Appendix C 

Agency Responses 

to Public Comments on the 

Kuiu Timber Sale Area Draft 

Environmental 

Impact Statement 
 
Kuiu Timber Sale FEIS Appendix C ● 1 

Introduction to Appendix C 

After the Kuiu Timber Sale Area Draft Environmental Impact Statement (DEIS) was 

made available to the public, a Notice of Availability was published in the Federal 

Register on February 2, 2006. Publication of the Notice started a 45-day public comment 

period, which ended on March 20, 2006. Public notices announcing availability of the 

DEIS were also published in the Juneau Empire, the Newspaper of Record, and the 

Petersburg Pilot, the local Petersburg newspaper. 

The Forest Service received approximately 76,200 emails, the majority of which were 

form letters generated from the Natural Resources Defense Council and the Wilderness 

Society websites. Approximately 100 other letters and emails were received, the majority 

expressing disapproval with the project, but they contained no substantive remarks. 

Approximately 100 other letters and emails were received, the majority expressing 

disapproval with the project, but they contained no substantive remarks. These comments 

were noted as well as the preference for Alternative 1, the No Action alternative. The 

original comments are in the project planning record. 

Additionally, there were 11 email comment letters that addressed general issues such as 

timber economics, opposition of new roads, the cost of roadbuilding, the exportation of 

timber, and the subsidizing of timber companies. None of these letters were specific to 

the Kuiu Timber Sale. These comments were considered and many were responded to 

within responses to other comments more specific to the Kuiu project. These comments 

are in the project planning record. 

The Forest Service received 18 substantive comment letters in response to the Kuiu 

Timber Sale Area DEIS from agencies, organizations, and individuals (Table D-1). Five 

comment letters were received from state and federal agencies, five from organizations 

and eight from individuals. The Interdisciplinary Team responded to the comments. 

Summary of Comments 

The comments received covered several topics and ranged from general issues to quite 

detailed concerns about the analysis. 

A majority of the letters included comments regarding water quality and fish habitat. 

There was concern that logging would increase sedimentation to watershed areas and 

create adverse effects to salmon and other types of fish species. 

Many concerns were also voiced about the Forest Plan. The comments were that TLMP 

had been invalidated in NRDC v. U.S. Forest Service and that the Forest Service should 

not be pursuing timber projects until a new Forest Plan for the Tongass is completed. 

Timber economics in general, and in relation to the Forest Plan, was also brought up in 

several comments. 

Some comments expressed concern about deer. These included: the use of the deer 

model, important deer winter range, and affects on subsistence for the residents of Kake. 

There were some concerns raised about soil stability and the risk of landslides. It was 

suggested that unit boundaries be redrawn to exclude areas with extreme hazard MMI – 4 

soils. 
Introduction 

2 ● Appendix C Kuiu Timber Sale FEIS 

One organization expressed a preference for Alternative 4, two agencies preferred 

Alternative 2, and the remaining comment letters advocated Alternative 1, the No-Action 

Alternative. 

SHPO concurred with the Kuiu Timber Sale Draft EIS, as did the State of Alaska. The 

EPA rated the Draft EIS as EC-1 (environmental concerns, adequate information 

provided). 

Table C- 1. Letters received from Agencies, Organizations, and Individuals 

No. Commenter Public Numbers 

Public 

Comment

Agency 

Response 

1 Alaska Coastal Management Program C3-6 C7 

2 Environmental Protection Agency C8-11 C12 

3 National Marine Fisheries Service C13-16 C17-19 

4 Department of the Army C20 C21 

5 Organized Village of Kake C22-24 C25-27 

6 Consolidated comments from: 

Greenpeace, Sitka Conservation 

Society, Juneau Group of the Sierra 

Club, The Wilderness Society, and the 

Natural Resources Defense Council 

C28-70 C71-98 

7 Southeast Alaska Conservation Council C99-106 C107-111 

8 The Committee on Conservation of 

Forests and Wildlife C112-114 C115-118 

9 Chico Area Fly Fishers C119-122 C123-125 

10 Sealaska Corporation C126-127 C128 

11 Dave Beebe C129-133 C134-140 

12 Edna Jackson C141-143 C144-145 

13 Katie Fearer C146 C147-148 

14 Glen Ith C149-151 C152-153 

15 John Kober C154 C155-156 

16 Mike Jackson C157-159 C160-162 

17 Steve Mashuda C163-165 C166-168 

18 Chris Zimmer, Juneau, Alaska C169-170 C171-172 

19 NRDC form letter C173 C174 

20 WS form letter C175 C176 
 Comment Letter #1 - ACMP 

Kuiu Timber Sale FEIS Appendix C ● 3 

 ACMP -1 
Comment Letter #1 - ACMP 

 4 ● Appendix C Kuiu Timber Sale FEIS 
 Comment Letter #1 - ACMP 

Kuiu Timber Sale FEIS Appendix C ● 5 

 ACMP - 2 
Comment Letter #1 - ACMP 

6 ● Appendix C Kuiu Timber Sale FEIS 

 ACMP - 3 
 Response to ACMP 

Kuiu Timber Sale FEIS Appendix C ● 7 

ACMP - 1 

The Forest Service notes the concurrence that the project is consistent with the ACMP 

and affected coastal district’s enforceable policies, to the maximum extent practicable. 

ACMP - 2 

The State’s preference for Alternative 2 has been noted. 

ACMP - 3 

The Forest Service will comply with all applicable State and federal regulations. The 

Forest Service will contact the Office of Project Management/Permitting if there is need 

for further review and approval. If cultural resources are discovered during project 

implementation, any work that may disturb those resources will stop and the Forest 

Service will proceed with Section 106 consultation. 
Comment Letter #2 - EPA 

8 ● Appendix C Kuiu Timber Sale FEIS 

 EPA - 1 
 Comment Letter #2 - EPA 

Kuiu Timber Sale FEIS Appendix C ● 9 
Comment Letter #2 - EPA 

10 ● Appendix C Kuiu Timber Sale FEIS 

 EPA - 2 

 EPA - 3 

 EPA - 4 
 Comment Letter #2 - EPA 

Kuiu Timber Sale FEIS Appendix C ● 11 

 
Response to EPA 

12 ● Appendix C Kuiu Timber Sale FEIS 

EPA - 1 

The EPA’s rating of EC-1 (Environmental Concerns-Adequate Information) and support for 

the selection of Alternative 2 is noted. 

EPA - 2 

The recommendation to discuss short-term impacts to watersheds in more detail has been 

addressed by expanding Issue 4 in Chapter 3 of the FEIS. Short-term sediment loading is 

expected to be consistent with the Forest Plan, and is not expected to exceed water quality 

standards set by the State of Alaska. The recommendation to avoid or minimize harvest in 

watersheds that have past cumulative harvest levels near 20 percent or greater is noted. The 

DEIS (p. 3-124) notes that because of the age of the majority of the existing clearcuts the 30-

year cumulative harvest levels within all the watersheds would be less than 12 percent by the 

year 2011, including the harvest from any of the proposed alternatives. 

EPA - 3 

The DEIS (p. 3-195) states that within four to seven years after harvest, root strength tends to 

decrease and soil cohesion begins to lesson, however, the upper time limit is not well 

defined. This discussion has been expanded in the FEIS to respond to the recommendation 

that the FEIS discuss the timeframe when mass movement would likely occur. 

EPA - 4 

The recommendation for the selection of Alternative 2 is noted. 
 Comment Letter #3 - NMFS 

Kuiu Timber Sale FEIS Appendix C ● 13 
Comment Letter #3 - NMFS 

14 ● Appendix C Kuiu Timber Sale FEIS 

 NMFS 

 1 

 NMFS 

 2 

 NMFS 

 3 

 

 NMFS 

 4 
 Comment Letter #3 - NMFS 

Kuiu Timber Sale FEIS Appendix C ● 15 

 NMFS 

 5a 

 

 NMFS 

 5b 

 NMFS 

 5c 

 NMFS 

 5d 

 

 NMFS 

 6 

 NMFS 

 7 

 NMFS 

 8 

 NMFS 

 9 

 NMFS 

 10 

 NMFS 11 

 NMFS 12 

 NMFS NMFS 

 13 

 NMFS 

 14 

 
Comment Letter #3 - NMFS 

16 ● Appendix C Kuiu Timber Sale FEIS 

 NMFS 

 15 

 NMFS 

 16 

 NMFS 

 17 

 NMFS 

 18 

 
 Response to NMFS 

Kuiu Timber Sale FEIS Appendix C ● 17 

NMFS - 1 

That NMFS concurs with the Forest Service determination is noted. 

NMFS - 2 

Culverts which reduce or restrict fish passage are being looked at and prioritized on a 

forest-wide level. The potential for correcting the red culverts in the planning area was 

examined and the opportunity to improve fish passage where road work is proposed for 

the timber sale project was incorporated. Two red fish passages problems will be 

corrected with the implementation of any of the action alternatives, creating a reduction 

in the cumulative impacts to fish passage. 

NMFS - 3 

Best Management Practices (BMPs) are sufficient to protect water quality. The existing 

roads were constructed before BMPs were in place. All proposed roads and 

approximately 8 to 11 miles of currently open NFS roads would be closed after timber 

harvest is complete. An interagency group is currently working on a model that would 

help make management recommendations for the red culverts. The model was tested in 

2006 and the preliminary findings are available. The model requires refinement and 

additional data needs to be collected before it can be used for all culverts on the forest. 

NMFS - 4 

A soil stability analysis was completed by a Soils Scientist for all MMI-4 soils within 

planned road locations and timber harvest units. All unstable slopes were avoided. 

However, due to numerous concerns, those units with MMI-3 and MMI-4 soils were 

reanalyzed. Units 207, 303, and 305 (see unit cards in FEIS Appendix B) will be 

modified to exclude the MMI-4 soils. For Unit 101, the MMI-4 soils in the southeast 

corner of the unit will be removed and the area along the western edge of the unit will 

remain. There are no streams in this area and the risk of sedimentation delivery to a 

stream is very small. The majority of the slope within unit 417 was between 45-65% and 

very little slope gradient over 70%. Where 70% slope gradients did exist, the area was 

well benched, well drained, and had no evidence of slumping or sliding. Although the 

GIS database has identified soils at the northeast corner as being MMI-3, this area is 

considered low risk for mass movement potential. 

NMFS - 5a 

The numbers in the DEIS were the numbers in the dive report. When the dive report was 

sent to ADEC it was reanalyzed and decided that the amount of bark accumulation was 

over estimated. The number reported by ADEC will be used in the FEIS. 

NMFS - 5b 

There are many variables that make estimation of additional bark accumulation 

impossible. If the logs are barged, then no significant amount of bark accumulation is 

expected as a result of this timber sale. If the logs are placed in the water, the amount of 

bark accumulation depends on: how much bark is on the trees when placed in the water, 

the wave action of the water, how long the logs are in the water, the time of year that the 

trees are harvested, and how the logs are placed in the water. The bark accumulation will 
Response to NMFS 

18 ● Appendix C Kuiu Timber Sale FEIS 

be monitored and if the accumulation exceeds EPA standards then appropriate action will 

be taken. 

NMFS - 5c 

Neither LTF meets all of the 1985 siting and construction guidelines. This, however, is 

not a requirement because they were constructed before 1985. The common practice in 

the timber industry is to barge logs; however, both the Saginaw and Rowan Bay LTFs are 

permitted under the EPA General Permit AK-G70-0027 to raft logs. It is important to 

retain the flexibility to raft logs if needed. 

NMFS - 5d 

The cost of a barge LTF is not significantly different from an in-water LTF. Both the 

Saginaw and Rowan Bay LTFs can accommodate barges at this time; however, Saginaw 

LTF could use additional work to make barging easier and more convenient. The benefit 

to biological resources of a barge LTF is that very little bark accumulation will occur. 

NMFS - 6 

The order of the watersheds in the tables was made consistent within the section to 

facilitate easier comparisons. 

NMFS - 7 

Please see NMFS – 5a for response to this comment. 

NMFS - 8 

The 20-year time frame referred to in the DEIS (p.3-114) describes the expected recovery 

time, with respect to landslide risk, for harvested slopes. This number comes directly 

from a paper that assessed slope recovery time (Brardinoni et al., 2002), and that paper is 

cited in the DEIS (p. 3-114). The 30-year time frame referred to elsewhere in the 

document comes from the Forest Plan, which states that a more complex watershed 

analysis should be conducted in watersheds having more than 20 percent of the watershed 

acres with trees in second-growth younger than 30 years. This direction is described in 

the DEIS (p.3-112). 

NMFS - 9 

There is an error on page 3-117 of the DEIS. The correct cumulative harvest level for 

Saginaw Creek is 29 percent, as stated in Appendix C on page C-27. This error has been 

corrected in the FEIS. 

NMFS - 10 

The information requested has been added to the Hydrology Resource report that is 

available in the planning record. It was not included in the FEIS to minimize document 

size. 

NMFS - 11 

The inherent SRI was included in the FEIS table. 
 Response to NMFS 

Kuiu Timber Sale FEIS Appendix C ● 19 

NMFS – 12 

The red and gray culvert locations are available by road number from the Road Condition 

Surveys located in the planning record. This information does not include watershed 

names. 

NMFS - 13 

Detailed stream channel condition assessments were only conducted for watersheds with 

greater than 20% cumulative harvest. Because Rowan Creek and 109-44-10370 do not 

exceed this threshold, the information requested is not available. 

NMFS - 14 

See NMFS - 2 for response 

NMFS - 15 

See NMFS - 4. 

NMFS - 16 

Units 207, 303, and 305 will be modified to exclude the MMI-4 soils. For unit 101, the 

MMI-4 soils in the southeast corner of the unit will be removed and the area along the 

western edge of the unit will remain. All roads opened for this project will be placed in 

storage after timber harvest is complete and additional miles of road will be placed in 

storage. Unstable slopes were avoided in road locations and timber harvest units. 

NMFS - 17 

As part of this project, approximately 8 to 11 miles of open road will be placed in 

storage. Some of these activities are in the beginning stages of analysis and may be 

completed before the FEIS can be implemented and others are outside the purpose and 

need of this project. 

NMFS - 18 

The common practice in the timber industry is to barge logs, however, the Rowan Bay 

and Saginaw Bay LTFs are permitted under the EPA General Permit AK-G70-1000 to 

raft logs. It is important to retain the flexibility to raft logs if needed. 
Comment Letter #4– Dept. of the Army 

20 ● Appendix C Kuiu Timber Sale FEIS 

 

 DA - 1 

 DA - 2 
 Response to Dept. of the Army 

Kuiu Timber Sale FEIS Appendix C ● 21 

DA - 1 

The Forest Service acknowledges the concurrence that all temporary roads proposed for 

this project are exempt from Clean Water Act permitting, provided they are constructed 

according to BMPs (best management practices). No new NFS roads proposed for this 

project would be maintained for public use. New NFS roads would be closed and placed 

in storage at the end of timber harvest activities. New NFS roads would also utilize BMPs 

listed in 33 CFR 323.4. 

DA - 2 

The Forest Service notes that reconstruction of Saginaw Bay LTF and/or modifications to 

Rowan Bay LTF may require DA authorization. 
Comment Letter #5 - Organized Village of Kake - OVK 

22 ● Appendix C Kuiu Timber Sale FEIS 
Comment Letter #5 - Organized Village of Kake - OVK 

Kuiu Timber Sale FEIS Appendix C ● 23 

 OVK 

 3 cont.

 OVK 

 4 

 OVK 

 5 
Comment Letter #5 - Organized Village of Kake - OVK 

24 ● Appendix C Kuiu Timber Sale FEIS 

 OVK 

 5 cont. 

 OVK 

 6 

 
 Response to OVK 

Kuiu Timber Sale FEIS Appendix C ● 25 

OVK - 1 

At this time the Forest Service and the Organized Village of Kake (OVK) are working 

towards a Memorandum of Understanding which establishes a general framework for the 

exchange of information and defines the expectations of meaningful consultation between 

OVK and officials on the Petersburg Ranger District (District). However, at this time the 

agreement is not complete and at the time of the planning of the Kuiu Timber Sale this 

agreement had not been written. The District strives to conduct meaningful consultation. 

The intent of the agreement is to provide guidelines to make consultations satisfactory to 

both parties. 

The District met with OVK, who has a cultural affiliation with the lands associated in the 

Project Area and on Kuiu Island, with the intent of providing an opportunity for the 

exchange of information. On June 3, 2004 and again in November 22, 2004, Forest 

Service Resource Specialists and Patricia Grantham, Petersburg District Ranger, met with 

Henrich Kadake, Sr., OVK President, and other OVK staff members to discuss the 

proposed project (DEIS Chapter 1-15, 16, Chapter 3-261, FEIS Chapters 1 and 3). These 

meetings included written information-sharing and government to government meetings 

between the District Ranger and OVK staff. In addition, the District held two Open 

Houses in Kake during these dates. The open houses included Project Area maps and 

District personnel available for discussions. On March 21, 2006, Patricia Grantham, 

Petersburg District Ranger, again meet with Henrick Kadake, Sr., OVK President and 

other OVK staff members to discuss the Kuiu Timber Sale Project. A subsistence hearing 

was held in Kake as per ANILCA Section 810 requirements in conjunction with this 

meeting. On May 21, 2006, the District Ranger and several District Specialists met with 

OVK staff to discuss ongoing district activities including the Kuiu Timber Sale project. 

The Forest Service solicited comments from OVK regarding cultural resources in the 

Project Area. As stipulated in Section 106 of the National Historic Preservation Act, the 

Heritage Resource Specialist report was presented to OVK for review and comment. The 

District Archeologist made several contacts in order to update the City of Kake 

community profile. 

OVK - 2 

The request urging the Forest Service to halt all planning activities related to the Kuiu 

Timber Sale project until the Forest Plan revision is complete has been noted. 

In August 2005, the Ninth Circuit held that the environmental impact statement and 

record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the 

use of projected market demand for timber, the range of alternatives considered, and the 

cumulative effects of activities on non-National Forest System lands. In response to the 

Court ruling, the Forest Plan is currently being amended through an environmental 

impact statement. The DEIS for the amendment was released for public comment in 

January 2007. 

FAA is currently analyzing market demand. Appendix A has been updated with the 

information from Brackley et al. 
Response to OVK 

26 ● Appendix C Kuiu Timber Sale FEIS 

The court listed its findings in Natural Resources Defense Council v. U.S. Forest Service

but did not list any requirements within that document. In response to the court’s decision 

the Tongass chose to amend the Forest Plan. This ruling did not put the Forest Plan “out 

of commission.” Projects will move forward, with the Forest Plan continuing to be the 

guiding document and contract with the public. It would be irresponsible to stop 

providing raw materials to help locally-owned businesses survive and to help Southeast 

Alaska communities. The Forest Plan is currently being amended, but the Forest Service 

land-management mission cannot be put on hold. The Tongass National Forest will 

continue to be managed in compliance with Section 101 of the Tongass Timber Reform 

Act of 1990 (TTRA), which modified the Alaska National Interest Lands Conservation 

Act (ANILCA). TTRA states that the Secretary of Agriculture “...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 market 

demand from such forest for each planning cycle.” To provide a steady flow of timber 

harvest volume, timber sale projects need to be completed through the NEPA process 

each year to meet current and future market demand. This is described more fully in 

Appendix A of the FEIS. 

OVK - 3 

The Forest Service made several attempts to involve the people of Kake with the 

planning process and to address the responses received. Scoping comments included the 

desire for small scale projects that could increase employment, and concerns over 

competition for subsistence items and the concern over low deer populations on Kuiu 

Island. 

• Small timber sales were considered but dropped because they were not 

economical 

• The competition for subsistence was analyzed in the DEIS (p. 3-86), and 

• The proposed activities are not expected to result in a significant restriction of 

subsistence uses (DEIS p. 3-95) 

• See paragraph 1 of OVK - 1 

 

OVK - 4 

The Organized Village of Kake feels the 1960s deer use figures substantially 

underestimate what the use was in those years, and that this carries over into 

underestimating current and future demand estimated by the Alaska Department of Fish 

and Game. Several declarations from Kake residents attest to their remembrance of deer 

taken from Kuiu during the 1950s and 1960s. Several residents recall that more than 30 

deer were taken by them or their families alone, and others estimate around 80 for an 

extended family to more than 100 for Kake people. 

Kake residents have pointed out that their recent (since 1975) reliance on Admiralty 

Island for deer hunting is not their preference, and that as the Kuiu herds increase more of 

their hunting will shift back to Kuiu Island. Kake residents on average (based 1993 to 

1995) take about 250 deer annually (TLMP Revision FEIS, Appendix H, p. H-76, based 

on 75% of their harvest being 185 deer). If all of these deer were harvested from Kuiu 
 Response to OVK 

Kuiu Timber Sale FEIS Appendix C ● 27 

the minimum deer needed to support that demand would be 2,500 deer. Table 3-29 shows 

that WAA 5012 would be able to meet this demand in all alternatives. 

All action alternatives would result in reductions of deer habitat capability. Alternatives 2 

and 3 would result in less than one percent decline in deer habitat capability. Alternatives 

4 and 5 would result in a one percent decline in deer habitat capability in WAA 5012. 

WAA 5012 has the habitat capability to meet the population objects and support a deer 

population sufficient to meet the State of Alaska’s population objectives and the hunter 

demand for the people of Kake at this time, even after applying the 36 percent reduction 

factor for wolf predation (DEIS, p. 3-83 Table 3-29). 

OVK - 5 

The FEIS has been updated to include current population estimates and uses the 

following income and employment information. 

U.S. Census data for Kake from the year 2000 shows the median household 

income was $39,643, per capita income was $17,411, and 14.61 percent of 

residents were living below the poverty level. 

A letter dated February 2006 from the Denali Commission confirmed Kake’s 

classification as a distressed community. Based on 2003 data, the Denali 

Commission estimates Kake average market income as below the $14, 872 

threshold level and that more than 70% of residents age 16 and over earned less 

than the threshold. 

The FEIS has been updated as much as possible with the following sites used as sources: 

1. Alaska Department of Commerce, Community and Economic Development 

community database (www.dced.state.ak.us), 

2. Denali Commission website (www.denali.gov), 

3. Kake Community Economic Development Strategy (2004) (the page provided) 

4. U.S. Census Bureau, Census 2000 (http://censtats.census.gov/pub/Profiles.shtml), 

and 

5. Personal communication with Kake Schools, OVK, the City of Kake and Jeannie 

Monk (Denali Commission). 

The Forest Service notes that Kake Foods has not operated for the past two years and that 

Kake Tribal recently sold all of its logging equipment. The Forest Service also 

acknowledges that as income has dropped, reliance on subsistence has increased. The 

FEIS Environmental Justice section (FEIS Ch 3 – Socioeconomics Section) has been 

expanded to recognize the above-mentioned conditions in Kake and acknowledge that 

during times of economic hardship tribal members depend even more on the gathering of 

customary and traditional foods. As a result of the project, the analysis shows conditions 

are not expected to worsen and there may be opportunity for employment (FEIS 

Socioeconomics Section) 

OVK - 6 

The preference for Alternative 1, the No-Action Alternative has been noted.
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

28 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 1a 

 GSS 

 1b 

 GSS 

 1c 

 GSS 

 2 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 29 

 GSS 

 2 cont. 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

30 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 2 cont. 

 GSS 

 3a 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 31 

 GSS 

 3a cont.

 GSS 

 3b 

 GSS 

 3c 

 GSS 

 4a 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

32 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 4b 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 33 

 GSS 

 4c 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

34 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 4d 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 35 

 GSS 

 4e 

 GSS 

 5a 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

36 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 5b 

 GSS 

 5c 

 GSS 

 6 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 37 

 GSS 

 7 

 GSS 

 7 cont. 

 GSS 

 8a 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

38 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 8a cont.
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 39 

 GSS 

 8a cont.
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

40 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 8a cont. 

 GSS 

 8b 

 GSS 

 9a 

 GSS 

 9b 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 41 

 GSS 

 10a 

 GSS 

 10b 

 GSS 

 10c 

 GSS 

 11 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

42 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 11 cont.

 GSS 

 12 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 43 

 GSS 

 12 cont. 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

44 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 13a 

 GSS 

 13b 

 GSS 

 14 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 45 

 GSS 

 15a 

 GSS 

 15b 

 GSS 

 15c 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

46 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 15c cont. 

 GSS 

 15d 

 GSS 

 15e 

 GSS 

 15f 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 47 

 GSS 

 16 

 GSS 

 17 

 GSS 

 18 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

48 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 18 cont. 

 GSS 

 19 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 49 

 GSS 

 20 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

50 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 21a 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 51 

 GSS 

 21a cont. 

 GSS 

 21c 

 GSS 

 21b 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

52 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 21c cont. 

 GSS 

 21d 

 GSS 

 21e 

 GSS 

 21f 

.
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 53 

 GSS 

 21g 

 GSS 

 21h 

 GSS 

 21i 

 GSS 

 21j 

 GSS 

 21k 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

54 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 21k cont

 GSS 

 22b 

 GSS 

 22a 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 55 

 GSS 

 22c 

 GSS 

 22d 

 GSS 

 22e 

 GSS 

 22f 

 GSS 

 23a 

 GSS 

 23b 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

56 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 23b cont 

 GSS 

 23c 

 GSS 

 23d 

 GSS 

 24a 

 GSS 

 24b 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 57 

 GSS 

 25a 

 GSS 

 25b 

 

 GSS 

 25c 

 GSS 

 25d 

 GSS 

 25e 

 GSS 

 25f 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

58 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 25f cont

 GSS 

 26a 

 GSS 

 26b 

 GSS 

 26c 

 GSS 

 26d 

 GSS 

 26e 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 59 

 GSS 

 27 

 GSS 

 28 

 GSS 

 29 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

60 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 30 

 GSS 

 31 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 61 

 GSS 

 32a 

 GSS 

 32b 

 GSS 

 32c 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

62 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 33a 

 GSS 

 33b 

 GSS 

 34 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 63 

 GSS 

 35 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

64 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 36 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 65 

 GSS 

 37 

 GSS 

 38 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

66 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 38 cont. 

 GSS 

 39 

 GSS 

 40 

 GSS 

 41 

 GSS 

 42 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 67 

 GSS 

 43a 

 GSS 

 43b 

 GSS 

 43c 

 GSS 

 44a 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

68 ● Appendix C Kuiu Timber Sale FEIS 

 GSS 

 44b 

 GSS 

 45 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

Kuiu Timber Sale FEIS Appendix C ● 69 
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau 

Group of the Sierra Club, The Wilderness Society, and the Natural 

Resources Defense Council -GSS 

70 ● Appendix C Kuiu Timber Sale FEIS 

 
 Response to GSS 

Kuiu Timber Sale FEIS Appendix C ● 71 

GSS - 1a and 1b 

In August 2005, the Ninth Circuit held that the environmental impact statement and 

record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the 

use of projected market demand for timber, the range of alternatives considered, and the 

cumulative effects of activities on non-National Forest System lands. In response to the 

Court ruling, the Forest Plan is currently being amended through an environmental 

impact statement. The DEIS for the amendment was released for public comment in 

January 2007. 

FAA is currently analyzing market demand. Appendix A has been updated with the 

information from Brackley et al. 

Forest plans are programmatic documents that guide future projects. The decisions to be 

made in a forest plan involve whether and how to change existing management direction. 

The status quo for a forest plan decision is the pre-existing management direction, not a 

complete cessation of all management activities. It would be counterproductive to 

sustainable management if all activities were shut down during the periodic amendments 

and revisions of forest plans. 

In NFMA, Congress directed that forest management continue under existing plans while 

the first NFMA forest plans were being developed [16 U.S.C. 1604(c)]. Likewise, under 

NEPA, the Council on Environmental Quality has recognized that the “no action” 

alternative for forest plans is the current management direction, not a halt of all activities 

[CEQ’s “40 Questions” #3]. Even if the Kuiu project is completed, the Project Area is 

still eligible to be designated as any of the land use designations, as harvested lands are 

included in reserve land use allocations. 

GSS – 1c 

The entire Tongass was evaluated and reviewed for possible Wilderness recommendation 

in the 2003 TLMP SEIS. All Tongass National Forest lands were assessed to determine if 

they were suitable for wilderness consideration based on the Wilderness Act and 

procedures in the Forest Service’s forest planning directives. Appendix C (TLMP SEIS 

Volumes II and III) includes documentation of the analysis and evaluation for each 

inventoried roadless area, and describes the relative contribution each roadless area 

would make to the National Wilderness Preservation System. The SEIS documents the 

results of a very intensive additional roadless area evaluation for the Tongass conducted 

in 2002 and 2003. This included updated mapping and evaluation of all unroaded lands, 

which led to the 109 inventoried roadless areas analyzed in the Final SEIS. The Kuiu 

roadless areas were evaluated and not recommended for Wilderness. 

The current revised Forest Plan allows for the activities in Kuiu to take place. Delaying 

planning and analysis regarding road building and timber harvest, even for a short time 

period, have a significant effect on the amount of timber available for sale in the next 

year, due to the time needed for sale preparation, appraisal and advertisement, and to 

provide for the time period when sale areas are typically inaccessible (winter months). 
Response to GSS 

72 ● Appendix C Kuiu Timber Sale FEIS 

The settlement agreement for Natural Resources Defense Council v. U.S. Forest Service, 

Case No.1: 03-cv-0029-JKS signed by both parties in April 2007, has been approved by 

the District Court on May 23, 2007. As part of this settlement agreement, the Forest 

Service will not sign new RODs or other decision documents for timber sales in 

Inventoried Roadless Areas or on Kuiu Island. For purposes of this agreement, the Forest 

Service will not take this and other actions described below until 30 days after 

publication of the notice of availability of the FEIS for the Tongass Forest Plan 

amendment in the Federal Register, unless the Forest Service designates a later effective 

date for the new plan, in which case the Forest Service will not take these actions until 

the effective date designated by the Forest Service. 

GSS - 2 

The EPA has rated the DEIS for Kuiu Timber Sale as Environmental Concerns- EC-1 

consistent with EPA’s rating system (see the EPA letter earlier in this Appendix). 

Turbidity monitoring, as described in the 2004 Annual Monitoring and Evaluation 

Report, included consultation with the Alaska Department of Environmental 

Conservation according to the memorandum of agreement between the agencies. The 

preliminary data and analysis, coupled with observations of appropriate BMP 

implementation on site, provide assurance of compliance with Alaska Water Quality 

Standards for turbidity. There were no violations of state water quality standards for 

turbidity issued by the State. 

The Forest Plan Monitoring and Evaluation Plan does not require the collection of 

sediment data. The Forest Plan Monitoring and Evaluation Plan, and the Kuiu DEIS (see 

p. 2-22 to 23) emphasize monitoring to ensure that BMPs are implemented as planned. 

The Forest Service’s implementation and monitoring of BMPs satisfies the requirements 

of the Alaska Non-point Source Pollution Control Strategy and is approved by the U.S. 

EPA, thereby ensuring that USFS activities are consistent with the Clean Water Act. No 

violations of the water quality standards for sediment are expected to occur as a result of 

the Kuiu Timber Sale project. 

GSS - 3a 

The Forest Plan (p. 4-96) says to use clearcutting where such a practice is determined to 

be the best system to meet the objectives and requirements of the Land Use Designation 

(LUD). Even-aged management, clearcutting, in the Timber Production LUD is a way to 

increase the commercial timber productivity of the site. As stated in the DEIS, (p.1-6) 

the Timber Production LUD is managed for the production of saw timber and other wood 

products. Pages 3-160 and 3-161 of the DEIS describe the reasons for using even-aged 

management. 

These lands are in a Timber Production LUD and an objective of this LUD is to increase 

the commercial timber productivity. It is for this reason that the removal of stands with 

dwarf mistletoe and wood decay fungi through even-aged management, to improve forest 

health and commercial productivity, is a valid consideration. 
 Response to GSS 

Kuiu Timber Sale FEIS Appendix C ● 73 

GSS - 3b 

Refer to GSS-3a for the objectives of Timber Production LUDs. The differences between 

clearcut logging and windthrow openings is discussed in the DEIS (p. 3-25). 

GSS - 3c 

The reasons to clearcut are explained in the Timber and Vegetation Resources section in 

Chapter 3 of the FEIS, in the above responses and in the Timber and Vegetation resource 

report. 

GSS - 4a – 4e 

FAA is currently analyzing market demand. Appendix A has been updated with the 

information from Brackley et al.

GSS - 5a 

The DEIS findings (p. 3-95) for the potential foreseeable effects from the action 

alternatives in the Kuiu Timber Sale Area are not expected to result in a significant 

restriction of subsistence uses. The Forest Plan Record of Decision (p. 36) concluded that 

the potential cumulative effects of implementation of the Plan could lead to a significant 

possibility of a significant restriction to subsistence use of deer in some areas at some 

time in the future due to the potential effects of projects on the abundance and 

distribution of these resources, and on competition for these resources. The competition 

was based on an 18 percent increase in community population growth for each of the first 

two decades and a 15 percent increase for each of the next three decades (FEIS Part 2, p. 

3-528 and DEIS p. 3-96). An 18% population growth has not occurred, yet. 

See reply GSS - 4a - e for a response about the market demand calculations and TTRA 

directions. 

The Forest Plan identifies all areas as open for subsistence uses and it would be difficult 

to identify an area that is “less sensitive to logging.” Logging creates environmental 

effects to resources; while logging in a specific area may reduce effects for one resource 

it may increase effects to another resource. Examples follow: 

When logging is planned on another island it may not affect Kake subsistence hunters but 

it would affect other subsistence users. 

When logging is planned in an area that has no prior logging many of the effects are 

diluted over the area and cumulative effects would be small, but this approach is not 

embraced by the general public because of the costs of road building and the potential 

fragmentation of old-growth patches. 

When logging occurs in an area that is already logged, such as the Kuiu Timber Sale area, 

the cumulative effects are compounded by past actions, fragmented forests are further 

fragmented, old-growth patches are further reduced in size, and wildlife travel corridors 

may be reduced or removed. However, analysis of the subsistence resources does not 

show a significant possibility of a significant restriction of subsistence resources, now or 

in the future. 

GSS - 5b 

See reply GSS - 4a-e and 5a 
Response to GSS 

74 ● Appendix C Kuiu Timber Sale FEIS 

GSS - 5c 

The DEIS findings (p. 3-95) for the potential foreseeable effects from the action 

alternatives in the Kuiu Timber Sale Area are not expected to result in a significant 

possibility of a significant restriction of subsistence uses. See reply GSS - 5a. 

GSS - 6 

See reply GSS-7, GSS-9a and GSS-11. 

No “pre-roading” has been done for the Kuiu Timber Sale. Maintenance and 

reconditioning of existing National Forest System (NFS) roads is an ongoing process that 

occurs on a periodic basis. Normally this kind of road work is determined to fit the 

category of routine repair and maintenance of roads that do not individually or 

cumulatively have a significant effect on the quality of the human environment and may 

be categorically excluded from documentation in an EIS or an EA unless scoping 

indicates extraordinary circumstances (FSH 1909.15, 31.12, #4). The maintenance and 

reconditioning of NFS roads on the project area may occur before, during and after the 

project analysis. This work is done through separate service contracts to reduce the 

backlog of deferred maintenance, recondition roads to comply with best management 

practices, maintain the existing infrastructure for the proposed timber sale or future 

harvest entries, and other National Forest management activities. The timing of this work 

may coincide with this project's analysis but is not part of the proposed action or 

alternatives being considered. See GSS-9a for further discussion. 

 

GSS - 7 

NEPA requires the disclosure of effects on the human environment, not the 

administrative costs of managing timber sale projects. Unlike socio-economic impacts 

considered in the Kuiu FEIS, administrative costs do not have impacts on the larger 

public the way the jobs created by timber sales do. Administrative costs play no part in 

the economic justification of the project. They are administrative costs, not economic 

benefits of the project. 

Even though NEPA does not require it, the administrative costs associated with 

implementing the Kuiu Timber Sale Area project are addressed. The Kuiu Timber Sale 

Area DEIS uses the average costs across the Alaska Region for administering timber 

sales (DEIS, pp. 3-107 - 3-108). These costs are based on calculations outlined in the 

Declaration of Forrest Cole (Decision Document #838). The Forest Service must use 

estimates of costs and revenues for timber sales in project NEPA documents as the actual 

costs and revenues will not be finally determined until the sales are sold. 

GSS – 8a 

The costs displayed in the comments include total expenditures by the Forest Service in 

various categories, derived from tables of expenditures by budget line item (BLI) from 

Tongass National Forest monitoring reports, 1998-2003. Although total expenditures by 

BLI include on-the-ground costs of timber sale planning, sale preparation, engineering 

support, and sale administration, timber sale costs to the Forest Service constitute only a 

portion of the various BLI totals. The expenditures in a BLI are the expenditures for the 
 Response to GSS 

Kuiu Timber Sale FEIS Appendix C ● 75 

entire National Forest in a given category in a given year, and cannot be attributed to 

specific projects. As outlined in the Declaration of Forrest Cole lodged with the District 

Court in NRDC v. Forest Service, (Case No. J04-010CV (JKS) Decision Document 

#838), the timber sale process is a multiple year process and there is no expectation that 

expenditures and actual harvest will occur in the same year. 

The Forest Service is not mandated to make money by offering timber for sale. The 

Timber program is not unusual in costing more to operate than the government receives 

in revenues from the program. Many programs on the Tongass NF generated no revenue, 

including the subsistence, heritage, inventory and monitoring, land management 

planning, geology, fish and wildlife management, trail improvements, and fire protection 

programs. 

The Forest Service is directed to sell commercial timber sales at not less than appraised 

rates. The Alaska Region implements this direction by established appraisal 

methodologies. Forest Service administrative costs play no part in the calculation of 

appraised value. 

NEPA requires the disclosure of effects on the human environment, not the 

administrative costs of managing timber sale projects. Unlike socio-economic impacts 

considered in the Kuiu FEIS, administrative costs do not have impacts on the larger 

public the way the jobs created by timber sales do. Administrative costs play no part in 

the economic justification of the project. They are administrative costs, not economic 

benefits of the project. 

Even though NEPA does not require it, the administrative costs associated with 

implementing the Kuiu Timber Sale Area project are displayed. The Kuiu Timber Sale 

Area DEIS uses the average costs across the Alaska Region for administering timber 

sales (DEIS, pp. 3-107 – 3-108). These costs are based on calculations outlined in the 

Declaration of Forrest Cole (Decision Document #838). The Forest Service must use 

estimates of costs and revenues for timber sales in project NEPA documents as the actual 

costs and revenues will not be finally determined until the sales are sold. 

GSS - 8b 

See reply GSS - 4a-e 

GSS - 9a 

The Forest Service receives annual road maintenance monies to be used for maintenance 

of the road systems for the present and perceived problem areas of the road system. 

Petersburg Ranger District is composed of several island road systems and the annual 

maintenance monies are generally divided between these island systems. As with Kuiu 

Island road system, the maintenance monies were allocated toward the mainline roads 

that receive the most usage. Forest Roads 6402, 6448, 6404, and 6415 are maintenance 

level 2 and 3 roads as delineated in the Tongass National Forest Forest-Level Roads 

Analysis Table D1 and the Kuiu Landscape Assessment Appendix A Tables E and F. It 

is the Forest Service’s responsibility to keep roads open for public use, maintained for 
Response to GSS 

76 ● Appendix C Kuiu Timber Sale FEIS 

safety of the public and the resources, and address the concern (in items GSS-14 and 

GSS-39) to maintain existing roads to avoid long-term adverse effects. 

Originally built for management of the timber resource, many of these roads are used for 

recreation, sport hunting, and subsistence use. The maintenance on these roads would 

have occurred whether or not timber harvest was planned for this Project Area. 

Maintenance and reconditioning of existing National Forest System (NFS) roads is an 

ongoing process that occurs on a periodic basis. The maintenance and reconditioning of 

NFS roads on the Project Area may be in the process of implementation, before, during 

and after the project planning process through separate service contracts to reduce the 

backlog of deferred maintenance. Reconditioning roads may be done to comply with best 

management practices, maintain the existing infrastructure for the proposed timber sale, 

future harvest entries, and other National Forest management activities. 

 

GSS - 9b 

The costs of roads are disclosed in the Transportation section of Chapter 3 and included 

in the financial efficiency analysis. As stated, small sales may be offered if there is 

interest. Sale size will be determined during implementation. 

See response GSS-9a. 

GSS - 10a 

Given the impact that litigation, injunctions and other factors have had on the ability of 

the timber industry to purchase and harvest timber during that period, plus the volatile 

nature of the markets, it is not unreasonable to expect fewer bidders in years when 

demand is low, and more bidders in years when demand is higher. 

GSS - 10b 

The values produced using the NEPA Economic Analysis Tool are meant to provide the 

Responsible Official with a relative ranking of economic value and not an absolute 

economic value. In the FEIS, the Kuiu project was analyzed using the Residual Value 

Appraisal (RV) version of NEAT, which is the current Forest Service Handbook 

direction. The RV system for appraising timber sales is an accepted Forest Service 

method for determining fair market values for products. RV relies on collecting selling 

values and costs directly from the purchasers of National Forest Service timber sales and 

aggregating those values and production costs annually. 
 Response to GSS 

Kuiu Timber Sale FEIS Appendix C ● 77 

GSS - 10c 

The sawmill in Wrangell is currently operating and is the sawmill nearest to the Project 

Area. Forest Service handbook direction is to appraise proposed timber sale projects to 

the sawmill nearest the timber sale. 

GSS - 11 

The analysis of jobs and income in the FEIS has been updated to reflect the changes in 

policy and where logs are being processed. These changes have been necessitated by 

several factors including current market conditions and manufacturing costs in Alaska 

that make it difficult for the Tongass National Forest to offer economic timber sales. 

Economic sales are critical to supply the local processors who depend on a steady supply 

of timber from the Tongass to remain in operation. 

On March 14, 2007, the Regional Forester approved a policy to allow limited interstate 

shipping of unprocessed Sitka spruce and western hemlock logs, and for future timber 

sale appraisals to reflect this allowance. This approval authorizes shipment to the lower 

48 States of unprocessed Sitka Spruce and western hemlock sawlogs that are: a) smaller 

than 15 inches in diameter at the small end of a 40-foot log, or b) grade 3 or grade 4 logs 

of any diameter. Shipments will be limited on each sale to a maximum of 50 percent of 

total sawlog contract volume harvested of all species; including western redcedar and 

Alaska yellow-cedar, unless expressly granted an exception in advance based on casespecific unusual circumstances. 

The number of jobs and income that may be generated by the project could be affected by 

the interstate shipping policy, and the potential changes as a result of the policy are now 

incorporated into the FEIS (see the Timber Economics section in Chapter 3). 

See http://www.fs.fed.us/r10/ro/policy-reports/for_mgmt/ for volumes exported from 

1999-2005. 

GSS - 12 

Table 3-2 in the DEIS shows that 134 acres of the Security IRA are within the planning 

area, and that those acres would not be directly affected by the proposed activities. The 

DEIS states (p. 3-9) that no activities are proposed within this Inventoried Roadless Area. 

The FEIS shows both direct and indirect effects to the North Kuiu Inventoried Roadless 

Area (as defined in the 2003 SEIS). Alternative 4 would have the greatest effect on this 

roadless area. Approximately 207 acres would be directly affected by road building and 

timber harvest. Indirectly, including the affects to the zone of influence, about 551 acres 

would be affected. This zone of influence is described in the table footnotes which state 

that the total area affected includes a 600-foot buffer around proposed timber harvest 

units and a 1,200-foot buffer along proposed temporary roads within the Inventoried 

Roadless Area. 

As stated in GSS – 1b the Forest Plan amendment will not address new Wilderness 

recommendations. The North Kuiu Roadless Area would still be eligible for Wilderness 

consideration in the next round of forest planning and for designation as a nondevelopment LUD in the current Forest Plan amendment. 
Response to GSS 

78 ● Appendix C Kuiu Timber Sale FEIS 

The DEIS did not analyze the potential impacts to the wilderness characteristics of the 

Security IRA because it stated there would not be any harvest within that Roadless Area 

(DEIS p. 3-9). (This decision was made in the 2003 SEIS). 

For the North Kuiu IRA, the opportunity for solitude and serenity, scenic, fisheries, 

vegetation, recreation, biological, cultural, and research values, and current uses for the 

North Kuiu IRA were discussed in the DEIS (pp. 3-9 to 3-12). These were used as units 

of measure to compare effects between alternatives (DEIS p.1-18). These are the same 

factors used in the 2003 SEIS. The DEIS compared the expected changes from the 

alternatives against the existing conditions. The SEIS found no known significant or 

unique features or values, opportunity for solitude low, opportunity of primitive 

recreation moderate, overall integrity not pristine, vegetation typical of Southeast Alaska, 

known cultural resource sites, and no recreation places within the North Kuiu IRA. Since 

the proposed alternatives would remove acres but would not change the above values, the 

effects to the overall Roadless Area were considered minimal. 

The settlement agreement for Natural Resources Defense Council v. U.S. Forest Service, 

Case No.1 :03-cv-0029-JKS signed by both parties in April 2007 has been approved by 

the District Court on May 23, 2007. As part of this settlement agreement, the Forest 

Service will not sign new RODs or other decision documents for timber sales in 

Inventoried Roadless Areas or on Kuiu Island. For purposes of this agreement, the Forest 

Service will not take this and other actions described below until 30 days after 

publication of the notice of availability of the FEIS for the Tongass Forest Plan 

amendment in the Federal Register, unless the Forest Service designates a later effective 

date for the new plan, in which case the Forest Service will not take these actions until 

the effective date designated by the Forest Service. 

The North Kuiu IRA is not the only roadless area left on north Kuiu. Figure 3-1 in the 

DEIS shows Security, Keku, and Camden IRAs and Table 3-1 (p. 3-8) in the DEIS shows 

that North Kuiu IRA is the smallest of these Roadless Areas. All these IRAs provide 

values associated with Roadless Areas. In addition, the Forest Plan designated 

approximately 73% of the Security IRA into non-development land use classifications. 

GSS - 13a 

The North Kuiu Roadless IRA would still exceed 9,000 acres in all action alternatives 

and would not be committed to a developed status or eliminated from options for 

consideration as a non-development LUD (DEIS Ch 3 p. 3-21)(see item GSS-1b). None 

of the alternatives would change the current condition of the Security IRA (FEIS Chapter 

3, Issue 1: Roadless Areas Section.) This project will be consistent with the Forest Plan. 

GSS - 13b 

See response GSS-1a 

GSS - 14

Road maintenance is an ongoing process. See GSS-9b. 
 Response to GSS 

Kuiu Timber Sale FEIS Appendix C ● 79 

The purpose and need of the Kuiu Timber Sale DEIS is discussed on pp. 1-2 and 1-3. 

Road maintenance and reducing the density of roads used during harvest activities is not 

part of the purpose and need. Alternative A, the No-Action Alternative, responds to the 

request for no new road construction, road reconditioning, or timber harvest. 

The ongoing Tongass ATM process responds to road maintenance and road density 

objectives on Kuiu Island. The Petersburg Ranger District ATM analysis will look at all 

road systems on the District. The ATM decision will include RMOs and any further road 

closures. As stated earlier in GSS-9a, road maintenance on Kuiu Island is completed 

through annual road maintenance monies. The Kuiu Landscape Assessment also lists 

recommendations for road management (Appendix A Tables E, F, and G) including 87.8 

miles of roads on Kuiu Island recommended for management as closed to vehicle traffic. 

The proposed road closures in the Kuiu Timber Sale FEIS respond to the opportunity to 

accomplish some of the recommended road closures during the timber sale. 

GSS - 15a

There are many ways to display the effects of harvest on productive old-growth (POG) 

forests. Table 2-2 on page 2-17 of the DEIS displays a summary comparison of 

alternatives and is not all-inclusive. A more detailed table of the effects within the Project 

Area can be found in Table 3-11 (p. 3-39) of the DEIS, including the percent changes in 

POG. 

The Forest Plan FEIS (Part 1, p. 3-387) analyzes the predicted amount of POG remaining 

within the WAA at the end of the rotation (2095) rather than the amount of POG 

removed. In order to compare current levels with Forest Plan predictions (DEIS p. 3-72,) 

the acres of POG remaining within both the WAA and the planning area in the tables are 

shown, however, the percent acres of POG removed within the planning area are 

discussed in further detail on page 3-40. 

GSS - 15b 

The acres of coarse canopy forest are displayed in Table 3-12 (page 3-41) in the DEIS. 

Coarse canopy is also discussed in Chapter 2 of the FEIS. 

GSS - 15c 

There was no discussion on pages 3-18 and 19 related to low-elevation POG, however, 

Table 3-18 on page 3-52 of the DEIS will be clarified with the remaining acres of POG 

below 800 feet and the total percent of harvest planned within this habitat. The historic 

acres of POG below 800 feet in elevation will be displayed. 

GSS - 15d 

The Forest Plan FEIS (Part 1, p. 3-373) analyzes effects to deer by the predicted amount 

of deer habitat that would remain within the WAA at the end of the rotation rather than 

the amount of deer habitat removed. In order to compare current levels with Forest Plan 

predictions, the acres of deer habitat remaining in the WAA are shown. 

GSS - 15e 

The effects to deer habitat carrying capacity are displayed by alternative (Table 3-21 p. 3-

54 for the WAA and in Table 3-24 p. 3-57) in the DEIS. The summary of the effects of 
Response to GSS 

80 ● Appendix C Kuiu Timber Sale FEIS 

the alternatives for subsistence use is the statement at the bottom of Table 2-2 in the 

DEIS. 

The correct multiplier is 100 deer/sq-mile for an HSI of 1.0 as noted in the Tongass 

National Forest Annual Monitoring & Evaluation Report for Fiscal Year 2000 p. 2-155 

and the Emerald Bay Appeal No. 06-10-00-0002 Southeast Alaska Conservation Council, 

et. al. 

In 1996, an interagency group of biologists met to review and discuss the deer model in 

use at the time. One recommendation from the group was that HSI scores be modified, 

and subsequently deer model scores were adjusted (from a range of 0 to 1.0) to a range of 

0 to 1.3, with the highest score (as in the previous model) assigned to south-facing, low 

elevation, low snow level, high-volume old-growth stands. This information is 

documented in the Tongass Plan FEIS Part 1 (pages 3-367 and 3-368). The carrying 

capacity (deer/square mile) multiplier that equates to an HSI score of 1.0 has been 

adjusted several times. Based on information supplied by research, the latest adjustment 

equates 100 deer/square mile with an HSI score of 1.0 (TNF 2000 Annual Monitoring 

and Evaluation Report released in April 2001 and instructions provided on the deer 

model spreadsheet). There is no documentation to support the assertion that the 100 

deer/square mile carrying capacity was intended to match an HSI score of 1.3. 

GSS - 15f 

The correct multiplier was used to estimate deer carrying capacity (see response 15e) and 

is displayed in a table in the Alexander Archipelago Wolf section of Chapter 3 in the 

FEIS. 

The effects to wolves would be similar with the implementation of any alternative; 

therefore, the effects to wolves are discussed under the Alexander Archipelago Wolf 

portion of the Effects Common to all Alternatives section of this Chapter. 

The alternative comparisons (pp. 3-68 – 3-71) address the effects of the proposed 

alternatives on wolves. 

The comparison of effects to wildlife species starts in the DEIS on page 3-67 – 3-68 with 

the effects common to all alternatives through 3-73. Comparisons of Effects are on page 

3-39 – 3 -71. The Cumulative Effects are on pages 3-71 – 3 -74. 

GSS - 16

The acres of POG lost in natural events were removed from the current condition in the 

FEIS. 

Effects of the proposed alternatives on POG high, medium, and low volume stands are 

displayed in Table 3-11 (p. 3-39) in the DEIS. 

GSS - 17 

As described in the DEIS (p. 3-41), the matrix is the availability of management lands 

subject to timber harvest. Within the Project Area, 93 percent of the area is in the Timber 
 Response to GSS 

Kuiu Timber Sale FEIS Appendix C ● 81 

production LUD (p.1-6 and p.1-9). The discussion and analysis of “Matrix” would be the 

same as the discussion and analysis of the Timber Production LUD. The Forest Plan 

analyzed the amount of forested lands that would remain at the end of the rotation (Forest 

Plan FEIS p. 3-387). These projections were not a goal, standard, or guideline that is 

required to be followed, and because the information is repetitive and confusing, it has 

been removed from the FEIS. The discussion of Matrix lands can still be found in the 

Wildlife Specialist Report. 

GSS - 18

The deer model uses the volume strata map, consistent with Forest Plan direction (TLMP 

FEIS, p. 3-365). 

GSS - 19 

The Kuiu deer habitat capability analysis used the approved current habitat capability 

model. Components of this model include average winter snow depth, elevation, aspect, 

and timber volume strata. Use of the volume strata map is consistent with Forest Plan 

direction (TLMP FEIS, p. 3-365). 

A recent study published in the Journal of Wildlife Management (69(1):322-331, 

DeGayner, Doerr and Ith) concluded that there was a lack of relationship between winter 

deer use and volume class. By contrast these researchers “[f]ound a consistent 

relationship in habitat selection using timber volume strata.” Research has demonstrated 

that the volume strata map is a statistically valid method of stratifying the forest for 

timber volume. 

It is reasonable that the deer model uses the volume strata map, since it was the only 

statistically valid map available at the time and it utilized research findings on deer 

habitat selection and timber volume. Currently, a new map is being researched to better 

evaluate forest structure. This map is undergoing peer review and is currently being 

tested for its utility for evaluating deer habitat. 

Challenging the components and application of the deer model is a Forest Plan-level 

issue. It is outside the scope of the Kuiu Timber Sale Project analysis to arbitrarily 

rewrite the model. The deer model is maintained and updated at the Forest level. Any 

changes to the model will be the result of field observations, thorough analysis, and peer 

review. 

The Forest Service uses TimTyp for evaluating coarse canopy forest in order to respond 

to requests from the State. 

GSS - 20 

The Wildlife Resource Report states that volume classes 6 and 7 from the Tongass GIS 

library were used to portray the currently best available information for coarse canopy 

stands and that the historic amount of coarse canopy was extracted from Mylar maps and 

pre-harvest aerial photos and added to the GIS library. The report also states that the 

mapping based on older aerial photos is not as accurate as those derived from more recent 
Response to GSS 

82 ● Appendix C Kuiu Timber Sale FEIS 

photos and field mapping; however, it does offer a fairly good approximation for the 

purposes of comparing alternatives. 

The Tongass National Forest does not currently have a peer reviewed method for 

delineating and mapping varying levels of canopy coarseness. A model for mapping tree 

size and density is being tested for accuracy. As of May 25, 2005, the Tongass Forest 

Supervisor has directed that all timber harvest NEPA projects use volume class 6 and 7 to 

portray the currently best available information for coarse canopy stands. In addition, the 

Forest Plan directs for the use of volume strata for vegetation analysis and mapping. This 

direction was followed in the Kuiu Timber Sale. 

Current Forest direction (Cole 2005) is to use volume classes 6 and 7 to represent coarse 

canopy forest, as stated below: 

“Use volume class 6 and 7 to portray the currently best available information for 

coarse canopy stands in the wildlife section. A table that displays volume class 

by alternative will be included in the wildlife section. The amount of volume 

class 6 and 7 will be included as part of the small OGR analysis.” 

Coarse canopy was displayed using volume class 6 and 7 within the wildlife specialist 

report and in the DEIS (pp.3-40 and 3-41). This corresponds with the high coarse canopy 

reported by Caouette and DeGayner (2004). 

GSS - 21a 

As discussed in GSS-18 and 19, the deer model is maintained and updated at the Forest 

level. The model was used as intended as discussed in GSS-15e. Any changes made to 

the model at the Forest level will be the result of field observations, through analysis, and 

peer review. 

GSS - 21b 

The DEIS (p. 3-52) further clarifies that the wildlife models used for the Forest Plan 

analysis are useful for comparing alternatives, but were never meant to predict population 

numbers (DeGayner, 1992). The model’s intended use is to make distinctions between 

alternative treatments. The models do this by providing numbers that represent habitat 

capacity. This is a theoretical long-term carrying capacity, not actual population numbers 

given normal winter conditions. These numbers are displayed in the DEIS (Table 3-29 

p.3-83). The related comparison of effects by alternatives (pp. 3-69 – 3-71) use those 

numbers as intended by comparing the percentage of change to the capacity of the habitat 

to support deer. 

The deer population numbers set by the State of Alaska were developed using the Deer 

Habitat Capability model. While it is unfortunate that actual numbers are used, these 

numbers are population objectives and not actual numbers of deer. The models are used 

to compare the impacts of the alternatives against the desired condition; in this case the 

population objective of the WAA. 

It has also been estimated that a deer population at carrying capacity could support an 

annual harvest by hunters of up to about 10 percent of winter carrying capacity, with the 
 Response to GSS 

Kuiu Timber Sale FEIS Appendix C ● 83 

population remaining stable and hunter satisfaction remaining fairly high (Flynn and 

Suring 1993 in 1997 FEIS p. 3-361). Without the use of numbers it is not possible to 

determine what 10 percent of the winter carrying capacity would be. 

Throughout the DEIS and FEIS, readers are reminded that these numbers are theoretical. 

The numbers from the model are rounded to the nearest whole number, because further 

manipulation of the data to the nearest 10th or 100th would imply a greater precision than 

the theoretical numbers the model generates. The actual whole numbers from the model 

are used in the analysis so as to not skew the data. Again, readers are continually 

reminded throughout the DEIS and FEIS that these numbers are theoretical. 

The use of the word “phantom” in the DEIS was to try to help the reader to understand 

that the numbers derived from the model are not real deer numbers but rather, 

information in the form of numbers used as a comparison of effects by alternatives. 

GSS - 21c 

The DeGayner 1992 document referenced on p. 3-14 does contain information on the 

reliability of habitat capability models. Additional creditable reviews of habitat 

capability models have been cited and are available in the planning record. The Council 

on Environmental Quality gives direction to prepare analytic rather than encyclopedic 

environmental impact statements (Sec. 1502.2(a)) 

GSS - 21d 

Additional information regarding the effects of road densities on marten has been added 

to the FEIS in the Wildlife section of Chapter 3. Road density is not a component of the 

Habitat Capability Model; however, studies have shown that road density may affect the 

quality of habitat for marten through trapping (Ruggerio et al. 1994, Suring et al. 1992). 

The road density factor was appended to the 5.0 version of the marten model but never 

incorporated. It is also not apart of the current model, version 7.0, used for this analysis. 

Road density on Kuiu Island was calculated using open road density because most of the 

former temporary roads in the Project Area were decommissioned after their use was 

terminated. National Forest System roads that are closed were placed in storage. 

Decommissioned roads and roads placed in storage have signs of removed structures; 

intact water bars, and are generally grown closed with alder. There is little evidence of 

ATV use on most of these roads, mainly due to the remoteness of Kuiu Island and the 

impassibility on the roads once the stream crossings have been removed. Most personal 

vehicle use on the island is in the form of pickup trucks, which cannot navigate the alder 

or the mound and pit type barriers normally found on decommissioned and stored roads. 

Foot trails along these roads are common. 

The FEIS reports that the current open road density for WAA 5012 is 0.46 mi/mi2

 and the 

total road density for the WAA is 0.68mi/mi2

. All action alternatives would decrease the 

open road density within the planning area by placing currently open roads into storage 
Response to GSS 

84 ● Appendix C Kuiu Timber Sale FEIS 

(see the Transportation section Chapter 3 for current and proposed road densities by 

alternative). 

GSS - 21e 

The FEIS and Wildlife Specialist Report have been corrected to say: “Deer habitat 

capability models likely overestimate the carrying capacity for deer” (Person et al. 1997). 

The model was developed to estimate impacts to habitat capability, not deer population 

numbers. 

GSS - 21f 

The deer/wolf model described has not been reviewed by the Tongass National Forest. 

Current Tongass National Forest direction is to use the Forest Plan deer model to 

determine habitat capability for the planning area and determine if the action alternatives 

will meet the 18 deer per square mile requirement to maintain sufficient animals for 

wolves and human consumption (Person et al. 1997, Puchlerz 2002, and Cole 2005). 

The Wildlife Specialist report acknowledges that the effect of deer habitat loss on deer 

populations is nonlinear. The addition of the above mentioned wolf factor is one way the 

model has been adjusted as new information is acquired. The Tongass National Forest 

Land and Resource Management Plan Implementation Policy Clarification 1998 (TPIT) 

recognized that both the deer model and wolf/deer equilibrium model made certain 

assumptions and contain a certain amount of variability, which needed to be considered 

when using any model. The model represents just one tool to be used in doing project 

level analysis. Models are best used to make relative comparisons between alternatives 

rather than actual populations. Other factors need to be considered by the professional 

biologist rather than solely relying upon model results (TPIT 1998, p.16). 

Changes to models and factors are more properly addressed at the Forest level. 

GSS - 21g 

The personal communications with Dave Person have been reviewed. They were not 

relevant to this project and were not added to the planning record because this 

communication speaks to the wolf predation rate on Sitka black-tailed deer in southeast 

Alaska and the consumption rate of food (deer) per kilogram of wolf body weight per 

day. The deer multiplier expresses the theoretical number of deer a given habitat can 

support as a function of the HSI score. Although the notes from the May and June 2005 

wildlife biologist conference calls do not contain any direction, they are contained in the 

planning record. 

GSS - 21h 

Columns for the year 2046 have been added to Tables in Issue 2 of the FEIS. See also 

GSS - 21j. 

GSS - 21i 

Table 3-14 in the FEIS shows the HSI value for the historic condition, current condition 

and future condition grown to 2046. As managed stands reach stem exclusion age, which 
 Response to GSS 

Kuiu Timber Sale FEIS Appendix C ● 85 

the model assumes will occur 26 years after harvest, deer habitat is reduced with the loss 

of browse. This assumption is part of the current condition HSI values. This information 

is included in Chapter 3 of the FEIS.

GSS- 21j 

The DEIS explicitly states that deer habitat capabilities are based on average winters. The 

DEIS (p.3-52) describes the deer habitat capability model and how the model assigns HSI 

values based on normal winter conditions and average winter snow depths. In fact, the 

first paragraph states: 

The deer habitat capability model developed for the Forest Plan was used to 

predict the potential number of deer that the habitat within the Kuiu Timber Sale 

Area can support over time. The result is not an actual population number but a 

theoretical long-term carrying capacity given normal winter conditions.

And the next paragraph of that page uses the word average snow depth three times to 

describe the winter condition. 

The DEIS (p. 3-53) further discusses the deer model ... “This number represents the 

theoretical maximum number of deer that an area can support over the long-term, 

assuming normal winter conditions.” 

Severe winter conditions would have a greater impact than shown in the model. 

However, there is no model available for severe winters and no way of knowing when or 

if a severe winter will occur. 

GSS - 21k 

The nonlinear deer population concerns were addressed in GSS 21g. 

GSS - 22a 

The DEIS (p. 3-25) contains a detailed description of the effects of harvest compared to 

natural disturbance and includes a discussion which compares the effects of natural wind 

disturbance to timber harvest.

GSS - 22b 

The effects of silvicultural treatments on deer habitat are discussed in the DEIS (pp. 3-50 

– 3-51) with Table 3-18 (p. 3-52) showing acres of POG, and high value wildlife habitat 

(below 800 feet) harvested by alternative. 

Discussions have been added to the FEIS to make it clear that the model treats partial cut 

units as clearcut units in all alternatives. A footnote has been added to the tables that 

compare the HSI by alternative. The deer model is not solely relied upon for the 

discussion of the biology of deer. Local knowledge and site-specific examples are given 

in the DEIS (p. 3-51). 
Response to GSS 

86 ● Appendix C Kuiu Timber Sale FEIS 

GSS - 22c 

Please see pages 3-164 – 3-165 in the DEIS for the descriptions of two-aged management 

and group selection. In general, the harvests will fall within plus or minus 10 percent of 

the targeted retention figure for these systems. 

For single-tree selection the DEIS (p. 3-166) states that the single tree selection 

“maintains a multi-aged structure by removing some trees in various size classes 

distributed across the stand....[t]his maintains or creates a stand of three or more distinct 

size classes.” It is not to be assumed that smaller trees will be retained in the place of 

larger trees. 

GSS - 22d 

The HSI values from the deer model are for clearcuts and no adjustments were made. The 

discussion of partial harvest on corridors and important deer winter range has been 

increased to address the role of partial harvest on corridors and deer habitat. See also 

response GSS-22b. 

 

GSS - 22e 

In an attempt to keep costs down, few photos are published in EISs. 

GSS - 22f 

In the DEIS Figures 3-5 and 3-6 shows the current HSI scores by quartile, with the unit 

pool and contour lines. The reader can easily deduct where the important winter range 

can be found for deer. Figure 3-4 shows the same thing for marten. 

GSS - 23a 

Most of the maps in the DEIS include a managed stand layer. The scale of the maps 

allows the reader to see the majority of north Kuiu Island and the amount of harvest that 

has been completed in that area. The photo included with the comments only shows a 

single drainage, and does not include the Project Area. The maps in the DEIS allow the 

reader to see the relationships better. 

GSS - 23b 

Fragmentation was analyzed in the Forest Plan. A large block of productive old-growth 

(POG) in the Project Area would be projected in the small old-growth reserve and remain 

unfragmented. The largest block of old-growth in the area is the North Kuiu Inventoried 

Roadless Area, of which 9,456 acres are forest and over 90% is POG. If any of the action 

alternatives is implemented, over 8,300 acres of old-growth would remain unfragmented. 

 

The Forest Plan does not require a site-specific fragmentation analysis. As mentioned in 

GSS 22d, the discussion on the function of the corridors has been expanded. The request 

to discuss connectivity for units that close gaps between previously logged units is noted. 

GSS - 23c 

As mentioned in 22d the discussion on the function of the corridors has been expanded. 

The request to have units that isolate habitat dropped from the unit pool is noted. 
 Response to GSS 

Kuiu Timber Sale FEIS Appendix C ● 87 

GSS - 23d 

Refer to the DEIS (pp. 3-164-166) for further discussion on the desired future condition 

and how the stand is expected to function for wildlife after harvest. 

The wording has been changed to better reflect that the action alternatives address the 

degree of fragmentation differently, rather than reduce fragmentation. 

 

GSS - 24a

Additional information has been added to the Subsistence portion of the FEIS concerning 

the annual response rates to the Subsistence reports and the reliability of those reports. 

GSS - 24b 

See response GSS - 15e. 

GSS - 25a 

The team strives to utilize all comments in developing a stronger document. The unit card 

is a summary of the field visits and helps to identify the concerns of the specialists and 

the appropriate response to that concern. This can then be utilized by the layout and 

implementation teams. The unit card is limited in its information but more detailed 

information is available from the field notes that are in the planning record. 

Unit card information does not include who visited the site. That information is available 

in the field notes and cards in the planning record. A statement has been added to the 

introduction of Issue 2: Deer Habitat and Subsistence Use (Chapter 3) that a Biologist or 

appropriately trained field technician visited the proposed units. When something 

relevant was noted in the field cards or notes it was placed on the unit card. 

GSS - 25b 

The unit cards each contain the Volume Strata by high, medium, and low, and in the 

Wildlife/Biological Diversity portion of each unit card is the number of acres of 

important deer winter range, high value marten habitat. A more detailed description of 

the units is available in the field cards and notes in the planning record. 

Timtyp does not come from field visits any more then HSI or Vol-strata data. 

More field information was added to the cards as requested. 

GSS - 25c 

Descriptions of the proposed harvest for units with two prescriptions for one alternative 

have been better clarified on the unit cards. 

GSS - 25d 

The silvicultural prescriptions are located on the unit card which accompanies each map. 

The majority of these units are designed for cable logging systems. Where a unit lists 

both cable and shovel logging systems the shovel logging systems will be used on slopes 
Response to GSS 

88 ● Appendix C Kuiu Timber Sale FEIS 

less than 35 percent. This can be determined from the topographic lines on the unit card 

maps. Units planned for helicopter logging list this system on the unit card narrative. 

GSS - 25e 

All Class I and Class II stream buffer widths are identified on the Appendix B Unit 

Cards. Units with Class I and II streams are 109, 109b, 111, 208a, 307, 308, 401, 402, 

403, 404, 412, 414, 415, 416, 418, and 503. 

GSS - 25f 

The corridor information has been updated on the unit cards and the medium HSI 

information has been corrected for the FEIS. 

GSS - 26a 

Information requests were not ignored. Requests were filled within a few days of when 

they were received. The planning record includes a log of requests and when and how 

they were addressed. The public is always welcome to come to the office during business 

hours and view the planning record, however, when they need to be copied and mailed 

the process takes longer. 

GSS - 26b 

Please refer to GSS-18. 

GSS - 26c 

Scoping comments are reviewed and pertinent and relevant information is incorporated 

into the EIS. 

GSS - 26d 

Analysis of biodiversity, including fragmentation and connectivity, were addressed in the 

DEIS (pp. 3-24 – 3-37) in the Wildlife Resource Report. 

GSS - 26e 

The wildlife models are discussed in both the DEIS and FEIS in Chapter 3 and in greater 

detail in the Wildlife Resource report available in the planning record. 

GSS - 27 

The Fadden (2005) memo is part of the planning record, however, the memo is not 

setting a policy. It is Fadden’s recommendation to continue to use the models in a 

fashion consistent with past practice as officially sanctioned by the senior forest 

leadership on the Tongass. It is the decision of the Forest Supervisor to use the Forest 

Plan deer model (Cole, 2005). To use other models that are untested on the Tongass or to 

change the parameters of the current deer model would be irresponsible. 

GSS - 28 

To analyze a project such as the Kuiu Timber Sale on one scale would not give a 

complete picture of the effects to the resources, the public, and the Responsible Official. 

Different scales of analysis were completed to best analyze the effects of the sale on that 
 Response to GSS 

Kuiu Timber Sale FEIS Appendix C ● 89 

particular resource. The rationale for the scales used in each analysis has been clarified 

in the FEIS and in the Resource Reports available in the planning record. The FEIS 

attempts to clarify which scale of analysis is used. 

The DEIS (p. 3-216 Table 3-80) displays all existing designated roads, and their status, 

within the Project Area including Roads 6415 and 6402 that delineate the Project Area 

boundary. 

The FEIS uses the WAA scale as the smallest area for road density following Forest 

Supervisor direction (Cole 2005). Wolf was assessed using both WAA and 

biogeographical province (island-wide) road density figures. 

GSS - 29 

The information for historic coarse canopy forests is incomplete and/or unavailable. It is 

not logistically or economically feasible to visit each harvested site to measure stumps to 

determine the historic habitat condition. The level of analysis needed was accomplished 

by assuming that the majority of the past harvest occurred in high volume timber stands. 

The assumptions are based on the knowledge that the majority of past harvest occurred 

along valley bottoms and in many cases included high volume stands. This leads to an 

assumption that most likely overestimates the amount of coarse canopy forests that were 

harvested and would not lead to an underestimate the degree of effect past harvest has 

had on high volume coarse canopy forests. A “hard-look analysis” was made by 

assuming a greater impact than what probably occurred. 

GSS - 30 

The analysis has been corrected. 

GSS - 31 

The Integrated Resource Inventory (IRI) crew conducted field surveys for MIS species in 

2003. These surveys included 113 plots. The MIS species included: red squirrel, black 

bear, moose, river otter, Sitka black-tailed deer, marten, wolf, northern goshawk, 

Vancouver Canada goose, bald eagle, red-breasted sap-sucker, hairy woodpecker, brown 

creeper, great blue heron, and osprey. Field records are available in the planning record. 

The Forest Plan’s standards and guidelines include direction for Wildlife Habitat 

Planning. The FEIS provides direction to “[c]onduct project level inventories to identify 

heron rookeries and raptor nesting habitat using the most recent inventory protocols” 

(TLMP p. 4-116). The TPIT (Appendix A p. A-4) provides the clarification of “most 

recent inventory protocols” as: 

Herons - “during project field work from April to July, project personnel shall 

scan intertidal mudflats within the analysis area for the presence of foraging great 

blue herons.” 
Response to GSS 

90 ● Appendix C Kuiu Timber Sale FEIS 

Raptor nests - “report any sightings to the team biologist who will conduct 

follow-up site visits to assess nesting raptor presence. Use nonspecific calls 

(goshawk or great horned owl) to elicit raptor responses to locate potential nests.” 

Inventories for herons and raptors were conducted during surveys for other wildlife 

including marbled murrelets, goshawks, breeding birds, and MIS plot surveys. 

Herons 

Great blue heron inventories occurred during field visits and are noted in the wildlife 

survey field notes which have been added to the planning record. Great blue herons were 

sighted on three separate occasions in 2003 and on 6/5/03 the area between Rowan Bay 

and Clear Creek was searched for signs of a rookery with no rookery found. 

Raptors 

Other raptors inventoried included goshawk, sharp-shinned hawk, red-tailed hawk, and 

great horned owl and are noted in the wildlife survey field notes which have been added 

to the planning record. No active nests were located. 

The planning record was a work-in-progress during preparation of the DEIS. The record 

has been completed and the goshawk survey information is in the planning record. 

GSS - 32a 

Due to well-trained field crews, two potential den sites were located; site 2003 was 

determined to be a den. This site occurs in a unit that has been dropped from the unit 

pool, and monitoring during 2004 and 2005 determined the den to be unused both years. 

Site 2004 was questionable as to whether it was a den and monitoring in 2005 determined 

the site unused. 

As described in the DEIS, (p. 3-66) Dave Person, ADF&G biologist, was consulted. He 

determined one site was a wolf den and the other site was most likely a resting site. (This 

information has been changed from the DEIS which said ‘bear den’). To be on the 

conservative side, a 1,200-foot buffer was placed around both locations. 

The FEIS (p. 4-117) states, “Design management activities to avoid abandonment of wolf 

dens. 

a) Maintain a 1,200-foot forested buffer, where available, around known active 

wolf dens. Road construction within the buffer is discouraged and alternative 

routes should be identified where feasible. No road construction is permitted 

within 600 feet of a den unless site-specific analysis indicates that local 

landform or other factors will alleviate potential adverse disturbance. 

b) If a den is monitored for two consecutive years and found to be inactive, 

buffers described above are no longer required. However, in the spring-time, 

prior to implementing on-the-ground management activities (timber harvest or 

road construction), each known den site will be checked to see if it has 

become active.” 
 Response to GSS 

Kuiu Timber Sale FEIS Appendix C ● 91 

As stated in the unit card, this den was monitored from 2003-2005 and no activity was 

noted in 2004 or 2005. Although the den has been inactive for the last two years, the unit 

boundaries were moved to exclude the site. 

The deer population on Kuiu Island remains above the recommended population to 

sustain wolves. The DEIS (p. 3-65) discussed that Person, et al. (1996) concluded that 

maintaining an average long-term deer habitat capability of at least 18 deer per square 

mile over broad areas should be sufficient to both provide for sustainable wolf 

populations and meet hunter demand for deer. The deer habitat capability analysis of 

Kuiu Island shows enough habitat to currently support 27 deer per square mile. 

GSS - 32b 

The scoping comments from ADF&G were used to design alternatives that did not target 

the highest value important deer winter range. Table 3-25 shows that while there is 

harvest planned within the important deer winter range it composes the minority of the 

total acres within each action alternative. The following alternative information shows: 

• Alternative 2: 128 acres (26%) important deer winter range harvested 

from a total of 491 acres, 

• Alternative 3: 130 acres (16%) important deer winter range harvested 

from 794 total acres harvested, 

• Alternative 4: 311 acres (22%) important deer winter range harvested 

from a total of 1425 acres harvested, and 

• Alternative 5: 264 acres (20%) important deer winter range harvested 

from 1231 total acres harvested. 

GSS - 32c 

Person (2001) did not make a distinction between open and closed roads in his model. 

However, he stated that he was making the assumption that while the U.S. Forest Service 

closed some roads by removing culverts and bridges that policy was sporadic and most 

roads were open for vehicular traffic. 

Within the Project Area, most of the roads currently closed were done so by removing 

culverts (including stream crossings) and log stringer bridges. In many cases they are not 

accessible to vehicles, including off-road vehicles (ORVs). The proposed temporary 

roads will be decommissioned with the removal of all structures, rendering them 

impassible. 

Person (2001) recognized there was a difference with regard to use on roads for those 

areas connected to the main system of roads and for those wildlife analysis areas that 

were not connected. Person (2001) found the average harvest for wildlife analysis areas 

connected to the main road system was 4.1 wolves and was much higher than the average 

of 1.3 wolves for wildlife analysis areas that were not connected by the road system.

Person (2001) estimated that a total density of roads >0.53 km/km2 (0.33 mi/mi2) for 

wildlife analysis areas connected to the main road system would likely result in 
Response to GSS 

92 ● Appendix C Kuiu Timber Sale FEIS 

overharvesting wolves. For wildlife analysis areas that were not connected to the main 

road system, the limit for density of roads was 1.04 km/ km2

 (0.65 mi/mi2). 

Regardless of whether Person (2001) made no distinction between open and closed roads 

in his modeling, he recognized the reality of the difference when the road was correctly 

closed to vehicular use. He believed that managing human access by closing roads from 

motorized use and limiting construction of new roads were measures necessary to 

conserve wolves over the long-term. 

Harvest records from ADF&G on Kuiu Island show the harvest of wolves since 1984 has 

averaged five animals with a high of 16 wolves in 1993 and a low of zero wolves in 1984 

and 1990. 

The DEIS (p. 3-66) recognized the importance of measuring road densities below 1200 

feet. 

In a study conducted on Prince of Wales and Kosciusko Islands from 1992 to 

1995, Person et al. (1996) found that WAAs with road density of 0.7 miles per 

square mile below 1,200 feet in elevation experiences a twofold increase in wolf 

mortality. The area was calculated using road density area within a WAA below 

370 meters (~1,200 feet) elevation as the denominator. Wolves spend most of 

their time at low elevations and calculations of road density reflect this relation. In 

a concurrent radiotelemetry study, the average annual mortality was 50 percent of 

the population, which is not sustainable (Person et al., 1996). 

Page 3-68 shows the open road density below 1,200 feet for WAA 5012. The FEIS has 

been changed to reflect the above rationale, to remove the road density by planning area, 

to add more discussion on road density by WAA (the scale to be measuring road densities 

for wolves, Person et al 1996) and to show the total road density in WAA below 1,200. 

The density shown was 0.5 mile per square mile, which is still well below the 0.7 mile 

per square mile figure. The above road discussion had been added to the Wildlife Report. 

GSS - 33a 

The DEIS (p.3-73) recognized the short-term potential benefits of logging from increased 

berry production and the longer term impacts from the closed canopy which may cause 

black bear populations to decline due to loss productive foraging habitat. 

GSS - 33b 

 The DEIS p. 3-257 says 

Impacts to recreation and sport activities during logging may prove negative due 

to increased traffic and possible noise disturbance. Also, the planned closure of 

currently open roads would limit access in the long-term. New temporary road 

access might prove beneficial for outfitter and guide activities and subsistence 

users. Access would be short-term since all new roads would be closed after 

harvest. Recreation activities occurring in Saginaw Bay and Security Bay during 

logging may be affected by noise disturbance. If the Saginaw Bay LTF were used, 

people in Saginaw Bay would be affected by barge activities. 
 Response to GSS 

Kuiu Timber Sale FEIS Appendix C ● 93 

GSS - 34

The Forest Plan standards and guidelines states: “cooperate and coordinate with State and 

other Federal agencies to better understand the life history requirements and distribution 

of the marbled murrelets,1” There is no requirement to survey project areas to identify 

nests. Despite this, stands were surveyed for marbled murrelet nesting activity in 2003, 

field survey information can be found in the project record. At this time, no nests have 

been found. If a nest or nests are found in the Project Area they will be protected as 

required by the Forest Plan. 

GSS - 35 

All information discussed in resource reports is not displayed in the FEIS. The rest of the 

paragraph states that they found that the low marten numbers were related to low 

densities of long-tailed voles. 

The resource report also covered discussions with Rich Lowell, Area Biologist for the 

Alaska Department of Fish and Game located in Petersburg, Alaska, which included the 

status of the marten populations on Kuiu Island, the historical trapping records, road 

access, and trapping effort. 

The Forest Plan identified areas of timber harvest in higher risk biogeographic provinces 

to retain the features of forest stand structure. The provinces do not include the Kuiu 

biogeographic province (Forest Plan 4-118). As the DEIS (p.1-9 Table 1-1) demonstrates, 

170,585 acres are designated as development LUDs (35 percent) on Kuiu Island. Less 

than 16 percent of the development LUD acres on Kuiu Island have been harvested. At 

this time, marten viability is not a concern. 

Additional information from Flynn and Schumacher (2004) was added to the Wildlife 

Report. 

GSS - 36 

 “1997 TLMP p. 4-12” refers to providing for maintenance of fish habitat enhancements. 

The reference to connectivity is on p. 4-120 in the Forest Plan. 

The Wildlife Report has an in-depth analysis of connectivity, which includes a discussion 

of the conservation strategy. 

Additional analysis of the effects of removal of the leave strips and the method of harvest 

has been added to the FEIS. 

Riparian reserves which were harvested were not included as corridors in the analysis of 

connectivity. 

 

1

 And to “maintain a 600 foot, generally circular, radius of undisturbed forest habitat surrounding identified 

murrelet nests, where available.” 
Response to GSS 

94 ● Appendix C Kuiu Timber Sale FEIS 

The concern over maintaining wildlife corridors is acknowledged and the request for 

dropping of several units has been noted. Also see response to 22d. 

There are no Units 102, 206, 301, or 408, and while there is a Unit 409 there is no 409a 

or 409b. Please refer to the FEIS for unit numbers. 

GSS - 37 

The forest is evaluating small endemic mammals and the Pacific Northwest Research 

Station (PNW) is conducting long-term studies to identify the existence of endemic 

mammal taxa throughout the island archipelago of Southeast Alaska (Dr. Winston Smith 

and others). These studies will continue and may be accelerated to examine islands less 

than 163,000 acres in size for the potential presence of locally endemic taxa that may be 

at risk as a result of additional vegetation management activities (TNF Annual 

Monitoring & Evaluation Report, 2004). 

Marten and small mammal trapping by Flynn and Schumacher occurred on Kuiu Island 

between 2001 and 2002 and is mentioned in the wildlife report along with an analysis on 

the endemic marten population on Kuiu Island. Additional small mammal trapping by the 

Petersburg Inventory Resource Crew in 2003 is available in the planning record. None of 

the species collected were rare endemics. 

TPIT Appendix A p. A-5 clarifies Forest Plan direction for endemic mammals: 

For islands greater than 50,000 acres, if presence or distinctiveness of the taxa is 

uncertain and potential management risk posed are high or unknown then apply 

the RNA sampling protocol as outlined in TPIT Appendix A p. A-5. If endemic 

taxa are already known to be present and the conservation strategy has a high 

likelihood of sustaining endemic taxa, no surveys are required. 

As noted in GSS-35, only 35 percent of Kuiu Island is in development LUDs and less 

than 16 percent of the developments LUDs have been harvested. Because of the large 

acreage of non-development LUDs on Kuiu Island, the conservation strategy has a high 

likelihood of sustaining endemic taxa. 

GSS - 38 

There is no requirement or need identified to prevent non-motorized access to local 

resources, nor was there any plan to exclude traffic from roads during the project 

operating years. The short-term increase in road densities during logging, due to the 

temporary road construction, has been analyzed in the DEIS. As Table 3-81 (p.3-218) 

shows, there will be an overall decrease in road densities with all action alternatives. The 

ongoing Access Travel Management plan (ATM) will address the maintenance levels of 

existing forest roads. 

The FEIS discusses the methods used to place open NFS roads into storage (see 

Transportation in Chapter 3). The FEIS also mentions throughout the document that all 

temporary roads would be decommissioned and all new and reconditioned NFS roads 
 Response to GSS 

Kuiu Timber Sale FEIS Appendix C ● 95 

would be closed after harvest is complete. More detail has been added about road closure 

and decommissioning. 

More site specific effects of road crossing have been added to the FEIS. 

GSS - 39 

As discussed in GSS-31, the Integrated Resource Inventory (IRI) crew conducted field 

surveys for MIS and other wildlife species in 2003. These surveys included 113 plots, 

which recorded any sighting of scat, track, verbal note, trail, feeding station, or actual 

sighting of red squirrel, black bear, moose, river otter, Sitka black-tailed deer, marten, 

wolf, northern goshawk, Vancouver Canada goose, bald eagle, red-breasted sap-sucker, 

hairy woodpecker, brown creeper, great blue heron, and osprey. Field records are 

available in the planning record. These surveys help complete the hard-look analysis 

required by NEPA. 

The Vancouver Canada goose and red-breasted sapsucker have been included in the 

FEIS. 

The MIS species were chosen for the analysis for this project, rather species that best 

represent the affected environment. The rationale for selection is indicated in Table 3-14 

in the DEIS (p. 3-43). 

GSS - 40 

Twenty-four units were surveyed for sensitive plants. The unit pool contains 37 units, so 

65% of the units were surveyed. Normally 100% of the units and roads are not surveyed. 

The habitats that are most likely to contain sensitive plants are the priority to survey 

(DEIS p. 3-149 to 3-151). The Petersburg Ranger District does not have a written 

protocol for how intensely to survey for sensitive plants, but the Ketchikan Area had one 

written in 1999. That protocol suggested, “At a minimum, 30% of likely harvest units 

and 50% of likely roads should be surveyed.” While conducting the surveys within units 

on Kuiu, roads within the units were walked as part of the unit survey. Also, while 

accessing the units, the access roads proposed for reconditioning were examined (DEIS 

pp. 3-149 & 3-150). 

GSS - 41 

The proposed project is consistent with management of Kadake Creek as a Recreational 

River under the Wild and Scenic River Act (Public Law 90-542, as amended; 16 U.S.C. 

1271-1287). 

More information has been added in Chapter 3 of the FEIS to clarify allowable activities 

within a Recreational River Land Use Designation (LUD) and to analyze the effects of 

the proposed activities on the Kadake Recreational River corridor. 

 The harvest impact to the Kadake Recreation River corridor would be minimal (less than 

one percent of the Recreation River corridor). Within the 6,585-acre Kadake Recreation 

River corridor, the project proposes partial harvest treatment of 18 acres in Unit 415 for 

Alternatives 2 and 4, and an additional 31 acres of partial harvest in Alternative 4 in Unit 

414 (DEIS and FEIS Appendix B Unit Cards). Alternatives 3 and 5 would not harvest 

any acres within the river corridor. Road management activity within the river corridor 

would be limited to reconditioning existing roads or the construction of temporary roads 
Response to GSS 

96 ● Appendix C Kuiu Timber Sale FEIS 

(DEIS, Unit cards, pp B82-85). These activities are allowable in a Recreational River 

LUD. 

Appendix E of the Forest Plan (p. E-251) divides Kadake Creek into four segments; 

Segment 1 and 3 meet the guidelines for Recreational River classification; Segments 2 

and 4 meet the guidelines for Wild River classification. The proposed harvest units in 

Alternatives 2 and 4 would be in the Recreational River Segment 1. Recreational River 

areas are defined as those rivers or sections of rivers that are readily accessible by road 

that may have undergone some development along their shorelines (Forest Plan p. 3-325). 

Forest Plan goals for Recreation River land use designations includes providing 

recreation opportunities in a pleasing, though modified, generally free-flowing river 

setting, while allowing timber harvest, transportation, and other developments (Forest 

Plan p. 3-112 and 3-118). 

The Partial Retention Visual Quality Objective will be applied in areas within the river 

corridor. The area outside the river corridor will be managed according to the guidelines 

of the adjacent LUD. In Alternatives 2 and 4, the timber harvest has been designed to 

meet the Partial Retention Visual Quality Objective as allowed under the standards and 

guidelines of the Recreational River LUD (DEIS, pp. 3-232 to 3-234, DEIS and FEIS 

Appendix A Unit Cards). 

GSS - 42 

The numbers have been corrected in Table 3-43 (Small old-growth habitat reserve 

options for VCU 398) in the FEIS. The recommendation will be considered when the 

decision is made. 

GSS - 43a 

The watershed analysis does include a more intensive, complex, and field-based 

watershed analysis for the watersheds with greater than 20% harvest in 30 years. The 

DEIS (p. 3-115 Table 3-40 and p.3-138 Table 3-49) includes a sediment risk analysis for 

each watershed affected by the project. The DEIS (pp. 3-117 – 3 -122 ) also includes a 

field-based inventory of stream channel conditions for each watershed with more than 20 

percent harvest in 30 years. 

The content of the watershed analysis does follow the basic framework outlined in 

Ecosystem Analysis at the Watershed Scale, even though it is presented in a different 

format. Notably, the watershed analysis addresses all core topics identified in Ecosystem 

Analysis, including erosion processes, hydrology, vegetation, stream channels, water 

quality, species and habitats, and human uses. The six step process outlined in 

Ecosystem Analysis at the Watershed Scale includes: 1) Characterization of the 

watershed, 2) Identification of issues and key questions, 3) Description of current 

conditions, 4) Description of reference conditions, 5) Synthesis and interpretation of 

information, and 6) Recommendation. All six of these steps can be identified in the 

watershed analysis, with the exception of Identification of key questions. The watershed 

analysis does answer the key questions that correspond to the core topics identified in 

Ecosystem Analysis. 
 Response to GSS 

Kuiu Timber Sale FEIS Appendix C ● 97 

GSS - 43b

The level of analysis for the Rowan Creek Watershed is consistent with the level 

recommended by the Forest Plan. 

GSS - 43c

Additional information has been added to the watershed cumulative effects sections of 

the document. This includes references to the Catalog of Events that was completed for 

Kuiu. The analysis of cumulative effects adequately analyzes the effects to watershed 

resources from past, present, and reasonably foreseeable future activities. 

GSS - 44a 

A hard look at the cumulative impacts to forest resources from past logging was done in 

the DEIS and can be found on the following pages: 

• Page 1-10, 1-11, and Table 1-2 shows the past harvest in the Kuiu Timber Sale 

area by decade. 

• Roadless Areas pp. 3-21 – 3 -22 

• Wildlife pp. 3-72 – 3-75

• Subsistence pp. 3-90 – 3-92

• Timber Economics pp. 3-110 – 3-111

• Watersheds pp. 3-124 – 3-125

• Timber and vegetation pp. 3-172 – 3-173

• Fisheries p. 3-185

• Soils and geology pp. 3-206 – 3-207

• Wetlands pp. 3-213 – 3-214

• Transportation pp. 3-222 – 3-223

• Scenery pp. 3-237 – 3-239

• Recreation p. 3-250

• Socioeconomics pp. 3-259 – 3-260

• Heritage Resources p. 3-265 

The impacts to regional habitat contiguity and large-scale concerns were evaluated on a 

Tongass-wide level by the Forest Plan. The Catalog of Events for Kuiu Island was 

referenced in determining cumulative effects. Effects boundaries were identified by 

individual resources. Those events from the catalog which had measurable overlapping 

effects were considered in the individual resource cumulative effects analyses. 

GSS - 44b 

The Five-year Timber Sale Plan is a dynamic plan which shows potential timber sale 

projects over a five-year period. The Five-year Timber Sale Plan is reviewed and 

adjusted annually. The Alecks Timber Sale, as mentioned in the Kuiu Landscape 

Assessment, is a good example. The Alecks Timber Sale project is not listed on the Fiveyear Timber Sale Plan signed on November 7, 2005, due to planners foreseeing the need 

to adjust the scheduling of timber sales in the area. It is important to keep in mind that a 

Landscape assessment is a “snapshot” of the current situation and the Five-year Timber 
Response to GSS 

98 ● Appendix C Kuiu Timber Sale FEIS 

Sale Plan is a “living” document that is reviewed and updated annually. The current Fiveyear Timber Sale Plan no longer lists the Bayport project. 

GSS - 45 Conclusion 

The request to stop planning on the Kuiu Timber Sale has been noted. A No Action 

Alternative is part of the range of alternatives being considered by the Forest Supervisor. 

The specific unit comments have been addressed in GSS-36. 
 Comment Letter #7 - SEACC

 

Kuiu Timber Sale FEIS Appendix C ● 99 
Comment Letter #7 - SEACC 

100 ● Appendix C Kuiu Timber Sale FEIS 

 SEACC 

 1a 

 SEACC 

 1b 
 Comment Letter #7 - SEACC 

Kuiu Timber Sale FEIS Appendix C ● 101 

 SEACC 

 1b cont.

 SEACC 

 3a 

 SEACC 

 3b 

 SEACC 

 2 
Comment Letter #7 - SEACC 

102 ● Appendix C Kuiu Timber Sale FEIS 

 SEACC 

 3b cont. 

 SEACC 

 3c 

 

 SEACC 

 3d 
 Comment Letter #7 - SEACC 

Kuiu Timber Sale FEIS Appendix C ● 103 

 SEACC 

 3e 

 SEACC 

 3f 
Comment Letter #7 - SEACC 

104 ● Appendix C Kuiu Timber Sale FEIS 

 SEACC 

 4a 

 SEACC 

 4b 

 SEACC 

 4c 

 SEACC 

 4d 
 Comment Letter #7 - SEACC 

Kuiu Timber Sale FEIS Appendix C ● 105 

 SEACC 

 4d cont. 

 

 SEACC 

 4e 

 SEACC 

 4f 

 SEACC 

 4g 

 

 SEACC 

 5 
Comment Letter #7 - SEACC 

106 ● Appendix C Kuiu Timber Sale FEIS 

 SEACC 

 6 
 Response to SEACC 

Kuiu Timber Sale FEIS Appendix C ● 107 

SEACC - 1a 

Refer to OVK-1 and MAJ-6. 

SEACC - 1b 

In August 2005, the Ninth Circuit held that the environmental impact statement and 

record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the 

use of projected market demand for timber, the range of alternatives considered, and the 

cumulative effects of activities on non-National Forest System lands. In response to the 

Court ruling, the Forest Plan is currently being amended through an environmental 

impact statement. The DEIS for the amendment was released for public comment in 

January 2007. 

FAA is currently analyzing market demand. Appendix A has been updated with the 

information from Brackley et al. 

SEACC - 2 

The microsale program on Prince of Wales Island referenced in the comments is a 

program set up for the microprocessors and individuals from the numerous communities 

located around that island. Although microsales could be offered, Kuiu Island does not 

have the same level of community development as Prince of Wales, and without this 

community structure it is unlikely the same demand will exist for minor amounts of down 

or dead trees from the existing road system. 

Due to the expense of mobilization to and from Kuiu Island, lack of any local processing 

facilities, and the distance to established processing facilities, it is unlikely that an 

operator will be interested in purchasing timber sale offerings with volumes less than 

1,000 MBF from this Project Area (DEIS Chapter 3 p.3-105 and the FEIS Chapter 3 – 

Timber Sale Economics section). 

SEACC - 3a 

The scale of analysis reflects the resource that is being analyzed. Deer habitat is analyzed 

by WAA and Project Area for historic, present, and proposed future conditions (DEIS 

pp.3-54 - 3-57), and island-wide deer densities are analyzed as prey species to support 

wolf populations (DEIS p. 3-68). 

Road densities are analyzed on a WAA basis below 1200’ elevation for wolf (DEIS p. 3-

68) and in the Project Area for black bear hunting pressure. 

The information has been presented for historic, current and proposed future conditions 

in most cases, and can be found throughout the document. 

SEACC - 3b 

The multiplier used in the Kuiu DEIS is 100 deer/sq-mile for an HSI of 1.0 as noted in 

the Tongass National Forest Annual Monitoring & Evaluation Report for Fiscal Year 

2000 p. 2-155 and the Emerald Bay Appeal No. 06-10-00-0002 Southeast Alaska 

Conservation Council et al.
Response to SEACC 

108 ● Appendix C Kuiu Timber Sale FEIS 

In 1996, an interagency group of biologists met to review and discuss the deer model in 

use at the time. One recommendation from the group was that HSI scores be modified, 

and subsequently deer model scores were adjusted (from a range of 0 to 1.0) to a range of 

0 to 1.3, with the highest score (as in the previous model) assigned to south-facing, low 

elevation, low snow level, high-volume old growth stands. This information is 

documented in the Tongass Plan FEIS (Part 1, pp. 3 – 367 – 3 – 368). The carrying 

capacity (deer/square mile) multiplier that equates to an HSI score of 1.0 has been 

adjusted several times. Based on information supplied by research, the latest adjustment 

equates 100 deer/square mile with an HSI score of 1.0 (TNF 2000 Annual Monitoring 

and Evaluation Report released in April 2001 and instructions provided on the deer 

model spreadsheet). The Forest Service has no documentation to support the assertion 

that the 100 deer/square mile carrying capacity was intended to match an HSI score of 

1.3. 

SEACC - 3c 

The deer harvest information is reliant on hunters reporting the location and the number 

of animals harvested; therefore, the estimated hunter demand may underestimate the 

actual demand and attempts to bridge this information gap have been made. See 

Response to OVK 4. 

SEACC - 3d 

The comments on the Doerr 1995 results have been noted. 

The FEIS has been corrected to say: 

Historic partial harvest treatments (50 percent retention) on the Tongass National 

Forest studied by Bob Deal (2001) show that these treatments could provide deer 

food and habitat better than clearcut treatments. The light (1-25% BA) and 

medium (26-50% BA) cutting intensity plots were similar to the uncut plots for 

both the recently harvested and older sites, and they did not differ significantly in 

community structure from the uncut plots. Partial harvest stands do not show the 

dramatic rise and fall of blueberry abundance in stands 20 to 80 years after 

clearcutting. Deal also noted that the decrease in blueberry abundance following 

partial harvest was small when compared to that of clearcutting. Community 

plant structures in the forests of Southeast Alaska appear to be resilient to 

moderate ranges of partial cutting (50 percent basal area removal). Overall, 

partial cutting maintained diverse and abundant plant understories comparable to 

the plant communities typically found in old-growth stands (Deal 2001). (See 

Response to ACMP for further information).

The DEIS (p. 3-51) discussed the values of partial harvest as deer and moose forage areas 

rather than retaining winter range. Additional information on how these areas may 

function as corridors for a longer time period than traditional clearcuts has been added to 

the Wildlife section of Chapter 3 in the FEIS. 
 Response to SEACC 

Kuiu Timber Sale FEIS Appendix C ● 109 

SEACC - 3e 

The figure was meant to show changes from the current condition and does not include 

harvest of the proposed unit pool. The unit pool has been removed and ‘From Current 

Condition’ has been added to the title to clarify Figure 3-6. 

SEACC - 3f 

See Response to OVK 4. 

SEACC – 4a 

Within the Recreational River corridor of Kadake Creek, Alternative 2 proposes to 

harvest 18 acres and Alternative 4 proposes to harvest 49 acres. Both silvicultural 

prescriptions call for 50% retention of the basal area (DEIS Appendix B, p.B-82 and B84). 

The proposed activities are not expected to significantly affect sportfishing in Kadake 

Creek due to buffers and the implementation of BMPs. The proposed project is 

consistent with management of Kadake Creek as a Recreational River under the Wild and 

Scenic River Act. (Public Law 90-542, as amended; 16 U.S.C. 1271-1287). The Forest 

Plan (p. 3-112) permits timber harvest on suitable timber lands if adjacent lands are being 

managed for that purpose in accordance with the standards and guidelines for the stated 

VQOs. See GSS-41 for further discussion. 

SEACC – 4b 

The content of the watershed analysis does follow the basic framework outlined in 

Ecosystem Analysis at the Watershed Scale, even though it is presented in a different 

format. Notably, the watershed analysis addresses all core topics identified in Ecosystem 

Analysis at the Watershed Scale: Federal Guide for Watershed Analysis’ (August 1995) 

including: erosion processes, hydrology, vegetation, stream channels, water quality, 

species and habitats, and human uses. The six step process outlined in Ecosystem 

1) Characterization of the watershed, 

2) Identification of issues and key questions, 

3) Description of current conditions, 

4) Description of reference conditions, 

5) Synthesis and interpretation of information, and 

6) Recommendation 

All six of these steps can be identified in the watershed analysis with the exception of 

Identification of key questions. 

SEACC – 4c 

The Pilot Watershed Analysis Report for the Kadake Creek Watershed was used as a 

general reference. It was not included in the planning record for the project or the list of 

references in Chapter 4 because it was not cited specifically in the FEIS or the reports 

prepared for the DEIS. 
Response to SEACC 

110 ● Appendix C Kuiu Timber Sale FEIS 

SEACC – 4d 

Long-term effects of timber harvesting and road building on summer low flows are not 

well studied. Hicks et al. (1991) documented two case studies in which the long-term 

effects of logging on summer low flows were opposite: an eventual decrease in low flows 

was detected in one watershed (after a period of increase), but an increase in summer low 

flows persisted in the other. The results of the study by Hicks et al. are not conclusive 

enough to be broadly applied. 

 

Variable effects on low flows following harvest have been reported in rain-dominated 

coastal watersheds (Keppeler and Ziemer 1990, Hicks et al. 1991). A study in Southeast 

Alaska concluded that timber harvest may result in higher levels of stream flow during 

dry periods (Bartos 1989). However, recent analysis of these data suggests that the 

change could be due to climatic cycles, not timber harvest (US Geological Survey 2000).

SEACC – 4e 

The level of detail in the analysis of watersheds in the Kuiu Timber Sale Project Area is 

based on direction in the Forest Plan. The Forest Plan (USDA Forest Service, 1997), in 

Appendix J, defines the core topics of the watershed analysis, and guides the scale and 

intensity of the analysis. The scale, intensity, and complexity of watershed analysis is to 

be commensurate with the level of cumulative risk. 

SEACC – 4f 

Watershed delineation and identification is described in the DEIS on page C-2. The 

Tongass National Forest recognizes the US Geological Survey (USGS) hierarchical 

watershed mapping and numbering system. For the sake of consistency, all watersheds 

analyzed for the Kuiu Timber Sale project, including the Kadake Creek Watershed, 

correspond to the 6th level hydrologic unit code (HUC). 

SEACC – 4g 

The restoration work is outside the scope of this project and has not been completed at 

this time. It has been incorporated into the Watershed Restoration Plan (WRP) for the 

Kadake Creek Watershed as a possible watershed improvement project. Watershed 

Restoration Plans are internal documents used to compete for funds that are allocated 

across the Tongass for watershed stewardship projects. The WRP for the Kadake Creek 

Watershed is expected to be complete in Fiscal Year 2007. Implementation of the 

restoration work in the WRP will depend upon the project proposal competing favorably 

with other restoration project proposals. 

 

SEACC - 5 

The DEIS does not characterize temporary roads as “temporary fills.” Temporary roads 

are defined in the glossary of the DEIS. The use of the road is temporary, but the 

footprint (fill) is not. This is why the effects of temporary roads are included in the 

DEIS. Temporary roads used in the past are shown as “decommissioned roads” in Figure 

C-1. The Forest Service decommissions temporary roads by removing drainage 

structures, constructing water bars and blocking the entrance to motorized traffic. These 

measures adequately “decommission” the road to allow natural conversion back to the 

original state: i.e. timber growth on the road footprint. In their memo of February 10, 
 Response to SEACC 

Kuiu Timber Sale FEIS Appendix C ● 111 

2006, commenting on the DEIS (included in this appendix), the Corps of Engineers 

concurred that “...all temporary roads proposed for this project are exempt from Clean 

Water Act permitting, provided they are constructed according to best management 

practices...” These best management practices have been incorporated into BMP 12.5 

(FSH 2509.22) and they will be implemented on all roads constructed for the Kuiu 

Timber Sale. 

SEACC - 6 

The status of the LTFs can be found in the DEIS (p. 3-181). 

A description of the existing marine environment conditions of the LTFs can be found in 

the DEIS (p.3-186). 

Descriptions of both the Rowan Bay LTF and Saginaw Bay LFT, as well as the location, 

size, and condition of the sort yards can be found in the DEIS on page 3-220.
Comment Letter #8 - The Committee on Conservation of 

Forests and Wildlife - CCFW 

112 ● Appendix C Kuiu Timber Sale FEIS 

 CCFW 

 1 

 CCFW 

 2 
Comment Letter #8 – The Committee on Conservation of 

Forests and Wildlife - CCFW 

Kuiu Timber Sale FEIS Appendix C ● 113 

 

 CCFW 

 3 

 CCFW 

 4 

 CCFW 

 5 
Comment Letter #8 - The Committee on Conservation of 

Forests and Wildlife - CCFW 

114 ● Appendix C Kuiu Timber Sale FEIS 

 

 

 

 

 

 

 CCFW 

 6 

 CCFW 

 7 

 CCFW 

 8 

 

 
 Response to CCFW 

Kuiu Timber Sale FEIS Appendix C ● 115 

CCFW - 1 

In August 2005, the Ninth Circuit held that the environmental impact statement and 

record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the 

use of projected market demand for timber, the range of alternatives considered, and the 

cumulative effects of activities on non-National Forest System lands. In response to the 

Court ruling, the Forest Plan is currently being amended through an environmental 

impact statement. The DEIS for the amendment was released for public comment in 

January 2007. 

The Tongass National Forest will continue to be managed in compliance with Section 

101 of the Tongass Timber Reform Act of 1990 (TTRA), which modified the Alaska 

National Interest Lands Conservation Act (ANILCA). This states that the Secretary of 

Agriculture “...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 market demand from such forest for each planning cycle.” 

As described more fully in Appendix A of the DEIS, to provide a steady flow of timber 

harvest volume, timber sale projects need to be completed through the NEPA process 

each year to meet current and future market demand. 

FAA is currently analyzing market demand. Appendix A has been updated with the 

information from Brackley et al. 

CCFW - 2 

Concern over the acres of clearcuts on Kuiu Island is noted. Note, however, that the 

27,856 acres harvested are located on an island 482,101 acres in size of which 64 percent 

is in non-development LUDs (Kuiu Island Landscape Assessment). Less than six percent 

of the island has been harvested and less than five percent of the major watersheds 

include any harvest. 

The proposed harvest would have minimal effects to the recreation activities on the island 

since they are proposed in areas of previous harvest and mostly roaded areas (DEIS, pp 3-

240 to 3-250). 

CCFW - 3 

The DEIS p. 3-63 confirms that the Alaska Department of Fish and Game believe the 

black bear population on Kuiu Island is stable, and skull measurements have remained 

relatively stable with the skull measurements averaging 18.6 inches. It is not the logging 

roads that have led to the restrictions but rather the number of hunters. Most of the 

logging roads were already in place when the hunting pressure on Kuiu Island began to 

escalate in the early 1990’s (DEIS p. 3-81, Table 3-27.) Due to concerns over the steadily 

increasing harvest of black bears by nonresident hunters, the Board of Game established a 

nonresident harvest guideline of 120 bears per year on Kuiu Island (DEIS p. 3-84). 

CCFW-4 

The DEIS p.3-50 and the FEIS Chapter 3 Wildlife Habitat section relate the deer crash to 

severe winter weather in the late 1960’s and early 1970’s rather than to loss of coarse-
Response to CCFW 

116 ● Appendix C Kuiu Timber Sale FEIS 

canopy old-growth habitat (at that time timber harvest had occurred on less than two 

percent of the island). It should be noted that the era of heaviest logging occurred 

between 1970 and 1989 after the deer crash and after these two decades of logging, deer 

populations continue to climb to a point that hunting was reopened in 1992. Although 

hunting limits remain low and hunting effort is high, it should be recognized that in the 

years of the deer crash, less than 4000 acres (8.7%) of the Project Area had been 

harvested and less than 7000 acres (1.4%) of the island had been harvested. 

It should also be noted that deer herds which crashed at the same time on the much 

heavier logged, roaded, and populated Prince of Wales Island have returned in much 

larger numbers than those on Kuiu. It must therefore be assumed that factors other than 

timber harvest alone are restricting the deer from reaching historic population levels. 

These other factors include the heavy predation from large populations of black bear and 

wolves (see the Wildlife section in Chapter 3 of the FEIS). 

 

There are no activities planned within Security Bay or Kadake Bay in the Kuiu Timber 

Sale FEIS, therefore no impacts to these areas are anticipated. 

While Security and Saginaw Bays are important waterfowl hunting areas, waterfowl 

hunting is just an incidental part of guiding operations on Kuiu Island. 

CCFW -5 

Of the 42 stream crossings, there are two proposed Class II stream crossings by NFS road 

construction, and two Class I and three Class II stream crossings on existing Road 6417 

that is currently in storage. All other stream crossings are on non-fish bearing streams. 

Best Management Practices identified in the DEIS (Appendix B pp. B-7 – B-9) will be 

applied to protect water quality where appropriate. 

The DEIS (p. 3-182) acknowledges that there will be an increase in sedimentation from 

road construction; however, this effect is expected to meet state water quality standards. 

The placement of stream buffers and the implementation of BMPs (DEIS Appendix B pp. 

B-7 – B-9) is expected to minimize the amount of sediment entering streams. 

Construction timing windows for stream crossings on roads proposed for reconditioning 

or storage will be implemented (DEIS p. 3-175). While individual fish may be impacted, 

the population as a whole is not expected to be affected. 

CCFW-6 

The cost of temporary road construction is the responsibility of the purchaser. Forest 

Service Handbook direction (FSH 2409.18) directs that a financial evaluation of 

alternatives be done for each alternative based upon the appraisal system used to establish 

the value of timber sales (FSH 2409.22). The accepted procedure for determining the 

value of timber in a timber sale is to estimate the value of the finished products and 

subtract all of the costs associated with producing the finished products. Some of these 

costs are timber falling, logging, hauling, towing, and road construction. 
 Response to CCFW 

Kuiu Timber Sale FEIS Appendix C ● 117 

Temporary roads were looked at again in the FEIS and some miles of road were 

reclassified as NFS road. The proposed action in the FEIS proposes 6.5 miles of new 

NFS road construction with an estimated cost of $170,000/mile. Additionally, there are 

3.9 miles of temporary road construction with an estimated cost of $110,000/mile. The 

total estimated cost of this road construction is $1,534,000. The cost to re-construct the 

NFS road in the Kuiu Timber Sale Area is estimated to be an additional $122,000. 

CCFW-7 

The Tongass is moving towards providing second-growth timber for industry. Currently, 

very few second-growth stands are of a commercial size. Prior to the 1950s there was 

only scattered timber harvest on the Tongass. Beginning in the late 1950s two long-term 

timber harvest contracts were offered and larger scale harvesting operations were started, 

resulting in the conversion of old-growth stands to second-growth stands. The majority 

of these second-growth stands are not yet large enough to provide commercial 

opportunities. While some second-growth harvest is being investigated in Southeast 

Alaska, most of this harvest has been near communities with mills where it is more 

economical to harvest second-growth timber. The second-growth timber on Kuiu is 

marginal in size for harvest and process, and it is estimated to be another 10 to 20 years 

before the oldest of the stands on Kuiu are large enough to provide commercial 

opportunities. 

The DEIS pp. 3-158 – 3-159, and the FEIS Chapter 3 Timber and Vegetation section 

show that the volume strata in the planning area is roughly 78 percent high volume, 18 

percent medium volume and 2 percent low volume. All action alternatives would harvest 

between 77-83 percent high volume, 13-19 percent medium volume and 2-4 percent low 

volume, well within a range of variability which duplicates the existing volume strata 

within the planning area. 

The Forest Service currently has an active pre-commercial thinning program in most 

second-growth stands to enhance growth potential and improve wildlife habitat 

capabilities and has precommerically thinned 4,700 acres of second growth stands in the 

Project Area. The Forest Service is investigating the replacement or removal of culverts 

that impede fish passage on a Forest-wide basis. The proposed timber sale action would 

remove two of these culverts. 

For discussion on the funding of roads, see the response to CCFW-6. 

Funds for the Forest Service are allocated by Congress, and the amount of money 

allocated to each resource is beyond the scope of this project. It would be irresponsible 

to use money allocated for one project to fund another project.

CCFW-8 

The request to cancel the proposed Kuiu timber sale has been noted. To divert the funds 

from one resource, such as timber, to another resource, like restoration, is beyond the 

scope of this project. 
Response to CCFW 

118 ● Appendix C Kuiu Timber Sale FEIS 

There are many different perceptions of “backcountry”; however, much of the planning 

area has been selected in the Forest Plan for timber development (DEIS 1-5 to 1-7 and 

FEIS Chapter 1 Forest Plan Land Use Designations section). Much of the infrastructure 

(roads) in the planning area already exist, and the area has had past harvest. The area does 

not fit the typical definition of backcountry. 
Comment Letter #9 - Chico Area Fly Fishers - CAFF 

Kuiu Timber Sale FEIS Appendix C ● 119 

 CAFF 

 1 

 

 CAFF 

 2 
Comment Letter #9 - Chico Area Fly Fishers - CAFF 

 

120 ● Appendix C Kuiu Timber Sale FEIS 

 CAFF 

 3 

 CAFF 

 4 

 CAFF 

 5 

 CAFF 

 6 

 CAFF 

 7 
Comment Letter #9 - Chico Area Fly Fishers - CAFF 

Kuiu Timber Sale FEIS Appendix C ● 121 

 CAFF 

 8 

 CAFF 

 9 
Comment Letter #9 - Chico Area Fly Fishers - CAFF 

 

122 ● Appendix C Kuiu Timber Sale FEIS 

 CAFF 

 10 
 Response to Chico Area Fly Fishers - CAFF 

Kuiu Timber Sale FEIS Appendix C ● 123 

CAFF - 1 

The Forest Service puts out timber sales because of a legal requirement from Congress. 

Section 101 of the Tongass Timber Reform Act of 1990 (TTRA), which modified the 

Alaska National Interest Lands Conservation Act (ANILCA) states that the Secretary of 

Agriculture “...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 market demand from such forest for each planning cycle.” 

The Kuiu Timber Sale planning area is currently well roaded and would only require 

construction of between 3.3 and 10.4 miles of roads to implement. 

CAFF - 2 

The Forest Service is a multiple-use agency and one mandate is to produce timber. 

Maintaining the natural state of the Tongass National Forest is also a prime concern. Of 

the approximately 17 million acres on the Tongass National Forest, 78 percent is 

Wilderness or designated as Natural Setting. On a state-wide basis ANILCA has 

designated Wilderness across the state and looks out for the national interests of the 

public. 

CAFF - 3 

In August 2005, the Ninth Circuit held that the environmental impact statement and 

record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the 

use of projected market demand for timber, the range of alternatives considered, and the 

cumulative effects of activities on non-National Forest System lands. In response to the 

Court ruling, the Forest Plan is currently being amended through an environmental 

impact statement. The DEIS for the amendment was released for public comment in 

January 2007. 

The Tongass National Forest will continue to be managed in compliance with Section 

101 of the Tongass Timber Reform Act of 1990 (TTRA), which modified the Alaska 

National Interest Lands Conservation Act (ANILCA). This states that the Secretary of 

Agriculture “...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 market demand from such forest for each planning cycle.” 

As described more fully in Appendix A of the DEIS, to provide a steady flow of timber 

harvest volume timber sale projects need to be completed through the NEPA process 

each year to meet current and future market demand. 

FAA is currently analyzing market demand. Appendix A has been updated with the 

information from Brackley et al. 

CAFF - 4 

Concern regarding the acres of clearcuts on Kuiu Island is noted. Note, however, that the 

27,856 acres of harvest are located on an island of 482,101 acres, of which 64 percent is 

in non-development LUDs (Kuiu Island Landscape Assessment). Less than six percent of 
Response to Chico Area Fly Fishers - CAFF 

124 ● Appendix C Kuiu Timber Sale FEIS 

the island has been harvested and less than five percent of the major watersheds include 

any harvest. 

The proposed harvest would have minimal affect to the recreation activities on the island 

since they are proposed in areas of previous harvest and mostly roaded areas (DEIS, pp 3-

240 to 3-250). 

CAFF - 5 

The DEIS (p. 3-63) confirms that the Alaska Department of Fish and Game believes the 

black bear population of Kuiu Island is stable, and skull measurements have remained 

relatively stable with the skull measurements averaging 18.6 inches. It is not the logging 

roads that have led to the restrictions but rather the number of hunters. The hunting 

pressure on Kuiu Island began to escalate in the early 1990s (DEIS p. 3-81 Table 3-27) 

long after a majority of the logging roads were already in place. Due to concerns over the 

steadily increasing harvest of black bears by nonresident hunters, the Board of Game 

established a nonresident harvest guideline of 120 bears per year on Kuiu Island (DEIS p. 

3-84). 

CAFF - 6 

See CCFW-4 for information on the Sitka black-tailed deer population crash. 

See OVK-4 for information on significant habitat to support subsistence needs for Sitka 

black-tailed deer. 

There are no activities planned within Security Bay or Kadake Bay in the Kuiu Timber 

Sale FEIS, therefore no impacts to these areas are anticipated. 

While Security and Saginaw Bays are important waterfowl hunting areas, there are no 

guiding operations for waterfowl hunting on the Petersburg Ranger District. 

CAFF - 7 

Of the 42 stream crossings, there are two proposed Class II stream crossings by NFS road 

construction, and two Class I and three Class II stream crossings on existing Road 6417 

that is currently in storage. All other stream crossings are on non-fish bearing streams. 

Best Management Practices identified in the DEIS (Appendix B pp. B-7 – B-9) will be 

applied to protect water quality where appropriate. 

The DEIS (p. 3-182) acknowledges that there will be an increase in sedimentation from 

road construction and reconditioning; however, this effect is expected to be short-term 

(clarified in the FEIS as 48 hours after construction). The placement of stream buffers 

and the implementation of BMPs (DEIS Appendix B pp. B-7 – B-9) are expected to 

minimize the amount of sediment entering streams. Road construction, installation of 

culverts and bridges, and the removal of culverts is expected to temporarily increase 

sediment delivery but is not expected to degrade fish habitat. Increased sediment may 

affect individual fish by reducing oxygen levels to developing eggs in spawning gravels 

and/or trapping of emerging fry in the gravel, the effect is expected to be short-term (48 
 Response to Chico Area Fly Fishers - CAFF 

Kuiu Timber Sale FEIS Appendix C ● 125 

hours or less) and the placement of timing restrictions will minimize impacts to fish (see 

the road cards in Appendix B). The BMP implementation will achieve state water quality 

standards. 

CAFF – 8 

Please see the response to CCFW – 6. 

CAFF - 9 

The Tongass is moving towards providing second-growth timber for industry. Currently 

very few second-growth stands are of a commercial size. Prior to the 1950s there was 

only scattered timber harvest on the Tongass. Beginning in the late 1950s two long-term 

timber harvest contracts were offered and larger scale harvesting operations were started, 

resulting in the conversion of old-growth stands to second-growth stands. While some 

second-growth harvest is being investigated in Southeast Alaska, most of this harvest has 

been near communities with mills where it is more economical to harvest second-growth 

timber. The second-growth timber on Kuiu is marginal in size for harvest, and it is 

estimated to be another 10 to 20 years before the oldest of the stands on Kuiu are large 

enough to provide commercial opportunities. 

Congress allocates funds to the Forest Service. The amount of money allocated to each 

resource is beyond the scope of this project. The temporary roads proposed in the Kuiu 

Timber Sale are funded by the purchaser, not the Forest Service. 

The Forest Service currently has an active pre-commercial thinning program in most 

second-growth stands to enhance growth potential and improve wildlife habitat 

capabilities. The Forest Service is investigating the replacement or removal of culverts 

that impede fish passage on a Forest- wide basis. The proposed timber sale action would 

remove two of these culverts.

CAFF- 10 

The request to cancel the proposed Kuiu timber sale has been noted. To divert the funds 

from one resource, such as timber, to another resource, such as restoration, is beyond the 

scope of this project. 
Comment Letter #10 - Sealaska 

126 ● Appendix C Kuiu Timber Sale FEIS 

 Sealaska 

 1 
 Comment Letter #10 - Sealaska 

Kuiu Timber Sale FEIS Appendix C ● 127 
Response to Sealaska 

128 ● Appendix C Kuiu Timber Sale FEIS 

Sealaska - 1 

The recommendation that Alternative 4 be implemented as presented is noted. 
 Comment Letter #11 - David Beebe 

 

Kuiu Timber Sale FEIS Appendix C ● 129 

 Beebe 

 2 

 Beebe 

 3 

 Beebe 

 1 

 Beebe 

 4 

 Beebe 

 5 
Comment Letter #11 - David Beebe 

130 ● Appendix C Kuiu Timber Sale FEIS 

 Beebe 

7

 Beebe 

 8 

 Beebe 

 6 
 Comment Letter #11 - David Beebe 

 

Kuiu Timber Sale FEIS Appendix C ● 131 

 Beebe 

 10 

 Beebe 

 11 

 Beebe 

 12 

 Beebe 

 13 

 Beebe 

 14 

 Beebe 

 9 
Comment Letter #11 - David Beebe 

132 ● Appendix C Kuiu Timber Sale FEIS 

 Beebe 

 14 contd.
 Comment Letter #11 - David Beebe 

 

Kuiu Timber Sale FEIS Appendix C ● 133 

 Beebe 

 15 

 Beebe 

 16 

 Beebe 

 17 

 Beebe 

 18

 Beebe 

 19 

 
Response to Beebe 

134 ● Appendix C Kuiu Timber Sale FEIS 

Beebe - 1

In August 2005, the Ninth Circuit held that the environmental impact statement and 

record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the 

use of projected market demand for timber, the range of alternatives considered, and the 

cumulative effects of activities on non-National Forest System lands. In response to the 

Court ruling, the Forest Plan is currently being amended through an environmental 

impact statement. The DEIS for the amendment was released for public comment in 

January 2007. 

The Tongass National Forest will continue to be managed in compliance with Section 

101 of the Tongass Timber Reform Act of 1990 (TTRA), which modified the Alaska 

National Interest Lands Conservation Act (ANILCA). This states that the Secretary of 

Agriculture “...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 market demand from such forest for each planning cycle.” 

As described more fully in Appendix A of the FEIS, to provide a steady flow of timber 

harvest volume, timber sale projects need to be completed through the NEPA process 

each year to meet current and future market demand. 

Beebe - 2 

Concern over the acres of clearcuts on Kuiu Island is noted. However the 27,856 acres 

and 78 watersheds referred to are located on an island 482,101 acres in size with 163 

major watersheds. Sixty four percent of the island is in non-development LUDs (Kuiu 

Island Landscape Assessment). Less than six percent of the island has been harvested and 

less than five percent of the major watersheds include any harvest. 

As noted in the DEIS p.3-119 and the FEIS Chapter 3 Cumulative Effects to Watershed 

section, approximately 59 percent of Watershed 109-45-10090 has been harvested, but 

only 20 percent of the watershed has been harvested within the last 30 years. The high 

amount of cumulative harvest in this watershed does not mean the watershed has lost its 

integrity. Hydrologic recovery due to regrowth of vegetation in harvested in areas is 

expected to require between 10 and 30 years (DEIS p. 3-124 and FEIS Chapter 3 

Cumulative Effects on Watersheds, Cumulative Watershed Effects section). Watersheds 

are altered by timber harvest and road building, not destroyed. The watersheds affected 

by the proposed project continue to produce clean water and support anadromous and 

resident fish populations. The watersheds are expected to continue to support these 

beneficial uses into the future, regardless of which alternative is selected. 

Beebe - 3 

On p. 3-26 of the DEIS it states, “The Forest Plan contains a comprehensive conservation 

strategy to assure viable and well-distributed wildlife populations (Forest Plan FEIS 

Appendix, Volume 4, Appendix N, 1997).” The DEIS goes on to explain much of this 

strategy. While there is expected to be some effects from the proposed actions of each 

alternative, the cumulative effects listed on pp. 3-72 thru 3-74 do not identify any threats 

to the viability to any species from the proposed timber harvest activities. 
 Response to Beebe 

 

Kuiu Timber Sale FEIS Appendix C ● 135 

The Conservation Strategy Review Workshop was conducted April 10-14, 2006 at the 

Ted Ferry Civic Center in Ketchikan Alaska. Key Findings from the workshop are listed 

below: 

• The Conservation Strategy is still sound. 

• There is a low risk of species viability problems related to Forest Plan 

implementation. 

• Endemic species continue to be a high priority information need. 

• There is good opportunity to manage habitats to emphasize production of prey 

species of other foods. 

• Management of young-growth forests for wildlife habitat is promising, 

especially for species like black-tailed deer. 

• There is a need to better understand the role and management of the Matrix 

part of the Strategy, including the role of non-National Forest System lands. 

• The wildlife monitoring program needs to be updated. 

Beebe - 4 

The large and medium old-growth reserves, of which there is approximately 25,171 acres 

on Kuiu Island (DEIS p. 3-26, Kuiu Island Landscape Assessment p. 4) are nondevelopment LUDs established in the Forest Plan and are not diminished in size for 

development activities including timber projection. Furthermore, there is a forest-wide 

system of protection provided by other non-development LUDs (307,729 acres on Kuiu 

Island (Kuiu Island Landscape Assessment p. 4)) that maintain the integrity of the forestwide ecosystem and provide future option for maintaining naturally occurring 

ecosystems. 

Beebe - 5 

The DEIS (p. 3-4) defines what irreversible and irretrievable commitments are and 

further clarifies that there would be no irreversible commitment of resources from the 

proposed project and the expansion of rock pits would lead to an irretrievable 

commitment of resources within this project. The Transportation section of the DEIS (p. 

3-211) addresses the need for a rock source to maintain and construct roads and while 

there will be no need to develop new rock quarries, existing quarries would be used and 

expanded. 

Removing trees from the landscape does not destroy it. The landscape remains and the 

trees will grow back. A responsibility of the Forest Service is to identify and present all 

of the effects from the proposed project including irreversible commitments of resources 

to the public and Responsible Official. 

Beebe - 6 

The Forest Service receives annual road maintenance monies to be used for maintenance 

of the road systems for the present and perceived problem areas of the road system. 

Petersburg Ranger District is composed of several island road systems and the annual 

maintenance monies are generally divided between these island systems. 
Response to Beebe 

136 ● Appendix C Kuiu Timber Sale FEIS 

Maintenance and reconditioning of existing National Forest System (NFS) roads is an 

ongoing process that occurs on a periodic basis. The maintenance and reconditioning of 

NFS roads in the Project Area may be in the process of implementation, before, during 

and after the NEPA process through separate service contracts to reduce the backlog of 

deferred maintenance. Reconditioning roads may be done to comply with best 

management practices, maintain the existing infrastructure for the proposed timber sale, 

future harvest entries, and other National Forest management activities. 

Fisheries and wildlife habitat restoration projects are ongoing within the Forest. In the 

planning area, the Kadake Creek tributary restoration project is ongoing and two red 

culverts (those that don’t pass fish at all flows) will be replaced with all action 

alternatives. The remaining red culverts are being evaluated on a forest-wide basis for 

prioritization for repair or replacement. 

As stated in the DEIS p. 1-6 and 3-167, of the total acres harvested in the project 

(approximately 10,393 acres) 4,766 have been pre-commercially thinned. The remaining 

5,627 acres are not ready for pre-commercial thinning. Decisions on thinning other areas 

of the Tongass does not fall within the realm of this project analysis. 

Beebe - 7 

There is no corporate land adjacent to the Project Area. There are 356 acres of nonNational Forest System lands within the Project Area: two acres of private land, seven 

acres of Bureau of Land Management land, and 347 acres of State of Alaska land. The 

concern over logging on native corporate land on Kupreanof Island in relation to 

significant loss of subsistence opportunities for residents of Kake has been addressed in 

the FEIS Chapter 3 – Issue 2 Deer Habitat and Subsistence Use section. The historic and 

current use of Kuiu Island for subsistence deer hunting has been updated in the FEIS (see 

Response to OVK 4). 

The scoping for this project found that there is concern that timber harvest on private 

lands on both Kuiu and Kupreanof Islands has had, or may have, harmful effects to deer 

populations on Kuiu Island. There are very few acres of State or private lands on Kuiu 

Island. State lands include the State Marine Park in Security Bay and two town sites in 

Rowan Bay and No Name Bay. There may be clearing of the Rowan Bay site in the 

future if the State sells lands for a town site. The No Name Bay site is part of the overselection and is low on the priority list of lands the State will select. Harvest will most 

likely not occur on the remaining State lands because of the nature of the lands 

withdrawn. 

The Sealaska Corporation owns lands on the northern portion of Kuiu in VCU 398. At 

this time, no harvest has occurred on these lands. These are small acreages and are not 

expected to have much impact to wildlife. 

The harvest of private lands on Kupreanof Island around the village of Kake is extensive. 

The Native Corporation completing this harvest has followed the State Forestry Practices 

Act and has cut what is available. This large harvest area has had major impacts to deer 

on Kupreanof Island but probably has had little effect to Kuiu populations. 
 Response to Beebe 

 

Kuiu Timber Sale FEIS Appendix C ● 137 

Beebe - 8 

The effects of harvest activities on rate of landslides are discussed in the DEIS p. 3-192 – 

3-197 and 3-201 and in the FEIS Chapter 3-Soils and Geology section. A soil stability 

analysis was completed by a Soils Scientist for all MMI-4 soils within planned road 

locations and timber harvest units. All unstable slopes were avoided. However, due to 

the numerous concerns received, those units with MMI-4 soils were reanalyzed. Units 

207, 303, and 305 (See unit cards in FEIS Appendix B) will be modified to exclude the 

MMI-4 soils. For Unit 101, the MMI-4 soils in the southeast corner of the unit will be 

removed and the area along the western edge of the unit will remain. There are no 

streams in this area and the risk of sedimentation delivery to a stream is very small. 

Beebe - 9 

Soil stability analysis was completed by a Soils Scientist (and is available in the planning 

record) for all MMI-4 soils within planned road locations and timber harvest units, and 

all unstable slopes were avoided. However, due to the numerous concerns received about 

including these MMI-4 soils within the units, the unit boundaries have been modified (see 

Beebe -8 response). The potential for landslides were discussed on pages 3-199 to 3-201 

of the DEIS and are discussed in the FEIS Chapter 3 – Soils and Geology section. 

See Beebe-2 for the response to the concern of harvest within Watershed 109-45-10090. 

Beebe - 10 

The DEIS analyzes the cumulative effects of harvest and road building on both deer and 

marten carrying capacities at the project level and the Wildlife Analysis Area (WAA) 

level. There was no significant habitat degradation or change to the carrying capacity of 

either species. 

The analysis of the proportion of volume class 6 and 7 harvested and proposed for 

harvest has been expanded in the FEIS and the Wildlife Report. The harvest on Kuiu 

Island is not disproportionate to its occurrence. Currently, approximately 25 percent of 

the POG is coarse canopy, and all of the alternatives would retain this proportion (DEIS 

pg 3-158 and 3-159 and FEIS Chapter 3 – Wildlife Habitat and Timber and Vegetation 

section). The action alternatives would harvest between 1 and 4 percent of the coarse 

canopy, which would not be a significant degradation to the habitat or its carrying 

capacity. 

Beebe - 11 

As the Watershed Analysis explains, there were no historical records on these streams to 

compare to, therefore it cannot be determined if the present conditions of these streams is 

due to common events, harvest or a combination thereof. As stated on p. C-19 of the 

DEIS: “Water quality parameters are not routinely monitored on Kuiu Island. The 

primary water quality parameters that can be affected by timber harvest activities are 

suspended sediment loads, turbidity, and stream temperature. Fuel storage on Kuiu 

Island also presents a potential water quality concern. All of these water quality concerns 

are addressed through the application of Best Management Practices (BMPs). 
Response to Beebe 

138 ● Appendix C Kuiu Timber Sale FEIS 

 A Memorandum of Agreement between Alaska Department of Environmental 

Conservation and USDA Forest Service documents the Forest Service’s role in the 

Alaska Nonpoint Source Pollution Control Strategy. State Approved BMPs are the 

mechanism through which the Forest Service protects water quality from nonpoint source 

pollution. The Forest Service’s implementation and monitoring of BMPs satisfies the 

requirements of the Alaska Nonpoint Source Pollution Control Strategy and is approved 

by the US EPA, thereby ensuring that USFS activities are consistent with the Clean 

Water Act. 

Beebe - 12 

The landslides within the Project Area have reseeded naturally and there are no plans to 

do anything about them at this time. Table 3-73 in the DEIS p. 3-197 displays the number 

of landslides in unharvested and harvested acres. Although landslides are more likely to 

occur in harvested acres than unharvested acres, the planning area consists of 10,393 

harvested acres and 35,709 unharvested acres. Approximately 77 percent of the planning 

area is unharvested area. Thirty-nine of the 57 landslides within the planning area have 

occurred within these unharvested areas as compared with 18 in the harvested areas. As 

discussed in the DEIS (p. 3-191) Swanston and Marion 1991 noted that “as a general 

rule, landslides in harvest areas are significantly smaller, occur at lower elevations, 

develop on gentler gradients and tend to travel shorter distances [than naturally induced 

landslides].” 

Beebe - 13 

As indicated in the DEIS (p. 3-50) the restriction to subsistence is the low deer 

populations due to severe winter die-offs and the slow recovery due to high predation 

(see CCWF-4). Additional information added to the FEIS Chapter 3- Subsistence section 

states that Kake residents have pointed out that their recent (since 1975) reliance on 

Admiralty Island for deer hunting is not their preference, and that as the Kuiu herds 

increase, more of their hunting will shift back to Kuiu Island. Kake residents on average 

(1993 to 1995) take about 250 deer annually (TLMP Revision FEIS, Appendix H, p. H76, based on 75% of their harvest being 185 deer). If all of these deer were harvested 

from Kuiu the minimum deer needed to support that demand would be 2,500 deer. Table 

3-29 in the DEIS p. 3-83 shows that WAA 5012 would be able to meet this demand in all 

alternatives. 

Beebe - 14 

Of the five slides that occurred within Watershed 109-45-10090, three did not reach a 

stream. The width-to-depth ratio for the stream draining this watershed does rate as poor 

when compared to the Tongass Fish Habitat Objectives; however, other indicators are 

rated as fair, good, and excellent (DEIS P. 3-120). Salmon habitat is not poor overall. 

Furthermore, width-to-depth ratios vary in nature and there is no pre-logging data 

available for the stream channel condition, therefore, it is not possible to determine what 

the width-to-depth ratio was before logging. 
 Response to Beebe 

 

Kuiu Timber Sale FEIS Appendix C ● 139 

Dean Creek Watershed does have one slide. This slide however is not in a managed 

stand. 

In Security Creek five of the 12 slides did not occur in harvest units. Two of the five not 

in harvest units were near streams. 

 

One hundred percent of the streams in this watershed flow into salmon spawning habitat. 

The stream channel condition was rated as poor for pools per kilometer, however, it is not 

correct to say that the condition has been downgraded to poor. No pre-logging data set 

exists for comparison. Note that the rating for percent of channel in pool area was rated 

as excellent. It could be that Kadake Creek naturally has few pools, but the pools are 

very large. The majority of the managed stands in the watershed are outside of the 

project boundary. Of the entire watershed (32,270 acres) 1.1% (352 acres) had slides. Of 

the 18 slides within the watershed, 8 were not in harvest units. 

There is no streambed in this watershed that has been destroyed by a road then 

haphazardly mitigated with inappropriate fill material. One hundred percent of streams 

in this watershed drain into salmon spawning habitat. The map on p. 3-141 shows 

landslide initiation points. Within the Saginaw Creek Watershed most of the landslides 

occurred outside of timber harvest units and away from roads, reflecting the fact that 

landslides are naturally occurring events in this watershed. 

The Forest Plan addresses multiple-use goals and objectives through the allocation of 

lands to the set of Land Use Designations (Forest Plan, p. 2-2). Thus, multiple-use goals 

are addressed at the Forest-wide level, not at the level of individual watersheds. Within 

this watershed there have been 19 slides for a total of 1.5 percent of the watershed. Of the 

19 slides, 11 occurred outside of harvest units and only one slide in Saginaw Creek 

Watershed was directly related to the 1988 storm event. 

Assessments of stream channel conditions for each watershed in Appendix C in the DEIS 

are made without the benefit of pre-logging data. No pre-logging data on stream channel 

conditions are available. 

Within the watershed, increased sediment may affect individual fish by reducing oxygen 

levels to developing eggs in spawning gravel and/or trapping of emerging fry in the 

gravel, however, the effect is expected to be short term (48 hours or less) and the 

placement of timing restrictions will minimize impacts to fish (see the road cards in 

Appendix B). The State of Alaska’s Water Quality Standards state that the quality of a 

water to support propagation of fish, shellfish, and wildlife and recreation in and on the 

water must be protected and maintained. BMP implementation will achieve state water 

quality standards (FEIS Chapter3 – Fisheries, Environmental Consequences section). 

Beebe - 15 

The table in the FEIS in Issue 4, Chapter 3 reports the correct number of acres of harvest 

proposed in the Kadake Creek Watershed in Alternative 4. 
Response to Beebe 

140 ● Appendix C Kuiu Timber Sale FEIS 

Beebe - 16 

The FEIS and Wildlife Specialist Report describes the interaction between predators and 

prey and analyzes it by applying the figures used by Person (1997, 2001). There is 

sufficient habitat to maintain 34 deer per square miles island-wide and 29 deer per square 

mile WAA-wide, which is above the predicted numbers Person used in his analysis. See 

Response to OVK-4 and SEACC 3c 

Beebe - 17 

The DEIS p. 3-83 Table 3-29 footnote b, shows a 36 percent reduction in the habitat 

capability for WAA to account for wolf predation. The Forest Service does not have 

reduction factor for black bear predation on deer. It is not possible to guess what the 

weather will be, therefore averages are used. All past, present, and reasonably foreseeable 

impacts were analyzed for the cumulative effects shown in Chapter 3 of the FEIS. 

Beebe - 18 

Watershed 109-44-10370 is not analyzed in detail in Appendix C because it has had a 

low level of cumulative harvest. The watershed is described on p. 3-123 of the DEIS. 

The locations of landslides within the Project Area are depicted on map 3-8 on p. 3-141 

of the DEIS. Figure 3-8 in the DEIS has been updated to make the landslides more 

visible. 

Beebe - 19 

Preference for the No-Action Alternative is noted. 
 Comment Letter #12 – Edna L. Jackson 

Kuiu Timber Sale FEIS Appendix C ● 141 

 

 

 EJ - 1 
Comment Letter #12 – Edna L. Jackson 

142 ● Appendix C Kuiu Timber Sale FEIS 

 EJ - 3 

 EJ - 4 
 Comment Letter #12 - Edna L. Jackson 

 

Kuiu Timber Sale FEIS Appendix C ● 143 

 EJ - 5 
Response to Edna L. Jackson 

144 ● Appendix C Kuiu Timber Sale FEIS 

EJ - 1 

The Forest Service acknowledges that these are customary and traditional use areas. 

EJ - 2 

In August 2005, the Ninth Circuit held that the environmental impact statement and 

record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the 

use of projected market demand for timber, the range of alternatives considered, and the 

cumulative effects of activities on non-National Forest System lands. In response to the 

Court ruling, the Forest Plan is currently being amended through an environmental 

impact statement. The DEIS for the amendment was released for public comment in 

January 2007. 

The Tongass National Forest will continue to be managed in compliance with Section 

101 of the Tongass Timber Reform Act of 1990 (TTRA), which modified the Alaska 

National Interest Lands Conservation Act (ANILCA). This states that the Secretary of 

Agriculture “...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 market demand from such forest for each planning cycle.” 

As described more fully in Appendix A of the DEIS, to provide a steady flow of timber 

harvest volume timber sale projects need to be completed through the NEPA process 

each year to meet current and future market demand. 

EJ - 3 

The Forest Service acknowledges the grief regarding the loss of three hunters from Kake 

and recognizes that the deer population on Kuiu Island has not returned to historic levels 

since the sever winter die-off in the late 60’s and early 70’s, which forces Kake hunters to 

travel farther than they might otherwise. 

EJ - 4 

The FEIS has been updated to include current population estimates and the following 

income and employment information. 

U.S. Census data for Year 2000 shows the median household income was 

$39,643, per capita income was $17,411, and 14.61 percent of residents were 

living below the poverty level. 

A letter dated February 2006 from the Denali Commission confirmed Kake’s 

classification as a distressed community. Based on 2003 data, the Denali 

Commission estimates Kake average market income as below the $14, 872 

threshold level and that more than 70% of residents age 16 and over earned less 

than the threshold. 

The FEIS has been updated as much as possible; the following sites were used as sources: 

6. Alaska Department of Commerce, Community and Economic Development 

community database (www.dced.state.ak.us), 
 Response to Edna L. Jackson 

 

Kuiu Timber Sale FEIS Appendix C ● 145 

7. the Denali Commission website (www.denali.gov), 

8. the Kake Community Economic Development Strategy (2004) (the page 

provided), 

9. the U.S. Census Bureau, Census 2000 

(http://censtats.census.gov/pub/Profiles.shtml) and 

10. Personal communication with Kake Schools, OVK, the City of Kake and Jeannie 

Monk (Denali Commission). 

The Forest Service has noted that Kake Foods has not operated in the past two years and 

that Kake Tribal recently sold all its logging equipment. The Forest Service also 

acknowledges that as income has dropped, reliance on subsistence has increased. The 

FEIS Environmental Justice section has been expanded to recognize the above-mentioned 

condition in Kake and acknowledge that, during times of economic hardship, tribal 

membership depends even more on gathering of customary and traditional foods. It was 

also noted that the project is not expected to make conditions worse and there may be 

some opportunities for employment as a result of the project. 

EJ - 5 

Preference for the No-Action Alternative (Alternative A) is noted. 
Comment Letter # 13 – Katie Fearer 

146 ● Appendix C Kuiu Timber Sale FEIS 

 KF - 1 

 KF- 3 

 KF - 2 

kfearer@myuw.net 

03/20/2006 10:42 AM 

To :Comments-alaska-tongass-petersburg@fs.fed.us 

cc: 

Subject: Kuiu Timber Sale 

I am commenting on the proposed Kuiu Timber Sale, which includes parts 

of Kadake Creek and other areas in the Kadake Bay watershed. 

I urge the Forest Service to select the “no action” alternative to the 

sale. 

I have traveled to Kadake Bay and have enjoyed fishing, wildlife 

watching, and hiking along Kadake Creek. I am drawn to the area 

because it is relatively undisturbed and supports a high-density 

population of black bears, along with wolves, moose, Sitka black-tailed 

deer, and 

course, salmon. 

It is my understanding that the Tongass Fish and Wildlife Resource 

Assessment (ADF&G, 1998) identified Kadake Creek as a primary sportfish 

producer and one of 19 “high value” watersheds in Southeast Alaska. It 

is also my understanding that in 1997 the Forest Service recommended 

23 miles of Kadake Creek as a recreational river under the Wild and 

Scenic River Act because of its high historic, recreation, and 

fisheries values. 

I do not believe that the demand that exists for Tongass timber 

 justifies logging this pristine area. According to a ruling by the 

9th Circuit in 2005, the Tongass Forest Plan’s estimates of the demand 

for Tongass timber are misleading, because they erroneously doubled the 

market demand for the timber. It is also my understanding that the 

Forest Service’s logging program in Southeast Alaska loses millions of 

dollars every year. 

Considering the adverse environmental and economic impacts of the 

proposed sale, I oppose it. 

Thank you for considering my comments. 

Katie Fearer 

2425 SW Webster St., Apt. E-4 

Seattle, WA 98106 
 Comment Letter #13 – Katie Fearer 

 

Kuiu Timber Sale FEIS Appendix C ● 147 

KF - 1 

Preference for Alternative 1, the No-Action Alternative, has been noted. 

KF - 2 

Most cultural, historical, recreational, fish and wildlife values of the Kadake watershed 

are concentrated at the mouth of Kadake Creek and within the riparian buffer of the creek 

itself (TLMP FEIS, Appendix, Vol. 2, pp E-251-254). None of the proposed harvest 

units or roads would be within these areas. The Kadake Creek Recreational River LUD 

contains 6,585 acres. Suitable forested land is available for harvest within the 

Recreational River LUD if the adjacent Land Use Designation allows timber harvest 

(Forest Plan p. 3-118) as is the case in the Kuiu Project Area (see Unit Cards Appendix B 

pp. B-83 and B-85). Alternatives 1, 3, and 5 do not propose any harvest within the 

Recreational River LUD. Alternative 2 proposes 18 acres of partial timber harvest within 

the 1⁄2 mile wide river corridor and Alternative 4 proposes 49 acres of partial harvest. See 

also Greenpeace Response #41. 

KF - 3 

There are several interpretations of pristine, however, this area already has a road 

structure and has been logged in the past and is therefore not pristine. It is because of the 

existing roads and infrastructure that this area is a good place for harvesting, as the 

existing infrastructure helps keep the high cost of road construction to a minimum. 

In August 2005, the Ninth Circuit held that the environmental impact statement and 

record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the 

use of projected market demand for timber, the range of alternatives considered, and the 

cumulative effects of activities on non-National Forest System lands. 

The Tongass National Forest will continue to be managed in compliance with Section 

101 of the Tongass Timber Reform Act of 1990 (TTRA), which modified the Alaska 

National Interest Lands Conservation Act (ANILCA). This states that the Secretary of 

Agriculture “...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 market demand from such forest for each planning cycle.” 

As described more fully in Appendix A of the FEIS, to provide a steady flow of timber 

harvest volume, timber sale projects need to be completed through the NEPA process 

each year to meet current and future market demand. 

The Forest Service does not lose millions of dollars yearly with the logging program; 

however, the Forest Service is not mandated to make money by offering timber for sale, 

either. This point is further emphasized in the Forest Supervisor’s declaration, where it 

states: 

There is no legal mandate for the Forest Service to generate a profit. The Timber 

program is not unusual in costing more to operate than the government receives in 

revenues for the program. Many programs on the Tongass National Forest 

generate no revenue, including the subsistence, heritage, inventory, and 
Response to Fearer 

148 ● Appendix C Kuiu Timber Sale FEIS 

monitoring, land management planning, geology, fish and wildlife management, 

trail improvements, and fire protection programs. The Tongass National Forest 

produces the majority of wildlife and fish for commercial, sport, and subsistence 

users in Southeast Alaska, yet receives no returns on its investments (Cole, 2006). 
 Comment Letter #14 – Glen Ith 

 

Kuiu Timber Sale FEIS Appendix C ● 149 

 Ith - 1 

 Ith – 2a 
Comment Letter #14 – Glen Ith 

150 ● Appendix C Kuiu Timber Sale FEIS 

 Ith – 2b 

 Ith – 2c 
 Comment Letter #14 – Glen Ith 

Kuiu Timber Sale FEIS Appendix C ● 151 

 Ith – 2d 

 Ith - 3 
Response to Ith 

152 ● Appendix C Kuiu Timber Sale FEIS 

Ith - 1 

The inventory done on this FEIS for the economic analysis is designed to be used as a 

Project Area average and not on an individual unit basis. 

Timber cruise plot surveys conducted within the planning area were used to derive the 

average volumes and tree species composition used in NEAT and NEAT_R. It is neither 

required nor practical to cruise all the units at this point in the sale program as all units 

are not included in all alternatives and may not be selected for harvest. 

Ith - 2a 

The DEIS p. 3-53 states that the “results were generated using the quartile model 

developed by the Forest Service and the State of Alaska as means of describing important 

deer winter range.” The methods to develop the quartiles mentioned above are what was 

being referred to on page 3-53. The MOU (Agreement No. 00MOU-111001-026 

Attachment 1 p. 1 states “All deer winter range in Project Area (that scores above 0 in 

most recent interagency approved version of deer HSI model) distinguished by quartile 

(i.e. by 25% of acres).” This has been clarified in the FEIS. 

Ith - 2b 

Analysis within the FEIS Chapter 3 Wildlife Habitat and Subsistence Uses section 

includes comparisons between past, present and reasonably foreseeable future important 

deer winter range by alternative. Important deer winter range was derived from the 

historic condition of WAA 5012 and quartiles were developed based on total acres of 

Habitat Suitability Indices (HSI) >0 within this area of analysis, as directed in the May 

25, 2005 Forest Supervisor’s letter (Cole 2005). The appropriate scale of analysis to 

develop HSI values for this project was the Wildlife Analysis Area (WAA) level in order 

to compare the quartile analysis with the Forest Plan analysis. 

Ith - 2c 

Although the meanings of the different terminology used to refer to deer winter range 

were the same, it is understandable how this could be confusing. The terminology in the 

FEIS has been changed to be more consistent. 

Ith - 2d 

The methods used to determine the quartiles for the important deer winter range are 

addressed in the Forrest Cole letter of May 25, 2005, in the wildlife section of the Annual 

Monitoring & Evaluation Report for FY 2000, and the MOU Agreement No. 00MOU111001-026 Attachment 1 p. 1 as mentioned above. 

Ith - 3 

The discussion of road density has been expanded to include both open and closed road 

densities and the accessibility of closed roads for OHV use in conjunction to marten 

trapping. The road density factor (90% reduction) was discussed in an earlier model 

(Suring et al. 1992) but was not added then or in the current marten model (Version 7.0). 

A discussion is available in the Wildlife Specialists Report. 
 Response to Ith 

 

Kuiu Timber Sale FEIS Appendix C ● 153 

As discussed in the DEIS and the FEIS, the road accessibility would be short-term, which 

is defined as over the life of the timber sale, and the overall cumulative effects of the 

action alternatives is a decrease in open road densities within the planning area. 
Comment Letter # 15 – John Kober 

154 ● Appendix C Kuiu Timber Sale FEIS 

 Kober - 1 

 Kober - 3 

 Kober - 2 

 Kober - 4 

 Kober - 5 

 
 Response to Kober 

 

Kuiu Timber Sale FEIS Appendix C ● 155 

Kober - 1 

The Forest Service acknowledges the importance of Kadake Creek and Bay. There are no 

proposed activities within Kadake Bay and the activities planned within Kadake Creek 

Watershed are consistent with the expectations for the Timber Land Use Designation 

(LUD) and the Kadake Creek Recreational River LUD (Forest Plan p. 3-118). 

Kober - 2 

Most recreational and fish values of the Kadake watershed are concentrated at the mouth 

of Kadake Creek and within the riparian buffer of the creek itself (Forest Plan, Vol.2, pp 

E-251-254). None of the proposed harvest units or roads would be within these areas. The 

fisheries values of Kadake Creek are not expected to change with the proposed project 

activities (DEIS p. 3-182). 

Kober - 3 

Preference for Alternative 1 - the No Action Alternative is noted. 

Kober - 4 

While the comment regarding the Kadake Creek Cabin and other cabins on the Tongass 

is outside the scope of the Kuiu Timber Sale, it will be shared with the staff in charge of 

cabins. The funds for the Forest Service are allocated by Congress and the amount of 

money allocated to each resource cannot simply be transferred back and forth. The 

Forest Service is undergoing a 5 year evaluation process with its public use cabins and is 

decommissioning those that cannot be maintained to standard. One cabin in the 

Petersburg Ranger District is being decommissioned this year due to lack of use and the 

inability to maintain to standard, and it is a cabin that has been unavailable to the public 

for over 10 years. 

The Forest Service is not mandated to make money by offering timber for sale. This point 

is further emphasized in the Forest Supervisor’s 2006 declaration, where it states: 

There is no legal mandate for the Forest Service to generate a profit. The Timber 

program is not unusual in costing more to operate than the government receives in 

revenues for the program. Many programs on the Tongass National Forest 

generate no revenue, including the subsistence, heritage, inventory and 

monitoring, land management planning, geology, fish and wildlife management, 

trail improvements, and fire protection programs. The Tongass National Forest 

produces the majority of wildlife and fish for commercial, sport, and subsistence 

users in Southeast Alaska, yet receives no returns on its investments. The Tongass 

provides cabins for recreational purposes in semi-remote and remote locations of 

the Forest. The returns on these investments do not cover annual maintenance 

costs of the facilities (Cole, 2006). 
Response to Kober 

156 ● Appendix C Kuiu Timber Sale FEIS 

Kober - 5 

The Forest Service is directed to sell commercial timber sales at not less than appraised 

rates. Some of the road building for this project is for temporary road construction, which 

is a part of the bidder’s costs and is not paid for by the Forest Service. 

The aversion to timber sales located in remote areas has been noted. However, this area 

has an existing infrastructure of roads and log transfer facilities and is not considered 

remote. 

Appendix A of the Kuiu Timber Sale Area DEIS states that the Forest Service should 

“...concentrate timber sales in less remote places that do not need further road building 

and do not lose money.” Subject to appropriations and applicable law, including the 

National Forest Management Act, section 101 of the TTRA directs the Secretary of 

Agriculture, to the extent consistent with providing for multiple use and sustained yield 

of all renewable resources, to “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 market demand from such forest for each planning cycle.” 

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 Land Use Designations. The second 

consideration is the suitability of the land for timber production. Keeping in mind all of 

the competing management issues across the forest, the decision to propose a timber sale 

in the Kuiu area is based on: the consideration of cumulative effects on other resources 

from past harvest activities, the location of timber sales under contract, and the eventual 

use of all suitable and scheduled lands for timber sale projects. 
 Comment Letter #16 – Mike A. Jackson 

 

Kuiu Timber Sale FEIS Appendix C ● 157 

 

 MAJ 

 1 
Comment Letter #16 – Mike A. Jackson 

158 ● Appendix C Kuiu Timber Sale FEIS 

 MAJ 

 2 

 MAJ 

 3 

 MAJ 

 4 

 MAJ 

 5 

 MAJ 

 6 
 Comment Letter #16 – Mike A. Jackson 

 

Kuiu Timber Sale FEIS Appendix C ● 159 

 

 MAJ 

 6 contd. 
Response to Mike A. Jackson 

160 ● Appendix C Kuiu Timber Sale FEIS 

MAJ - 1

Opposition to any further logging on Kuiu Island is noted. 

MAJ - 2 

The Forest Service acknowledges that much of Kuiu Island is a customary and traditional 

use area for people from Kake. During the Alaska Wilderness, Recreation and Tourism 

(AWRTR v. Morrison Settlement Agreement) Workshops held at Kake, many areas 

formerly open to commercial timber harvest received special protection in the Forest 

Plan. Examples of these areas include: Rocky Pass, Pillar Bay, Kadake Creek, Fall Dog 

Creek, the Red Cedar Area. All beach and estuary areas are protected with the 1000 foot 

beach/estuary buffer. 

MAJ - 3 

The Kuiu Timber Sale DEIS (p.3-182) states that there will be temporary increases in 

sediment delivery to streams, primarily due to road construction activities. The FEIS has 

been updated to clarify the ‘temporary increases’ as sediment levels are expected to 

return to normal within 48 hours of the completion of construction work. These 

temporary increases in sediment are not expected to significantly degrade water quality or 

fish habitat. The streams are expected to continue to support the fisheries on which 

subsistence users depend. Port Camden, Security Bay, and Kadake Bay are not expected 

to be affected by this project. Current conditions of Rowan Bay and Saginaw Bay are 

described in the DEIS (p. 3-180 and 3-181). The project will use either the existing 

Rowan Bay or Saginaw Bay LTFs. Logs will likely be barged from the sites, although 

there is a possibility logs will be placed into the water and rafted for towing from the 

bays. Barging logs will not increase bark accumulation at either site. Log rafting will 

cause newly dislodged bark to accumulate at the sites. Annual monitoring will determine 

the amount of accumulation, if any, and trigger cleanup if accumulation exceeds 

Environmental Protection Agency’s National Pollutant Discharge Elimination System 

(NPDES) permit requirements. 

The DEIS (p. 3-95 and 3-269) states that the potential foreseeable effects from the action 

alternatives in the Kuiu Timber Sale Area are not expected to result in a significant 

restriction of subsistence uses of Sitka black-tailed deer, black bear, moose, furbearers, 

marine mammals, upland birds, water fowl, salmon, other finfish, shellfish, or other 

foods. 

MAJ - 4 

The Forest Service attempted to involve as many people as possible in the planning 

efforts. As early as February of 2004, scoping letters were sent to City and Tribal 

governments and interested citizens of Kake. That letter signified the beginning of the 

planning process and desire for input. Open houses were held in July and November of 

2004 in which additional input to the proposals was solicited. A subsistence hearing was 

held in March of 2006. Information about the open houses and subsistence hearings was 

sent out on the scanner, by newspapers and posted on bulletin boards in town. 
 Response to Mike A. Jackson 

 

Kuiu Timber Sale FEIS Appendix C ● 161 

On November 22, 2004, several members of the Kuiu Timber Sale planning team 

accompanied Patricia Grantham, Petersburg District Ranger, to Kake. The Forest Service 

group met with Henrich Kadake, Sr., OVK President, and other OVK members, where 

the Kuiu Timber sale was discussed including a presentation of the SHPO report. 

The Forest Service is currently planning a timber sale on Kupreanof Island that will 

consider timber sale opportunities for small-scale operators. Due to the expense of 

mobilization to and from Kuiu Island, lack of any local processing facilities, and the 

distance to established processing facilities it is unlikely that an operator will be 

interested in purchasing timber sale offerings with volumes less than 1,000 MBF from 

this Project Area (DEIS Chapter 3 p. 3-105 and the FEIS Chapter 3-Timber Sale 

Economics section). It is not the policy of the Tongass National Forest to subsidize 

sawmills large or small. 

MAJ - 5 

In August 2005, the Ninth Circuit held that the environmental impact statement and 

record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the 

use of projected market demand for timber, the range of alternatives considered, and the 

cumulative effects of activities on non-National Forest System lands. 

The Tongass National Forest will continue to be managed in compliance with Section 

101 of the Tongass Timber Reform Act of 1990 (TTRA), which modified the Alaska 

National Interest Lands Conservation Act (ANILCA). This states that the Secretary of 

Agriculture “...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 market demand from such forest for each planning cycle.” 

As described more fully in Appendix A of the FEIS, to provide a steady flow of timber 

harvest volume, timber sale projects need to be completed through the NEPA process 

each year to meet current and future market demand. 

MAJ - 6 

The Forest Service acknowledges the loss of three hunters from Kake and recognizes that 

deer populations on Kuiu Island have not returned to historic levels since the die off in 

the late 60’s and early 70’s, which forces hunters to travel farther than they might 

otherwise. 

The FEIS has been updated to include current population estimates and used the 

following income and employment information. 

U.S. Census data for Year 2000 shows the median household income was 

$39,643, per capita income was $17,411, and that 14.61 percent of residents were 

living below the poverty level. 

A letter dated February 2006 from the Denali Commission confirmed Kake’s 

classification as a distressed community. Based on 2003 data, the Denali 
Response to Mike A. Jackson 

162 ● Appendix C Kuiu Timber Sale FEIS 

Commission estimates Kake average market income as below the $14, 872 

threshold level and that more than 70% of residents age 16 and over earned less 

than the threshold. 

The FEIS has been updated as much as possible with the following sites used as sources: 

11. Alaska Department of Commerce, Community and Economic Development 

community database (www.dced.state.ak.us), 

12. Denali Commission website (www.denali.gov), 

13. Kake Community Economic Development Strategy (2004) (the page 

 provided) 

14. U.S. Census Bureau, Census 2000 (http://censtats.census.gov/pub/Profiles.shtml) 

15. personal communication with Kake Schools, OVK, the City and Jeannie Monk 

(Denali Commission). 

The Forest Service notes that Kake Foods has not operated in the past two years and that 

Kake Tribal has recently sold all of its logging equipment. The Forest Service also 

acknowledges that as income has dropped, reliance on subsistence has increased. The 

FEIS Environmental Justice section has been expanded to recognize the above-mentioned 

condition in Kake and acknowledge that during times of economic hardship tribal 

members depend even more on the gathering of customary and traditional foods. This 

project is not expected to make conditions worse, and there may be some opportunities 

for employment as a result of the project.
 Comment Letter #17 – Steve Mashuda 

Kuiu Timber Sale FEIS Appendix C ● 163 

 Mashuda 

 1 

Steve Mashuda 

1000 25th

 Ave. E 

Seattle, WA 98112 

grizmer@aol.co

(206) 322-7932 

 March 20, 2006 

Via electronic mail 

Kris Rutledge, Team Leader Attn: Kuiu 

Timber Sale USDA Forest Service 

P.O. Box 1328 Petersburg, AK 99833 

RE: Kuiu Timber Sale DEIS 

Dear Kris: 

Thank you for the opportunity to comment on the Draft Environmental Impact 

Statement (“DEIS”) for the Forest Service’s proposed Kuiu timber sale. The action 

alternatives propose logging between 14.6 million board feet of timber from 491 acres to 

42.65 MMBF from 1,425 acres from the Kuiu Timber Sale Area on north Kuiu Island. 

Each of the action alternatives includes a significant amount of clearcutting in several 

watersheds, including Kadake Creek, Saginaw Bay, Rowan Bay, and Security Bay. I 

write to urge the Forest Service to adopt Alternative 1, the “No Action” alternative. I 

write with special emphasis on the place I know best, the Kadake Creek watershed. 

Over the past five years, I have come to treasure Kuiu Island, making the trek 

from Seattle via Petersburg a number of times to fish for steelhead and coho salmon, 

dolly varden, sea-run cutthroat, and Dungeness crab in Kadake creek and Kadake bay. 

I’ve hiked (and sometimes struggled) through much of the low-elevation old growth in 

the Kadake watershed. I’ve had the privilege of watching and photographing the island’s 

black bears, wolves, bald eagles, waterfowl, river otters, and deer. Several good friends 

and I fly into the Forest Service cabin in Kadake Bay at least once a year to fish, hunt 

waterfowl, and hike. On these trips, I spend over $800.00 on lodging in Petersburg – on 

chartered float plane flights, fishing licenses, groceries, camping and fishing supplies, 

and entertainment – all in just two days on either side of our flights to the Kuiu. 

 I’ve seen first hand the devastation caused by intensive logging outside the 

Roadless Areas on the north end of the island. Attached to these comments is a Google 

Earth satellite photograph of the proposed Project Area that shows the pattern of past 

harvest units pock-marking the northern part of Kuiu. That image, which I witnessed 

from the air flying into Kadake Bay on a clear day, speaks volumes about the wisdom 

of additional large-scale logging on the island. Others, including the Tlingit natives of 

the Village of Kake, can attest more accurately to the value of this area for native 

Alaskans and the impacts that this legacy of past logging on the island have had on their 
Comment Letter #17 – Steve Mashuda 

164 ● Appendix C Kuiu Timber Sale FEIS 

 Mashuda 

 3b 

 Mashuda 

 3c 

 Mashuda 

 3d 

 Mashuda 

 4 

 Mashuda 

 5 

 Mashuda 

 2 

 Mashuda 

 3a 

use of the area. 

 Despite these impacts, parts of North Kuiu still retain their wild character. Both 

the Forest Service and the Alaska Department of Fish and Game (ADF&G), have made 

official what the people of Kake and anyone who’s ever hooked a steelhead in Kadake 

Creek, struggled to find a stream crossing amongst throngs of spawning pink salmon, or 

feasted on Dungeness crab from Kadake Bay in September, already know – the Kadake 

watershed is a special place. The Tongass Fish and Wildlife Resource Assessment 

identified the stream systems for the Saginaw, Security, Rowan, and Kadake watersheds 

(all affected by the action alternatives) as primary salmon producers. ADF&G 

designated Kadake Creek in particular as a primary sportfish producer and one of 19 

“high value” watersheds in Southeast Alaska. In 1997, the Forest Service recommended 

23 miles of Kadake Creek as a recreational river under the Wild and Scenic River Act 

because of its high historic, recreation, and fisheries values. 

The DEIS does not adequately discuss the potential for significant effects to any 

of these watersheds and their fisheries from siltation, including the potential for increased 

sedimentation to destroy productive salmon spawning habitat. Further [logging or roadbuilding, including construction of so-called “temporary” roads, is inconsistent with 

protecting the recognized cultural, fish and wildlife, and recreational values of these 

watersheds, especially Kadake Creek.] I urge the Forest Service to [consider an 

alternative that would exclude this watershed and other sensitive areas from any timber 

sale units.] While such an alternative could take many forms, [the agency should 

examine an alternative that includes selective logging from existing road systems by 

smaller-scale operators.] I understand that this program has been used successfully 

elsewhere in the Tongass to meet legitimate demand for timber while protecting vital 

natural resources. 

Though the DEIS does not disclose or otherwise analyze this issue, the Ninth 

Circuit Court of Appeals last year invalidated the Tongass National Forest Plan 

because, among other things, it contained a fatally flawed economic analysis that 

“inflated the economic benefits and discounted the environmental impacts of the Plan.” 

See Natural Resources Defense Council v. U.S. Forest Service, 421 F.3d 797, 811 (9th

Cir. 2005). But this proposed sale appears to be based on that same flawed plan. It is an 

unfortunate, but now well-documented fact, that the Forest Service loses millions of 

dollars annually on its timber sale program both in Southeast Alaska and on the 

national level. This sale, with its construction of 19 miles of new roads, is no 

exception. 

At the same time, the Forest Service has proposed to close, sell, or eliminate 

needed repairs to several recreational cabins in the Tongass because of a budget shortfall 

of approximately $300,000.00 in its recreation program. The agency’s multiple-use 

mandate requires the Service to treat recreation and timber production at least on an equal 

basis. It simply does not make any sense to be proposing to close cabins that provide 

access and recreational opportunities to the public because of budget shortfalls while 

simultaneously proposing another timber sale that will lose more money. The Forest 

Service needs to take a step back and take a comprehensive look at the Tongass Forest 

Plan with these kinds of discrepancies in mind and fix the Plan before moving ahead with 
 Comment Letter #17 – Steve Mashuda 

Kuiu Timber Sale FEIS Appendix C ● 165 

 Mashuda 

 6 

 Mashuda 

 7 

this sale. 

On a related, but contrasting note, it is heartening to see that the Tongass National 

Forest has proposed, through its recreation master plan, to up.rade the cabin at Kadake 

Bay. As mentioned earlier, this cabin provides access to some of the best fishing, 

hunting, and recreational opportunities in Southeast Alaska. These are the kinds of 

decisions that make sense and ensure long-term economic productivity from the Forest. 

Thank you for the opportunity to comment on this proposed sale. For all of the 

reasons discussed above, the Forest Service should drop its proposal for this sale. North 

Kuiu Island is the . Short of that, the EIS process should be suspended at least until the 

Tongass National Forest Plan is amended or rewritten to comply with the Ninth 

Circuit’s NRDC decision. Only after that can the Forest Service have a chance to 

produce a Final Environmental Impact Statement that considers the full economic and 

environmental costs and benefits of this sale along with a broader range of action 

alternatives and other uses of the forest that protect the unique resources on Kuiu Island. 

 Sincerely, 

 /s/ 

 Steve Mashuda 
Response to Mashuda 

166 ● Appendix C Kuiu Timber Sale FEIS 

Mashuda - 1 

Preference for Alternative 1, the No-Action Alternative, has been noted. 

Mashuda - 2 

As noted, parts of North Kuiu Island still retain their wild character and it is the intention 

of the Kuiu Plan that the area will still retain wild characteristics after implementation of 

the proposed project. 

Most recreational and fish values of the Kadake watershed are concentrated at the mouth 

of Kadake Creek and within the riparian buffer of the creek itself (TLMP, Vol.2, pp E251-254). None of the proposed harvest units or temporary roads would be within these 

areas. The fisheries values of Kadake Creek are not expected to change with the proposed 

project activities (DEIS p. 3-182). 

The activities planned within the Kadake Creek Recreational River Land Use 

Designation (LUD) are consistent with the expectations for that LUD. Suitable forested 

land is available for harvest within the Recreational River LUD if the adjacent Land Use 

Designation allows timber harvest (Forest Plan p. 3-118) as is the case in The Kuiu 

Timber Sale Area (see Unit Cards Appendix B p. B-83 and B-85). Alternatives 1, 3, and 

5 do not propose any harvest within the Recreational River LUD. Alternative 2 proposes 

18 acres of partial timber harvest within the 1⁄2 mile wide river corridor and Alternative 4 

proposes 49 acres of partial harvest. See also Greenpeace Response #41. 

Mashuda - 3a 

The expected effects of the proposed project include temporary increases in sediment 

delivery to streams, primarily during road construction (DEIS p. 3-182). However, 

sediment delivery to streams associated with this project is not expected to significantly 

degrade fish habitat. The strategy for avoiding significant effects to streams within the 

Project Area includes the implementation of Forest-wide Standards and Guidelines and 

Best Management Practices (BMPs) (pp. B-6 – B-10 of the DEIS). Site specific design 

and mitigation measures for protecting streams are listed on the unit card narratives 

(DEIS B-16 to B-95) and are incorporated into road construction plans. Action 

alternatives proposed in this project would increase the amount of open road temporarily, 

but would ultimately reduce the amount of open road within the Project Area (DEIS 

Table 3-50, p. 3-129). 

The DEIS (p.3-182) acknowledges that there will be an increase in sedimentation from 

temporary road construction and reconditioning; however, this effect is expected to be 

short term (clarified in the FEIS as 48 hours after construction). The placement of stream 

buffers and the implementation of BMPs (DEIS Appendix B pp. B-7 – B -9) is expected 

to minimize the amount of sediment entering streams. The following statement has been 

added to the DEIS: Because sedimentation may reduce oxygen levels to developing eggs 

in spawning gravel and/or trap emerging fry in the gravel construction, timing windows 

for stream crossings on roads proposed for reconditioning or storage will be implemented 

(DEIS p. 3-175). 
 Response to Mashuda 

Kuiu Timber Sale FEIS Appendix C ● 167 

Mashuda - 3b 

See Mashuda #2 and Greenpeace Response #41. 

Mashuda - 3c 

Alternative 1, the No-Action alternative, does not propose any timber harvest or road 

building within the Kadake watershed. While Alternatives 2-5 do propose timber harvest 

within the Kadake watershed, Alternatives 3 and 5 do not propose harvest within the 1⁄2-

mile wide river corridor that is recommended as a Recreational River in the Wild and 

Scenic River System. The harvest proposed by Alternatives 2 and 4 within the corridor is 

limited to 18-acres partial harvest in unit 415 and an additional 31 acres partial harvest in 

Unit 41 in Alternative 4. See also Greenpeace #41. 

Mashuda - 3d 

The alternatives were developed in response to issues raised during public scooping, and 

timber sale economics was one of the issues identified. Supplying timber for a small 

sales program, as exists on other areas of the Tongass National Forest, is a program set up 

exclusively for the small mills and individuals from the numerous communities located 

around that area. Kuiu Island does not have the same level of community development as 

Prince of Wales Island, where the small sale program is located. Without this community 

structure, it is unlikely minor amounts of down or dead trees from the existing road 

system would provide economic timber. 

The Forest Service is currently planning a timber sale on Kupreanof Island that will 

consider timber sale opportunities for small-scale operators. 

Mashuda - 4 

In August 2005, the Ninth Circuit held that the environmental impact statement and 

record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the 

use of projected market demand for timber, the range of alternatives considered, and the 

cumulative effects of activities on non-National Forest System lands. In response to the 

Court ruling, the Forest Plan is currently being amended through an environmental 

impact statement. The DEIS for the amendment was released for public comment in 

January 2007. 

FAA is currently analyzing market demand. Appendix A has been updated with the 

information from Brackley et al. 

The Forest Service is not mandated to make money by offering timber for sale. The 

Timber program is not unusual in costing more to operate than the government receives 

in revenues from the program. Many programs on the Tongass NF generated no revenue, 

including the subsistence, heritage, inventory and monitoring, land management 

planning, geology, fish and wildlife management, trail improvements, and fire protection 

programs. 

Mashuda - 5 
Response to Mashuda 

168 ● Appendix C Kuiu Timber Sale FEIS 

The Multiple-Use Sustained Yield Act of 1960 directs the Forest Service to consider and 

manage all the resources on the national forests. It also recognizes that some land will be 

used for less than all of the resources. The Act does not mandate equal spending for each 

resource on the national forest. The Forest Service is allocated a certain amount of 

funding for recreation, timber and other resources with specific direction on how to use 

that money. The amount of money allocated to each resource is beyond the scope of this 

project. 

The Forest Service is undergoing a 5-year evaluation process with its public use cabins, 

and is decommissioning those that cannot be maintained to standard. One cabin in the 

Petersburg Ranger District is being decommissioned this year due to lack of funding and 

lack of demand, and it is a cabin that has been unavailable to the public for over 10 years 

due to its poor condition. 

The Forest Service is directed to sell commercial timber sales at no less than appraised 

rates. The Kuiu Timber Sale is not a deficit sale. 

Mashuda - 6 

The Forest Service is glad to have agreement with some of the management decisions. 

Mashuda - 7 

For the rest of the comments see the response to Mashuda - 4. 
 Comment Letter #18 – Chris Zimmer 

Kuiu Timber Sale FEIS Appendix C ● 169 

 Zimmer 

 1 

 Zimmer 

 2 

 Zimmer 

 3 

 Zimmer 

 4 

 Zimmer 

 5 
Comment Letter #18 – Chris Zimmer 

170 ● Appendix C Kuiu Timber Sale FEIS 

 Zimmer 

 5 contd. 

 

 
 Response to Zimmer 

Kuiu Timber Sale FEIS Appendix C ● 171 

Zimmer - 1 

Most cultural, historical, recreational, fish and wildlife values of the Kadake watershed 

are concentrated at the mouth of Kadake Creek and within the riparian buffer of the creek 

itself (TLMP FEIS, Appendix, Vol. 2, pp E-251-254). None of the proposed harvest 

units or roads would be within these areas. See also Mashuda #2 and GSS #41. 

Zimmer - 2 

Preference for Alternative 1 – The No Action Alternative, is noted. 

Zimmer - 3 

In August 2005, the Ninth Circuit held that the environmental impact statement and 

record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the 

use of projected market demand for timber, the range of alternatives considered, and the 

cumulative effects of activities on non-National Forest System lands. The court did not 

find a willful inflation of market demand to justify logging. In response to the Court 

ruling, the Forest Plan is currently being amended through an environmental impact 

statement. The DEIS for the amendment was released for public comment in January 

2007. 

FAA is currently analyzing market demand. Appendix A has been updated with the 

information from Brackley et al. 

The microsale program on Prince of Wales Island referenced in the comments is a timber 

sale consisting of dead or down timber, which has been proposed by a prospective 

purchaser, that the District Ranger agrees to offer for bidding using an informal 

advertisement and short Bid Form. The maximum size of a microsale is 50 MBF and 

$10,000 advertised value. District Rangers review each proposed microsale that is greater 

than 25 MBF for its potential as a regular small sale. 

Kuiu Island does not have the same level of community development as Prince of Wales 

Island. Without this community structure, it is unlikely the same demand will exist for 

minor amounts of down or dead trees from the existing road system. 

Zimmer - 4 

The court listed its findings in Natural Resources Defense Council v. U.S. Forest Service

but did not require the Forest to revise the plan. In response to the court’s decision the 

Tongass chose to amend the Forest Plan. Until the revision is completed, projects will 

move forward, with the Forest Plan continuing to be the guiding document and contract 

with the public. 

The Tongass National Forest will continue to be managed in compliance with Section 

101 of the Tongass Timber Reform Act of 1990 (TTRA), which modified the Alaska 

National Interest Lands Conservation Act (ANILCA). This states that the Secretary of 

Agriculture “...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 market demand from such forest for each planning cycle.” 
Response to Zimmer 

172 ● Appendix C Kuiu Timber Sale FEIS 

As described more fully in Appendix A of the FEIS, to provide a steady flow of timber 

harvest volume, timber sale projects need to be completed through the NEPA process 

each year to meet current and future market demand. 

Zimmer - 5 

The Forest Service is undergoing a 5-year evaluation process with its public use cabins, 

and is decommissioning those that cannot be maintained to standard. One cabin in the 

Petersburg Ranger District is being decommissioned this year due to lack of funding and 

lack of demand, and it is a cabin that has been unavailable to the public for over 10 years 

due to its condition 

The Forest Service is not mandated to make money by offering timber for sale. The 

Timber program is not unusual in costing more to operate than the government receives 

in revenues from the program. Many programs on the Tongass NF generated no revenue, 

including the subsistence, heritage, inventory and monitoring, land management 

planning, geology, fish and wildlife management, trail improvements, and fire protection 

programs. 
 Comment Letter #19 – NRDC form letter 

Kuiu Timber Sale FEIS Appendix C ● 173 

 NRDC - 1 

 NRDC - 2 

 NRDC - 3 
Response to NRDC form letter 

174 ● Appendix C Kuiu Timber Sale FEIS 

NRDC - 1 

Opposition to new road building and logging on Kuiu Island has been noted. 

NRDC - 2 

Concern over the acres of clearcuts on Kuiu Island in noted. The 27,856 acres of harvest 

referred to are located on an island that is 482,101 acres, 64 percent of which is in nonmanagement LUDS (Kuiu Island Landscape Assessment). Less than six percent of the 

island has been harvested and less than five percent of the major watersheds have any 

harvest in them. In addition there is a forest-wide system of protection provided by other 

non-development LUDs (282,558 acres on Kuiu Island) that maintain the integrity of the 

forest-wide ecosystem and provide future options for maintaining naturally occurring 

ecosystems. 

The Project Area is mostly roaded. The use of the existing road system was one of the 

reasons this area was chosen. 

NRDC - 3 

See response GSS-12 
 Comment Letter #20 – WS form letter 

Kuiu Timber Sale FEIS Appendix C ● 175 

 

 

 WS - 1 
Response to WS form letter 

176 ● Appendix C Kuiu Timber Sale FEIS 

WS - 1 

The request to cancel the proposed Kuiu timber sale has been noted. 

In August 2005, the Ninth Circuit held that the environmental impact statement and 

record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the 

use of projected market demand for timber, the range of alternatives considered, and the 

cumulative effects of activities on non-National Forest System lands. In response to the 

Court ruling, the Forest Plan is currently being amended through an environmental 

impact statement. The DEIS for the amendment was released for public comment in 

January 2007. 

The past harvest and road construction referred to is located on an island 482,101 acres in 

size of which 64 percent is in non-management LUDs (Kuiu Island Landscape 

Assessment). Less than six percent of the island has been harvested and less than five 

percent of the major watersheds include any harvest. 

On p. 3-26 of the DEIS it states, “The Forest Plan contains a comprehensive conservation 

strategy to assure viable and well-distributed wildlife populations (Forest Plan FEIS 

Appendix, Volume 4, Appendix N, 1997).” The DEIS goes on to explain much of this 

strategy. While there is expected to be some effects from the proposed actions of each 

alternative, the cumulative effects listed on pp. 3-72 thru 3-74 do not identify any threats 

to the viability to any species from the proposed timber harvest activities. 

The Conservation Strategy Review Workshop was conducted April 10-14, 2006 at the 

Ted Ferry Civic Center in Ketchikan Alaska. Key Findings from the workshop are listed 

below: 

• The Conservation Strategy is still sound. 

• There is a low risk of species viability problems related to Forest Plan 

implementation. 

• Endemic species continue to be a high priority information need. 

• There is good opportunity to manage habitats to emphasize production of prey 

species of other foods. 

• Management of young-growth forests for wildlife habitat is promising, 

especially for species like black-tailed deer. 

• There is a need to better understand the role and management of the Matrix 

part of the Strategy, including the role of non-National Forest System lands. 

• The wildlife monitoring program needs to be updated. 

The historic and current use of Kuiu Island for subsistence deer hunting has been updated 

in the FEIS (see Response to OVK 2a). Analyses for heritage resources, subsistence, and 

socioeconomics can be found in Chapter 3.