12/W95	16'-19	Ubl-.H————-

unsuitable for woodcook.
Not 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 off era no documentation to support this contention.  To the beat of our knowledge, the creation 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 basin* 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 th« larvae to grow to adulthood*
*  DIFW statea that it was "misleading" when the federal resource agencies claimed that sears Island "provides habitat for 21 atate and/or federally listed wildlife."
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 information, and/or habitat loss" (sea 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 claim that Sears Island provides unique bald eagle or peregrine falcon habitat.  Rather, the Evaluation actually stated that Seara Island provides resting and hunting habitat for these species, and that the individuals using the island would ba adversely affected by the proposed project*
*  DtFW atatee there are only two osprey nestfit on Sears Island, as opposed to the three counted by the federal resource agencies.
ERA contacted DIFW on October 23, 1995, and learned that tha two nests referred co in the difw letter was based on, at best, 1986 data»  DIFW alao confirmed that the 19»2 data used by the federal resource agenoias w«e roore accurate than the data used in the October 13, 1995 DIFW letter.