To: US Forest Service -- Monongahela National Forest, Supervisor Charles Myers and Daniel Arling

Comments on Proposal to Amend the 1986 Monongahela NF Plan Regarding Threatened and Endangered Species

These comments pertain to the Feb. 1, 2001 letter, the November 2000 Biological Assessment (BA), and the 1986 Plan.

I thoroughly object to the short time period I have had to comment on this proposal. I just got the BA (~140 pages) and have only had a week to review it. This is a significant, complex, and Forest-wide proposal. I formally request that the comment period on your scoping letter be extended another 30 days.

The Monongahela National Forest [MNF] is in the midst of rewriting its management plan for threatened and endangered species on the forest. The plan outlines an increase in logging of 10 million board feet more (from 15 to 25 MMBF, almost double what it is now) and 100 acres of herbicide application a year. The plan also projects development of 68 gas well sites serviced by 19 miles of new roads and 82 miles of gas pipelines in the next 10 years.

It is not clear how many acres you will spray with insecticides (e.g., for gypsy moth "control"). And this Forest has been fragmenting forestland with an average of 35 miles per year of new system road for the last 13 years; but "only" plans on 15 miles per year in the future (and this is just "system" road; how much temporary {sic} road do you foresee?).

There is some commendable effort happening here and I thank you, but my overall impression upon reading the BA is: This is disgraceful and reprehensible; business as usual is the apparent priority, not the ecological requirements for the recovery of these unfortunately imperiled populations. If you ever wonder why more and more people think that when it comes to the Forest Service, the appearance of careful management is actually the careful management of appearances, look no farther than here. This proposal/BA appear not as a real plan to protect Threatened and Endangered species, but instead as a way to facilitate increased logging and other destructive activities on the National Forest. It is being pushed through on an expedited time line in order to continue developing the Forest and open up land for more logging and mining and roading and poisoning as soon as possible.

For just two examples : (1) from reading the BA it turns out that logging, prescribed fires, road construction/reconstruction, forest fragmenting "wildlife openings," grazing allotments, "mineral activity" and gas developments are all beneficial to Indiana Bats. Since all of these habitat developments have been going on in the forests of WV and the MNF for decades, we should be up to our asses in Indiana Bats. But we’re not; I guess those stupid Bats just don’t know how good they’ve got it. (2) We are told "[m]ost timber harvesting projects [why not ALL?] now employ ...mitigation measures" (BA-18). And what is this so-called "mitigation?" Logging that results in removal of 1/4 to 1/2 or even more of the riparian canopy. And you have the nerve to refer to this sorry state as an "increased emphasis on riparian area protection."

Overall, there appears to be very little thought (and far less proposed action) given to what is necessary for, and the effects of management activities on, recovery of thriving populations. But that is the intent of the Endangered Species Act and National Forest Management Act (see 36 CFR 219.19(a)(7); it is certainly possible on the MNF for objectives and conservation measures, far beyond the oftentimes meagre measures described in the BA, that provide for the removal of species from listing). For just one example, see the section on the Bald Eagle. The one Eagle nesting site on the MNF is in a 6.2 management area with no roads nearby, steep slopes, and well buffered by mature forest. Here is a species that "prefer[s] areas with limited human activities ...shootings and disturbance at nest sites are the biggest factors affecting eagles in this state" (BA-25). And yet every management activity assessed is said to result in "no effect" or to "not likely adversely affect;" some treecutting may even be "beneficial." Apparently the tack is taken that as long as the nesting site in the 6.2 area (the least disturbed MA in the Forest after Wilderness) is maintained with little disturbance, then activities that degrade habitat elsewhere are okay, even at potential habitat areas such as Buffalo, Summit, Spruce Knob, and Sherwood Lakes.

Discounting obvious destruction and degradation of habitat does not, cannot, aid in recovery of viable populations of Eagles on the Forest.

The Forest Service is not entering into formal consultation with Fish and Wildlife Service [FSW] on this plan, except on the Indiana Bat. But the consultation on the present Forest Plan is over 15 YEARS old, and the present state-of-the-science information is much changed (as have ecosystems and public concerns). The FS needs to enter into formal consultation with Fish and Wildlife, for ALL ESA listed species (i.e., Bald Eagle, Cheat Mountain Salamander, Virginia Big-eared Bat, West Virginia Northern Flying Squirrel, Running Buffalo Clover, Shale Barren Rock Cress, Small- whorled Pogonia, and Virginia Spirea). The FWS and USFS are required to protect all Threatened and Endangered species. The public must also be allowed to formally comment on changes proposed for all species Recovery Plans.

The Forest Service has issued a Biological Assessment on threatened and endangered species and has now started the comment process. You are starting the amendment process before Fish and Wildlife has completed their Biological Opinion setting forth Terms and Conditions the Forest Service must follow in protecting threatened and endangered species. The Proper procedure is to ask the public to comment after Fish and Wildlife has commented on the Monongahela Forest document. The Forest Service is guessing at what Fish and Wildlife will say and jumping ahead of itself to save time. Proper procedures must be followed. The public must have clear and ample opportunity to review Fish and Wildlife’s requirements along with the Forest Service’s comments. Is that what the EA to be developed is for?

The public has a right to comment on the details of these proposed management changes before any decision is rendered.

The amendment does not cover "sensitive species" which it should. The plan describes benefits from some form of logging for most threatened and endangered species -- and even says that most of them are not affected by, or even benefit from herbicide spraying, controlled burns, gypsy moth spraying, gas drilling, and road building. Many of these species depend on older growth forests for food and shelter, undisturbed caves, clean mountain streams, and an undisturbed forest floor. The Forest Service assumptions are not backed by common sense or the best science. The Forest Service Biological Assessment, which is the basis for the amendment, is not based on sufficient research. The Forest Service needs to consider the impacts of the management plans outlined in the Biological Assessment on Sensitive species and species being considered for listing as well as on threatened and endangered species.

Surveys for most species in the past have been inadequate. The Forest Service needs to have "quantifiable recovery objectives" in their plan. Before the Monongahela Forest Plan is amended, adequate surveys should be done for all species. This should include monitoring to determine "distribution, status and trends for threatened, endangered, proposed and sensitive species and their habitats on Forest lands" to give the Forest Service quantifiable objectives. The Forest Service should not move forward with their plan until adequate studies are done on all PETS species.

The current S&G in the Plan (pg. 84) refers to "habitat critical to endangered and threatened ... species ... and critical habitat areas." Precisely what (acreage figures and location) "critical habitat" has been identified and designated on MNF lands for each of the T&E species? Please send me copies of the documents and maps defining and describing these areas. If critical habitat has not been designated for any of these species, why not and when will it be? This identification is required to be done as part of any on-going Plan revision or amendment (see 36 CFR [code of federal regulations] 219.19(a)(7)).

Are you using "Areas of Influence" as a substitute for "critical habitat?"

What is the legal relationship of "Areas of Influence" with "critical habitat?" Do "areas of Influence" carry the weight of law or regulation, or is this just a discretionary term used by FS planners that has no enforcement capability?

Regarding the Cheat Mountain Salamander [CMS]: where is the "Figure 6" referred to on pg.31? Habitat fragmentation, genetic isolation of populations, and habitat disturbance all contribute to their vulnerability and limited occurrence. Thus, roads have very negative affects on this species. So why is "mineral activity" (with its associated road construction/reconstruction) allowed in CMS habitat (see BA-38)? And to simply not allow roading and logging in "occupied" or "high potential" CMS habitat does not address the issues of fragmentation of populations (e.g., impeding movements or gene flow) or of indirect impacts to populations (e.g., increased edge predators). Degradations to their entire habitat area and metapopulations are not being addressed. Strict road density standards (i.e., no more than 0.5 miles/1000 acres), as well as limitations on other disturbance, need to be implemented for the Salamanders’ entire limited range, including standards mandating road decommissioning and obliteration. The Salamanders’ entire range on the MNF should be allocated to a special management area designation (e.g., Special Biological Area) with minimal disturbance allowed. This would do much to help recover their numbers and secure the species future. The BA fails to consider global warming scenarios on future habitat availability.

Regarding the Indiana Bat [IB]: this section of the BA is rife with contradiction, ill-logic and obfuscation. It is not clear how it is that killing their prey (lepidopterans) with nonspecific gypsy moth poisons is "not likely to adversely affect" them. And why isn’t it possible to gate every known hibernaculum on the Forest? If they were receiving the requisite top priority, this would be done (unless doing so would alter airflow or microclimate). This is an ENDANGERED species; they need all the help we can give them. At least 35 snags per acre is optimal (BA-41); so why only retain a minimum of 6/acre in cutting units? ALL snags should be retained. In addition, actual protection of riparian areas (by not cutting them) would no doubt benefit this species more than the present weak riparian strictures. The fact (?) that wintering IB populations in WV have increased since the MNF implemented its Plan does NOT indicate that Forest activities are not negatively affecting IBs upon leaving their hibernacula. And you apparently would have us believe that when habitat within 5 miles of their winter caves is destroyed or degraded while the Bats are hibernating, then it doesn’t adversely affect them. (What, if somebody destroyed your home and vehicle while you were asleep, impeding and depriving you of the means for going to work and making a living, you wouldn’t notice it when you woke up?) This finding is not supported by sound science or logic, and as such is unprofessional and illegal. ALL spring, summer, and fall habitat on the MNF within 5 miles of winter hibernacula should be allocated to a special management area designation (e.g., Special Biological Area) with minimal disturbance allowed. This would do much to help recover their numbers and secure the species future. The current state of scientific information on this species makes it clear that their life history requirements are best met by old growth forest conditions. I do not have time now to submit all my comments about IBs.

Gypsy Moth poisoning within the 6-mile foraging radius of the Virginia Big-eared Bat would adversely affect them (BA-67, 71).

It is not clear what you are proposing where for the West Virginia Northern Flying Squirrel [WVNFS]. Are all "299,400 non-Wilderness acres" (BA-79) where "vegetation management activities would not be allowed ..." (BA-94) ? ALL these acres should be strictly protected. What is the total estimated population of WVNFS on the MNF? The Squirrels are known to use forest types other than those referred to on BA-81. They eat acorns. Some oak forest types may have a significant component of conifer and/or northern hardwood species (I am thinking particularly of high elevation sites in Pocahontas and Pendleton Counties adjacent to Highland County, VA). These too should be protected.

I have further comments which I will addend at a later date.

Sincerely,

Steven Krichbaum March 12, 2001