest in the proposed project would in the long term improve habitat favored by Indiana bat, but the Hoosier cannot dismiss the possibility of harm to individual bats from project activities. The Hoosier has taken careful steps to minimize the chance of harm to individuals. These steps include following terms and conditions in the USDI Fish and Wildlife Service’s 2001 biological opinion, which included the conclusion that “continued implementation of the Hoosier National Forest Land and Resource Management Plan is not likely to jeopardize the continued existence of the Indiana bat” (USDI F&WS 2001). The cover letter for the revised BA noted that “these actions appear to be of a type that was found in the BO “not likely to jeopardize the continued existence of the Indiana bat.” The letter also stated, “Although the project is expected to improve Indiana bat foraging habitat by restoring native hardwood forest, there will also be potential to damage or kill an Indiana bat during the operations, since a large portion of the activities would take place during the months when the bats are active” (USDI FWS 2005). In a letter dated August 25, 2005, the USDI F&WS concurred with the Hoosier’s finding that “the proposed project is not likely to jeopardize the continued existence of the Indiana bat and that the anticipated effects and resulting level of incidental take are consistent with those analyzed within the programmatic BO” (USDI F&WS 2005).” Above we have the Forest Service say that activities will take place when the bats are active. We understand this to mean that logging and/or burning/ road building etc. will happen between April 15 and September 15. USFWS BO 2006: The accepted active period for Indiana bats within their summer habitat is from April 15th to September 15th; From the BO Letter, USFWS, August 25, 2005: “The HNF proposes to allow operations during the summer. The normal summer operating season typically begins around June 1; Why will the Forest service pursue activities that may adversely affect bats in the time period between April 15 and Sept. 15 if this means a higher likelihood that bats will be “taken”? From the 2001 USFWS BO:“Take of Indiana bats from this activity can only occur if a tree is cut when bats are present, between April 15 and September 15. If hazard trees are removed outside the time period when bats are present the activity is not likely to adversely affect the Indiana bat.” Click here for Part 20b. Indiana bat (Part 2 of 5)Protect Our Woods
PO Box 352 Paoli, Indiana 47454 |