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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 20e. Indiana bat (Part 5 of 5)Roosting Habits of Male BatsThere have been some findings regarding the roosting habits of males. While some males stay near the caves and even roost in the caves, some males leave the caves and roost in the forest during the summer. For example, the Hoosier National Forest, in mist netting in Indiana, actually found males roosting in unthinned pine plantations. This information, regarding the use of pine trees, which reinforces the data of Kiser and MacGregor, makes dead pines within a dense forest very important roosting habitat, at least for males. MacGregor has found about half the roost used by the bats where shortleaf pine.Other researchers have found that males roost in the forest. For example, Hobson found that: This (male) bat used a mature, live, shagbark hickory (Carya ovata) tree as a diurnal roost; up to 10 other bats roosted in the same tree. The bat primarily foraged among tree canopies within 625-ha area of an 80-year-old, oak-hickory forest. Our study suggests that male M. sodalis use foraging areas and tree roosts found in the area of hibernacula. Thus, we recommend that conservation efforts protect and manage foraging and tree roosting habitat in the vicinity of M. sodalis hibernacula. Kiser et al found that males, as well as a female, in the fall swarming period within the vicinity of a cave, all roosted in “forested areas with a high density of trees.” While some of the roosts recorded by Kiser occurred in small openings in the forest, some were in forest interior, even considering the fact that his studies occurred in the fall, a time where the bats obviously would be seeking trees which would pick up some sun for warming. Even humans tend to stay in the shade during the summer and get in the sun during the fall and spring. This is not rocket science. But there is no indication that the species prefers trees standing alone in the middle of an opening. When they do chose a site with sun exposure, it is within a forest setting, and often the death of the tree itself which is chosen for roosting, is sufficient to create the opening preferred by the species. Laval et al found that “Our bats, mostly adult males, foraged in densely forested situations, most of them on hillsides and ridges.” Clearly, males as well as females are forest species. They prefer forested habitat for roosting and foraging. Instead of stressing the importance of protecting forests, as earlier drafts had done, this plan makes concluding statements that lead the reader to believe that logging and other manipulating activities are just fine with the bats. This is unrealistic and reflects the bias of handpicked scientists. While there is some data to suggest that Indiana bats will utilize roosts in non-shaded areas, this data is very season specific or the exception. It is not consistent with the preponderance of the data, especially regarding maternity colonies, which are critical to the recovery of the species, to suggest that the species avoids closed canopy forests. As a matter of fact, the evidence is clear that the species requires forests. It needs a variety of roosts to survive the variety of natural events that can occur, but clearly forest interior habitat is the critical habitat to protect.” Seasonal Cutting Restrictions Aren’t Protective and Don’t Promote Recovery of the Indiana BatThe agency relies on “seasonal cutting restrictions” as the main protection by which the agency avoids taking the Indiana bat, although that avoidance, even by their own standards, isn’t total. We contend that seasonal cutting restrictions do not adequately deal with the well settled science that indicates that Indiana bats are loyal to their summer habitat. We submit evidence from bat experts (Whitaker email and Garner memo in the Hoosier LRMP appeal) that shows that there is grave concern in the scientific community about cutting in Indiana bat habitat during the winter months. Not only does it damage habitat that will be used by colonies, but it doesn’t account for the increasing warmer days in the winter when bats are observed foraging. Global warming will stimulate more of these days in the future. In addition, seasonal cutting restrictions, (as well as not designating summer critical habitat) does not conserve the species according to the ESA in that it doesn’t promote the recovery. Without identifying and protecting known occupied habitat, the agency can’t purport to be aiming toward the recovery of the species, because it won’t know what that is. Failure to consider this and plan for it is a violation of NEPA, NFMA, and the ESA.No Surveys or Tallies Have Been DoneFrom the German Ridge BO, USFWS:“To our knowledge, no bat surveys have been conducted within or adjacent to the GRRP project area.” Why haven’t surveys been done? From the HNF BO: “For each project proposed, the Forest Service and the Service will evaluate the specific impacts associated with the project and tally any take that is anticipated to occur.” Since there were no surveys, and therefore no tallies, does this not make the Hoosier NF and USFWS out of compliance with the B.O. even before the Project is implemented? Where are the tallies for the entire HNF so we can add up how much the Project will add to the tally of anticipated takes? From the HNF BO: “As future projects are developed, HNF will provide the Service with project-specific information that: (1) includes a cumulative tally of incidental take that has occurred since the adoption of the 2006 Forest Plan, including a map showing the cumulative incidental take action areas. “ Where are these maps with the cumulative incidental take action areas????? A big concern is that the data from the USFWS 2006 BO was partially based on the Hoosier-Shawnee Ecological Assessment. This means that not only is the Hoosier LRMP and the German Ridge FEIS illegal, but the USFWS BO as well. From USFWS Letter: “In general, dense plantations of non-native pines have very little value to most bat species, including the Indiana bat. They appear to have minimal value as roosting habitat for maternity colonies as no reproductive adult female or juvenile Indiana bats have been recorded roosting in dead or live pine trees in Indiana (BFO records). In contrast, a few adult males have occasionally been found day roosting in pine snags on the HNF. Therefore, we do anticipate that a few widely scattered, solitary, adult male Indiana bats may also roost in pine and/or hardwood snags within or near the project area.” This paragraph is astounding. As illusive and rare as Indiana bats seem to be, still they were found in German Ridge pine trees. Yet the USFWS and the Forest Service STILL say the pines have little value to the bat! “Currently, the roosting habitat (especially medium to large snags with exfoliating bark typically associated with maternity colony use) and foraging habitat appears to be of limited quality and abundance (A. King, pers. obs.)." Again, we are astounded. EVEN THOUGH bats have been found in these pine trees, bat habitat in the area is still observed to be of “limited quality and abundance.” Note this is an observance by one person, without any monitoring, in an area where bats have been found. “Large-diameter suitable roost trees are scarce.” If large diameter roost trees are scarce, then why are we going to be cutting them? The USFWS BO 2006 has new information that is different from the 2001 BO for the LRMP that we would like to point out: • The hibernation dates starting at Sept. 15 is absurd. We all know that it stays warm enough for bats to fly way after that. • The BO states that males do come out in the forest individually during the summer, but it doesn’t try to describe what kind of forest they prefer, because they prefer a full canopied forest. • The BO focuses on protecting existing colonies and not on protecting habitat for future colony recruitment i.e., recovery. This is a huge flaw in their rationale. Click here for Part 21. Species SurvivalProtect Our Woods
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