MOOSE FIRE SALVAGE WILDLIFE EFFECTS EVALUATING THE CUMULATIVE

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MOOSE FIRE SALVAGE WILDLIFE EFFECTS EVALUATING THE CUMULATIVE Powered By Docstoc
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MEADOW SMITH PROJECT:
EFFECTS AT FOREST AND REGIONAL SCALES--
COMPATIBILITY WITH NF MA REQUIREMENTS FOR
MAINTAINING SPECIES VIABILITY
Prepared by Mike Hillis, Cohesive Strategy Team
            Lewis Young, Flathead National Forest
            Jane Ingebretson, Swan Lake Ranger District

            February 28, 2003.


INTRODUCTION
The National Forest Management Act of 1976 (NMFA) directs the Forest Service to
manage wildlife habitat to maintain viable populations of existing native and desired non-
native species in the planning area. Rarely are viability analyses conducted for any
species that conclusively determine whether viability is assured under a given habitat and
population management strategy. For instance, a very rigorous viability analysis was
attempted for the northern spotted owl in USFS Region Six in the 1980s. Large numbers
of adult owls were trapped and radio-tracked from subpopulations across the species’
range. Nest production was closely monitored. Fledglings were radioed and monitored
to determine survival, dispersal, and recruitment into the adult population. Nonetheless,
while millions of dollars were invested, many questions remain about the viability of
northern spotted owls.

Region One usually applies one of two strategies to assure that NFMA viability
requirements are met.

A strategy typically used for sensitive species (species at risk of federal listing) involves
the following steps, using the flammulated owl as an example. Forests dominated by old
ponderosa pine have been largely lost in Region One, due to a combination of logging
and fire exclusion (Wisdom et al. 1999). The flammulated owl is a sensitive species in
Region One, and is largely dependent on old ponderosa pine forests (Wright 1996). A
Region-wide assessment (Hillis, Wright, and Jacobs, 2002a) suggests such forests only
occur at 12 to 16% of their former, pre-fire suppression/pre-logging levels. Furthermore,
70% of those remaining old, ponderosa pine forests are at severe risk of stand-replacing
fire. Those two factors alone suggest the viability of flammulated owls in Region One
may be at risk. The Region’s strategy for restoring habitat for the flammulated owl
includes: 1) protecting and restoring existing stands of old ponderosa pine forests (usually
conducted by removing the understory vegetation and/or reintroducing low severity
fires); 2) aggressively recruiting old ponderosa pine stands for the future (usually
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conducted by thinning young stands); and 3) monitoring the effectiveness of such
treatments in restoring old ponderosa pine stands and the occurrence of flammulated owls
within such stands. This strategy in no way guarantees that flammulated owls will be
restored to viable levels, largely because it takes a long time to grow old ponderosa pine
stands. The strategy does, however, employ all tools available, within existing budget
and legal constraints to: 1) protect and recruit habitat: 2) measure the effectiveness of
the strategy; and 3) if necessary, modify the strategy to incorporate monitoring or new
research findings.

For federally listed species, Region One applies a different strategy. The Endangered
Species Act of 1973 (ESA) directs the Fish and Wildlife Service to identify recovery
goals that would, when met, allow a given listed species to be de-listed. While the
language in ESA does not necessarily equate recovery with viability, it is assumed that
meeting the recovery goals and removing a species from the list is the first needed step in
maintaining long-term species viability. Recovery Goals for listed species are very
specific. As an example, for the recently listed Canada lynx, the direction for recovery
includes: 1) managing habitat components consistent with the direction in the Lynx
Conservation Assessment and Strategy (LCAS, Ruediger et al. 2000); 2) amending Forest
Plans to incorporate the LCAS, and 3) conducting research on Canada lynx populations,
distribution, and habitat use, and on snowshoe hare (the lynx’s primary prey) habitat use.
Again, following this direction does not guarantee that lynx will be restored to viable
levels in Region One. Following this strategy will, however, assure that: 1) land
management decisions will be done prudently to avoid adverse effects on lynx where
possible; 2) vegetative treatments will be limited to those that shift the landscape closer to
historic patterns, age classes, and stand structures while retaining natural processes; and
3) long-term management strategies and recovery goals will be shaped by ongoing
research findings.

Appropriate Analysis Scale
For species with a large global distribution, such as Canada lynx or grizzly bear,
consistency with species viability strategies can seldom be addressed on small scales.
Project areas are invariably too small to determine whether management actions are
consistent with, or not consistent with sustaining viable populations of a given species.
Consequently, large-scale analyses are usually needed to determine whether cumulative
activities are consistent with maintaining species viability. Planning Units (usually
homologous with National Forest boundaries) are a more logical scale at which to
determine whether or not management strategies are consistent with sustaining or
restoring species viability.

Multiple Scale Analyses
It is also important to assess consistency with strategies for maintaining species viability
at multiple scales. For instance, natural events, i.e. wildfires, may make it impossible to
meet certain recovery goals or management strategies on some small landscapes. For
instance, the LCAS directs National Forests to keep unsuitable habitat (very young
stands, too young to provide habitat for hares, and hence unsuitable for lynx) at no more
than 30% of the lynx analysis unit (LAU). The Bitterroot Fires of 2000 left many LAUs
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with greater than 30% unsuitable habitat. Since lynx are wide-ranging and fire-
dependent (Ruggiero et al. 1994), the research suggests such large wildfires may be
ultimately beneficial. Multi-scale analyses of lynx habitat in Region One (Hillis et al.
2002b) confirmed that although the LCAS standard for unsuitable habitat was exceeded
within several LAUs as a result of the 2000 fires, the levels of unsuitable habitat at
increasingly larger scales (4th Code Hydrologic Unit, Forest, Planning Zone, and Region
One) suggested that the Bitterroot Fires will be beneficial to lynx in the long-term and
therefore, fully consistent with recovery.

Applying Those Strategies to the Meadow Smith Project
The Meadow Smith Project area is located at the south end of the Swan River drainage,
east of Highway 83. The FEIS describes the area as being influenced by a mild rain
shadow from the Missions Mountains to the west. As a result, low elevation landscapes
are forested with a mix of moderately xeric ponderosa pine, Douglas-fir, and western
larch. The fire regimes in these lower elevation landscapes are described as a mix of
non- lethal and mixed-severity fires. Upper elevations on the face of the Swan Range
receive substantially more precipitation and are forested with stands of subalpine fir,
spruce, and lodgepole pine. The fire regimes in these upper elevation sites are described
as stand-replacing fires at fairly long intervals.

Proposed vegetative treatments are limited to the lo w elevation lands, and include: 1)
commercial thinning designed to recruit older stands of ponderosa pine and larch; 2)
commercial harvest, designed to protect individual trees and stands of old ponderosa pine
and western larch; and 3) prescribed burning, designed to reintroduce low-to-moderate
severity fires and restore the natural single-storied stand structures. Other treatments
include road closures and watershed improvement activities.

The FEIS assessed the effects on 14 federally listed and sensitive wildlife species at the
project and cumulative effects area scales, including: Canada lynx (threatened), grizzly
bear (threatened), wolf (endangered), bald eagle (threatened), black-backed woodpecker
(sensitive), wolverine (sensitive), flammulated owl (sensitive), fisher (sensitive); northern
goshawk (sensitive), harlequin duck (sensitive), boreal toad (sensitive), bog lemming
(sensitive), common loon (sensitive), and big-eared bat (sensitive). Because these species
are either federally listed or sensitive, some analysis on the degree to which project-level
activities are consistent with maintaining species viability at larger scales is warranted
and will be evaluated in this document. Effects on pileated woodpeckers and other snag-
dependent species are also discussed in the FEIS.

Species given detailed, multi-scale discussion- The Canada lynx, grizzly bear, wolf,
bald eagle, black-backed woodpecker, wolverine, flammulated owl, fisher, goshawk,
boreal toad, pileated woodpecker, and ungulates are all affected by broad-scale changes
in vegetation, natural processes, or human disturbances and will receive detailed
discussion in this analysis.

Species occupying microsites or affected by human disturbance activities that are
totally unrelated to the Meadow Smith project- The harlequin duck, bog lemming,
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common loon, and big-eared bat either occupy “microsites” and/or are affected by a very
specific type of human disturbance. For instance, the harlequin duck nests in large,
rushing streams. The limiting factor to nest success appears to be human disturbance
during the nesting season. Thus, even in wilderness situations, fishing or kayaking
activity can affect nesting. While regulating and monitoring such activities is critical to
the recovery of harlequin ducks (Genter 1991), such activities are un-related to the broad
vegetative treatments prescribed in the Meadow Smith project. Bog lemmings occur in
sphagnum bogs (Foresman pers comm.). Such microsites are generally protected by
wetlands regulations. Because such wetlands protection is all-encompassing and
redundant across National Forest lands, there is no need to further demonstrate that
lemming populations will be protected, consistent with sustaining species viability,
beyond the protection provided by those laws. Loons nest in large lakes. Disturbance
from boating activity during the nest season is the primary threat to nest production
(Dolan 199_). While regulating and monitoring boating activity is critical to the
recovery of loons, such activities are un-related to the broad vegetative treatments
prescribed in the Meadow Smith project. Big-eared bats roost and hibernate in mine adits
or caves. Federal regulations which require closing mine adits to protect the public can
inadvertently make some adits inaccessible to bats. Modified closure devices are very
effective in both keeping the public out of adits, and in allowing bats access to those
adits. While regulating and monitoring access to mine adits is critical to the recovery of
big-eared bats, such activities are un-related to the broad vegetative treatments prescribed
in the Meadow Smith project. For these reasons, nothing prescribed in the Meadow
Smith project is incompatible or related with on-going activities to restore harlequin
duck, bog lemmings, loons, and big-eared bats to viable status.


CANADA LYNX
Findings at the Project and Cumulative Effects Area Scale
The FEIS concluded that all vegetative treatment activities would be conducted outside of
lynx habitat, defined and mapped as landscapes generally within the subalpine fir series
(Ruediger et al. 2000). Conditions for individual Lynx Analysis Areas (LAUs) were
disclosed. Cumulative factors, including private land activities and disturbance from
Highway 83, were evaluated. It was concluded that the project would not exacerbate any
existing cumulative adverse effects from those off- forest activities. The FEIS and
Biological Assessment (BA), therefore, concluded that the project would have “No
Effect” on the lynx at the project and cumulative effects scale.

The Status of Lynx Habitat Compone nts at Larger Scales
Further effects on lynx habitat at Forest and larger scales are disclosed in Table 1 (From
Hillis et al. 2002b).

Table 1. Levels of Lynx habitat components at 4 th Code Hydrologic Unit (HUC4), Forest,
Planning Zone, and Region One scales.
 Habitat                   LCAS         Swan         Flathead      Planning      Region
                 HRV*
 component                standard     HUC4             NF           Zone         One
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 Unsuitable        9.5%     30% max          2.8%          9.7%             9.3%        9.2%
 Foraging          19%          --           9.1%          8.9%             4.0%        5.4%
 Denning           10%      10% min           --**           --               --        15.1%
* HRV or the Historic Range of Variability reflects the average conditions expected before fire
   suppression or logging substantially changed the vegetative pattern in lynx habitat.

** Although no hard data are available, the availability of dense, late-seral forest in the Upper
   Swan Valley, disclosed in the supplemental Biological Evaluation (Figure IV.12. LaFontaine,
   2001) suggests denning habitat occurs at substantially higher than the 10% minimum level
   within the HUC4.

At the project scale, the proposed activities will have no effect on lynx. Looking at the
HUC4 scale, note in Table 1 that the level of unsuitable habitat is well below the
maximum LCAS level of 30%. Note too, that foraging habitat is below the HRV,
suggesting some additional disturbance from wildfires, prescribed burning, or logging,
would be beneficial in the long-term. This may be especially important in the HUC4
since the Lynx BA concluded that most foraging habitat in the ana lysis area is 20-30
years old. This suggests that much of this foraging habitat will “disappear” in another 15
to 25 years. In addition, since there is only 2.8% unsuitable habitat, little foraging habitat
is available for recruitment from habitat that is currently unsuitable. The Swan HUC4
was missed by big fires in 2000 and 2001 that affected much of the Flathead and adjacent
Lolo and Bitterroot National Forests, which explains its low level of unsuitable habitat.

Note that there is much more unsuitable habitat at the Forest scale (9.7%) than the HUC4
scale. This is the result of the Moose Fire, the Little Wolf Fire, and recent concentrated
timber harvest on the Tally Lake District and other agency activities in the Stillwater
drainage (Hillis et al. 2002b). While well below the LCAS maximum of 30%, this 9.7%
provides a large reserve of habitat available for recruitment into foraging habitat in a few
years. Like the HUC4 findings, forage habitat at the Forest scale is well below the HRV
suggesting long-term stand-replacing disturbance would be desirable for lynx.

The levels of unsuitable and foraging habitat are roughly comparable at the Planning
Zone and Region One scales, suggesting stand-replacing disturbance is needed. The
trend to more frequent, hotter fires since 1988 (Hillis et al. 2002c) suggests this may
resolve itself. Denning habitat at the Region One scale occurs at higher-than- mean-
historic levels. While the Region One Lynx Assessment (Hillis et al. 2002b) did not
assess denning habitat at smaller scales, other assessments (Hillis and Lockman in prep
a) strongly suggest that denning habitat is not limiting in most geographic areas. At the
project scale, since no unsuitable, foraging, or denning habitat will be impacted, the
project’s treatment strategy is fully compatible with the LCAS and lynx recovery.

In summary, lynx are a disturbance-dependent species (Ruggiero et al. 1994). Stands 0 to
15 years old, while unsuitable for lynx in the short run, are needed to provide foraging
habitat for the future. Levels of unsuitable habitat are below the standard at all scales.
Foraging habitat in the Region is well below the historic average. Fortunately, the Fires
of 1988, 2000, and 2001 have provided a substantial “pulse” of unsuitable habitat at the
Forest scale that will provide foraging habitat in 1 to 14 years. Denning habitat appears
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surplus at the scales evaluated. While other factors outside of the Forest Service’s
control (non-target trapping mortality, high competing predator populations, global
warming, etc.) may impede lynx recovery, the actions taken in the Meadow Smith project
are fully compatible with recovering lynx to non-listed status and consistent with
maintaining well-distributed habitat for viable populations of lynx at the Forest and
Regional scales.


GRIZZLY BEAR
Effects of the Meadow Smith Project on Grizzly Bears
The FEIS disclosed that changes in open roads would result in a slight improvement in
the total/open/core index within the Meadow Smith grizzly bear subunit. The subunit
already meets the Flathead Forest Plan’s Amendment 19 (USDA 1995) since it has <75%
FS ownership and meets the “no net loss” requirement mandated in A19.

Status of Grizzly Bears at the Flathead National Forest Scale
Flathead National Forest lands comprise approximately 40% of the Northern Continental
Divide Grizzly Bear Ecosystem (NCDE). Flathead National Forest land ownership
occurs within 73 grizzly bear subunits totaling 2,452,410 acres, and Amendment 19
applies to 54 subunits totaling 1,662,162 acres (Figure 2). Forest Service ownership
ranges from less than 10% to 100% within the subunits. The area on the Flathead
National Forest within the grizzly bear recovery area includes portions of the Swan
Valley, North Fork Flathead, and Stillwater River drainages where Plum Creek Timber
Company, Montana Department of Natural Resources and Conservation, and/or small
private lands may account for substantial land ownership. In addition, the South Fork,
Middle Fork, and Swan River drainages contain substantial areas of Wilderness. All of
these areas and land categories play an important role in determining and describing
grizzly bear management and habitat suitability on the Flathead National Forest.

Of the 19 subunits where Amendment 19 does not apply, 16 are within the Bob Marshall
Wilderness where road management is not an issue. Habitat effectiveness is very high in
all the wilderness subunits with only a few high use trails affecting grizzly bears. The
other three subunits are in the Stillwater River drainage where FS lands comprise less
than 10% of the subunits.

Amendment 19
Amendment 19 applies to 54 subunits primarily outside the wilderness and was
developed to provide Forest Plan direction concerning levels of open roads, total roads,
and secure or “core” habitat that would contribute to the recovery and conservation of
grizzly bears. A19 specifies that within each subunit, the maximum levels allowable for
open and total roads is 19%, and the minimum level allowable for core habitat is 68%.
This is commonly referred to as the “19/19/68” rule. Within subunits with less than 75%
National forest ownership, A19 specifies “no net loss” in road standards. The standards
are described in the Decision Notice for Amendment 19 (USDA 1995).
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Fourteen subunits, including the Meadow Smith subunit, have FS ownership <75% and
all of them met the “no net loss” standard on FS lands in 1995 and still meet it (Table 2)
although the open, total, and core numbers for the entire subunit typ ically do not meet
19/19/68.

Table 2. Forest-wi de summary of grizzly bear subunits, levels of open road density, total road
density, and core habi tat, and summary of compliance wi th Amendment 19. Based on situati on as of
January 2001.
   Subunits >75% FS land          Open      Total      Core                Compliance summary
 Frozen Lake                       10         4          86      Meets
 Ketchikan                         19         3          71      Meets
 Upper Trail                       17         4          85      Meets
 Lower Whale                       44        23          43      Does not meet
 Upper Whale Shorty                12        12          83      Meets
 Red Meadow Moose                  25        20          57      Does not meet
 Hay Creek                         28        15          61      Does not meet
 Coal, S Coal                      15        26          71      Nearly meets*
 Werner                            37        41          42      Will meet after Moose Post-Fire
 Lower Big                         25        34          51      Will meet after Moose Post-Fire
 Canyon McGinnis                   32        38          43      Does not meet
 Peters Ridge                      32        19          63      Does not meet
 Swan Lake                         23        18          66      Nearly meets
 Crane Mtn                         35        60          29      Does not meet but has decision to imp rove
 Beaver Cr                         6         26          72      Nearly meets
 Doris Lost Johnny                 28        13          68      Nearly meets
 Wounded Buck Clayton              32        40          41      Does not meet
 Emery Firefighter                 27        38          49      Recent decision to nearly meet
 Riverside Paint                   25        34          60      Recent decision to meet
 Jewel Basin Graves                21        23          57      Does not meet
 Wheeler Qu intonkon               22        22          62      Does not meet
 Logan Dry Park                    32        36          52      Does not meet
 Lower Twin                        9          2          91      Meets
 Twin Creek                        0          0         100      Meets
 Moccasin Crystal                  7          1          81      Meets
 Stanton Paola                     7          3          79      Meets
 Dickey Java                       9          0          81      Meets
 Long Dirtyface                    0          0          95      Meets
 Tranquil Geifer                   0          2          76      Meets
 Skyland Challenge                 15        16          58      Nearly meets
 Plu me Mtn Lodgepole              0          0          78      Meets
 Flotilla Capitol                  0          0          94      Meets
 Ball Branch                       3          9          89      Meets
 Kah Sold ier                      30        37          57      Recent decision to meet
 Spotted Bear Mtn                  20        23          63      Recent decision to meet
 Big Bill Shelf                    12         6          78      Meets
 Jungle Addition                   32        23          59      Recent decision to meet
 Bunker Creek                      5          3          80      Meets
 Go rge Creek                      0          0          87      Meets
 Harrison Mid                      1          0          91      Meets
 Subunits <75% FS land**
 State Coal Cyclone                29        21          60      Meets
 Cedar Teakettle                   30        23          31      Meets
 Noisy Red Owl                     12        14          65      Meets
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 S Fk Lost Soup                    41          40           44      Meets
 Goat Creek                        30          49           47      Meets
 Lion Creek                        21          38           58      Meets
 Meadow Smith                      22          51           49      Meets
 Buck Ho lland                     24          38           39      Meets
 Porcupine Woodward                46          53           37      Meets
 Piper Creek                       20          30           64      Meets
 Cold Jim                          19          56           47      Meets
 Hemlock Elk                        8          29           71      Meets
 Glacier Loon                      25          39           50      Meets
 Coram Lake Five                   29          46           22      Meets
* Nearly Meets” is defined as being within 10 percentage points total for any combinat ion of the open,
total, or core standards.
** The standard for these subunits with FS ownership less than 75% is “no net loss on FS land.”

Forty subunits have FS ownership >75% and 18 of them met the 19/19/68 standard in
1995 when A19 was signed. As of the end of 2000, the same 18 still meet all standards
(Table 2). Four other subunits (Riverside Paint, Kah Soldier, Spotted Bear Mountain,
Jungle Addition) have recent NEPA decisions that when fully implemented over the next
8 years would achieve compliance with all three parameters. The Moose Decision will
bring two more subunits (Lower Big Creek Subunit and Werner Creek subunit--through a
Forest Plan Amendment) into full compliance after implementation over the next 7 years.

Closing or obliterating roads is a controversial action on the Flathead National Forest as
is recovering grizzly bears due to a wide range of feelings among the public. As a result,
bringing the Forest into compliance with Amendment 19 on a subunit-by-subunit basis
has been slow. Nonetheless, progress has been substantial when considering the miles of
roads that have been restricted or decommissioned since Amendment 19 was signed in
1995. Available information indicates that over the entire forest, between 1995 and 1999
total miles decreased by about 210 miles (2816 to 2605), open miles decreased about 145
miles (995 to 850), seasonally open miles decreased about 5 miles (252 to 248), and
restricted miles decreased about 60 miles (1569 to 1506). The roads on the Island Unit of
the Swan Lake District cannot be separated out even though they are not in an area
covered by Amendment 19. Additional miles of roads have been restricted and
decommissioned since 1999 but updated numbers are not available at this time.

Re-initiation of Formal Consultation
Amendment 19 included both 5- and 10- year objectives for reaching the standards. The
5-year objectives were not achieved due to a combination of reasons including reduced
budget for NEPA work; increased duties for NEPA personnel in appea ls, litigation, and
FOIAs; reduced funding for road access management; and increased local resistance to
more road closures.

On March 8, 2000, the Flathead National Forest requested reinitiation of formal
consultation to consider motorized access direction on the forest. The consultation
process is ongoing. The expected outcome is to revise the implementation schedule with
the continuing goal that the applicable open road density, total road density, and core
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habitat standards be met in all subunits unless changed through individual subunit
consultations.

Food Storage Order
Minimizing the risk of mortality due to conflict with humans and human associated foods
is also an important facet of grizzly bear management. A food storage special order was
signed on April 15, 1998, applying to national forest system lands within the Northern
Continental Divide Ecosystem on the Flathead, Lewis and Clark, Lolo, and Helena
National Forests. The purpose of the restrictions is to minimize grizzly bear/human
conflicts and thereby provide for visitor safety and recovery of the grizzly bear. The food
storage order contains requirements for storage and handling of bear attractants such as
human foods and garbage, livestock feed, and wildlife and livestock carcasses. The food
storage order also provides protection for grizzly bears in those rare situations when they
venture outside of the North Continental Divide Grizzly Bear Ecosystem.

Coope rative Access Management
Amendment 19 includes an objective to “improve habitat effectiveness through
cooperative management with other land ownerships, land adjustments, or other means.”
The Forest in cooperation with Plum Creek Timber Company, Montana Department of
Natural Resources and Conservation, and the U. S. Fish and Wildlife Service developed
and implemented an agreement for access management and timber harvest scheduling in
the intermingled ownership lands of the Swan Valley. The Swan Valley Grizzly Bear
Conservation Agreement (US Fish and Wildlife Service 1995) establis hed a cooperative
management plan to promote grizzly bear habitat use and security on approximately
370,000 acres.

Coope ration with Montana Fish, Wildlife, and Parks
The Flathead Forest has cooperated with and helped fund a Grizzly Bear Management
Specialist position with Montana Fish, Wildlife, and Parks since inception of the position
in northwest Montana. The position works on both public and private lands to correct
problem situations and educate people about how to live with bears and minimize the
potential for conflicts. The Management Specialist has pioneered efforts in rapid and
complete cleanup of railroad grain spills, the use of aversive conditioning techniques to
educate bears including the use of Karelian bear dogs, and the hazard and necessity of the
cleanup of large and small attractants at private residences. The work may lead to an
increased ability of grizzly bears to utilize habitats in areas currently having high
mortality risk and low use potential.

Grizzly Bear Relocation
The Flathead National Forest cooperates with various other agencies to relocate grizzly
bears according to Interagency Grizzly Bear Committee (IGBC) guidelines and the
Flathead National Forest Grizzly Bear Relocation Plan. The Flathead National Forest has
identified numerous sites that may be used to relocate grizzlies identified as nuisance
bears under IGBC and Flathead guidelines. Typically, several grizzlies are relocated on
to the Flathead National Forest each year. In addition, grizzlies may be captured and
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moved short distances or released on site with aversive conditioning as pre-emptive
relocations.

NCDE Population
Grizzly bear population monitoring using a DNA sampling technique was carried out in
1998 and 2000 in approximately the northern one-third of the NCDE. The Flathead
National Forest was one of the cooperators along with Glacier National Park; U.S.
Geological Survey; Blackfoot Tribe; Kootenai and Lewis and Clark National Forests;
Montana Fish, Wildlife, and Parks; and Montana Department of Resources and
Conservation. The sample area included the North Fork of the Flathead River. A
provisional population point estimate of 381 bears was derived from the 1998 work and
273 from the 2000 data, but those estimates could change somewhat pending final
analysis (Kate Kendall, personal communication). The population estimates from this
study area cannot be simply extrapolated to the rest of the NCDE but it does serve to
indicate a population exists in the study area that is contributing substantially to the
NCDE-wide population goal. The Grizzly Bear Recovery Plan (U.S. Fish and Wildlife
Service 1993, page 62) identifies a minimum NCDE-wide grizzly bear population of 391.

Conclusion
Although recovery does not necessarily equate to viability, it is likely that providing for
recovery contributes to maintaining long-term viability. One of the goals of the Flathead
Forest Plan is to provide sufficient habitat to promote the recovery of threatened and
endangered species and conserve the ecosystems upon which they depend. Past and
ongoing actions taken by the Flathead National Forest, including project activities in the
Meadow Smith project, are contributing to the recovery of grizzly bears, consistent with
the Endangered Species Act and NFMA.

GRAY WOLF
Wolves are rapidly re-colonizing Montana and Idaho. Wolves, once packs become
established, are one of only a very few species that are easily detectable. Consequently,
unlike other species where we have to rely on habitat or prey availability to assess
whether or not management activities are consistent with maintaining species viability,
the question of meeting recovery goals or population viability for wolves can be
answered simply by monitoring populations. The recovery goal for wolves in the Tri-
State area (Montana, Idaho, and Wyoming) is 30 packs (USDI 1987). That goal has been
exceeded in the Tri State area (Fontaine pers comm.). Western Montana alone has about
18 packs (Fontaine pers comm.). Yellowstone Park had nine packs by 2000 and the
number of packs is still increasing. Looking just at the Flathead National Forest, there
are four or five packs, two or three of which are shared with Glacier Park and the Lolo
National Forest (Fontaine pers comm.). If the 30-pack recovery goal were proportioned
evenly across all land management units in the Tri-State area, Western Montana and the
Flathead National Forest would have exceeded that proportionate target by several times.

The Meadow Smith FEIS discloses that there is no evidence of wolf pack activity in the
cumulative effects analysis area. The FEIS discloses effects on ungulates, assuming that
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such effects will potentially affect wolves at that very fine scale. While effects on wolf
prey at the project scale are favorable (beneficial for elk and mule deer, and benign or
slightly adverse for white-tailed deer), wolf pack numbers at the Forest, Western
Montana, and Tri-State area clearly indicate that cumulative, broad-scale activities are
consistent with recovery at all scales.

Wolves are also the one species where we can probably conclude that recovery (to de-
listing levels) equals viability. Wolves have an extremely high fecundity rate, are highly
mobile, and have sustained some habitat connectivity with large populations in Canada.
Consequently, there is little concern among wildlife professionals that the 30-pack
recovery goal should not be sufficient for long-term species viability.


BALD EAGLE
Like wolves, bald eagles are rapidly increasing in Region One. The Recovery Goal for
de-listing eagles in Montana in the 1986 Recovery Plan was 99 pairs of active nests
(USDI 1986). That has since been amended to 800 pairs in the 7-Western State Area
(MBEWG 1994). Nesting bald eagles are very easily detectable. The Montana Bald
Eagle Management Plan (MBEWG 1994) has developed specific direction for recovery
to non- listed status. Determining whether or not recovery direction is being met
involves: 1) monitoring nesting pairs and nest production to ensure that populations are
increasing consistent with recovery goals; and 2) ensuring that Montana Bald Eagle
Management Plan nest protection direction is applied consistently to all active nests.

Bald Eagle Status at the Project and Cumulative Effects Scale
The FEIS discloses that there are no active nests or communal roosts in the project area.
The FEIS also discloses the existence of suitable nest habitat near Pony Creek, but
indicates that that site is not occupied. The project area is well outside of the disturbance
zones of nests in the Clearwater drainage to the south on the Lolo National Forest. For
these reasons, the FEIS and BA conclude that the project would have “No Effect” on the
bald eagle.

Bald Eagle Status at the Forest and Region One Scales
The Flathead National Forest has about 10 nesting pairs. There were 138 active nests in
western Montana and 297 active nests statewide after the 2001 nesting season. Within
western Montana, 96 of those active nests produced 158 fledglings (Youmans, pers
comm., MDFWP 2001 Statewide Bald Eagle Nest Records). The recovery goal has been
exceeded at all scales. Proportionately, the Flathead National Forest and western
Montana have many more nests than the rest of the State. Montana alone has more than
1/3 of the nests needed to meet the 7-state recovery goal of 800 nests. Consequently,
actions described in the Moose Post-Fire Project are consistent with recovering bald
eagles to non- listed status at all scales.
                                                              Meadow Smith Exhibit ____
                                                                         Page 12 of 26

BLACK-BACKED WOODPECKER
In Montana, black-backed woodpeckers are a fire-dependent species that occur at high
densities in burned forests, from 1 to 6 years following the burn (Hillis et al. 2002c).
Black-backed woodpeckers forage on bark beetles and woodborers that occur at high
densities in burned forests (Powell 2000). During extended periods of wet, cool summers
when few fires burn, black-backed woodpeckers disperse and forage on small bark beetle
outbreaks at low densities (Saab and Dudley 1998). Black-backed woodpeckers are
highly mobile and probably migrate at least 30 miles to exploit recent burns (Hoyt 2000).

Fire suppression has had adverse effects on black-backed woodpeckers, by substantially
reducing the amount of burned forests (Hillis et al. 2002c). Salvage logging, especially
during extended low fire periods, can further reduce the amount of fire-killed forest
habitat available to black-backed woodpeckers (Hillis et al. 2002c). The Meadow Smith
FEIS disclosed that thinning, understory removal, and prescribed burning “may impact
individuals but (would) not lead to federal listing.”

At the Region One scale, Hillis and others (2002c) concluded that historically, burned
forests 1 to 6 years old covered about 2% of the landmass of forests in Region One. They
also found that between 1940 and 1987, black-backed woodpecker habitat declined to
only 18.8% of that historic level as a result of very successful fire suppression. Large
fires in 1988, 2000, and 2001, however, brought the average for the 1940 to 2001 period
up to 75.4% of the historic level. When Hillis and others looked just at the period from
1988 to 2001, the level of available black-backed woodpecker habitat was 284.4% of
average historic levels.

Hillis and others (2002c) concluded that the scale at which fires burned was another
important consideration in the management of black-backed woodpeckers. They found
that historically, burned stands that provided substantial amounts of black-backed
woodpecker habitat, were essentially the result of a few, very large fires. Frequent small
fires, while perhaps important to local populations of black-backed woodpeckers,
historically did not contribute many acres. Big fires, of 1889 or 1910 magnitude, tended
to occur on a scale that typically encompassed a 5 th code hydrologic unit (~100,000 acre)
to a 4th code hydrologic unit (~1,000,000 acres). Losensky (2002) concluded such big
fires occurred at the rate of 1 or 2 per decade in Region One.

This 284.4% level of habitat, measured at the Region One scale , and the 127% level
measured at the Forest scale (see Table 3 below) for the 1988 to 2001 periods, might
suggest black-backed woodpeckers are not at risk and do not justify their sensitive status.
Hillis and others (2002b) concluded otherwise. They felt that the 47- year interval from
1940 to 1987, in which available habitat was only at 18.8% of normal not counting losses
from salvage logging, may have substantially impacted black-backed woodpecker
populations. They based this conclusion on two factors: 1) black-backed woodpeckers
are a short-lived species (6 to 8 years, Saab and Dudley 2002) and unlikely to persevere
at normal population densities for such long, low- fire intervals; and 2) the normal large
fire interval at the Regional scale is one to two 1910-magnitude fires per decade
                                                                  Meadow Smith Exhibit ____
                                                                             Page 13 of 26

(Losensky 2002), and much shorter than the 47 year low- fire interval between 1940 and
1987.

While Hillis and others’ rationale may suggest black-backs are still at some risk, recent
research findings and National Forest monitoring indicate black-backed woodpecker
populations are still reasonably high. Several researchers including Hitchcox (1996),
Caton (1996), Hejl and McFadzen (2000) and Powell (2000) found numerous nesting
pairs of black-backed woodpeckers on fires that burned in 1991, 1988, and 1998
respectively. National Forest monitoring crews (O’Connor and Hillis 2000, Monson and
Koniecki 2002) found numerous nesting pairs on fires that burned in 1998 and 2000
respectively.

Hillis and others (2002c) concluded that while such nesting population data may indicate
that black-backed woodpeckers have survived the 1940 to 1987 “bottleneck” in
reasonable numbers, they recommended that the management of burned forests should
consider: 1) limiting salvage logging to only those 4 th code hydrologic units in which
black-backed woodpecker habitat (defined as burns 1-6 years old in stands >9” dbh) is
greater than 2% of the area of the hydrologic unit; 2) retaining unsalvaged burned stands
>9” at no less than 2% of any 4th code hydrologic unit; and 3) avoiding salvaging burns
during extended, low-fire periods, when the burned- forest acreage is substantially lower
than the historic average.

Consistency of the Meadow Smith project with Forest and Region One levels of
available habitat- Existing levels of black-backed woodpecker habitat at the forest and
Region One scales are disclosed in Table 3.

Table 3. Existing black-backed woodpecker habitat on the Fl athead National Forest and Region One
scales (expressed as a percentage of the mean historic range of variability).
           Mean HRV                    Fl athead Nati onal Forest             Region One
              100%                               127%                           284.4%

The recommendations of Hillis and others (2002c) were designed to address broad-scale
fire suppression and the salvaging of large burned areas. Consequently, as prescriptive
recommendations, they do not apply to the Meadow Smith project. Hillis and others
(2002c), however, also identified a need to restore the natural mix of fires and natural
processes to forested landscapes so that forests would be resilient to those disturbances,
and thus could be allowed to burn. The Meadow Smith project, with its goals and
prescriptive treatments does exactly that. Therefore, while the Meadow Smith project
will have little effect on black-backed woodpeckers in the short-term, it will result in
conditions in which natural fires can be allowed to burn and where dead trees created by
those events can be allowed to remain in the forest, and provide black-backed
woodpecker foraging habitat. Such long-term effects are clearly consistent with the long-
term sustainability of black-backed woodpeckers at the Forest and Region One scales.

In summary, while the black-backed woodpecker may have been imperiled by past fire
suppression activities, the current amount of habitat is surplus to what occurred
historically. Salvage activities planned on the Flathead, Lolo, and Bitterroot National
                                                               Meadow Smith Exhibit ____
                                                                          Page 14 of 26

Forests will retain greater-than-historic levels of habitat when completed. Research and
monitoring indicates black-backed woodpeckers are present and nesting in high densities
in burned forests. Consequently, actions taken on the Flathead National Forest (and the
Lolo and Bitterroot as well), including the Meadow Smith project appear fully consistent
with NFMA direction to maintain well-distributed habitat consistent with sustaining
viable populations of black-backed woodpeckers.

The FEIS identified the olive-sided flycatcher, a neotropical migrant bird, as another
fire-dependent species that may have suffered from long-term fire suppression and
salvage logging. Olive-sided flycatchers occur in forest openings (Hutto and Young
1999) that naturally were fire-created. Openings created by timber harvest, may or may
not provide comparable nesting habitat (Hutto pers comm.). Research is underway
(Smucker and Hutto, in prep) to compare olive-side flycatcher nest production between
naturally occurring fire-created openings and timber harvest-created openings. Assuming
that timber harvest may not provide habitat comparable to burns, the effects on olive-
sided flycatchers at the project, Forest, and Regional scales, probably parallel those of
black-backed woodpeckers. Since the fires of 2000 and 2001 exceeded the historic
average by over 2 ½ times (Hillis et al 2002c), and un-salvaged burned areas on the
Flathead, Lolo, and Bitterroot National Forests, will still exceed the historic average after
logging, there is no indication that the olive-sided flycatcher, or any other comparable
migrant bird, is at risk from such projects as Meadow Smith at either the project, Forest
or Region scale.



WOLVERINE
Wolverines are a rather poorly understood species (Ruggiero et al. 1994, Copeland pers
comm). Wolverines are habitat generalists, foraging within all elevations and vegetative
communities on carrion and small mammals. Wolverines are secretive and avoid contact
with humans (Ruggiero et al. 1994). Females den in very remote, high elevation cirque
basins in late winter (Copeland 1996, Foresman pers comm.). Copeland (1996) found
that when denning females were exposed to even low levels of human disturbance, those
females often immediately relocated their dens, often miles away from the original
location. Several researchers have speculated that such behavior to avoid humans could
result in reduced young survival or total den failure (Ruggiero et al. 1994, Copeland
1996). Krebs corroborated this assumption in British Columbia by demonstrating that
wolverine populations had the highest levels of juvenile recruitment (demonstrated by
“normal” age class distribution in a trapped population) within areas where there was no
human disturbance in late winter.

High elevation cirque basins have traditionally received little human activity in late
winter with the exception of downhill ski areas. Kennedy, however, demonstrated that
the recent popularity of backcountry snowmobiling and advent of more powerful
snowmobiles has resulted in substantially increased late winter disturbance into areas
suitable for denning female wolverines (Kennedy In: USDA 1998).
                                                               Meadow Smith Exhibit ____
                                                                          Page 15 of 26


Since backcountry snowmobilers are capable of covering a vastly greater area than cross-
country skiers, and areas accessible to snowmobiles are vastly greater in size than lands
occupied by downhill ski areas, backcountry snowmobiling has been identified as a
possible limiting factor to wolverines in Region One. That is not the only potential
limiting factor. Trapping may be a threat to wolverines since they have a low fecundity
rate and are easily trapped (Ruggiero et al. 1994). Also, since wolverines are highly
mobile, highways may pose a threat from collisions with autos, or may inhibit their
mobility. Backcountry snowmobiling, however, constitutes the most likely National
Forest- managed limiting factor potentially affecting wolverines.

Ongoing research suggests the relationship of snowmobile disturbance and wolverine
denning success is not an absolute. During lynx research in the Pioneer Mountains,
Squires and Ruggiero (in prep) trapped five wolverines in a landscape that in general
receives heavy snowmobile activity. While there was no way of knowing where those
wolverines came from, it suggests that the relative intolerance of denning wolverines to
human disturbance found by Copeland (1996) may vary by individual.

The Meadow Smith FEIS disclosed that the project would have “No Impact” on
wolverines due to the project’s positive effects on ungulates (periodically available as
carrion) and no access changes that might affect habitat connectivity. Areas treated
within the cumulative effects area have no natal den habitat.

Hillis and others (in prep b) identified all natal den habitat in Region One. They
overlayed that data layers with designated wilderness and National parks where winter
snowmobiling was prohibited. Hillis and others (in prep b) concluded that at the Flathead
National Forest scale, 73.1% of all natal den habitat was protected by Glacier National
Park, the Bob Marshall Wilderness Complex, and the Mission Wilderness. This number
is conservative because it ignores lands recommended for wilderness inclusion, which are
currently closed to motorized access, and restrictions on motorized travel in the Travel
Plan. At the Regional scale, Hillis and others (in prep b) concluded that 46.2% of all
natal den habitat was protected by National Parks and designated wildernesses. This
number too, is conservative because it ignores Forest Plan and Travel Plan restrictions. It
also include wolverine habitat in eastside “island forests” not continuously occupied by
wolverines (Copeland pers comm.).

A summary of protection provided to natal den habitat at the previously discussed scales
follows in Table 4.

Table 4. Summary of wolverine natal den habitat and acres and percentage protected by
wilderness, National Parks, and other agreements at multiple scales.
                                  Project Cumulative       Flathead National
                                                                               Region One
                                 Effects Analysis Area           Forest
 Acres natal den habitat                  0 ac                 631,952 ac     5,186,854 ac
 Acres/% protected by
                                                               461,668ac      2,397,546 ac
 wilderness and National                   --
                                                                73.1% *         46.2% **
 Parks
                                                                Meadow Smith Exhibit ____
                                                                           Page 16 of 26


       *The 73.1% estimate is low and ignores areas closed to snowmobiling in the North Fork
        Flathead, Jewel Basin, and along the Swan Face.

       ** The 46.2% includes eastside “island forests” that generally lack wolverine
        populations. Most wolverine populations are limited to the “spine of the Rockies” where
        protection is substantially higher than the 46.2% level.


The high percentage of natal den habitat protected at the Flathead National Forest scale
suggests that the majority of reproducing female wolverines should be successfully
producing young. For reasons stated above, habitat protection at the Region One scale is
probably adequate for areas that have sustainable numbers of wolverines. Furthermore,
the 53.8% (100 – 46.2) of wolverine habitat in Region One that is “unprotected” at the
Region One scale includes some additional RARE 2 lands that are closed to
snowmobiling in Forest Plans or Travel Plans, but that were not addressed in Hillis and
others (in prep b). Consequently, the actual Region One percentage of natal den habitat
protected by provisions that exclude snowmobiles, is higher than the levels projected
here. There may be other non- forest variables affecting wolverines (trapping, non-target
trapping mortality, highway road-kill, etc). These high percentages of well-distributed
protected, natal den habitat, however, suggest that current levels of motorized access are
not in conflict with sustaining viable populations of wolverines at the Meadow Smith
project, Forest or Region One scales.


FLAMMULATED OWL

Habitat for the flammulated owl, defined as open stands of old ponderosa pine, may have
suffered the greatest departure from historic conditions of any habitat in the forested
portions of Region One (see introduction). Hillis and others (2002a) concluded most of
the remaining habitat for the flammulated owl, estimated at 12-16% of historic levels,
occurs on the Nez Perce, Bitterroot, and Lolo National Forests. Only very small, isolated
amounts of habitat occur on the Flathead National Forest. One of the largest
concentrations of habitat on the Flathead National Forest is in the Meadow Smith project
area. Nonetheless, such small amounts of habitat may be biologically important because
of the genetic variation typical in populations on the “periphera of the range.”

Status of Flammulated Owls at The Project and Cumulative Effects Area
The FEIS concludes that all remaining habitat in the project area has suffered major
changes in stand structure. Stands that were historically open and dominated by
ponderosa pine and larch are now dense, multi-storied, and increasingly dominated by
climax conifers. Those stands are at severe risk of loss to stand-replacing fire, insects,
and disease. Because of short-term disturbance associated with timber harvest and
underburning, the FEIS concludes that the project “may impact individuals but will not
lead to federal listing.”

Status of Flammulated Owls at the Forest and Region One scales
                                                                Meadow Smith Exhibit ____
                                                                           Page 17 of 26

Hillis and others (2002a) concluded that flammulated owl habitat occurs at about 12 to
16% of the mean historic range of variability at the Region One scale, and 2% of the
mean historic range of variability at the Flathead NF scale (see Table 5). 70% of the
remaining habitat was in condition classes 2 and 3, suggesting most of the remaining
habitat is at extreme risk of stand-replacing fire. Hillis and others (2002a) cited many
examples of recent fires that killed large stands of flammulated owl habitat during the
fires of 1994, 1998, and 2000, as the result of long-term fire exclusion. Hillis and others
(2002a) suggested the remaining habitat should be aggressively treated to remove the
understories and reintroduce low-severity fires. They also recommended an aggressive
program of thinning and underburning young stands to recruit old growth stands. Levels
of flammulated owl habitat at the Forest and Region One scale are summarized in
TABLE 5.

Table 5. Summary of flammulated owl habitat at the project, Forest and Region One scales
                              Project Cumulative         Flathead National
                                                                               Region One
                              Effects Analysis Area            Forest
 Acres potential habitat                                      14,763 ac        539,911 ac
 Acres/% existing habitat                   --
                                                                   134 ac            38,022 ac
 Mean HRV (from Losensky
                                          53%                       53%                53%
 ’93)
 % habitat remaining
 compared to the HRV                                                2%                 13.2%
 (existing ÷ potential)÷.53


Degree to which Meadow Smith Meets Those Recommendations
The Meadow Smith treatment prescriptions are fully compatible with what was
recommended by Hillis and others (2002a). Restoration of old growth ponderosa pine
and western larch habitat, used by flammulated owls, is one of the major goals of the
project. For this reason, the Meadow Smith project is fully consistent with restoring well-
distributed flammulated owl habitat to levels that are needed to maintain viable levels at
the Region One scale.


FISHER

The fisher is a mid-sized member of the weasel family. Fishers are like American
martens in that they are often characterized as interior forest species, i.e. they tend to
avoid edges and openings, and are sensitive to activities that fragment the forest
(Ruggiero et al. 1994). Jones (1991, In: Hillis and Jacobs in prep c) found fishers to
occur in low-to- mid elevation, mesic, mature and old forests. Jones also concluded that
while fishers are capable of traveling across large tracts of forest, 80% of his relocations
were within 100 meters of streams or wet areas. Fishers in Region One are generally
limited to west of the Continental Divide.
                                                                         Meadow Smith Exhibit ____
                                                                                    Page 18 of 26

Hillis and Jacobs (in prep c) mapped fisher habitat in Region One defined as low-to- mid
elevation, mesic, mature and old forests. They included only areas within 100 meters of
streams. To address patch size and habitat connectivity relevant for fishers, they
excluded any patch of habitat that was less than 160 acres and more than 600 feet from
the nearest patch of adjacent cover (Jones 1991, Ruggiero et al 1994, In: Hillis and
Jacobs in prep c). That habitat was compared against levels of habitat that would have
been available in pre- fire suppression/pre- logging periods.

Status of fishers in the Meadow Smith Project Area
The FEIS concluded that the project “may impact individuals but (would) not lead to
federal listing.” That determination was based on the high level of protection provided to
riparian zones, and the unknown effects on fishers associated with thinning dry, low
elevation forests.

Status of Fishe rs at the Forest and Region scales
The current status of fishers at the Forest and Region One scales is disclosed in Table 5.

Table 5. Percentages of existing fisher habitat at the Fl athead National Forest and Region One
Scales.
                                                          HRV *            Fl athead NF       Region One
 Percentages within mature and old age classes      38% to 64% **         74.3%             77.5%
 Significant departure evident?                                           None evident      None evident
*Fro m Losensky (1993)
** Based on the 1900 distribution of mature/old age classes in the grand fir/redcedar and En glemann spruce
cover types


Table 5 suggests that fisher habitat occurs at historically normal levels at both the
Flathead National Forest and Region One scales. This should not be interpreted that
management activities have not had adverse effects on fisher habitat. Rather, when fisher
habitat was mapped, it clearly showed portions of Region One where timber harvest
activities on both corporate and National Forest lands had fragmented and reduced the
acres of existing fisher habitat. Hillis and others (in prep c), however, point out that even
during the 1970s and 80s when timber harvest was intensive, riparian zones were
generally avoided, which could explain why the loss of habitat to fragmentation was not
greater. Additionally, they speculate that the recruitment of mature/old forests due to fire
exclusion, within what are typically very productive sites, could have compensated for
timber harvest-related losses to a substantial degree.

Jones (1991, In: Hillis in prep c) concludes that fishers are e xtremely vulnerable to
trapping. This and other unknown variables that might explain the poor distribution of
fishers in Region One. Based on the availability of habitat at both Flathead National
Forest and Region One scales, however, habitat is not limiting. The activities planned in
the Meadow Smith project are clearly consistent with sustaining well-distributed habitat
to support viable populations of fishers at Forest and Region One scales.


NORTHERN GOSHAWK
                                                                    Meadow Smith Exhibit ____
                                                                               Page 19 of 26


The northern goshawk is a large raptor occupying most forested habitats. Goshawks nest
in dense, multi-storied stands of mature and old conifers (Reynolds 1983, In: Hillis et al
in prep d). Goshawks can nest at maximum densities in fairly developed or fragmented
forests. Clough (2000, In: Hillis et al in prep d) found no difference in the nest density
between undeveloped and developed landscapes. Hillis and others (in prep d) assembled
data from 328 goshawk nests in Region One. They limited the sample to geographic
areas in which the effort to locate nests was rigorous, continuous, and where the nest
searches were conducted consistently (Stahlecker and Kennedy 1993, In: Hillis et al in
prep d). Hillis and others (in prep d) identified the potential vegetation types, size
classes, canopy closures, and elevations that best “explained” those 328 nests. They then
applied those criteria to remaining portions of Region One that had not been rigorously
sampled. This suggested that out of 2350 6 th code hydrologic units (HUC6s) in the
Region (watersheds 10,000 to 30,000 acres in size) no less than 1599 or 68% had habitat
sufficient to support at least one nest. Fine-scale validation of random HUC6s showed
substantially more goshawk nest habitat on-the-ground than predicted. Samson (pers
comm.) noted that the number of HUC6s predicted to contain adequate nest habitat was
substantially lower than the actual nests catalogued in the Nature Conservancy database.
Hillis and others (in prep d) suggested goshawks probably do not warrant their sensitive
status in Region One.

Status of Gos hawks in the Meadow Smith Project and Cumulative Effects Area
The FEIS disclosed that the Meadow Smith project “may impact individuals but not lead
to federal listing.”

Status of Gos hawks at the Forest and Region One scale
On the Flathead National Forest, the abundance of this species is classified as
"uncommon" in summer and winter, and "occasional" in spring/fall. Presence of the
northern goshawk has been reported from all Ranger Districts. Forest and Region One
status is disclosed in the Table 6. Based on Hillis and others (in prep d), of the Forest’s
161 HUC6s, no less than 131 HUC6s or 81% have habitat to support at least one pair

Table 6. Predicted mini mum number of HUC6s with habi tat sufficient to support a g oshawk nest pair.
                                                    Fl athead Nati onal Forest        Region One
 Total number of HUC6s                                              161                  2350
 HUC6s w/ habitat to support at least one pair                      131                  1599
 Percentage                                                        81%                   68%

Note that the percentages of predicted occupied habitat are high at both Forest and
Region One scales. While the Meadow Smith FEIS correctly disclosed that thinning
could have adverse effects on goshawk nesting habitat in some microsites, the broad-
scale data disclosed in Table 6 clearly show such limited treatments constitute no risk to
goshawks at broader scales. Clearly, the activities planned in the Meadow Smith project
will retain well-distributed habitat at the landscape scale, consistent with maintaining
species viability at both Forest and Region One scales.
                                                             Meadow Smith Exhibit ____
                                                                        Page 20 of 26

BOREAL TOAD

Amphibians are declining worldwide (Maxell 2000). It has been suggested that boreal
toads are also declining (Maxell 2000). Various explanations have been offered,
including those typically suggested for all amphibians such as global warming, ozone
depletion, introduced exotic predators, introduced exotic diseases, pesticides, and
chemical pollution. Fish introductions into historically fishless lakes has been shown to
adversely impact spotted frogs in Central Idaho (Pilliod 2000), and it has been suggested
this might also adversely impact toads. An introduced disease, chytrid skin fungus, the
organism presumed responsible for the local extirpation of leopard frogs in western
Montana, may also be reducing toad populations (Maxell 2000). Maxell (pers comm.)
suggested another possibility that might explain declines in toads, which is increased
predation from corvids (ravens and crows). Corvids are behaviorally adapted to prey on
toads. Toads have toxic skin on their backs and are therefore somewhat immune to
predation from birds. Corvids, uniquely, have learned to flip toads on their back and
consume them from the “belly down.” Corvids are considered to be a “weed species,”
(Hutto and Young 1999) meaning they have increased substantially as a result of human
expansion. Consequently, predation from corvids, that might not have been a problem in
pre-human-settlement periods, could be an issue given documented increases in corvid
densities (Hutto and Young 1999).

Toads are terrestrial during their adult life and disperse throughout a mix of forested
habitats. Like all amphibians, however, they reproduce in bodies of water that provide
nursery habitat for the young from eggs through metamorphosis. In Region One, nursery
habitat for toads includes ponds, lakes, and sloughs, and occasionally roadside ditches
and puddles (Maxell 2000). Maxell (2000) describes the density of toads in Region One
as “well-distributed but rare.”

The Meadow Smith FEIS identified no direct or indirect effects on toads, and concluded
that the project would have “No Impact” on toads. All alternatives provide full
protection to nursery habitat through a combination of project design, protective
measures in the Montana Streamside Management Zone Law, Montana Water Quality
Act, and INFISH standards for threatened bull trout.

The protective measures described in the FEIS that include Montana Streamside
Management Zone Law, Montana Water Quality Act, and INFISH, apply equally at
larger scales including the Flathead National Forest, Western Montana Planning Zone,
and that portion of Region One within the state of Montana.

On the Flathead National Forest, toads have been found at 88 locations. Over 80% of
these occurred in two riparian landtypes: NL1A or NL1E. Of the remaining
observations, nearly all were of tadpoles found in roadside ditches, or of adults found
away from breeding habitat. These two landtypes appear to encompass primary breeding
habitat for toads.
                                                                     Meadow Smith Exhibit ____
                                                                                Page 21 of 26

Riparian landtypes NL1A and NL1E are characterized by low gradient (nearly leve l,
valley bottom, 2-4% slopes), with relatively fine substrates (clays, silts, fine and medium
sand), and subalpine fir (NL1A) or willow and sedge (NL1E) potential vegetation
community. These two riparian landtypes comprise a small fraction of the land base, but
are distributed across all ranger districts (Table 7).

Table 7. Ri parian landtypes that likely encompass breedi ng habitat for boreal toad, Flathead
National Forest (mapping completed on non-wil derness lands only).
                                NL1A                       NL1 E                        Total
 Ranger District        Acres       % of land      Acres       % of land        Acres       % of land
 Glacier View             488 ac      0.14%        1,982 ac      0.57%          2,470 ac      0.71%
 Hungry Horse *           250 ac      0.08%        1,098 ac      0.37%          1,348 ac      0.45%
 Spotted Bear *           168 ac      0.09%          664 ac      0.35%            832 ac      0.44%
 Swan Lake *            2,465 ac      0.51%        5,134 ac      1.06%          7,599 ac      1.57%
 Tally Lake             3,083 ac      1.02%        7,680 ac      2.55%        10,763 ac       3.58%
 Forest Total           6,454 ac      0.40%       16,558 ac      1.02%         23,012 ac      1.42%
* = Non-wil derness only


When we consider all the factors that may place toads at risk, failure to protect nursery
habitat would probably be at the top of the list of factors that the Forest Service has
control over. Since protection of riparian habitats is substantial, and somewhat redundant
(multiple laws providing overlapping protection), the decline in toads cannot be attributed
to failure to protect nursery habitat. This suggests that Forest Service Region One
management actions, including the Meadow Smith project, at all those scales, are not
placing toads at risk, and therefore are fully consistent with sustaining viable populations
of toads.




SNAG HABITAT and PILEATED WOODPECKER

The meadow Smith FEIS concludes that snags are critical habitat for snag-dependent
species. The project is designed to protect and recruit large diameter ponderosa pine,
larch, and Douglas- fir including large diameter snags.

Status of snags and snag dependent species at the Region One scale- Hillis and others
(2003) assessed the status of snag habitat and snag-dependent species Region One. West
of the continental divide, the analysis was designed to address the habitat needs of the
pileated woodpecker. Hillis and others conclude: 1) the distribution of mature/old forest,
that provides nesting habitat for pileated woodpeckers, has not changed substantially
since pre- fire-suppression/pre-logging periods; 2) the ratio of mature to old forest has
changed substantially on low elevation forests west of the continental divide; 3) partial
removal timber harvest and woodcutting (as facilitated by road access) accounted for an
additional loss of 28% of the snags across Region One lands; and 4) fire exclusion,
particularly as it affects the occurrence of low-to-moderate severity fires has severely
threatened the recruitment and durability of snags.
                                                                        Meadow Smith Exhibit ____
                                                                                   Page 22 of 26


Status of snags and snag-dependent species at both the Forest and Region One, west
of the continental divide scales.- TABLE 8 compares the status of snags at both the
Forest and Region One scales.

Table 8. Levels of mature/ ol d forest at the Forest and Region One scales, relati ve to the Historic Range
of Variability (HRV)
                                                           Fl athead Nati onal Forest       Region One,
                                                                                               Westside
 Acres of potential habitat                                         1,455,982               10,520,384 ac
 Acres of existing habitat                                            720,062                5,128,766 ac
 Percentage of mature/old forest (existing/potential)                   49.5%                   48.8%
 HRV                                                            24.7 to 72.1%               24.7 to 72.1%



Table 8 suggests that there has been no substantial departure in snag densities from
historic levels at either the Forest or Region One scale. A more significant finding of
Hillis and others (2003) is that there has been a huge shift in the ratio between mature
and old forest in low elevation forests, i.e. little old forest remains with higher-than-
normal levels of mature. Even more alarming, Hillis and others (2003) conclude that
snags and old live trees are at high risk on 70% of those remaining old, low elevation
stands. Consequently, the treatments prescribed in Meadow Smith, which are focused on
recruiting and protecting old, low elevation ponderosa pine and larch stands, are fully
compatible with the findings of Hillis and others (2003).

At the Flathead National Forest scale, Amendment 21 (USDA 1999) provides further
direction for the management of old growth forests that contain large snags. Key
elements of that direction include: 1) treatments within old growth forests are limited to
those that “maintain or restore old growth composition and structure, consistent with
native succession and disturbance regimes”; 2) “provide an amount (of old growth
forest) that is within the 75% range around the median of the historical range of
variability”; and 3) manage for natural patterns, processes, snags and coarse, woody
debris. Since old growth forests provide the best opportunities for snag recruitment,
Amendment 21 suggests that there is excellent potential for long-term recruitment of snag
habitat for snag-dependent species, consistent with historic conditions at the Forest scale.

When we consider the emphasis on managing old growth forests (USDA 1999), and the
large number of recent fires on the Flathead National Forests in 1988, 1994, and 2001
that recruited large numbers of snags, we can conclude that at the Flathead National
Forest scale, snag habitat is being both recruited and retained (after natural events) at
higher-than-normal levels. Consequently, we can assume that the Meadow Smith
Project, recognizing its emphasis on recruiting and protecting large diameter trees and
snags, is fully consistent with sustaining well distributed snag habitat and snag-
dependent species including the pileated woodpecker.
                                                              Meadow Smith Exhibit ____
                                                                         Page 23 of 26

DEER AND ELK

Elk, and in most cases mule deer and white-tailed deer, are given substantial attention in
all Region One Forest Plans. The factors that affect deer and elk are numerous and in
western Montana and include fire exclusion, noxious weed invasion, loss of security
cover, road management, loss of winter ranges to subdivision, and more recently
habituation of white-tailed deer to human development, which in some areas places them
in a nuisance category.

The issues surrounding deer and elk are all focused on producing high numbers of deer
and elk for hunting and/or wildlife viewing. In Montana, Montana Department of Fish,
Wildlife, and Parks (MDFWP) regulates hunting on all lands within and surrounding the
Flathead National Forest. In all MDFWP Regions and hunting districts statewide,
MDFWP biologists identify harvestable surpluses of deer and elk, and fix hunting
seasons and bag limits designed to remove that surplus. In an absence of hunting,
MDFWP publicly concludes that surplus would be lost to winter-killed mortality.

Viability of deer and elk is seldom a concern in North America. There are exceptions.
Florida’s keys white-tailed deer are clearly imperiled with extinction due to massive and
almost total subdivision of its habitat in Southern Florida. There are no comparable
threats to deer and elk in Montana or on the Flathead National Forest. A high percentage
of lands are publicly-owned. While a small percentage of winter ranges are at risk due to
subdivision, most winter ranges are in public ownership across western Montana. Since
deer and elk are disturbance-dependent, the recent fires in 1988, 1994, 2000, and 2001
will ultimately prove beneficial to most populations.

Given the lack of concern over viability of deer and elk on the Flathead National Forest
and within Region One, we can assume the effects of the Meadow Smith project, which
are generally positive for deer and elk, are consistent with maintaining viable
populations of deer and elk at Forest and Region One scales.
                                                                  Meadow Smith Exhibit ____
                                                                             Page 24 of 26

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Copeland, J. P. 1996. Biology of the wolverine in central Idaho. MS. Thesis. University of
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Copeland, J. P. Personal Communication regarding wolverine distributions in Region One.

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                                                                   Meadow Smith Exhibit ____
                                                                              Page 25 of 26


Hillis, J. Michael, Lorraine Clough, and Dave Lockman. In preparation d. An assessment of
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                                                                              Page 26 of 26
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