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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 20b. Indiana bat (Part 2 of 5)USFWS, August 25, 2005: Regarding Clearcuts“Due to the potential extent of habitat affected (10 – 40-acres), and the fact that the Standards and Guidelines do not prohibit this management activity during the Indiana bats’ active period, we expect that both direct and indirect take is likely to occur; therefore, this management activity will be included in the incidental take statement.” USFWS BO 2006: Hazard Tree Removals - The removal of trees that are considered hazardous to forest resources (buildings, roads and trails, Forest Service personnel, etc.) and/or forest visitors. Likely, these are dead or dying trees that are within a campsite, along a road, adjacent to a forest building or structure, or along a trail. Studies have shown that Indiana bats consistently roost in dead or dying trees (snags), or in live shagbark hickories (Humphrey, et all 1977). It is therefore potentially harmful to remove dead and dying trees, especially during the active period for the Indiana bat (April 15 to September 15). It can also be potentially harmful to remove known roost trees that become hazards outside the active period, since bats have demonstrated a “homing” pattern of returning to the same summer breeding areas each year (Gardner, et al 1991, 1996). The US Fish & Wildlife Service (USFWS) obviously does not object, and just accepts the fact that the FS will have ”activities” during the active season of the bat. USFWS BO 2006: In order to avoid Indiana bat responses rising to the level of take, prescribed fires should only be conducted when Indiana bats are not likely to be present in the area. The accepted active period for Indiana bats within their summer habitat is from April 15th to September 15th Does the Forest Service intend to follow this assessment about burning periods and refrain from burning from to April 15 and September 15? Below we see how the USFWS accommodates the Forest Service, basically leaving it to the Forest Service to determine what is “possible”. USFWS BO 2006: “Guidelines relevant to Indiana bat maternal roosting habitat include: When possible, the removal of hazard trees will be delayed until between September 15th and April 15th, the likely hibernating period of the Indiana bat.” And what about harassment? Will the bats be harassed since activities will take place when the bats are active? Why is taking summer habitat from the bats not considered harassment? However, even if the Forest Service would refrain from anything that could adversely affect the bat between April 15 and September 15, and instead log and burn and conduct other related activities only in the fall and winter, the terms and conditions, and standards and guidelines of the BO and of the Forest Plan would not be sufficient to protect the Indiana bat: • Bats fly in and out of hibernation in the fall and winter, after the date that the Forest Service is planning to log and burn. In other words, on warm fall and winter days, bats have been seen leaving their hibernacula and flying into the forest. Consequently they could be harmed from logging and burning operations after Sept 15 and before April 15, contrary to the 2006 USFWS BO. • With temperatures increasing in the winter months over the past few years, the likelihood of bats being outside of their hibernacula will increase. • The BO roughly states that bat colonies like large dead trees. However, the issue is much more complicated than is stated by the Forest Service and Fish and Wildlife Service. While bats might occupy large dead trees at times, at other times the colonies bust up and go to other trees due to microclimate conditions, such as shade in the hot months and sun in the cooler months. The BO states that the Forest Service leaves enough trees on a logging site for the bat colonies. However, the Forest Service doesn’t deal with the fact that they are opening up the canopy and that the trees’ level of “shadiness and sunlight” will change. By leaving only a few large dead trees that offer appropriate microclimates only at some times, but not at others, the Forest Service diminishes suitable habitat for bats. • The documents also misrepresent the issue of Indiana bat foraging habitat. Indiana bats are consistently found foraging over a full canopy. They will incidentally forage open lands and get drinks from ponds as they go from one forest to another, but they overwhelmingly prefer a full canopy forest. • The documents consistently neglect to mention pertinent information about male Indiana bats. Males don’t join the colonies. They stay in caves or flit around in the forest and stay in random trees. They really prefer to roost in a full canopy. There are some findings that the male bats’ primary roost trees have solar exposure. And on cooler evenings in the fall they will look for open trees where it is warmer. But this doesn’t translate into a blanket finding that opening up the forest canopy and having less understory as a result of logging and burning will favor all the bats overall. This is simply not the case. • The documents fail to point out that the population of Indiana bats has been increasing on the Hoosier and Shawnee where the Forest Service has not been logging much over the same time period. In other words, forest preservation, not “management”, has favored Indiana bats and furthered their existence. On the other hand, in forests with more extensive logging, the populations are decreasing. The points above are considered in more depth below. With each Biological Opinion, the USFWS is rubber stamping many projects similar to German Ridge in Indiana and across the region. With these rubber stamps, we are seeing hundreds of thousands of acres of take. However, nowhere in the DSFEIS, Hoosier National Forest (HNF) Land and Resource Management Plan (LRMP), BO or other documents do we see an evaluation of the cumulative effects of all of these takes. More information can be found by looking at Heartwood et al. Vs. USFS and USDA FS, Southern District of Ohio. It is unclear from the FEIS of the HNF LRMP what standards and guidelines are enforceable in regards to the Indiana bat and what is not. This skews the INDIANA BAT ANALYSIS. Even though the enforceable standards are supposedly highlighted with an asterisk, as we point out in the standards and guidelines section, the Forest Service is being deceptive: these are no longer considered by the Forest Service to be enforceable (although we disagree and have challenged this in the Hoosier LRMP appeal, and the Forest Service conceded this point on the Mark Twain National Forest Plan appeal). The impact analysis on the Indiana bats in both the HNF LRMP AND/ OR THE GERMAN RIDGE FEIS cites little if any science supporting its conclusion that there won’t be much impact on the Indiana bats from all the burning and logging. Click here for Part 20c. Indiana bat (Part 3 of 5)Protect Our Woods
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