**United States Department of the Interior**

FISH AND WILDLIFE SERVICE

1500 Museum Road, Suite 105

Conway, Arkansas 72032

Tel.: 501/513-4470 Fax: 5011513-4480

> IN REPLY REFER TO:

March 21,2002

Mr. Steve Best

Ozark-St. Francis National Forest

*605* West Main Street

Russellville, AR 72801

Dear Mr. Best:

This letter constitutes an amendment to the June *25,* 1998, Biological
Opinion (BO) on the Effects of Management Activities Conducted by
Ozark-Saint Francis National Forest (ONF) on the Indiana Bat. The Fish
and Wildlife Service (Service) has received your letter requesting
reinitiation of consultation and your proposal "The Role of Fire in
Restoring the Forest Ecosystem on the Ozark-St. Francis National Forest"
(Plan 2001) to modify ONF's prescribed fire plan. The ONF proposes to
increase the cap on the number of acres burned from 30,000 to 153,000
annually. Our comments are submitted in accordance with the Endangered
Species Act (87 Stat. 884, as amended 16 U.S.C. 1531 et seq.). This
information is based on data provided in the Plan from the ONF that
analyzed the affects of increasing the number of acres burned annually
on IBs.

Due to new information on Indiana Bat (IB) habitat requirements, life
history, and Service Consultation Guidance (2001), the Service is
requesting reinitiation of consultation on some forest management
practices in addition to the ONF request for reinitiation on prescribed
fire practices. The changes we are recommending are important to the
conservation of the IB and we would like to work with the ONF to
incorporate them into your management practices. After meeting with the
ONF on January 28, 2002 to discuss the feasibility of implementing the
Service's recommendations contained in our January 17, 2002, letter, the
following conditions were agreed upon by both agencies. The ONF has
further agreed that management practices implemented after the date the
Service signs this letter, will incorporate the guidelines set forth in
this amendment.

> The current programmatic BO addresses the potential affects of various
> even-age and uneven age timber harvest techniques, sales, salvage and
> firewood sales, routine road construction/reconstruction, herbicide
> applications, routine maintenance and clearing of roads and small
> openings, prescribed fire, and mineral exploration. Other activities
> that may require minor timber removal which were also addressed
> include management of recreation areas,
>
> range management, and wildlife management activities. Land exchanges
> are another ONF activity and it was determined that these activities
> would require an individual biological evaluation. The HO authorized
> the use of prescribed fire for up to 30,000 acres annually. These
> burns are conducted for fuel reduction, wildlife and rare species
> management, site preparation, and ecosystem restoration. In the HO,
> the affects from prescribed burning on IBs were determined to include
> direct mortality or injury due to the actual roost tree being
> incinerated or death of individuals caused by smoke inhalation.
> Indirect effects were identified as removal of living trees or snags
> which have the potential to serve as roosts for maternity colonies or
> individual bats, and reduction of the density of mature trees and
> overstory canopy which could result in the loss or alteration of the
> summer and prehibernation habitat. The HO concluded that the above
> mentioned activities are not likely to jeopardize the continued
> existence of the LB. However, it was determined that even with the
> implementation of the ONF standard guidelines, the Reasonable and
> Prudent Measures and the Term and Conditions there was still the
> potential for incidental take. An incidental take statement was issued
> to the ONF concurrently with the issuance of the HO.
>
> The ONF is presently requesting that the cap on the number of acres
> that may be burned on an annual basis be increased from 30,000 to
> 153,000. The request for this increase is a result of numerous factors
> including ecosystem restoration. ONF's Plan states that the forest of
> the past looked much different than that of today. The current
> condition of ONF is largely even-aged and uniformly physiologically
> mature. Over 75 percent of the forest is over 61 years of age or older
> according to the Continuous Inventory of Stand Conditions Database
> conducted by the ONF. Findings in the Ouachita-Ozark Highlands
> Assessment (OOHA) indicate that the impact of lighting-caused and
> aboriginal burning in the pre-settlement forest likely produced
> "park-like" stands with open, grassy understories and more
> widely-spaced overstories. OOHA found that the mean fire interval
> between 1620 to 1850 was an average of 11 years. The suites of flora
> and fauna that characterized the landscape were adapted to, or even
> dependent on periodic, low-intensity fires. Approximately 29 percent
> of ONF is xeric pine and pine-oak forest and woodland, 66 percent is
> in dry-mesic oak forest, and 3 percent of dry and dry-mesic oak-pine.
> Fire plays an important and historical role in maintaining the
> composition and structure of all these community types.
>
> The actions proposed in the ONF Plan are needed in conjunction with a
> variety of vegetation management strategies and practices to
> accomplish ecosystem restoration. The use of prescribed fire to
> restore and maintain oak ecosystems has been advocated by multiple
> researchers (Plan 2001). Prescribed fire can help maintain valuable
> timber arid mast producing oak forest by giving oak reproduction the
> competitive advantage over other species. The ONF proposes to increase
> the amount of acres burned to allow for fire-return intervals
> consistent with the ecological requirement of fire adapted species,
> one of the fire adapted species being

\_\_\_ the IB. Summer habitat for IBs consists of riparian and upland
forest for roosting and foraging. They prefer large frees (9 inches or
larger at dbh) in the open or on edges, they seem to prefer open
canopies (canopy cover ranges from 60-80 percent), fragmented forest
landscapes, and forest with open understory (US Fish & Wildlife 1999).
To achieve this habitat type, multiple management practices should be
implemented including prescribed fire.

> In addition to ecosystem restoration, prescribed burning can
> significantly change fuel types, fuel loading, fuel arrangement and
> flammability. Increasing the amount of acres burned annually will
> lessen the threat of catastrophic fires, reduce the risk of injury to
> firefighters, mitigate impacts of wildfires in urban interface,
> provide a higher level of public safety, and reduce wildfire
> suppression cost.
>
> Sections 4(d) and 9 of the ESA, as amended, prohibit take (harass,
> harm, pursue, hunt, shoot, wound, kill, trap, capture or collect, or
> attempt to engage in any such conduct) of listed species of fish or
> wildlife without a special exemption. The HO established that an
> undeterminable number of IBs, which may be within the identified
> action areas, may be taken. The action areas included prescribed fire
> disturbance of up to 30,000 acres of potential lB habitat per year. As
> a result of the ONF's proposed Plan of increasing the number of acres
> that may be prescribe burned to 153,000 annually, the amount and
> extent of incidental take needs to be revised. As stated in the
> existing HO, the Service anticipates that incidental take of IB as a
> result of forest management activities, will be difficult to quantify
> and detect, and monitoring of take will be a complex and difficult
> task due the reasons set forth in the HO. The Service has concluded
> that this will continue to be the case. However, the level of take can
> be anticipated by the amount of potential roosting habitat affected.
> Therefore, an annual loss of an indeterminate number of roost trees
> and potential roost trees, from no more than the acreage for timber
> harvest set forth in the HO, and no more than 153,000 acres of
> prescribed fire, as set forth in this amendment, of potential LB
> habitat per year.

The current Reasonable and Prudent Measures, and Terms and Conditions in
the HO still need to be adhered to except when specifically overridden
by the new Reasonable and Prudent Measures, and Terms and Conditions.
Below are the new Reasonable and Prudent Measures, and Terms and
Conditions that are necessary and appropriate to minimize take of the
IBs. The Reasonable and Prudent Measures are mandatory actions that the
Service believes are necessary and appropriate to minimize impacts to
the IB. The Terms and Conditions implement the Reasonable and Prudent
Measures and outline the required reporting/monitoring requirements. We
have also included additional Conservation Recommendations. Conservation
Recommendations are discretionary measures to minimize or avoid adverse
effects of an action on listed species.

## Discussion

New research has determined that IB's dispersal distance from known
hibernacula differs depending on the time of year. Fall swarming outside
hibernaculum occurs from October to November *15.* Movement during this
time for males is a *5* mile radius and for females is a *1.5* mile
radius around hibernacula (US Fish & Wildlife Service 1999 and US Fish &
Wildlife Service 2001). Foraging areas during October can range from 479
to 786 acres (ITS Fish & Wildlife Service 1999 and US Fish & Wildlife
Service 2001). Emergence from hibernacula occurs from April through May.
Movement in spring can reach a 10 mile radius from roost sites for males
and females. Maternity colonies are present from mid-May to the end of
July. So, from April *15* to November 15, the area immediately adjacent
to the hibernaculum is used heavily by lB's. For this reason, a baseline
buffer of a *0.25* mile radius should be maintained (US Fish & Wildlife
Service 1999). It should be kept in mind that there may be multiple cave
entrances and these recommendations apply to each entrance. However,
this does not mean that no disturbance activities can occur in this
area, rather, appropriate disturbance activity should be conducted
outside of April 15 to November 15 to manage the area for IBs. Habitat
management is an important tool in this 0.25 mile radius area. So we
reiterate that we are not advocating elimination of disturbance
activity, but modifying the time frame in which disturbance activities
should occur.

The optimal foraging and roosting habitat for IBs are an open midstory
and an overstory canopy of 50 to 70 percent and 60 to 80 percent,
respectively (US Fish & Wildlife Service 1999, Review and Daniel Boone
NF). The suitability of a given area as roosting habitat declines
slightly as canopy closure increases from 80 to 100 percent, and also
declines as canopy closure falls below 60 percent (Menzel etal. 2001).
Most primary maternity roosts are well exposed to extensive solar
radiation. However, some are completely shaded or totally exposed
(Menzel et al. 2001). Brack (1983) found that the probability of
capturing an IB in a mist net increased if habitat was riparian,
understory density was low, overstory species richness was high, and
understory species richness was low. However, this should be interpreted
with caution due to the disparity that may be a result of the lack of
distinction between the capture rate probability rather than actual
differences in habitat use. To provide these habitat types ONF should
strive to maintain, a landscape scale average of 50 to 80 percent canopy
within the 5 mile radius of a hibernaculum (rather than evaluating
canopy stand by stand). To accomplish these habitat types, vegetation
management will need to be implemented, such as described in the ONF's
Plan. However, depending on the time of year and the intensity of a
prescribed fire, the midstory and overstory may or may not be removed or
thinned. Monitoring efforts within the 5 mile radius should be
implemented in post bum sites to evaluate the canopy and midstory. If
the desired openness is not achieved for foraging and roosting habitat,
then other means should be implemented after negative results are
noticed. The Service recommends using prescribed fire and timber
management concurrently to achieve quality habitat within the 5 mile
radius. To accomplish long term sustainable habitat for IBs, forest
management should also strive to ensure a mosaic of habitats and a
continuous supply of roost trees within the 5 mile radius.

The Service concurs that the possibility of killing a male IB as a
result of prescribed burning during the summer is highly unlikely.
However, due to the immobility of young and the reservations females
would have about leaving their young, the potential of killing
individuals of a maternity colony is a possibility. The Service
recognizes that to date no TB maternity colonies have been documented on
the ONF, only one juvenile has been captured on the forest, and the ONF
is not in the core maternity range. However, this does not mean
maternity colonies are not present. Furthermore, IBs are known to
inhabit hibernacula on the ONF. The new guidance issued by the Service
(2001) is designed to set an area of as mile radius around ecologically
important sites (hibernacula) within which the Service will presume IBs
are always present outside of the hibernating season (US Fish & Wildlife
Service 2001). Of particular concern in this area is the presence of
maternity colonies during mid-May to the end of July

Smoke entering hibernaculum is not the only concern the Service has with
regards to take of IBs, although we are concerned with this issue.
Killing of individuals of a maternity colony during a summer bum is also
a concern, due to direct take of individuals by fire or smoke or take of
roosting frees. In regards to smoke management, not only should the wind
direction blow away from cave openings, but also the barometric pressure
and temperature shifts should be calculated to determine if a cave is
breathing in or out, and to determine movement of air flow with regards
to the time of day affecting temperatures, which then affect the uphill
or downhill movement of air. For example, during the day air moves
uphill, but during the night air movement is downhill. If a cave is
breathing in or air is moving towards cave opening it would not be safe
to burn. IBs are very loyal to their hibernacula (US Fish & Wildlife
Service 1999). 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. Only a small
percentage of available caves provide for the specialized requirements
of IBs (US Fish & Wildlife Service 1999).

IBs have strong site fidelity to summer colony areas, roosts, and
foraging habitat. For that reason it is important to maintain the
minimum appropriate habitat requirements. During the summer months, IBs
typically roost during the day beneath loose or exfoliating bark in
snags or living frees. To a limited extent, free cavities or hollow
portions of tree boles and limbs also provide suitable root sites
(Gardner et a!. 1991, Kurta et al 1993). Most maternity roosts are found
in large frees where the average diameter (Menzel et al. 2001) was
*14.5* inches. Miller et al (1996) found IB capture increased where
large diameter trees were abundant. Gardner et al (1991) listed the
optimal number of roost frees as 26 per acre for upland habitat and 17
per acre for floodplains. In Missouri the highest density was 0.10 per
acre, although all roosts were not discovered and the type of habitat
(upland or wetland) at this study area was unclear. Another report found
a roost density of 6 per acre, which was raised to 12 per acre after
instillation of artificial roost structures (Menzel et al. 2001). It is
essential that a variety of suitable roost exist within a colony's
occupied summer area to assure the continuance of the colony in that
area (US Fish & Wildlife Service 1999). Certain species of roost trees
can remain suitable for up to eight years (Menzel et al. 2001). New
Service Guidance (200l)and literature recommends retaining a landscape
average density of 16 live potential roost trees per acre and all snags
per acre that are greater than 9 inches at dbh, both of class one and
class two species (description of free classes are in the US Fish &
Wildlife Service 1999). However, retention of all snags is not an
appropriate or implementational method for the ONF. Rather, we are
recommending retaining 16 live potential roost trees per acre and 20
snags per acre (where available), all 9 inches or greater at dbh, both
of class one and class two species (description of tree classes are in
the US Fish & Wildlife Service 1999) on a landscape scale in timber
harvest operations within the *5* mile radius of hibernacula. However,
the Service would like to see the retention of all snags, hollow frees,
live trees with large dead limbs, and shagbark hickories forest wide.
(US Fish & Wildlife Service 1999, Menzel etal. 2001 and Daniel Boone
NF).

Brack (1983) compared the proportion of foraging activity that occurred
in forested habitats. Forested areas were selected over open areas
(e.g., pastures, old fields) by foraging Indiana IBs. Brack (1983)
reported that in Missouri, IBs commonly forage in upland habitats in the
southern portion of its range. Conversely, in Michigan he found that IBs
forage primarily in wetland habitats. Gardner et al. (1991) reported
that there was great variability in habitat use. Although this result
supported Bowles' (1982) observation that IBs are somewhat opportunistic
in selecting summer foraging habitats, they should be interpreted with
caution. The ONF should strive to maintain approximately 80 to 90
percent of the acreage within a *5* mile radius of a hibernacula with a
50 to 80 percent overstory canopy. This provides approximately 10 to 20
percent of the area for regeneration within the 0-10 age class (Daniel
Boone NF). For regeneration areas within the *5* mile area, one or more
live frees should be retained in the vicinity of about 1/3 of all dead
or dying potential primary roost frees wherever possible to provide
partial shade in summer and cover during inclement weather. The
remaining 2/3 of the potential primary roost trees will be left in the
open (Daniel Boone NF).

As stated in the BO and the incidental take permit, reports on the
status of the IB on the ONF are to be submitted to the Service annually.

*[Reasonable]{.underline} [and]{.underline} [prudent]{.underline}
[measures]{.underline}*

1\. A landscape scale average of 50 to 80 percent canopy within the *5*
mile radius of a hibernacula (rather than evaluating canopy stand by
stand), and a mosaic of habitats and a continual supply of roost frees
of should be maintained.

2\. The ONF should strive to maintain approximately 80 to 90 percent of
the acreage within a 5 mile radius of hibernacula with a 50 to 80
percent overstory canopy. This provides approximately 10 to 20 percent
of the area for regeneration within the 0-10 age class (Daniel Boone
NF).

3\. A baseline buffer of a 0.25 mile radius with a 60 to 80 percent
canopy should be maintained (US Fish & Wildlife Service 1999) around
hibernaculum

4\. Implementation of disturbance activities should be conducted outside
the maternity season within the 5 mile radius around hibernaculum.

*5.* For timber harvest areas within the 5 mile area, one or more live
trees should be retained in the vicinity of about 1/3 of all dead or
dying potential primary roost trees wherever possible to provide partial
shade in summer and cover during inclement weather. The remaining 2/3 of
the potential primary roost frees will be left in the open (Daniel Boone
NF).

6\. Ensure that smoke will not enter hibernacula and adversely affect
IBs during all burns.

7\. Retain a landscape average density of 16 live potential roost trees
at least 9 inches at dbh per acre and of 20 snags per acre that are at
least 9 inches at dbh (when available),

[\_\_\_\_\_\_\_]{.mark} both of class one and class two species, in
timber harvest areas within a 5 mile radius

of hibernaculum. However, it is recommended that every effort be made to
retain all snags, hollow frees, live frees with large dead limbs, and
shagbark hickories forest wide. (US Fish & Wildlife Service 1999, Menzel
et al. 2001 and Daniel Boone NF). If 20 snags per acre are not
available, then as many snags that can safely be retained, should be
retained.

8\. The guidelines set forth in the existing BO and this amendment,
should be applied to all currently active hibernaculum and roost sites,
as well as all historic hibernaculum and roost sites.

*[Terms and]{.underline} [Conditions]{.underline}*

To maintain long term sustainable habitat for IBs, forest management
should create a landscape scale average of 50 to 80 percent canopy, and
ensure a mosaic of habitats and a continual supply of roost frees within
the 5 mile radius of hibernaculum. Vegetation management will need to be
implemented, such as described in the ONF's Plan. Monitoring efforts
within the *5* mile radius should be implemented in post burn sites to
evaluate the canopy and midstory. If the desired openness is not
achieved for foraging and roosting habitat, then other means should be
implemented after negative results are noticed. The Service recommends
using prescribed fife and timber management in conjunction to achieve
quality habitat within the S mile radius.

a\. To maintain suitable habitat for IBs in the *5* mile radius around a
hibernaculum, appropriate management practices will be needed.
Activities that are recommended outside the maternity season include
prescribed fire, timber harvesting, pond construction (or appropriate
water sources) and some regeneration.

b\. Activities that should be avoided at all times within the *5* mile
radius of hibernacula are new permanent roads, trails, cattle/hay
allotments and food plots.

c\. If the ONF does propose one of the above activities within the *5*
mile area that should be avoided year round, then they should consult
with the Service. If disturbance activities are proposed to be
implemented during the maternity season, mist net surveys and when
available Anabat surveys need to be conducted prior to project
implementation. To be effective surveys should be implemented prior to
the project during May 15 to the end of July of the same year as
project. Mist netting will confirm the presence of maternity colonies
or, with negative results, conclude that lB are present only in very low
numbers (US Fish and Wildlife Service 2001).

d\. Mist net survey protocol is provided in Appendix LI of the Recovery
Plan.

2\. To maintain a 60 to 80 percent canopy in the 0.25 mile radius
baseline buffer, appropriate disturbance activity should be conducted
outside of April 15 to November

. Prior to any disturbance proposed for this area, the Service should be
consulted.

Again the Service reiterates the need for management in this area and is
not advocating --- otherwise. However, we are requesting to be included
in the planning process.

3\. To ensure that smoke is not adversely affecting IBs, wind direction,
temperature shifts and barometric pressure should be calculated,
topography and other factors should be evaluated. If a hibernaculum is
located within the 0.25 mile radius of the project site and it is
determined that the cave is breathing in, it would not be safe to burn.
If the burn is outside the 0.25 mile radius, the amount of threats to
any hibernacula in the surrounding area should be evaluated on an
individual basis by ONF. If there is a risk that smoke could enter
caves, every effort should be made to ensure that smoke does not enter
the cave. If it is not possible to avoid smoke entering the hibernacula
then no burning should be conducted.

4\. If the ONF proposes to conduct prescribed fire, timber harvest,
herbicide application, construction of roads, trails, openings, ponds,
and food plots, or allow mineral exploration and cattle/hay allotments
or other disturbance within the 0.25 mile radius of a hibernacula at any
time during the year, then consultation with the Service is needed. If
the ONF proposes to construct new permanent roads, trails, food plots,
or allow cattle/hay allotments within the *5* mile area any time
throughout the year then consultation with the Service is needed. If the
ONF proposes to conduct prescribed fire, timber harvesting, pond
construction or regeneration within the 5 mile radius during the
maternity season, mist net surveys, in conjunction with Anabat surveys
(when possible), should be completed prior to project implementation.
Surveys should be conducted prior to project implementation during mid
May to the end of July of the same season as project implementation. If
bats are detected then no activity should occur from mid-May to July 31.

*[Conservation recommendations]{.underline}*

1\. The Service sees no purpose for conducting mist net surveys
[only]{.underline} within 5 miles of a known hibernaculum (US Fish &
Wildlife Service 2001) to monitor the status of IBs on the ONF. Rather
the Service recommends conducting mist net, and when possible Anabat
surveys, in the 5 mile radius to monitor population trends and outside
the 5 mile area to identify new roost or maternity sites.

2\. Water sources should be created within a 1.5 mile radius of the
hibernaculum. Flight corridors should be maintained with a 50 to 80
percent canopy and an open midstory to provide open access to water
sources. Water sources of varying depths should be used as well as
variable types of water sources (Daniel Boone NF).

3\. Girdling should be implemented to create snags in timber harvest
areas where there are less than 20 snags per acre.

This concludes consultation on the actions outlined in the reinitiation
request. As provided in 50 CFR Sec. 402.16, reinitiation of 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 of the agency action that may affect listed species or
critical habitat in a manner or to an extent not considered in the
biological 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 the

biological 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. If you have any questions
please call David Kampwerth 501-513-4477 or Hayley Dikeman at
501-513-4486.

> Sincerely,

Margaret Harney

> Acting Field Supervisor

cc: Roger Fryar, Ozark-St. Francis National Forest

> David Kampwerth, Karst Biologist, Arkansas Field Office
>
> 9

Literature Cited

Bowles, J. B. 1982. Results of monitoring of Indian bat maternity sites
in south-central Iowa. Unpubl. Report to Iowa Conserv. Commission.

Brack, V. W. 1983. The non-hibernating ecology of bats in Indiana, with
emphasis on the endangered Indian bat, *Myotis sodalis.* Unpublished
Ph.D. dissertation. Purdue University, W. Lafayette, Indiana. 28Opp.

Daniel Boone National Forest. Proposed strategy for the management
Indiana bat *(Myotis soda/is)* habitat on the Daniel Boone National
Forest. Springfield, MO: US Department of Agriculture, Forest Service.
27pp.

Gardner,\]. E., J. d. Gamer, and J. E. Hoffinann. 1991. Summer roost
selection and roosting behavior *of Myotis soda/is* (Indiana Bat). Bat
Res. News 30(1): 1-8.

Kurta, A., D. King, J. A. Teramino, J. M. Strible and K. J. Williams.
1993. Summer roosts of the endangered Indiana bat *(Myotis soda/is)* on
the northern edge of its range. Amer. Midl. Nat 129:132-138.

Menzel, Michael A.; Menzel, Jennifer M.; Carter, Timothy C.; Ford, W.
Mark; Edwards, John W. 2001 Review of the forest habitat relationship of
the Indiana bat *(Myotis sodalis)).* Gen. Tech. Rep. NE-284. Newtown
Square, PA: US Department of Agriculture, Forest Service, Northeastern
Research Station. 2 'pp.

Miller, N. e. 1996. Indian bat summer habitat patterns in northern
Missouri. Unpubl. M. S. thesis, University of Missoun-Columbia,
Columbia, Missouri. lOOpp.

Ozark-Saint Francis National Forest. 2001. The role of fire in restoring
the forest ecosystem on the Ozark-St. Frances National Forest.
Russellville, Arkansas: US Department of Agriculture, Forest Service.
l9pp.

US Fish and Wildlife Service. 1998. Formal consultation under section 7
of the Endangered Species Act for the effects of management activities
conducted by Ozark-Saint Frances National Forests on the Indiana bat.
Vicksburg, Mississippi. 3lpp.

US Fish and Wildlife Service. 1999. Agency draft Indiana bat *(Myótis
soda/is)* revised recovery plan. Fort Snelling, Minnesota. 53pp.

US Fish and Wildlife Service. 2001. Draft Indiana bat consultation
guidance.