Appendix A 

Reasons for 

Scheduling the 

Environmental 

Analysis of the Kuiu 

Timber Sale 

 
Appendix A 

Table of Contents 

Introduction .........................................................................................................1 

Why is Timber from the Tongass National Forest Being Offered for Sale? .......2 

How Does the Forest Service Develop Forecasts about Future Timber Market 

Demand?.............................................................................................................6 

What Steps Must Be Completed to Prepare a Sale for Offer? ...........................9 

How Does the Forest Service Maintain an Orderly and Predictable Timber Sale 

Program? ..........................................................................................................10 

How Does the Forest Service Decide Where Timber Harvest Projects should 

be Located? ......................................................................................................14 

Conclusion ........................................................................................................19 

References........................................................................................................20
Kuiu Timber Sale FEIS Appendix A • 1 

Reasons for Scheduling the 

Environmental Analysis of the 

Kuiu Timber Sale Project Area 

Introduction 

This appendix provides an explanation of the rationale for a specific 

timber harvest project and its importance to the multi-year timber 

program on the Tongass National Forest. To accomplish this, the 

following questions are answered:

• Why is timber from the Tongass National Forest being offered 

for sale? 

• How does the Forest Service develop forecasts about future 

timber market demand? 

• What steps must be completed to prepare a sale for offer? 

• How does the Forest Service maintain an orderly and 

predictable timber sale program? 

• How does the Forest Service decide where timber sale projects 

should be located? 

Coordinated timber sale planning is essential for meeting the goals of 

the Tongass Land and Resource Management Plan (Forest Plan) and to 

provide an orderly flow of timber to local industry. To determine the 

volume of timber to offer each year, the Forest Service can look to 

current market conditions and the level of industry operations. 

However, the planning process for timber harvest projects requires the 

Forest Service to rely on projections of future harvest levels to decide 

how many timber sale projects to begin each year. This document 

explains how the Forest Service uses information about future markets 

and past experience with timber sale planning to determine the volume 

of timber that needs to be started through this process each year. This 

appendix relies heavily on the current annual timber demand analysis 

and the most recent timber sale schedule. 
Appendix A 

2 • Appendix A Kuiu Timber Sale FEIS 

Why is Timber from the Tongass 

National Forest Being Offered for Sale? 

On a national level, the legislative record is clear about the role of the 

timber program in the multiple-use mandate of the national forests. One 

of the original objectives for creation of national forests was to provide 

natural resources, including timber, for the American public. The 

Organic Act of 1897 (partially repealed in 1976) directed the agency to 

manage the forests in order to "improve and protect the forest ... [and] 

for the purpose of securing favorable conditions of water flows, and to 

furnish a continuous supply of timber for the use and necessities of the 

citizens of the United States" (emphasis added). The Multiple-Use 

Sustained Yield Act of 1960 directs the Forest Service to administer 

federal lands for “outdoor recreation, range, timber, watershed, and 

wildlife and fish purposes.” 

The National Forest Management Act (NFMA) of 1976 states that “the 

Secretary of Agriculture...may sell, at not less than appraised value, 

trees, portions of trees, or forest products located on National Forest 

System Lands.” Although the heart of the Act is the land management 

planning process for national forests, the Act also sets policy direction 

for timber management and public participation in Forest Service 

decision making. Under NFMA, the Forest Service was directed to 

“limit the sale of timber from each national forest to a quantity equal to 

or less than a quantity which can be removed from such forest annually 

in perpetuity on a sustained-yield basis.” 

The NFMA directs the Forest Service to complete land management 

plans for all units of the National Forest System. Forest plans are 

developed by an interdisciplinary team to provide for the coordination of 

outdoor recreation, range, timber, watershed, wildlife and fish, and 

wilderness. Forest plans designate areas of national forest where 

different management activities and uses are considered appropriate 

including those areas suitable for timber harvest. 

Timber from the Tongass National Forest is being offered for sale as 

part of the multiple-use mission of the Forest Service identified in the 

public laws guiding the agency. In addition, Alaska-specific legislation 

and the Tongass Forest Plan direct the Forest Service to seek to provide 

timber to meet market demand, subject to certain limitations. 

The Alaska National Interest Lands Conservation Act (ANILCA) and 

the Tongass Timber Reform Act (TTRA) provide direction on the issue 

of Tongass timber supply. Section 101 of TTRA amended the ANILCA 

timber supply mandate and fixed budget appropriations and replaced 

them with the following text in Section 705 (a): 

National Legislation 

Alaska-Specific 

Legislation 
Appendix A 

Kuiu Timber Sale FEIS Appendix A • 3 

“Sec. 705. (a) Subject to appropriations, other applicable law, and 

the requirements of the National Forest Management Act of 1976 

(P.L. 94-588); except as provided in subsection (d) of this section, 

the Secretary shall, to the extent consistent with providing for the 

multiple use and sustained yield of all renewable forest resources, 

seek to provide a supply of timber from the Tongass National Forest 

which (1) meets the annual market demand for timber from such 

forest and (2) meets the annual market demand from such forest for 

each planning cycle.” 

The Record of Decision for the Tongass Land Management Plan 

Revision (Forest Plan) was signed by the Alaska Regional Forester in 

1997. The Forest Plan incorporated new resource information and 

scientific studies and reflected an extensive public involvement process. 

There was direction to supplement the 1997 Final EIS to evaluate and 

consider roadless areas within the Tongass for recommendation as 

potential wilderness areas as part of the March 2001 US District Court 

decision on litigation on the 1997 Forest Plan. The Record of Decision 

for the Supplemental Environmental Impact Statement was signed in 

February 2003. The No-action Alternative was selected; no additional 

lands were recommended for Wilderness designation and no changes 

were made to the Land Use Designations (LUDs) from the 1997 Record 

of Decision. The 1997 Forest Plan defines appropriate activities within 

each LUD. Approximately 74 percent of the Tongass is allocated to 

LUDs where commercial timber harvest is not allowed. 

Amendments have been made to the 1997 Forest Plan, primarily to 

modify small Old-growth Habitat Reserves to meet Forest Plan criteria. 

These amendments have been accomplished through environmental 

analysis and are documented in decision documents. Due to those 

modifications, LUDs in certain areas have changed from development 

LUDs that allow timber harvest to Old-growth Habitat LUD or changed 

from the Old-growth Habitat LUD to development LUDs. Since the 

plan was signed in 1997, these amendments have affected two percent of 

the acres designated as suitable commercial timber by re-designating 

them as Old-growth Habitat LUD where timber harvest is not allowed. 

The effects to resources in the Final EIS for the 1997 Forest Plan were 

analyzed as if the full timber harvest allowed under each alternative 

would occur over the next decade and into the future. In that way, the 

Forest Plan analysis displayed the maximum environmental effects that 

could be reasonably foreseen. Since substantially less timber volume 

and acres have been harvested since the 1997 Forest Plan revision than 

was analyzed, the effects on resources are expected to be less than 

projected in the 1997 Final EIS. The environmental effects analysis in 

the Forest Plan projected that up to 267 MMBF and 10,200 acres could 

be harvested per year based on the suitable forest lands where timber 

Tongass National 

Forest Land and 

Resource 

Management Plan 

(Forest Plan, as 

amended) 
Appendix A 

4 • Appendix A Kuiu Timber Sale FEIS 

harvest is compatible with the Forest Plan Land Use Designations. 

Forest Plan monitoring indicates that average annual harvest has been 

considerably less than that amount (Figure A-1). 

Figure A-1 

 Tongass Timber Harvest, 1998-2006 

119.8

145.8 146.8

47.8

33.8

50.8 46.0 49.6 43.1

0

20

40

60

80

100

120

140

160

1998 1999 2000 2001 2002 2003 2004 2005 2006

 Timber Harvest - mmbf per year

On August 5, 2005, the Ninth Circuit Court of Appeals ruled that a 

misinterpretation of the Brooks and Haynes 1997 draft timber demand 

projections rendered the 1997 Record of Decision for the Tongass Land 

Management Plan Revision arbitrary and capricious. The court of 

appeals remanded the matter for further proceedings consistent with the 

court's opinion (Natural Resources Defense Council v. U.S. Forest 

Service). The process of remedying the shortcomings identified by the 

court of appeals is in progress with a Forest Plan Amendment Draft EIS 

released in January 2007. However, there are lengthy time periods 

involved in clearing timber volume through the NEPA, administrative 

appeals and litigation processes. Clearing a timber sale project through 

the NEPA process is an important step in the process the Alaska Region 

uses to comply with this mandate. Delaying the completion of this and 

other site-specific projects until after a decision on the Forest Plan 

Amendment is made would undermine the Forest Service’s ability to 

keep an even-flow of economical timber supply. This project will be 

reviewed for consistency with the decision on the Forest Plan 

Amendment.

Allowable Sale Quantity (ASQ) 

The ASQ serves as an upper limit on the amount of timber that may be 

offered for sale each decade as part of the regularly scheduled timber 

sale program. The Record of Decision for the 1997 Forest Plan states: 

“The maximum amount of timber that could be harvested 

(Allowable Sale Quantity or ASQ) during the first decade of the 

Forest Plan implementation is an average of 267 MMBF per year. A 

timber volume level less than the ASQ is likely to be offered over 
Appendix A 

Kuiu Timber Sale FEIS Appendix A • 5 

the next few years, given current market conditions, the transition 

that both the timber industry and the Forest Service are experiencing, 

and the current amount of appeals and litigation. 

The ASQ is the maximum amount of sustainable timber harvest on 

suitable forest lands allocated to development by the Forest Plan, in 

accordance with its standards and guidelines and management direction. 

It consists of two separate Non-Interchangeable Components (NICs) 

called NIC I and NIC II. The NIC I component includes lands that can 

be harvested with normal logging systems including helicopter logging 

with less than 3⁄4 mile yarding distance. The NIC II component includes 

land that has high logging costs due to isolation or special equipment 

requirements. Most of these NIC II lands are presently considered 

economically and technically marginal. 

There are two purposes of partitioning the ASQ into two components: 

(1) to maintain the economic sustainability of the timber resource by 

preventing the over-harvest of the best operable ground, and (2) to 

identify that portion of the timber supply that may not be harvested 

because of marginal economic conditions. 

With regard to timber production sustainability, the Record of Decision 

for the 1997 Forest Plan further states: 

“The timber resource will be managed for production of sawtimber 

and other wood products from timberlands available for sustainable 

timber harvest, on an even-flow, sustained-yield basis and in an 

economically efficient manner. The Tongass National Forest will 

seek to provide a timber supply sufficient to meet the annual market 

demand for Tongass National Forest timber and the market demand 

for the planning cycle. 

The Tongass National Forest will continue to allow timber harvest 

while maintaining sustained yield and multiple-use goals. The 

forest-wide standards and guidelines for timber include general 

direction to “[e]nsure that silvicultural systems other than 

clearcutting are considered through an appropriate project level 

analysis process.” However, uneven-aged management systems will 

be limited to areas where yarding equipment suited to selective 

logging can be used. 

The January 2001 Roadless Area Conservation Rule prohibited most 

timber harvest and road construction in inventoried roadless areas on 

National Forest System lands. 

The Roadless Area Conservation Rule (1/12/2001) has been the subject 

of several lawsuits. In the most recent ruling (9/20/06), the court reinstituted the rule as it appears in the 2004 version of 36 CFR Parts 200 

to 299. The rule in effect includes the text at 294.14(d): "this subpart 

does not apply to road construction, road reconstruction, or the cutting, 

Roadless Area 

Conservation Rule 
Appendix A 

6 • Appendix A Kuiu Timber Sale FEIS 

sale or removal of timber in inventoried roadless areas on the Tongass 

National Forest". 

An analysis of the effects to roadless areas within the project area has 

been included as part of the analysis for this project. This project is 

consistent with agency policy and procedures and has been designed to 

meet the management direction, goals and objectives, and standards and 

guidelines in the Forest Plan. 

How Does the Forest Service Develop 

Forecasts about Future Timber Market 

Demand? 

Consistent with the provisions of the Tongass Timber Reform Act, the 

Tongass National Forest makes two determinations on volume to be 

offered. The first, “annual market demand” is an estimate on volume to 

be offered for the current year, based on a forecast of annual timber 

market demand. The second is “planning cycle market demand” 

forecasts potential timber volume needs over the life of the Forest Plan. 

Annual market demand is analogous to assessing industry performance 

in the short-term. The general approach is to consider the timber 

requirements of the region’s sawmills at different levels of operation and 

under different assumptions about market conditions and technical 

processing capability. 

The annual market demand forecast is a methodology used to set the 

short-term goals for the Tongass timber sale program – it is the projected 

volume of Tongass timber needed to meet annual market demand. The 

estimated annual market demand is the volume the Forest plans to offer 

for sale in the current year pending sufficient funding. 

The reports Responding to the Market Demand for Tongass Timber

(Morse, 2000) and Tongass National Forest Timber Sale Procedures 

(Morse, 2000a) document the formulas and procedures used in 

forecasting annual market demand. The Morse methodology originally 

used the projected harvest from the final 1997 Brooks and Haynes 

report. Currently calculations of the annual demand use the annual 

projected harvest from Brackley 2006 as one of the inputs. In addition, 

the methodology is self-correcting based on actual experience and 

considers such factors as mill capacity, utilization, and volume under 

contract. To the extent that actual harvest is lower than projected 

harvest, the inventory of timber under contract builds up and the demand 

for new timber decreases, as long as economic volume is available. The 

procedures are designed to be flexible given the uncertainty associated 

with forecasting market conditions. This is especially difficult in 

Southeast Alaska because of the structural transformation underway in 

the timber industry. The methodology accounts for the fact that the 

Annual Market 

Demand
Appendix A 

Kuiu Timber Sale FEIS Appendix A • 7 

Forest Service timber sale program cannot quickly respond to market 

fluctuations, and allows the industry to accumulate adequate volume 

under contract. The methodology includes provisions to monitor 

industry behavior and includes ways to adjust timber sale program levels 

to reflect harvest activity with some specific criteria for action. These 

assumptions provide a basis for estimating the volume of timber likely 

to be processed by the industry as a whole in any given year. The 

volume of timber likely to be purchased is equal to the volume needed to 

make up any inventory shortfall in addition to the volume likely to be 

harvested in the coming year. 

To keep the annual demand current, the timber sale plan is updated each 

fiscal year for each ranger district, whereby the current year is dropped 

at the end of the fiscal year and a new year is added. These plans from 

the ranger districts are then consolidated into the Tongass Timber Sale 

Plan. In the past, the Tongass prepared a 10-year timber sale plan. For 

several reasons, the Tongass now uses a 5-year timber sale plan, which 

is consistent with Forest Service Manual 2430. These reasons include 

the difficulty to project changing market conditions, the outcome of 

timber harvest decisions affected by litigation, the time it will take to 

remedy the Forest Plan to be consistent with the court’s opinion 

(Natural Resources Defense Council v. U.S. Forest Service) and the 

completion of the amendment to the Forest Plan currently in progress. 

This 5-year plan is based on completed and ongoing environmental 

analyses and will contain more-accurate information to purchasers and 

provide a plan that is easier to adjust in response to changing market 

conditions. 

The volume that needs to be offered to meet the “annual market 

demand” for FY 07 is projected to be 131 MMBF. This figure was 

calculated using the Brackley 2006 “expanded lumber scenario” which 

allows for sufficient timber volume for the existing Southeast Alaska 

sawmills to operate efficiently. The spreadsheet displaying how this 

demand is calculated and a summary of the factors used in these 

calculations are in the project record. 

The planned annual timber volume offer could include a combination of 

new, previously offered, and reconfigured timber sales. Both green 

timber and salvage will be components of the program. Offerings will 

consist of those targeted for Small Business qualified firms, as well as a 

portion of the volume being made available for the open market. 

There have been a number of “planning cycle market demand” analyses 

prepared for Tongass timber program, including three series prepared by 

Brooks and Haynes (1990, 1994, and 1997) for the Forest Service’s 

Pacific Northwest Research (PNW) Station that are the 1997 demand 

projections were used in the preparing the 1997 Tongass Forest Plan. 

Market Demand for 

the Planning Cycle 
Appendix A 

8 • Appendix A Kuiu Timber Sale FEIS 

An update of the “planning cycle market demand” assessment by Brooks 

and Haynes (1997) was requested from the US Forest Service. In 2006, 

the PNW Research Station published new harvest projections (Brackley 

et al. 2006). The Brackley 2006 projections contain four scenarios, as 

opposed to the three in Brooks and Haynes (1997). These four 

scenarios include: 1) limited lumber production which represents the 

current situation where timber supply is limited; 2) expanded lumber 

production which represents the current industry in southeast Alaska 

operating without the current supply limitations; 3) medium integrated 

industry which represents an expansion of the current industry capacity 

and better utilization of forest products removed from public timber 

sales; and 4) high integrated industry which represents full utilization of 

forest products. More information about these scenarios is in the Forest 

Plan Amendment Draft EIS (January 2007). 

The 2006 projections did not require changes to the basic methodology 

from the procedure outlined in Morse (2000a) except to use the 

projections from Brackley, 2006 rather than the 1997 Brooks and 

Haynes projections (Alexander, 2006). 

Table A-1. Projected Tongass National Forest Timber Harvest— in 

Million Board Feet (MMBF); (Alexander, 20061

) 

Year 1- Limited 

lumber 

scenario 

2 - Expanded 

lumber 

scenario 

3 -Medium 

integrated 

scenario 

4 - High 

integrated 

scenario 

2007 49.8 61.9 67 67 

2008 49.8 66.4 139 139 

2009 51.3 72.4 151 151 

2010 52.8 78.5 166 166 

2011 52.8 84.5 184 184 

2012 54.3 90.5 204 286 

2013 55.8 98.1 204 291 

2014 57.3 105.6 204 295 

2015 58.9 113.2 204 299 

2016 58.9 122.2 204 303 

2017 60.4 131.3 204 308 

2018 61.9 140.3 204 312 

2019 63.4 150.1 204 317 

2020 64.9 163.0 204 325 

2021 66.4 175.0 204 333 

2022 67.9 187.1 204 342 

2023 69.4 200.7 204 351 

2024 70.9 215.8 204 360 

2025 72.4 230.9 204 370 
Appendix A 

Kuiu Timber Sale FEIS Appendix A • 9 

1 Annualized calculation to fulfill derived demand scenarios from Brackley et al. 

(2006). This table was created using annualized values provided by Dr. Allen 

Brackley (personal communication, Nov 29 2006) from the model used to develop 

derived demand estimates in Brackley et al. (2006a). The values for Limited Lumber 

Scenario and Expanded Lumber scenarios reported in this table have been adjusted to 

include low quality material not included in the demand projections and include saw 

logs, cedar export, and utility (chip) volumes available from sawmill production. The 

Medium and High Integrated Scenarios are not adjusted and include saw logs, cedar 

exports, chip volumes, low-grade material, and utility in Brackley et al. (2006

Both the “annual market demand” and the “planning cycle market 

demand” projections are important for timber sale program planning 

purposes. They provide guidance to the Forest Service to request 

budgets, to make decisions about workforce and facilities, and to 

indicate the need to begin new environmental analysis for future 

program offerings. They also provide a basis for expectations regarding 

future harvest, and thus provide an important source of information for 

establishing the schedule of probable future sale offerings. The weight 

given to the projections will vary depending on a number of factors, 

such as how recently they were done and how well they appear to have 

accounted for recent, site-specific events in the timber market. 

What Steps Must Be Completed to 

Prepare a Sale for Offer? 

The Tongass National Forest’s timber sale program is complex. A 

number of projects are underway at any given point in time, each of 

which may be in a different stage of planning and preparation. A system 

of checkpoints, or “gates”, helps the Forest Service track the 

accomplishments of each stage of a project from inception to contract 

termination. 

Gate 1 – Initial Planning of Timber Sale Project 

A Timber Sale Project Plan, often referred to as a Position Statement, is 

a brief analysis of the project area with the intent of determining the 

feasibility of a potential timber sale. After the Position Statement is 

developed, the Forest Service decides whether the project area merits 

continued investment of time and funds in sale planning. 

Gate 2 – Project Analysis, Sale Area Design, and Decision 

This step is commonly referred to as the “NEPA” phase and includes 

field work, public scoping, analysis, draft disclosure of the effects of the 

project on the environment, public comment, final analysis and 

disclosure, decision, and potentially administrative appeals and 

litigation. Gate 2 activities must be completed before a sale is awarded. 

Legislation, policy changes, and appeals and litigation have recently 

extended completion of some projects for a much longer timeframe, 

often doubling the desired time frame. 
Appendix A 

10 • Appendix A Kuiu Timber Sale FEIS 

Gate 3 – Preparation of a Timber Sale 

During this step, the information and direction included in the decision 

document from Gate 2 is used to layout units and design roads on the 

ground. Additional site-specific information is collected at this time. In 

order to maintain an orderly flow of sales, Gate 3 activities need to be 

complete before a sale is advertised. 

Gate 4 – Advertise a Timber Sale 

The costs and value associated with the timber sale designed in Gate 3 

are appraised and packaged in a timber sale contract. The contract is a 

legally binding document that tells a prospective timber sale purchaser 

how the sale must be harvested to conform to the project decision 

document. This step occurs during the final year of the project 

development and culminates with the advertisement of the project for 

sale. 

Gate 5 – Bid Opening 

Gate 5 is completed with the opening of bids for the project. If a bid is 

submitted, contractual provisions govern when the award of the sale 

takes place, when the sale will be completed (contract length and 

operation season), and how timber removal is to occur. 

Gate 6 – Award a Timber Sale Contract 

Gate 6 is the formal designation of a contract between a bidder and the 

Forest Service. 

How Does the Forest Service Maintain 

an Orderly and Predictable Timber Sale 

Program? 

As discussed earlier, the Forest Service tracks the accomplishment of the 

different steps of development of each timber sale with the Gate System 

process (Forest Service Handbook 2409.18). From a timber sale 

program standpoint, it is also necessary to track and manage multiple 

projects through a “pipeline” of time as projects collectively move 

through the Gate System. Because of the timeframes needed to 

accomplish a given timber sale and the complexities inherent in timber 

sale project and program development, it is necessary to track various 

timber sale program volumes from Gate 1 through Gate 6. 

The goal of the Tongass National Forest is to provide an even flow of 

timber sale offerings on a sustained-yield basis to meet market demand. 

In recent years, this has been difficult to accomplish due to a 

combination of uncertainties such as delays related to appeals and 

litigation; changing economic factors, such as rapid market fluctuations; 

and industry-related factors, such as changes in timber industry 

processing capabilities. To achieve an even flow of timber sale 

offerings, ‘pools’ of volume in various stages of the Gate System are 

Pools of Timber 

(Pipeline Volume) 
Appendix A 

Kuiu Timber Sale FEIS Appendix A • 11 

maintained so volume offered can be balanced against current year 

demand and market cycle projections. 

Today, upward trends in demand are resolved by moving out-year 

timber projects forward, which may leave later years not capable of 

meeting the needs of the industry. In other instances, a number of new 

projects are started based on today’s market but will not be available for 

a number of years. By the time the added projects are ready for offer, 

the market and demand for this volume may have changed. Three pools 

of timber volume are tracked to achieve an even flow of timber sale 

offerings. 

The objective of the timber pools concept is to maintain sufficient 

volume in preparation and under contract to be able to respond to yearly 

fluctuations in a timely manner. Refer to Table A-2, which displays the 

current estimated volume in each pool, as well as the goal for volume to 

be maintained in each pool, based on historic patterns. Based on historic 

patterns, the Tongass has established a goal for the volume to be 

maintained in each of the timber pools. Appeals and litigation can cause 

timber sale projects to be reevaluated to ensure they meet current 

standards and direction, which can cause delays in making projects 

available to move through the pools, thereby not fully meeting the goals 

for volumes in each pool. 

Pool 1 - Timber Volume Under Analysis (Gate 1 and Gate 2) 

Volume in Gate 1, the initial planning step, represents a large amount of 

volume, but represents a relatively low investment in each project. This 

relatively low investment level offers the timber program manager a 

higher degree of flexibility and thus, does not greatly influence the flow 

of volume through the pipeline. 

Gate 2, timber volume under environmental analysis, includes sales 

being analyzed and undergoing public comment through the NEPA 

process. This pool includes any project that has started the scoping 

process through those projects ready to have a decision issued. In 

addition, tracking how much volume is involved in appeals or litigation 

may be necessary to determine possible effects on the flow of potential 

timber sales. Volume in appeals and litigation is tracked as a subset of 

this pool as necessary (Table A-3). 

Based on historic patterns, the Tongass has established a goal for the 

pipeline volume to be maintained in each of the timber pools. The goal 

for Pool 1 is to be maintained at approximately 4.5 times the amount of 

the projected harvest to account for projects at various stages of analysis. 

That goal reflects a number of factors which can lead to a decrease in 

volume available, such as a decision in Gate 1 to drop further analysis in 

a particular planning area (called the “no go” decision), a falldown in 

estimated volume between Gate 1 and Gate 2, and volume not available 

for harvest due to appeals or litigation. 
Appendix A 

12 • Appendix A Kuiu Timber Sale FEIS 

Pool 2 - Timber Volume Available for Sale (Gates 3, 4 and 5) 

Timber volume available for sale includes sales for which environmental 

analysis has been completed, and have had any administrative appeals 

and litigation resolved. Enough volume in this pool is needed to be 

maintained to be able to schedule future sale offerings of the size and 

configuration that best meets market needs in an orderly manner. 

As a matter of policy and sound business practice, the Forest Service 

announces probable future sale offerings through the Periodic Timber 

Sale Announcement. Recent delays at Gate 2 have affected sale 

preparation and have made scheduling uncertain. At Gate 4, sales have 

been fully prepared and appraised, and are available to managers to 

advertise for sale. This allows potential purchasers an opportunity to do 

their own evaluations of these offerings to determine whether to bid, and 

if so, at what level. 

Timber in this pool can include a combination of new sales, previously 

offered unsold sales, and remaining volume from cancelled sales. The 

goal is to maintain Pool 2 at approximately 1.3 times the amount of the 

projected harvest to allow flexibility in offering sales. 

Pool 3 - Timber Volume under Contract (Gate 6) 

Timber volume under contract contains sales that have been sold and a 

contract awarded to a purchaser, but which have not yet been fully 

harvested. Contract length is based on the amount of timber in the sale, 

the current timber demand, and the accessibility of the area for 

mobilization. The longer the contract period, the more flexibility the 

operator has to remove the timber based on market fluctuations. Timber 

contracts typically initially give the purchaser 3 years to harvest and 

remove the timber purchased. Analysis of Tongass timber sales 

indicates an average sale length of about 6 years due to modifications in 

the contracts due to inoperable periods of weather, injunctions, and other 

contractual delays. 

The Tongass attempts to maintain roughly 3 years of unharvested 

volume under contract to the industry as a whole. This volume of timber 

is the industry’s dependable timber supply, which allows adaptability for 

business decisions. This practice is not limited to the Alaska Region, 

but is particularly pertinent to Alaska because of the nature of the land 

base. The relative absence of roads, the island geography, the steep 

terrain, and the consequent isolation of much of the timber land means 

that timber purchasers need longer-than-average lead times to plan 

operations, stage equipment, set up camps, and construct roads prior to 

beginning harvest. 

A combination of projected harvest and projected demand is used to 

estimate the volume needed to maintain an even-flow timber sale 

program. As purchasers harvest timber, they deplete the volume under 

contract. Timber harvest is then planned and offered by the agency as 
Appendix A 

Kuiu Timber Sale FEIS Appendix A • 13 

sales that give the industry the opportunity to replace this volume and 

build or maintain their working inventory. Although there will be 

variation for practical reasons from year to year, in the long-run over 

both the high points and low points of the market cycle, the volume 

harvested will equal the timber volume sold, excluding cancelled sales. 

The goal for Pool 3, volume under contract, is to maintain timber 

volume at approximately three times the amount of annual projected 

harvest. This allows the purchasers to have a continuous supply of 

timber volume available for harvest so they can plan their operations and 

be flexible to allow for weather conditions and market fluctuations. 

Table A-2 

Accomplishments in Gate System and Timber Pools (MMBF)

Pipeline Pool Volume 2007 Goal FY 07 (as of 

1/1/07) 

Pool 1 

Volume Under Analysis 

 (Gates 1 and 2) 2791

 350 

Pool 2 

Volume Available for Sale 

 (Gates 3, Gate 4 and Gate 5) 792

 3043

Pool 3 

Volume Under Contract

 (Gate 6) 1864

 1005

1 The goal for volume under analysis is approximately 4.5 times the projected harvest 

for the current year (61.9 MMBF for 2007 based on expanded lumber scenario). 

Volume under analysis includes all volume in projects from the Notice of Intent 

through completion of the environmental analysis for sales planned. 

2 The goal for volume available for sale is to have at least 1.3 times the projected 

harvest for the current year (61.9 MMBF) in sales that have approved NEPA and 

completion of timber sale preparation. 

3 Includes volume from sales mutually cancelled under the provision of the 2004 

Appropriations Act (Sec. 339). However, most of this volume appraises deficit under 

current market conditions and can not be offered for sale under Congressional direction 

in the 2006 Appropriations Act (Public Law 109-54, Sec. 416). Does not include 

volume under litigation – see Table A-3. 

4 The goal for volume under contract is for purchasers to have 3 times the volume 

under contract as projected for harvest for the current year (61.9 MMBF). 

5 Estimated volume under contract available for harvest (not including timber enjoined 

from harvest or sales that have had mutual cancellation requests granted).
Appendix A 

14 • Appendix A Kuiu Timber Sale FEIS 

Timber harvest projects require site-specific environmental analysis that 

usually is documented in an environmental assessment (EA) or an 

environmental impact statement (EIS). The public is notified of the 

analysis and is provided the opportunity to comment on proposals and 

file an appeal on decisions. The administrative appeal process for most 

timber harvest projects takes up to 105 days before implementation to 

occur. 

When decisions are appealed and affirmed through the administrative 

appeal process, the project can still be litigated. Litigation can be a 

lengthy process. Although litigation does not preclude offering timber 

for sale, the Forest Service and potential purchasers are often reluctant to 

enter into a contract where the outcome is uncertain. Recently, sales 

were enjoined from harvest after the contracts were awarded. The 

outcome of litigation affects the Forest’s ability to provide a reliable 

timber supply. 

Table A-3 

Timber Volume Involved in Appeals and/or Litigation1

Timber volume remanded on appeals2

 23 MMBF 

Timber volume involved with litigation 35.2 MMBF 

1

 As of May 23, 2007 – date of Settlement Agreement with NRDC. 

2

 Remanded – Decision overturned during internal review. Does not include volume in 

decisions currently in the appeal period or undergoing an appeal review. 

How Does the Forest Service Decide 

Where Timber Harvest Projects should 

be Located? 

The location of timber sale projects is based first on the land allocation 

decisions in the Forest Plan. Under the 1997 Forest Plan, lands 

designated for possible timber harvest are in the development Land Use 

Designations (LUDs), primarily the Timber Production, Modified 

Landscape, and Scenic Viewshed LUDs. 

The second consideration is the suitability of the land for timber 

production. Many acres within the development LUDs are not suitable 

for timber production due to poor soils or steep slopes. The process for 

determining the suitability of the land is found in the Forest Plan, 

Appendix A. Figure A-2 depicts the classification of all the lands within 

the Tongass National Forest. Four percent of the Tongass land base, the 

suitable, available and scheduled forest land, provides the land base for 

the Allowable Sale Quantity of 267 MMBF per year. Under the 1997 

How Appeals and 

Litigation Affect the 

Timber Sale 

Program 

Timber Resource 

Land Suitability 
Appendix A 

Kuiu Timber Sale FEIS Appendix A • 15 

Forest Plan, the remainder of the land, approximately 96 percent, does 

not allow, is not scheduled, or is not physically suitable. 

Figure A-2 

1997 Forest Plan Timber Resource Suitability Analysis 

Non-Forest land

41%

 Withdrawn lands

25%

Non-Productive Forest

14%

Productive Forest 

Suitable and Available -

 Scheduled 4%

Productive Forest NonDevelopment LUD

8%

Productive Forest 

Suitable and Available - 

Unscheduled 2%

Productive ForestNot suitable

6%

Non-Forest land – Land that has never supported forests, e.g. muskeg, rock, ice, etc. 

Withdrawn Lands – Lands designated by Congress, the Secretary of Agriculture, or Chief for purposes 

that preclude timber harvest, e.g. Wilderness Areas 

Non-productive Forest – Forest land not capable of producing commercial wood on a sustained yield 

basis 

Productive Forest, Not suitable, Physical Attributes – Forest land unsuitable for timber due to physical 

attributes (steep slopes, soils, etc.) and/or inadequate information to ensure restocking of trees within 

five years of final harvest. 

Productive Forest, Not Suitable, Non-development LUD – Productive forest lands where timber 

production is not allowed due to Forest Plan land use designation, e.g. Semi-Remote Recreation, Oldgrowth Habitat, etc. 

Productive Forest, Suitable and Available, Scheduled – Forest land that meets all the criteria for timber 

production suitability and is available and is scheduled by the Forest Plan over the planning horizon 

Productive Forest Suitable and Available Unscheduled – Forest land that meets all the criteria for timber 

production suitability, is available for harvest, however was not scheduled in the Forest Plan model for 

harvest. 

The Tongass National Forest is divided into ten ranger districts. For 

planning and scheduling purposes, the Allowable Sale Quantity (ASQ) 

has been allocated to the ranger districts based on the Forest Plan 

modeling (FORPLAN) results of suitable and available acreage. The 

average annual distribution of the full Forest Plan ASQ by ranger 

District-Level 

Planning 
Appendix A 

16 • Appendix A Kuiu Timber Sale FEIS 

districts is displayed in Table A-4 (all volumes are identified as sawlog 

plus utility). 

Table A-4 

Annual Distribution of Forest Plan Allowable Sale Quantity 

(mmbf) by District 

Non-Interchangeable 

Component (NIC)1

Ranger District 

NIC I NIC II 

Ketchikan/Misty Fiords 32 7 

Thorne Bay 42 9 

Craig 33 7 

Wrangell 28 6 

Petersburg 50 9 

Sitka 17 4 

Hoonah 7 2 

Juneau 7 2 

Yakutat 4 1 

Admiralty National Monument 0 0 

NIC Totals 220 47 

ASQ Total(mmbf) 267 

1 NIC I component – lands that can be harvested with normal logging systems 

including helicopter logging with less than 3⁄4 mile yarding distance. 

NIC II component – includes land that has higher logging costs due to isolation or 

special equipment requirements. 

The Forest Supervisor for the Tongass National Forest is responsible for 

the overall management of the Forest’s timber sale program. Included 

within these responsibilities is making the determination on the amount 

of timber volume to be made available to industry. Whether or not 

sufficient funding is appropriated to attain the program is the 

responsibility of the Congress and the President. 

The District Rangers to develop a timber sale plan of the potential 

timber harvest projects. This plan aims to attain the prescribed offer 

level for the current year based on the estimated annual market demand 

and to develop a timber program for several years of the planning cycle. 

The offer level for the current year in this plan is based, to the extent 

possible, on the forecasted annual market demand. Demand may 

fluctuate from year to year but recent years have shown little change in 

the annual demand projection. Offerings may vary from year to year but 
Appendix A 

Kuiu Timber Sale FEIS Appendix A • 17 

recently they have been in the low market scenario range, as determined 

by the projected annual demand. 

The District Ranger is responsible for identifying and recommending the 

project areas for the 5-Year Timber Sale Plan. The Ranger’s role is to 

develop and recommend to the Forest Supervisor timber harvest projects 

that meet Forest Plan goals and objectives. Districts work on various 

timber sale projects simultaneously, resulting in continual movement of 

projects through the stages of the timber program pipeline. This 

schedule allows the necessary time to complete preliminary analysis, 

resource inventories, environmental documentation, field layout 

preparations and permit acquisition, appraisal of timber resource values, 

advertisement of sale characteristics for potential bidders, bid opening, 

and physical award of the timber sale. Project delays through the 

completion of Gate 2 attributable to legal injunctions and litigation have 

affected the offer level in recent years. Once all of the Rangers’ 

recommendations are made and compiled into a consolidated schedule, 

the Forest Supervisor is responsible for the review and approval of the 

final timber sale plan. 

Considerations the District Ranger takes into account for each project 

include: 

• The project area contains a sufficient number of suitable timber 

production acres allocated to development land use designations. 

Available information should indicate that the timber volume being 

considered for harvest can be achieved while meeting Forest Plan 

goals, objectives, standards and guidelines. 

• Other resource use and potential future uses of the area and of 

adjacent areas and of non-National Forest lands. 

• Areas where the investment necessary for project infrastructure 

(roads, bridges, etc.) is achievable with the estimated value of timber 

in the project area. Where infrastructure already exists, the project 

would allow any maintenance and upgrade of facilities necessary for 

removal of timber volume. 

• Area where investments for the project coincide with long-term 

management based on Forest Plan direction. 

The implementation of the sales on the timber sale plan depends in part 

on the final budget appropriation to the agency. In the event insufficient 

budget is allocated, or resolution of pending litigation or other factors 

delay planned sales, timber sale projects are selected and implemented 

on a priority basis. Generally, the higher-priority projects include sales 

where investments such as road networks, camps or log transfer 

facilities have already been established or where land management 

status is not under dispute. The distribution of sales across the Tongass 

is also taken into account to distribute the effects of sales and to provide 
Appendix A 

18 • Appendix A Kuiu Timber Sale FEIS 

sales in proximity to timber processing facilities. Timber sale projects 

scheduled for the current year that are not implemented, or the 

remaining volume of sales that are only partially implemented, are 

shifted to future years in the plan. The sale plan becomes very dynamic 

in nature due to the number of influences on each district. 

This project meets all laws and regulations governing the removal of 

timber from National Forest System lands, including Forest Service 

policies as described in Forest Service manuals and handbooks and the 

1997 Forest Plan and Record of Decision. Based on current year and 

anticipated future timber volume demand and the timber supply 

provisions of the Tongass Timber Reform Act, the analysis of the Kuiu 

Timber Sale is prudent at this time to meet timber sale needs as included 

on the approved multiple-year timber sale plan. The anticipated budget 

allocations and the availability of resources are sufficient to prepare and 

offer this project for sale as scheduled. 

This project is currently in Gate 2, Project Analysis. The amount of 

volume considered for harvest under the action alternatives ranges from 

14.1 MMBF to 41.4MMBF, which would contribute to the Tongass 

timber sale program. A no-action alternative is also analyzed in this 

EIS. If an action alternative is selected in the decision for this project, 

this volume will be added to the volume available for sale. 

As described in the Pools of Timber section of this appendix, the volume 

of timber needed to maintain Pool 1 is 4.5 times the amount of the 

projected harvest to account for projects at varying stages of analysis for 

that year. As displayed in Table A-2, the goal for volume under analysis 

is 589 MMBF. Currently, the forest-wide volume under analysis (Pool 

1) is about 490 MMBF and includes the volume for this project. This 

project contributes to timber sale program planning objectives to meet 

the goal of providing an orderly flow of timber from the Tongass on a 

sustained yield basis to meet timber supply requirements. It is 

reasonable to be conducting the environmental analysis for this project 

at this time. The timber volume from this project is currently proposed 

for offer in Fiscal Year 2008. 

As explained above, timber harvest project areas are selected for 

environmental analysis for a variety of reasons. The reasons this project 

is being considered in this area include: 

• The area is identified in the Forest Plan as Timber Production LUD. 

• The Kuiu Timber Sale Area contains sufficient acres of suitable and 

available forest land to make this timber harvest proposal reasonable. 

Areas with available timber need to be considered for harvest in 

order to seek to provide a supply of timber from the Tongass 

National Forest which (1) meets the annual market demand from 

such forest, and (2) meets the market demand from such forest for 

How Does This 

Project Fit into the 

Tongass Timber 

Program? 

Why is This Project 

Occurring in This 

Location? 
Appendix A 

Kuiu Timber Sale FEIS Appendix A • 19 

each planning cycle, pursuant to Section 101 of the Tongass Timber 

Reform Act (TTRA). 

• Providing substantially less timber volume than required to meet 

Forest Plan and TTRA Section 101 timber supply and employment 

objectives in order avoid harvest in the project area is not necessary 

or reasonable. 

• There is an existing road system. Some new NFS and temporary road 

would be required to access timber. 

• There are two LTFs with the associated sort yards available for log 

transfer. The Rowan Bay LTF would require no upgrading and the 

Saginaw Bay LTF would require some reconstruction, including the 

development of a low angle barge ramp. 

Effects on subsistence resources from timber harvest Tongass-wide are 

projected to have few differences based on the sequence in which areas 

are harvested. Harvesting other areas with available timber on the 

Tongass National Forest would be expected to have greater potential 

effects on subsistence resources because of the relatively low level of 

subsistence harvest in this project area. Harvest within other areas is 

foreseeable under the Forest Plan. 

Conclusion 

There is a long legislative recognition that timber harvest is one of the 

appropriate activities on national forests, starting with the founding 

legislation for national forests in 1897. The National Forest Organic Act 

provides that national forests may be established “to improve and 

protect the forest within the boundaries of, or for the purposes of 

securing favorable conditions of water flows and to furnish a continuous 

supply of timber for the use and necessities of the citizens of the United 

States.”

Congress’s policy for national forests, as stated in the Multiple-Use 

Sustained Yield Act of 1960, is “the national forests are established and 

shall be administered for outdoor recreation, range, timber, watershed, 

and wildlife and fish purposes.” Accordingly, Congress has authorized 

the Secretary of Agriculture to sell trees and forest products from the 

national forests “at no less than appraised value.” The National Forest 

Management Act directs that forest plans shall “provide for multiple use 

and sustained yield, and in particular, include coordination of outdoor 

recreation, range, timber, watershed, wildlife, fish and wilderness.” 

In addition to nationwide statutes, Section 101 of the Tongass Timber 

Reform Act directs the Forest Service to seek to meet market demand 

for timber from the Tongass, subject to certain qualifications. It is the 

goal of the Tongass National Forest to provide an even-flow of timber 

on a sustained-yield basis and in an economically efficient manner. The 
Appendix A 

20 • Appendix A Kuiu Timber Sale FEIS 

amount of timber offered for sale each year is based on the objective of 

offering enough volume for sale to meet the projected annual demand. 

That annual demand projection starts with installed mill capacity, and 

then looks to industry rate of capacity utilization under different market 

scenarios, the volume under contract, and a number of other factors, 

including anticipated harvest and the range of expected timber 

purchases. 

As described by Morse (April 2000), in terms of short-term economic 

consequences, oversupplying the market is less damaging than 

undersupplying it. If more timber is offered than purchased in a given 

year, the unsold volume is still available for re-offer in future years. The 

unsold volume would have no environmental effects because it would 

not be harvested. Conversely, a short fall in the supply of timber can be 

financially devastating to the industry. This project could supply from 

9.6 MMBF to 33.4 MMBF of volume for sale, with harvest potentially 

beginning in 2008. 

References 

Alexander, S. in preparation. Tongass National Forest Timber Sale 

Procedures: Using Information about Market Demand to Schedule FY 

2006 Timber Offerings (Draft). USDA Forest Service Region 10, 

Juneau AK. xx p. On file with: Regional Economist, Alaska Region, 

PO Box 21628, Juneau AK 99802 

Brackley, A.M.; Rojas, T.D.; Haynes, R.W. 2006. Timber products 

output and timber harvests in Alaska: projections for 2005-25. Gen. 

Tech. Rep. PNW-GTR-677. Portland, OR: U.S. Department of 

Agriculture, Forest Service, Pacific Northwest Research Station. 33 p. 

Brooks, D.J.; Haynes, R.W. 1997. Timber products output and timber 

harvests in Alaska: projections for 1997-2010. Gen. Tech. Rep. PNWGTR-409. Portland, OR: U.S. Department of Agriculture, Forest 

Service, Pacific Northwest Research Station. 17 p. 

Morse, K.S. 2000. Responding to the Market Demand for Tongass 

Timber: using adaptive management to implement Sec. 101 of the 1990 

Tongass Timber Reform Act. Manag. Bull. R10-MB-413. Juneau, AK: 

U.S. Department of Agriculture, Forest Service, Alaska Region. 43 p. 

Morse, K.S. 2000a. Tongass National Forest Timber Sale Procedures: 

Using Information about Market Demand to Schedule FY 2001 Timber 

Offerings. USDA Forest Service Region 10, Juneau AK. 17 p. 

USDA Forest Service, Forest Plan Amendment Draft Environmental 

Impact Statement, January 2006.