BIOLOGICAL OPINION

on the

Programmatic Biological Assessment of the Huron-Manistee National
Forests

Land and Resource Management Plan

(January 2003)

Submitted to the U.S. Forest Service

June 12, 2003

Prepared by:

U.S. Fish and Wildlife Service

East Lansing Field Office

2651 Coolidge Road, Suite 101

East Lansing, Michigan 48823

[Consultation history]{.underline}

On March 18, 1985, the HMNF requested formal consultation on the
implementation of the proposed Land and Resource Management Plan (LRMP).
On September 17, 1985, we issued a non-jeopardy biological opinion:
Peregrine falcon (*Falco peregrinus*), Kirtland's warbler (*Dendroica
kirtlandii*), and bald eagle (*Haliaeetus leucocephalus*); and the
piping plover (*Charadrius melodus*), which was proposed for listing at
that time.

On November 11, 2000, we received a letter from the HMNF indicating that
the Forest wished to begin a programmatic consultation on the effects of
the LRMP on seven listed species. This letter included a Statement of
Work to be used to contract the writing of a biological assessment for
the consultation. A series of pre-consultation meetings were held on
January 22, April 30, and May 1, 2001 to discuss the issues of the
consultation, the format and content of the biological assessment, and a
timeline for completion of the programmatic consultation.

In June of 2001, we received a draft of the biological assessment for
review and issued comments to the HMNF in a letter on July 11, 2001.
After incorporation of many these comments, the HMNF submitted another
draft biological assessment (only the sections regarding listed species)
via email on September 27, 2001. We reviewed this draft and provided
additional comments via facsimile on November 20, 2001. These comments
were further discussed in meetings between the Service and the HMNF on
November 26-27, 2001. Further issues were discussed in a meeting between
the Service and the HMNF on February 15, 2002. After additional comments
were reviewed and incorporated, another draft of the biological
assessment was submitted to the Service in June 2002.

On November 18, 2002, the HMNF requested initiation of formal
consultation with a final biological assessment that concluded that the
continued implementation of the LRMP would have no effect on the
Michigan monkey-flower, Houghton\'s goldenrod, American burying beetle,
and Hungerford's crawling water beetle; would be not likely to adversely
affect the Great Lakes piping plover; and would be likely to adversely
affect the Karner blue butterfly, Indiana bat, and Pitcher's thistle. We
concluded that the November 18 biological assessment did not constitute
a complete initiation package. The Service and the HMNF met on December
11, 2002, to further discuss issues and comments regarding the
biological assessment. At this meeting, it was established that
additional modifications to the biological assessment were necessary
before formal consultation could proceed. A December 16, 2002 letter to
the HMNF further detailed our comments and information requests.

A telephone conversation on December 19, 2002 and a January 14, 2003
meeting between Mr. Rex Ennis (HMNF) and Ms. Jessica Gourley (Service)
provided an additional forum for discussion. After incorporation of our
comments, the HMNF submitted a second request for initiation of formal
consultation and final biological assessment on January 17, 2003. We
evaluated this biological assessment and, in a letter dated February 7,
2003, informed the HMNF the initiation package was complete and the
formal consultation would begin effective January 17, 2003. We requested
and received a variety of additional documents and information from the
HMNF via telephone, email, or facsimile during the formal consultation
process.

**[BIOLOGICAL OPINION]{.underline}**

**DESCRIPTION OF THE PROPOSED ACTION**

As defined in 50 CFR 402.02, "action" means all activities or programs,
of any kind, authorized, funded, or carried out, in whole or in part, by
Federal agencies in the United States or upon the high seas. The "action
area" is defined as all areas to be directly or indirectly affected by
the effects of the actions (including the proposed action and any
interrelated or interdependent actions) and not merely the immediate
area involved in the action. The direct and indirect effects of the
actions and activities from the Federal action must be considered in
conjunction with the effects of other past and present Federal, State,
or private activities, as well as cumulative effects of reasonably
certain future State or private activities within the action area.

The proposed action considered in this Opinion is the continued
implementation of the existing Huron-Manistee National Forests Land and
Resource Management Plan (LRMP), as amended, including additional
species conservation measures (USDAFS 2003a). The purpose of the LRMP is
to "provide direction for the multiple use management and the sustained
yield of goods and services from the National Forest System lands in an
environmentally sound manner" (USDAFS 1986a). The LRMP represents a
programmatic planning document that establishes HMNF management goals
and objectives, specifies Standards and Guidelines for management
activities, and establishes monitoring and evaluation requirements.
Management directions and associated activities that are planned,
funded, executed, or permitted by the HMNF are implemented in accordance
with the provisions contained in the LRMP.

Since the LRMP was signed in 1986, additional species have been listed
as endangered or threatened under the Act and new information about the
status of species listed before 1986 has become available. Therefore,
the potential effects of LRMP implementation on those species were not
considered in the September 17, 1985 biological opinion. Based on the
results of this 2003 consultation, the Forest Service will amend its
LRMP to contain provisions for the species or information not previously
considered. Table 1 lists the species considered by the Forest Service
in this proposed action and associated new information for each.

Table 1. New species information to be considered.

+------------------------------+---------------------------------------+
| **Species**                  | **New Information Considered in this  |
|                              | Proposed Action**                     |
+==============================+=======================================+
| Michigan monkey-flower       | Listed as endangered in 1990          |
|                              |                                       |
| (*Mimulus glabratus var.     |                                       |
| michiganensis*)              |                                       |
+------------------------------+---------------------------------------+
| American burying beetle      | Listed as endangered in 1989          |
|                              |                                       |
| (*Nicrophorus americanus*)   |                                       |
+------------------------------+---------------------------------------+
| Hungerford's crawling water  | Listed as endangered in 1994          |
| beetle                       |                                       |
|                              |                                       |
| (*Brychius hungerfordi*)     |                                       |
+------------------------------+---------------------------------------+
| Great Lakes piping plover    | Critical habitat designated on the    |
|                              | HMNF in 2001                          |
| (*Charadrius melodus*)       |                                       |
+------------------------------+---------------------------------------+
| Karner blue butterfly        | Listed as endangered in 1992          |
|                              |                                       |
| (*Lycaeides melissa          |                                       |
| samuelis*)                   |                                       |
+------------------------------+---------------------------------------+
| Indiana bat                  | Species discovered on HMNF in 1994    |
|                              |                                       |
| (*Myotis sodalis*)           |                                       |
+------------------------------+---------------------------------------+
| Houghton's goldenrod         | Listed as threatened in 1988          |
|                              |                                       |
| (*Solidago houghtonii*)      |                                       |
+------------------------------+---------------------------------------+
| Pitcher's thistle            | Listed as threatened in 1988          |
|                              |                                       |
| (*Cirsium pitcheri*)         |                                       |
+------------------------------+---------------------------------------+

This Opinion considers only those species that may be affected by the
proposed action. The HMNF determined that the Michigan monkey-flower,
American burying beetle, Hungerford's crawling water beetle, and
Houghton's goldenrod are not present within the action area and will not
be affected ([no effect]{.underline} determination) by this proposed
action; therefore, these species will not be considered further in this
Opinion.

The HMNF determined that the proposed action may affect, but is [not
likely to adversely affect]{.underline} the piping plover and critical
habitat, and is [likely to adversely affect]{.underline} the Karner blue
butterfly, Indiana bat, and Pitcher's thistle. We concur with these
determinations and the following Opinion addresses whether the proposed
action of continued implementation of the LRMP as amended, including any
interrelated or interdependent actions, is likely or not likely to
jeopardize the continued existence of these species.

The proposed action represents an interim measure required to
specifically incorporate new information on listed species and critical
habitat into the current LRMP, as previously discussed. Scheduled
revision of the LRMP, including all aspects of forest management, is in
progress and will require additional consultation upon its completion.
The terms of this consultation will apply to the implementation of the
current LRMP until a new consultation on the revised LRMP is completed.
Based on current estimates, completion of the revision of the LRMP is
planned for March 2006 (Rex Ennis, HMNF, pers. comm. 2003). The analyses
contained in this Opinion are therefore reflective of an approximate
3-year time period. The HMNF will need to reinitiate this consultation,
if at the end of this time period, new information becomes available
regarding implementation of this LRMP. Thus, the estimated 3-year time
period does not represent a deadline, but merely a relevant time frame
for analyses given the HMNF's current LRMP revision schedule.

**Programmatic Consultation Approach**

This programmatic biological opinion establishes a two-level
consultation process for activities completed under the LRMP (Table 2).
Evaluation of the LRMP at the plan level represents the Level 1
consultation and all subsequent project-specific evaluations for future
actions completed under the LRMP are the Level 2 consultations. Under
this approach, the Level 1 programmatic opinion establishes guidelines
and conditions that each individual future project must adhere to and
operate within to remain consistent with the scope of the Level 1
opinion; these future projects will be subject to Level 2 consultations.
The Level 1 programmatic opinion and incidental take statement (ITS)
will estimate the level of incidental take that is anticipated to occur
from future Level 2 projects. Due to the temporal and spatial
uncertainty that exists at the LRMP level regarding this anticipated
incidental take, however, incidental take will be exempted in the Level
2 biological opinions for site-specific actions as they are proposed,
consulted on, and appended to the programmatic opinion (specific details
of this process are described below). This will help ensure that the
HMNF adheres to the reasonable and prudent measures needed to
appropriately minimize the impacts of the incidental take that will
result from the Level 2 action under review, while not being
inappropriately burdened by those reasonable and prudent measures that
are pertinent to other Level 2 actions.

Table 2. Outline of a programmatic consultation approach.

  ------------------- ---------------------------------------------------
  Level 1             Establishes guidelines and conditions applicable to
  Consultation and    all future projects
  Biological Opinion  

                      ITS estimates incidental take that is anticipated
                      to occur from all future projects, but does not
                      provide exemption

  Level 2             Establishes project-specific guidelines and
  Consultation and    conditions
  Biological Opinion  

                      ITS estimates and exempts incidental take that is
                      expected for each project, including appropriate
                      reasonable and prudent measures and terms and
                      conditions
  ------------------- ---------------------------------------------------

Under this programmatic approach, the Forest Service must continue to
review all future individual projects to determine if they may affect a
listed species or designated critical habitat. Future projects that [may
affect]{.underline} listed resources are subject to Level 2
consultation; written notification to the Service, including a
biological assessment as necessary, of such projects is required.
Projects that may affect, but are [not likely to adversely
affect]{.underline} listed species or designated critical habitat will
require written concurrence from the Service through informal Level 2
consultation. In most cases the response time for these concurrences
should be significantly abbreviated. Projects that are [likely to
adversely affect]{.underline} listed species or designated critical
habitat will be individually reviewed to determine: 1) whether they were
contemplated in the Level 1 programmatic opinion and 2) if they are
consistent with the guidelines established in the Level 1 programmatic
opinion and whether the reasonable and prudent measures and terms and
conditions provided in the incidental take statement are applicable.
This will ensure that the effects of any incidental take resulting from
individual projects is minimized. In response, we will produce a Level 2
opinion that will be appended to the original programmatic opinion.
Level 2 opinions will update the status of the species and environmental
baseline project-by-project, as appropriate. The Level 2 opinions will
provide exemption for some incidental take in accordance with the
reasonable and prudent measures and terms and conditions provided in the
Level 1 programmatic incidental take statement, plus any additional
project-specific measures required to minimize effect of the incidental
take, as necessary. The original programmatic opinion taken together
with all project documentation contained in the Level 2 opinion will
make up the complete biological opinion for each Level 2 project. In
most cases implementing a programmatic consultation approach should
significantly reduce the time required to complete formal consultation
(e.g., 30 days instead of 90 days).

Future projects that are likely to adversely affect listed species or
critical habitat, and do not adhere to the guidelines and conditions
evaluated during the programmatic consultation, or any future projects
that are considered to be outside the scope of the proposed action or
LRMP, may require separate formal consultations.

**Action Area**

The proclamation boundary of the HMNF includes 2,025,769 ac (819,817 ha)
located in two forest units, one in eastern and one in western Lower
Michigan (Figure. 1). The Huron National Forest (Huron NF), located in
Alcona, Crawford, Iosco, Ogemaw, and Oscoda counties in the northeastern
portion of the Lower Peninsula of Michigan, is divided into three Ranger
Districts: Tawas, Harrisville, and Mio. These districts are managed out
of two ranger stations, one at Mio and the other at Oscoda, Michigan.
The Huron NF boundary encompasses 694,098 ac (280,898 ha), 433,915 ac
(175,603 ha; 63 percent) of which are National Forest System lands
managed by the Forest Service (USDAFS 1999). The Manistee National
Forest (Manistee NF), located in Lake, Manistee, Mason, Mecosta,
Montcalm, Muskegon, Oceana, Newaygo, and Wexford counties in the
northwestern one-quarter of Michigan's Lower Peninsula, is divided into
four Ranger Districts: Baldwin, Cadillac, Manistee, and White Cloud.
These districts are managed out of two ranger stations, one at Manistee
and one at Baldwin, Michigan. The Manistee NF boundary encompasses
1,331,671 ac (538,920 ha), 534,916 ac (216,478 ha; 40 percent) of which
are National Forest System lands managed by the Forest Service (USDAFS
1999).

![](media/image1.wmf)

Figure 1. Map of the Action Area (form USDAFS 2003a)

The Ecological Classification and Inventory System defines ecological
land classification units on the HMNF and describes their
characteristics. This system uses climate, geomorphology, landform,
soils, hydrology, and vegetation to define Landtype Associations (LTA's;
USDAFS 1999). Landforms categorize terrain by general shape. They
incorporate information on the presence of geology and potential
vegetation type. Combinations of landforms and geologic units (bedrock
and surficial) form a variety of LTA's on the Forests (Table 3). The
LTA's utilize landform information and reflect landscape scale physical
characteristics that remain fairly stable over time because they are
resistant to land use practices. The most common landtype associations
are classified as outwash, moraines, and sandy hills, representing 80
percent of the acreage of the HMNF.

Table 3. Landtype Associations of the Huron-Manistee National Forests
(from USDAFS 2003a).

+---------------------------+------------------+-----------------------+
| **Landtype Association**  | **Total Forest   | **LTA % of**          |
|                           | Acres**          |                       |
|                           |                  | **Total Forest        |
|                           |                  | Acres**               |
+---------------------------+------------------+-----------------------+
| 1-- Outwash               | 435,537          | 45%                   |
+---------------------------+------------------+-----------------------+
| 2 -- Sandy Hills          | 148,068          | 15%                   |
+---------------------------+------------------+-----------------------+
| 3 -- Moraines             | 188,396          | 20%                   |
+---------------------------+------------------+-----------------------+
| 4 -- Wet Plains           | 52,003           | 5%                    |
+---------------------------+------------------+-----------------------+
| 5 -- Alluvial / Fluvial   | 101,743          | 11%                   |
| Organics                  |                  |                       |
+---------------------------+------------------+-----------------------+
| 6 -- Clay Hills / Plains  | 16,220           | 1.6%                  |
+---------------------------+------------------+-----------------------+
| 7 -- Ground Moraines      | 15,398           | 1.6%                  |
+---------------------------+------------------+-----------------------+
| 8 -- Dunes                | 2,566            | 0.3%                  |
+---------------------------+------------------+-----------------------+
| Unknown                   | 5,148            | 0.5%                  |
+---------------------------+------------------+-----------------------+

Soils on 90 to 95 percent of the HMNF have sandy surfaces. The low
relief of the Forests, in combination with low compaction and high
permeability of sandy soils, combine to minimize erosion. Loamy soils,
including peats, are associated with lowlands and moraines of the HMNF.
The stratigraphic record of the HMNF indicates that the majority of rock
formations in the area are of marine origin. No rock outcrops occur on
the Forests.

Topography on the HMNF indicates glaciation, varying from level to
undulated and broken. HMNF lands are located in the Michigan Basin, a
glacial environment with deep deposits of sand and gravel common across
the area (USDAFS 1986b). Most of the hills are low and rolling, but may
occasionally be greater than 230 ft (70 m) high, with a 1312-ft (400-m)
range of elevation across the Forests (USDAFS 1999).

Approximately 93 percent of the HMNF is forested, with the remaining 7
percent of land including marshes, shrubs, swamps, leatherleaf bogs, and
maintained openings (USDAFS 2003a). Hardwoods are the most abundant
forest type (USDAFS 1986, 2003). Outwash plains with conifer forest
dominate the Huron NF. The Manistee NF consists of outwash plains and
moraines, which support a mixture of conifer and deciduous forest
species. Long-rotation oaks and northern hardwoods are present on
202,828 ac (82,083 ha) in the Forests, with an additional 145,315 ac
(58,808 ha) in short-rotation hardwoods (USDAFS 1999). Dominant hardwood
species include northern red oak (*Quercus rubra*), black oak (*Q.*
*velutina*), white oak (*Q. alba*), sugar maple (*Acer saccharum*) and
beech (*Fagus grandifolia*). Big-toothed aspen (*Populus*
*grandidentata*), trembling aspen (*P. tremuloides*) and birch (*Betula*
spp.) stands are found on 170,164 ac (68,864 ha). Long-rotation red and
white pine (*Pinus resinosa* and *P. strobus*) stands are present on
191,265 ac (77,404 ha) in the Forests, with an additional approximate
117,133 ac (47,403 ha) in jack pine (*P. banksiana*) short-rotation
stands (USDAFS 1999). Lowland conifers are present on 29,999 ac (12,140
ha). Dominant lowland species include northern white cedar (*Thuja
occidentalis*), tamarack (*Larix laricina*), balsam fir (*Abies
balsamea*), hemlock (*Tsuga canadensis*), and spruce (*Picea* spp.).

Historical land usage, including logging, wildfires, agriculture, and
burning significantly reduced woody forest vegetation (USDAFS 1999).
Since then much of the area has been reforested. Increases in human
population density and recreational use within and around the HMNF have
occurred in the last decade. These land use changes have more recently
reduced forest lands.

HMNF contains 1,779 mi (2,869 km) of stream, 17,496 ac (7,081 ha) of
lakes, and approximately 57,000 ac (23,068 ha) of wetland habitats
(USDAFS 1986b). Wetland types include sedge meadow, marsh, open water,
shrub swamp, wooded swamp, and bog. Huron NF contains headwaters of four
major river basins, while eight major rivers flow through Manistee NF.
Fisheries and watershed projects focus on reducing deposition from
erosion and restoring in-stream structure. In addition, Consumers Energy
Company (Consumers) currently operates 11 hydroelectric facilities on
HMNF streams and rivers (USDAFS 1999).

Special Interest Area designation provides protection for unique areas
that have scientific, biological, geological, historical, or
recreational characteristics of local, regional, or national
significance. HMNF currently has twelve designated Special Interest
Areas (Management Area 8.1) totaling over 47,000 ac (19,021 ha). These
include Au Sable National Scenic River; Bear Swamp; Loda Lake Wildflower
Sanctuary; Lumberman\'s Monument; Manistee National Recreation River and
Bear Creek National Scenic River; Newaygo Experimental Forest; Newaygo
Prairie Ecological Study Area; Pere Marquette National Scenic River;
Pine National Scenic River; Pine River Experimental Forest; Udell
Experimental Forest; and Walkinshaw Wetlands Wildlife Emphasis Area.

Research Natural Areas (RNAs) are established to preserve ecologically
significant areas for research, education, and maintenance of biological
diversity. Sixteen areas were identified in the Forest Plan as Candidate
RNAs. The HMNF subsequently established three of the Candidate areas
under consideration as RNAs (MA 8.1). They include Hayes Tower, Newaygo
Prairies (West Tract and Finger Prairie) and Nordhouse Dunes/Sensibar
Tract (located within Nordhouse Dunes Wilderness). Three of the
remaining RNA Candidates remain under consideration for RNA
establishment and ten locations are no longer receiving consideration.
Subsequent to the 1986 Forest Plan, thirty-two additional areas were
suggested as potential Candidate RNAs. These areas are also currently
under consideration.

The HMNF also has one designated wilderness area, the Nordhouse Dunes
Wilderness located in northwestern Lower Michigan, approximately 12 mi
(19.4 km) southwest of Manistee, Michigan. This wilderness consists of
3,395 ac (1,374 ha) and lies within the Manistee Ranger Districts.

Private and State-owned lands are intermixed with HMNF lands. In
addition, roads, farms, towns, and utility corridors fragment the
landscape. Pre-European settlement forests were estimated to cover
nearly 36 million ac (14.6 million ha) of Michigan. Prior to settlement,
fires started by lightning and native peoples are assumed to have caused
major losses of forest vegetation. Currently, forestland covers
approximately 19.3 million ac (7.8 million ha; 53 percent) of Michigan's
total land area. This total represents an approximate 6 percent increase
since 1980 (USDAFS 2003a). Temperate forests support 200,000 jobs and
contribute \$12 billion to Michigan's economy each year.

The human population (total number of individuals) of all but one county
within the HMNF region are increasing, with the largest increases
occurring in counties within and adjacent to the Manistee NF during the
period from 1990 to 2000. Higher population densities result in
increased road construction, land use changes, higher usage of the HMNF
for resources, loss of wildlife habitat, and greater demand for use of
recreational opportunities provided.

**Project Description**

The biological assessment states that the desired future condition
provided for by the LRMP is a diverse mosaic of landscapes that have the
ability to provide a variety of products, recreational experiences and
services for the public. Management specified by the Forest Plan is
focused on maintaining a diversity of vegetation and age class
structure, soil, water, visual and heritage resources; fish and wildlife
habitat; and endangered, threatened and sensitive species (USDAFS
2003a).

The following sections summarize the types of management that occur on
the HMNF that are relevant to the analysis of potential effects on
listed resources. Forest management is discussed by Management
Activities, Management Areas, and Species Specific Conservation
Measures.

[Management Activities]{.underline}

-   Timber Management

Timber harvest, for the primary purposes of providing commercial timber
products and for managing wildlife habitat is one of the primary
management activities that alters forest habitat and occurs on
potentially 53 percent of the HMNF (USDAFS 2003a; Rex Ennis, HMNF, pers.
comm. 2003). Between 1986 and 1996, the average annual harvest of timber
was 10,145 ac (4,106 ha); this number decreased for the period from 1997
to 2001 with 7,512 ac (3,040 ha) harvested (USDAFS 2001). Timber
harvests use primarily even-aged techniques, but uneven-aged techniques
are also employed.

Even-aged management, which maintains stands of similar age class or
size trees, is the primary silvicultural method used on the HMNF (USDAFS
1986a, 2003a). The three primary methods of even-aged management are
clearcutting, shelterwood, and thinning. Clearcutting maximizes harvest
by removing all trees in a stand with one cut. Clearcutting is used
where regeneration of early successional species is a priority and may
favor species of wildlife that use open and young-growth habitat (USDAFS
2003a). Shelterwood cuts remove all trees in a stand in two or three
cuts. Shelterwood cuts are designed to improve the vigor and seed
production of remaining trees while preparing the site for new seedlings
and are best used where seeds and seedlings are species tolerant of a
partial overstory (USDAFS 2003a). Shelterwood cuts remove mature trees
and favor species of wildlife that use open and young-growth habitat
(USDAFS 1986a). Thinning cuts remove 30 to 40 percent of the of the
basal area in a stand and are designed to improve stand growth, stand
yield, and improve wildlife habitat (Rex Ennis, HMNF, pers. comm. 2003;
USDAFS 2003a). Thinning is employed primarily in red pine stands on the
HMNF. A fourth even-aged harvest type that is used on a very limited
basis on the HMNF is the seed-tree method. Used where a seed source and
full sunlight are necessary for stand regeneration, the seed-tree method
removes all but a few trees in a stand (USDAFS 2003a) These "seed trees"
are left to reseed the stand and are removed only after adequate
regeneration has been achieved.

Uneven-aged methods are used in northern hardwood stand types, which
make-up approximately 7 percent of the total forest acres (USDAFS
2003a). These methods include either the periodic removal of individual
trees (single-tree selection) and or small clearcuts of trees (group
selection), leaving mature tree classes in the stand at all times. These
methods require repeated operations and a more extensive skid road
system (USDAFS 1986a, 2003a).

Other types of timber harvest that occur on the HMNF are firewood
cutting and salvage harvests which are used when diseases or other
natural events, such as storms, produce dead or dying trees in excess of
what is normally considered necessary for wildlife or other forest
management goals (USDAFS 2003a).

Between 1986 and 2001, a total of 149,156 ac (60,362 ha) of timber
harvest treatments occurred on the HMNF (USDAFS 2001). Table 4 shows
these timber harvest activities by forest type and harvest method
completed on an annual basis.

Table 4. Timber harvest activities completed from 1986 -- 2001 (based on
USDAFS 2001).

+-----------------------+----------------------+-----------------------+
| **Harvest method**    | **Forest Type**      | **Average forest      |
|                       |                      | acres harvested       |
|                       |                      | annually**            |
+=======================+======================+=======================+
| Clearcut              | Aspen/Birch          | 1,298                 |
|                       |                      |                       |
| *Total harvested for  |                      |                       |
| all forest types:     |                      |                       |
| 50,412 acres*         |                      |                       |
+-----------------------+----------------------+-----------------------+
|                       | Mixed Hardwoods      | 532                   |
+-----------------------+----------------------+-----------------------+
|                       | Jack Pine            | 1,029                 |
+-----------------------+----------------------+-----------------------+
|                       | Red/White Pine       | 292                   |
+-----------------------+----------------------+-----------------------+
| Shelterwood           | Aspen/Birch          | 30                    |
|                       |                      |                       |
| *Total harvested for  |                      |                       |
| all forest types:     |                      |                       |
| 17,701 acres*         |                      |                       |
+-----------------------+----------------------+-----------------------+
|                       | Mixed Hardwoods      | 670                   |
+-----------------------+----------------------+-----------------------+
|                       | Red/White Pine       | 407                   |
+-----------------------+----------------------+-----------------------+
| Thinning              | Aspen/Birch          | 27                    |
|                       |                      |                       |
| *Total harvested for  |                      |                       |
| all forest types:     |                      |                       |
| 81,043 acres*         |                      |                       |
+-----------------------+----------------------+-----------------------+
|                       | Mixed Hardwoods      | 1,083                 |
+-----------------------+----------------------+-----------------------+
|                       | Red/White Pine       | 3,955                 |
+-----------------------+----------------------+-----------------------+

Timber activities are based on advancing the desired conditions and
goals for specific areas set in the LRMP (USDAFS 2003a). Currently, the
HMNF is not meeting the regeneration goals for aspen and northern
hardwoods set in the LRMP. Regeneration harvests will likely increase in
these timber types to better meet forest goals (USDAFS 2003a). Other
forest vegetation types are generally consistent with desired conditions
as projected through 2035; however, the species mix and projected
harvest quantities have departed from the goals in the LRMP (USDAFS
2003a). Future timber management goals will continue to focus on desired
wildlife and vegetation conditions, market conditions, harvest
opportunities, and HMNF budgets (USDAFS 2003a).

The HMNF anticipates that, due to reduced budgets and ongoing
requirements for National Environmental Policy Act (NEPA) compliance,
less acreage will be harvested in the time frame for this proposed
action (2003-2006) than what was projected in the LRMP (Rex Ennis, HMNF,
pers. comm. 2003). Therefore, the HMNF estimates that for the duration
of the proposed action, the following timber harvest activities will
occur annually:

######## - Clearcutting 

-   1,500 acres of jack pine annually (1070 acres for Kirtland's warbler
    management)

-   1,500 acres of aspen annually

-   800 acres of mixed hardwoods annually (includes of 1/3 of the
    estimated aspen harvest)

\- Thinning

-   2,700 acres of red and white pine annually

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-   Range Management

There are currently four grazing allotments encompassing a total of 927
range-capable acres (375 ha) on the HMNF (USDAFS 2001). On these
allotments, grazing and hay cutting is permitted on existing forage
areas. Livestock access to water sources on these allotments is
controlled to limit impacts to aquatic habitats and water quality.
Grazing use is projected to increase from 0.25 M AUM in 1986 to 0.30 M
AUM by 2026 (USDAFS 1986a, 2003a). Additional or expanded grazing
allotments are unlikely because of the lack of available grasslands and
the high cost of converting forested areas into productive range (USDAFS
2003a).

-   Recreation, Wilderness, and Related Resource Management

The LRMP emphasizes dispersed recreation activities on the HMNF (USDAFS
1986a). The primary recreational uses are camping, hunting, fishing,
boating, mountain biking, walking, hiking, and Off-Road Vehicle (ORV)
use (USDAFS 2003a). These activities are supported through a variety of
recreational facilities, areas, and trails (Table 5).

Table 5. Designated recreation areas and facilities on the HMNF

(Rex Ennis, HMNF, pers. comm. 2003; USDAFS 2003a).

  -----------------------------------------------------------------------
  **Facility/Area Type**                                 **Number**
  ------------------------------------------------------ ----------------
  Boating                                                33 sites

  Trailheads                                             53 sites

  Campgrounds                                            41 sites

  Picnic Areas                                           8 sites

  Observation Interpretive Sites                         13 sites

  Fishing                                                7 sites

  Swimming sites                                         5 sites

  Hiking                                                 372 miles

  Horse                                                  85 miles

  ORV/ATV                                                487 miles

  Semi-primitive Recreation Areas                        14 areas

  Wilderness/Semi-primitive Recreation Area              1 area
  -----------------------------------------------------------------------

The LRMP projected 2,257 MRVDs per year (one MRVD = one thousand
Recreation Visitor Days) for dispersed recreation and 669 MRVDs for
developed recreation (e.g., campgrounds, toilet facilities) (USDAFS
2003a). Current values for dispersed and developed recreation are
estimated to range between 1,117 and 2,485 MRVDs (Kocis et al. 2002).
Some recreational areas and facilities are experiencing increased
degradation such as litter, soil compaction, and soil erosion (USDAFS
2001).

In 1999, a Recreational Visitor Fee Demonstration Program was
implemented on the HMNF to help fund the operation, maintenance, and
upgrading of recreational areas (USDAFS 2001). The funds from this
program have been used for projects such as trail repair and
maintenance, replacement or enhancement of campground facilities (e.g.,
toilets, campfire rings), increased cleaning of recreational facilities,
interpretation and signing, and increased law enforcement (USDAFS 2001).

All types of recreation on the HMNF are projected to continue increasing
over the next 40 years (USDAFS 2003a). Ongoing and future potential
strategies for improved management of recreation activities and
resources are: develop a recreation monitoring strategy to better
identify use patterns and problem areas, increase designation of
semi-primitive areas including road closures, increase the construction
and maintenance of trails, expand a comprehensive transportation plan to
better address trails issues, and possibly expand the Visitor Fee
Demonstration Program to other areas of the HMNF (USDAFS 2001).

-   Watershed Management

Specific goals for aquatic resources are to protect and improve habitat
conditions and maintain high water quality and wetlands (USDAFS 2003a).
Water quality is protected by employing best management practices to
land management activities. Specific management and protection of
sensitive riparian resources is addressed via protective standards and
guidelines incorporated into the forest plan through amendment in 2001
(USDAFS 2001). Lake management on the Forest focuses on fishing
opportunities, control of exotic species, enhancement of wildlife
habitat.

Watershed problems that the HMNF will focus on in upcoming years include
projects that address stream sediment load problems caused by erosion
near roadways, poor water quality near stream impoundments, and habitat
degradation around streams and lake due to high recreational use (USDAFS
2001, 2003a).

-   Wildlife, Fish and Sensitive Plant Management

The LRMP prescribes active management of forest vegetation types for a
variety of wildlife and plant species on the HMNF. The HMNF manages
wildlife habitat in different forest vegetation types using management
indicator species that are representative of a variety of species needs
in similar habitat conditions (USDAFS 2001). The HMNF prioritizes
management for threatened and endangered species, such as Pitcher's
thistle, Karner blue butterfly, Indiana bat, and Kirtland's warbler
(USDAFS 2003a).

The LRMP prioritizes consideration of both aquatic and terrestrial
wildlife communities (USDAFS 1986). Aquatic and riparian habitats are
actively managed for fisheries and aquatic dependent species (e.g.,
waterfowl) (USDAFS 2001). Management of terrestrial habitat includes
general wildlife openings, maintenance of old growth, and minimal
conversion of aspen and oak (USDAFS 2003a). General wildlife management
projections through 2005 include 27,800 ac (11,250 ha) of aspen
clearcuts, 30,000 ac (12,141 ha) of wildlife openings, 172,000 ac
(69,606 ha) of old growth, 2,249 structural fisheries improvements, and
5,216 ac (2,111 ha) of nonstructural fisheries habitat improvements
(USDAFS 2003a). Management actions may include different harvest types,
methods, and rotation schedules, in addition to prescribed burning
(USDAFS 1986a, 2001).

-   Minerals and Geology

Mineral resources on USFS lands are publicly owned, and leasing and
development are administered by the Federal agencies in the public
interest (USDAFS 2003a). Currently, 50 and 30 percent of mineral rights
on the Huron NF and Manistee NF, respectively, are privately owned. The
remainder of mineral ownership within the Forests lies with the Federal
Government and the State of Michigan. The LRMP allows for the
development of Federally-owned mineral resources on the HMNF, except in
areas designated as wilderness (USDAFS 1986a). Privately-owned mineral
rights on all HMNF lands are recognized, and reasonable access for
exploration or extraction are provided (USDAFS 1986a). However, all
potential resource development actions, whether Federal or private
rights, must first undergo environmental review on a project-by-project
basis (USDAFS 2003a).

Common variety minerals, including sand, clay, and gravel, are found in
glacial drifts on the Forests, with deeper mineral deposits of gypsum,
anhydrite, coal, salt, and potash (USDAFS 2003a). However, the mining
for these minerals is not economical due to the depth of overburden.
Resources more commonly extracted from the HMNF include oil, natural
gas, gravel, and sand (USDAFS 2003a).

As of March 1984, oil and gas leases had been issued for 346,800 ac
(140,348 ha), whereas in 1999, less than 200,000 ac (80,939 ha) were
leased for oil and gas production on the Forest (Rex Ennis, HMNF, pers.
comm. 2003). During the first decade of the LRMP, oil and gas leases on
the HMNF exceeded projected goals, peaking at 500,000 ac (202,344 ha)
from 1988 to 1990; however, by 1999, they had declined to 200,000 ac
(80,937 ha) (USDAFS 2003a). In 2001, an additional 9,500 ac (3,845 ha)
were opened to potential oil and gas leasing (USDAFS 2001). The HMNF
projects that an additional 82,000 ac (33,184 ha) will be leased for oil
and gas activities for the duration of the proposed action (Rex Ennis,
HMNF, pers. comm. 2003).

Gravel mining occurs in 2 locations on the HMNF (Rex Ennis, HMNF, pers.
comm. 2003, USDAFS 2003a).including the Three Lakes Pit (T25N, R4E, Sec.
21, SESW), which is approximately 11 ac (4 ha) in size. Currently, the
active area of this pit is in State-owned gravel. As funding becomes
available, the HMNF may expand this pit into federally owned gravel, if
present. Luke's Corner (T20N, R14W, Sec. 26, NENE), the other active
gravel pit on the HMNF, is approximately 20 ac (8 ha) in size.
Additional gravel sales are not anticipated and this pit is in the
process of being closed and reclaimed.

Sand mining on the Forest is greatly restricted by state Critical Dunes
designations that prohibit sand mining and by HMNF regulations that
prohibit such activities within 300 ft (91 m) of a water body (USDAFS
2003a).

-   Forest Pest Management

The LRMP recognizes that insects and diseases are natural in forest
ecosystems and that the best method of controlling pest and disease
outbreaks is to proactively manage for good vegetative diversity and
spatial distribution within a stand and throughout the forest (USDAFS
1986a). In 2001, outbreaks of jack pine bud worm, large aspen tortrix,
and foliage discoloration were detected on 91,701 ac (37,110 ha) on the
HMNF (USDAFS 2001). Invasive exotic plants such as purple loosestrife
(*Lythrum salicaria*) and spotted knapweed (*Centaurea maculosa*) are
found on the forest. Control of these plants has included the
introduction of biological agents and mechanical removal methods (USDAFS
2003a). While permitted under the LRMP, current HMNF policy does not
allow for the use of chemical pesticides or herbicides. *Bacillus
thuringiensis* (Btk) a type of soil bacteria, is used to control gypsy
moth infestations (USDAFS 2003a).

In general, insect and disease are considered to be at a healthy or
manageable level on the HMNF (USDAFS 2001). Additional use of any
pesticide or herbicide would require environmental review before
approved (USDAFS 2003a).

-   Fire Management

There are four Fire Management Zones (FMZ) designated on the HMNF
(USDAFS 2001, 2003a). These are FMZ 01- Manistee northern hardwoods, FMZ
02- Manistee dry site oak/jack pine, FMZ 03- Huron dry site oak/jack
pine, and FMZ 04- Huron jack pine-thick. Fire management, both
prescribed burning and wildfire, is managed in each area based on a
variety of factors including forest community type, wildlife habitat,
hazardous fuels load, and proximity of human populations (USDAFS 2001).

Wildfires set by visitors or natural causes burn an average of 2,360 ac
(955 ha) annually on the HMNF (Rex Ennis, HMNF, pers. comm. 2003). Many
of the vegetation types on the HMNF, such as prairie grass systems, oak
savannahs and oak-pine barrens, are especially susceptible to
fast-moving, high-intensity forest fires (USDAFS 2001). Jack pine stands
are of particular fire concern on the HMNF because their low-moisture
and volatile chemical composition, coupled with their arrangement on the
landscape, tends to encourage fire (USDAFS 2001). Recently, unusually
warm and dry climatic conditions have led to higher than average
wildfire activity on the HMNF (USDAFS 2003a). Furthermore, the generally
flat terrain of the HMNF tends to facilitate the spread of wind-driven
fires; a condition exacerbated by frequent high wind events off of Lake
Michigan (USDAFS 2001).

Prescribed burning is a particularly useful management tool in pine
barren, oak savannah, and dry sand prairie (USDAFS 2003a). An average of
3,000 to 10,000 ac (1,214 to 4,047 ha) are managed annually through the
use of prescribed burns on the HMNF (USDAFS 2003a). Prescribed fire on
the HMNF is used primarily for fuel reduction near urban areas to
minimize the potential for fires that may threaten public safety (USDAFS
2001). Prescribed fire is also an essential tool used to maintain
habitat for the Kirtland's warbler (FMZ 04) and Karner blue butterfly
(FMZ 02). Burning programs for improvement of wildlife habitat will
continue to be a priority for these and other species where necessary on
the HMNF (USDAFS 2001).

Increasing stand age, hazardous fuels build-up, and increasing urban
encroachment has increased the potential for large-scale catastrophic
fires on the HMNF (USDAFS 2001). Plans to address this concern include
proactive planning and preparation, improving staff knowledge and
experience in fire management, public education about wildlife risks,
and incorporation of the latest fire management ecological principles
into the LRMP (USDAFS 2001, 2003a).

-   Transportation

The LRMP projected a net decrease in road miles, dictating closure of
roads determined to be nonessential for forest resource management
(USDAFS 1986a). Initially, requirements for timber harvest were expected
to be the primary source of new road construction. However, the HMNF has
been constructing more temporary roads in addition to using existing
road systems to meet timber harvest needs (USDAFS 2001). Road
reconstruction for recreational uses has continued to increase as
necessary (USDAFS 2001). From 1986 to 2001, the following road
activities occurred: 33.8 mi (54.4 km) were constructed, 244.2 mi (360.8
km) were reconstructed, 400.6 mi (644.7 km) were decommissioned, and
247.7 mi (398.6 km) were closed (gated or bermed) (USDAFS 2001).

In general, annual road construction and reconstruction has occurred at
a significantly slower rate than planned, while road decommissioning is
near forest projections (USDAFS 2001). As of 2001, there were a total of
3,866 mi (6,236 km) of classified and unclassified roads on the HMNF
(USDAFS 2001). Over the next four decades, the rate of annual road
construction is planned to further decrease, resulting in a net
reduction of 686 mi (1,106 km) of roads by 2035 (USDAFS 2003a).

[Management Areas]{.underline}

The HMNF consists of 16 different management areas (MAs). The MAs are
areas of the HMNF that have common management direction, with one
management prescription applied to achieve the desired future condition
of the land. Management prescriptions are sets of practices designed to
create this desired future condition. Selection of the proper
prescription requires matching its suitability and capability to produce
a mix of goods, services, and desired uses with the attributes of an
area. Assignment of management prescription areas on the HMNF reflects a
wide variety of ecological land type associations, vegetative conditions
and recreation opportunities (USDAFS 1986a). The management prescription
applied to any area may shift depending on objectives of alternative
resource activities. The 16 MAs are described in Table 6.

Table 6. Management Areas on the HMNF (USDAFS 2003a).

+----------------+--------------------------------------+--------+-----+
| **Management   | **Primary Goals**                    | **A    | **% |
| Area**         |                                      | cres** | of  |
|                |                                      |        | To  |
|                |                                      |        | tal |
|                |                                      |        | For |
|                |                                      |        | est |
|                |                                      |        | A   |
|                |                                      |        | cre |
|                |                                      |        | s** |
+================+======================================+========+=====+
| 1.1-           | \- Provide semi-primitive motorized  | 4,522  | \   |
| Semi-primitive | recreational experiences             |        | <1% |
| motorized      |                                      |        |     |
| rolling plains | \- Enhance wildlife habitat          |        |     |
| and morainal   |                                      |        |     |
| hills          | \- Reduce potential wildfire damage  |        |     |
+----------------+--------------------------------------+--------+-----+
| 2.1- Roaded    | \- Provide high volumes of quality   | 1      | 20% |
| natural plains | hardwood timber and firewood         | 94,055 |     |
| and morainal   | products                             |        |     |
| hills          |                                      |        |     |
|                | \- Manage wildlife and fisheries     |        |     |
|                | emphasis areas                       |        |     |
|                |                                      |        |     |
|                | \- Maintain a variety of recreation  |        |     |
|                | and visual opportunities             |        |     |
+----------------+--------------------------------------+--------+-----+
| 3.1-           | \- Provide a variety of motorized    | 0      | 0%  |
| Semi-primitive | recreational opportunities           |        |     |
| motorized      |                                      |        |     |
|                | \- Provide moderate volumes of       |        |     |
|                | quality hardwood timber products     |        |     |
+----------------+--------------------------------------+--------+-----+
| 4.1-           | \- Provide a variety of motorized    | 0      | 0%  |
| Semi-primitive | recreational opportunities           |        |     |
| motorized      |                                      |        |     |
| wetlands       | \- Enhance fish and wildlife         |        |     |
|                | habitats, particularly deer          |        |     |
|                | wintering areas                      |        |     |
+----------------+--------------------------------------+--------+-----+
| 4.2- Roaded    | \- Provide high volumes of quality   | 3      | 38% |
| natural sandy  | hardwood timber and firewood         | 68,701 |     |
| plains and     | products                             |        |     |
| hills          |                                      |        |     |
|                | \- Manage game and wildlife emphasis |        |     |
|                | areas                                |        |     |
|                |                                      |        |     |
|                | \- Reduce potential wildfire damage  |        |     |
+----------------+--------------------------------------+--------+-----+
| 4.3- Roaded    | \- Provide a variety of motorized    | 1      | 14% |
| natural        | recreational opportunities           | 40,323 |     |
| wetlands       |                                      |        |     |
|                | \- Manage game and wildlife emphasis |        |     |
|                | areas                                |        |     |
+----------------+--------------------------------------+--------+-----+
| 4.4- Rural     | \- Provide a variety of motorized    | 49,585 | 5%  |
| sandy plains,  | recreational opportunities           |        |     |
| morainal       |                                      |        |     |
| hills, and     | \- Provide moderate to high volumes  |        |     |
| riparian areas | of quality hardwood timber products  |        |     |
|                |                                      |        |     |
|                | \- Coordinate wildlife management    |        |     |
|                | with adjacent land usage             |        |     |
+----------------+--------------------------------------+--------+-----+
| 4.5-           | \- Provide and maintain essential    | 1      | 11% |
| Kirtland's     | habitat for Kirtland's warbler       | 10,670 |     |
| warbler        |                                      |        |     |
|                | \- Produce high volumes of softwood  |        |     |
|                | and hardwood timber products         |        |     |
+----------------+--------------------------------------+--------+-----+
| 5.1-           | \- Provide a variety of nonmotorized | 3,395  | \   |
| Wilderness     | recreational opportunities while     |        | <1% |
|                | emphasizing solitude                 |        |     |
+----------------+--------------------------------------+--------+-----+
| 6.1-           | \- Provide a variety of nonmotorized | 26,676 | 3%  |
| Semi-primitive | recreational opportunities           |        |     |
| nonmotorized   |                                      |        |     |
| sandy hills    | \- Reduce the potential for wildfire |        |     |
| and plains     | damage                               |        |     |
+----------------+--------------------------------------+--------+-----+
| 6.2-           | \- Provide a variety of nonmotorized | 11,130 | 1%  |
| Semi-primitive | recreational opportunities and       |        |     |
| nonmotorized   | wildlife diversity                   |        |     |
| rolling        |                                      |        |     |
| p              |                                      |        |     |
| lains/morainal |                                      |        |     |
| hills          |                                      |        |     |
+----------------+--------------------------------------+--------+-----+
| 6.3-           | \- Provide a variety of nonmotorized | 19,969 | 2%  |
| Semi-primitive | recreational opportunities           |        |     |
| nonmotorized   |                                      |        |     |
| wetlands       | \- Enhance fish and wildlife habitat |        |     |
+----------------+--------------------------------------+--------+-----+
| 7.1- Rural     | \- Provides variable developed rural | 0      | 0%  |
| developed      | recreational facilities (i.e.,       |        |     |
| recreation     | downhill skiing)                     |        |     |
+----------------+--------------------------------------+--------+-----+
| 8.1- Special   | \- Provides variable direction for   | 33,490 | 3%  |
| areas          | unique biological, geological,       |        |     |
|                | cultural reasons, or legislative     |        |     |
|                | designation                          |        |     |
+----------------+--------------------------------------+--------+-----+
| 9.1- Minimum   | \- Includes areas unsuitable for     | 386    | NA  |
| level          | timber management, areas identified  | ,000\* |     |
| management     | for potential land exchange, or      |        |     |
|                | where only minimal management will   |        |     |
|                | be conducted                         |        |     |
+----------------+--------------------------------------+--------+-----+
| 9.2- Lands in  | \- Includes lands awaiting           | 0      | 0%  |
| holding        | designation                          |        |     |
+----------------+--------------------------------------+--------+-----+
| Other/unknown  |                                      | 2,563  | \   |
|                |                                      |        | <1% |
+----------------+--------------------------------------+--------+-----+

\* within other MAs

[Species Specific Conservation Measures Included as Part of the Proposed
Action]{.underline}

This section discusses species specific conservation measures derived
from the following sections of the biological assessment for the
proposed action: 1) Effects of Continued Implementation of the Forest
Plan, 2) Summary: Determination of Effects and Rationale, and 3)
Conservation Measures. Further details and discussion for each species
may be found in the section entitled "Analysis of Species/Critical
Habitat that May Be Affected by the Proposed Action" in this Opinion.

-   Piping Plover and Critical Habitat

Piping plover habitat and critical habitat on the HMNF falls under two
different management prescriptions, MA 5.1 and MA 4.3. Table 7 lists
critical elements of the proposed action and conservation measures for
the piping plover and critical habitat in MAs 5.1 and 4.3.

Table 7. Protective measures proposed for the piping plover and critical
habitat.

+---------------------------------------------------+--------+--------+
| **Proposed Action/Protective Measure**            | **MA   | **MA   |
|                                                   | 5.1**  | 4.3**  |
|                                                   |        |        |
|                                                   | *      |        |
|                                                   | *(Wild |        |
|                                                   | erness |        |
|                                                   | A      |        |
|                                                   | rea)** |        |
+===================================================+========+========+
| **Camping and Recreation**                        |        |        |
+---------------------------------------------------+--------+--------+
| Prohibit groups with \>10 people.                 | √      |        |
+---------------------------------------------------+--------+--------+
| Prohibit camping within 400ft (122m) of the Lake  | √      |        |
| Michigan shoreline.                               |        |        |
+---------------------------------------------------+--------+--------+
| Prohibit beach fires within 400ft (122m) of the   | √      | √^1^   |
| Lake Michigan shoreline.                          |        |        |
+---------------------------------------------------+--------+--------+
| Prohibit collection of driftwood, dunewood, roots | √      | √^2^   |
| and shrubs.                                       |        |        |
+---------------------------------------------------+--------+--------+
| Require pets to be leashed from April 1 to July 1 | √      | √      |
| and at anytime near an active nest.               |        |        |
+---------------------------------------------------+--------+--------+
| Prohibit kite flying within 656ft (200m) of       | √      | √      |
| active nest sites.                                |        |        |
+---------------------------------------------------+--------+--------+
| Prohibit fireworks within 3281ft (1000m) of       | √      | √      |
| active nest sites.                                |        |        |
+---------------------------------------------------+--------+--------+
| Prohibit horses and other pack animals.           | √      |        |
+---------------------------------------------------+--------+--------+
| Restrict loud noise from April 1 to July 1.       | √      | √      |
+---------------------------------------------------+--------+--------+
| Keep shoreline free of litter and debris.         | √      | √      |
+---------------------------------------------------+--------+--------+
| **Trail Management**                              |        |        |
+---------------------------------------------------+--------+--------+
| Encourage foot traffic to stay on designated      | √      | √      |
| trails or along the shoreline.                    |        |        |
+---------------------------------------------------+--------+--------+
| Prohibit the public from leaving trails near      | √      | √      |
| active nest sites from April 1 to                 |        |        |
|                                                   |        |        |
| August 31 and at anytime near an active nest.     |        |        |
+---------------------------------------------------+--------+--------+
| Trail management and construction will direct     | √      | √      |
| public away from active nest sites from April 1   |        |        |
| to August 31 and at anytime near an active nest.  |        |        |
+---------------------------------------------------+--------+--------+
| Prohibit new trail construction in areas of       | √      | √      |
| critical habitat with the Primary Constituent     |        |        |
| Elements (PCEs).                                  |        |        |
+---------------------------------------------------+--------+--------+
| Relocate existing trails as necessary in areas of | √      | √      |
| critical habitat with PCEs.                       |        |        |
+---------------------------------------------------+--------+--------+
| **Vehicle and ORV Traffic**                       |        |        |
+---------------------------------------------------+--------+--------+
| Prohibit all motorized vehicles, equipment, and   | √      |        |
| ORV use.                                          |        |        |
+---------------------------------------------------+--------+--------+
| Prohibit ORV use in essential nesting habitats    | NA     | √      |
| for sensitive species.                            |        |        |
+---------------------------------------------------+--------+--------+
| Prohibit ORV use from April 1 to July 1.          | NA     | √^3^   |
+---------------------------------------------------+--------+--------+
| Limit vehicle traffic to emergency use only near  | √      | √      |
| active nest sites from April 1 to August 31.      |        |        |
+---------------------------------------------------+--------+--------+
| Limit road construction in or adjacent to         | NA     | √      |
| critical habitat to that which will not have an   |        |        |
| adverse effect.                                   |        |        |
+---------------------------------------------------+--------+--------+
| **Development**                                   |        |        |
+---------------------------------------------------+--------+--------+
| Prohibit sand mining and oil/gas leasing and      | √      | √      |
| development.                                      |        |        |
+---------------------------------------------------+--------+--------+
| **Habitat Management and Protection**             |        |        |
+---------------------------------------------------+--------+--------+
| Implement protective seasonal restrictions and    | √      | √      |
| closures of piping plover critical habitat in     |        |        |
| areas where nesting occurs or where birds have    |        |        |
| established a pattern of use.                     |        |        |
+---------------------------------------------------+--------+--------+
| Design all habitat modifications, trail           | √      | √      |
| construction/relocation, and other management     |        |        |
| activities to improve critical habitat.           |        |        |
+---------------------------------------------------+--------+--------+
| Prohibit artificial beach stabilization if it     | √      | √      |
| interferes with natural dune processes.           |        |        |
+---------------------------------------------------+--------+--------+
| Management direction dictates that prescribed     | NA     | √      |
| burning is very unlikely to be used in dune       |        |        |
| habitat.                                          |        |        |
+---------------------------------------------------+--------+--------+
| Prescribed burns in adjacent areas will be        | NA     | √      |
| limited to conditions when smoke will not drift   |        |        |
| into critical habitat from April 1 to July 1, or  |        |        |
| whenever piping plovers are present.              |        |        |
+---------------------------------------------------+--------+--------+
| Prohibit control of nonnative woody vegetation in | √      | √      |
| areas of critical habitat with PCEs between April |        |        |
| 1 and July 1, or whenever piping plovers are      |        |        |
| present.                                          |        |        |
+---------------------------------------------------+--------+--------+
| **Nest protection**                               |        |        |
+---------------------------------------------------+--------+--------+
| Install psychological fencing and predator        | √      | √      |
| exclosures around active nests.                   |        |        |
+---------------------------------------------------+--------+--------+
| **Monitoring and Evaluation**                     |        |        |
+---------------------------------------------------+--------+--------+
| Monitor for piping plovers and nests in critical  | √      | √      |
| habitat twice weekly during the nesting season,   |        |        |
| from April 1 to July 1.                           |        |        |
+---------------------------------------------------+--------+--------+
| Monitor active nest sites, evaluate the           | √      | √      |
| effectiveness of protective measures, and         |        |        |
| document the cause of nest failures using         |        |        |
| standard protocols.                               |        |        |
+---------------------------------------------------+--------+--------+
| Monitor PCEs in critical habitat.                 | √      | √      |
+---------------------------------------------------+--------+--------+
| Implement recovery measures as appropriate:       | √      | √      |
| inventories, management plans, information and    |        |        |
| education, restoration, research.                 |        |        |
+---------------------------------------------------+--------+--------+

^1^ Prohibited only between April 1 and July 1

^2^ Prohibited only between April 1 and July 1

^3^ ORV use is allowed under MA 4.3, but there are currently no ORV
trails in critical habitat

We appreciate the HMNF's commitment to expanded protective time periods
in areas with piping plovers present. This applies an appropriate
increased level of protection that further decreases the likelihood for
adverse affects on the piping plover as a result of implementing the
LRMP.

-   Indiana Bat

Known and potential Indiana bat habitat is found in MAs 2.1, 4.2, 4.3,
4.4, 5.1, 6.1, 6.2, and 6.3 (USDAFS 2003a). Table 8 lists the
conservation measures that are proposed for the protection, restoration,
and maintenance of Indiana bat or its habitat in all MAs.

Table 8. Protective measures proposed for the Indiana bat.

+--------------------------------------------------------------+-------+
| **Proposed Action/Protective Measure**                       | *     |
|                                                              | *Pote |
|                                                              | ntial |
|                                                              | and   |
|                                                              | occ   |
|                                                              | upied |
|                                                              | habi  |
|                                                              | tat** |
+==============================================================+=======+
| **Habitat Management and Protection**                        |       |
+--------------------------------------------------------------+-------+
| Where vegetation management occurs, an average of 9 suitable | √     |
| roost trees ([\>]{.underline}9 in \[23 cm\] dbh) per acre    |       |
| will be maintained within the treated acres where available  |       |
| by the following priorities:                                 |       |
|                                                              |       |
| -High quality summer roost trees (snags) regardless of       |       |
| species, prioritized by the following size classes:          |       |
|                                                              |       |
| \- 16 in (41 cm) dbh or greater.                             |       |
|                                                              |       |
| \- 9 to 16 in (23 to 41 cm) dbh.                             |       |
|                                                              |       |
| \- 3 to 9 in (8 to 23 cm) dbh.                               |       |
|                                                              |       |
| \- Retain as many standing snags \>3 in (8 cm) dbh as        |       |
| practical (a minimum of 9) within regeneration and timber    |       |
| management units:                                            |       |
|                                                              |       |
| \- Give preference to larger snags; retain all snags         |       |
| [\>]{.underline} 16 in (41 cm) dbh.                          |       |
|                                                              |       |
| \- Snags should be retained regardless of species.           |       |
|                                                              |       |
| \- Assure that care is taken during site preparation,        |       |
| seeding, etc., to avoid damage or loss of retained snags.    |       |
|                                                              |       |
| \- Standing live trees \>3 in (8 cm) dbh with \>25 percent   |       |
| exfoliating bark, regardless of species.                     |       |
|                                                              |       |
| \- Retain hollow, den, and cavity trees \>9 in (23 cm) dbh   |       |
| as practical, regardless of species.                         |       |
|                                                              |       |
| \- Retain shagbark and bitternut hickories, regardless of    |       |
| size, and regardless of whether dead or alive.               |       |
|                                                              |       |
| \- When few snags are available or cannot be left, leave at  |       |
| least 9 of the largest live trees on site (preferably        |       |
| [\>]{.underline} 26 in \[66 cm\] dbh) in the Class I         |       |
| Category.                                                    |       |
|                                                              |       |
| \- Retain live trees around larger snags (\>16 in \[41 cm\]  |       |
| dbh) to provide protection from wind throw; give preference  |       |
| to retaining oaks and hickories; if individual trees are     |       |
| health or safety concerns, consider grouping them or protect |       |
| zones around them.                                           |       |
|                                                              |       |
| \- Leave seed trees uncut in seed-tree harvest areas,        |       |
| particularly in areas of oaks and hickories; retain the      |       |
| largest trees as seed trees in order to ensure a component   |       |
| of large, over-mature trees.                                 |       |
|                                                              |       |
| \- In individual and group selection harvests:               |       |
|                                                              |       |
| \- Ensure that a component of large, over-mature trees       |       |
| remain to provide suitable roosting habitat -- retaining at  |       |
| least 3 live trees per acre \>20 in (51 cm) dbh; these must  |       |
| be among the largest trees available in the stand.           |       |
|                                                              |       |
| \- If there are no trees \>20 in (51 cm) dbh, retain 16 of   |       |
| the largest available trees per acre.                        |       |
|                                                              |       |
| \- When available, trees left should be Class I type trees,  |       |
| (oaks and hickories; other desirable species include eastern |       |
| cottonwood, green and white ash, and American and slippery   |       |
| elm).                                                        |       |
+--------------------------------------------------------------+-------+
| Regeneration units will be designed with irregular borders   | √     |
| to provide edges for solar exposure of roost sites,          |       |
| interspersion of roosting and foraging habitat, and travel   |       |
| corridors.                                                   |       |
+--------------------------------------------------------------+-------+
| Survey and document pre- and post-harvest roost tree         | √     |
| conditions, including inventory and protection measures.     |       |
+--------------------------------------------------------------+-------+
| Prohibit removal of standing dead trees for firewood between | √     |
| May 1 and August 31. Annually update the firewood cutting    |       |
| maps to identify areas that are off limits.                  |       |
+--------------------------------------------------------------+-------+
| Generally, prescribed burns are prohibited between May 1 and | √     |
| August 31. Prescribed burns in the Tippy Management Zone     |       |
| (5-mi \[8-km\] radius around Tippy Dam) are prohibited       |       |
| between May 1 and October 20.                                |       |
+--------------------------------------------------------------+-------+
| Protection zones will be established around maternity        | √     |
| colonies as discovered.                                      |       |
+--------------------------------------------------------------+-------+
| Create or renovate upland water sources for Indiana bat by:  | √     |
|                                                              |       |
| \- Developing water holes in wildlife openings along the     |       |
| forest edge.                                                 |       |
|                                                              |       |
| \- Designating Maintenance Level 1 and decommissioned roads  |       |
| to provide upland water sources.                             |       |
|                                                              |       |
| \- Designing road construction and reconstruction projects   |       |
| to include small waterholes adjacent to the                  |       |
|                                                              |       |
| road, where feasible.                                        |       |
+--------------------------------------------------------------+-------+
| Manage the 5-mi (8-km) radius around Tippy Dam to best       | √     |
| benefit the bat.                                             |       |
+--------------------------------------------------------------+-------+
| Habitat removal and modification include considerations for  | √     |
| minimizing potential adverse impacts, such as visual         |       |
| assessments of roosting habitat quality (exfoliating bark,   |       |
| splits/cracks, hollows, holes, dens, and cavities) or other  |       |
| assessment techniques such as mist-netting                   |       |
+--------------------------------------------------------------+-------+
| Habitat removal and modifications will employ seasonal       | √     |
| avoidance measures as feasible and prudent                   |       |
+--------------------------------------------------------------+-------+
| Site-specific project protection measures will be developed  | √     |
| during biological evaluations to identify appropriate        |       |
| protection measures.                                         |       |
+--------------------------------------------------------------+-------+
| **Monitoring and Evaluation**                                |       |
+--------------------------------------------------------------+-------+
| Monitoring for Indiana bat and habitat:                      | √     |
|                                                              |       |
| \- Monitor the presence of Indiana bats at the Tippy Dam     |       |
| hibernaculum during fall swarming and winter surveys in      |       |
| cooperation with Consumers Energy on a five-year frequency   |       |
| interval.                                                    |       |
|                                                              |       |
| \- Monitor presence of Indiana bats during the summer period |       |
| on the Manistee National Forest suitable habitat area using  |       |
| Service-approved protocols on a three-year frequency         |       |
| interval.                                                    |       |
+--------------------------------------------------------------+-------+
| As appropriate, conduct periodic Indiana bat studies such    | √     |
| as: summer surveys in the western half of the Manistee       |       |
| National Forest and autumn swarming/spring staging surveys   |       |
| in the area near Tippy Dam.                                  |       |
+--------------------------------------------------------------+-------+

-   Karner Blue Butterfly

The Karner blue butterfly is occurs in MAs 2.1, 4.2, 4.3, 4.4, 6.1, 6.2,
8.1. Table 9 lists critical elements of the proposed action and
conservation measures for the Karner blue butterfly as they apply to
unoccupied and occupied habitat in all MAs.

Table 9. Protective measures proposed for the Karner blue butterfly.

+--------------------------------------------------+---------+--------+
| **Proposed Action/Protective Measure**           | **O     | **Unoc |
|                                                  | ccupied | cupied |
|                                                  | Ha      | Hab    |
|                                                  | bitat** | itat** |
+==================================================+=========+========+
| ### Camping and Recreation                       |         |        |
+--------------------------------------------------+---------+--------+
| Direct camping to areas outside occupied         | √       |        |
| habitat. Where posted, camping will be           |         |        |
| prohibited in occupied sites.                    |         |        |
+--------------------------------------------------+---------+--------+
| **Trail Management**                             |         |        |
+--------------------------------------------------+---------+--------+
| Trail construction, road construction, and       | √       | √      |
| vegetation management activities will be         |         |        |
| designed to improve potential Karner blue        |         |        |
| butterfly habitat.                               |         |        |
+--------------------------------------------------+---------+--------+
| Roads and trails will be managed and maintained  | √       | √      |
| in a manner to protect areas with wild lupine.   |         |        |
| Where this is not feasible and damage is         |         |        |
| occurring, trails and roads may be relocated or  |         |        |
| decommissioned.                                  |         |        |
+--------------------------------------------------+---------+--------+
| **Vehicle and ORV Traffic**                      |         |        |
+--------------------------------------------------+---------+--------+
| Maintenance and use of existing roads and trails | √       | √      |
| will be managed in a manner to protect or        |         |        |
| maintain occupied habitat and areas with wild    |         |        |
| lupine. Where this is not feasible and damage is |         |        |
| occurring, trails and roads will be relocated or |         |        |
| decommissioned.                                  |         |        |
+--------------------------------------------------+---------+--------+
| Prohibit ORV use with woodland strips or brush   | √       |        |
| piles along trails and roads.                    |         |        |
+--------------------------------------------------+---------+--------+
| **Development**                                  |         |        |
+--------------------------------------------------+---------+--------+
| Oil and gas development will contain a \"no      | √       |        |
| surface occupancy\" stipulation and will exclude |         |        |
| road building.                                   |         |        |
+--------------------------------------------------+---------+--------+
| **Habitat Management and Protection**            |         |        |
+--------------------------------------------------+---------+--------+
| Conduct pre-activity surveys to determine        | √       | √      |
| presence/absence of the species. If the species  |         |        |
| is found, the HMNF will follow the conservation  |         |        |
| measures for occupied habitat.                   |         |        |
+--------------------------------------------------+---------+--------+
| Monitor activities at the project level.         | √       | √      |
+--------------------------------------------------+---------+--------+
| Provide dispersal corridors in order to          | √       | √      |
| facilitate dispersal between occupied and        |         |        |
| unoccupied areas (suitable habitat sites).       |         |        |
+--------------------------------------------------+---------+--------+
| The application and use of herbicides or         | √       |        |
| pesticides is prohibited in and adjacent to      |         |        |
| occupied Karner blue butterfly habitat between   |         |        |
| April 1 and August 15 except when the wind is    |         |        |
| not blowing toward the habitat and there is a    |         |        |
| minimum buffer of 100 foot (30 m) between the    |         |        |
| habitat and the treatment area.                  |         |        |
+--------------------------------------------------+---------+--------+
| Maintain or restore occupied Karner blue         | √       |        |
| butterfly sites using prescribed burning,        |         |        |
| mowing, and timber harvest methods outlined on   |         |        |
| p. 92-93 and 101 of the biological assessment.   |         |        |
+--------------------------------------------------+---------+--------+
| Activities will be scheduled and completed when  | √       |        |
| they are least likely to impact any life stage   |         |        |
| of the butterfly.                                |         |        |
+--------------------------------------------------+---------+--------+
| Watershed management activities that are         | √       |        |
| incompatible with Karner blue butterfly will be  |         |        |
| excluded.                                        |         |        |
+--------------------------------------------------+---------+--------+
| **Monitoring and Evaluation**                    |         |        |
+--------------------------------------------------+---------+--------+
| Monitoring for Karner blue butterfly and habitat | √       |        |
| including:                                       |         |        |
|                                                  |         |        |
| \- Annual sampling each of the four              |         |        |
| metapopulations during the first or second       |         |        |
| flight period to determine population size.      |         |        |
| Preference should be given to the second flight  |         |        |
| period because this is when the greatest number  |         |        |
| of butterflies would be present.                 |         |        |
|                                                  |         |        |
| \- Determining and tracking the amount and       |         |        |
| condition of habitat maintained and restored     |         |        |
| annually.                                        |         |        |
|                                                  |         |        |
| \- Identifying threats and disturbance factors   |         |        |
| affecting metapopulations and habitat a minimum  |         |        |
| of every three years.                            |         |        |
|                                                  |         |        |
| \- Assessing the connectivity of subpopulations  |         |        |
| every three years to confirm that subpopulations |         |        |
| remain connected.                                |         |        |
+--------------------------------------------------+---------+--------+
| Implement recovery measures: inventories,        | √       |        |
| management plans, information and education,     |         |        |
| restoration, and studies as appropriate.         |         |        |
+--------------------------------------------------+---------+--------+

-   Pitcher's Thistle

Table 10 lists critical elements of the proposed action and conservation
measures for the Pitcher's thistle as they apply to MAs 5.1, 4.3, and
4.2.

Table 10. Protective measures proposed for the Pitcher's thistle.

+------------------------------------------------+----------+---------+
| **Proposed Action/Protective Measure**         | **MA     | **MA**  |
|                                                | 5.1**    |         |
|                                                |          | **4.2 & |
|                                                | **(Wi    | 4.3**   |
|                                                | lderness |         |
|                                                | Area)**  |         |
+================================================+==========+=========+
| ### Camping and Recreation                     |          |         |
+------------------------------------------------+----------+---------+
| Prohibit groups with \>10 people.              | √        |         |
+------------------------------------------------+----------+---------+
| Prohibit camping within 400 ft (122 m) of Lake | √        |         |
| Michigan .                                     |          |         |
+------------------------------------------------+----------+---------+
| Prohibit beach fires within 400 ft (122 m)     | √        |         |
| Lake Michigan.                                 |          |         |
+------------------------------------------------+----------+---------+
| Prohibit horses and other pack animals.        | √        |         |
+------------------------------------------------+----------+---------+
| **Trail Management**                           |          |         |
+------------------------------------------------+----------+---------+
| Limit foot traffic in areas occupied by        | √        | √       |
| Pitcher's thistle; design foot traffic on      |          |         |
| dunes to limit impacts to Pitcher's thistle    |          |         |
+------------------------------------------------+----------+---------+
| **Vehicle and ORV Traffic**                    |          |         |
+------------------------------------------------+----------+---------+
| Prohibit all motorized vehicles, equipment,    | √        |         |
| and ORV use.                                   |          |         |
+------------------------------------------------+----------+---------+
| Limit ORV traffic to trails.                   | NA       | √       |
+------------------------------------------------+----------+---------+
| Close some roads into Pitcher's thistle areas. | NA       | √^1^    |
+------------------------------------------------+----------+---------+
| **Development**                                |          |         |
+------------------------------------------------+----------+---------+
| Prohibit oil/gas exploration/extraction.       | √        |         |
+------------------------------------------------+----------+---------+
| Prohibit resource development and mining in    | NA       | √       |
| occupied Pitcher's thistle habitat.            |          |         |
+------------------------------------------------+----------+---------+
| No surface occupancy w/in 300 ft (91 m)of Lake | NA       | √       |
| Michigan.                                      |          |         |
+------------------------------------------------+----------+---------+
| **Habitat Management and Protection**          |          |         |
+------------------------------------------------+----------+---------+
| Prohibit pesticide use in occupied Pitcher\'s  | √        | √       |
| thistle habitat.                               |          |         |
+------------------------------------------------+----------+---------+
| Apply a management direction indicates that    | √        | √       |
| prescribed burning very unlikely to be used in |          |         |
| dune habitats.                                 |          |         |
+------------------------------------------------+----------+---------+
| Prohibit watershed management activities in    | √        | √       |
| Pitcher's thistle habitat.                     |          |         |
+------------------------------------------------+----------+---------+
| Control introduced species.                    | √        | √       |
+------------------------------------------------+----------+---------+
| Provide protective/informative signage for     | √        | √       |
| public.                                        |          |         |
+------------------------------------------------+----------+---------+
| Increase law enforcement to protect Pitcher's  | √        | √       |
| thistle.                                       |          |         |
+------------------------------------------------+----------+---------+
| **Monitoring and Evaluation**                  |          |         |
+------------------------------------------------+----------+---------+
| Monitor Pitcher\'s thistle populations on a 5  | √        | √       |
| year interval.                                 |          |         |
+------------------------------------------------+----------+---------+
| Implement recovery measures: inventories,      | √        | √       |
| management plans, information and education,   |          |         |
| restoration, and studies, as appropriate.      |          |         |
+------------------------------------------------+----------+---------+

^1^ Road closures of 2.9 mi (4.7km) projected for MA 4.3 only

**SPECIES/CRITICAL HABITAT THAT MAY BE AFFECTED** **BY THE PROPOSED
ACTION**

**Species [Not Likely to Be Adversely Affected]{.underline} by the
Proposed Action**

**Great Lakes Piping Plover**

The HMNF has determined that the action being considered in this Opinion
is not likely to adversely affect the Great Lakes piping plover or
critical habitat. The following section discusses the status of the
piping plover and critical habitat, both on a range-wide basis and
within the action area, and our evaluation of the determination for this
species.

######## Species Description

The piping plover, named for its melodic call, is a small North American
shorebird approximately 6.7 in (17 cm) in length (Palmer 1967) that
weighs 1.4-2.3 oz (40-65 g) and has a wing span measuring about 15 in
(38 cm) (Haig 1992). Light sand-colored upper plumage and white
undersides blend in well with the piping plover's principal beach
habitats. During the breeding season, the legs and bill are bright
orange and the bill has a black tip. Other distinctive markings include
a single black band across the upper breast and a smaller black band
across the forehead. In adult females, the breast band is often thin or
incomplete, and plumage is frequently duller than in adult males (Wilcox
1959; Haig 1992). During winter, the legs pale, the bill turns black,
and darker markings are lost. Chicks have speckled gray, buff, brown,
and white down. The coloration of fledged young resembles that of adults
in winter. Juveniles acquire adult plumage the spring after they fledge
(Prater et al. 1977).

[Life History]{.underline}

Piping plovers return to their breeding grounds in late April to early
May, and most nests are initiated by mid- to late May (Pike 1985).
Courtship behavior includes aerial displays, digging of several nest
scrapes, and a ritualized stone-tossing display (Cairns 1977; 1982; Haig
1992). Piping plover nests are shallow scrapes in the sand that are
lined with pebbles, shells, and driftwood. Both adults actively defend
nest territories and share incubation duties that last 25 to 31 days
(Wilcox 1959; Cairns 1977; Prindiville 1986; Wiens 1986; Haig and Oring
1988). Females lay an egg approximately every other day; clutches are
complete at three or four eggs.

At Great Lakes nesting sites, eggs hatch from late May to late July
(Lambert and Ratcliff 1981; Pike 1985). Precocial chicks usually hatch
within one half to one day of each other and are able to feed themselves
within a few hours, following their parents and plucking invertebrates,
including insects, spiders, marine worms, crustaceans, and mollusks,
from the sand (Haig 1992). Most foraging is diurnal. Piping plovers
utilize numerous areas within breeding and wintering habitats for
foraging, including wet sand in the wash zone, intertidal ocean beach,
wrack lines, washover passes, mud, sand and algal flats, and shorelines
of streams, ephemeral ponds, lagoons, and salt marshes (Powell 1991;
Hoopes et al. 1992; Loegering 1992; Zonick et al. 1998). Several studies
on the Atlantic Coast indicate that foraging habitat and food resources
ultimately affect piping plover survival (Loegering and Fraser 1995;
Goldin and Regosin 1998; Elias et al. 2000).

Piping plover eggs and young are so well camouflaged that they may go
unnoticed. When predators or intruders are near, the young remain
motionless while the parents attempt to attract the attention of the
intruders to themselves, often by feigning a broken wing or false
brooding. Chicks cannot fly until between 21 and 30 days after hatching,
making them vulnerable to predators. Piping plovers depart their Great
Lakes breeding areas from mid-July to early September (Pike 1985; Wemmer
2000).

The wintering ranges of the three breeding populations of the piping
plover overlap and extend from Virginia to Florida on the Atlantic Coast
and from the Florida Gulf Coast west to Texas and into Mexico, the West
Indies and the Bahamas (Haig 1992). The amount of population mixing that
occurs on the wintering grounds is not known. Great Lakes piping plovers
winter primarily on the Atlantic and Gulf Coasts from Virginia to Texas,
although some migrate as far south as Mexico and the Bahamas.

Recent data from piping plovers banded in Michigan suggest an adult
survival rate of approximately 70 percent, a similar level to that
reported for other populations (Wemmer and Cuthbert 1999; Wemmer 2000).
Survival of fledglings in the Great Lakes to first breeding (30 percent)
falls between rates reported for populations in the Great Plains and
Atlantic Coast.

In Michigan, adults returned to beaches where they nested previously
approximately 65 percent of the time. Adult fidelity to breeding areas
in other piping plover populations range from 24 percent to 69 percent
(Haig and Oring 1988). Because adults use numerous beaches throughout
their lifetimes and many young breeders nest distant from natal areas,
preservation of historic and less frequently used areas in addition to
traditional breeding sites remains important for population persistence.

# [Threats]{.underline}

Several factors threaten the continued existence of piping plovers on
Great Lakes beaches, including habitat destruction and modification,
predation, inadequate regulatory mechanisms, disturbance by humans and
pets, small population size, and contaminants. Shoreline development and
increased recreational use of beaches on the breeding and wintering
grounds is responsible for habitat loss. Predation by gulls, crows,
owls, falcons, merlins, foxes, coyotes, skunks, and other animals and
use of ORVs on beaches threaten piping plover survival. Human
developments near beaches attract increased numbers of predators such as
skunks and raccoons (USFWS 1985). Vehicles have crushed eggs and killed
chicks and adults. Other motorized activities, such as boating,
jet-skiing, or flying aircraft may also be a disturbance if they occur
too close to beaches that support piping plovers. Beach-walking, bike
riding, kite flying, fireworks, bonfires, horseback riding, kayaking,
windsurfing, camping and close-up photography are among many
non-motorized activities that disturb piping plovers and disrupt normal
behavior patterns. Disturbance by humans and pets may deter plovers from
using nesting or foraging habitat, cause chicks to become separated from
their parents, or cause parents to desert their nests, leaving eggs or
chicks exposed to summer sun and predators. Dogs frequently chase and
attempt to capture adults and chicks.

By virtue of its small size and geographic isolation, the Great Lakes
piping plover population is at greater risk of extinction than larger
widespread populations because it is more likely to be destroyed by
random environmental events. Inbreeding depression and loss of genetic
diversity through a population bottleneck are potential concerns.

Piping plovers may accumulate contaminants from point sources and
non-point sources at breeding, migratory stopover, and wintering sites.
Oil spills represent an important concern for Great Lakes piping plovers
wintering on both the Atlantic and Gulf Coasts and to piping plovers
migrating and breeding along Great Lakes waterways.

######## Range-wide Status and Distribution of the Species

The piping plover was listed under the Act on January 10, 1986 (50 FR
50726). The piping plover breeds only in North America in three
geographic regions: the Atlantic Coast, the Great Lakes, and the
Northern Great Plains. These three breeding populations were listed
separately in the final rule; the Atlantic and Northern Great Plains
populations are classified as threatened and the Great Lakes population
as endangered. Plovers on migration and in wintering areas are
considered threatened under the Act.

Critical habitat for the breeding population of the Great Lakes piping
plover was designated on May 7, 2001 (USFWS 2001a). A total of 35 units,
encompassing 325 km (201 mi) of shoreline in 26 counties in eight states
(Minnesota, Michigan, Wisconsin, Illinois, Indiana, Ohio, Pennsylvania,
and New York) were included in the designation. The greatest number of
critical habitat units (23) occurs in Michigan with a total shoreline
length of 139 mi (224 km). The remaining units cover approximately 62 mi
(101 km) of shoreline in the other seven states. Within the geographic
areas designated, only those areas that contain the Primary Constituent
Elements (PCEs), as defined by 50 CFR 424.12(b), are considered as
critical habitat. The PCEs for the Great Lakes breeding population of
the piping plover are defined as island and mainland shorelines that
support open, sparsely vegetated, sandy habitats, such as sand spits or
sand beaches, that are associated with wide, unforested systems of dunes
and inter-dune wetlands. Per the rule, suitable sites must have at least
0.12 mi (0.2 km) of gently sloping, sparsely vegetated (\< 50 percent
herbaceous and woody cover) sand beach with a total beach area of at
least 5 ac (2 ha). Within these size sites, the habitat must be at least
164 ft (50 m) in length where beach width is greater than 23 ft (7 m);
there is protective cover for chicks; and the distance to the treeline
from the normal high water line is more than 164 ft (50 m). The beach
width may be narrower than 23 ft (7 m) if areas of sand and cobble of at
least 23 ft (7 m) exist between the dune and treeline. Sites must also
have a low level of disturbance from human activities and from domestic
animals.

The final rule designating critical habitat for the wintering grounds
was published on July 10, 2001 (USFWS 2001b). A total of 142 units,
encompassing 1798.3 mi (2,891.7 km) of shoreline and approximately
165,211 ac (66,881 ha) in eight states (North Carolina, South Carolina,
Georgia, Florida, Alabama, Mississippi, Louisiana, and Texas) were
included in the designation. The greatest number of critical habitat
units occurs in Florida (34 units) and Texas (37 units). Critical
habitat units designated in Florida, Texas and Louisiana encompass 1351
mi (2,172 km) of shoreline. The PCEs for the wintering population of the
piping plover are defined as geologically dynamic coastal areas that
support intertidal beaches and flats (between annual low tide and annual
high tide) and associated dune systems and flats above annual high tide.
Intertidal flats include sand and/or mud flats with no or very sparse
emergent vegetation. Adjacent unvegetated or sparsely vegetated sand,
mud, or algal flats above high tide are also important. Important
components of the beach/dune ecosystem include surf-cast algae for
feeding of prey, sparsely vegetated back-beach for roosting and refuge
during storms, spits for feeding and roosting, salterns, and washover
areas for feeding and roosting.

A draft recovery plan for the Great Lakes piping plover population was
published on August 5, 2002 (USFWS 2002a). The objective of the recovery
plan is to restore and maintain a viable population (95 percent or
greater chance of persisting 100 years) to the Great Lakes region and
delist the Great Lakes population by 2020. Recovery criteria include: 1)
increasing the population to at least 150 pairs (300 adults) with at
least 100 pairs (200 adults) in Michigan and 50 pairs (100 adults)
distributed among the other Great Lakes states for 5 consecutive years;
2) increasing 5-year average fecundity to 1.5 - 2.0 fledglings per pair
per year; 3) adequately protecting essential breeding and wintering
habitat; 4) assuring and maintaining adequate genetic diversity over the
long-term; and 5) assuring agreements and funding mechanisms are in
place for long-term protection and management activities in essential
breeding and wintering habitat.

Piping plovers once nested on Great Lakes beaches in Illinois, Indiana,
Michigan, Minnesota, New York, Ohio, Pennsylvania, Wisconsin, and
Ontario, Canada. Historically, as many as 492-682 breeding pairs may
have nested in the Great Lakes region in the late 1800s (Russell 1983).
Michigan may have had 215 pairs or more; Ontario and Illinois likely
supported the next largest populations (152-162 and 125-130,
respectively). Indiana, Ohio, and Wisconsin were estimated to have 100
or fewer breeding pairs each, and Minnesota, New York, and Pennsylvania
fewer than 30 each.

Piping plovers were extirpated from Great Lakes beaches in Illinois,
Indiana, New York, Ohio, Pennsylvania and Ontario by the late 1970s
(Russell 1983), coincident with major industrial development and
urbanization of the southern lakeshores. Few piping plovers nested in
Wisconsin after the 1970s, and no nests were found in the state between
1983 and 1997 (Sumner. Matteson, Wisconsin DNR, pers. comm., 1998 as
cited in USFWS 2002a). Similarly, the small number of pairs that nested
in Duluth Harbor, Minnesota had abandoned the area by 1986 (Bonita
Eliason, Minnesota DNR, pers. comm., 1999 as cited in USFWS 2002a). In
1977, the Great Lakes population was estimated at 31 nesting pairs
(Lambert and Ratcliff 1979) but declined to approximately 17 pairs by
1985 (USFWS 1985). When the piping plover was listed as endangered in
1986, the Great Lakes population nested exclusively at a few sites on
the northeastern shore of Lake Michigan and southeastern shore of Lake
Superior in Michigan, the state with the most habitat remaining.

From 1986 to 2001, the Great Lakes piping plover population ranged from
12 to 32 breeding pairs. In 2002, 51 pairs (50 pairs in Michigan, 1 pair
in Wisconsin) were observed nesting in the Great Lakes. Although this is
a substantial increase in population size compared to the previous
years, the species remains critically endangered. Reproductive success
has also fluctuated among years and may be negatively correlated with
increases in lake levels (Wemmer 2000). Fledging success in 2002 was
1.20 chicks fledged per pair, while overall fledging success from 1984
to 2002 is 1.41 chicks fledged per pair. In recent years, the Great
Lakes population has gradually increased and expanded to the south and
east in Michigan and to the west with pairs breeding in Wisconsin.

######## Status and Distribution of the Species in the Action Area

Although there are no historic records of piping plovers in the action
area, piping plovers have been recently documented on the HMNF. In 1999,
at least one pair of piping plovers was sighted just outside the
Manistee NF, at the City of Ludington harbor, but no nests were located.
In 2002, a breeding pair was documented in Ludington State Park, within
designated critical habitat (Unit MI-17). This pair successfully fledged
four young and the adults and young were observed on the HMNF, near the
southern border, after hatching (USDAFS 2002a). No piping plover nests
were observed on HMNF lands. This area of the HMNF however, is
considered suitable piping plover nesting habitat (Jack Dingledine,
USFWS, pers. comm. 2003).

The Nordhouse Dunes and Ludington State Park Critical Habitat Unit
(MI-17) is approximately 8.3 miles (13.4 km) of Lake Michigan shoreline
in Mason County. Approximately 4.6 miles (7.4 km) are part of the HMNF
Nordhouse Dunes Wilderness Area, and the remaining 3.7 miles (6.0 km)
are part of Ludington State Park. This unit extends from the mouth of
the Cooper Creek south to the mouth of the Big Sable River (66 FR 22938
Section 4.4.2).

Tawas State Park Critical Habitat Unit (MI-23) is approximately 1.2
miles (2.0 km) of Lake Huron shoreline in Iosco County. It includes
areas used for foraging by transient piping plovers and contains
suitable nesting habitat. The entire designated area is within Tawas
State Park and extends from the Tawas State Park boundary on the east
side of Tawas Point and includes all shoreline within Township 22 north,
Range 8 east, Section 34 and offshore sand spits. Tawas State Park is
adjacent to Huron NF (66 FR 22938 Section 4.4.2). Piping plover were
documented to have nested in this critical habitat unit in 2002 (Jack
Dingledine, USFWS, pers. comm. 2002).

The areas of critical habitat provides the best potential for piping
plover on the HMNF. Limited dune and shoreline habitat is also found
along Lake Huron on HMNF in the Black River area (MA 8.1). This area,
however, does not contain the high quality habitat found on the Lake
Michigan shore, particularly in the Nordhouse Dunes Wilderness Area.
There are no records of the piping plover from this area and it was not
designated as critical habitat.

######## Analysis and Determination of Effects

We concur with the HMNF's determination that potential effects of the
proposed action on the piping plover and critical habitat will be
insignificant or discountable. The reasons for this are twofold: 1)
piping plovers are not known to nest on the HMNF and 2) implementation
of the proposed conservation measures will provide significant
protection for the species on the HMNF. The conservation measures
committed to by the HMNF, as described in the biological assessment,
will avoid or significantly reduce the potential for adverse effects to
the species and its critical habitat by 1) as necessary, restricting or
prohibiting recreational activities such as ORV use, camping, foot and
horse trail use, and related activities within potential piping plover
habitat, 2) prohibiting sand mining and other resource development
activities within potential piping plover habitat, 3) seasonally closing
critical habitat, as necessary, 4) designing management activities to
improve critical habitat, 5) monitoring for piping plover use on the
HMNF, and 6) committing to participate in nest monitoring and
protection, as necessary. Thus, the potential habitat for piping plovers
will be protected for future use, should the species become established
within the action area.

Although protective measures proposed for potential piping plover nests
will help ensure adverse effects to piping plover are avoided,
implementation of these measures can also cause short-term unavoidable
adverse impacts to the species. As such, if nesting of piping plovers
occurs on the HMNF, reinitiation of consultation will be required so new
information may be incorporated, and the potential effects of the
proposed action considered in this Opinion on this species may be
analyzed. Upon the discovery of a piping plover nest, the HMNF should
contact the Service's East Lansing Field Office for further
consultation.

The piping plover and its critical habitat will not be considered
further in this Opinion.

**Species [Likely to Be Adversely Affected]{.underline} by the Proposed
Action**

The HMNF has determined that the proposed action considered in this
Opinion is likely to adversely affect the Indiana bat, Karner blue
butterfly, and Pitcher's thistle. The remainder of this analysis will
focus on the status of these species, summarizing the information
necessary to establish the species status and environmental baseline to
assess the effects of the proposed action.

**Indiana bat**

Status of the species and critical habitat

This section presents the biological or ecological information relevant
to formulating the biological opinion. The purpose is to provide the
appropriate information on the species= life history, its habitat and
its [range-wide]{.underline} distribution and conservation status for
analyses in later sections. This section also documents the effects of
all past human and natural activities or events that have led to the
current status of the species.

######## Species Description

The Indiana bat is a medium-sized, monotypic species (there are no
subspecies) of the genus Myotis. Its forearm length is 1.4 to 1.6 in (35
to 41 mm). The head and body length ranges from l.6 to l.9 in (41 to 49
mm). This species closely resembles the little brown bat (*M.
lucifugus*) and the northern long-eared bat (*M. septentrionalis*). The
Indiana bat usually has a distinctly keeled calcar. The hind feet tend
to be small and delicate with fewer, shorter hairs (do not extend beyond
the toenails) than its congeners. The fur lacks luster (Hall 1981;
Barbour and Davis 1969). The ears and wing membranes have a dull
appearance and flat coloration that do not contrast with the fur. The
fur of the chest and belly is lighter than the flat (not glossy),
pinkish- brown fur on the back, but does not contrast as strongly as
does that of the little brown bat or northern long-eared bat, for
example (Richard Clawson, Missouri Department of Conservation, pers.
observ. October 1996 as cited in USFWS 1999). The skull has a small
sagittal crest, and the braincase tends to be smaller, lower, and
narrower than that of the little brown bat (Hall 1981; Barbour and Davis
1969).

######## Life History

*Behavior*. Generally, Indiana bats hibernate from October through April
(Hall 1962; LaVal and LaVal 1980), but this period may be extended to
September through May in northern areas (Kurta, pers. observ. June 1997
as cited in USFWS 1999) depending upon local weather conditions. They
hibernate in large, dense clusters, ranging from 300 bats/ft^2^ (3,230
bats/m^2^) (Clawson et al. 1980) to 484 bats/ft^2^ (5,215 bats/m^2^)
(Clawson, pers. observ. October 1996 as cited in USFWS 1999). Figure 2
shows the annual life cycle for the Indiana bat.

![](media/image2.png){width="5.7347222222222225in"
height="1.4020833333333333in"}

Figure 2. Indiana bat annual life cycle (USFWS 1999)

Indiana bats are very loyal to their hibernacula (LaVal and LaVal 1980).
Upon arrival at hibernating caves in August-September, Indiana bats
"swarm," a behavior in which "large numbers of bats fly in and out of
cave entrances from dusk to dawn, while relatively few roost in the
caves during the day" (Cope and Humphrey 1977). Swarming continues for
several weeks and mating occurs during the latter part of the period.
Fat supplies are replenished as the bats forage prior to hibernation.
Indiana bats tend to hibernate in the same cave in which they swarm
(LaVal et al. 1976; Stihler, pers. observ. October 1996 as cited in
USFWS 1999) although swarming has occurred in caves other than those in
which the bats hibernated (Cope and Humphrey 1977; MacGregor, pers.
observ. October 1996 as cited in USFWS 1999).

During swarming, males remain active over a longer period of time at
cave entrances than do females (LaVal and LaVal 1980), probably to mate
with the females as they arrive. After mating, females enter directly
into hibernation. A majority of bats of both sexes hibernate by the end
of November \[by mid-October in northern areas (Kurta, pers. observ.
June 1997 as cited in USFWS 1999)\], but hibernacula populations may
increase throughout the fall and even into early January (Clawson et al.
1980).

Adult females store sperm through the winter and become pregnant via
delayed fertilization soon after emergence from hibernation. Young
female bats can mate in their first autumn and have offspring the
following year, whereas males may not mature until the second year.
Limited mating activity occurs throughout the winter and in late April
as the bats leave hibernation (Hall 1962).

Indiana bats emerge from hibernation differentially by sex. Females
emerge from hibernation ahead of males; most winter populations leave by
early May. Some males spend the summer near hibernacula in Missouri
(LaVal and LaVal 1980) and West Virginia (Stihler, pers. observ. October
1996 as cited in USFWS 1999). In spring when fat reserves and food
supplies are low, migration is probably hazardous (Tuttle and Stevenson
1978). Consequently, mortality may be higher in the early spring,
immediately following emergence.

Humphrey et al. (1977) reported that Indiana bats first arrived at their
maternity roost in early May in Indiana, with substantial numbers
arriving in mid-May. Females may arrive at their summer habitats as
early as April 15 in Illinois (Gardner et al. 1991a, Brack 1979). During
this early spring period, a number of roosts (e.g., small cavities) may
be used temporarily, until a roost with larger numbers of bats is
established. Most of the documented maternity colonies contained 100 or
fewer adult bats.

Maternity colonies occupy roost sites in forested riparian, floodplain,
or upland habitats, and exhibit strong roost site fidelity (Cope et al.
1978; Clark et al 1987; Gardner et al. 1991a, b; Brack 1983; Callahan et
al. 1997; MacGregor, pers. observ. October 1996as cited in USFWS 1999;
Stihler, pers. observ. October 1996 as cited USFWS 1999). Some male
Indiana bats disperse throughout the range and roost individually or in
small numbers in the same types of trees and in the same areas as
females, while other males remain near their hibernacula.

After grouping into nursery colonies, parturition occurs in late June
and early July (Easterla and Watkins 1969; Humphrey et al. 1977).
Females give birth to a single young which are capable of flight within
a month of birth, typically by mid-July to early August (Mumford and
Cope 1958; Cope et al. 1974; Humphrey et al. 1977; Clark et al. 1987;
Gardner et al. 1991a; Kurta et al. 1996).

Male and female Indiana bats spend the latter part of the summer
accumulating fat reserves for fall migration and hibernation.

*Food Habits.* Indiana bats feed strictly on aquatic and terrestrial
flying insects; selection of prey items reflects the environment in
which they forage. Diet varies seasonally and variation is observed
among different ages, sexes, and reproductive-status groups (Belwood
1979; Lee 1993). Reproductively active females and juveniles exhibit
greater dietary diversity than males and non-reproductively active adult
females, perhaps due to higher energy demands. Reproductively active
females eat more aquatic insects than do adult males or juveniles (Lee
1993).

Moths (Lepidoptera) are major prey items identified in several studies
(Belwood 1979; Brack and LaVal 1985; Lee 1993; Gardner and Brack,
unpubl. data as cited USFWS 1999), but caddisflies (Trichoptera) and
flies (Diptera) are major prey items documented in another (Kurta and
Whitaker 1998). Another major prey group includes mosquitoes and midges
(Belwood 1979; Gardner and Brack, unpubl. data as cited in USFWS 1999),
especially species that form large mating aggregations above or near
water (Belwood 1979). Other prey include bees, wasps, and flying ants
(Hymenoptera), beetles (Coleoptera), leafhoppers (Homoptera),
treehoppers (Homoptera), stoneflies (Plecoptera), and lacewings
(Neuroptera) (Whitaker 1972; Belwood 1979; Gardner and Brack, unpubl.
data as cited in USFWS 1999).

Male Indiana bats summering in or near a hibernation cave feed
preferentially on moths and beetles. Additionally, caddisflies, flies,
mosquitoes, midges, stone flies, leafhoppers, treehoppers, and true bugs
are consumed, but in low percentages. Many bats species predominately
eat terrestrial insects, as would be expected from observations of their
foraging habitat (Brack and LaVal 1985); however, the Indiana bat is
known to depend heavily on aquatic insects (Kurta and Whitaker 1998).

[Habitat Use and Requirements]{.underline}

*Winter Habitat*. Indiana bats require specific roost sites in caves or
mines that attain appropriate temperatures to hibernate. In southern
parts of the bat's range, hibernacula trap large volumes of cold air and
the bats hibernate where resulting rock temperatures drop; in northern
parts of the range, however, the bats avoid the coldest sites. In both
cases, the bats choose roosts with a low risk of freezing. Ideal sites
are 50°F (10°C) or below when the bats arrive in October and November.
Early studies identified a preferred mid-winter temperature range of
39-46°F (4-8°C), but a recent examination of long-term data suggests
that a slightly lower and narrower range of 37-43°F (3-6°C) may be ideal
for the species. Only a small percentage of available caves provide for
this specialized requirement. Stable low temperatures allow the bats to
maintain a low rate of metabolism and conserve fat reserves through the
winter, until spring (Humphrey 1978; Richter et al. 1993).

Relative humidity at roost sites during hibernation usually is above 74
percent but below saturation (Hall 1962; Humphrey 1978; La Val et al.
1976), although relative humidity as low as 54 percent has been observed
(Myers 1964). Humidity may be an important factor in successful
hibernation (Thomas and Cloutier 1992).

Specific cave configurations determine temperature and humidity
microclimates, and thus suitability for Indiana bats (Tuttle and
Stevenson 1978; LaVal and LaVal 1980). Indiana bats select roosts within
hibernacula that best meet their needs for cool temperatures; in many
hibernacula these roosting sites are near an entrance, but may be deeper
in the cave or mine if that is where cold air flows and is trapped
(Tuttle and Stevenson 1978; Clawson pers. observ. October 1996 as cited
in USFWS 1999).

*Summer Habitat*. A full, well-integrated understanding of the summer
needs of this endangered species is not available. Early researchers
considered floodplain and riparian forest to be the primary roosting and
foraging habitats used in the summer by the Indiana bat (Humphrey et al.
1977), and these forest types unquestionably are important. More
recently, upland forest has been shown to be used by Indiana bats for
roosting (Clark et al. 1987; Gardner et al. 1991b; Callahan et al.
1997); and upland forest, old fields, and pastures with scattered trees
have been shown to provide foraging habitat (Gardner et al. 1991b;
Butchkoski and Hassinger 2002).

Indiana bats live in highly altered landscapes and use an ephemeral
resource (e.g., dead and dying trees) as roost sites. Anecdotal evidence
suggests that the Indiana bat may, in fact, respond positively to
habitat disturbance. Maternity roosts have been found where hog lots
have killed overstory trees and removed understory trees in Illinois,
Indiana, and Missouri (Gene Gardner, Missouri Department of
Transportation; Jim Cope, Earlham College (retired); and Clawson,
respectively, pers. observ. October 1996 as cited in USFWS 1999). Timber
harvest activities neither directly damaged known roosts nor discouraged
bats from continuing to forage in one harvested area that was studied in
Illinois (Gardner et al. 1991a), and Indiana bats have been found
roosting in shelterwood cuts in Kentucky (MacGregor, pers. observ. June
1997 as cited in USFWS 1999). A couple of maternity colonies, including
the first discovered maternity roost in Indiana, were found when a tree
was cut down and the bats moved to another tree. These observations
suggest that the Indiana bat may be a more adaptable species than
previously thought.

Conceptually, at least in the western part of the species' range, the
Indiana bat may have been a savanna species. The following facts support
this contention: Indiana bats prefer large trees in the open or at
edges, they seem to prefer open canopies and fragmented forest
landscapes, and they seem to prefer forest with an open understory.

Within the range of the species, the existence of Indiana bats in a
particular area may be governed by the availability of natural roost
structures, primarily standing dead trees with loose bark. The
suitability of any tree as a roost site is determined by 1) its size
(dbh), 2) its condition (dead or alive), 3) the quantity of loose bark,
4) the tree's solar exposure and location in relation to other trees,
and 5) the tree's spatial relationship to water sources and foraging
areas.

A number of tree species have been reported to be used as roosts by
Indiana bats (see Cope et al. 1974; Humphrey et al. 1977; Gardner et al.
1991a; Kurta et al. 1993a; Kiser and Elliott 1996; Kurta et al. 1996;
Callahan et al. 1997). Morphological characteristics of the bark of a
number of trees make them suitable as roosts for Indiana bats; that is,
when dead, senescent, or severely injured (e.g., lightning-struck) these
trees possess bark that springs away from the trunk upon drying.
Additionally, the shaggy bark of some living hickories (*Carya spp*.)
and large white oaks (*Quercus alba*) also provide roost sites. The most
important characteristics of trees that provide roosts are not species
but structure: exfoliating bark with space for bats to roost between the
bark and the bole of the tree. The persistence of peeling bark varies
with the species of tree and the severity of environmental factors to
which it is subjected.

To a very limited extent, tree cavities or hollow portions of tree boles
and limbs also provide roost sites for Indiana bats (Gardner et al.
1991a; Kurta et al. 1993b). A crevice in the top of a lightning-struck
tree (Gardner et al. 1991a), and splits below splintered, broken tree
tops have also been used as roosts (MacGregor, pers. observ. June 1997
as cited in USFWS 1999).

Indiana bat maternity colonies use multiple roosts, in both dead and
living trees. Important factors in suitability and use include exposure
of roost trees to sunlight and location relative to other trees. Because
cool temperatures can delay the development of fetal and juvenile young
(Racey 1982), selection of maternity roost sites may be critical to
reproductive success. Dead trees with east-southeast and south-southwest
exposures may allow solar radiation to effectively warm nursery roosts.
Roosts in some species of living trees (e.g., shagbark hickory \[*Carya
ovata*\]), on the other hand, may provide better protection from rain
water and other unfavorable environmental conditions because their
greater thermal mass maintains more favorable temperatures for roosting
bats during cool periods (Humphrey et al. 1977).

Most of the roost trees used by a maternity colony are close together.
The spatial extent and configuration of a colony's regular use area is
probably determined by the availability of suitable roosts. The
distances between roosts occupied by bats within a single maternity
colony have ranged from just a few meters for nearest distance to
another roost to several kilometers ( Al Kurta, Eastern Michigan
University, pers. observ., October 1996 as cited in USFWS 1999; Callahan
et al. 1997). Miller (1996) compared habitat variables for sites in
northern Missouri where surveys for Indiana bats had been conducted and
noted that significantly larger trees \[\> 30 cm (12 in) in dbh\] were
found where reproductively active Indiana bats had been netted, than at
sites at where bats had not been captured.

Indiana bat maternity roosts can be described as "primary" or
"alternate" based upon the proportion of bats in a colony occupying the
roost site, and location in relation to forest canopy cover (Callahan et
al. 1997; Kurta et al. 1996). Maternity colonies have at least one
primary roost (up to three have been identified for a single colony)
that is used by the majority of the bats throughout the summer. Colonies
also use multiple alternate roosts that are used by small numbers of
bats intermittently throughout the summer (up to 17 have been found for
a single colony). Primary roosts are located in openings or at the edge
of forest stands, while alternate roosts can be in either the open or
the interior of forest stands. Thermoregulatory needs may be a factor in
roost site selection. Primary roosts are not surrounded by closed canopy
and can be warmed by solar radiation, thus providing a favorable
microclimate for growth and development of young during normal weather.
Alternate roosts tend to be more shaded, frequently are within forest
stands, and are selected when temperatures are above normal or during
periods of precipitation. Shagbark hickories seem to be particularly
good alternate roosts because they provide cooler roost conditions
during periods of high heat and their tight bark shields bats from the
encroachment of water into the roost during rain events (Callahan et al.
1997). Roost site selection and use may differ between northern and
southern parts of the species' range, but more data are needed before
such differences can be specified.

Trees that provide Indiana bat roosts are ephemeral. It is not possible
to generalize or estimate roost longevity due to the many factors that
influence it. Bark may slough off completely or the tree may fall over.
Although roosts may only be habitable for one to two years under
"natural conditions" for some tree species (Humphrey et al. 1977),
others with good bark retention such as slippery elm (*Ulmus rubra*)
cottonwood (*Populus deltoides*), Green ash (*Fraxinus pennsylvanica*),
and oaks (Quercus spp.), may provide roosting habitat four to eight
years (Gardner et al. 1991a; Callahan et al. 1997; Kurta, pers. observ.
June 1997 as cited in USFWS 1999). Hickories also retain bark well.

Indiana bats have strong site fidelity to summer colony areas, roosts,
and foraging habitat. Females have been documented returning to the same
roosts from one year to the next (Humphrey et al. 1977; Gardner et al.
1991a, b, Callahan et al. 1997; Kurta and Murray 2002). Male Indiana
bats also have been recaptured when foraging in habitat occupied during
prior summers (Gardner et al. 1991b).

The Indiana bat may be more adaptable with regard to roosts than
previously believed. Humphrey et al. (1977) suggested that previously
used summer roosts may be important to the reproductive success of local
Indiana bat populations; that if these roosts are lost or unavailable,
adult females may be faced with finding suitable maternity sites at a
time when they are already stressed from post-hibernation migration and
the increased metabolic energy costs of pregnancy. Recent studies have
shown, however, that Indiana bats know of and occupy a number of roost
sites within a maternity colony area. Bats move from one roost to
another within a season, in addition to responding to changes in
environmental conditions (temperature and precipitation), and when a
particular roost becomes unavailable (Gardner et al. 1991a; Callahan et
al. 1997). Therefore, while the Indiana bat appears to be an adaptable
animal, it is essential that a variety of suitable roosts exist within a
colony's occupied summer area to assure the continuance of the colony in
that area (Kurta et al. 1993a; Callahan et al. 1997; Kurta et al. 2002).

In areas of high latitude or elevation, cool summer temperatures appear
provide sub-optimal thermal conditions for Indiana bat reproduction
(Brack et al. 2002). Reproductive females of several bat species are
also reported to become less common at higher elevations (Brack et al.
2002). Erickson and West (2002) found that summer activity of several
bat species was positively correlated with increasing temperatures in
Oregon and Washington. Such elevational restrictions on the distribution
of female Indiana bat are evident in South Dakota (Cryan et al 2000),
the eastern Appalachian states (Brack et al 2001), Pennsylvania
(Butchkoski and Hassinger 2001), and in Virginia (Hobson 1993). In Iowa,
the northern limit to Indiana bat distribution is 42º north latitude
(Clark et al. 1987). In Pennsylvania, mist netting between 41 and 42^o^
north latitude failed to produce Indiana bats (Kiser et al. 2001a). This
portion of Pennsylvania is characterized by a low annual temperature
(43ºF average), high elevation, high annual rainfall (45 inches), and
extreme annual variation of temperature and rainfall. Indiana bat
reproduction was documented at three sites in Vermont between 43°50\'
and 43°58\' north latitude (Kiser et al. 2001b). These sites, however,
were located in areas with lower elevation, higher than average mean
annual temperature (45°F), and lower than average precipitation relative
to the rest of the region. It is believed that Indiana bats are unlikely
to reproduce in significant numbers outside of the species' core range
where climatic constraints imposed at high elevations or high latitudes
are present (Brack et al. 2002).

*Fall and Spring Roosts*. Indiana bats use roosts in the spring and fall
similar to those selected during the summer. During the fall, when
Indiana bats swarm and mate at their hibernacula male bats roost in
trees nearby during the day and fly to the cave during the night. In
Kentucky, Kiser and Elliott (1996) found male Indiana bats roosting
primarily in dead trees on upper slopes and ridgetops within 1.5 mi (2.4
km) of their hibernaculum. During September in West Virginia, male
Indiana bats roosted within 3.5 mi (5.6 km) in trees near ridgetops, and
often switched roost trees from day to day (Craig Stihler, West Virginia
Division of Natural Resources, pers. observ. October 1996 as cited in
USFWS 1999). Fall roost trees more often tend to be exposed to sunshine
rather than being shaded (MacGregor, pers. observ. October 1996 as cited
in USFWS 1999).

Upon emergence from hibernation in the spring, some males remain within
the vicinity of their hibernacula where they roost and forage in mature
forest; movements of 2.5 - 10 mi (4 - 16 km) have been reported in
Kentucky, Missouri, and Virginia respectively (MacGregor, pers. comm.
December 1998 as cited in USFWS 1999; Hobson and Holland 1995;
3D/International 1996). However, other males leave the area entirely
upon emergence in the spring. Females dispersing from a Kentucky
hibernaculum in the spring moved 4 - 10 mi (6.4 - 16 km) within 10 days
of emergence (MacGregor, pers. comm. December 1998 as cited in USFWS
1999).

*Foraging Habitat and Behavior*. Indiana bats forage in and around the
tree canopy of floodplain, riparian, and upland forest. In riparian
areas, Indiana bats primarily forage around and near riparian and
floodplain trees \[e.g., sycamore (*Platanus occidentalis*), cottonwood,
black walnut (*Juglans nigra*), black willow (*Salix nigra*), and
oaks\], and solitary trees and forest edge on the floodplain (Belwood
1979; Cope et al. 1974; Humphrey et al. 1977; Clark et al. 1987; Gardner
et al. 1991b). Within floodplain forests where Indiana bats forage,
canopy closures range from 30 to 100 percent (Gardner et al. 1991b).
Cope et al. (1978) characterized woody vegetation with a width of at
least 98 ft (30 m) on both sides of a stream as excellent foraging
habitat. Streams, associated floodplain forests, and impounded bodies of
water (e.g., ponds, wetlands, reservoirs) are preferred foraging
habitats for pregnant and lactating Indiana bats, some of which may fly
up to 1 mi (1.6 km) from upland roosts (Gardner et al. 1991b). Indiana
bats also forage within the canopy of upland forests, over clearings
with early successional vegetation (e.g., old fields), along the borders
of croplands, along wooded fencerows, and over farm ponds in pastures
(Clark et al. 1987; Gardner et al. 1991b).

The extent of foraging area used by an Indiana bat maternity colony has
been reported to range from a linear strip of creek vegetation 0.5 mi
(0.8 km) in length (Belwood 1979; Cope et al. 1974; Humphrey et al.
1977), to a foraging area 0.75 mi (1.2 km) in length, within which bats
flew over the wooded river or around the riverside trees (Cope et al.
1978). Indiana bats return nightly to their foraging areas (Gardner et
al. 1991b).

Indiana bats usually forage and fly within an air space from 6 - 100 ft
(2 - 30 m) above ground level (Humphrey et al. 1977). Most Indiana bats
caught in mist nets are captured over streams and other flyways at
heights greater than 6 ft (2 m) (Gardner et al. 1989).

During summer, male Indiana bats that remained near their Missouri
hibernacula flew cross-country or upstream toward narrower, more densely
wooded riparian areas during nightly foraging bouts, perhaps due to
interspecific competition with gray bats (*M. grisescens*). Some male
bats also foraged at the edges of small floodplain pastures, within
dense forest, and on hillsides and ridgetops; maximum reported distance
was 1.2 mi (2 km) (LaVal et al. 1976; LaVal et al. 1977; LaVal and LaVal
1980). In Kentucky, MacGregor (pers. comm. December 1998 as cited in
USFWS 1999) reported that the maximum distance males moved from their
hibernaculum in the summer was about 2.6 mi (4.2 km). In the fall, male
Indiana bats tend to roost and forage in upland and ridgetop forests,
but also may forage in valley and riparian forest; movements of 1.8 -
4.2 mi (2.5 - 6.8 km) have been reported in Kentucky and Missouri (Kiser
and Elliott 1996; 3D/International 1996).

######## Threats

-   Documented Threats.

*Disturbance and Vandalism*. A serious cause of Indiana bat decline has
been human disturbance of hibernating bats during the decades of the
1960s through the 1980s. Bats enter hibernation with only enough fat
reserves to last until spring. When a bat is aroused, as much 68 days of
fat supply may be used in a single disturbance (Thomas et al. 1990).
Humans, including recreational cavers and researchers, passing near
hibernating Indiana bats can cause arousal (Humphrey 1978; Thomas 1995).
If this happens too often, the bats' fat reserves may be exhausted
before the species is able to forage in the spring.

Direct mortality due to human vandalism has been documented. The worst
known case occurred in 1960 when an estimated 10,000 Indiana bats were
killed in Carter Cave State Park, Kentucky by three youths who tore
masses of bats from the ceiling and trampled and stoned them to death
(Mohr 1972). Another documented incident was reported from Thornhill
Cave, Kentucky, where at least 255 Indiana bats were found in January
1987, killed by shotgun blasts (Anon. 1987).

*Improper Cave Gates and Structures*. Some hibernacula have been
rendered unavailable to Indiana bats by the erection of solid gates in
the entrances (Humphrey 1978). Since the 1950s, the exclusion of Indiana
bats from caves and changes in air flow are the major cause of loss in
Kentucky (an estimated 200,000 bats at three caves) (MacGregor, pers.
observ. October 1996 as cited in USFWS 1999). Other cave gates have so
modified the climate of hibernacula that Indiana bats were unable to
survive the winter because changes in air flow elevated temperatures
which caused an increase in metabolic rate and a premature exhaustion of
fat reserves (Richter et al. 1993).

Conversely, an Indiana bat population may be restored if an improper
gate is replaced with one of appropriate design. In Wyandotte Cave,
Indiana, dramatic population increases followed gate replacement and
restoration of traditional air flow. Success, however, may not be
immediate or automatic, as in Hundred Dome Cave, Kentucky. At Hundred
Dome, air flow obstructions have been removed and bat-friendly gates
installed. Indiana bats have returned to their traditional hibernation
site, but expected population gains have not yet materialized. At sites
where populations do not increase in response to proper gate
installation, other factors should be investigated to determine if the
site is suitable for a large population (Currie 2002).

*Natural Hazards*. Indiana bats are subject to a number of natural
hazards. River flooding in Bat Cave, Mammoth Cave National Park, drowned
large numbers of Indiana bats (Hall 1962). Other cases of hibernacula
being flooded have been recorded by Hall (1962), DeBlase et al. (1965),
and MacGregor (pers. observ. October 1996 as cited in USFWS 1999). A
case of internal cave flooding occurred when tree slash and debris
(produced by forest clearing to convert the land to pasture) were
bulldozed into a sinkhole, blocking the cave's rain water outlet and
drowning an estimated 150 Indiana bats (MacGregor, pers. observ. October
1997 as cited in USFWS 1999). One case of flash flooding compounded by
cave gates occurred in 1997: in early March, a severe flood occurred at
Bat Cave (Carter Caves State Park, Kentucky- a Priority One
hibernaculum). Debris that had accumulated on the gate at the upper Bat
Cave entrance impounded rain water until pressure completely destroyed
the gate, allowing a surge of water through the cave system where it was
backed up again at the gate in the lower cave entrance. Water reached
the ceiling in portions of the hibernation section of the cave and
drowned an estimated 3,000 Indiana bats (T. Wethington, Kentucky DNR,
pers. comm. March 1997 as cited in USFWS 1999).

Bats hibernating in mines are vulnerable to ceiling collapse (Hall
1962), and this is a serious concern at Pilot Knob Mine in Missouri,
once the largest known Indiana bat hibernating population. To a lesser
extent, ceiling collapse in caves is also possible.

Another hazard exists because Indiana bats hibernate in cool portions of
caves that tend to be near entrances, or where cold air is trapped. Some
bats may freeze to death during severe winters (Humphrey 1978; Richter
et al. 1993). Indiana bats apparently froze to death in Bat Cave
(Shannon County, Missouri) in the 1950s (R. Myers, U. S. Weather Service
(retired), pers. comm. October 1996 as cited in USFWS 1999). The
population at the same site was 30,450 in 1985, when the bats were
observed roosting on a high ceiling, presumably to escape severe cold at
their traditional roosting ledges 7-9 ft above the cave floor. In the
subsequent 1987 survey, the population plummeted to 4,150 bats and the
floor of the cave was littered with bat bones, suggesting that the bats
died during hibernation, most likely from freezing (Clawson, pers.
observ. October 1996 as cited in USFWS 1999).

At Missouri's Great Scott Cave, average mid-winter temperatures appear
to have risen 8°F (4.4ºC) from the mid 1980s through the present,
compared to temperatures in the 1970s and early 1980s; a major
population loss occurred between the mid 1980s and 1998. Preliminary
analysis of fall and winter temperature data suggests that a similar
trend has occurred in ambient temperature outside the cave, and thus
appears to have played a role in these population losses (Clawson, pers.
observ. July 1998 as cited in USFWS 1999). A much more detailed analysis
is needed, along with detailed temperature profiles of this and other
hibernacula, to better understand the relationships among climate, air
flow, and hibernation microclimates within important hibernacula.
Indiana bats are vulnerable to the effects of severe weather when
roosting under exfoliating bark during summer. For example, a maternity
colony was displaced when strong winds and hail produced by a
thunderstorm stripped the bark from their cottonwood roost and the bats
were forced to move to another roost (Gardner, pers. observ. October
1996 as cited in USFWS 1999).

*Other*. Other documented sources of decline include indiscriminate
collecting, handling and banding of hibernating bats by biologists, and
flooding of caves by reservoirs (Humphrey 1978).

-   Suspected Causes.

*Microclimate Effects*. Caves and mines change far more than is
generally recognized. Entrances and internal passages essential to air
flow may become larger, smaller, or closed altogether, with concomitant
increases or decreases in air flow. Blockage of entry points, even those
too small to be recognized, can be extremely important in hibernacula
that require chimney-effect air flow to function. As suggested by
Richter et al. (1993) and Tuttle and Kennedy (2002), changes in air flow
can elevate temperatures which can cause an increase in metabolic rate
and a premature exhaustion of fat reserves.

Hibernacula in the southern portions of the Indiana bat's range may be
either near the warm edge of the bat's hibernating tolerance or have
relatively less stable temperatures. Hibernacula in the North may have
passages that become too cold. In the former case, bats may be forced to
roost near entrances or floors to find low enough temperatures, thus
increasing their vulnerability to freezing or predation. In the North,
bats must be able to escape particularly cold temperatures. In both
cases, modifications that obstruct air flow or bat movement could have
serious consequences.

Tuttle and Kennedy (2002) recently evaluated the midwinter temperatures
for 15 important Indiana bat hibernacula. This study found that
hibernacula with midwinter temperatures between 37ºF and 45ºF (3°C and
7.2ºC) had increasing populations, while hibernacula with midwinter
temperatures outside of this range had decreasing populations. These
results suggest that some deviations in roost temperatures may account
for some of the overall population decline.

*Land Use Practices*. The Indiana bat's maternity range has been changed
dramatically from pre-settlement conditions: forest has been fragmented
in the upper Midwest, fire has been suppressed, and prairie has been
supplanted with agricultural systems (primarily row crop and
pasture/hayland). Native plants, especially grasses, have been replaced
with exotics in large portions of the maternity range, and diverse plant
communities have been replaced with simple ones or monocultures.
Simplification of the habitat can have profound effects through factors
such as availability and abundance of insects on which the bats prey.

Conversely, regions surrounding hibernacula in the Missouri Ozarks and
elsewhere may be more densely forested than they were historically. If
the Indiana bat is a savanna species, maternity habitat in these regions
may be more scarce than previously known.

In the eastern U.S., the area of land covered by forest has been
increasing in recent years. Whether or not this is beneficial to the
Indiana bat is an open question. The age, composition, and size class
distribution of the woodlands will have a bearing on their suitability
as habitat for the species.

A clearer picture of the relationship between the Indiana bat and its
summer habitat is needed. Until we better understand the factor or
factors that have contributed to the decline of the species, we cannot
accurately assess whether the loss of summer habitat (especially
riparian, floodplain, or upland forest) is limiting to regional or range
wide populations of the species.

*Chemical Contamination*. Pesticides have been implicated in the
declines of a number of insectivorous bats in North America (Mohr 1972;
Reidinger 1972, 1976; Clark and Prouty 1976; Clark et al. 1978; Geluso
et al. 1976; Clark 1981). The effects of pesticides on Indiana bats have
yet to be studied. McFarland (1998) studied two sympatric species, the
little brown bat (*M. lucifugus*) and the northern long-eared bat (*M.
septentrionalis keenii*) as surrogates in northern Missouri and
documented depressed levels of acetylcholinesterase, suggesting that
bats there may be exposed to sublethal levels of organophosphate and/or
carbamate insecticides applied to agricultural crops. McFarland (1998)
also demonstrated that bats in northern Missouri are exposed to
significant amounts of agricultural chemicals, especially those applied
to corn. BHE Environmental, Inc. (1999) collected tissue and guano
samples from five species of bats at Fort Leonard Wood, Missouri and
documented the exposure of bats to p,p'-DDE, heptachlor epoxide, and
dieldrin. Additional research is needed to further determine the effect
of these contaminants on Indiana bats.

######## Range-wide Status and Distribution of the Species

The Indiana bat was listed as an endangered species on March 11, 1967
(32 FR 4001) under the Endangered Species Preservation Act of October
15, 1966 \[80 Stat. 926; 16 U. S. C. 668aa(c)\]. Critical Habitat was
designated for the Indiana bat on September 24, 1976 (41 FR 41914); 11
caves and two mines in six states were listed as critical habitat:
Illinois - Blackball Mine (LaSalle Co.); Indiana - Big Wyandotte Cave
(Crawford Co.), Ray's Cave (Greene Co.); Kentucky - Bat Cave (Carter
Co.), Coach Cave (Edmonson Co.); Missouri -- Cave 021 (Crawford Co.),
Caves 009 and 017 (Franklin Co.), Pilot Knob Mine (Iron Co.), Bat Cave
(Shannon Co.), Cave 029 (Washington Co.); Tennessee - White Oak Blowhole
Cave (Blount Co.); and West Virginia - Hellhole Cave (Pendleton Co.).

The Service has completed an agency draft revised recovery plan for the
Indiana bat (USFWS 1999). Reasons for updating the plan are: 1) to
update the recovery plan with information on the life history and
ecology of the Indiana bat, especially information on summer ecology,
that has been gathered since 1983; 2) to highlight the continued and
accelerated decline of the species; 3) to continue site protection and
monitoring efforts at hibernacula; and 4) to focus new recovery efforts
towards research to determine the factor or factors causing population
declines. The recovery actions identified in the draft revised plan are:

1.  Conduct research necessary for the survival and recovery of the
    Indiana bat, including studies on ecology and life history; summer
    habitat requirements; genetics; potential chemical contamination;
    and assessments of temperature profiles and hibernation
    microclimates of major hibernacula.

2.  Obtain information on population distribution, status, and trends.

3.  Protect and maintain Indiana bat populations.

4.  Provide information and technical assistance outreach.

5.  Coordinate and implement the conservation and recovery of the
    Indiana bat.

If recovery criteria are adequately met, reclassification of the Indiana
bat to threatened would be considered in 2005 and delisting would be
considered in 2011.

The Indiana bat is a migratory species found throughout much of the
eastern U.S. During winter, Indiana bats are restricted to suitable
hibernacula primarily located in karst-dominated regions (USFWS 1999).
More than 85 percent of the Indiana bat population hibernates in caves
in Indiana, Kentucky, and Missouri. They have also been found
hibernating in abandoned mines, hydroelectric dams, and other man-made
underground chambers. Smaller hibernating populations are known from
Alabama, Arkansas, Connecticut, Georgia, Illinois, Iowa, Maryland,
Massachusetts, Michigan, Mississippi, New Hampshire, New Jersey, New
York, North Carolina, Ohio, Oklahoma, Pennsylvania, South Carolina,
Tennessee, Vermont, Virginia, West Virginia, and Wisconsin (USFWS 1999).
Table 11 lists population estimates, based on counts at hibernacula, for
each state where the Indiana bat occurs.

Table 11. Summary of hibernating Indiana bat populations by state, based
upon estimates nearest to year indicated^1^. Only states with records of
greater than 100 hibernating Indiana bats are listed (adapted from USFWS
1999 and Clawson 2002).

  -------------- --------------------- --- --------------------- --- --------------------- --- --------------------- ---
                 Estimated Population                                                                                

  State          1960/1970                 1980                      1990                      2000-2001             

  Alabama        350                       350                       350                       250                   

  Arkansas       15,000                    15,000                    4,500                     2,500                 

  Illinois       14,800                    14,800                    14,900                    19,300                

  Indiana        160,300                   155,200                   163,500                   173,100               

  Kentucky       248,100                   102,200                   78,700                    47,900                

  Missouri       399,000                   342,000                   150,100                   73,000                

  New York       20,200                    21,100                    26,800                    34,900^2^             

  Ohio           150                       3,600                     9,500                     9,800                 

  Pennsylvania   700                       700                       400                       700                   

  Tennessee      20,100                    20,100                    16,400                    10,200                

  Virginia       3,100                     2,500                     1,900                     1,000                 

  West Virginia  [1,500]{.underline}       [1,200]{.underline}       [6,500]{.underline}       [9,700]{.underline}   

  Total          883,300                   678,750                   473,550                   382,350               
  -------------- --------------------- --- --------------------- --- --------------------- --- --------------------- ---

^1^ Due to inconsistent records, population estimates for a particular
period were extrapolated from the nearest survey prior to or subsequent
to the year displayed in the table; therefore, all caves are represented
in each period.

^2^ Data from 1998-1999

Information on range-wide Indiana bat migration patterns is limited
(USFWS 1999). Available banding data indicate that females and some
males migrate north in the spring upon emergence from hibernation (Hall
1962; Barbour and Davis 1969; Kurta 1980; La Val and La Val 1980; Bowles
1982), although there also is evidence that movements may occur in other
directions.

The range-wide summer distribution of Indiana bats is not well
understood. The majority of summer records of the Indiana bat are from
southern Iowa, northern Missouri, northern Illinois, northern Indiana,
southern Michigan, and western Ohio. Most observations suggest that
female Indiana bats in the Midwest tend to migrate north to summer
maternity range while male Indiana bats are found throughout the entire
range of the species during summer months.

Most of the maternity records of the Indiana bat are documented from the
Midwest (southern Iowa, northern Missouri, northern Illinois, northern
Indiana, southern Michigan, and western Ohio). Although the woodland in
this glaciated region is mostly fragmented, it has a relatively high
density of maternity colonies. Today, small bottomland and upland
forested tracts with predominantly oak-hickory forest types and
riparian/bottomland forests of elm-ash-cottonwood associations exist in
an otherwise agriculturally dominated (nonforested) landscape (USFWS
1999). Unglaciated portions of the Midwest (southern Missouri, southern
Illinois, southern Indiana), Kentucky, and most of the eastern and
southern portions of the species' range appear to have fewer maternity
colonies per unit area of forest. Such conclusions may be premature,
however, given the lack of search effort in these areas.

######## Status and Distribution of the Indiana Bat in Michigan

Based on survey and studies of bat species and historical records (Kurta
1982; Kurta et al., 1989; Kurta et al., 1993a; Kurta 2000; Tibbels and
Kurta *in press*), the current known distribution of the Indiana bat in
Michigan is shown in Figure 3. Indiana bats have been documented in the
summer almost exclusively in southern Michigan, with only one record in
northern Michigan. Summer distribution (May 15 to August 15) of the
Indiana bat in Michigan is currently known is from Barry, Branch,
Calhoun, Eaton, Ingham, Hillsdale, Livingston, St. Joseph, and Washtenaw
counties. Historical summer records have been recorded from Emmet,
Jackson, and Wayne counties. The record from Emmet County, the northern
most sighting of this species in Michigan, was a male Indiana bat found
under wooden shake siding on a building in early May (MacGregor, pers.
comm. 2001 as cited in USFWS 1999). Available evidence indicates that
most Indiana bats known to summer in Michigan, likely winter in caves in
Indiana, Illinois, and Kentucky (Kurta 1982, 2002), although one
hibernaculum with a small population of Indiana bats has been documented
in northern Michigan.

![](media/image3.jpeg){width="4.5in" height="3.9in"}

Figure 3. Distribution of the Indiana bat in Michigan (based on USDAFS
2003a).

Kurta (1992) reports that temperature is the most important
environmental factor affecting biology of all bats. It affects the
species' hibernation, roosting, duration of gestation and lactation,
activity of insect prey, and ultimately activity patterns, of all bat
species (Kurta 1992, Erickson and West 2002). Summer temperature regimes
on a micro- and macro- scale likely play a key role in distribution,
abundance, and reproduction of the Indiana bat (Brack et al. 2001).
Cooler summer temperatures associated with latitude or elevation likely
constrain reproductive success and therefore the summer distribution
(Brack et al. 2002). Cave temperatures, which are typically a function
of regional surface temperature, must be cold, but not too cold for
hibernation (Brack et al. 2002). Thus, Indiana bats likely require a
unique combination of summer warmth and winter cold to persist in an
area (Brack et al. 2002).

Hargrove and Hoffman (1999) developed an ecoregion characterization
using multivariate clusters, which uses multiple environmental
conditions, including temperature, to produce ecoregion borders. Brack
et al. (2001), using the "growing degree days" (number of days in the
growing season temperature range per year) of Hargrove and Hoffman
(1999), provided additional understanding of the summer range of the
Indiana bat, beyond that of ecosystem- or habitat-based models alone.
The dotted line on the Indiana bat distribution map (Figure 3) is a
segregation line in growing degree-days from multivariate clustering
from Hargrove and Hoffman (1999). The segregation is being used to
depict a northern boundary of the potential summer range of the Indiana
bat in Michigan.

Indiana bats were discovered in 1994 hibernating in Tippy Dam (Kurta and
Teramino 1994), owned by Consumers Energy Company (Consumers), but
located within the administrative boundary of the HMNF (Manistee NF) on
the Manistee River in Manistee County. The spillway of Tippy Dam
shelters one of the largest populations of hibernating bats (multiple
species) in Michigan, and it is the only known Indiana bat hibernaculum
in the state (Kurta et al 1997). Annual counts estimated 16,000 to
20,000 bats hibernating inside the hollow concrete spillway of Tippy Dam
between 1994 and 1998 (Kurta 1998; Kurta et al. 1997). Although numbers
have fluctuated recently, dropping as low as 9,000 bats in February 2000
(Kurta 2000), surveys preformed in 2001 to 2002 indicate that the
numbers of hibernating bats has rebounded to approximately 19,000
individuals (Kurta 2002).

Most of the bats known to hibernate in the spillway of Tippy dam are
little brown bats (*M. lucifugus*) and northern bats (*M.
septentrionalis*); very few are Indiana bats. The exact number of
Indiana bats that hibernate in the spillway is unknown, however, since
the internal geometry of the dam makes it difficult to view closely and
identify every bat. Since 1994, surveys have documented a total of 15
individual Indiana bats, eight females and seven males, at Tippy dam;
eleven of these were caught during hibernation and four during swarming.
Two new individuals were caught and banded in the 2001 - 2002 survey
(Kurta 2002). Based on the survey data, the total number of Indiana bats
in Tippy dam is estimated between 3 to 65 bats; the actual number,
however, is most likely on the lower end of this range (Kurta et al.
1997).

Based on surveys performed from 1994 to 2002, Indiana bats are
consistently present at Tippy Dam, albeit in low numbers (Kurta 2002).
The existing Tippy Dam spillway appears to provide suitable temperature
and humidity conditions for the bat species that hibernate there. Human
disturbances during the fall and winter are rare because access to the
spillway is limited and controlled by Consumers. Access to the area is
further limited because most of the land surrounding Tippy Dam is owned
by Consumers, the Little River Band of Odawa Tribe, and the HMNF. The
habitat surrounding Tippy Dam is wooded and appears to supply adequate
roosting habitat for bats during swarming. Further details on habitat
management are available in the Indiana Bat Management Plan (Kurta 1995)
and Manistee River Land Management Plan prepared in compliance with
requirements for the Federal Energy Regulatory Commission's (FERC)
relicensing the Consumers hydropower facility at Tippy Dam. The bat
population, including Indiana bats, hibernating in Tippy dam is
considered stable and well-protected (Kurta 2002).

No additional caves or mines exist on the HMNF. The other dams on the
HMNF lack suitable cave-like habitat found in Tippy Dam. Because Tippy
Dam is the only known hibernaculum in Michigan, autumn swarming and
spring staging are likely restricted to this area. Radio-telemetry
studies documented two male Indiana bats roosting in woodlands near
Tippy Dam during autumn swarming season (Kurta 2000). Both roosted in a
variety of trees within 2.1 mi (3.4 km) of the dam. These are the only
records of Indiana bats in the action area, outside of the Tippy Dam
hibernaculum.

The potential range of the Indiana bat extends into the northwestern
part of the Manistee NF, along Lake Michigan (see Figure 3). This is the
area where Indiana bats, if present anywhere on the HMNF (Huron or
Manistee NFs) in summer, would most likely be found. Although Tippy Dam
is located just outside of this range, lands within 5 mi (8 km) of the
hibernaculum, the Tippy Management Zone (TMZ), are also considered
potential Indiana bat habitat. Of the potential Indiana bat range in
Michigan, a total of 441,214 ac (178,554 ha) are within the action area,
approximately 40 percent of which (178,214 ac; 72,121 ha) is owned by
the HMNF.

Indiana bats known to summer in southern Michigan must migrate from
hibernacula to the south in Indiana, Ohio, and Kentucky, or from Tippy
Dam to the north. Indiana bats banded during summer in southern Michigan
have not been documented hibernating in Tippy Dam, however, they have
been recovered in hibernacula in Indiana and Kentucky, providing
evidence that migration to the south has taken place (Kurta and Murray
2002). Migration between the summer range and hibernacula either to the
north or the south could include of much of HMNF during spring and
autumn. Migratory habitat could include essentially all types of
woodlands, bridges, buildings, and other structures.

To date, Indiana bats have not been found during summer on the HMNF and
the summer range for the Indiana bats hibernating at Tippy Dam is
unknown (Kurta and Rice 2002). The closest known summer maternity record
for the Indiana bat is near Vermontville, Michigan (Eaton Co.),
approximately 62 mi (100 km) southeast of the Manistee NF, and about 130
mi (209 km) southeast of Tippy Dam. There are no historic records for
the Indiana bat on the HMNF (Kurta 1982). Surveys performed in central
Michigan, including HMNF lands, in 1986 found no Indiana bats (Kurta et
al. 1989). Summer mist net surveys conducted at 27 sites on suitable
habitat in the Manistee portion of the HMNF in 1998 and 1999 also found
no Indiana bats (Kurta 2000). Recently, Tibbels and Kurta (*in press*)
performed ultrasonic monitoring and mist net surveys in red pine stands
on the HMNF found no Indiana bats. The authors believe that red pine
stands have low insect abundance and are too structurally complex to be
suitable habitat for bats.

The negative results of these surveys, however, do not provide
conclusive evidence that Indiana bats do not summer on the HMNF. It is
possible that small, isolated colonies were missed (Kurta 2000). Given
the small numbers of Indiana bats known to hibernate in Tippy Dam, the
probability of detecting them on the HMNF in the summer is very low
because of the large area of available habitat.

Male Indiana bats may remain geographically close to the hibernacula
during summer (LaVal and LaVal 1980; Brack 1983; Whitaker and Brack
2001; Gumbert 2001). During this time, males often roost individually,
and likely use trees similar in character to those used near hibernacula
in autumn and spring. They sometimes visit the hibernacula during
summer. Thus, it is possible that male Indiana bats may summer on the
HMNF, near Tippy Dam (Kurta 2000).

The potential summer range of the Indiana bat in Michigan includes the
western portion of the Manistee NF (Figure 3), in an area of relatively
mild climatological conditions from lake influence and lower elevation.
Areas of suitable upland and riparian forest on the Manistee NF within
this climatological zone may provide summer habitat for both maternity
colonies and for males. Land within the TMZ may also provide summer
habitat for male Indiana bats. Potential habitat in both areas may
include essentially all types of forest, even scattered trees, bridges,
buildings, and other structures.

It is possible that small isolated maternity colonies or scattered
individual male Indiana bats are present on the Manistee NF during
summer, and have not yet been detected (Kurta 2000). Restrictive
climatological conditions, however, similar to those known to limit
Indiana bat reproduction elsewhere in its range, are present. Most of
the Manistee NF, extends above 43º north latitude. The line delineating
the potential northern extent of the Indiana bat range, derived from
growing degree days, corresponds with the delineation of mean annual
temperatures of 45°F. Thus, the potential Indiana bat range on the
Manistee NF is consistent with the known northern limits of distribution
in other portions of Indiana bat range and has similar climatological
conditions that are sub-optimal for Indiana bat reproduction (Clark et
al. 1987; Hobson 1993; Cryan et al 2000; Brack et al 2001; Kiser et al.
2001a and 2001b; Brack et al. 2002). Furthermore, the entire HMNF,
including the Manistee NF, falls outside of the core summer range of
this species (USFWS 1999). Based on the low numbers of hibernating
individuals and the apparent reproductive constraints imposed by local
climate, it is unlikely that the Indiana bats from Tippy Dam, or from
anywhere else in the species' range, summer or reproduce in significant
numbers on the HMNF.

######## Factors Affecting The Species Environment Within The Action Area

-   Indiana Bat Management Plan

In response to Article 412 of the FERC\'s relicensing order of July 15,
1994 for Tippy Dam, a management plan for the Indiana bat at Tippy Dam
was developed (Kurta 1995). The Indiana Bat Management Plan represents
Part V of the Manistee River Land Management Plan for Tippy Dam (FERC
Project No. 2580) that was filed with FERC on January 16, 1996. The plan
for the bat addresses two threats to the species at Tippy Dam: 1)
disturbance to hibernating bats and 2) destruction/degradation of
nonhibernating bat habitat.

Disturbance during hibernation is a major threat to any species of
hibernating bat. Consequently, to prevent disturbance to hibernating
Indiana bats, the plan prohibits unnecessary entry into the spillway
between September 1^st^ and June 1^st^ of each year. The plan also
prohibits unnecessary operation of the spill gates during the same
period. Operation of the gates causes a large amount of water to enter
the interior of the spillway through the lower ventilation openings,
resulting in a significant increase in noise levels and presumably a
sudden change in air temperature and humidity, as well as an increase in
air currents.

To protect any Indiana bats that may roost outside the spillway during
the summer and swarming seasons, the plan prohibits tree‑cutting on
Consumers Tippy Project land within a 3.1 mi (5 km) radius around Tippy
Dam, from May 1 through October 1 of each year. Use of pesticides is
prohibited during this same period to prevent effects on the bats and
their food supply (insects). In addition, the plan mandates the
preservation of a suitable density of potential roost trees

(\>4 trees per acre) on forested portions of Consumers Tippy Project
land.

The plan also calls for monitoring population trends and environmental
parameters to establish baseline conditions. Monitoring both population
levels and environmental parameters during the hibernation season
immediately following the spillway rehabilitation work was initiated to
assess potential long‑term effects on all bats within the spillway.
Monitoring of population levels began in February 1995, and temperature
and humidity recordings were started in August 1995. Both were set to
continue through the 1999-2000 season when the need for continued
monitoring was be assessed. Monitoring was continued for two more
seasons through the 2001-2002.

Based on the apparent stability of the bat population (including Indiana
bats) and the consistent environmental and protective conditions present
at the site (Kurta 2002), Consumers believes that it has fulfilled the
requirements set forth in the plan, and will no longer fund monitoring
of the bat population in Tippy Dam (Hittle *in litt*.). They are
amenable, however, to allow others to continue the effort and options to
continue monitoring of the Indiana bats in Tippy Dam are being explored.

The Indiana Bat Management Plan has, and continues to provide, critical
management and protection for Indiana bats and the Tippy Dam
hibernacula, and has improved the status of the species and its habitat
within the action area.

-   First Implementation of the LRMP, 1986

The LRMP for the HMNF was first implemented in 1986 and underwent formal
section 7 consultation. The Indiana bat was not known to be present on
the Forest at that time and thus was not included in the consultation.
Furthermore, the standards and guidelines for timber harvest included in
the LRMP provided no special protection or consideration for the Indiana
bat or its habitat. Although bat surveys performed in 1986 found no
Indiana bats on the HMNF (Kurta et al. 1989), Indiana bats may have been
present on the HMNF, but only in undetectable numbers. Because of this,
adverse effects to this species may have occurred. Specifically, harvest
in suitable Indiana bat habitat may have resulted in degradation of
roosting habitat or loss of roosting individuals in felled trees.

Given the large amount of suitable habitat available, it is unlikely
that management activities would have encountered and directly impacted
individuals (e.g., fell trees with roosting bats) or indirectly impacted
Indiana bats by removing habitat to the extent that their foraging or
roosting activities would have been impaired. Therefore, we believe that
implementation of the LRMP did not likely impose long-term significant
negative impacts on the Indiana bat.

-   Spillway Rehabilitation Project at Tippy Dam, 1997

A comprehensive investigation was performed in 1993 to evaluate the
structural condition of all hydroelectric plants owned by Consumers,
including Tippy Dam. The investigation at Tippy Dam revealed extensive
deterioration of exposed concrete, resulting from freeze‑thaw cycles.
The damage posed no immediate threat, but repairs were deemed necessary
to extend the useful life of the dam. Consequently, after consulting
with the FERC, Tippy Dam was scheduled for spillway rehabilitation in
1997.

On July 2, 1996, the FERC initiated formal consultation with the Service
to address potential effects of the proposed action on the Indiana bats
hibernating in the dam. Rehabilitation of Tippy Dam primarily
entailed 1) structural rehabilitation of the concrete spillway and
concrete elements of the powerhouse tailrace, 2) addition of ballast to
the spillway interior to enhance long‑term sliding stability, and 3)
construction of a temporary cofferdam, including any necessary auxiliary
structures to operate and maintain the spill capacity of the plant,
during the rehabilitation period.

Along with the proposed action, multiple conservation measures for
Indiana bats were proposed, including:

\- Completion of the projects between May and September to avoid direct
impacts to swarming and hibernating bats

\- Maintenance or improvement of potential bat roosting cavities within
the dam structure

\- Maintenance of appropriate ventilation in the dam

\- Continued implementation of the Indiana Bat Management Plan

In its January 8, 1997 biological opinion, we analyzed the potential
effects of this project and determined that rehabilitation of the Tippy
Dam spillway was not likely to jeopardize the continued existence of the
Indiana bat. We estimated that unavoidable construction delays may
eliminate or reduce suitable habitat for hibernating bats at Tippy Dam
during the fall and winter of 1997-98. Because there were no known
suitable substitute hibernacula nearby, this could have resulted in the
incidental take of all Indiana bats that utilize the dam. Thus, based on
population estimates, incidental take was permitted for 3-65 Indiana
bats. No authorized or unauthorized take of Indiana bats, however, was
documented as a result of this project and the physical suitability of
the dam as a bat hibernaculum was maintained.

-   Informal Consultations

Since the discovery of Indiana bats in Tippy Dam in 1994, both the FERC
and the HMNF have consulted with the Service on actions that may affect
the Indiana bat. Consultation with the HMNF occurred with the assumption
that the Indiana bat was present where suitable habitat existed.
Consultation occurred throughout the HMNF, and this assumption did not
apply the climatic variables that are now used to define the species
potential range on the HMNF (although the potential for these climatic
restrictions were discussed in project-specific biological assessments).
The outcome of these informal consultations was "not likely to adversely
affect." This determination was reached by either avoiding stands with
suitable Indiana bat habitat, or by incorporation of a variety of
conservation measures including:

\- Seasonal harvest prohibition in potential Indiana bat habitat between
May 1 and August 31.

\- Seasonal harvest prohibition in the Tippy Management Zone between May
1 and October 20.

\- Prohibition of prescribed burns in the Tippy Management Zone between
May 1 and

> October 20.

\- Where timber harvest occurs in potential Indiana bat habitat, an
average of 4 suitable roost trees per acre are maintained.

\- Regeneration units designed with irregular borders to provide edges
for solar exposure of roost trees, interspersion of roosting and
foraging habitats, and travel corridors.

\- Removal of standing dead trees for firewood cutting prohibited in
potential Indiana bat habitat between May 1 and August 31.

Over the past decade, the HMNF has harvested timber on approximately
10,496 ac (4,278 ha) in the potential Indiana bat range of the Manistee
NF, which is only about 2 percent of the total potential Indiana bat
habitat within the action area. We believe that the use of these
conservation and avoidance measures in each individual project has
cumulatively, for all projects, maintained or improved the status of
this species in the action area by reducing the possibility of take of
an Indiana bat, maintaining or increasing the long-term number of
available suitable roost trees, and improving potential roosting habitat
on the Manistee NF.

######## Summary and Synthesis of the Environmental Baseline

Indiana bats have been detected within the administrative boundary of
the HMNF, inside of Tippy dam while hibernating and within the TMZ
during autumn swarming. This small population of hibernating Indiana
bats appears to be protected and stable. Indiana bats have not been
detected elsewhere within the action area, and it is unknown where the
Tippy Dam Indiana bats summer. The lack of summer records within the
action area is consistent with other portions of the species range with
similar climatic conditions. If Indiana bats are present during the
summer, they likely occur in very low numbers. The species is more
likely to be present within the TMZ, most likely during autumn and
spring. Given the overall rarity of the Indiana bat on the HMNF and the
conservation measures that were implemented in past activities to
protect this species and its potential habitat (both summer and the
TMZ), it is unlikely that the status of the species in the action area
has decreased or is decreasing contemporaneously with this consultation.

Effects of the Action

This section assesses the effects of the proposed action, including the
direct and indirect effects together with the effects of other
activities that are interrelated or interdependent (50 CFR 402.02).
Indirect effects are those that are caused later in time, but are still
reasonably certain to occur. Interrelated actions are those that are
part of a larger action and depend upon the larger action for their
justification. Interdependent actions are those that have no independent
utility apart from the action under consideration (50 CFR 402.02). This
section also assesses the cumulative effects, including the effects of
future State, tribal, local or private actions that are reasonably
certain to occur in the action area.

######## Analysis for the Effects of the Action

The following management actions in the LRMP will have [no
effect]{.underline} or are [not likely to adversely affect]{.underline}
the Indiana bat.

-   *Range Management*

There are grazing allotments on 1,300 ac (546 ha) within potential
Indiana bat range. Trees on the edges of grazed areas receive more solar
exposure making them better potential roosting habitat. Indiana bats
have been documented foraging and roosting in grazed areas (Brack 1983,
Callahan 1993). The effects of range management of existing allotments
on the Indiana bat are likely beneficial. Additional or expanded grazing
allotments are unlikely because of the lack of available grasslands and
the high cost of converting forested areas into productive range (USDAFS
2003a).

-   *Recreation, Wilderness, and Related Resource Management*

Indiana bats have been observed near picnic, park, and camping areas
(Brack 1983; Kiser et al., 1998). Therefore, most recreational
activities, including both developed and dispersed recreation, are not
expected to disturb them. Maintenance of recreational facilities
requiring removal of trees could adversely affect roosting habitat.
These activities are applied to a limited area of the HMNF and are not
expected to occur on a significant amount of Indiana bat habitat.
Moreover, the use of habitat evaluation techniques, such as visual
assessments, will be employed to detect and avoid suitable roosting
habitat, further reducing the potential for adverse effects.
Furthermore, the HMNF has committed to seasonal restrictions for actions
that would result in habitat removal and modification to avoid potential
impacts to the Indiana bat, where feasible and prudent. Removal of trees
for human hazard or safety considerations will also employ seasonal
restrictions in developed recreation areas; in dispersed recreation
areas, potential similar impacts to the Indiana bat will be minimized by
inspecting a tree prior to its removal. We expect that, since the HMNF
determined that this management action is not likely to adversely affect
the Indiana bat, these measures will insure that a project will only
result in effects on the Indiana bat that are likely to be beneficial,
insignificant, or discountable.

-   *Watershed Management*

Vegetation management activities such as creating access points to
streams and acquiring woody debris for restoration may affect the
Indiana bat. These activities are not expected to occur on a significant
amount of Indiana bat habitat, and the use of visual assessments to
detect and avoid suitable roosting habitat further reduces the potential
for adverse effects. Furthermore, the HMNF has committed to use seasonal
restrictions to avoid potential impacts, where feasible and prudent. It
is our expectation that, since the HMNF determined that this management
action is not likely to adversely affect the Indiana bat, this measure
will insure that a project will only result in effects on the Indiana
bat are likely to be beneficial, insignificant, or discountable.

-   *Forest Pest Management*

Pesticides may affect bats directly through contact (Schmidt et al.
2001), or indirectly if pesticide application alters or contaminates the
prey base. Pesticides are used on a very limited basis under restrictive
guidelines on the HMNF. Indiana bats are very rare on the HMNF and are
thus very unlikely to come into contact with a pesticide application.
Indiana bats, however, forage over a wide array of habitats and prey,
and are not likely to be affected by a localized alteration in prey
base. Furthermore, the HMNF has committed to performing an environmental
analysis, including section 7 consultation to address any potential
effects on listed species, before the application of any pesticide. It
is our assumption that, since the HMNF determined that this management
action is not likely to adversely affect the Indiana bat, this analysis
will further insure that any proposed pesticide application will only
result in effects that are likely to be insignificant or discountable.

-   *Fire Management*

Fire management activities, associated with both wildfire suppression
and prescribed burning for a variety of purposes (e.g., fuel reduction,
wildlife management) are planned for 500 to 1,650 acres per year (202 to
668 ha per year), totaling approximately 500 to 4,950 ac (607 to 2,003
ha) for the estimated period of the proposed action. In general, fire
may adversely affect the Indiana bat by killing individuals, destroying
roost trees, or suffocating bats due to smoke inhalation. However, fire
management is anticipated to have beneficial effects as well. Fire
suppression may benefit the Indiana bat by reducing the potential for
these adverse effects from wildfires. Prescribed burning is generally
beneficial to the Indiana bat because it aids in maintaining forest
ecosystems used by the species. Fires can damage or kill trees,
contributing to the production of roost trees. Fires may also kill
saplings and smaller trees, opening up the canopy and allowing solar
warming of roost sites. Fires may also kill trees in the understory,
reducing understory clutter and making it more suitable for traveling
and foraging. Trails or other travel corridors may be kept open by fire,
or as firebreaks. In general, prescribed fires, if properly employed,
are likely to contribute to the long-term maintenance of suitable
habitat for the Indiana bat. The majority of potential adverse effects
from fire management are expected to be insignificant or discountable
because: 1) the HMNF has committed to using seasonal restrictions, when
feasible, for prescribed burning to avoid adverse effects (prescribed
burns generally prohibited in potential Indiana bat habitat from May 1
to August 31, in the TMZ from May 1 to October 20), 2) effects of
prescribed burning on hibernating Indiana bats in Tippy dam will be
avoided by planning burns when the wind will not carry the smoke into
the hibernacula, and 3) prescribed fires will be applied to very small
portion, less that one percent, of the potential Indiana bat habitat on
the HMNF. Therefore, we expect that the majority of fire management
activities will result in effects that are beneficial, insignificant, or
discountable.

Potential adverse effects on the Indiana bat may result from some fire
management activities, specifically wildlife management (primarily for
the Karner blue butterfly) and fuels management. These adverse effects
will be discussed later in this effects analysis section.

-   *Transportation System*

Although transportation projects have the potential to impact only a
small portion of potential Indiana bat habitat, construction or
improvement of roads that require vegetation management may affect the
species. Furthermore, as roads are decommissioned, potential water
sources that bats may depend on (i.e., road-rut puddles) are frequently
destroyed. These potential effects, however, are considered
insignificant and discountable because the HMNF will 1) use seasonal
restrictions to avoid impacts as necessary, 2) plan transportation
projects in a manner that avoids adverse impacts, 3) perform an
environmental analysis, including section 7 consultation to address
potential effect on listed species, for proposed transportation
projects. We expect that, since the HMNF determined that this management
action is not likely to adversely affect the Indiana bat, this analysis
will insure that any proposed project will only result in effects that
are beneficial, insignificant, or discountable.

-   *Recovery Plan Actions Addressed by the LRMP*

Beneficial effects are expected from continued implementation of the
LRMP by contributing to the recovery of the Indiana bat by addressing
the following draft revised recovery plan actions (USFWS 1999):

*Recovery Plan Action 1. Conduct research as necessary for survival and
recovery.*

> The HMNF will identify situations where conservation of the Indiana
> bat may be compatible with the conservation and management of other
> species, resources, or management actions.
>
> *Recovery Plan Action 2. Obtain information on population
> distribution, status, and trends.*
>
> The HMNF will continue to monitor the status of the Tippy Dam
> hibernacula and attempt to further delineate the habitat, of the
> Indiana bat on Forest Lands.

*Recovery Plan Action 3. Protect and maintain Indiana bat populations.*

> The HMNF will implement a variety of strategies, as previously
> discussed in this section, to protect and maintain the Indiana bat
> within the TMZ, and in areas of potential summer habitat on HMNF
> Lands.

*Recovery Plan Action 4. Provide information and technical assistance
outreach.*

> The HMNF will implement educational actions to inform the public about
> the Indiana bat.
>
> *Recovery Plan Action 5. Coordinate and implement the conservation and
> recovery of the Indiana bat.*

The HMNF will continue to communicate with land managers and researchers
regarding Indiana bat recovery efforts.

Note that for the management actions discussed above, if through Level 2
consultation, we determine that these management actions will adversely
affect the Indiana bat, reinitiation of section 7 consultation at the
programmatic level (i.e., reinitiation of this Level 1 consultation and
Opinion) will be required.

The following management actions in the LRMP are [likely to adversely
affect]{.underline} the Indiana bat:

-   *Timber Harvest, Minerals and Geology, Fire Management, and
    Wildlife, Fish and Sensitive Plant Management*

Adverse effects may result from these management actions when either
vegetation management or prescribed fire activities that are used within
potential Indiana bat habitat at a time and location where the species
may be present. These time and location combinations include the
following: 1) in the TMZ during fall swarming, spring staging, summer
(males may remain in proximity to the hibernaculum during summer months)
or 2) during the summer outside of the TMZ, but within the species
potential range on the HMNF.

Prescribed burning is prohibited within the TMZ from May 1 to October 20
and the majority of the prescribed burning within the larger area of
potential Indiana bat habitat will be completed outside of the summer
roosting period (May 1 to August 31). Some burning, however,
specifically for fuels management and management of wildlife habitat
will be proposed during these time periods. In particular, late spring
burning (after May 1) in Karner blue butterfly habitat restoration will
be occasionally employed to help control encroachment of woody
vegetation (Joe Kelly, HMNF, pers. comm. 2003). Adverse effects from
vegetation management may occur because: 1) the proposed action allows
for vegetation management to be performed throughout potential Indiana
bat habitat when it may be occupied and 2) vegetation management is
proposed on an overall large area of potential Indiana bat habitat on
the HMNF.

Potential direct effects of both vegetation management and prescribed
fire are the removal of roost trees used by a maternity colony (although
no colonies have been documented on the HMNF, the potential for such
colonies exists given the proximity to the hibernaculum and the extent
of suitable habitat present) and migrants during spring and fall
migration. Mortality or injury of individuals or small groups of
roosting bats could result during the felling or burning of trees that
may harbor roosts. Vegetation management activities may also directly
affect summering males adjacent to the hibernaculum in the TMZ and males
and females during the fall swarming and spring staging within the TMZ.
Impacts from prescribed fire may also include inhalation of smoke,
particulates, and toxins leading to suffocation of bats in roost trees.
Other direct effects could result from timber removal and prescribed
fire if roosting individuals or maternity colonies (i.e., bats occupying
trees which are not being harvested or burned but are in close proximity
to these activities) are forced to abandon a traditionally used site.
Roosting individuals may be forced to expend additional energy to find a
new roosting site, resulting in a lower survival rate. This effect would
be exacerbated in maternity colonies with pregnant females or females
that are already expending extra energy in caring for their young. The
survival rate of young may also decrease with forced abandonment by
lactating females from occupied roosts.

We believe that, based on the known status of the species in the action
area, the Indiana bat is likely to be present in the action area in only
very small numbers (best population estimate is as high as 65 Indiana
bats). Given the amount of potentially suitable habitat available on the
Manistee NF \[441,214 ac (178,554 ha)\], the likelihood of an individual
bat or colony occupying an area where vegetation management or
prescribed fire is to be used and thus incurring the impacts just
described is very low. The Indiana bats, however, are not likely to be
randomly distributed throughout this potential habitat, and as such,
there may be specific areas within HMNF where the potential to encounter
and adversely affect Indiana bats increases. These areas include the TMZ
and areas of particularly optimal habitat, such as stands with open
canopies, a high proportion of suitable roost trees, and adequate water
sources and foraging habitat. Thus, vegetation management and prescribed
fire within these types of areas pose a higher risk of adverse effects
(i.e., direct mortality or injury, lower reproductive success, and
higher young mortality) to the Indiana bat.

Vegetation management and prescribed burning may also result in the
temporary loss and degradation of roosting and foraging habitat, which
could indirectly affect Indiana bats. The effect of this temporary loss
and degradation of habitat, however, is expected to be insignificant and
discountable. The reasons for this are: 1) the proposed standards and
guidelines and conservation measures for vegetation management will
ensure suitable roosting habitat is maintained by preserving roost
trees, such as snags and live trees of optimal size and type;

2\) some data suggest that the Indiana bat can adapt well to
disturbances such as timber harvest, provided that adequate roosting
habitat remains intact; 3) the proposed standards and guidelines and
conservation measures for prescribed burning will ensure that suitable
roosting and foraging habitat is available in the proximity by limiting
the size, spatial arrangement, and annual rotation of burned areas; 4)
Indiana bats forage over a wide range of habitats including riparian
corridors, upland areas, fields, shelterwood cuts, and other disturbed
areas; and 5) Indiana bats are foraging generalists that will take
advantage of prey from numerous types of forest conditions.

Beneficial effects are expected from management activities completed
under the LRMP that should further offset adverse effects on roosting
and foraging habitat. In the long-term, implementation of the LRMP is
expected to increase the amount of suitable habitat. Through vegetation
management, opening of the forest canopy and designing stands with
irregular borders and openings in certain situations will improve
habitat suitability for roosting and reproduction by increasing exposure
of individual trees to solar radiation. Proposed vegetation management
methods will increase the overall tree size and proportion of hardwoods
in a stand and increase the potential for large dead trees or snags that
are suitable for roosting. Prescribed burning also will also have
beneficial effects for the Indiana bat by maintaining roosting,
foraging, and dispersal habitat by increasing dead trees or snags for
roosting, maintaining an open canopy by killing smaller trees, and
clearing the understory vegetation. Also, creation of additional
suitable foraging habitat through other forest management activities
(e.g., the creation of water sources in wildlife openings and as roads
are decommissioned) is expected.

The conservation measures proposed by the HMNF will provide significant
protection for the Indiana bat and its habitat from effects due to the
continued implementation of the LRMP. These conservation measures are
expected to be successful at avoiding or reducing the potential for
direct or indirect impacts to the species throughout its range on the
HMNF. Nonetheless, the potential for the take of all Indiana bats on the
HMNF may still result from timber removal and prescribed fire
activities.

We are not aware of any actions that are interdependent or interrelated
to the proposed action being considered in this Opinion.

######## Cumulative Effects

Cumulative effects include the combined effects of any future State,
local, or private actions that are reasonably certain to occur [within
the action area]{.underline} covered in this Opinion. Future Federal
actions that are unrelated to the proposed action are not considered in
this section because they require separate consultation pursuant to
section 7 of the Act.

Although we are aware of no major non-Federal actions are reasonably
certain to occur within the action area, it may be expected that some
activities, particularly on private lands, could have a progressive
negative effect on Indiana bats in the action area. Human populations in
the counties with potential Indiana bat habitat have been rapidly
increasing in recent years (USDAFS 2003a). Human population growth is
typically accompanied by increased urbanization, including road
construction and land development. Both of these activities could result
in the permanent loss of potential Indiana bat habitat. Additional
actions performed on private lands that may adversely affect the Indiana
bat in the future are fire suppression, application of pesticides, and
timber harvest.

The development of privately-owned mineral rights is possible on both
private and HMNF lands. Mineral rights on Federal lands are subject to
an environmental analysis, review, oversight, and permit from the
Federal agency. The Federal agency, however, may not be able to
condition a permit in a manner that would preclude the development of
the resource. In such cases, the HMNF may not be able to impose a "no
surface occupancy" stipulation in the permit for mineral extraction in
potential Indiana bat habitat, and the species may be adversely
affected. However, since there are no known mineral developments that
are reasonably certain to occur, we cannot figure them into our jeopardy
analysis for this species.

While the above activities may impact non-Federal lands within the
action area, there are 178,214 ac (72,121 ha) of potential Indiana bat
habitat under HMNF ownership. This is a significant amount of land and
should provide more than enough habitat for the fewer than 65 Indiana
bats that may summer in the action area. The proposed action will have
positive effects for the Indiana bat on HMNF lands that should help
offset negative effects of non-Federal activity in the action area. We
expect that the net long-term cumulative effect of the timber management
and other protective measures in the action area should be beneficial to
and improve the overall status of the species within the action area.

Conclusion

After reviewing the current status of the Indiana bat, the environmental
baseline for the action area, the effects of the proposed action, and
the cumulative effects, it is our biological opinion that the action, as
proposed, is not likely to jeopardize the continued existence of the
Indiana bat. Critical habitat for this species has been designated as
previously described in the accompanying Opinion, however, this action
does not affect designated critical habitat and, thus, no destruction or
adverse modification of that critical habitat is anticipated.

Continued implementation of the LRMP is likely to result in some low
level of adverse effects to the Indiana bat. These adverse effects are
most likely to occur either as injury or death of individual Indiana
bats or alteration of habitat. There will, however, also be beneficial
effects for this species, including the maintenance and improvement of
roosting and foraging habitat. Furthermore, many actions completed under
the LRMP will not occur in potential Indiana bat habitat, or are
designed such that they will not impart adverse effects on the species.
Thus, the anticipated level of adverse effects to the Indiana bat is
expected to be small and is not reasonably expected to, directly or
indirectly, reduce appreciably the likelihood of both the survival and
recovery of this species in the wild by reducing their reproduction,
numbers, or distribution.

The following factors, among others, were important in our assessment of
jeopardy:

-   The HMNF is on the very northern periphery of the Indiana bat range

-   The estimated population of Indiana bats on the HMNF (up to 65 bats)
    represents less than one percent (0.017 percent) of the total
    range-wide estimated population of Indiana bats (382,350 bats;
    Clawson 2002).

-   Proposed conservation measures will avoid or reduce the potential
    impacts to the Indiana bat and its habitat on the HMNF.

-   Continued implementation of the LRMP will contribute to the recovery
    of the Indiana bat by addressing recovery Actions.

We believe that even if all individuals potentially found on the HMNF
were taken as a result of the proposed action, we would not expect the
likelihood of the range-wide survival and recovery of the Indiana bat to
be appreciably reduced.

Incidental Take Statement

Section 9 of the Act and Federal regulation pursuant to section 4(d) of
the Act prohibit the take of endangered and threatened species,
respectively, without special exemption. Take is defined as to harass,
harm, pursue, hunt, shoot, wound, kill, trap, capture or collect, or to
attempt to engage in any such conduct. Harm is further defined by the
Service to include significant habitat modification or degradation that
results in death or injury to listed species by significantly impairing
essential behavioral patterns, including breeding, feeding, or
sheltering. Harass is defined by the Service as intentional or negligent
actions that create the likelihood of injury to listed species to such
an extent as to significantly disrupt normal behavior patterns which
include, but are not limited to, breeding, feeding or sheltering.
Incidental take is defined as take that is incidental to, and not the
purpose of, the carrying out of an otherwise lawful activity. Under the
terms of section 7(b)(4) and section 7(o)(2), taking that is incidental
to and not intended as part of the agency action is not considered to be
prohibited taking under the Act provided that such taking is in
compliance with the terms and conditions of this incidental take
statement.

In general, an incidental take statement specifies the impact of any
incidental taking of endangered or threatened species. It also provides
reasonable and prudent measures that are necessary to minimize the
impacts of the take and sets forth terms and conditions which must be
complied with in order to implement the reasonable and prudent measures.

A complete discussion of the Programmatic Consultation process and how
it relates to this incidental take statement is found on page 4 of the
accompanying Opinion.

######## Amount or Extent of Take

In this incidental take statement, we are evaluating the incidental take
of Indiana bats that may result from continued implementation of the
current LRMP for the HMNF. An LRMP is a permissive plan level document
that allows and guides, but does not authorize, specific actions to
occur. As explained within the accompanying Opinion and within HMNF's
biological assessment, the LRMP allows for actions that are likely to
adversely affect the Indiana bat. As such, specific actions conducted
under the LRMP may result in adverse effects to individual Indiana bats
that rises to the level of take. The conservation measures proposed as
part of the proposed action, however, substantively reduce the potential
for adverse effects and incidental take to occur as a result of actions
implemented under the LRMP. Therefore, projects completed under the LRMP
that comply with the conservation measures, standards and guidelines,
and other project commitments detailed in the biological assessment in
many cases would not adversely affect the Indiana bat such that take
would not be anticipated in many instances. There may be situations,
however, in which incidental take is likely regardless of whether the
conservation measures, standards and guidelines, and other project
commitments are adhered to. The likelihood of such instances is strongly
influenced by the timing and the location of the activity within HMNF.

Based on surveys to date, we believe a small population (best population
estimate is as high as 65 individuals) of Indiana bats may be present
within the action area. Indiana bats are not distributed evenly
throughout the suitable habitat. Thus, individual projects implemented
under the purview of the LRMP at specific times and locations could
result in the incidental take of 0 to 65 Indiana bats. Incidental take
of Indiana bats is expected to be in the form of killing, harming , or
harassing. Tree removal or prescribed burning during the non-hibernation
season may result in mortality to females and young or to individual
roosting male Indiana bats, if a particular tree that is impacted
contains a maternity colony or roosting bats. If an occupied roost tree
is accidentally lost and the bats using it were not killed during
removal, the colony (or roosting individuals) would be forced to find an
alternate roost which may cause them harm. Furthermore, the bat or bats
may die if no suitable alternative roosts are available.

Monitoring of incidental take of Indiana bats as a result of individual
projects completed as part of the proposed action will be required. We
anticipate that incidental take will be difficult to quantify and detect
due to the bat's small body size and their tendency to form small,
inconspicuous, widely dispersed colonies under loose bark or in cavities
of trees. Furthermore, the location of any summer roosting populations
will be difficult to detect within the large range of potential habitat
within the HMNF.

When used for other actions that adversely affect the Indiana bat,
monitoring of individual projects to track incidental take of individual
Indiana bats within an expansive area of forested habitat is a complex
and difficult task. Information is required in the form of a pre- and
post-project habitat survey. Before a harvest begins, every individual
tree that contains suitable roosting habitat requires inspection by a
knowledgeable biologist. Without this, it is impossible to know
definitively if a maternity colony or roosting Indiana bats are present
in an area proposed for harvest or other types of tree removal.
Incidental take is further evaluated by surveying trees that are removed
or disturbed after the harvest is completed. This type of tree
inspection is a very difficult and impractical survey method, and is
infrequently used as a means to determine incidental take of Indiana
bats. It is also possible to perform mist net surveys of a project area
to determine if Indiana bats are present; however, this is also a
costly, time-consuming method that in the end, does not definitively
prove absence of the species.

The level of incidental take is more easily monitored using the spatial
extent of potential habitat affected by the proposed action. Based on an
average annual timber harvest of 1,050 ac (425 ha) completed on the HMNF
in the potential Indiana bat range over the past 10 years (USDAFS
2003a), 3,150 ac (1,275 ha) of potential Indiana bat habitat may be
harvested for the duration of this proposed action. The HMNF estimates
that 2,648 ac (1,071 ha) of habitat within the potential Indiana bat
range on the HMNF may be burned for fire management or wildlife habitat
management activities for the duration of this proposed action (Rex
Ennis, Joe Kelly, HMNF, pers. comm. 2003). The best scientific and
commercial data available indicates that there may be as many as 65
Indiana bats present on potentially 441,214 ac (178,554 ha) within the
boundaries of the HMNF. However, Indiana bats are not randomly
distributed throughout the potential habitat area, but rather are more
likely to occur in areas that provide optimal habitat for the particular
season of year. Although only a small fraction of the available habitat
will be harvested as a result of the proposed action, it is possible
that up to 65 bats could be incidentally taken. Therefore, this
incidental take statement anticipates the taking of up to 65 Indiana
bats associated with the harvesting 3,150 ac (1,275 ha) and the
prescribed burning of 2,648 ac (1,071 ha) of habitat within the
potential Indiana bat range on the HMNF for the duration of the proposed
action. Project acres treated during the hibernation period or cleared
through surveys outside of the hibernation period through negative mist
net results do not count against the annual allowable acres exempted
under the programmatic incidental take statement.

Any future actions completed under the LRMP that may adversely affect
the Indiana bat will require section 7 formal consultation. These
consultations will proceed using the procedures outlined in the
"Programmatic Consultation Approach" section in the accompanying Opinion
(page 4). A Level 2 biological opinion will be written and appended to
this Opinion for each project that may adversely affect the Indiana bat.
During this Level 2 consultation, project-specific incidental take, as
well the cumulative amount of take (i.e., acres of habitat harvested)
pursuant to implementation of the LRMP that has occurred, will be
assessed. Section 9 exemption under the terms of sections 7(b)(4) and
7(o)(2) of the Act will be granted, if appropriate. In these future
incidental take statements, reasonable and prudent measures and terms
and conditions to minimize the effect of any incidental take that may
result will be developed and applied, as appropriate.

######## Effect of Take

In the accompanying Opinion, we determined that the proposed action is
not likely to jeopardize the continued existence of the Indiana bat or
destroy or adversely modify its critical habitat. Therefore, we have
determined that the level of anticipated incidental take associated with
the actions completed under the LRMP is not likely to jeopardize the
Indiana bat. As further explained in the accompanying Opinion, 1) only
an extremely small population of Indiana bats are known occupy the HMNF,
2) this small population occurs on the northern periphery of the range
of Indiana bat, and 3) the population represents less than one percent
(0.017 percent) of the total range-wide population of Indiana bats.
Therefore, loss of all 65 Indiana bats potentially present in the action
area is not likely to appreciably reduce the likelihood of survival and
recovery of Indiana bat.

######## Reasonable and Prudent Measures

We cannot exempt incidental take at the plan level consultation (Level
1). We believe, however, that the following Reasonable and Prudent
Measures will be applied to some project level consultations (Level 2)
in the future to minimize the effect of incidental take that may result
from such projects, where appropriate on a project-by-project basis.

-   Reduce the potential to impact the Indiana bat in areas of the HMNF
    where it is most likely to occur. Such areas include, but are not
    limited to, the TMZ and forest stands within the range of the
    species on the HMNF that most likely provide optimal summer
    reproductive habitat.

We believe that, where required on a project-by-project basis, the
reasonable and prudent measure outlined above will significantly reduce
the impacts of incidental take of Indiana bats on the HMNF.

######## Terms and Conditions

In order to be exempt from the prohibitions of section 9 of the Act, the
HMNF must comply with the following terms and conditions which implement
the reasonable and prudent measure described above. In order to reduce
the potential to impact the Indiana bat in areas of the HMNF where it is
most likely to occur, the following terms and conditions may be applied
on a project-by-project basis. The applicability of each term and
condition will be determined based on the technical requirements and
biological characteristics of individual projects. Where required, these
terms and conditions are non-discretionary.

1.  Protect spring staging and fall swarming habitat in the Tippy Dam
    Management Zone, an area of five-mile radius centered on Tippy Dam.
    Vegetation management and prescribed fire are to be conducted, as
    feasible and prudent, outside the spring staging period from May 1
    to June 15, and the fall swarming period September 1 to October 20.

2.  Protect Indiana bat habitat within the TMZ by establishing
    management area prescriptions that emphasize Indiana bat habitat and
    allow for activities compatible with Indiana bat management.

3.  Within the species range on the HMNF, protect optimal summer
    maternity habitat and maternity sites. Optimal summer maternity
    habitat will be defined by the following factors:

-   Number of potential roost trees.

-   Availability or proximity of water sources.

-   Availability or proximity of foraging habitat.

-   Amount of ground cover.

-   Amount of canopy closure.

> It is difficult to provide a definitive and universal quantification
> of these characteristics to classify optimal maternity habitat in any
> given portion of the species' range.
>
> The quality of summer habitat may be more meaningfully classified by
> evaluating a combination of these characteristics on a
> project-by-project basis. For example, a hypothetical timber stand
> with 3 potential roost trees, no available water sources, minimal
> foraging habitat, dense ground cover, and 90 percent canopy closure
> may be deemed poor quality habitat. A hypothetical stand with 18
> potential roost trees, plentiful water sources and foraging habitat,
> little ground cover, and an open canopy may be deemed high quality and
> thus optimal maternity habitat. In this manner, the stand\'s
> characteristics in combination with the best professional judgment may
> be used to determine the habitat quality.

a\) In optimal summer maternity habitat, conduct vegetation management
and prescribed fire, as feasible and prudent, outside summer maternity
period from May 1 to August 31.

> b\) In optimal summer maternity habitat, individual projects may
> proceed during the summer maternity period if surveyed for Indiana
> bats, according to protocols established by the Service, prior to
> project implementation.
>
> 1\. If a reproductive female Indiana bat is found, postpone project
> activities that may affect Indiana bats to outside of the summer
> maternity period.
>
> 2\. If no Indiana bats or male or non-reproductive female Indiana bats
> are found, the project may proceed using the established conservation
> measures and operating procedures committed to in the biological
> assessment. Mist netting results are valid for a 3-year period only.
> If project has not been completed within this timeframe, a new survey
> will be required.

The appropriateness of this term and condition will be evaluated by the
Service, in coordination with the HMNF, on project-by-project basis
considering the timing, location, and habitat quality of the proposed
harvests.

######## Requirements for Monitoring and Reporting of Incidental Take of Indiana Bats

Federal agencies have a continuing duty to monitor the impacts of
incidental take resulting from their activities \[50 CFR 402.14(i)(3)\].
In doing so, the Federal agency must report the progress of the action
and its impact on the species to the Service as specified below.

1.  Supply the Service with an annual report, due by January 31 of each
    following year, that specifies:

    a.  the amount of suitable habitat harvested in the current year and
        the total harvested since issuance of the Opinion,

    b.  progress and results of any terms and conditions that were
        required, identified by project, and

    c.  the number of live or dead Indiana bats encountered.

2.  Care must be taken in handling dead bat specimens that are found on
    the HMNF to preserve biological material in the best possible
    condition.

3.  Any dead specimens found should be placed in plastic bag and
    refrigerated as soon as possible following discovery.

4.  The finding of any dead specimen should be reported immediately to
    the Service's East Lansing Field Office.

We anticipate the taking of up to 65 Indiana bats associated with
harvesting 3,150 ac (1,275 ha) and the prescribed burning of 2,648 ac
(1,071 ha) of potential Indiana bat habitat on the HMNF is reasonably
certain to occur as a result of the proposed action. The reasonable and
prudent measures, with their implementing terms and conditions, are
designed to minimize the impact of incidental take that might otherwise
result from the proposed action. If, during the course of the action,
this level of incidental take is exceeded, such incidental take
represents new information requiring reinitiation of consultation and
review of the reasonable and prudent measures provided. The Federal
agency must immediately provide an explanation of the causes of the
taking and review with the Service the need for possible modification of
the reasonable and prudent measures.

Conservation Recommendations

Section 7(a)(1) of the Act directs Federal agencies to utilize their
authorities to further the purposes of the Act by carrying out
conservation programs for the benefit of endangered and threatened
species. Conservation Recommendations are discretionary agency
activities to minimize or avoid adverse effects of a proposed action on
listed species or critical habitat, to help implement recovery plans, or
to develop information.

We believe that the HMNF has already initiated or participated in
important efforts to protect, manage, and increase our understanding of
the Indiana bat, including their commitment to implement the
Conservation Measures in the proposed action. We offer the following
Conservation Recommendations to further expand the knowledge of this
species, and help better manage for the Indiana bat in Michigan.

-   For the upcoming revision of the LRMP, perform surveys concentrated
    in the potential range of the Indiana bat on the HMNF, including the
    TMZ, to further evaluate and document the this species' presence (or
    lack thereof ) during the summer reproductive and migratory periods.
    This information should help the Service and the HMNF better
    understand the status of the species in the action area in
    preparation for the upcoming section 7 consultation for the LRMP
    revision.

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-   If a female Indiana bat is found during surveys, conduct a radio
    telemetry study to determine the location of the maternity roost.
    Upon location of the maternity roost, coordinate with the Service in
    the establishment of a protection zone around the colony. This
    information would be valuable in managing for the species on the
    HMNF.

-   If a male Indiana bat is found during surveys, conduct a radio
    telemetry study to evaluate the habitat use (i.e., roosting trees
    and foraging). This information would be valuable in managing for
    the species on the HMNF.

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-   Periodically evaluate the utility and possibility of HMNF funding of
    increased monitoring of the Indiana bat population that hibernates
    in Tippy Dam from a 5-year to a 2-year schedule, per recommendations
    in Kurta 2002.

-   Design an Indiana bat management plan that 1) examines the spatial
    organization and extent of optimal Indiana bat habitat on the
    HMNF, 2) outlines an extent and appropriate spatial arrangement for
    optimal Indiana bat habitat, and 3) plans management activities to
    maintain this habitat arrangement through time.

The Service recognizes that these Conservation Recommendations may
require long-term efforts by the HMNF and does not expect their
implementation to be confined to or completed within the time period of
this consultation. In order for the Service to be kept informed of
actions minimizing or avoiding adverse effects or benefiting listed
species or their habitats, we request notification of the implementation
of any conservation recommendations.

**Karner Blue Butterfly**

Status of the species and critical habitat

This section presents the biological or ecological information relevant
to formulating the Opinion. The purpose is to provide the appropriate
information on the species= life history, its habitat and its
[range-wide]{.underline} distribution and conservation status for
analyses in later sections. This section also documents the effects of
all past human and natural activities or events that have led to the
current status of the species.

[Species Description]{.underline}

The Karner blue butterfly (*Lycaeides melissa samuelis*) is small and
silvery, with a wingspan of about 2.5 cm (1 in). The forewing length of
the adult is 1.2 to 1.4 cm (0.47 to 0.55 in) for males and 1.4 to 1.6 cm
(0.55 to 0.62 in) for females. The dorsal side of the wing of the male
is violet-silvery blue with a black margin and a white-fringed edge. The
upper side of female wings range from dull violet to bright purplish
blue near the body and central portion of the wings, while the remainder
of the wing ranges from light to dark gray-brown, with marginal orange
crescents typically restricted to the outer edges of the hind wing. Both
sexes are grayish fawn to pearly gray in color on the ventral surface of
the wings with several rows of black spots on the inner portions. Near
the margins of the underside of both wings are a line of orange
crescents and metallic spots. The black terminal line along the margin
of the hind wing is usually continuous (Klots 1979; Nabokov 1944). Many
other subspecies of *Lycaeides melissa* resemble the Karner blue
butterfly, and male genitalia is the most reliable character for
distinguishing adult Karner blue butterflies from other subspecies (and
species) (Nabokov 1944, 1949).

The eggs of Karner blue are tiny (approx. 0.7 mm in diameter), radially
symmetrical, somewhat flattened, and pale greenish-white in color (Dirig
1994). The surface is deeply reticulated with a fine geometric pattern
(Scudder 1889). Larvae are a pea-green color, pubescent, and dorsally
flattened, with a brown-black to black head capsule. The head is often
not visible as it is tucked under the body. Older larvae have pale green
(to white) lateral stripes, and a dark green longitudinal stripe
dorsally. In pre-pupal larvae the lateral stripes become less distinct
and the color becomes a duller green. Pupae are bright green and smooth,
changing to a light tan with hints of purple shortly before emergence.

# [Life History]{.underline}

The Karner blue butterfly is bivoltine, completing two generations per
year. First brood larvae hatch from overwintered eggs in mid- to late
April and begin feeding on wild lupine[^1] *(Lupinus perennis*). Wild
lupine is the only known larval food source. The larvae pass through
four instars (Savignano 1990), feeding for approximately three to four
weeks before pupation in late May to early June. Karner blues are known
to pupate in leaf litter, on stems and twigs, and occasionally on lupine
leaves (Dirig 1976; Cyan and Dirig 1978). Pupation generally lasts seven
to eleven days, with adults emerging in late May through mid-June. Peak
flight for males usually precedes peak flight for females by a couple of
days. Adults are believed to live an average of four to five days, but
can live as long as two to three weeks. First flight adult females lay
their eggs primarily on lupine plants, often singly on leaves, petioles,
stems, or occasionally on other plants or leaf litter close to lupine
plants.

Second brood eggs hatch in five to ten days, and larvae can be found
feeding on wild lupine leaves and flowers from early June through late
July. Typically, a larva can survive on one large lupine stem, however,
it moves from leaf to leaf on the lupine stem, often returning to leaves
fed on during earlier instars, and it may even move to other lupine
stems (Lane 1999b). Larvae are found often on the lower parts of the
stems and petioles. Ants typically tend both first and second brood
larvae. During midday on hot days tending may be reduced.

Second brood adults begin to appear in early to mid-July and fly until
mid-August. Flight phenology may be delayed because of cool wet summers
and result in an adult flight period lasting through late August (Cathy
Bleser, pers. comm., 1995 as cited in USFWS 2001c; Cynthia Lane, pers.
comm., 1995 as cited in USFWS 2001c). The peak flight period usually
lasts one to two weeks. Generally, there are about three to four times
as many adults in the second brood as compared with the first brood
(Schweitzer 1994b), but exceptionally poor years can occur where the
second brood is not larger than the first brood. The first brood is
usually smaller, probably because of high overwintering mortality of
eggs, the inability of larvae to find lupine in the spring, or greater
oviposition success of first flight females.

Karner blue adults are diurnal and initiate flight between 8:00-9:00
a.m. and continue until about 7:00 p.m., a longer flight period than
most butterflies. Adult activity decreases in very hot weather, at
temperatures lower than 75^o^ F (24^o^ C), during heavy to moderate
rains, or during extremely windy conditions.

# [Habitat Use and Requirements]{.underline}

Throughout its range, the Karner blue butterfly was historically
associated with landscapes composed of sandy soils, which supported oak
or oak-pine savanna barrens and savanna ecosystems. It is now associated
with remnant barrens and savannas, highway and powerline right-of-ways,
gaps within forest stands, young forest stands, forest roads and trails,
airports, and military camps that occur on the landscapes previously
occupied by native barrens and savannas. Almost all of these
contemporary habitats are described as having a broken or scattered tree
canopy that varies within habitats from zero to between 50 and 80
percent canopy cover, with grasses and forbs common in the openings. The
habitats have lupine and other nectar plants for adult feeding, critical
microhabitats, and attendant ants. The stature and spacing of trees in
native savannas is somewhat variable, reflecting differences in soils,
topography and climate (Nuzzo 1986), and the distribution of trees in
contemporary habitat is similarly diverse. Soils are typically
well-drained sandy soils which influences both plant growth and
disturbance frequency. These conditions are generally wet enough to grow
trees but dry enough to sustain periodic fires (Breining 1993).
Topography is diverse and includes flat glacial lake beds, dune and
swale lake shores, and steep, dissected hills.

Karner blue butterfly larvae feed exclusively on wild lupine. Lupine is
an early successional species adapted to survive on dry, relatively
infertile soils. Plants in dense shade rarely flower. All available
evidence suggests that lupine thrives on nitrogen-poor soils in partial-
to open-canopied areas, and is suppressed by shade; it may not be
competitive with other plants on nitrogen-rich soils, and
phosphorus-poor soils. Several species of pines, oaks, and shrubby
vegetation are adapted to the same soils and habitat as lupine (Haney
and Apfelbaum 1990; Nuzzo 1986), and without disturbance, they will
close the canopy, shading and suppressing lupine (Apfelbaum and Haney
1991; Haney and Apfelbaum 1990). Consequently, disturbances that reduce
tree and shrub canopy cover are necessary for lupine to persist. Several
disturbances are beneficial for renewing lupine habitat, including
prescribed fire, tree removal, and a variety of other methods to kill
trees and shrubs.

Adults need adequate nectar resources and will utilize a wide variety of
native and introduced flowering plants (Rabe 2001). In Michigan, Karner
blue butterflies frequently nectar on lupine and dewberry (*Rubus* spp.)
during the spring brood, and horse mint (*Monarda punctata*), butterfly
weed (*Asclepias tuberosa*), spotted knapweed (*Centaurea maculosa*),
and blazing star (*Liatris aspera*) during the summer brood (Rabe 2001).
In addition to nectaring, males and females sip at moist earth
(mud-puddling) and human perspiration, and males sip at animal droppings
(Swengel and Swengel 1993). Adults may be obtaining sodium or other
substances from this behavior. In addition to wild lupine, the Karner
blue butterfly requires tall grass for late afternoon basking and
overnight roosting, some shading vegetation to prevent overheating, and
a source of water.

Adults and larvae use a variety of subhabitats created by variation in
tree canopy and shrub cover, topography, and soil moisture. Mating,
roosting, and adult feeding take place primarily in open-canopied areas.
Oviposition occurs in many types of subhabitats, but larval growth and
survival may be best in partial- to closed-canopy areas. It is important
for butterflies to be able to move easily between subhabitat types, as
optimal subhabitat types differ for adults and larvae. Small-scale
variation in topography and soil moisture could be beneficial to Karner
blue butterfly. A highly variable microtopography creates a highly
variable thermal environment, plant community, and canopy structure.
Variation in soil moisture will also contribute to variation in plant
community and canopy structure. Variation in plant community and canopy
could be beneficial to the Karner blue in the long-term because in hot,
dry years, the species can be found using shady, moist subhabitats,
while in cool years, they are more strongly associated with sunny and
partially sunny subhabitats.

# [Population Dynamics]{.underline}

Literature on the historic distribution of the Karner blue butterfly
suggests that this species occurred as shifting clusters of populations
distributed across a vast fire-swept landscape covering thousands of
acres. While the fires resulted in localized extirpations, vegetative
succession following these fires maintained suitable habitat and allowed
rapid population expansion or repopulation (Schweitzer 1989).

The Karner blue butterfly is an example of a species for which suitable
habitat occurs in relatively small areas (or patches) distributed over
larger areas (Zaremba 1991). Like other species whose habitat occurs in
patches rather than large continuous tracts of land, populations of the
Karner blue butterfly exist as dynamic collections of subpopulations
that are interconnected by dispersal. Collectively these interconnected
subpopulations make up a metapopulation. Metapopulations continually
shift in distribution across the landscape as habitat patches change
from suitable to unsuitable habitat. This change in habitat suitability
is due to varying stages of disturbance and succession (Givnish et al.
l988; Schweitzer l989). No one theoretical metapopulation structure is
advocated for the Karner blue butterfly; rather, the recovery plan
focuses on those factors that would restore healthy metapopulations
including sufficient suitable habitat, connectivity of subpopulations,
and management. Persistence of metapopulations is governed by the
balance between extirpation of subpopulations and recolonization of
unoccupied suitable habitat sites.

To preserve species with patchy distributions, it is necessary to
maintain: (1) existing patches of suitable habitat, (2) the processes
that create new habitat patches, and (3) the corridors that allow a
species to migrate between habitat patches (Harrison et al. 1988). Open
linear areas such as road and railroad rights-of-way, utility corridors,
and forest roads and trails can serve as dispersal corridors for the
Karner blue butterfly, allowing them to recolonize or colonize wild
lupine patches. Research has shown dispersal of the Karner blue
butterfly to range from about 600 ft (183 m) to about 2 mi (3.2 m).

# [Threats]{.underline}

The major threats to survival of the Karner blue butterfly in native
habitats are succession to woodlands and forests, and management for
other wildlife and natural areas goals that do not take into account the
needs of the butterfly, such as restoration and maintenance of native
vegetation, or that encourage use by game animals and recreationists.
Human use of these native habitats and adjacent developed habitats has
often resulted in suppression of disturbance and decline of Karner blue
butterfly populations. Although wildlife and other management goals are
often concordant with enhancement of Karner blue, too vigorous a pursuit
of these other goals can be detrimental to the butterfly.

Karner blue butterfly inhabits several non-native habitats, including
some silvicultural areas, mowed rights-of-way, and roadside edges. Some
of these habitats are being lost to more intensive development
pressures. Some silvicultural habitats that are suitable for Karner
blues are being converted to more intensive silvicultural uses that may
be less compatible and to incompatible residential and commercial uses.
Along roadsides, uniform, exotic vegetation has replaced native
vegetation. Roads can also fragment habitats and cause a portion of the
population to be threatened by vehicle traffic, while adults are
congregating at water sources or dispersing within these areas.

Improper timing of management practices can also threaten Karner blue
butterflies, such as timing of pest control, timing of mowing, and
poorly planned prescribed fires (USDAFS 1999). Improper timing or poorly
located herbicide treatment can kill or otherwise suppress lupine and
other nectar-producing plants, thereby affecting the Karner blue
butterfly. Mowing between late spring and early summer can damage or
reduce lupine, eliminating food for larvae. Mowing can also directly
crush eggs or larvae and decrease nectar sources. Poor timing and the
improper use of fire in Karner blue butterfly habitat; severe fires at
frequent intervals or burning during larval, first flight and second
flight periods; or burning a majority of the habitat can be detrimental.

A variety of natural predators, such as spiders, predaceous insects, and
even deer can cause direct mortality by ingestion of larvae. Heavy
mammalian browsing on lupine has indirect effects on habitat because
fewer lupines are available for larvae and adults (USDAFS 1999).

Collection of the Karner blue butterfly is not currently considered to
be a significant factor in population declines in most areas. Stochastic
events, such as unusual weather, can detrimentally affect Karner blue
populations. Large-scale wildfire events, although infrequent, could
destroy a large metapopulation.

[Range-wide Status and Distribution of the Species]{.underline}

The Karner blue butterfly was listed as endangered on December 14, 1992
(57 FR 59236). No critical habitat has been designated for this species.
Historically, the Karner blue occurred in a narrow geographic area that
extended from eastern Minnesota, across portions of Iowa, Wisconsin,
Illinois, Indiana, Massachusetts, Michigan, Ohio, Pennsylvania, New
York, New Hampshire, Maine, and the province of Ontario, Canada. Over
the past 100 years, Karner blue butterfly populations have declined
significantly throughout the species' range. It is now believed
extirpated from Ontario, Canada, Maine, Massachusetts, Pennsylvania,
Iowa, and Illinois. Currently, the Karner blue is extant in seven
states: Minnesota, Wisconsin, Indiana, Michigan, Ohio, New York, and New
Hampshire. In 1998, it was reintroduced to Ohio as part of a 5-year
reintroduction program. Wisconsin and Michigan have the largest number
of local populations with the greatest numbers of individuals.

A draft recovery plan notice was published on December 5, 2001 (66 FR
63248). In general, the recovery strategy for this species is to
perpetuate viable metapopulations of the Karner blue butterfly in the
major ecological regions throughout its geographic range. Thirteen
ecological regions are identified (called \"recovery units\" \[RUs\]),
based on known variation in physiography, climate, and vegetation, and
potential geographic genetic variation in Karner blue populations.
Wisconsin and western Michigan now harbor the largest metapopulations of
Karner blue that occur in the greatest amount of area in the geographic
range of the species. The goal for these areas is to stabilize and
maintain, and in some cases expand, the populations that now occur.
Because of the significance of these two states as the centers of Karner
blue abundance, there are more RUs and more metapopulations established
in these areas than in other parts of the range. These multiple RUs
should protect the species against wide-scale declines in either state.

The RUs in New Hampshire, New York, Minnesota, parts of Indiana, and
possibly parts of Michigan, have populations that are at risk of
extinction. The goal for these areas is to protect existing habitat
(both occupied and unoccupied sites) and to increase, stabilize, and
maintain the populations. Fewer metapopulations are established in these
RUs. Finally, six potential RUs are identified. These potential RUs are
not essential for recovery, but the species would benefit if viable
metapopulations were recovered in these RUs.

The recovery actions identified in the draft plan are (USFWS 2001c):

1.  Protect and manage the Karner blue and its habitat to perpetuate
    viable metapopulations.

2.  Evaluate and implement translocation where appropriate.

3.  Develop range-wide and regional management guidelines.

4.  Develop and implement information and education program.

5.  Collect important ecological data on Karner blue and associated
    habitats.

6.  Review and track recovery progress.

Full recovery of the Karner blue butterfly is anticipated to require at
least 20 years, until about 2020.

The following is a brief review of survey efforts and the distribution
of the Karner blue butterfly in each state where RUs have been
established via this recovery planning process.

*New Hampshire (Merrimack/Nashua River System RU)*

The only remaining occurrence of the Karner blue in New England is in
the Concord Pine Barrens in Concord, New Hampshire. Two very small
subpopulations occur on relatively small areas along a powerline
right-of-way (Main Site) and in the grassy safeways of the Concord
Airport. This population has severely declined in number from
2,000-3,000 estimated butterflies in 1983 (Helmbolt and Amaral 1994), to
219 butterflies in 1991 and to less than 50 in 1995 where subsequent
numbers have remained below 50, making this site at extreme risk for
extinction (Peteroy 1998).

*New York (Glacial Lake Albany RU)*

The Karner blue butterfly was once common in New York (Cryan and Dirig
1978; Dirig 1994). In the Albany area alone, the Karner blue probably
inhabited most of the 25,000 acres of the original Albany Pine Bush, the
area from which Karner blues were first described. The Albany Pine Bush
area once supported an estimated 17,500 butterflies in one 300 acre site
during 1978 (Sommers and Nye 1994). By the mid-1980\'s, however, much of
the Albany Pine Bush had been destroyed by development, and degraded by
introduction of non-Pine Bush species, and natural succession. By 1988,
only 2,500 acres of the original 25,000 acres remained (Givnish et al.
1988), and loss of habitat has continued. Current populations number
only in the several hundreds (Schweitzer 1994a), and existing habitat
continues to undergo succession and degradation.

Additional Karner blue butterfly sites occur in the Saratoga Sandplains
and Saratoga West areas north of Albany. The majority of the sites in
these areas support less than 100 butterflies. The largest population of
the butterfly is at the Saratoga Airport, and is estimated to support
10,000 Karner blue butterflies.

Currently the New York Department of Environmental Conservation (NY DEC)
has identified 70 Karner blue localities and 55 subpopulations in the
Glacial Lake Albany RU. Of those, 45 subpopulations are within the 3
metapopulation goal areas; 8 in the Albany Pine Bush, 28 in Saratoga
Sandplains, and 9 in Saratoga West (Kathy O\'Brien, NY DEC, pers. comm.,
1997, 1999 as cited in USFWS 2001c).

*Indiana (Indiana Dunes RU)*

Historically, the Karner blue was reported from eight counties in
Indiana. In 1990, Karner blue butterflies were identified at 10 sites
out of 35 potential sites surveyed (Martin 1994). Two population
clusters were identified within two counties (Lake and Porter), the
majority of which was associated with medium to high quality Karner blue
habitat (Martin 1994). The early surveys in Porter County (which
includes the National Park Service\'s Indiana Dunes National Lakeshore
\[IDNL\]), identified between 1,000 and 10,000 second brood Karner blue
adults (Baker 1994). In Lake County, at the IDNL, several thousand
second brood adults were estimated (Schweitzer 1992) and in other Lake
County sites the subpopulations likely number between 100-500 (John
Shuey, TNC, pers. comm., 1998 as cited in USFWS 2001c). Several
subpopulations occur in West Gary (Lake County) associated with a
remnant dune and swale complex.

Currently it is estimated that 17 subpopulations of Karner blue
butterflies (using the 200 meter separation criteria) occur at IDNL
(Ralph Grundel and Noel Pavlovic, USGS, pers. comm., 1998 as cited in
USFWS 2001c). In West Gary, about 21 tracts clustered into 11 individual
preserves and management areas have been identified as potentially able
to at least periodically support the Karner blue (John. Shuey, undated
as cited in USFWS 2001c). Karner blue butterflies have been documented
on four of these tracts which comprise the only extant subpopulations of
Karner blue butterflies in West Gary (John Shuey, pers. comm., 1998 as
cited in USFWS 2001c).

*Wisconsin (Morainal Sands, Glacial Lake Wisconsin, West Central
Driftless, Wisconsin*

*Escarpment and Sandstone Plateau and Superior Outwash RUs)*

The Wisconsin DNR began systematic statewide surveys for the Karner blue
in 1990 including surveys of 33 of the 36 historic butterfly sites.
Initial surveys by Bleser (1993) reported that only 11 of the 33
historical sites supported Karner blues, and also identified 23
previously unknown sites. Additional survey efforts were subsequently
conducted by the Wisconsin DNR, the Service (Trick 1993, Necedah
National Wildlife Refuge), Fort McCoy (Leach 1993), and other biologists
(Swengel 1994, Bidwell 1996). By 1993, there were an estimated 150 to
170 discrete Karner blue sites (Baker 1994). In recent years, additional
surveying has been done by partners to the Wisconsin Statewide Habitat
Conservation Plan including county forest departments, the private
forest industry, and utility companies. County and state foresters in
Wisconsin routinely survey for the butterfly prior to conducting
forestry activities in an effort to avoid adverse impacts to the Karner
blue.

As of May 1998, Wisconsin DNR\'s Natural Heritage Inventory data base
noted 280 subpopulations (using a 200 meter separation criteria) of the
butterfly in Wisconsin (Cathy Bleser, WDNR, pers. comm. 1998 as cited in
USFWS 2001c). Most of the subpopulations can be lumped into about 15
large population areas, many of which are found on sizable contiguous
acreages in central and northwest Wisconsin (WDNR 2000). Wisconsin
supports the largest and most widespread Karner blue butterfly
population rangewide. At least one sizable population occurs in each of
the five Wisconsin RUs with the West Central Driftless RU believed to
support the largest populations (Cathy Carnes, USFWS, pers. comm. 1998
as cited in USFWS 2001c). The largest Karner blue populations are found
at Necedah NWR, Fort McCoy, Glacial Lake Grantsburg State Wildlife Area,
Eau Claire County Forest, Jackson County Forest, Black River State
Forest, and on a complex of state and private lands in Portage County.

*Minnesota (Paleozoic Plateau RU)*

Karner blue butterflies currently only occur at the Whitewater Wildlife
Management Area (WMA) in southeastern Minnesota. Two to possibly five
small local populations are located in a 1,770 ac (716 ha) expanse of
poor to high quality oak savanna at the WMA.

Surveys conducted at two sites since 1992 (the "Cuthrell" and "Historic"
sites), recorded peak second flight counts ranging from 9 to 64
butterflies (mean = 22.9) at Cuthrell; and from 2 to 8 butterflies (mean
= 0.7) at Historic. A translocation project was started in 1999 to
reintroduce Karner blues to Lupine Valley, an historic Karner blue
butterfly site at the Whitewater WMA (Lane 1999a).

There are other locations in the southeastern and east-central part of
the state that formerly supported lupine and the Karner blue butterfly,
such as the Cedar Creek Natural History Area. Surveys of 50 potentially
suitable sites in Minnesota (oak savanna with sandy soil and lupine)
revealed that many lupine sites were no longer present and that Karner
blue butterflies had been extirpated from the Cedar Creek site (Lane and
Dana 1994).

*Michigan: (Ionia, Allegan, Newago and Muskegon RUs)*

The Karner blue butterfly is currently found in 10 of the 11 Michigan
counties in which it historically occurred (Figure 4). Surveys by
Wilsmann (1994) noted that the Karner blue populations were reduced and
highly fragmented. The majority of the Karner blue butterfly sites occur
on state land (Flat River and Allegan State Game Areas \[SGAs\]) in the
Ionia and Allegan RUs, and on Federal lands (HMNF) in the Newaygo and
Muskegon RUs.

Survey efforts during 1994-1996 by the Michigan Natural Features
Inventory of 65 areas within the Ionia RU on public and private lands
revealed nine extant Karner blue sites, eight within the Flat River SGA;
with the exception of one site, all supported low numbers of butterflies
(Cuthrell and Rabe 1996). Based on data through 1998, eight
subpopulations (defined as separated by 200 meters of unsuitable
habitat) have been identified at the Flat River SGA and 23 at the
Allegan SGA. In addition, two other subpopulations occur on private
property; one near each of these state properties (Daria Hyde, MNFI,
pers. comm. 1998 from USFWS 2001c). The Ionia RU is the least well
surveyed of all the Michigan RUs with much of the area outside of the
Flat River SGA developed for agriculture and other uses (Baker 1994,
Wilsmann 1994). The most sizable populations in the state occur at
Allegan and Flat River SGAs and the HMNF (Jennifer Fettinger, MNFI,
pers. comm. 2002 from USFWS 2001c).

As of the fall of 2002, Michigan, excluding the Allegan SGA, supported
158 subpopulations of Karner blues (based on a 200 meter separation
criteria) (Jennifer Fettinger, MNFI, pers. comm. 2002 as cited in USFWS
2001c). As noted above, in 1998, Allegan SGA supported 23 subpopulations
of Karner blues; this number is currently under revision to reflect 2002
numbers.

The majority of Karner blue sites in the Newaygo and Muskegon RUs occur
on the Huron-Manistee NF and are discussed under the "Status of the
Species in the Action Area" section.

![](media/image4.png){width="4.252083333333333in"
height="4.002777777777778in"}

Figure 4. Distribution of the Karner blue butterfly in Michigan (from
USDAFS 2003a).

Environmental Baseline

This section describes the species status and trend information within
the [action area]{.underline}. It also includes State, tribal, local,
private actions already affecting the species or that will occur
contemporaneously with the proposed action. Unrelated Federal actions
that have completed formal or informal consultation are also included in
the environmental baseline.

######## Status of the Species within the Action Area

The Karner blue butterfly is found in the HMNF (Manistee NF), in the
Newaygo and Muskegon Recovery Units. The Newaygo RU is located in west
central Michigan, in six counties (Mason, Lake, Oceana, Newaygo,
Mecosta, and Montcalm), and is associated with oak or white pine barrens
scattered throughout the Newaygo outwash plain and sandy terminal
moraines. It corresponds to ecoregion subsection IV.3 as described in
Albert (1995). Topography is relatively flat and the climate is colder
and more variable than the other Michigan RUs. Oaks and pines dominate
the sandy soils. The Muskegon RU is located in west central Michigan
along Lake Michigan, in four counties (Mason, Oceana, Newaygo, and
Muskegon), and is associated with oak or white pine barrens scattered
through the Manistee sand lake plain. It corresponds to ecoregion
subsection IV.4 as described in Albert (1995). Climate is moderated by
Lake Michigan, but is colder and more variable than other RUs in
Michigan. There is considerable topographic relief in some parts of this
RU.

Most known sites for the Karner blue butterfly on the HMNF are strongly
associated with the HMNF's Land Type Association 1 (LTA 1), which is
classified as Sandy Outwash Plains, characterized by poorly developed,
excessively well-drained sands in the mesic to frigid soil temperature
zone. Landscape scale habitat is found in MAs 2.1, 4.2, 4.3, 4.4, 6.1,
6.2, and 8.1, with most occurring in area 4.2, "Roaded Natural Sandy
Plains and Hills."

Within the action area, approximately 13,396 acres (5,421 ha) of the
HMNF and about 784 acres (317 ha) of private land were surveyed for the
presence of Karner blue butterflies from 1989 to 2001. From these
surveys, approximately 263 Karner blue butterfly-occupied areas have
been found on HMNF lands and 56 occupied areas were found on private
lands. These occupied areas comprise 2,026 ac (820 ha) of HMNF land and
441 ac (178 ha) of private ownership (Joe Kelly, HMNF, pers. comm.
2003).

The areas of occupied and potential habitat on the HMNF have been
segregated into four (Central, Southeast, Southwest, and North) Karner
blue butterfly Management Areas (KBBMA) distributed in the two RUs as
follows: Central and Southeast KBBMAs in the Newaygo RU, Southwest and
North KBBMAs in the Muskegon RU. The KBBMAs collectively contain 24
Management Units (KBBMU) delineated based upon concentrated areas of
LTA 1. These encompass all the areas of occupied or potential Karner
blue butterfly habitats on the HMNF. The four KBBMAs are separated by
habitat that is unsuitable for Karner blue butterflies, Connectivity or
the potential for dispersal between the four KBBMAs is currently
unknown.

Karner blue butterflies occupy primarily five of the KBBMUs: Otto
(Southwest KBBMA), Burns Lake (Southwest KBBMA), M-37 (Central KBBMA),
Croton (Southeast KBBMA), and White River (Southwest KBBMA) (USDAFS
1994, USDAFS 2002b). The HMNF currently monitors the Karner blue
butterflies in these units using presence/absence surveys (USDAFS
2003b). While population numbers and trends cannot be determined from
this type of information, they may provide some indication of the
species status. The presence of Karner blue butterflies has appeared to
decline in these units, despite restoration activities (USDAFS 2003b).
The HMNF believes that the following factors may be responsible for the
apparent Karner blue butterfly declines in these units (Joe Kelley,
HMNF, pers. comm. 2003; USDAFS 2003b):

-   Decreased lupine due to drought conditions have resulted from
    several years for below normal precipitation in Michigan. These
    particular Karner blue butterfly units may be more susceptible to
    drought due to soil conditions (e.g., low clay content) which
    inhibits moisture retention.

-   Increased deer browsing of lupine in these Karner blue butterfly
    units.

-   The topography of these units, with low depressional areas,
    increases the occurrence of growing-season frost pockets that may
    damage lupine and other plants.

-   Increased ORV use that may damage lupine or kill individuals

Restoration activities are ongoing in these units, and the HMNF is
monitoring and exploring ways to address these potential threats.

The status of other areas of occupied Karner blue butterfly habitat in
the KBBMAs are also believed to be decreasing due to lack of restoration
activities (Joe Kelley, HMNF, pers. comm. 2003). The primary issue in
these areas is growth of red pines (i.e., in the Otto unit) that were
planted before the Karner blue butterfly was listed. These areas will
eventually shift into mature red pine plantations and will become
unsuitable for Karner blue butterflies if restoration activities do not
occur (USDAFS 2003b).

Given these trends, the continued management, research, and restoration
of Karner blue butterfly habitat will be essential to the species'
survival on the HMNF. Given the appropriate management, there is
sufficient suitable habitat to support viable populations of the Karner
blue butterfly on the HMNF.

######## Factors Affecting The Species Within The Action Area

##### Federal Actions That Have Undergone Prior Section 7 Consultation

-   First Implementation of the LRMP, 1986

The LRMP for the HMNF was first implemented in 1986. The LRMP underwent
formal section 7 consultation; however, the Karner blue butterfly was
not considered because the species was not yet listed as under the Act.
Therefore, the standards and guidelines for management actions provided
no special protection or consideration for the Karner blue butterfly. As
a result, it is possible that this species was adversely affected by
management activities; however, as population status was not known, the
extent of adverse effects is not determinable. Potential adverse effects
most likely occurred as habitat conversion to incompatible uses (e.g.,
roads, trails, red pine plantations) and killing of individuals through
management activities, such as burning or cutting, applied in without
regard to the Karner blue butterfly in occupied habitat.

#### Informal Consultations

Since the listing of the Karner blue butterfly as endangered under the
Act in 1992, the HMNF and other Federal agencies (e.g., FERC) have
consulted with the Service on actions that may affect the Karner blue
butterfly within the action area. We concurred with determinations of
"no effect" or "not likely to adversely affect" for these actions. These
determinations were reached for actions that completely avoided occupied
or suitable Karner blue butterfly habitat, or incorporated of a variety
of protective conservation measures including:

\- Exclude project activities that may adversely affect the Karner blue
butterfly from occupied or potential habitat.

\- Limit burning, harvest, and other potential restoration activities to
habitat that is currently not suitable for or not occupied by the Karner
blue butterfly. These activities would be performed to benefit the
species by creating potential future habitat.

We believe that the use of these conservation and avoidance measures in
each individual project has cumulatively, for all projects, maintained
or improved the status of this species in the action area by reducing
the possibility of take of a Karner blue butterfly and maintaining or
increasing the long-term available habitat on the HMNF.

-   The HMNF Karner Blue Butterfly Management Plan, 1994-1999

In 1992, shortly after the Karner blue butterfly was listed as
endangered, the HMNF began communicating with the Service's East Lansing
Field Office on consultation requirements for Karner blue butterfly
management activities. The management activities described in the
Management Plan included nectar plant planting or propagation, mowing,
cutting, scarification, and burning on occupied sites. On October 13,
1994 the HMNF initiated formal consultation to address the potential
effects of these proposed management activities for the Karner blue
butterfly on the HMNF from 1994 to 1999. During this six-year period,
the HMNF proposed to manage 920 ac (372 ha) for Karner blue butterflies,
of which 606 ac (245 ha) were occupied. Included in the proposed action
were the following conservation measures, intended to reduce the impact
to the butterfly while conducting beneficial management actions:

-   Burn no more than one third of the occupied acreage within any KBBMA
    in a given year.

-   After one-third of the occupied Karner blue butterfly acreage in a
    KBBMA has been burned, no additional burning in the KBBMA will be
    considered for at least 3 years.

-   No more than half of a KBBMA will be treated by any means, including
    prescribed burning, within a given year.

-   Once 50 percent of a KBBMA has been treated, no additional
    treatments will be considered for a minimum of 3 years.

-   No treatments, except for prescribed burning, will occur on occupied
    Karner blue butterfly sites during March 15 and August 15 to
    minimize effects on adults, eggs, and larvae.

-   Pre- and post- burn monitoring of Karner blue butterflies, other
    invertebrates, and plants will take place for at least 3 years after
    a burn.

In its March 28, 1995 biological opinion, we analyzed the potential
effects of the proposed management activities and determined that
implementation of the Management Plan was not likely to jeopardize the
continued existence of the Karner blue butterfly. We determined that the
proposed management activities would likely result in a net benefit to
the Karner blue butterfly by improving habitat conditions and increasing
numbers of butterflies in the action area. Incidental take of eggs,
larvae, and adults was permitted on the basis of total known occupied
acreage affected annually. A total of 580 ac (235 ha) were authorized
for the six year period (see Table 1, page 13, of the March 29, 1995
biological opinion). This biological opinion was amended on June 18,
1998, to increase the amount of incidental take allowed to 651 ac (263
ha). According to a May 23, 2002 letter, only 457 ac (185 ha) were
treated in the 1994-1999 period.

Although the management plan and biological opinion have not officially
been extended past 1999, we have been working with the HMNF to address
and minimize the potential effects of any incidental take resulting from
management activities. As of 2002, a total of 500 ac (202 ha) of Karner
blue butterfly habitat have been managed and restored on the HMNF (Joe
Kelly, HMNF, pers. comm. 2003). Implementation of the Karner blue
butterfly management plan has helped ameliorate the adverse effects of
past management activities and improved the overall status of the
species in the action area.

-   Cooperative Gypsy Moth Suppression Project, Michigan

In 1996, the USFS State and Private Forestry Division formally consulted
on a proposed gypsy moth suppression project for 22,579 ac (9,137 ha) in
Mecosta, Muskegon, Newaygo, and Oceana counties. The proposed action was
to aerially apply the biological insecticide *Bacillus* *thuringiensis*
var. *kurstaki* (Btk) to private and public recreational lands. Many of
the properties proposed for treatment were on non-Federal lands within
the HMNF administrative boundary. The Btk is lethal to Karner blue
butterfly larvae as well as gypsy moth larvae, and if Karner blue
butterflies occurred within a spray block, mortality was expected.

In a May 31, 1996 biological opinion, we analyzed the effects of the
proposed action and determined that the project, as proposed in 1996,
was not likely to jeopardize the continued existence of the Karner blue
butterfly. Survey indicated that the Karner blue butterflies occupied
approximately 20 percent of areas with suitable soil types (LTA 1) on
the HMNF. Therefore, we assumed that Karner blue butterflies could occur
on up to 20 percent of the project treatment acreage within suitable
soil types. Incidental take was authorized for the 20 percent of the
treatment acres with the potential to support the species that may be
occupied; this number was equivalent to 1,097 ac (444 ha). In addition,
the terms and conditions stipulated that no more than 50 percent of any
area known to be occupied by Karner blue butterflies may be treated with
Btk and no area shall be treated in consecutive years. All areas with
lupine were assumed to support Karner blue butterflies (see page 18 of
the May 31, 1996 biological opinion for more details).

Portions of at least two, possibly four, of the proposed treatment
blocks were known to be occupied by the Karner blue butterfly. It is not
known, however, exactly what portion of the suitable habitat that was
authorized for take was actually occupied by the Karner blue butterfly.
It is possible that there were treatment blocks of suitable Karner blue
butterfly habitat that were not occupied, and thus take did not reach
the authorized amount. We expect that some level of take did occur,
however, since there were some areas of known occupied habitat included
in the treatment blocks. Since it is impossible to quantify the actual
amount of take that occurred, it is prudent to assume incidental take
occurred on all authorized 1,097 ac (444 ha), although it was likely
less than this. There are a total of 131,694 ac (53,295 ha) of potential
habitat within the HMNF, based on areas with LTA 1 classification
(USDAFS 2003a). Given the estimated occupancy rate of 20 percent in
potential habitat, we can assume that Karner blue butterflies may occur
on up to 26,338 ac (10,659 ha) within the HMNF. Furthermore, laboratory
studies indicated an approximately 80 percent mortality rate of Karner
blue caterpillars treated with Btk (Herms 1996). It is likely that a
portion of the Karner blue butterflies in a spray block would be pupae,
adults, or eggs and may not be affected by the Btk. Based on this
information, it is

unlikely that any Karner blue butterfly population was eliminated with
any single application of Btk. Thus, the amount of take authorized in
1996 was likely less than 4 percent of the total potential occupied
habitat in the action area, and did not appreciably diminish the
potential long-term survival and recovery of the Karner blue butterfly
in the action area.

In 1999, consultation for this project was reinitiated, as new
information became available. The 1999 gypsy moth suppression project
consultation considered treatment of 5,087 ac (2059 ha) of suitable
Karner blue butterfly habitat in Allegan and Muskegon counties. Most of
the proposed spray blocks with potential to affect the Karner blue
butterfly were private or State lands within or near the HMNF
boundaries. These areas were proposed for treatment with Btk or
Gypcheck^^, a newly developed virus for biological control specific to
gypsy moths, that does not affect Karner blue butterflies. Following
informal consultation, the USFS agreed to apply Gypcheck^^ in place of
Btk on all spray blocks within one mile sections adjacent to sections
with a known Karner blue butterfly occurrence. Using this application
strategy, known occurrences of Karner blue butterfly within proposed
spray blocks would not be sprayed with Btk, and unknown occurrences
within one mile of known occurrences will also be avoided. No known
Karner blue butterfly occurrences were proposed for treatment with Btk;
however, we again believed that unknown occurrences might be sprayed
with Btk and the USFS entered into formal consultation. In the May 6,
1999 biological opinion, we analyzed the effects of the proposed action
and determined that the project was not likely to jeopardize the
continued existence of the Karner blue butterfly. Based on the same
reasoning used in the previous biological opinion, we determined that
unknown Karner blue butterfly occurrences may be present on about 20
percent of the 5087ac (2059 ha) with a soil type suitable for lupine,
and authorized take for no more than 1,017 ac (412 ha).

When the project was continued in 2000, the USFS determined that it was
"not likely to adversely affect" the Karner blue butterfly. In the
previous biological opinions, we concluded that unknown Karner blue
butterfly occurrences may be present on about 20 percent of LTA 1. This
was reconsidered in 2000, however, because further analysis determined
that no data existed to support this conclusion. Based on the following
parts of the USFS 2000 proposed action: 1) all occupied sites and sites
adjacent to occupied sites were treated with Gypcheck^^, which is not
toxic to Karner blue butterflies and 2) none of the Btk treatment areas
were known to have Karner blue butterflies present, no adverse effects
from the project were expected. Based on the best available data, no
known or unknown occurrences of the Karner blue butterfly were likely to
be adversely affected by the proposed action and thus, it was not
possible to identify any incidental take of the species that was
reasonably certain to occur. In addition, based on this analysis, it is
unlikely that there were any adverse effects from this proposed action
in 1999, and the incidental take authorized for 1,017 ac (412 ha) was
not likely realized. In a May 10, 2000 letter, we concurred with the
"not likely to adversely affect" determination made by the USFS and
rescinded the May 6, 1999 biological opinion.

Informal consultation with the Service takes place annually for this
project. The HMNF, in consultation with the Service, has cancelled
proposed Btk treatments, or replaced Btk with Gypcheck^^, on or near
occupied Karner blue butterfly habitat. The availability and use of
Gypcheck^^ continues to provide a reasonable, safe alternative to Btk,
and ongoing Michigan Cooperative Gypsy Moth Suppression Projects are not
likely to result in adverse effects or incidental take of Karner blue
butterflies.

• Consumers Energy Muskegon River Hydroelectric Project Lands

On June 7, 1999, the FERC initiated formal consultation on a Karner blue
butterfly management plan for areas of occupied and suitable habitat on
Consumers Energy hydroelectric project lands along the Muskegon River in
Newaygo County. The action area included the Croton Boat Launch
Powerline Corridor (Croton site) and the Newaygo Park State Park
Powerline Corridor (Newaygo site); both of these sites fall within the
HMNF boundaries. The proposed action included conducting prescribed
burns, managing for lupine and other crucial components of Karner blue
butterfly habitat, and protecting Karner blue butterfly habitat from
human disturbance. In a February 24, 2000 biological opinion, we
determined that implementation of the proposed management plan was not
likely to jeopardize the continued existence of the Karner blue
butterfly. Incidental take was authorized on the basis of known occupied
habitat, and included 0.3 ac (0.1 ha) for Area 1 and 0.13 ac (0.05 ha)
for Area 7 of the Croton site (for more detail, see pages 11-13 of the
February 24, 2000 biological opinion). No prescribed burning has been
conducted on this site, although other management activities have been
implemented.

The Croton site has become degraded for a variety of reasons in recent
years. The highest quality habitat at this site occurs at the top of a
bluff, on the bluff face, and near the boat launch. In June of 1999,
areas of the Croton site were sprayed with a broad-spectrum herbicide,
killing lupine and other plants in the area. In response to this
incident, Consumers prepared a Damage Assessment and Restoration Plan
that included planting and re-establishing colonies of lupine. Consumers
protected this area from human disturbance by putting up a guardrail. In
September 2001, a accidental human-caused wildfire burned a portion of
the site at the top of the bluff. In addition, the area at the top of
the bluff is heavily trampled during annual Fourth of July fireworks
displays. A drought in recent years has severely reduced the lupine on
the bluff face (Gary Dawson, Consumers Energy, pers. comm., 2003). The
newly planted area is threatened by spotted knapweed invasion.

Although the Croton site is degraded, Karner blue butterflies persist in
relatively small numbers. An extant population of Karner blue
butterflies was re-discovered at the Newaygo site in 2002; this site
currently provides higher quality habitat than the Croton site. The
management and restoration efforts, as detailed in the Consumers Karner
blue butterfly management plan, will continue to be critical in
maintaining the remnant populations of Karner blue butterflies both
sites.

[Section 10 Permits (Research and Recovery Activities)]{.underline}

-   The Nature Conservancy (TNC), Clawson Tract

The Nature Conservancy actively manages for Karner blue butterfly on the
Clawson Tract, which has approximately 35 ac (14 ha) of occupied Karner
blue butterfly habitat. The major management need on this property is
the control of invasive alien plants that are competing with native
nectar plants and lupine. The management actions include prescribed
burning, hand removal and spot herbicide treatment of exotic species,
and native plant reintroduction. There are six management units on the
tract. The Clawson tract is within the boundaries of the HMNF. TNC's
current section 10(a)(1)(A) permit (Permit TE022454-1) authorizes the
take of all Karner blue butterflies incidental to conducting habitat
management activities on Unit 1 of the Clawson Tract, which is
approximately 5 acres. In March 1999, a prescribed burn of Unit 1 was
conducted. Spot burning and hand-removal of exotic species has also been
conducted in Unit 1. Because this type of active management is required
for the persistence of suitable Karner blue butterfly habitat,
implementation of these restoration actions have improved status of the
species in the action area.

##### Other natural and human caused factors 

Michigan has experienced several years of below average precipitation.
The resulting dry conditions are suspected to have reduced the survival
of lupine in some areas of Karner blue butterfly habitat on the HMNF
(Joe Kelly, HMNF, pers. comm. 2003).

Some privately-owned lands in the action area that formerly supported
Karner blue butterfly populations ago have been lost to succession,
agricultural conversion, forestry, and development. Furthermore,
activities such as ORV use, pesticide use, and mowing and burning are
known to occur in Karner blue butterfly habitat (USDAFS 2003a; Joe
Kelley, HMNF, pers. comm. 2003). While this has resulted in lost
habitat, the Karner blue butterfly is known to occupy disturbed areas,
such as powerlines and gas pipeline corridors, old fields, forest
openings, roadsides, and lightly stocked oak stands (USDAFS 2003a).

Overall, it is likely that these climatic conditions and human
activities have reduced the extent and quality of Karner blue butterfly
habitat in the action area.

# 

# [Summary and Synthesis of the Environmental Baseline]{.underline}

Approximately 263 Karner blue butterfly-occupied areas have been found
on HMNF lands and 56 occupied areas on private land within the HMNF
boundary. Occupied areas in the action area include 2,026 acres (820 ha)
in Federal ownership and 441 (178 ha) in private ownership (Joe Kelly,
HMNF, pers. comm. 2003). Areas of occupied and potential habitat on
Manistee NF have been segregated into and are managed as four KBBMAs
containing 24 management units. Karner blue butterfly Management Areas
(KBBMA) distributed in the two RUs that occur on the HMNF as follows:
Central and Southeast KBBMAs in the Newaygo RU, Southwest and North
KBBMAs in the Muskegon RU. These include all the areas of occupied or
potential Karner blue butterfly habitats on the HMNF.

The Karner blue butterfly populations in the action area are managed and
protected by the HMNF and other organizations (e.g., TNC). In the past,
there were likely adverse effects in the form of habitat loss and
killing of individual Karner blue butterflies on both HMNF and non-HMNF
lands from human activities (e.g., development, agriculture). These
activities, in concert with other natural factors, have negatively
affected the overall status of the Karner blue butterfly in the action
area.

More recently, however, the necessary and appropriate habitat management
techniques have been implemented and have maintained and improved Karner
blue butterfly habitat. These restoration projects benefit the Karner
blue butterfly by mimicking the natural disturbance processes that are
necessary to maintain the species. Furthermore, the protective
conservation and avoidance measures that were implemented to protect
this species and its habitat since it was listed in 1992 have minimized
or avoided potential adverse effects from both restoration and
non-restoration actions. These protective measures and restoration
actions are still being implemented today.

Current presence/absence monitoring data indicate that populations of
Karner blue butterfly on the HMNF may be declining. These data must be
interpreted carefully, however, because actual population numbers and
trends cannot be determined from this type of survey information. The
HMNF is investigating factors, such as drought, deer browsing, and
frost-pockets, that may be adversely affecting these populations.

Effects of the Action

This section assesses the effects of the proposed action, including the
direct and indirect effects together with the effects of other
activities that are interrelated or interdependent (50 CFR 402.02).
Indirect effects are those that are caused later in time, but are still
reasonably certain to occur. Interrelated actions are those that are
part of a larger action and depend upon the larger action for their
justification. Interdependent actions are those that have no independent
utility apart from the action under consideration (50 CFR 402.02). This
section also assesses the cumulative effects, including the effects of
future State, tribal, local or private actions that are reasonably
certain to occur in the action area.

######## Analysis of the Effects of the Action

The following management actions in the LRMP will have [no
effect]{.underline} or are [not likely to adversely affect]{.underline}
the Karner blue butterfly.

-   *Range Management*

The four active grazing allotments on the HMNF are not within Karner
blue butterfly habitat. Range management activities will have no effect
on the Karner blue butterfly.

-   *Watershed Management*

Watershed management activities are not generally performed in Karner
blue butterfly habitat. Any activities that are required, but are not
compatible with the Karner blue butterfly will be excluded from occupied
habitat. Therefore, watershed management activities will have no effect
on the Karner blue butterfly.

-   *Wildlife, Fish, and Sensitive Plant Management*

There are a variety of wildlife and plant species management activities
that are completed on the HMNF which could adversely affect the Karner
blue butterfly. In Karner blue butterfly habitat, however, such
activities will be either excluded or modified so that they will have no
effect or any resulting effects will be insignificant or discountable.
The potential beneficial and adverse effects that may result from
restoration and management specifically for Karner blue butterfly
habitat will be discussed later in this effects analysis section.

-   *Minerals and Geology*

Resource extraction activities for all federally or State-owned mineral
leases on the HMNF will have a \"no surface occupancy\" stipulation in
Karner blue butterfly habitat to avoid direct impacts. Furthermore,
resource extraction on the HMNF is allowed only after an environmental
review, including section 7 consultation to address any potential
effects on listed species. It is our expectation that, because the HMNF
determined that this management action at the LRMP level is not likely
to adversely affect the Karner blue butterfly, this environmental review
will insure that a project is not completed at a time and place where
there will be adverse effects to the species. Therefore, if there are
any resulting effects on the Karner blue butterfly, they are likely to
be insignificant or discountable. Potential adverse effects from
privately owned mineral leases are discussed in the \"Cumulative
Effects\" section.

-   *Forest Pest Management*

The application of pesticides (includes insecticides, herbicides, and
other chemical or biological controls) for pest control is prohibited in
and adjacent to occupied Karner blue butterfly habitat between April 1
and August 15, except when the wind is not blowing toward the habitat,
and there is a minimum buffer of 100 ft (30 m) between the habitat and
the treatment area. Furthermore, the application of a pesticide is
allowed only after an environmental review, including section 7
consultation to address any potential effects on listed species. It is
our expectation that, since the HMNF determined that this management
action is not likely to adversely affect the Karner blue butterfly, this
review will insure that a pesticide application is not completed at a
time and place where there will be adverse effects to the species.
Therefore, any resulting effects on the Karner blue butterfly are likely
to be insignificant or discountable.

-   *Transportation System* and *Recreation and Related Resource
    Management*

Potential effects from use of transportation (roads) and recreational
facilities (trails, campgrounds) include habitat degradation via
trampling, removing, or otherwise disturbing wild lupine and other
vegetation, and directly harming, harassing or killing Karner blue
butterflies (all life stages). In the past, dispersed camping sites have
degraded occupied habitat. Under the proposed action, these sites will
be signed and closed to camping, effectively eliminating this impact.
Construction of roads and trails (foot and ORV) may also degrade
habitat. Under the proposed action, the HMNF will manage all trails and
roads only in a manner that will maintain or improve Karner blue
butterfly habitat. Therefore, we expect that there will be no new road
or trail construction that would be likely to adversely affect the
Karner blue butterfly habitat.

The maintenance and use of existing roads and ORV trails may also affect
the Karner blue butterfly. Both foot traffic and ORV use may damage or
disturb habitat, and harm or kill individual Karner blue butterflies if
these activities occur off designated trails. Karner blue butterflies
may be killed by impacts with vehicle traffic while moving and
dispersing over roads. Karner blue butterflies have also been observed
using road-rut ponds as a water sources which may increase their
potential to be killed by impacts with vehicles. The overall potential
for this action to take individuals is low, however, because the HMNF
has committed to manage all trails and roads only in a manner that will
maintain or improve Karner blue butterfly habitat. This may include
temporarily or permanently closing, altering, relocating, or
decommissioning trails and roads where they are adversely affecting the
Karner blue butterfly or its habitat. Based on this analysis, the
potential effects of existing roads and ORV trails is insignificant or
discountable.

-   *Recovery Plan Actions Addressed by the LRMP*

Beneficial effects are expected from the continued implementation of the
LRMP by contributing to the following recovery plan actions for the
Karner blue butterfly (USFWS 2001c):

Recovery Plan Action 1. Protect and manage the Karner blue and its
habitat to perpetuate viable metapopulations.

> The HMNF will: 1) protect existing Karner blue butterfly populations,
> 2) monitor the population trends, distribution, and habitat
> availability, 3) search for new populations in unsurveyed areas within
> the action area, 4) implement management activities for all
> metapopulations within action area, and 5) develop recovery
> implementation strategies to promote recovery.

*Recovery Plan Action 3. Develop range-wide and regional management
guidelines.*

> The HMNF will: 1) develop Karner blue butterfly Forest Management
> Guidelines, and
>
> 2\) develop standardized monitoring protocols for Karner blue
> butterflies.

*Recovery Plan Action 4. Develop and implement information and education
program.*

The HMNF will 1) inform local governments of Karner blue butterfly
recovery units,

> 2\) participate in training workshops for government and private
> organizations involved in Karner blue butterfly recovery, and 3)
> develop public outreach materials to inform the public about the
> Karner blue butterfly, and 4) cooperate with adjacent private
> landowners in the action area with management for the Karner blue
> butterfly.

Recovery Plan Action 5. Collect important ecological data on the Karner
blue butterfly and associated habitats.

> The HMNF will gather a important ecological information on the Karner
> blue butterfly in association with its habitat management and
> restoration actions.

Note that for the management actions discussed above, if through Level 2
consultation we determine that these management actions are likely to
adversely affect the Karner blue butterfly, reinitiation of section 7
consultation at the programmatic level (i.e., reinitiation of this Level
1 consultation and Opinion) will be required.

The following management actions in the LRMP are [likely to adversely
affect]{.underline} Karner blue butterfly:

-   *Karner blue butterfly habitat restoration activities (including
    activities under Timber, Fire, and Wildlife, fish, and sensitive
    plant management)*

Adverse effects may unavoidably result from management and restoration
of occupied Karner blue butterfly habitat. Restoration efforts are
designed to maintain suitable Karner blue butterfly habitat using
actions such as planting and propagation of nectar plants, mowing,
cutting, scarification, and burning on occupied sites to manage Karner
blue butterfly habitat. While adult Karner blue butterflies are less
likely to be directly affected because treatments are not planned during
larval or flight periods, there could be short-term adverse direct
effects via crushing or burning of eggs and larvae.

Management for the Karner blue butterfly could be detrimental to the
species if not planned and executed appropriately. For example,
restoration activities, particularly burning, could eliminate an entire
population of Karner blue butterflies if there is no source of
individuals outside and near the treated areas to allow for
repopulation. To appropriately restore and manage Karner blue butterfly
habitat for maximum benefit to the species, the HMNF has established
strict conditions and guidelines under which management activities will
occur. Conditions and guidelines include, but not are limited to, the
following: 1) planning, both annually and cumulatively for the term of
the project, for the appropriate amount, spatial arrangement, and
rotation schedule of restoration sites to maximize habitat recovery and
recolonization potential, 2) seasonal time restrictions for each
restoration technique to minimize the potential for take and to maximize
effectiveness, and 3) minimization of incidental habitat damage due to
equipment or methodology. Among the many other protective measures, pre-
and post-treatment monitoring for Karner blue butterfly and habitat
responses is one of the most important. Monitoring of results and
progress allows for any necessary adjustments to be made. The proposed
monitoring protocol includes the following:

-   Annual pre- and post- treatment monitoring to determine response to
    restoration activities.

-   Monitoring invasive exotic plant species and remove them when
    feasible and desirable (i.e., when there is an adequate native plant
    community available).

-   Annual sampling of each of the four metapopulations during the first
    or second flight period to determine population size. Preference
    should be given to the second flight period because this is when the
    greatest number of butterflies would be present.

-   Tracking of the amount and condition of habitat maintained and
    restored annually.

-   Identification of threats and disturbance factors affecting
    metapopulations and habitat a minimum of every three years.

-   Assessment of subpopulation connectivity every three years to ensure
    that the connectivity remains intact.

Restoration activities proposed by the HMNF conform with current
standards recommended by other sources of Karner blue butterfly
management expertise, such as the Wisconsin DNR (2000) and the draft
Karner blue butterfly Recovery Plan (USFWS 2001c). The expected net
effect of restoration is improved habitat conditions, evidenced by
increased production and biomass of lupine and other nectar-producing
plant species and suppression of woody vegetation. The restoration
should also increase numbers of Karner blue butterfly in the action
area. The action should also benefit populations on adjacent private
lands by improving dispersal opportunities.

Within the action area, there are a total of 2,467 ac (998 ha) of known
occupied Karner blue butterfly habitat. This comprises 2,026 ac (820 ha)
of Federal and 441 ac (178 ha) of non-Federal land (Joe Kelly, HMNF,
pers. comm. 2003). To date 500 ac (202 ha) of this occupied habitat has
undergone restoration treatments. During the period of the proposed
action considered in this Opinion, the HMNF proposes to manage
approximately 675 ac (276 ha) of occupied Karner blue butterfly, which
is 1/3 of the total occupied habitat owned by the HMNF. If completed
following the guidelines and protective measures as proposed, this
action, while allowing short-term adverse effects (e.g., mortality due
to crushing or burning eggs and larvae), will provide significant
benefits to the Karner blue butterfly and is necessary for the long-term
survival of the species on the HMNF.

In summary, the proposed action will provide significant protection and
benefits for the Karner blue butterfly and its habitat. The conservation
measures that the HMNF has committed to are expected to avoid or reduce
the potential for direct or indirect impacts to the species throughout
its range on the HMNF. Nonetheless, unavoidable incidental take of
Karner blue butterfly from the proposed restoration activities on the
HMNF will occur. Such take, however, is not anticipated to impair the
survival and recovery of the Karner blue butterfly population within the
action area.

We are not aware of any actions that are interdependent or interrelated
to the proposed action being considered in this Opinion.

######## Cumulative Effects

Cumulative effects include the combined effects of any future State,
local, or private actions that are reasonably certain to occur [within
the action area]{.underline} covered in this Opinion. Future Federal
actions that are unrelated to the proposed action are not considered in
this section because they require separate consultation pursuant to
section 7 of the Act.

Approximately one-half of the total land acreage and approximately 18
percent of the known occupied acreage within the KBBMAs is under
non-Federal, mostly private, ownership (USDAFS 1994, 2003a). Although we
are aware of no major non-Federal actions are reasonably certain to
occur in the action area, it may be assumed that some activities,
particularly on private lands, could have a progressive negative effect
on the Karner blue butterfly in the action area. Human populations in
the counties with Karner blue butterfly habitat have been rapidly
increasing in recent years (USDAFS 2003a). Human population growth is
typically accompanied by increased urbanization, including road
construction and land development. Both of these activities may
potentially result in the permanent loss of Karner blue butterfly
habitat. Additional actions performed on private lands that may
adversely affect the Karner blue butterfly in the future are fire
suppression, mowing and grazing, ORV use, application of pesticides, and
timber harvest. Additionally, the development of privately-owned mineral
rights is possible on both private and HMNF lands. Mineral rights on
Federal lands are subject to an environmental analysis, review,
oversight, and permit from the Federal agency. The Federal agency,
however, may not be able to condition a permit in a manner that would
preclude the development of the resource. In such cases, the HMNF may
not be able to impose a "no surface occupancy" stipulation in the permit
for mineral extraction in Karner blue butterfly habitat, and the species
may be adversely affected.

In occupied Karner blue butterfly habitat, future take would be subject
to the prohibitions under section 9 of the Act. As such, actions
resulting in incidental take would require a 10(a)(1)(B) permit, and the
adverse effects would be minimized and mitigated to extent practicable.

Given that a significant portion of Karner blue butterfly habitat is
federally-owned, the positive effects of the proposed action should help
offset potential negative effects of non-Federal activity in the action
area. We expect that the net long-term cumulative effect of the
restoration treatments and other protective measures and planned
activities in the action area overall should be beneficial to the
species. Implementation of the proposed action over time should produce
an ecosystem effect at a landscape scale that has the potential to
balance any non-Federal action and result in increased numbers of Karner
blue butterflies.

Conclusion

After reviewing the current status of the Karner blue butterfly, the
environmental baseline for the action area, the effects of the proposed
action, and the cumulative effects, it is our biological opinion that
the action, as proposed, is not likely to jeopardize the continued
existence of the Karner blue butterfly. No critical habitat has been
designated for this species, therefore, none will be affected.

Karner blue butterflies depend on early successional stage vegetation,
primarily wild lupine. Historically, wild lupine was maintained by fire
and other disturbances. The habitat management plan for Karner blue
butterflies proposed by the Forest Service attempts to mimic natural
disturbances by use of prescription burns, mowing, cutting, and
scarification. Although those management measures will result in some
incidental take of eggs, larvae, and adults, they are necessary to
preserve, enhance, and create habitat for the Karner blue butterfly.
This level of adverse effects, however, is expected to be small and is
not reasonably expected to, directly or indirectly, reduce appreciably
the likelihood of both the survival and recovery of the Karner blue
butterfly in the wild by reducing their reproduction, numbers, or
distribution within the action area.

The following factors, among others, were important in our assessment of
jeopardy:

-   The restoration activities proposed are for the purpose of
    conserving Karner blue butterflies on the HMNF.

-   These restoration activities will be implemented in a manner to
    minimize adverse effects the extent feasible and conform with
    current standards recommended by other sources of Karner blue
    butterfly management expertise.

-   For non-Karner blue butterfly management activities, the proposed
    conservation measures will avoid or reduce the potential impacts to
    the Karner blue butterfly and its habitat on the HMNF, so that they
    likely to only result in insignificant or discountable effects.

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-   The continued implementation of the LRMP will assist with achieving
    the recovery Actions for the Karner blue butterfly.

Therefore, we believe that continued implementation of the LRMP will not
appreciably reduce the likelihood of the range-wide survival and
recovery of the Karner blue butterfly.

Incidental Take Statement

Section 9 of the Act and Federal regulation pursuant to section 4(d) of
the Act prohibit the take of endangered and threatened species,
respectively, without special exemption. Take is defined as to harass,
harm, pursue, hunt, shoot, wound, kill, trap, capture or collect, or to
attempt to engage in any such conduct. Harm is further defined by the
Service to include significant habitat modification or degradation that
results in death or injury to listed species by significantly impairing
essential behavioral patterns, including breeding, feeding, or
sheltering. Harass is defined by the Service as intentional or negligent
actions that create the likelihood of injury to listed species to such
an extent as to significantly disrupt normal behavior patterns which
include, but are not limited to, breeding, feeding or sheltering.
Incidental take is defined as take that is incidental to, and not the
purpose of, the carrying out of an otherwise lawful activity. Under the
terms of section 7(b)(4) and section 7(o)(2), taking that is incidental
to and not intended as part of the agency action is not considered to be
prohibited taking under the Act provided that such taking is in
compliance with the terms and conditions of this incidental take
statement.

In general, an incidental take statement specifies the impact of any
incidental taking of endangered or threatened species. It also provides
reasonable and prudent measures that are necessary to minimize the
impacts of the take and sets forth terms and conditions which must be
complied with in order to implement the reasonable and prudent measures.

A complete discussion of the Programmatic Consultation process and how
it relates to this incidental take statement is found on page 4 of the
accompanying Opinion.

######## Amount or Extent of Take

In this incidental take statement, we are evaluating the incidental take
of Karner blue butterflies that may result from continued implementation
of the current LRMP for the HMNF. An LRMP is a permissive plan level
document that allows and guides, but does not authorize, specific
actions to occur. As explained within the accompanying Opinion and
within the biological assessment, the LRMP allows actions that are
likely to adversely affect the Karner blue butterfly. As such, specific
actions conducted under the LRMP may impart a level of adverse effects
to individual Karner blue butterflies that rises to the level of take.
The conservation measures proposed as part of the proposed action,
however, substantively reduce the potential for adverse effects and
incidental take to occur as a result of some actions implemented under
the LRMP. Therefore, projects completed under the LRMP that comply with
the conservation measures, standards and guidelines, and other project
commitments detailed in the biological assessment in many cases would
not adversely affect the Karner blue butterfly to a degree that take
would not be anticipated in many instances. In situations related to
restoration of occupied Karner blue butterfly habitat, however,
incidental take is likely regardless of whether the conservation
measures, standards and guidelines, and other project commitments are
adhered to.

We anticipate that incidental take of Karner blue butterflies will
result from the proposed management activities in occupied Karner blue
butterfly sites. Incidental take of actual eggs, larvae, or adult Karner
blue butterflies may be difficult or impossible to detect because
finding a dead or impaired specimen is unlikely due to small body size,
and losses may be masked by seasonal fluctuations in numbers or other
causes. The level of take of this species can be anticipated by acreage
of occupied habitat restored because habitat characteristics,
particularly the presence of wild lupine, are adequately identifiable
and actual presence of Karner blue butterflies has been determined by
survey. Incidental take of eggs, larvae, and adults will be permitted on
the basis of total known occupied acreage affected annually. For the
duration of the proposed action considered in this Opinion, the HMNF
proposes to manage a total of approximately 675 ac (276 ha) of occupied
Karner blue butterfly, which is 1/3 of the total occupied habitat owned
by the HMNF. Thus, this incidental take statement anticipates the taking
of all Karner blue butterflies associated with restoration of up to, but
no more than, 675 ac (276 ha) of occupied Karner blue butterfly habitat
on the HMNF for the duration of the proposed action. This anticipated
incidental take will be portioned and exempted annually by the Service,
in consultation with the HMNF on a project-by-project basis.

Any future actions completed under the LRMP that may adversely affect
the Karner blue butterfly will require site-specific section 7 formal
consultation. These consultations will proceed using the procedures
outlined in the "Programmatic Consultation Approach" section in the
accompanying Opinion. A Level 2 biological opinion will be written and
appended to this Opinion. During this Level 2 consultation,
project-specific incidental take, as well the cumulative amount of take
(i.e., acres of occupied habitat restored) pursuant to implementation of
the LRMP that has occurred, will be assessed. Section 9 exemption under
the terms of sections 7(b)(4) and 7(o)(2) of the Act will be granted. In
these future incidental take statements, reasonable and prudent measures
and terms and conditions to minimize the effect of any incidental take
that may result will be developed and applied, as appropriate.

######## Effect of Take

In the accompanying Opinion, we determined that the proposed action is
not likely to jeopardize the continued existence of the species.
Therefore, we have determined that the level of anticipated incidental
take associated with the actions completed under the LRMP is not likely
to jeopardize the Karner blue butterfly. Disturbance of this habitat is
expected to be [short term]{.underline}, that is, lupine and Karner blue
butterflies are anticipated to re-occupy disturbed sites after
management treatments. Therefore, the take of Karner blue butterflies is
considered short-term. Furthermore, the restoration activities proposed
by the HMNF conform with current standards recommended by other sources
of Karner blue butterfly management expertise, which are designed to
minimize adverse effects. Thus, the expected net effect of the
restoration is improvement of the habitat conditions and overall status
of the Karner blue butterfly in the action area. Furthermore, these
activities are designed to reverse the effects of land use practices
that have caused the decline of the Karner blue butterfly and to restore
habitat. Although these management actions are likely to result in the
death of undeterminable number of individual eggs, larvae, and adults,
they also are likely to cause an increase in the population of and
produce long-term benefit for the species on the HMNF.

######## Reasonable and Prudent Measures

The Service cannot exempt incidental take at the plan level consultation
(Level 1). We believe, however, that the following Reasonable and
Prudent Measures will be applied to some project level consultations
(Level 2) in the future to minimize the effect of incidental take that
may result from such projects, where appropriate on a project-by-project
basis.

1\. Conduct all management in a manner that minimizes take to the
maximum extent practicable.

2\. Seek new information annually on the distribution and status of
Karner blue butterflies in the action area and apply such information to
management to minimize take.

We believe that, where required on a project-by-project basis, the
reasonable and prudent measure outlined above will significantly reduce
the impacts of incidental take of the Karner blue butterfly on the HMNF.

######## Terms and Conditions

In order to be exempt from the prohibitions of section 9 of the Act, the
HMNF must comply with the following terms and conditions which implement
the reasonable and prudent measures described above. In order to reduce
the potential to impact the Karner blue butterfly, the following terms
and conditions may be applied on a project-by-project basis. The
appropriateness of applying each term and condition will be determined
based on the technical requirements and biological characteristics of
individual projects. Where required, these terms and conditions will be
non-discretionary.

1\. Conduct all management of Karner blue butterfly habitat in a manner
that minimizes take to the maximum extent practicable.

a)  Restoration activities are to be carried out as proposed in the
    biological assessment. These measures are as follows:

> [Under section 4.5.8.8 "Fire Management":]{.underline}

-   Divide contiguous Karner blue butterfly breeding habitat areas into
    three or more burn units

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-   Never burn an entire population at one time

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-   For each prescribed burn, leave at least 2 unburned units with an
    adequate firebreak between them to protect against wildfire or other
    chance events

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-   Promote Karner blue butterfly burn survival and facilitate post-burn
    recolonization; for burn units larger than about 40 acres, maintain
    a long-term unburned refugium (a small area of occupied lupine
    habitat) within the burn unit by alternative management such as
    mowing and herbicide use, or simply exclude an occupied lupine area
    during a fire for the short-term

-   Design burn rotations so that populations on burned areas can
    recover before adjoining source colonies are burned; Annual pre- and
    post-treatments monitoring will be required to determine recovery
    from treatment

-   Burns should be no more frequent every four years so that
    populations can recover; burn frequencies of 5 to 10 years are
    preferred, unless woody succession or exotic invasion is a threat

-   If burns are required more frequently than four years, consider
    alternative treatments

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-   Mowing

-   Exclude lupine patches which large numbers of the butterfly

-   Maintain refugia that support the butterfly and that go unburned

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-   Utilize existing artificial or natural breaks such as trails,
    wetlands, or roads as firebreaks

-   When possible, avoid creating firebreaks by exposing the dirt to
    mineral soil; lupines readily colonize bare soil, but so do many
    other aggressive exotic species

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-   If such breaks are necessary to protect human safety, use rotovated
    or disced breaks rather than fire-plowed breaks

-   Avoid spreading seeds of weedy plants via equipment

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-   Monitor for invasion of aggressive exotic plants and remove them, as
    prudent and necessary

-   Vary the degrees and intensities of burns

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-   Use patchy burns

-   Leave a mosaic of burned and unburned areas when possible and
    compatible with overall needs of the habitat

-   Leave unburned areas near the center of the area to facilitate
    post-burn recolonization

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-   Vary the timing of prescribed burns to avoid selecting for or
    favoring some community components over others by repeated
    application of fire at the same time of year

[Under section 4.5.11 "Conservation Measures":]{.underline}

-   Maintain or restore occupied Karner blue butterfly sites by:

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-   Providing savanna-like conditions with 25-50 percent crown closure
    or openings with an abundance of wild lupine.

-   Maintaining savanna-like conditions by removing woody encroachment.

-   Prohibiting the cutting of trees between March 15 and August 15.
    Allow removal of trees that pose a safety hazard.

-   Cutting trees with non-mechanized equipment such as chainsaws is
    preferred. Mechanized tree cutting equipment may be allowed by
    exception.

-   Locating logging roads, skid trails, and log yards to avoid or
    minimize impact to the habitat.

-   Piling slash not to exceed 20 percent of an area, burning during the
    winter, and avoiding piling slash in areas containing concentrations
    of wild lupine.

-   Mowing and/or brush hogging activities are prohibited between March
    15 and August 15 and on a four-year frequency.

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-   Dividing areas into at least two units, each of which supports
    lupine and nectar sources. At least one unit will remain untreated
    each season unless there is a colonization source within ¼ mile that
    has the capability to recolonize this area.

-   Leaving cut vegetation on site that may contain eggs, unless the cut
    vegetation is collected and placed in another suitable habitat site.

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-   Prescribe burning will be conducted by:

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-   Dividing sites into at least three burn units based on numbers of
    butterflies and burn no more than ⅓ of any site in any one year. If
    there are less than 10 individual butterflies during the first
    flight survey, then the entire site can be burned.

-   Keeping unburned occupied patches within ¼ mile (0.46 km) of burned
    patches to aid recolonization.

-   Designing burn areas with irregular shapes and small-scale unburned
    vegetation (skips).

-   Having an approximate four-year burning frequency.

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-   Site scarification will be conducted by:

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-   Exposing mineral soil to aid seeding of native nectar plants.

-   Leaving 25 to 50 percent of the occupied area undisturbed.

-   Protecting concentrations of wild lupine or other nectar plants.

-   Treating areas will be prohibited between March 15 and August 15 and
    on a four-year frequency.

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-   Propagating nectar plants by using seeds with a locally-based
    genotype when possible. If collected from the site, limit the
    collection to no more than 25 percent of available seeds and collect
    after July 1.

b)  Undertake the reasonable necessary measures during restoration
    activities to ensure that new employees, contractors, and other
    parties involved in restoration and in other activities in the
    action area understand the guidelines and protective measures
    designed to minimize take and avoid long-term adverse effects on
    Karner blue butterflies. Such measures should include, but not be
    limited to, a) biologists, managers, and others as appropriate shall
    meet annually prior to any treatments to review for oversight and
    compliance this biological opinion and the Plan; and b)
    knowledgeable HMNF staff shall familiarize laborers, contractors,
    and others as appropriate with treatment unit locations and
    perimeters before treatment.

2\. Seek new information annually on the distribution and status of
Karner blue butterflies in the action area and apply such information to
management to minimize take.

a)  Use annual surveys and pre- and post-treatment monitoring data to
    avoid management activities that are unnecessary or that could
    result in excessive take.

######## Requirements for Monitoring and Reporting of Incidental Take of the Karner blue butterfly

Federal agencies have a continuing duty to monitor the impacts of
incidental take resulting from their activities \[50 CFR 402.14(i)(3)\].
In doing so, the Federal agency must report the progress of the action
and its impact on the species to the Service as specified below.

1.  Supply the Service's East Lansing Field Office with an annual
    report, due by January 31^st^ each year, that outlines the
    following:

    a.  The amount of occupied habitat restored in the current year and
        the total restored since issuance of this Opinion. The report
        should include what methods were used and pre- and
        post-treatment photos.

    b.  Results of all monitoring activities, as outlined in the
        accompanying Opinion and biological assessment.

    c.  Results of annual Karner blue butterfly metapopulation surveys.

    d.  Progress and results of terms and conditions, as they were
        required, identified by project.

2.  Salvage of specimens is unlikely due to the nature of the proposed
    activities and the physical characteristics of Karner blue
    butterflies, eggs, and larvae. Therefore, no protocol is provided
    for salvage of specimens.

We anticipate the taking of all Karner blue butterflies associated with
restoration of 675 ac (276 ha) of occupied Karner blue butterfly habitat
on the HMNF is reasonably certain to occur as a result of the proposed
action. This anticipated incidental take will be portioned and exempted
annually by the Service, in consultation with the HMNF on a
project-by-project basis. The reasonable and prudent measures, with
their implementing terms and conditions, are designed to minimize the
impact of incidental take that might otherwise result from the proposed
action. If, during the course of the action, this level of incidental
take is exceeded, such incidental take represents new information
requiring reinitiation of consultation and review of the reasonable and
prudent measures provided. The Federal agency must immediately provide
an explanation of the causes of the taking and review with the Service
the need for possible modification of the reasonable and prudent
measures.

Conservation Recommendations

Section 7(a)(1) of the Act directs Federal agencies to utilize their
authorities to further the purposes of the Act by carrying out
conservation programs for the benefit of endangered and threatened
species. Conservation Recommendations are discretionary agency
activities to minimize or avoid adverse effects of a proposed action on
listed species or critical habitat, to help implement recovery plans, or
to develop information.

We believe that the HMNF has already initiated or participated in
important efforts to protect, manage, and increase our understanding of
the Karner blue butterfly, including their commitment to implement the
Conservation Measures in the proposed action. We offer the following
Conservation Recommendations to further expand the knowledge of this
species, and help better manage for the Karner blue butterfly in
Michigan.

-   Take action to improve habitat conditions and avoid or minimize take
    of Karner blue butterfly on private land within or adjacent to the
    HMNF by a) adopting an education program which includes, but is not
    limited to, landowner contact, either independently or preferably in
    cooperation with the Landowner Contact Program of the MDNR and MNFI
    already in progress; b) seeking opportunities to develop information
    on presence of Karner blue butterflies on private land where owners
    are willing; and c) seeking opportunities, especially through
    partnerships, to help fund and carry out beneficial habitat
    management on private lands of willing owners.

-   To the extent possible, develop information on the presence of
    Federal candidate plants and animals during the conduct of
    monitoring activity of the Plan and regular Karner blue butterfly
    surveys.

-   Evaluate the contributions of drought, deer browsing, and
    growing-season frost on HMNF Karner blue butterfly populations, and
    propose potential solutions where necessary and prudent.

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-   Evaluate whether measures to address potential adverse effects of
    roads and trails are necessary and prudent.

-   Adopt monitoring protocols detailed in the draft Karner blue
    butterfly recovery plan

The Service recognizes that these Conservation Recommendations may
require long-term efforts by the HMNF and does not expect their
implementation to be confined to or completed within the time period of
this consultation. In order for the Service to be kept informed of
actions minimizing or avoiding adverse effects or benefiting listed
species or their habitats, we request notification of the implementation
of any conservation recommendations.

#### Pitcher's Thistle

Status of the species and critical habitat

This section presents the biological or ecological information relevant
to formulating the biological opinion. The purpose is to provide the
appropriate information on the species= life history, its habitat and
its [range-wide]{.underline} distribution and conservation status for
analyses in later sections. This section also documents the effects of
all past human and natural activities or events that have led to the
current status of the species.

[Species Description]{.underline}

First noted at the Grand Sable Dunes of the Upper Peninsula of Michigan
in 1827, the Pitcher's thistle is a monocarpic (flowers and sets seed
only once), perennial, herbaceous plant, generally flowering after a 5-8
year juvenile stage (Loveless 1984). The stems and leaves of juveniles
and adults are woolly-white, and the leaves are deeply pinnatifid with
the lobes less than 0.4 in

(1 cm) wide and up to 1.6 in (4 cm) long. Minute spines are concentrated
along the edge of the leaf at its base, with a few spines between the
lobes of the distal leaf margins. The flowering stems are up to 3.2 ft
(1 m) tall and have several to a dozen widely scattered leaves.
Individuals typically have a single branching flowering stem with
terminal and axillary flowering heads of a cream or pinkish color.
Juveniles and adults have a taproot that may reach 2 m in length (see
USFWS 2002b).

[Habitat]{.underline}

Pitcher's thistle is one of a few plant species endemic to the
post-Wisconsinan Great Lakes sand dunes. Species restricted to these
dune ecosystems are part of a dynamic dune ecosystem of considerable
biological significance. Pitcher's thistle is found most frequently in
the near-shore plant communities, although it occurs in all non-forested
areas of Great Lakes dune systems. Healthy populations of Pitcher's
thistle are a general indication of high quality of dune ecosystems. The
rust, *Puccinia laschii* (Saville 1970) that is sometimes found on adult
leaves may be host-specific, and therefore dependent on Pitcher's
thistle. In addition, Pitcher's thistle is a food (pollen, nectar and
seed) source for many organisms (Keddy and Keddy 1984; Loveless 1984).

Great Lakes dune systems are similar to coastal dunes worldwide (Figure
5). Generally, in undisturbed settings a low barrier dune ridge, or
foredune, forms immediately inland from the beach (Buckler 1979). This
ridge breaks the onshore winds, trapping sand as it blows shoreward from
the beach. Frequently, on the landward side of the foredune is an
interdunal trough, a topographically protected low area of varying depth
and width. In some areas the interdunal trough is filled with
groundwater, forming small interdunal ponds. Inland from the trough is a
series of larger, secondary dunes that range in height from as much as
197 ft (60 m) at the southern tip of Lake Michigan to less than a 3.2 ft
(1 m) in the north (Cowles 1899; Olson 1958a).

![](media/image5.png){width="5.499305555555556in"
height="3.5833333333333335in"}

Figure 5. Generalized dune landscape providing Pitcher\'s thistle
habitat (from McEachern 1992)

The coastal dunes of the Great Lakes formed as the last glaciers
retreated from the lake basins 14,000 to 10,000 years ago (Hansel et al.
1985), and the larger dune systems formed 4,700 to 4,000 years ago
during, higher, Nipissing shorelines. Shoreline erosion and river
discharge brings sand into the Great Lakes. Once in the water, sand is
picked up by long shore currents, transported along the coastline, and
deposited by waves on sandbars and beaches. Onshore winds then rework
the beach sands into dunes. Fluctuating lake levels may deposit and
erode sand along the dune lines (Olson 1958a, Larsen 1985). Because
sediment loads are lower today than during deglaciation, beaches and
large dunes are not being formed at the same rates as in recent geologic
history (Buckler 1979). A different equilibrium now exists between the
interacting forces of sand supply through long shore currents, dune
formation and erosion by winds, and stabilization through plant
establishment and succession.

[Life History and Ecology]{.underline}

Pitcher's thistle colonizes patches of open, windblown areas of the
landscape, and gradually declines locally as the density of vegetation
and ground litter increases through plant succession. The species is
patchily distributed with varying population sizes in all open zones of
the dunes vegetation. Plant populations decline in stabilized, late
successional secondary dune sites and in areas heavily used by people.
Pitcher's thistle density peaks in mid-successional habitats and
requires 70 percent open sand for successful seedling establishment and
survival (McEachern 1992). Population sizes may vary with habitat.

Environmental conditions for plant growth become less harsh with
increasing distance from shore, resulting in zonation of plant
communities paralleling the dune forms (Figure 5). Many fast-growing
annual plant species, inhabit the loose, blowing sands of the beach
between the wave-wash zone and the foredune. In years of high lake
levels or intense summer storm activity this zone can be very narrow to
nonexistent, while in other years it can be many meters wide. Therefore,
these annual plants fluctuate greatly in number and distribution from
year to year and depend on a store of dormant seeds buried in the sand
to carry them through harsh years.

The foredune presents a similarly dynamic substrate for plant growth, as
it grows and moves in response to weather patterns. When lake levels are
low and the beach is wide, a large amount of sand is blown landward. The
sand is trapped by the vegetation and the foredune builds rapidly. In
years of narrow beach area, the foredune grows more slowly, or may even
be undercut by high waves. Foredune vegetation is typically a near
monoculture of rhizomatous beach grass (*Ammophila breviligulata*)
growing with stress tolerant shrubs and herbaceous species inhabiting
the open, stabilized spaces between the grass stems. In wet springs
foredune buildup may be caused by a flush of cottonwood regeneration and
establishment (Poulson 1990, 1995). Foredune plants tolerate high
amounts of sunlight and wind, and adjust their growth rates to
accommodate the shifting sand substrate. In the interdunal trough zone
this plant community becomes more dense and species less drought
tolerant are found.

In secondary dunes, the greater distance from the shore allows lower
wind speeds, more stable sand substrate, and more dense plant growth.
Beach-adapted species are replaced by perennial grasses, such as little
bluestem (*Andropogon scoparius*). Whereas ground cover can be as low as
6 percent in the foredunes, it commonly reaches 40-50 percent in the
secondary dunes (McEachern 1992). The sands have incorporated more
organic matter into the surface layer, and can support a greater amount
of biomass (Olson 1958b). Plant species diversity is higher in the
secondary dunes, with a greater variety of life forms, ranging from
small herbaceous annuals to evergreen shrubs and small trees. This dune
grassland typically grades into an oak, pine or beech-maple woodland on
the older dunes. Ground-layer vegetation there receives little light,
and the open dunes flora is completely replaced by shade tolerant forest
understory plants.

When foredunes are breached by high winds, waves or human activities,
parabolic blowouts push inland from the trough and windward face of the
secondary dune. Recent evidence suggests that blowouts are formed after
some lake level highstands that occur at approximately 150 year
intervals (Loope and Abrogast 2000). These blowouts range from several
square meters to hectares in area. Blowouts and other disturbances in
the secondary dunes provide foredune-like habitats for beach and
foredune species such as Pitcher's thistle, if destabilizing effects of
the disturbance are not too severe. Once stabilized, the blowouts
eventually succeed to little bluestem dominated grassland, displacing
the colonizing species.

By colonizing blowouts, Pitcher's thistle and other species
characteristic of the beach and foredune locations persist for a time at
scattered sites within the more protected secondary dunes. In years when
the foredunes are truncated by high lake levels or storm activity, such
sites may serve as refugia for those species, contributing to eventual
beach and foredune recolonization (McEachern 1992). Beach and foredune
plant species depend on a dynamic microhabitat for their persistence in
the dune flora. Therefore, smaller dune fields, limited in their range
of microhabitats, are more likely to lose these species than are larger
dune fields richer in the mosaic of dune forms and early successional
openings.

*Seed Ecology.* Pitcher's thistle has the largest individual seeds among
thistles in the eastern United States, each weighing about 0.010 grams
(Gleason 1952; Montgomery 1977). This large seed size may be
advantageous for rapid seedling establishment by maximizing seedling
root growth in the often hot, dry, and infertile dune sand substrate.
Seed dispersal commences in late July at the northern limits of its
range (Keddy and Keddy 1984), but can occur from June to August
(McEachern 1992). Seeds have a long (up to 25 mm) loosely attached
pappus. Primary seed dispersal is through individual seeds blowing from
the inflorescence head or by the whole plant and heads falling to the
ground at the end of the flowering season. Maximum observed primary
dispersal distances range from 1.83 to 4.00 m based on seed locations
and on seedling distributions around previous year's adult plants (Keddy
and Keddy 1984; Loveless 1984; Ziemer 1989). Secondary dispersal is
effected by wind blowing seed and seed heads across the sand, snow or
water surface (Loveless 1984).

Pitcher's thistle seeds are subject to various pre- and post-dispersal
herbivory. Predispersal herbivores include the artichoke plume moth
larvae (*Platyptilia carduidactyla*), ground squirrels, goldfinches
(*Spinus tristis*), and deer. Sparrows and other ground feeding birds
and small mammals may eat seeds after dispersal (Keddy and Keddy 1984;
Loveless 1984; McEachern 1992; D'Ulisse and Maun 1996; Stanforth et al.
1997). Predispersal seed predation can have a significant impact on
Pitcher's thistle demography as evidenced by observed seed set
reductions of 42 and 14 percent at the Canadian population on Lake
Superior (Keddy and Keddy 1984; Loveless 1984). Little is known
concerning post-dispersal seed losses.

Pitcher's thistle appears to have a small between-year seedbank
(Loveless 1984; McEachern 1992; Bowles and McBride 1996; Hamzé and Jolls
2000). This suggests a buried seedbank may not strongly buffer
population stability when plants are destroyed. Seed dispersal to nearby
suitable habitats may be more important for population stability than
the seedbank.

Seed dormancy is broken by cold, moist stratification (Hamzé and Jolls
2000), with seed germination occurring in May and June (Loveless 1984).
Seed germination may vary yearly depending on rainfall, depth of burial,
and seed size (Loveless 1984; Hamzé and Jolls 2000). Episodic
germination occurs in late-successional sites after moderate sand
deposition (McEachern 1992).

*Seedling Stage.* Seedlings produce 1 to 6 leaves in the first season
(Loveless 1984). Seedling densities are greater where bare ground is
abundant (McEachern et al. 1989) than in stabilized sites with greater
vegetation cover; however, there is greater seedling mortality in
foredune sites relative to inland sites (Keddy and Keddy 1984; Loveless
1984). After establishment, plant mortality decreases on foredunes, but
remains lower and constant on more stabilized sites. Seedling mortality
is caused by ant and wind excavation, drought, excessive burial in sand,
and trampling (Keddy and Keddy 1984; Loveless 1984; Ziemer 1989,
McEachern 1992).

*Juvenile Stage.* Juveniles typically consist of one rosette, unless
they are grazed, trampled or buried where they may develop multiple
rosettes. Juveniles may remain dormant for one or two years as a result
of drought (McEachern 1992). The chances of juvenile mortality decrease
as they increase in size. Causes of mortality include human and moose
trampling (Keddy and Keddy 1984; Gibson 1988), sand deposition and
erosion (McEachern, pers. comm. as cited in USFWS 2002b; Steve Weller,
University of California, Irvine, pers. comm. as cited in USFWS 2002b),
drought, and rabbit herbivory (Weller, pers. comm. as cited in USFWS
2002b). Observations indicate juvenile plants in foredunes grow by
increasing leaf number, whereas in inland stabilized habitats they grow
by increasing leaf size (Loveless 1984). These growth differences may be
significant in determining the age when juveniles reach a critical
flowering size. Pitcher's thistle plants may respond to intense
herbivory by decreasing or delaying flowering efforts, having lower
survivorship or decreased growth.

*Adult Reproductive Stage.* Adults are typically single stemmed, but
multiple stemmed plants (2 to 30 stems) are known. Multiple stemming may
be a result of apical meristem damage caused by many factors including
trampling, grazing (Phillips and Maun 1996), sand burial, or predation
by artichoke plume moth (Keddy and Keddy 1984; Loveless 1984). The
number of flowering heads per plant varies with habitat, latitude, plant
size, and year (Keddy and Keddy 1984; Loveless 1984; McEachern et al.
1989), and is highly correlated with stem diameter (McEachern 1992). Age
of reproduction ranges from 5 to 8 years.

*Floral Biology.* Pitcher's thistle blooms from May to September, with
the date of peak anthesis occurring later with increasing latitude
(mid-July at Sleeping Bear Dunes). Flowering is determinant and
commences from the terminal head and proceeds downward. Smaller axillary
flowering head buds located below the flowering inflorescence may bloom
late in the season or if distal heads are damaged or removed. Floret
number per head is positively correlated with head diameter and ranges
from 30 to almost 300 florets (Keddy and Keddy 1984; Loveless 1984).
Head diameter and floret number both decline as the season progresses.
Florets are bisexual and insect pollinated, with maturation proceeding
from the outside of the head towards the center. Anthers of each floret
produce mature pollen before the stigma is receptive. This intra-head
and intra-floret phenology prevents self-pollination of florets, but
allows pollination among inflorescence heads on the same plant.

Thirty insect species from four orders (predominantly bees: Hymenoptera)
have been observed visiting Pitcher's thistle, although which are
legitimate pollinators is unknown. Inter-plant pollination predominates
early and late in the blooming season, whereas intra-plant pollination
dominates in mid-season (Loveless 1984). Pitcher's thistle has a mixed
mating system, with outcrossing ranging from 35 to 88 percent (Keddy and
Keddy 1984; Loveless 1984). The species is apparently self compatible;
however out crossed and open-pollinated heads have higher seed set than
self-pollinated heads. Genetic neighborhoods are likely to be quite
small. Whether inbreeding leads to the loss of fitness is unknown. A
mixed mating system suggests that inbreeding depression could occur in
small populations.

[Population Dynamics]{.underline}

Metapopulation dynamics are important for the conservation of Pitcher's
thistle (McEachern 1992). A metapopulation is a more or less continuous
or loose collection of somewhat separate but potentially interacting and
dynamic populations delimited by marked or discrete gaps in habitat or
colony boundaries on a dune landscape (Figure 5). As a species,
Pitcher's thistle exhibits several characteristics of metapopulations
(Levins 1970; Hanski 1989). First, patches of Pitcher's thistle are
distributed across dune landscapes. Patches are connected by gene flow
through seed and pollen dispersal to other patches, but those farther
away are more loosely connected than those closer. In any dune
landscape, not all suitable habitat patches are occupied by Pitcher's
thistle. Second, Pitcher's thistle patches are dynamic and can be
created or destroyed. For example, a patch can be destroyed by excessive
sand deposition or erosion, especially near the shoreline. After
conditions make the site suitable, it can be recolonized by seed
dispersal from adjacent patches provided they are close enough
(McEachern 1992). Third, disturbances that influence the patch's number
of individuals, size, growth, and fate must be partially uncorrelated in
space and time in large dune systems. For example, McEachern (1992)
found that storms that destroyed near shore populations were less severe
inland and actually contributed to population growth inland by causing
light sand deposition which allowed the establishment of new plants.

At the ecosystem level, the sand dune habitat for Pitcher's thistle in
the western Great Lakes is limited by the geomorphic processes that
created the dunes. These habitats are often influenced by fluctuating
lake levels due to severe seasonal weather patterns and regional
climatic variation. Episodic sand deposition occurs in shoreline dunes
when lake levels are declining and in perched dunes when lake levels are
increasing. Therefore weather events are unlikely to simultaneously
destroy all Pitcher's thistle habitats.

Populations of Pitcher's thistle are relatively short-lived on dune
landscapes, because they are prone to extirpation due to successional
change, erosional loss and catastrophic events depending on their
location. A shifting mosaic of dune processes on a large dune system
landscape can ensure a species persistence so long as seed is available
to disperse to existing or newly created adjacent suitable habitats. In
the long-term, Pitcher's thistle populations will also shift on such a
landscape. This metapopulation perspective clearly shows how human
development on an unoccupied habitat could eventually fragment Pitcher's
thistle connectivity and increase the probability of local extirpation
of the species. Construction on a portion of a dune system where
Pitcher's thistle is currently absent will, in the long, run fragment
the dune system and increase the probability of population extinction by
eliminating habitat available for decolonization. Dune landscape
fragmentation effectively isolates populations and presents barriers to
dispersal while changing dune processes.

The fates of local habitats and populations are determined by succession
and disturbance. Similarly, Pitcher's thistle populations can fluctuate
greatly in number, size class distribution, and growth rate between
years (Loveless 1984; McEachern 1992) in response to a variety of
natural and human factors that alter individual Pitcher's thistle death
and reproductive rates. In order to accommodate the extensive, near
random movement of the populations and establish seedling populations in
numbers that provide some buffering against stochastic events, a large
expanse of continuously open sand habitat may be required. Generally,
occurrences in areas of sustained, low-level sand deposition showed
stable or increasing populations (McEachern 1992).

For a particular occurrence of Pitcher's thistle to survive, disturbance
must be frequent enough to prevent extirpation from succession and
infrequent enough to allow juveniles to reach maturity; thus the
Pitcher's thistle life history is finely tuned to a specific disturbance
regime (McEachern 1992). Disturbances may eliminate local occurrences,
but as long as those disturbances are not synchronous throughout the
landscape, and occurrence creation exceeds decline, the species will
persist (Pavlovic 1994). From a landscape perspective, recovery of
Pitcher's thistle will require the preservation of large unfragmented
dune systems retaining dynamic dune processes and many local patches
widely dispersed among multiple successional stages throughout the dune
system. From an ecosystem perspective, protection and conservation of
both lake level and perched dune systems will probably prevent
extinction from climatically driven disasters because the two dune
systems respond oppositely to the same climatic perturbations.

[Threats/Reasons for Decline]{.underline}

*Destruction, modification or curtailment of habitat or range.*

Development, sand mining, beach and dune stabilization projects, and
certain types of frequent recreation have destroyed, modified or
curtailed approximately 10 percent of the Pitcher's thistle habitat, and
reduced its range. For instance, seven Pitcher's thistle populations
were extirpated from Indiana and Illinois, but the number lost elsewhere
is not known.

Residential home construction, hotel and resort construction, road
construction, condominium construction and marina construction have
impacted Pitcher's thistle (Lake Michigan Development Commission 1987).
Many of these areas support Pitcher's thistle or potential habitat.
Human disturbance along highway shoulders adjacent to existing thistle
populations often encourages the short-term establishment of Pitcher's
thistle; however, these plants are vulnerable to destruction from road
maintenance mowing, grading, brush and tree removal, herbicide spraying
and road improvements including road widening, pavement recycling,
guardrail removal, slope flattening, culvert extensions, and vegetation
removal for safety. Ballard and Stuart (1995) monitored the effects of
marina development on the long-term population trends of Pitcher's
thistle at the Presque Isle State Mooring Facility. Their findings
support the fact that road construction can also negatively impact
Pitcher's thistle habitat by allowing for accelerated invasion of shrub
growth, which can expand into the dunes, decreasing thistle habitat, due
to the local microenvironment for wind-sand deposition being altered,
allowing the road edge to serve as a microsite that fosters shrub and
other exotic invasive species growth (Ballard and Stuart 1995).

Trampling from beach and dune visitors, and ORV users also threaten
Pitcher's thistle and their habitat, where such recreation is frequent
and prolonged. For example, off-road vehicles destroy plants, create new
blowouts, and severely destabilize dunes that are accessible (USFWS
1988). Trampling from high visitor use causes a decrease in survival and
reproduction of individual plants and can cause seed bed destabilization
(McEachern et al. 1989; McEachern 1992). Direct human trampling occurs
primarily during the growing season and is caused by people hiking,
climbing dunes, and hang gliding (Davis and Wood 1980). Trampling and
high visitor use is a significant issue at certain areas in Wisconsin
(Dobberpuhl and Gibson 1987), Indiana, Michigan and potentially in
Illinois where beach and dune zones are quite narrow.

Shoreline stabilization projects such as jetties, sea walls and rip-rap
change sand supply through the alteration of off-shore sand transport,
which alters local dune geomorphic processes and precludes the creation
and maintenance of Pitcher's thistle habitat (Dobberpuhl and Gibson
1987; McEachern et al. 1989). Sea walls and jetties were built along
beaches containing Pitcher's thistle in Wisconsin, Indiana and Michigan
(Dobberpuhl and Gibson 1987; McEachern et al. 1989). In 1987 hundreds of
Pitcher\'s thistle were destroyed when rip-rap was placed on the
shoreline to maintain U.S. Highway 2 east of Brevort, Michigan.

Planting to stabilize dunes also alters dune building processes and may
decrease habitat available to the plants (Dobberpuhl and Gibson 1987;
McEachern et al. 1989; Loope et al. 1995). For example, planting or
invasion of beach grass (*Ammophila breviligulata*), northern white
cedar (*Thuja occidentalis*), spotted knapweed (*Centaurea maculosa*),
baby's-breath (*Gypsophila paniculata*) or sweet clover (*Melilotus
alba*) stabilizes dunes, thereby reducing the creation of new Pitcher's
thistle habitat (Dobberpuhl and Gibson 1987).

Foundry-sand mining operations are present along the Lake Michigan
shore. The amount of sand mined has increased overall from 1.6 million
tons in 1991 to 2.8 million tons in 2000 (MDEQ 2000). The impact on
Pitcher's thistle is not known in the six counties with active sand
mining permits and species occurrences. No Pitcher\'s thistle sites are
being mined in Indiana or Wisconsin.

*Natural or manmade factors affecting its continued existence*.

Pitcher's thistle is threatened by fragmentation, and may be threatened
by genetic introgression, non-native invasive weeds and non-native
insect species accidentally introduced or deliberately introduced to
control weedy thistles. Global warming may also pose a risk. The
long-term survival of Pitcher's thistle requires a shifting mosaic of
suitable habitat available at all times so that, as areas are made
unsuitable by succession, new areas of suitable habitat are created
close enough for seed dispersal. Fragmentation prevents the creation of
new areas of suitable habitat and likely interferes with seed dispersal.

Proximity of the common bull thistle (*Cirsium vulgare*) may present a
potential threat of introgressive hybridization with Pitcher's thistle
(Dobberpuhl and Gibson 1987). *Cirsium vulgare* is also the adopted host
of several microlepidoptera (moths) that feed on native *Cirsium* spp.
(Louda 2000). *Cirsium vulgare* in the vicinity could increase
populations of the moths and lead to increased feeding damage on
Pitcher's thistle flowerheads, over and above the significant levels
already seen at some sites (Louda and McEachern 1995). Stabilization of
large areas of the dunes by invasive non-native weeds, such as spotted
knapweed, can also retard the natural maintenance of the shifting mosaic
of suitable sand habitat. The magnitude of this potential threat should
be monitored and quantified.

The flowerhead weevil (*Rhynocyllus conicus)* was introduced into
several North American sites to control species of Eurasian thistles
(*Carduus* sp.). This flowerhead weevil has spread to many locations,
and has become naturalized (Louda et al. 1997). The flowerhead weevil
develops on multiple native *Cirsium* species in the United States
(Goeden and Ricker 1986a, 1986b, 1987a, 1987b; Turner et al. 1987; Louda
et al. 1997), including *Cirsium canescens*, the putative progenitor of
Pitcher's thistle (Johnson and Iltis 1963). Studies show that
flowerheads of *Cirsium canescens* infested with flowerhead weevil bear
only 14.1 percent as many seeds as flowerheads not infested with
flowerhead weevil (Louda et al. 1997). Laboratory tests in the summer of
1999 demonstrated that this weevil will oviposit on Pitcher's thistle,
and that it feeds and develops on Pitcher's thistle under common garden
test plot conditions in Alberta, Canada (Louda et al. 2002). Thus, if
the flowerhead weevil spreads to Pitcher's thistle range, and the
Pitcher's thistle shows a comparable reduction in seed production, the
flowerhead weevil poses a serious threat to Pitcher's thistle seed
production and regeneration (Louda et al. 1997; Louda 2000). Other
insects introduced for the biological control of non-native thistle
species may also threaten native thistles, including close relatives of
Pitcher's thistle (Louda and O'Brien 2002).

Introduction of the rust *Puccinia carduorum* from Turkey to control the
weedy non-native thistle (*Carduus nutans)* is under consideration by
the United States Department of Agriculture (Politis et al. 1984;
Bruckart and Dowler 1986). In a greenhouse study with conditions optimal
for rust infection, Pitcher's thistle seedlings, but not adults, were
susceptible to the rust infection. In a field trial no Pitcher's thistle
plants were infected (William Bruckart, Agricultural Research Service,
USDA, pers. comm. as cited in USFWS 2002b). A determination cannot be
made from present data as to whether Pitcher's thistle is susceptible to
infection under natural environmental conditions. Introduction of this
rust could be a threat to the survival of Pitcher\'s thistle.

Global warming may increase drought frequency. Droughts may account for
the poor success of Pitcher's thistle populations at the Indiana Dunes
National Lakeshore (McEachern et al. 1989) and at other southern
locations. Global warming may affect the water table levels along the
Great Lakes shorelines and impact the species through altered shoreline
processes.

[Range-wide Status and Distribution]{.underline}

Actions to list the Pitcher's thistle began in 1980 when the Service
included the plant as a category 1 species in its revised notice of
review for native plants (45 FR 82480). Category 1 includes those
species for which the Service has sufficient biological data to propose
for listing as threatened or endangered. It was eventually proposed for
listing as threatened under the Act in July 1987 and listed as
threatened in July 1988. The Pitcher's thistle has been assigned a
recovery priority of 8C indicating a moderate threat, a high recovery
potential, and conflict with construction or other forms of economic
activity. The species is classified as threatened in Canada (Keddy
1988). At the State level, it is listed as threatened in Indiana,
Michigan, Wisconsin and Illinois. The species is extirpated in Illinois.

We recently completed a final recovery plan for the Pitcher\'s thistle
(USFWS 2002b). The goal of the plan is to delist the Pitcher\'s thistle
by protecting and managing the occurrences and habitat. The recovery
criteria established for the Pitcher\'s thistle are as follows: 1) the
essential habitat associated with a total of 115 priority occurrences
representing each biogeographic region and dune type is protected and
managed under a management plan for each management unit; 2) regular
field surveys to verify occurrences and record new occurrences have been
established; 3) landowner contacts have been initiated and protection
has been investigated for the remaining public and private occurrences;
4) monitoring of known sites shows a stable or increasing trend toward
recovery, and that protective plans are being implemented; 5)
restoration of two occurrences from among historical sites where
sufficient habitat remains in Illinois, Indiana, Wisconsin, and southern
Lower Michigan has been completed, and 6) research necessary to protect,
manage and restore Pitcher's thistle has been conducted. The recovery
actions identified in the plan are:

1.  Protect and manage known occurrences and essential habitat.

2.  Establish and conduct regular field surveys to verify known and
    record new occurrences.

3.  Inform the public, recreationists, public land managers and private
    landowners.

4.  Monitor occurrences for stable or increasing trends and
    implementation of protective plans.

5.  Restore Pitcher's thistle populations on two appropriate sites
    within its historical range.

6.  Conduct research necessary for protection, management and
    restoration.

If the recovery criteria are adequately met, delisting would be
considered in 2014.

Pitcher's thistle is endemic to the beaches and grassland dunes of Lakes
Michigan, Superior, and Huron (Guire and Voss 1963). The majority of its
known sites occur along the shores of Lake Michigan. The species ranges
from the north shore of Lake Superior south to Indiana, and formerly
occurred in northern Illinois, where it is has been experimentally
reintroduced (Bowles et al. 1993; Bowles and McBride 1993, 1994; Bowles
and Bell 1998). Distribution of the species extends along the Lake
Michigan shoreline in Wisconsin. In the east it ranges through northern
Lake Huron to the Manitoulin Island archipelago and southern Georgian
Bay in Ontario. Pitcher's thistle extends as far south as Lambton
County, Ontario, Canada on Lake Huron, as indicated by pre-1964
collections for two localities (White et al. 1983).

Pitcher's thistle occurrences are distributed along the Great Lakes
dunes. However, individual populations have not been delineated because
available inventory information is insufficient to identify boundaries
of separate populations. For instance, while progressing along a dune
one may encounter a group, or patch, of Pitcher's thistle plants,
followed by an unoccupied gap, followed by additional groups of plants,
then gaps, and so on. Some groups of plants may contain hundreds of
individuals, while others contain less than a dozen. In this context,
element occurrences are recorded by State natural heritage programs. The
data are specific locations (township, range, section and quarter
section) of where the species was found. Maps of occurrences neither
imply a completed survey for all Pitcher's thistle populations and
plants, nor circumscribe the total potential habitat adjacent to the
mapped populations on that dune system. Because mapped occurrences do
not imply the identification of biological populations, we will use the
term occurrence in this plan to identify the basic locations where
Pitcher's thistle occurs. For the purposes of this recovery plan, an
occurrence of Pitcher's thistle is defined as all Pitcher's thistle in
an area within approximately one mile of each other, and at least one
mile from the nearest Pitcher's thistle which would be part of another
occurrence. Within one occurrence, two individual plants may be greater
than one mile apart, but would have other Pitcher's thistle between them
making the nearest neighbor distance less than one mile.

Occurrence data are not equally complete or current for all the states.
Indiana data are from 1990-1991 (McEachern 1992; Cloyce Hedge, Division
of Nature Preserves Indiana DNR, pers. comm. as cited in USFWS 2002b),
Wisconsin data are from 1987 and 2001 (Dobberpuhl and Gibson 1987; Darcy
Kind, Wisconsin DNR, pers. comm. 2001 from USFWS 2002b) and Canada data
are from 1988 (Keddy 1988). Since Pitcher's thistle is extirpated from
Illinois, occurrences are based on herbarium collections only. Most
recent Michigan data are from 2001. Some Michigan sites have not been
surveyed since the late 1800s and 1911, but the majority (142 out of 156
sites) have been observed since 1980. Occurrences were organized into
six biogeographical regions (see Albert et al. (1986) for Michigan
boundary definitions): 1) southern Lower Michigan, 2) northern Lower
Michigan, 3) eastern Upper Michigan, 4) Indiana, 5)

Illinois, and 6) Wisconsin.

To compare occurrences among states, the global ranking criteria
developed by The Nature Conservancy and now administrated by Nature
Serve, were used for assignment of element occurrence rank for all
occurrences. The occurrence ranks were assigned on the basis of the
quality of the plant community. Plant community quality was determined
by the level of human disturbance and the condition of the plant
community structure and composition. The ranks assigned are A
(excellent), B (good), C (fair), and D (poor). Although the system is
subjective, it is useful because it has been applied consistently. For
all states, element occurrences are synonymous with occurrences as
defined above. The Michigan Natural Features Inventory (MNFI) uses a
size class ranking system, assigning values from one to five, based on
the aerial extent of the occurrence and the abundance of the species.
Lower ranks have larger area and larger populations. Public and private
ownership have the following definitions. Public ownership is land owned
by the Federal, State, county and city government. Private property
includes private and corporate lands, and conservation organization
owned lands.

*Canada*. Pitcher's thistle occurs at a total of 22 Lake Huron dune
sites in Ontario (Jalava 2003). Although more than 25 percent of its
geographic range is in Canada, the population that is supported by this
range is less than 10 percent (Jalava 2003; Oldham and Line 1999).
Pukaskwa National Park on the north shore of Lake Superior, in the
Thunder Bay District of Ontario, is the northernmost population of this
species. That population has been monitored for several years (Keddy
1988). The majority of Canadian occurrences are from Lake Huron,
concentrated around Manitoulin Island and the Bruce Peninsula region.
There are approximately 10,000 Pitcher's thistles plants in Canada.

*United States*. One hundred and ninety-one historic and existing
occurrences are known in the United States, but 18 have been extirpated.
Pitcher's thistle probably occurred more commonly along the Great Lake
shorelines prior to European settlement, but it is unknown how many
occurrences were lost due to settlement and shoreline development. Most
of the known extirpated occurrences are in Illinois and Indiana.

Of the 173 extant occurrences, 156 (90 percent) are in Michigan and the
remaining 17 are divided between Indiana and Wisconsin. Seventy-eight
percent of the occurrences are in the Lake Michigan basin, with one
occurrence (\<1 percent) in the Lake Superior basin and the remainder
(21 percent) in the Lake Huron basin. Sixty (35 percent) extant
populations are entirely in public ownership, 42 occurrences (24
percent) cover adjoining public/private lands, and 71 (41 percent) occur
on private lands. Most occurrences are considered to be of moderate
quality; most high quality sites are on public lands or a combination of
public and private ownership, while most low quality occurrences are
found on private lands (USFWS 2002b). Most of the high quality sites are
found in Michigan.

A majority of the 173 extant occurrences, 60 percent (96), are on simple
linear dunes, 14 percent (23) on complex continuous dunes; 18 percent
(29) on complex discontinuous dunes; and only 8 percent (12) on perched
dunes. Occurrences on larger dune systems (i.e., perched and complex
continuous), are generally higher quality than the occurrences on simple
linear and complex discontinuous dune types. Nevertheless, high quality
occurrences exist for each dune type.

# Environmental Baseline

This section describes the species status and trend information within
the [action area]{.underline}. It also includes State, tribal, local,
private actions already affecting the species or that will occur
contemporaneously with the proposed action. Unrelated Federal actions
that have completed formal or informal consultation are also included in
the environmental baseline.

[Status of the Species within the Action Area]{.underline}

There are three known populations of Pitcher's thistle within the action
area; two on HMNF and one on private lands. There are approximately 660
ac (267 ha) of potential Pitcher\'s thistle habitat on HMNF lands (Rex
Ennis, HMNF, pers. comm. 2003) and an additional 100 ac (41 ha) of
unoccupied potential habitat on two blocks of private land, one being
just north of the Lake Michigan Recreation Area and the other being a
much longer shoreline north to the Manistee NF boundary (Rex Ennis,
HMNF, pers. comm. 2003). The two Pitcher\'s thistle populations within
Manistee NF\-- Big Sable Point and Cooper Creek Dunes\-- occur in Mason
County in areas designated Critical Dune Areas by Michigan Department of
Environmental Quality (USFWS 2002b; MSA 13a35301).

The Big Sable Point population is within the Nordhouse Dunes Wilderness
(MA 5.1). It is one of the largest worldwide (\>5000 individuals) and
has an excellent habitat ranking of A, the highest possible rank. The
Cooper Creek population is located approximately five miles to the north
along the Lake Michigan shoreline outside of the wilderness in MA's 4.2
and 4.3 and is ranked CD, fair to poor, with significant human
disturbance and fewer individuals.

The third population, Au Sable Point, is located on private property
within the Huron NF proclamation boundary in Iosco County. This is a
slightly smaller population with 500 to 5,000 individuals, on good
habitat, with some human disturbance, and has a B ranking.

The federally-owned populations are periodically monitored by the HMNF
(USDAFS 1996; O'Connell and Stephens 2002). The objectives of the
monitoring project are to track population trends and age class changes
over time and monitor changes in the habitat to determine if these
changes were due to the type or amount of recreational use, or other
threats (O'Connell and Stephens 2002). There appears to be a correlation
between the amount of bare ground and the presence of the Pitcher's
thistle. The Pitcher's thistle is least abundant in the most stable,
vegetated zones of its habitat. Monitoring data indicate that the total
number of Pitcher's thistle plants increased by approximately 86 percent
(751 to 1401) from 1993 to 1996 and then decreased by 58 percent (1401
to 751) from 1996 to 2001; this resulted in a total decreased of 21
percent (751 to 596) from 1993 to 2001 (O'Connell and Stephens 2001).

Although the reasons for dramatic shifts in population size are not
fully understood, it is likely that a variety of factors play a role in
the population dynamics of this species. As previously discussed, the
long-term persistence of Pitcher\'s thistle depends on the natural
disturbance and variability of dune habitats. Parts of a population may
be lost due to natural dune accretion and erosion, yet seed germination
and population expansion requires the early successional habitat created
by these processes (O'Connell and Stephens 2002; USFWS 2002b). Based on
these dynamics, some natural amount of variability within a population
is expected. Pitcher\'s thistle populations on the HMNF are impacted by
invasions of non-native, invasive plants. Lombardy poplar is the primary
concern for the Pitcher\'s thistle because it is a dune stabilizer,
known to inhibit the natural dune accretion and erosion processes
(O'Connell and Stephens 2002). Recreational use, specifically trampling
from foot traffic, has also been observed in the action area. Trampling
damages the rosettes and flowering plants and may cause seedbed
destabilization (McEachern et al. 1989). The higher use areas at the day
use area and campground at Lake Michigan Recreation Area, where the
Cooper Creek population occurs, are especially vulnerable (O'Connell and
Stephens 2002). Based on the interactions of these factors, Pitcher\'s
thistle populations on HMNF lands may regularly cycle up and down
(O'Connell and Stephens 2002).

[Factors Affecting the Species Within the Action Area]{.underline}

-   First Implementation of the LRMP, 1986

The LRMP for the HMNF was first implemented in 1986. The LRMP underwent
formal section 7 consultation upon its implementation. During this time,
the Pitcher's thistle was listed as a category 1 candidate species, and
not yet recognized as federally threatened. In the LRMP, however, the
HMNF committed to including the Pitcher\'s thistle in its future formal
consultations for actions that may affect the species. Since this time,
no projects requiring formal consultation have been proposed.

-   Informal Consultations

Since the listing of Pitcher's thistle in 1988 as a federally threatened
species, the HMNF has consulted with the Service on actions that may
affect the Pitcher's thistle. The outcome of these consultations was "no
effect" or "may affect, not likely to adversely affect." These
determinations were reached through the following project conditions: 1)
the Pitcher's thistle was not present in the project area or affected in
any way or 2) the action had completely beneficial effects on the
species by maintaining natural dune processes required for its long-term
persistence in the project area. We believe that the use of these
conservation and avoidance measures in each individual project has
cumulatively, for all projects, maintained or improved the status of
this species in the action area by reducing the potential adverse
effects to the Pitcher\'s thistle and improving potential Pitcher\'s
thistle habitat on the HMNF.

-   State Actions

Under the State of Michigan's Natural Resources and Environmental
Protection Act of 1994, sand dune regulations protect areas that have
been designated as "Critical Dune" habitats (MSA 13a.35301). In Critical
Dune areas, actions that may alter or otherwise adversely affect the
habitat (e.g., sand mining, waste disposal, development) are severely
restricted or prohibited. While these regulations provide significant
protections for Pitcher\'s thistle habitat state-wide, they do not apply
to all Pitcher\'s thistle habitat.

Both the Big Sable and Cooper Creek Pitcher\'s thistle populations on
the HMNF are in designated critical dune habitat. The privately owned
Pitcher\'s thistle habitat in the action area, the Au Sable point
population and the two reaches of unoccupied potential habitat on the
Manistee NF, are not subject to State dune regulations and are therefore
not as well protected. These areas have been impacted by human
activities including roads and development. The Au Sable point
population has been less impacted and still maintains relatively
high-quality Pitcher\'s thistle habitat. The quality of the private
lands within the Manistee NF and their suitability as Pitcher\'s thistle
habitat, however, has been diminished.

-   Other natural and human caused factors (also see discussion under
    Status of the Species in the Action Area).

Populations of Pitcher\'s thistle and unoccupied suitable habitat within
the action area are impacted by invasions of exotic plants. Lombardy
poplar is present within Pitcher's thistle habitat and within the
project area. Lombardy poplar is known to inhibit the natural dune
process by stabilizing the dunes. Spotted knapweed is known to spread
with increased disturbance. The extent and severity of these effects
within the action area has not been quantified (O'Connell and Stephens
2002).

Recreational use, specifically trampling from foot traffic has also been
observed in the action area. Trampling damages the rosettes and
flowering plants and may cause seedbed destabilization (McEachern et al.
1989). The higher use areas, including the Cooper Creek population and
the private unoccupied potential habitat on the Manistee NF are
especially vulnerable to these types of impacts (O'Connell and Stephens
2002). The extent and severity of these effects within the action area,
however, have not been well documented (O'Connell and Stephens 2002).

######## Summary and Synthesis of the Environmental Baseline

The three populations of Pitcher\'s thistle within the action area are
variable in size and condition. The Big Sable population is one of the
largest range-wide and is the largest and highest quality Pitcher\'s
thistle population in the action area. This population has suffered the
fewest impacts due to its location in the Nordhouse Dunes Wilderness
Area where most HMNF activities are under significant restrictions. The
Cooper Creek population is relatively smaller and more impacted because
it falls in MAs 4.2 and 4.3 which have fewer activity restrictions.
Plant numbers in these populations have fluctuated, but generally
decreased in recent years. The Au Sable Point population is also
relatively smaller, but has had fewer impacts and is in better condition
than Cooper Creek. The Au Sable population, however, is privately owned
and outside of the direction of the HMNF; there are no data available
regarding population numbers and trends of this population.

Potential impacts from various HMNF activities have been significantly
reduced by the implementing conservation measures to minimize and avoid
adverse impacts. Overall, however, it is likely that impacts from human
development, recreational activities, and invasive exotic species have
affected and continue to adversely affect the Pitcher\'s thistle within
the action area. This is especially evident in the Cooper Creek
population which is characterized by low plant numbers and poor habitat
quality. Therefore, we believe that the status of the Pitcher's thistle
has declined within the action area.

## Effects of the Action

This section assesses the effects of the proposed action, including the
direct and indirect effects together with the effects of other
activities that are interrelated or interdependent (50 CFR 402.02).
Indirect effects are those that are caused later in time, but are still
reasonably certain to occur. Interrelated actions are those that are
part of a larger action and depend upon the larger action for their
justification. Interdependent actions are those that have no independent
utility apart from the action under consideration (50 CFR 402.02).

######## Analysis of the Effects of the Action

The following management actions in the LRMP that will have [no
effect]{.underline} or are [not likely to adversely affect]{.underline}
the Pitcher's thistle.

-   *Range Management*

The four active grazing allotments on the HMNF are not within Pitcher\'s
thistle habitat. Range management activities will have no effect on the
Pitcher\'s thistle because dune habitat does not provide suitable
grazing pasture or hay cutting material.

-   *Timber Management*

All timber management activities are performed outside of dune habitats.
Therefore, timber management will not effect on the Pitcher\'s thistle.

-   *Watershed Management*

Watershed management activities are prohibited in occupied or potential
Pitcher\'s thistle habitat. Therefore, watershed management activities
will not effect on the Pitcher\'s thistle.

-   *Wildlife, Fish, and Sensitive Plant Management*

Management actions for wildlife, fish, and sensitive plants for most
species are not used in dune habitats and will therefore have no effect
on the Pitcher\'s thistle. Management activities undertaken for the
Pitcher\'s thistle (i.e., removal of exotic species, access
restrictions) would have beneficial effects for this species.

-   *Minerals and Geology*

Strict State and Federal laws regulate all resource extraction in dune
habitats on the HMNF. Surface occupancy for resource extraction is
prohibited under the following circumstances: 1) within 300 ft (92 m) of
Lake Michigan, 2) in State-designated Critical Dune habitat, and 3) in
the Nordhouse Dunes Wilderness Area, and 4) in any occupied Pitcher\'s
thistle habitat. These restrictions cover all Pitcher\'s thistle habitat
on the HMNF, therefore there will be no effect on this species.

-   *Forest Pest Management*

Removal of problem exotic species (i.e., spotted knapweed and Lombardy
poplar) will be done by hand, which will have beneficial effect for the
Pitcher\'s thistle. The application of pesticides (includes
insecticides, herbicides, and other chemical or biological controls) for
pest control is prohibited in occupied Pitcher\'s thistle habitat. Pest
management activities in dune habitats, by any means, require an
environmental analysis, including section 7 consultation, to address any
potential effects on listed species. We expect that since the HMNF
determined that pest management in not likely to adversely affect this
species, this environmental analysis and consultation would preclude any
adverse effects from pest management activities. Therefore, use of
pesticides will have no effect, beneficial effects, or effects that are
insignificant or discountable.

-   *Fire Management*

Fire management activities on the HMNF are focused on areas with a high
fuel hazard (i.e., forested areas) or are areas targeted for Karner blue
butterfly habitat restoration. The Pitcher\'s thistle is not found in
either of these habitat types. Wildfires (natural or human caused),
while possible, are typically rare in dune habitats. Therefore,
potential effects of fire management will have no effect on Pitcher\'s
thistle, or result in discountable effects.

-   *Transportation System*

Currently, there are no roads for motorized use in the dune areas with
Pitcher\'s thistle. Furthermore, roads are prohibited in the Nordhouse
Dunes, in the Research Natural Area, and in dune habitats that provide
habitat for the Pitcher\'s thistle. Roads that provide access into
Pitcher\'s thistle habitat, however, may indirectly affect this species
by increasing human disturbance and introduction of invasive exotic
species. These effects, however, have been greatly reduced or avoided
because the HMNF has eliminated road access into occupied Pitcher\'s
thistle areas. Future impacts will be further minimized because there
are only two indirect access points that provide only foot traffic
access. Therefore, transportation will either have no effect or result
in effects that are insignificant or discountable.

-   *Recovery Plan Actions Addressed by the LRMP*

The continued implementation of the LRMP will also have [beneficial
effects]{.underline} for the Pitcher\'s thistle by contributing to the
following recovery plan action items for the Pitcher\'s thistle (USFWS
2002b):

*Recovery Plan Action 1. Protect and manage known occurrences and
essential habitat.*

> The HMNF will continue to protect and manage Pitcher\'s thistle
> habitat on HMNF lands. The HMNF will develop, implement, and evaluate
> restoration for dune habitat and Pitcher\'s thistle populations where
> necessary.

Recovery Plan Action 2. Establish and conduct regular field surveys to
verify known and record new occurrences.

The HMNF will identify coastal areas for further investigation for
occurrences of Pitcher\'s thistle.

> *Recovery Plan Action 3. Inform the public, recreationists, public
> land managers and private landowners.*
>
> The HMNF will develop an educational program and provide and place
> materials to inform the public about conservation of the Pitcher\'s
> thistle and other listed shoreline species.

Recovery Plan Action 4. Monitor occurrences for stable or increasing
trends and implementation of protective plans.

> The HMNF will continue monitoring on a five-year interval unless
> monitoring indicates that threats to Pitcher's thistle habitat
> requires more frequent intervals.
>
> *Recovery Plan Action 6. Conduct research necessary for protection,
> management and restoration.*
>
> The HMNF will evaluate cause and effect relationships for population
> declines, develop restoration protocols, and study long-term
> metapopulation dynamics.

Note that for the management actions discussed above, if through Level 2
consultation we determine that these management actions will adversely
affect the Pitcher's thistle, reinitiation of section 7 consultation at
the programmatic level (i.e., reinitiation of this Level 1 consultation
and Opinion) will be required.

The following management actions in the LRMP are [likely to adversely
affect]{.underline} the Pitcher\'s thistle.

-   *Recreation and Related Resource Management*

Recreational activities, such as off-trail foot traffic and camping, are
likely to adversely affect the Pitcher\'s thistle. Adverse effects
include erosion of dune habitat, seed bed disturbance, and crushing or
loss of individual Pitcher\'s thistle plants. These potential impacts
are most likely to occur in the Lake Michigan Recreation Area (Cooper
Creek population), versus the Nordhouse Dunes (Big Sable population),
because there is a higher concentration of visitors and fewer
restrictions on recreational activities. Since recreational activities
will still occur, the potential for adverse impacts will remain;
however, the HMNF has committed to managing recreational activities in
Pitcher\'s thistle habitat to avoid and minimize potential adverse
effects by limiting foot traffic, posting signs and educational
information, and increasing law enforcement to protect plants.
Therefore, we do not believe that this management actions will not
threaten the long-term survival of either population.

In summary, the proposed action along with the conservation measures
that the HMNF has committed to are expected to avoid or reduce the
potential for direct or indirect impacts to the species throughout its
range on the HMNF. The Pitcher\'s thistle will also benefit from many
actions. Nonetheless, habitat alteration and loss or damage to
Pitcher\'s thistle plants from the recreational activities on the HMNF
will occur. Given the HMNF's commitment to manage and restrict
recreational activities, however, the potential take is not anticipated
to impair the survival and recovery of the Pitcher\'s thistle population
within the action area.

We are not aware of any actions that are interdependent or interrelated
to the proposed action being considered in this Opinion.

######## Cumulative Effects

Cumulative effects include the combined effects of any future State,
local, or private actions that are reasonably certain to occur [within
the action area]{.underline} covered in this Opinion. Future Federal
actions that are unrelated to the proposed action are not considered in
this section because they require separate consultation pursuant to
section 7 of the Act.

Potential cumulative effects could occur in the Au Sable Point
Pitcher\'s thistle population and in the other areas of private
ownership on the Manistee NF. Human activities, including development,
recreation, and roads to the shoreline are present and may be expected
to continue in these areas. If performed in Pitcher\'s thistle habitat,
these activities may have a progressive negative impact on the species
within the action area. The Au Sable Point population is vulnerable to
sand mining and other resource extraction activities because it is
located on lands not protected by State (Critical Dune designation) or
Federal (HMNF restrictions) regulations. It is possible that resource
extraction activities may adversely affect the Pitcher\'s thistle,
however, as we have no evidence that these activities are reasonably
certain to occur, we cannot factor such actions into our analysis of
jeopardy for this species.

Many of the previously described actions would require a Federal permit
under section 404 of the Clean Water Act, as administered by the U.S.
Army Corps of Engineers, and may be subject to future section 7
consultation. In these cases, the impacts to the species will the
addressed during those consultations.

Given that a significant area of Pitcher\'s thistle habitat within the
action area is federally-managed (660 ac, 267 ha), the positive effects
of the proposed action should help offset negative effects of
non-Federal activity in the action area. We expect that the net
long-term cumulative effect of the protective measures and management
activities in the action area should provide a net benefit to the
species.

Conclusion

After reviewing the current status of the Pitcher\'s thistle, the
environmental baseline for the action area, the effects of the proposed
action, and the cumulative effects, it is our biological opinion that
the action, as proposed, is not likely to jeopardize the continued
existence of the Pitcher\'s thistle. No critical habitat has been
designated for this species; therefore, none will be affected.

There are likely to be adverse effects to the Pitcher\'s thistle in the
action area as a result of recreational activities. These adverse
effects are expected to be in the form of habitat degradation and take,
including crushing or loss of individual plants, resulting primarily
from foot traffic and trampling. The HMNF has committed to avoiding or
reducing these impacts by limiting and managing foot traffic in dune
habitats as necessary. We believe that, while this level of adverse
effects remains, the proposed action taken together with cumulative
effects is not reasonably expected to, directly or indirectly, reduce
appreciably the likelihood of both the survival and recovery of the
Pitcher\'s thistle in the wild by reducing the species' reproduction,
numbers, or distribution within the action area.

The following factors, among others, were important in our assessment of
jeopardy:

-   The Pitcher\'s thistle populations in the action area comprise only
    3 of the 195 known extant occurrences of the species in the United
    States and Canada.

-   Efforts will be made to manage and minimize the potential adverse
    effects of recreational activities on the HMNF to extent that the
    range-wide population potential will not be adversely impacted,
    despite possible loss of individual plants.

-   Efforts will be made to control and minimize the impact of invasive
    exotic species in Pitcher\'s thistle habitat.

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-   For non-recreational management activities, the proposed
    conservation measures will avoid or reduce the potential impacts to
    the Pitcher\'s thistle and its habitat on the HMNF, so that they are
    likely to only result in beneficial, insignificant, or discountable
    effects.

-   The continued implementation of the LRMP will assist with achieving
    the recovery objectives for the Pitcher\'s thistle.

Although we believe adverse effects will occur as a result of the
proposed action, the effects are not likely to significantly affect the
population viability within the action area. Therefore, we believe that
continued implementation of the LRMP will not appreciably reduce the
likelihood of the range-wide survival and recovery of the Pitcher\'s
thistle.

Incidental Take Statement

Section 9 of the Act, as amended, prohibits any taking of listed species
without special exemption. Sections 7(b)(4) and 7(o)(2) of the Act
exempts taking that is incidental to and not intended as part of an
agency's action, as long as that taking complies with the terms and
conditions of an Incidental take statement.

Sections 7(b)(4) and 7(o)(2) of the Act, however, generally do not apply
to listed plant species. Protection of listed plants is provided to the
extent that the Act requires a Federal permit for removal or reduction
to possession of endangered plants from areas under Federal
jurisdiction, or any act that would remove, cut, dig up, or damage or
destroy any such species on any other areas in knowing violation of any
regulation of any State or in the course of any violation of a State
criminal trespass law. Regulations (50 CFR 17.71) extend protection to
threatened plants as well, but with limitations. As Pitcher's thistle is
currently listed as threatened under the Act, any take resulting from
the proposed action would not require the Section 7(o)(2) exemption
provided by an incidental take statement.

Conservation Recommendations

Section 7(a)(1) of the Act directs Federal agencies to utilize their
authorities to further the purposes of the Act by carrying out
conservation programs for the benefit of endangered and threatened
species. Conservation Recommendations are discretionary agency
activities to minimize or avoid adverse effects of a proposed action on
listed species or critical habitat, to help implement recovery plans, or
to develop information.

We believe that the HMNF has already initiated or participated in
important efforts to protect, manage, and increase our understanding of
the Pitcher\'s thistle, including their commitment to implement the
Conservation Measures in the proposed action. We offer the following
Conservation Recommendations to further expand the knowledge of this
species, and help better manage for the Pitcher\'s thistle in Michigan.

-   Where appropriate, consider redesigning trails using measures such
    as markers, boardwalks, or other appropriate means to reduce the
    effects of recreational use, particularly foot traffic, on
    Pitcher\'s thistle populations and potential habitat.

-   Continue information and education (e.g., signs and kiosks) at
    Pitcher\'s thistle sites to inform the public about conservation and
    protection of the species.

-   Take action to protect and improve habitat conditions and avoid or
    minimize adverse effects on Pitcher\'s thistle on private land
    within or adjacent to the HMNF by a) adopting an education program
    which includes landowner contacts, b) seeking opportunities to
    develop information on presence of Pitcher\'s thistle on private
    land where owners are willing, and c) seeking opportunities,
    especially through partnerships, to help fund and carry out
    beneficial habitat management on private lands of willing owners.

The Service recognizes that these Conservation Recommendations may
require long-term efforts by the HMNF and does not expect their
implementation to be confined to or completed within the time period of
this consultation. In order for the Service to be kept informed of
actions minimizing or avoiding adverse effects or benefiting listed
species or their habitats, we request notification of the implementation
of any conservation recommendations.

**REINITIATION NOTICE**

This concludes formal consultation on the actions outlined in the
request. As provided in 50 CFR 402.16, reinitiation of formal
consultation is required where discretionary Federal agency involvement
or control over the action has been retained (or is authorized by law)
and if: 1) the amount or extent of incidental take is exceeded; 2) new
information reveals effects of the agency action that may affect listed
species or critical habitat in a manner or to an extent not considered
in this Opinion; 3) the agency action is subsequently modified in a
manner that causes an effect to the listed species or critical habitat
not considered in this Opinion; or 4) a new species is listed or
critical habitat designated that may be affected by the action. In
instances where the amount or extent of incidental take is exceeded, any
operations causing such take must cease pending reinitiation.

Applicability of this Opinion to Site Specific Projects

We believe that the scope of effects for specific projects developed
through the continued implementation of the LRMP on the HMNF falls under
the umbrella of this consultation for the following reasons:

1.  The terms and conditions associated with the reasonable and prudent
    measures outlined in this Opinion will minimize the impact of the
    incidental take identified for the Indiana bat and Karner blue
    butterfly on both a programmatic level and for individual projects
    yet to be identified.

2.  If after adhering to the terms and conditions associated with the
    reasonable and prudent measures outlined in this Opinion, the HMNF
    determines that activities on a project level are likely to
    adversely affect the Karner blue butterfly or Indiana bat, the
    Service requests that formal consultation be initiated.

3.  Any individual project that exceeds the level of incidental take
    identified in this Opinion would necessitate reinitiation of formal
    consultation as previously outlined.

4.  The HMNF will continue to conduct site-specific project analyses to
    ensure that each individual action follows recommendations set forth
    in this Opinion.

5.  The Service will continue to review all site-specific projects to
    ensure that, as appropriate, there is strict adherence to the terms
    and conditions associated with the reasonable and prudent measures
    outlined in this Opinion and that incidental take levels identified
    in this Opinion are not exceeded.

**REFERENCES**

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**ABBREVIATIONS**

°C Degrees Celsius

°F Degrees Fahrenheit

ac Acres

Act Endangered Species Act

AUM Animal Unit Month

BA Biological Assessment

CFR Code of Federal Regulations

cm Centimeter

DNR Department of Natural Resources

FERC Federal Energy Regulatory Commission

FMZ Fire Management Zone

FR Federal Register

FY Fiscal Year

g Gram

ha Hectares

HMNF Huron-Manistee National Forests

in Inch

km Kilometer

LRMP Land and Resource Management Plan

LTA Landtype Association

m Meter

MA Management Area

MDEQ Michigan Department of Environmental Quality

MDNR Michigan Department of Natural Resources

MI Michigan

mm Millimeters

MNFI Michigan Natural Features Inventory

MRVD Thousand Recreation Visitor Days

NEPA National Environmental Policy Act

NF National Forest

ORV Off-road Vehicle

PCE Primary Constituent Elements

RNA Research Natural Area

Service U.S. Fish and Wildlife Service

TMZ Tippy Management Zone

TNC The Nature Conservancy

USDAFS United States Department of Agriculture -- Forest Service

USGS United States Geological Service

[^1]: In this Biological Opinion, the term "lupine" will refer to
    *Lupinus perennis* to the exclusion of all other con-generic
    species.