We believe this statement to be incorrect.  The 1992 book Tfte Amphibians and Reptiles of.Maine, prepared in collaboration with DIFW, states that the ribbon snake has been reported only in southwestern Maine (York county), with outlier records in Kennebac and sagadahoc Counties.  The book suggests that unices additional ribbon snake populations are discovered in the near future, the species should be considered threatened or endangered.  In addition, the southern bog leiming ia reported in technical literature aa being "uncommon(( in Maine, living in "scattered" communities.
*  DIFW states that the percentago of wetland and water dependent wildlife found on Sears Island is not unusual, and that these species would be expected in similar habitats throughout coastal Maine,
The wildlife data collected for sears Island spanned several years and was, in many casas, quite intensive.  Therefore, it is difficult to compare statistically the biodiversity found on Sears island with other areas, as these other areas were not subject to the game rigorous analysis.  However, preliminary comparisons of bird biodiversity on Sears Island with other islands and peninsulas in the area indicate that Sears Island is more diverse.  Moreover, given the mixture of habitats found on Sears Island, common sense dictates that biodiversity would be higher than other areas without the same mixture of habitats*
*  DIFW states that Sears island ia not heavily utilized by wintering deer, and faults the federal resource agencies tor stating that Sears Island provides important wintering habitat for this species.
in February of 1987, an employee of mdot^s environmental division noted that there was a "traditional deer wintering area" in the center of the island, and "good winter shelter11 for deer in the softwood areas."  The author documented heavy use by deer in 15 to 20 inches of snow, and said it was "likely that deer will always use this area in the winter."  Therefore, although Sears Island may not have a mapped deer wintering habitat, wintering deer nevertheless use it in heavy snow,
*  The difw letter agrees that the alder thickets found on Sears Island are Important for woodcock, but states that these areas will "steadily decline" and eventually become forested, and thus
5 see February 12, 1987 State of Maine inter-Departmental Mttroorandma from Mike Thompson to the file.
12/13/-95	16--19
US £PP AIR ^w
0%

uneuitable for woodcock.
Mot all shrub areas grow into forests*  in fact, the hydrology of the alder thickets on Sears Island suggest that the current shrub conditions may persist indefinitely.
*  DIFW states that vernal pool habitat can be created.
DIFW offara no doouinantation to support this contention.  To th® beat of our knowledge, the oreation of vernal pools has not been successfully demonstrated anywhere in New England. Moreover/ while spotted salamanders and wood frogs are laying eggs in the existing detention basins on the island, there ie no evidence to suggest that these created basins function as vernal pools.  Specifically/ it is unclear whether the hydrology and invertebrate food base in these detention basins are sufficient to permit the eggs to hatch and the larvae to grow to adulthood*
*  DIFW states that it was "misleading" when the federal resource agencies claimed that sears Island "provides habitat for 21 state and/or federally listed wildlif."
As we stated in our evaluation, many of these species are State watch List species, which "warrant special attention due to possible population declines, restricted distribution/ lack of infomation, and/or habitat loss" (sac Evaluation, p» 5, footnote 6).
*  dipw suggested that the federal resource agencies stated that Sears -island provides "unique" habitat fwbald eagles or' "" " peregrine falcons.
Nowhere did the federal resource agencies clqia» that sears Island provides unique bald eagle or peregrine falcon habitat.  Rather, the Evaluation actually stated that Saara Island provides resting and hunting habitat tor theee species/ and that the individuals using the island would ba adversely affected by the proposed project.
*  DIFW states there are only two osprey neste on Seara Island, a» opposed to the three counted by the federal resource agencies.
ERA contacted DIFW on October 23, 1995, and learned that tha two nests referred so in the DIFW letter was based on, at best, 1986 data.  DIFW alao confirmed that the 19»2 data used by the federal resource agendas w«e n»or® accurate than the data uued in the October 13, 1995 DIFW letter.