Chapter 1 

Purpose and Need 
Chapter 1 

Table of Contents 

Chapter 1 ........................................................................................................ 1

Purpose and Need .......................................................................................... 1

1.1 Introduction........................................................................................... 1

1.2 Proposed Action ................................................................................... 1

1.3 Purpose and Need................................................................................ 2

1.4 Decisions to be Made ........................................................................... 2

1.5 Management Direction ......................................................................... 4

1.6 Description of the Project Area............................................................. 9

1.7 Public Involvement ............................................................................... 9

1.8 Consultation........................................................................................ 11

1.9 Significant Issues................................................................................ 13

1.10 Other Issues and Concerns.............................................................. 16

1.11 Federal and State Permits, Licenses, and Certifications ................. 18

1.12 Applicable Laws and Executive Orders............................................ 19
Kuiu Timber Sale FEIS Chapter 1 • 1

Chapter 1 

Purpose and Need 

1.1 Introduction 

The Kuiu Timber Sale Area (Project Area) is located on north Kuiu 

Island, on the Petersburg Ranger District, Tongass National Forest, 

Alaska Region (Region 10) of the Forest Service, an agency of the 

U.S. Department of Agriculture (see Vicinity Map, Figure 1-1). 

This chapter discusses the background of the Kuiu Timber Sale project 

and tiers to the Tongass National Forest Land and Resource 

Management Plan (referred to as the Forest Plan in this document). It 

includes the steps taken to identify environmental issues and public 

concerns related to implementation of the project. 

1.2 Proposed Action 

A “proposed action” is defined early in the project-level planning 

process to briefly describe the project’s actions and magnitude. This 

serves as a starting point for the environmental analysis and gives the 

public and other agencies specific information to focus comments 

upon. Using these comments (see discussion of Significant Issues later 

in this chapter), and information from preliminary analysis, the 

interdisciplinary team develops alternatives to the proposed action. 

These are discussed in detail in Chapter 2. 

The Proposed Action for the Project Area (Alternative 4) is for the sale 

and harvest of approximately 33.3 million board feet (mmbf) of 

sawlog and utility volume from 1,387 acres of National Forest System 

land. This harvest would require about 3.9 miles of temporary road 

construction, and 6.5 miles of NFS road construction. The logs would 

be hauled by truck to existing log transfer facilities (LTFs) at Rowan 

Bay or Saginaw Bay for shipment. Timber from this project would be 

offered through the Tongass National Forest timber sale program. 

The Proposed Action includes adjusting the boundary of three small 

old-growth habitat reserves (OGRs) in or adjacent to the Project Area 

to meet Forest Plan criteria. The proposed adjustments would result in 

changes to the size of the OGRs (see Chapter 3, Wildlife). Any 
1 Purpose and Need 

2 • Chapter 1 Kuiu Timber Sale FEIS 

proposed OGR adjustments would require a non-significant 

amendment to the Forest Plan. 

1.3 Purpose and Need 

The project would achieve goals and objectives described in the Forest 

Plan, and help realize desired conditions described in that plan. Forestwide goals and objectives (Forest Plan, pp. 2-3 and 2-4) that this 

proposed action would achieve include the following: 

• Provide for a vigorous and healthy forest environment, including 

management of the timber resource for production of saw timber 

and other wood products from suitable lands made available for 

timber harvest on an even-flow, long-term sustained yield basis, 

and in an economically efficient manner, 

• Ensure that the small OGR system criteria meets the minimum 

size, spacing, and composition, 

• Provide diverse opportunities for resource uses that contribute to 

the local and regional economies of Southeast Alaska, supporting a 

wide range of natural-resource employment opportunities within 

Southeast Alaska’s communities. 

Appendix A provides information on how this project relates to the 

overall Tongass timber sale program, and why the project is being 

scheduled at this time. 

1.4 Decisions to be Made 

Based on the environmental analysis in this EIS, the Forest Supervisor 

will decide whether and how to implement activities within the Project 

Area in accordance with Forest Plan goals, objectives, and desired 

conditions. The decision may include: 

• The location, design, scheduling, amount, and method of timber 

harvest, NFS and temporary road construction and closure, LTFs, 

and silvicultural practices, 

• Any necessary project-specific mitigation measures and 

monitoring requirements, 

• A determination of whether there may be a significant possibility 

of a significant restriction on subsistence uses, and 

• Whether any changes in the small OGRs in VCUs 398, 399, or 402 

should be made and approved as a non-significant amendment to 

the Forest Plan. 
K e k u S t r a i t

Port

Cam

de

n

Bay of Pillars

Washington

Bay

Saginaw Bay

Kadake

Bay

Security

Bay

Rowan

Bay

Threemile Arm

C

h

a

t

h

a

m

S

t

r

a i t

F r e d e r i c k S o u n d

Kake

Legend

Non-National Forest

Lakes/Salt Water

500ft Contour Interval

Kuiu Project Area Boundary

Existing Roads

Vicinity Map of Kuiu Timber Sale

Petersburg Ranger District

Tongass National Forest

0 2.5 5

Miles

±

Area of Detail

Juneau

Petersburg

Ketchikan

^_

Figure 1-1

LTF

LTF

Kuiu Island

Kupreanof

Island

u:/workspace/kuiu_roaded/feis/plots/feis_plots/f1_1rightmargin.mxd 07-09-07 EP
1 Purpose and Need 

4 • Chapter 1 Kuiu Timber Sale FEIS 

1.5 Management Direction 

The Kuiu Timber Sale EIS is a project-level analysis. The scope of the 

analysis is confined to the Project Area, and when appropriate, areas 

adjacent to the sale area. The analysis addresses the significant issues 

and environmental consequences of the proposed action and its 

alternatives. While it does not attempt to address decisions made at 

higher levels of planning, it does implement direction provided at 

those higher levels. 

The Forest Plan embodies the provisions of the National Forest 

Management Act (NFMA), its implementing regulations, and other 

guiding documents. The Forest Plan sets forth in detail the direction 

for managing the land and resources of the Tongass National Forest, 

and this EIS tiers to the 1997 Forest Plan and 1993 Forest Plan SEIS. 

The process of remedying the shortcomings identified by the Ninth 

Circuit Court of Appeals is in progress with a Forest Plan Amendment 

DEIS released in January 2007. The current revised Forest Plan allows 

for the activities in the Kuiu Project Area 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 account for the 

time period when sale areas are typically inaccessible (winter months). 

Delayed project analyses affect other projects “in line” for 

consideration, creating impacts to the entire sale program several years 

into the future. Delayed project analyses also diminish the Forest 

Service’s ability to respond to the on-going timber demand since the 

analyses are time-consuming. The Kuiu project includes consideration 

of an alternative that does not directly affect roadless areas. The Kuiu 

FEIS will be reviewed for consistency with the Forest Plan 

Amendment decision following the procedures in the Forest Service 

Handbook FSH 1909.15 Section 18. Any portions of this project will 

be adjusted as necessary to be consistent with the management 

direction in the Forest Plan Amendment decision. 

The Forest Plan uses Land Use Designations (LUDs) to guide the 

management of the National Forest System lands on the Tongass 

National Forest. Chapter 3 of the Forest Plan contains a detailed 

description of each land use designation. The Project Area includes 

three of these LUDs – Timber Production, Recreational River, and 

Old-growth Habitat Reserve (Table 1-1). Goals, objectives and desired 

future conditions of each are summarized below. The locations of each 

LUD on Kuiu Island, including the Project Area, are shown on Figure 

1-2. Less than one percent of the lands in the Project Area are nonNational Forest system lands. 

1.5.1 Forest 

Plan Land Use 

Designations 
 Purpose and Need 1

Kuiu Timber Sale FEIS Chapter 1 • 5 

1.5.1.1 Timber Production LUD (42,905 acres) 

Tongass-wide these lands are managed for the production of saw 

timber and other wood products on an even-flow, long-term sustained 

yield basis. The forested areas are healthy stands with a balanced mix 

of age classes. An extensive road system is developed for accessing 

timber and subsequently used for recreation, hunting, fishing, and 

other public and administrative uses. Roads may be closed, either 

seasonally or year-round, to address resource and other needs. 

Management activities will generally dominate most seen areas. A 

variety of wildlife habitats, predominately in the early and middle 

successional stages, is present. 

The Timber Production LUD includes areas of beach and estuary 

fringe, riparian reserves, high-vulnerability karst, Riparian 

Management Areas (RMAs), non-forested areas, and non-productive 

forested areas totaling approximately 8,182 acres. These acres are 

considered unsuitable for timber production and were removed from 

the suitable1 timber base by the Forest Plan. Prior to the signing of the 

Forest Plan Record of Decision, approximately 1,739 acres of what is 

now considered unsuitable land for timber production had been 

harvested. Most of this harvest took place in what are now recognized 

as riparian areas, beach fringe areas, and non-development LUDs. 

These acres are included in the total acres harvested discussion in the 

“Prior Management of the Area” section in this chapter and throughout 

the EIS. 

Approximately 29,362 acres in the Timber Production LUD are 

considered suitable for timber production, and 8,654 of these acres 

have been previously harvested. Of the total acres harvested in the 

Project Area (approximately 1,739 from unsuitable lands and 8,654 

from suitable lands), 4,766 acres have been pre-commercially thinned. 

The remaining 5,627 acres are too young and not large enough for 

commercial thinning. The second-growth that is on suitable land is not 

proposed for harvest at this time. 

 

1

 Suitable Forest land - Forest land that is producing or is capable of producing crops 

of industrial wood and; 1) has not been withdrawn by Congress, the Secretary of 

Agriculture, or the Chief of the Forest Service; 2) existing technology and 

knowledge is available to ensure timber production without irreversible damage to 

soils productivity or watershed conditions; 3) existing technology and knowledge, as 

reflected in current research and experience, provides reasonable assurance that it is 

possible to restock adequately within five years after final harvest, 4) adequate 

information is available to project responses to timber management activities, and 5) 

where timber harvest is allowed under the Forest Plan. 
1 Purpose and Need 

6 • Chapter 1 Kuiu Timber Sale FEIS 

The remaining 20,708 acres of suitable timber in the Project Area 

includes land with productive old-growth1

 timber and is available for 

harvest at this time. 

1.5.1.2 Recreational River LUD (1,246 acres) 

Recreational River segments are managed to maintain a free-flowing 

river resource, while providing for access and use consistent with the 

Wild and Scenic Rivers Act and the Alaska National Interest Lands 

Conservation Act (ANILCA). Timber harvest is permitted on suitable 

lands if adjacent lands are being managed for timber. These 

Recreational River lands would also be managed for recreation use and 

activities to meet the criteria for a number of social encounters, on-site 

developments, methods of access and visitor impacts. Roads are 

permitted to access, parallel or cross the river. Visual Quality 

Objectives (VQOs) would be applied within the corridor. 

In the Project Area approximately 1,246 acres are in the Recreational 

River LUD. This LUD maintains the eligibility status of the Kadake 

River corridor for the Wild and Scenic River designation. 

1.5.1.3 Old-growth Habitat LUD (1,595 acres) 

In the Project Area, there are approximately 1,595 acres in the Oldgrowth Habitat LUD. The LUD’s objectives are to provide forest 

habitats to maintain viable populations of native and desired nonnative fish and wildlife species that may be closely associated with 

old-growth forests. Other objectives are to contribute to the habitat 

capability of fish and wildlife resources in order to support sustainable 

human uses, and to maintain biological diversity components and 

ecological processes associated with old-growth forests. 

 

1

 Productive Old-growth – old-growth stands capable of producing 20 cubic feet per 

acre per year with 8,000 or more board feet of timber per acre 
 Purpose and Need 1

Kuiu Timber Sale FEIS Chapter 1 • 7 

Table 1- 1. Forest Plan Land Use Designations on Kuiu 

Island 

Land Use 

Designation 

(acres) 

Kuiu Island Kuiu Project 

Area (acres)

% of project 

area in LUD

Non-development LUDs 

Wilderness 124,576 0 0 

Special 

Interest Area 1,094 0 0 

Remote 

Recreation 42,347 0 0 

Old-growth 

Habitat 25,171 1,595 3% 

Semi-remote 

Recreation 106,149 0 0 

Wild River 1,807 0 0 

Recreational 

River 6,585 1,246 3% 

Development LUDs 

Recreational 

River1 6,585 1,246 3% 

Modified 

Landscape 29,444 0 0 

Timber 

Production 141,141 42,905 93% 

Other

Non-National 

Forest System 

Land 

3,787 356 <1% 

1

Recreation LUDs may be considered for development LUDs based on the adjacent lands. 
421

402

400

420

399

403

401

398

419

405

427

Kake

Land Use Designation Map of Kuiu Timber Sale

Petersburg Ranger District

Tongass National Forest

0 2.5 5

Miles

Figure 1-2 Kuiu Project Area Boundary

WAA 5012 Boundary

Modified Landscape

Non-National Forest

Old-growth Reserve

Remote Recreation

Recreation River

Special Interest Area

Semi-Remote Recreation

Scenic Viewshed

Timber

Wild River

Wilderness

Rowan

Bay

Washington

Bay

Security

Bay

Saginaw

Bay

Kadake

Bay

C

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a

t

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a

m

S

t

r

a

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F r e d e r i c k S o u n d

K e k u S t r a i t

Port

Camden

Legend

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 Purpose and Need 1

Kuiu Timber Sale FEIS Chapter 1 • 9 

There are 356 acres of non-National 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. Although the 

Forest Service does not have authority over these non-national Forest 

Service lands, for purposes of this EIS they are considered when 

analyzing cumulative effects. 

1.6 Description of the Project Area 

The Project Area is located on north Kuiu Island, on the Petersburg 

Ranger District of the Tongass National Forest in Southeast Alaska, 

Townships 57, 58, and 59 South, Ranges 71 and 72 East, Copper River 

Meridian. The Project Area includes lands within Value Comparison 

Units (VCUs) 399, 400, 402, and 421, an area approximately 46,102 

acres (Figure 1-2). VCUs are comparable to large watersheds and 

generally follow major topographic divides. The Project Area is 

encompassed by National Forest System (NFS) Roads 6402 and 6415 

and the peninsula between Security Bay and Saginaw Bay. 

The Project Area is located approximately 12 air-miles southwest of 

the city of Kake, which is located on Kupreanof Island. Approximately 

356 acres of non-national forest system lands are included in the 

Project Area. Access to the area is by boat or floatplane. 

1.7 Public Involvement 

Public involvement is a key component of the planning process. The 

Council on Environmental Quality (CEQ) defines scoping as “...an 

early and open process for determining the scope of issues to be 

addressed and for identifying the significant issues related to a 

proposed action” (40 CFR 1501.7). Among other things, the scoping 

process is used to invite public participation, to help identify public 

issues, and to obtain public comment at various stages of the 

environmental analysis process. Scoping begins early and is a process 

that continues until a decision is made. Comments received at other 

levels of the planning process, such as for the Forest Plan and the 

landscape level analysis, were also considered. The following 

paragraphs describe the public involvement activities that have 

occurred for the Project Area analysis. 

The project has been included in the Tongass National Forest Timber 

Sale Plan since 2004 and was first placed on the Spring 2004 Schedule 

of Proposed Actions (SOPA). This schedule is updated quarterly and 

mailed to everyone who requests it, and is available at Ranger District 

1.5.2 

Non-National 

Forest 

System 

Lands 

1.6.1 

Geographic 

Location and 

Boundaries 
1 Purpose and Need 

10 • Chapter 1 Kuiu Timber Sale FEIS 

offices and on the Tongass National Forest website 

(www.fs.fed.us/r10/tongass). 

Comments made during the 2005 Kuiu Landscape Assessment scoping 

and open house events parallel the Forest Plan’s desired condition for 

the Tongass. People want to see a healthy deer population maintained 

on the island in perpetuity to meet the needs of subsistence hunters. 

They are concerned about the fragmentation of old-growth habitat and 

supportive of the old-growth habitat conservation strategy. 

Public comments support a sustainable timber harvest, although 

opinions differ on what level of harvest is acceptable. Public 

comments concerning recreation emphasize maintaining a wide 

spectrum of recreation opportunities, from developed to nondeveloped. Public comments strongly favor protection of water quality 

as it relates to fish and shellfish habitat because of the importance of 

aquatic species for subsistence and commercial uses. Public opinions 

regarding National Forest System roads vary widely, but most people 

agree that all open roads should be well maintained to minimize their 

environmental effects and to provide for the comfort and safety of 

users. 

Nearby residents in Kake, Point Baker, and Port Protection emphasize 

the importance of considering traditional community values and 

customs when proposing management activities. They express a desire 

for balance between meeting the economic needs of a community and 

meeting the ecological needs of the landscape. 

1.7.2.1 Public Mailing 

Public scoping began in February 2004. A newsletter identifying the 

Project Area and requesting information on site-specific concerns was 

mailed to approximately 270 people who: requested to be on project 

mailing lists, previously expressed interest in timber sale proposals, 

and either own property or conduct business near the Project Area. In 

addition, the newsletter was mailed to local, state, and federal agencies 

and federally recognized tribal governments. 

The project mailing list is frequently updated to accommodate requests 

for additions, deletions, and address changes. 

The Forest Service received 28 responses to this mailing. While some 

comments supported the proposed timber sale, most expressed 

concerns about additional road construction, uneconomic timber 

harvest, disturbance to wildlife, clearcutting as a harvest method, and 

the cumulative effects of additional harvest on previously harvested 

watersheds. 

1.7.1 

Kuiu Island 

Landscape 

Assessment 

Scoping 

1.7.2 

Project Area 

Scoping 
 Purpose and Need 1

Kuiu Timber Sale FEIS Chapter 1 • 11 

1.7.2.2 Open Houses 

Open houses that included information about the Kuiu Timber Sale 

were held in Petersburg in March 2004, December 2004, and June 

2005. Open houses were held in Kake in June and November of 2004. 

These open houses were advertised in the Petersburg Pilot, the local 

weekly newspaper in Petersburg, and on KFSK Public Radio in 

Petersburg. Flyers were posted on bulletin boards throughout 

Petersburg. In Kake, flyers were sent to the City Council for posting 

prior to the meetings. There is no local paper or radio station in Kake. 

A Notice of Intent to Prepare an Environmental Impact Statement was 

published in the Federal Register on August 9, 2004. On September 

14, 2004, a revised Notice of Intent was published. This Notice briefly 

described the proposed action and the purpose and need for the project. 

Estimated timelines for the project were given, along with the project 

background summary and contact information for those interested in 

participating in the planning process. 

1.8 Consultation 

The Forest Service is committed to working closely with other 

agencies at all stages of planning. The agency is responsible for 

coordinating reviews of the project by several other agencies. In some 

cases, the reviews are required because another agency has authority to 

issue permits for certain proposed activities. In other cases, the reviews 

allow interaction with other agencies with responsibilities for certain 

environmental conditions, like clean water or healthy wildlife 

populations. This interagency cooperation helps identify the means to 

avoid or mitigate possible harmful environmental effects. In many 

cases, an ongoing professional dialogue is maintained with these 

agencies throughout the planning process. 

The following agencies have been consulted about this project: 

• Alaska Department of Fish and Game 

• Alaska Department of Environmental Conservation 

• Alaska Office of History and Archaeology 

• Alaska Department of Natural Resources 

• U.S. Environmental Protection Agency 

• National Marine Fisheries Service 

• U.S. Army Corps of Engineers 

• U.S. Fish and Wildlife Service 

1.7.3 

Notice of 

Intent 

1.8.1 

Consultation 

with Other 

Government 

Agencies 
1 Purpose and Need 

12 • Chapter 1 Kuiu Timber Sale FEIS 

In 1998, in a collaborative process, a Forest Service wildlife biologist 

worked with biologists from the U.S. Fish and Wildlife Service 

(USFWS), the Alaska Department of Fish and Game (ADF&G), and 

the Alaska Department of Environmental Conservation (DEC) to 

develop a biologists’ recommended design for placement of the small 

old-growth habitat reserves for all of Kuiu Island. In June 2004, 

representatives from ADF&G, USFWS, and DEC met with the Kuiu 

Interdisciplinary Team (IDT) to further discuss options for 

reconfiguring the small OGRs in northern Kuiu Island, including those 

in or near the Project Area. The following day, the IDT coordinated an 

interagency field trip to the Project Area with representatives of 

ADF&G, USFWS, and DEC. There was agreement to submit the 

proposed small OGR recommendations for VCUs 398, 399, and 402 

for analysis in this document. 

Consultation with federally recognized tribal governments included 

government-to-government and staff level communications. On 

November 22, 2004, several members of the Kuiu Timber Sale 

planning team accompanied Patricia Grantham, Petersburg District 

Ranger, to Kake. They met with Henrich Kadake, Sr., Organized 

Village of Kake (OVK) President, and other OVK members, where the 

Kuiu Timber Sale was discussed. The Kuiu Timber Sale Heritage 

Resources report was given to the OVK council for review and 

comment. The Forest Service also sent letters of consultation and 

copies of our heritage resource report to the Petersburg Indian 

Association, Sealaska Corporation, and Tlingit/Haida Central Council. 

After the Draft EIS was made available to the public, the 

Environmental Protection Agency published the Notice of Availability 

of the Draft EIS in the Federal Register on February 2, 2006. Notices 

were also published in the Juneau Empire, the official newspaper of 

record, and in the Petersburg Pilot. The 45-day public comment period 

for the Draft EIS ended on March 20, 2006. Eighteen individual 

comment letters were received during the comment period, and are 

included in Appendix D. We also received two electronic form letters 

from two special interest groups, the Wilderness Society (WS) and the 

Natural Resource Defense Council (NRDC). The WS form letter was 

received from approximately 12,000 individuals and the NRDC was 

received from approximately 64,000 individuals. Responses to these 

form letters are included in Appendix D. Key issues from the DEIS 

comments include: water quality and fish habitat; timber economics; 

Forest Plan and legislation regarding NRDC vs U.S. Forest Service; 

effects on deer populations and subsistence users; and soil stability and 

the risk of landslides. 

1.8.2 

Consultation 

with Federally 

Recognized 

Tribal 

Governments 

1.8.3 

Availability of 

Draft EIS and 

Comments to 

DEIS 
 Purpose and Need 1

Kuiu Timber Sale FEIS Chapter 1 • 13 

In accordance with Section 810 of the Alaska National Interest Lands 

Conservation Act (ANILCA), a subsistence hearing for the Kuiu 

Timber Sale Area was held in Petersburg, Alaska on March 16, 2006 

at the Petersburg City Council Chambers. The date, time, and location 

of the subsistence hearing were publicized in the local media. Three 

people testified at the hearing. Their general concerns focused on the 

cumulative effects the proposed project would have on wildlife, 

subsistence and watersheds. 

Another subsistence hearing was held in Kake, Alaska at the 

Organized Village of Kake office on March 21, 2006. This hearing 

was delayed about a week due to weather conditions. The date, time, 

and location of this hearing were publicized in the local media and 

with flyers posted throughout town. One person testified at this 

hearing. The testifier’s concerns were about the negative effects the 

project could have on subsistence use by Kake residents (specifically 

on fish and waterfowl). He was also concerned about increased road 

use by hunters and declining bear populations. 

The Kuiu Timber Sale Area Final EIS Notice of Availability will be 

published in the Federal Register. A public notice will also appear in 

the Juneau Empire, the official newspaper of record, and the 

Petersburg Pilot. 

The planning record for this project includes the Draft EIS, Final EIS, 

material incorporated by reference, and all materials produced during 

the environmental analysis of this project. The planning record is 

available for public review at the Petersburg Ranger District in 

Petersburg, Alaska during normal business hours. 

1.9 Significant Issues 

Significant issues are used to formulate and design alternatives, 

prescribe mitigation measures, and analyze significant effects. 

Significant issues for the Kuiu Timber Sale have been identified 

through public and internal scoping. Similar issues are combined 

where appropriate. Issues can arise from a variety of sources, 

including: 

• Issues, concerns, and opportunities identified in the Forest Plan, 

• Issues identified for similar projects (past actions), 

• Current internal issues, 

• Changes in public uses, attitudes, values, or perceptions, 

• Issues raised by the public during scoping, and 

• Comments from other government agencies. 

1.8.4 

Comments 

Received 

During 

Subsistence 

Hearings 

1.8.5 

Availability of 

the Final EIS 

1.8.6 

Availability of 

the Planning 

Record 
1 Purpose and Need 

14 • Chapter 1 Kuiu Timber Sale FEIS 

Measures of the significance of an issue are based on the extent of the 

geographic distribution, the duration of the related effects, or the 

intensity of interest or resource conflict surrounding the issue. For an 

issue to be considered significant at the project level, it must be 

relevant to the specific project so that it can be appropriately addressed 

at the project level. Some issues have already been resolved through 

national level direction or analyzed at the Forest Plan level. 

Once a significant issue is identified, measures are developed to 

analyze how each alternative responds to the issue. Measures are 

chosen that are quantitative (where possible), predictable, responsive 

to the issue, and linked to cause and effect relationships. These 

measures describe how the alternative affects the resource(s) at the 

heart of the issue. Monitoring and mitigation of the anticipated 

environmental effects of the project are also designed to be responsive 

to significant issues. 

The Forest Supervisor determined four significant issues within the 

scope of the Kuiu Timber Sale decision. These issues are addressed 

through the proposed action and the alternatives and are as follows: 

• Issue 1- Inventoried Roadless Areas, 

• Issue 2-Deer Habitat and Subsistence Use, 

• Issue 3-Timber Harvest Economics, and 

• Issue 4-Cumulative Watershed Effects. 

Some concerns will be addressed in the same way in all alternatives. 

For example, riparian and beach buffer strips will protect fish habitat 

from some of the effects of timber harvest in all alternatives. These 

measures are described in Chapter 2 in the section titled, “Design 

Criteria Common to All Action Alternatives.” They are also discussed 

in Chapter 3, Section 3.9 Fisheries. 

Issue 1 relates to timber harvest and the related construction of new 

roads to facilitate timber harvest in roadless areas or in the smaller 

unroaded areas (Figure 3-1). Additional roads and harvest could result 

in reducing acres of roadless area in the Project Area, and could affect 

roadless values as identified in the 2003 Tongass Land Management 

Plan Revision Final Supplemental Environmental Impact Statement – 

Roadless Area Evaluation for Wilderness Recommendations (Forest 

Plan SEIS). 

Nationally, roadless areas are considered to have valuable qualities. 

Several comments were received from the public concerning 

management of roadless in the Project Area. This analysis examines 

the values of two Inventoried Roadless Areas and three smaller 

unroaded areas that may be affected by this proposed project. 

1.9.1 

Issue 1 – 

Inventoried 

Roadless 

Areas 
 Purpose and Need 1

Kuiu Timber Sale FEIS Chapter 1 • 15 

Units of Measure 

To respond to this issue, alternatives will be compared according to 

how they affect acres and values of the two inventoried roadless areas 

and the three smaller unroaded areas within the Project Area. This 

evaluation will display the number of acres of proposed harvest and 

miles of road construction within Inventoried Roadless Areas and 

unroaded areas. Inventoried Roadless Areas will also be analyzed by 

their potential for Wilderness recommendation, and the changes to 

existing values as identified in the Forest Plan SEIS. 

Issue 2 relates to cumulative effects on deer habitat and connectivity 

from past, present, and proposed activities, and the resulting effects on 

subsistence uses. 

The cumulative reduction of important deer winter range for Sitka 

black-tailed deer from past, present, and proposed timber harvest may 

have adverse effects on the availability of deer for subsistence and 

may result in a significant possibility of a significant restriction to 

subsistence hunting. Sitka black-tailed deer are also a Forest Plan 

Management Indicator Species (MIS) which represents the habitat 

needs of several old-growth wildlife species that require low elevation, 

high volume habitat (see Issue 2: Deer Habitat and Subsistence Use, in 

Chapter 3). 

Most impacts from timber harvest activities occur in Productive Oldgrowth Habitats (POG). Timber harvest and road construction could 

affect corridors connecting old-growth habitat. Specifically, travel 

corridors from low to high elevation habitat could be affected by 

proposed activities. 

Units of Measure 

Effects of timber harvest on Sitka black-tailed deer habitat will be 

evaluated by using the deer habitat capability model to measure the 

effects of the alternatives on acres of important deer winter range and 

potential deer carrying capacity of Wildlife Analysis Area (WAA) 

5012, and by comparing model results to historic and current hunting 

effort data from ADF&G. 

POG and low elevation/high volume POG will be analyzed by 

comparing changes in acres between current, proposed, and reasonably 

foreseeable future activities in the WAA. 

Connectivity will be discussed by looking at the removal of existing 

corridors by proposed harvest units and, in particular, corridors linking 

high and low elevation habitat. 

1.9.2 

Issue 2 – Deer 

Habitat and 

Subsistence 

Use 
1 Purpose and Need 

16 • Chapter 1 Kuiu Timber Sale FEIS 

Issue 3 relates to the economic viability of the proposed timber sale or 

sales. It also relates to the potential employment and the revenue 

generated for communities in the area. If proposed timber harvest 

alternatives are not designed to be economically viable across 

fluctuating market conditions, there is concern that the forest products 

industry in Southeast Alaska cannot remain viable. 

Units of Measure 

Comparison of alternatives for this issue will include the amount 

(volume) of timber harvested, the value of the timber to be removed 

(stumpage values), the number of direct jobs and estimated direct 

income generated (present net value), the logging costs, and the 

anticipated contributions to the regional economy. 

Watersheds within the Project Area have high value for fisheries. Two 

of the watersheds within the Project Area exceed 20 percent 

cumulative harvest within the last 30 years. The cumulative effects of 

harvest and road construction within the Project Area may affect the 

condition of stream channels that drain these watersheds. 

Units of Measure 

To respond to this issue, alternatives will be compared according to: 

acres of proposed cumulative timber harvest within each major 

watershed; miles of new NFS and temporary road construction; and 

miles of NFS roads to be closed. 

The analysis of cumulative watershed effects will also make use of: 

the Sediment Risk Index, a tool that integrates stream, soil and 

watershed characteristics to facilitate a comparison of the relative 

potential for sediment-related changes in stream channels to occur 

among a group of watersheds; an analysis of current stream channel 

conditions compared to the Tongass Fish Habitat Objectives; and 

projections of watershed recovery rates based on calculations of future 

cumulative harvest levels using a 30-year window. 

1.10 Other Issues and Concerns 

Many comments received during the public scoping process concerned 

issues that are not considered significant because they are already 

addressed through other processes or in the Forest Plan (see Design 

Criteria Common to All Action Alternatives, Section 2.4 in Chapter 2), 

or their resolution is beyond the scope of this project. As needed, 

resource effects related to these concerns are discussed in Chapter 3. 

1.9.3 

Issue 3 –

Timber 

Harvest 

Economics 

1.9.4 

Issue 4 –

Cumulative 

Watershed 

Effects 
 Purpose and Need 1

Kuiu Timber Sale FEIS Chapter 1 • 17 

Some comments received during scoping are not specific to the project 

or concern decisions that are made at a higher level of planning. These 

comments are paraphrased and addressed below. 

1.10.1.1 No more logging or road building on National 

Forest Lands, the Tongass National Forest and/or Kuiu 

Island 

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

appropriate activities on National Forests, starting with the founding 

legislation for National Forests in 1897. The National Forest Organic 

Act provides that National Forests may be established “to improve and 

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

securing favorable conditions of water flows and to furnish a 

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

of the United States.” 

Congress’s policy for National Forests, as stated in the Multiple-Use 

Sustained Yield Act of 1960, is “the National Forests are established 

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

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

authorized the Secretary of Agriculture to sell trees and forest products 

from the National Forests “at no less than appraised value.” The 

National Forest Management Act directs that forest plans shall 

“provide for multiple use and sustained yield, and in particular, include 

coordination of outdoor recreation, range, timber, watershed, wildlife, 

fish and wilderness.” 

This was one of the significant issues raised during the development of 

the Forest Plan. During that forest planning process, a wide array of 

alternatives was developed and analyses were conducted to estimate 

the effects of those alternatives. The selected alternative documented 

in the Forest Plan Record of Decision permitted timber harvest to 

occur in certain areas on the forest. The majority of the Project Area is 

allocated to the Timber Production LUD, where timber harvest is 

permitted. 

The No-Action Alternative for this EIS responds to this issue by not 

proposing timber harvest in the Project Area. 

1.10.1.2 Protect all old-growth forests 

The guidelines for management of old-growth forests are developed at 

the Forest Plan level. During the Forest Plan analysis, various 

strategies were analyzed for the protection of old-growth. This resulted 

in the forest-wide old-growth habitat reserve system. Other old-growth 

forests are protected by riparian, beach, and estuary fringe standards 

and guidelines and non-development land use designations. Some oldgrowth is designated as available for timber harvest by development 

1.10.1 

Issues Beyond 

the Scope of 

this EIS 
1 Purpose and Need 

18 • Chapter 1 Kuiu Timber Sale FEIS 

LUDs, such as Timber Production, Scenic Viewshed, and Modified 

Landscape. 

1.10.1.3 Analyze the impacts of the project on carbon 

sequestering 

It is currently being addressed with the Forest Plan Amendment. 

1.10.1.4 Identify the number of logging jobs that would be 

filled by seasonal, nonresident workers 

While this document provides an estimate of the number of jobs 

created by each alternative (Issue 3: Timber Sale Economics in 

Chapter 3), it is not possible to predict with any degree of reliability 

the residency of those who would fill the jobs that might be supported 

by a particular timber sale. 

1.11 Federal and State Permits, 

Licenses, and Certifications 

To proceed with the activities proposed in this EIS, various permits 

from other federal and state agencies may be required. The following 

permits have been or will be obtained. 

U.S. Army Corps of Engineers 

Section 404 of the Clean Water Act (1977, as amended) requires a 

permit from the Corps of Engineers before filling or dredging in 

wetlands and tidelands. Section 10 of the Rivers and Harbors Act of 

1899 requires Corps of Engineers approval for the construction of 

structures or work in navigable waters of the United States. This 

applies to the existing Rowan Bay and Saginaw Bay LTFs, for which 

any reconstruction at Saginaw Bay LTF would require an amendment 

to the existing permit. All roads proposed for this project meet the 

criteria for a silvicultural exemption from permits required by Section 

404. 

U.S. Environmental Protection Agency 

A Storm Water Discharge Permit and a permit for discharge of bark 

and wood debris (Section 402 of the Clean Water Act) has been 

obtained. Both of these permits are required for the Rowan Bay and 

Saginaw Bay LTFs. The contractor will be responsible for obtaining 

the necessary stormwater discharge permits for log storage and 

handling at the LTFs, and for ground disturbing activities on more than 

one acre. 
 Purpose and Need 1

Kuiu Timber Sale FEIS Chapter 1 • 19 

State of Alaska, Department of Natural Resources 

Use of the Rowan Bay and Saginaw Bay LTFs requires authorization 

for occupancy and use of tidelands and submerged lands from the 

Alaska Department of Natural Resources. This permit has been 

obtained. 

State of Alaska, Department of Environmental Conservation 

A Certification of Compliance with Alaska Water Quality Standards 

(Section 401 Certification) has been obtained for the Rowan Bay and 

Saginaw Bay LTFs. 

1.12 Applicable Laws and Executive 

Orders 

This section includes a partial list of federal laws and executive orders 

pertaining to project-specific planning and environmental analysis on 

federal lands. Disclosures and findings required by these laws and 

orders are found at the end of Chapter 3. 

• Organic Administration Act of 1897 (as amended) 

• Rivers and Harbors Act of 1899 

• Migratory Bird Treaty Act of 1918 (as amended) 

• Bald and Golden Eagle Protection Act of 1940 (as amended) 

• Multiple-Use Sustained-Yield Act of 1960 

• National Historic Preservation Act of 1966 (as amended) 

• Wild and Scenic Rivers Act of 1968, amended 1986 

• National Environmental Policy Act (NEPA) of 1969 (as amended) 

• Clean Air Act of 1970 (as amended) 

• Alaska Native Claims Settlement Act (ANCSA) of 1971 

• Coastal Zone Management Act (CZMA) of 1972 (as amended) 

• Marine Mammal Protection Act of 1972 

• Endangered Species Act (ESA) of 1973 (as amended) 

• Forest and Rangeland Renewable Resources Planning Act (RPA) 

of 1974 (as amended) 

• National Forest Management Act (NFMA) of 1976 (as amended) 

• Clean Water Act of 1977 (as amended) 
1 Purpose and Need 

20 • Chapter 1 Kuiu Timber Sale FEIS 

• American Indian Religious Freedom Act of 1978 

• Alaska National Interest Lands Conservation Act (ANILCA) of 

1980 

• Archeological Resource Protection Act of 1980 

• Cave Resource Protection Act of 1988 

• Native American Graves Protection and Repatriation Act (1990) 

• Tongass Timber Reform Act (TTRA) of 1990 

• Magnuson-Stevens Fishery Conservation and Management Act of 

1996 

• Executive Order 11593 (cultural resources) 

• Executive Order 11988 (floodplains) 

• Executive Order 11990 (wetlands) 

• Executive Order 12898 (environmental justice) 

• Executive Order 12962 (aquatic systems and recreational fisheries) 

• Executive Order 13007 (American Indian Sacred Sites) 

• Executive Order 13186 (Migratory Bird Treaty)