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<br />............................................................................................................. F RAY E 0 SA F E T Y NET S <br /> <br />that area. Uncovered species, if subsequently <br />listed, can also be incorporated into a take per- <br />mit. Public agencies will pay for any additional <br />preservation that is necessary if the species <br />depends upon a habitat type that is "sufficiently <br />conserved" under the original plan. For species <br />dependent upon habitat types that are not suffi- <br />ciently conserved, a combination of public and <br />private money will be required for additional <br /> <br />protections. <br />Of the plans reviewed here, two H CPs in the <br />Pacific Northwest have assurances to landowners <br /> <br />-- <br /> <br />based on protection of habitat types. In the <br />Plum Creek Timber Company HCP, the breed- <br />ing and feeding habitat preferences of all 285 <br />vertebrate species in the planning area are consol- <br />idated into 16 "lifeforms." For each lifeform, <br />the habitat required by the species is defined in <br />terms of stand structure. Since Plum Creek <br /> <br />Timber Company performs inventories of stand <br />structures under the HCP (and arguably in the <br />absence of an HCP), they will be able to keep <br />track of whether stand structures will decline or <br />increase under the plan. From this, they will <br />infer whether wildlife in each lifeform are likely <br />to decline or increase. Although this analysis is <br />the basis of granting assurances for all 285 <br />species, there are several serious flaws in this <br />approach. First, a lifeform can contain a group <br />of species that have very different biological <br />requirements (e.g., bats, peregrine falcons and <br />mountain goats are in one lifeform). Second, the <br />stand structure analysis is not spatially explicit <br />(i.e., there is no analysis of habitat patch size or <br />connectivity between patches). Third, the focus <br />on stand structures ignores habitat characteristics <br /> <br />that are relevant to particular species (e.g., eleva- <br />tion parameters, geographic location). <br />The Weyerhaeuser Willamette draft HCP has <br />a habitat-based approach to the level of assur- <br />ances granted to Weyerhaeuser for particular <br />species. In this case, FWS recognizes that the <br />HCP is designed for land that has very little old- <br />growth habitat and that species associated with <br />that habitat are not necessarily well protected <br />under the plan. To resolve this, under this draft <br />HCP there are three tiers of species. Tier 1 <br />species are listed or proposed for listing. Tier 2 <br />species are all other unlisted species except Tier 3 <br />species, which are those "interior, upland, older- <br />forest-dependent species that may not benefit <br />form the HCP prescriptions" (pp. 2-20, draft <br />HCP). Weyerhaeuser will receive a permit for <br />Tier 2 species when they are listed. Tier 3 <br />species will be included in the incidental take <br />permit only if "Weyerhaeuser can demonstrate <br />that this HCP maintains, enhances or establishes <br />the habitat conditions or features associated with <br />the species' use of managed forests" (pp. 2-22, <br />draft HCP). This draft HCP represents one way <br />of explicitly tying assurances for landowners to <br />the level of uncertainty associated with the ade- <br />quacy of the plan for particular species. <br />Finally, it is important to emphasize that <br />conservation plans cannot be used as an excuse <br />not to list species that, according to scientific <br />information, should be listed. This issue has a <br />high profile in the MSCp, where environmental <br />groups are suing to list the short-leafed dudleya <br />(Dudleya blochmaniae spp. brevifolia - a rare <br />plant) because according to scientific informa- <br />tion, it is imperiled right now whether or not the <br />