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12^13^95	16:17	US EPfl flIR DIU
*  difw i« likely correct in suggesting that sears Island is not as unique as Cobscook Bay, Merrymeeting Bay, and other outstanding coastal areas.  However, Sears Island ie not "typical of the average situation," as DIFW states.
As discussed above, the federal resource agencies believe that Sears Island contains an uncommon mixture of habitats. The fact that Scars Island is not as large or ecologically diverae ae some of Maine's other spectacular natural areas is not germane to the issue at hand*
*  The DIFW letter states that sears Island does not provide habitat '•essential to the conservation of any state or feaerally endangered or threatened species, or provide significant wildlife habitat values tor any wildlife species."
DIPW iff UBing the terro "significant" as defined in the state's Natural Resources Protection Act (NRPA), which differs from the definition contained in the Section 404(b)(l) guidelines,  in so doing difw appears to confuse mrpa's definition of "significant" (which is restricted to a fairly narrow range of areas mapped by DIFW) with the way in which the term ie used in the context of the 404(b)(1) guidelines.  While we agree that sears Island is not "essential" habitat for the aurv<val of any endangered or threatened species, the Island provides Important habitat for a wide array of fish and wildlife.2
*  DIFW atatea; that Sears Island does not provide "otherwise significant habitat values that are of particular importance to the conservation of any of these [wildlife] species."
We diaagree.  Forest interior habitat is important to the conservation of migratory songbirds; intertidal habitat is important to the conservation of shellfish and finfish;
vernal pools are important to the conservation of amphibians/ mudflats are important to shellfish, shorebirds, and somo mammals/ and eelgrass ie critical for a variety of shellfish and finfish.  To suggest that these productive and diverse habitats do not contribute to conservation of the apacies utilising the habitats is scientifically unsound.
*  difw otataa that "[in] any of the data and coiamenta presented would equally apply to shoreland areaa throughout central and eastern portions for the state, including presence of some rar-s
*peciea such as the ribbon snake and southern bog lamaing..."
2  In fact, the DIFW agrees with this point when it states, "The Island and adjacent watera, as reported, are usad by a br&^. array of wildlife."