United States Department of the
Interior![](media/image1.png){width="1.0166666666666666in"
height="1.038888888888889in"}![](media/image2.png){width="0.9194444444444444in"
height="1.0930555555555554in"}

Fish and Wildlife Service

Bloomington Field Office (ES)

620 South Walker Street

Bloomington, IN 47403-2121

Phone: (812) 334-4261 Fax: (812) 334-4273

June 2, 2006

James E. Denoncour

District Ranger

Hoosier National Forest

811 Constitution Ave.

Bedford, IN 47421

**RE: Proposed hazard trees (3) removal from Celina Lake campground**

Dear Mr. Denoncour:

This letter is in response to your May 30, 2006 letter (received June 1,
2006) notifying the Bloomington Field Office of the Unites States Fish
and Wildlife Service (BFO) of your intention to remove three (3) hazard
trees from the Celina Lake campground. BFO issued a programmatic
Biological Opinion (BO) and Incidental Take Statement (ITS) on January
3, 2006 for the implementation of the Hoosier National Forest's (HNF)
Land and Resource Management Plan. The BO analyzed anticipated effects
from management activities on bald eagles (*Haliaeetus leucocephalus*),
Indiana bats (*Myotis sodalis*), gray bats (*Myotis grisescens*), rough
Pigtoe pearly mussel (*Pleurobema plenum*), and the fanshell mussel
(*Cyprogenia stegaria*).

It has been determined that these trees pose a safety hazard to those
who use and maintain the campground. It has furthermore been determined
by Clark McCreedy (HNF Wildlife Biologist) that one (1) tree, a live
pignut hickory, has no potential as an Indiana bat roost tree. The other
two (2) trees, one (1) dead black oak and one (1) dead red oak, have
potential as Indiana bat roost trees. These trees will have emergence
counts performed on them before being removed. Your letter states that
if Indiana bats are encountered, you will promptly notify BFO. We have
two (2) clarifications to make in regard to this action: please notify
us of *any* bats identified during the emergence counts, as Indiana bats
are difficult to distinguish from other bats using this survey
technique; and, if no bats are detected during emergence counts, please
promptly remove the hazard trees the very next morning in order to
insure that bats do not begin too utilize the tree after the emergence
count has been conducted.

We understand that this action (hazard tree removal) is necessary to
ensure the safety of HNF visitors and employees alike. We further
understand the level of commitment the HNF has demonstrated in the
protection of threatened and endangered wildlife in relation to forest
management. We believe that the proposed project is not likely to
jeopardize the continued existence of the Indiana bat and that the
anticipated effects and resulting level of incidental take are
consistent with those analyzed in the programmatic BO. Anticipated
effects from hazard tree removal are discussed on page 36 of the BO.

The amount of incidental take (in the form of harm through habitat
loss/alteration) of Indiana bats from this project is **three (3)
trees**. This project brings the cumulative total of trees removed under
*Hazard tree Removal* to three (3) trees out of 600 trees originally
anticipated for this management activity in the programmatic BO. The
available balance of anticipated trees/acreage for each management
activity in which incidental take is be tracked is also shown on the
attached spreadsheet. The Service (BFO) concurs that the attached
spreadsheet is complete and accurately reflects anticipated impacts of
the proposed project without exceeding anticipated levels of incidental
take.

To be in compliance with the ITS of the programmatic BO and to obtain
exemption from the section 9 prohibitions of the Endangered Species Act
(ESA) of 1973, the Forest Service must adhere to the Reasonable and
Prudent Measures (RPMs) and Terms and Conditions (T&Cs) identified in
the January 3, 2006 programmatic BO.

To ensure that the impacts of take associated with this project are
appropriately minimized and that the exemption of incidental take
appropriately documented, the Forest Service and Fish and Wildlife
Service are using an 'appended' programmatic consultation approach.
After assessing the anticipated effects of the proposed project, we
concur they are within the scope of the programmatic BO and we agree to
append the Forest Service's May 30, 2006 letter and spreadsheet along
with this response letter to the programmatic BO and label them as
"Appendix 1".

This precludes the need for further consultation on this individual
project as required under section 7 of the ESA, as amended. If, however,
new information on endangered species within the proposed project area
becomes available, or, if significant changes are made to the proposed
project, then please contact Michael Tosick at (812)334-4261, ext. 218
fro further consultation.

Sincerely,

Scott E. Pruitt

Field Supervisor