United States 

Department of 

Agriculture

Forest 

Service 

Alaska Region 

Tongass National Forest 

648 Mission Street 

Ketchikan, AK 99901 

Phone: (907) 225-3101 

Fax: (907) 228-6215

 Caring for the Land and Serving People Printed on Recycled Paper 

File Code: 1950-3 

Date: January 23, 2008 

 

Dear Planning Participant: 

 

This letter accompanies the Record of Decision (ROD), Final Environmental Impact Statement 

(Final EIS) and Amended Land and Resource Management Plan (Forest Plan) which respond to 

a decision issued by the 9th Circuit Court of Appeals. 

In August 2005, the U.S. Court of Appeals for the Ninth Circuit issued a decision in Natural 

Resources Defense Council, et al., v. United States Forest Service, et al., 421 F.3d 797 (9th Cir. 

2005) that found deficiencies in the process used to develop the 1997 Forest Plan revision. 

Specifically, the Court found inadequacies related to timber demand, the range of alternatives 

considered relative to timber demand and potential effects on roadless areas, and cumulative 

effects from activities conducted on non-National Forest System lands. The Court ordered 

additional analysis and the development of an environmental impact statement (EIS) to correct 

these deficiencies. The documents being released today address all of the deficiencies identified 

by the Court, as well as a number of needs identified by the 5 Year Review of the Forest Plan. 

The Tongass’ extensive collaboration with many new and existing partners has played a very 

important role in the development of this Amendment and will continue to be an integral part of 

the forest management in the future. The Forest worked with State and Federal agencies, Tribal 

Governments, SE Alaska Communities, organizations and individuals to develop this Amended 

Forest Plan. One of the most significant partnerships is with the State of Alaska, designated as a 

Cooperating Agency for this analysis. Governor Sarah Palin and Forest Service Chief Abigail R. 

Kimbell signed a Preamble to the ROD, which sets the vision for sustainability of the Tongass 

and for Southeast Alaska’s communities in a coordinated effort to improve and promote natural 

resource management. 

Approximately 84,500 comments were received on the Draft EIS. These comments were used 

to refine the analysis and shape the decision. A summary of comments and Forest Service 

responses can be found in Appendix H of the Final EIS. 

One important element of the Plan that many have been anticipating is the amount of timber the 

Forest can offer for timber sales over the life of this Plan. The Allowable Sales Quantity, or 

ASQ, in the Amendment remains unchanged from the 1997 Plan of approximately 267 million 

board feet a year over the next 10 years. The total suitable land base the Plan outlines for timber 

harvest is comparable to the 1997 Plan at about 773,000 acres. 

What is a significant change in the Amended Plan is how the Forest will plan and offer timber 

sales. The ROD introduces a new strategy, referred to as the Timber Sale Adaptive Management 

Strategy, which limits the lands available for timber harvest to that necessary to support 
demonstrated levels of demand. While the majority of higher value roadless areas are not 

available for timber harvest, this strategy will ensure those areas that are available are not 

impacted until timber demand rises. 

The new Timber Sale Adaptive Management Strategy will be implemented in three phases, 

based upon performance. Under Phase 1 timber harvests will be restricted to roaded and mostly 

lower value inventoried roadless areas (areas in close proximity to existing roads) until the level 

of timber harvest reaches 100 million board feet a year for two consecutive years. 

Phase 2 restricts harvest to Phase 1 lands and additional moderate value inventoried roadless 

areas (areas farther from existing roads with multiple-use value for recreation, fish and wildlife 

use) until the level of timber harvest reaches 150 million board feet a year for two consecutive 

years. Finally, Phase 3 of the Strategy applies, and includes the remaining suitable land base. A 

map of these phases is included on the CD and on the website at www.fs.fed.us/r10/tongass/. 

 

The ROD, Final EIS and Amended Forest Plan will be published in the Federal Register in early 

to mid February. The Amended Forest Plan can be implemented 30 days from that date. 

Publication in the Federal Register also begins a 90 day appeal period. See the ROD for more 

information. 

All of these documents as well as more information about the amendment process can be found 

at www.fs.fed.us/r10/tongass/. Please contact Lee Kramer, the Project Manager at 907-789-6246 

for more information. 

Sincerely, 

 

FORREST COLE 

Forest Supervisor 

 

 
Tongass Land and

Resource Management Plan

Final Environmental

Impact Statement

Plan Amendment

United States

Department of

Agriculture

Forest Service

R10-MB-603a

January 2008

Record of Decision



Tongass National Forest 

Land and Resource Management Plan 

Amendment 

2008 Environmental Impact Statement

Record of Decision 

United States Department of Agriculture 

Forest Service−Alaska Region

January 2008 

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USDA’s TARGET Center at (202) 720-2600 (voice and TDD). 

To file a complaint of discrimination, write U.S. Department of Agriculture, Director, Office of Civil Rights, Room 

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Federal Recycling Program

Printed on Recycled Paper

Record of Decision

iii

CONTENTS 

INTRODUCTION ...................................................................................................................1 

THE DECISION......................................................................................................................2 

Decision Components Required by NFMA...........................................................3 

Changes Adopted in this ROD to Alternative 6 ....................................................8 

Timber Sale Program Adaptive Management Strategy.........................................9 

ALTERNATIVES CONSIDERED .......................................................................................10 

Alternatives Considered in Detail, Including the No-Action Alternative ...........12 

Alternatives Considered but not Analyzed in Detail...........................................14 

The Environmentally Preferable Alternative.......................................................14 

RATIONALE FOR THE DECISION ...................................................................................15 

Summary..............................................................................................................15 

Protecting Fish and Wildlife Habitat and Biodiversity .......................................18 

Recreation and Tourism.......................................................................................28 

Market Demand ...................................................................................................29 

Need for an Integrated Industry...........................................................................35 

Minimizing Effects on Roadless Areas ...............................................................37 

Problems Identified by the Ninth Circuit Court of Appeals................................43 

Comparison of Alternatives.................................................................................47 

Other Considerations ...........................................................................................49 

National Policy Considerations ...........................................................................55 

MEANS TO AVOID ENVIRONMENTAL HARM.............................................................56 

Mitigation Measures Adopted .............................................................................56 

Mitigation Measures Not Adopted ......................................................................56 

Monitoring and Evaluation..................................................................................57 

FINDINGS RELATED TO OTHER REQUIREMENTS .....................................................57 

National Environmental Policy Act.....................................................................58 

National Forest Management Act........................................................................59 

Endangered Species Act ......................................................................................59 

Magnuson-Stevens Fishery Conservation and Management Act........................59 

Tongass Timber Reform Act ...............................................................................60 

Coastal Zone Management Act ...........................................................................60 

Alaska National Interest Lands Conservation Act ..............................................60 

Clean Water Act ..................................................................................................62 

Clean Air Act.......................................................................................................62 

Floodplains and Wetlands (Executive Orders 11988 and 11990) .......................62 

Environmental Justice (Executive Order 12898).................................................62 

Civil Rights..........................................................................................................63 

IMPLEMENTATION............................................................................................................63 

Plan Effective Date..............................................................................................63 

Effective Direction...............................................................................................63 
Record of Decision

iv

Continuing the Partnership with the State of Alaska...........................................63 

Timber Sale Program Adaptive Management Strategy.......................................64 

Timber Sale Economics.......................................................................................66 

Forest Plan Implementation Demonstration Area ...............................................67 

Transition to the Amended Forest Plan ...............................................................67 

ADMINISTRATIVE APPEAL RIGHTS..............................................................................71 

CONTACT PEOPLE.............................................................................................................72 

APPROVAL ..........................................................................................................................72 

LIST OF TABLES 

Table 1. Land Use Designations for the Amended Forest Plan 5 

Table 2. Statistics for 39 Tongass Forest Plan Alternatives Considered in Detail; 

1990 – 2003 11 

Table 3. Volume of Tongass National Forest Timber that Must be Cut to Supply 

Derived Demand Reported in Brackley et al. (Million Board Feet) 33 

Table 4. Projected Demand1 in 2022 Under each Brackley et al. Scenario 

Compared to Second-decade Average Annual ASQ for each Final EIS 

Alternative 44 

LIST OF FIGURES 

Figure 1. Timber Sale Program Adaptive Management Strategy 65 
Record of Decision 

v

ABBREVIATIONS 

ADOT&PF Alaska Department of Transportation and Public Facilities 

AFA Alaska Forest Association 

AFHA Anadromous Fish Habitat Assessment 

ANILCA Alaska National Interest Lands Conservation Act 

ASQ Allowable Sale Quantity 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

CZMA Coastal Zone Management Act 

EIS Environmental Impact Statement 

FWS Fish and Wildlife Service 

KIC Ketchikan Indian Community 

LUD Land Use Designation 

MDF Medium Density Fiberboard 

MMBF Million Board Feet 

MOU Memorandum of Understanding 

NEPA National Environmental Policy Act 

NFMA National Forest Management Act 

NFS National Forest System 

NIC Non-Interchangeable Component 

P.L. Public Law 

ROD Record of Decision 

ROS Recreation Opportunity Spectrum 

RPA Forest and Rangeland Renewable Resources Planning Act 

TTRA Tongass Timber Reform Act 

TUS Transportation and Utility System 

U.S.C. United States Code 

USDA United States Department of Agriculture 

VCU Value Comparison Unit 

Record of Decision 

1

Record of Decision 

Introduction 

This document is a public Record of Decision (ROD) that documents my decision to approve the 

2008 Amendment to the Tongass Land and Resource Management Plan (Forest Plan), and the 

rationale for making that decision. The amended Forest Plan is contained in the document titled 

Land and Resource Management Plan – Tongass National Forest, dated January 2008, and is 

based on Alternative 6 in the Tongass Land and Resource Management Plan Amendment Final 

Environmental Impact Statement (Final EIS), with four modifications as described in this document. 

The map of record for the amended Forest Plan is labeled “Tongass National Forest, Land Use 

Designations, January 2008.” 

Under the National Forest Management Act (NFMA), the Secretary of Agriculture is required to 

“develop, maintain, and, as appropriate, revise land and resource management plans [forest plans] 

for units of the National Forest System.” 16 U.S.C. § 1604(a). Forest plans are expected to be 

reviewed every 5 years, and revised every 15 years. 16 U.S.C. § 1604(f)(5)(A); 36 CFR § 219.10(g). 

Pursuant to 16 U.S.C. § 1604(g), the Secretary of Agriculture promulgated regulations at 36 CFR 

Part 2191

 establishing procedures for the development, amendment, and revision of forest plans. 

Because this amendment essentially completes the process of revising the Tongass Forest Plan that 

was initiated in 1987, the Forest Plan will not need to be revised again for 10 to 15 years, unless 

changed conditions require it sooner. 

Forest planning on the Tongass National Forest has long been a complex and contentious 

undertaking. This history is described in detail in Chapter 1 of the Final EIS, so I will offer only a 

brief summary of it here. In 1979, the Tongass National Forest was the first to complete a forest 

plan under NFMA. As required by NFMA’s implementing regulations, the Forest Service completed 

a 5-year review of the Forest Plan in 1984, which led to an amendment of the Forest Plan that was 

completed in 1986. The agency began work to revise the Forest Plan in 1987. The Tongass Timber 

Reform Act became law in November 1990, which resulted in a second amendment to the Plan in 

1991. The Revised Forest Plan was approved in 1997, and was appealed by several parties. The 

Under Secretary of Agriculture affirmed the 1997 decision, but also issued a new ROD that modified 

the 1997 Plan, mainly to prohibit timber harvest and road construction in 18 “areas of special 

interest.” As a result of subsequent litigation, the 1999 ROD was vacated, and the Forest Service 

was directed to prepare a Supplemental EIS to determine whether additional wilderness areas 

should be recommended. That Supplemental EIS was completed in 2003; based on that analysis, I 

recommended no additional wilderness. 

The validity of the 1997 Forest Plan was challenged, and that litigation eventually resulted in a 

decision by the U.S. Court of Appeals for the Ninth Circuit in Natural Resources Defense Council vs. 

U.S. Forest Service (421 F.3d 797) in August 2005. The Forest Service had erroneously nearly 

doubled the market demand for timber from the Tongass that was projected by Forest Service 

economists. The court found that this error influenced the selection of Alternative 11 in the 1997 

ROD. The court also found inadequacies in the 1997 EIS, including the following: 

• The EIS did not provide decision makers and the public with an accurate assessment of 

information relevant to evaluating the Tongass Plan; had the accurate market demand 

forecast and related potential employment and earnings information been used, an 

alternative may have been selected with less environmental impact and in less 

environmentally sensitive areas. 

 

1

 The Forest Service promulgated new planning regulations in 2000, and again in 2005. In accordance with the 

transition provisions of the 2005 regulations, the 2008 Tongass Forest Plan Amendment was prepared pursuant 

to the pre-2000 regulations. All citations in this ROD to regulations in Part 219 refer to the pre-2000 regulations. 
Record of Decision

2

• The Forest Service had not considered alternatives that set the Allowable Sale Quantity (the 

maximum amount of timber allowed to be cut) equal to the correct demand scenarios. 

• Each of the alternatives considered allocated some currently roadless areas to the Land Use 

Designations (LUDs) that allow development; the EIS omitted an alternative that allocated 

less undeveloped land to the development LUDs. 

• The EIS did not fully consider the cumulative effects of disproportionate high-volume logging 

on non-federal land because the EIS did not include: (1) a catalog of past projects; (2) a 

discussion of how those projects (and differences between the projects) have harmed the 

environment; (3) a discussion of the connection between individual non-federal high-volume 

harvests and the prior environmental harm from those harvests; and (4) an assessment of 

the potential impacts of reasonably foreseeable continued “highgrading” in the future. 

• A cumulative effects analysis in a programmatic EIS is necessary for the Forest Service and 

the public to make a rational evaluation of the proposed action balancing the competing 

goals of timber harvest, environmental preservation, and recreational use in the Tongass. 

The 2008 Tongass Forest Plan Amendment and the associated EIS have been prepared in 

response to the Ninth Circuit court’s decision. The Amendment also responds to the 5-Year Review 

of the Plan completed in early 2005, which recommended several updates to the Plan. 

Forest plans are programmatic in nature; they do not, by themselves, authorize activities such as 

timber harvest or road construction that affect the environment. Rather, when an individual project 

(such as a timber sale) is proposed, the Forest Service undertakes a site-specific analysis of its 

likely environmental effects and renders a formal decision regarding it. See Inland Empire Public 

Lands Council v. U.S. Forest Service, 88 F.3d 754 (9th Cir. 1996); Sierra Club v. Robertson, 28 F.3d 

753, 758 (8th Cir. 1994). Thus, forest plans do not have environmental effects. Ohio Forestry Ass’n 

v. Sierra Club, 523 U.S. 726, 729 (1998). However, the planning regulations governing the 2008 

Tongass Forest Plan Amendment require the preparation of Environmental Impact Statements for 

forest plans. 36 CFR § 219.10(b). 

My objectives for the 2008 Forest Plan Amendment and the associated EIS have consistently been 

to correct the deficiencies identified by the Ninth Circuit and bring the Plan up to date, while 

balancing the competing goals cited by the court. My overall intent has always been to ensure that 

the Tongass National Forest continues to be managed in a sustainable manner. NFMA requires 

forest plans to “provide for multiple use and sustained yield of the products and services” obtained 

from the National Forest System. 16 U.S.C. § 1604(e)(1). Sustained yield of products and services 

is defined as “the achievement and maintenance in perpetuity of a high-level annual or regular 

periodic output of the various renewable resources of the national forests without impairment of the 

productivity of the land.” 16 U.S.C. § 531(b). I also recognize the State of Alaska’s authority and 

responsibility to ensure sustainable management of fish and wildlife on all lands in Alaska. Multiple 

use management is a deceptively simple term that describes the enormously complicated task of 

striking a balance among the many competing uses to which land can be put, including outdoor 

recreation, range, timber, watershed, wildlife, fish, and wilderness. The additional goal of sustained 

yield requires the Forest Service to control consumptive uses of natural resources of the National 

Forest System to ensure a high level of valuable uses in the future. 

For reasons that will be explained throughout this ROD, I conclude the amended Forest Plan meets 

all of these very challenging requirements. 

The Decision 

The decision I am making today is to approve the amended Forest Plan, which is based on 

Alternative 6 as described in the Final EIS, with the four modifications that are described in this 

ROD. The components of this decision are listed below. These decision components are fully 

supported by the environmental analysis documented in the Final EIS, as required by law and 

regulation. The details of these decision components may be found in the Forest Plan chapters or 

appendices noted. 
Record of Decision 

3

I have made my decision after careful consideration of the public comments on the Draft EIS for the 

2008 Tongass Land and Resource Management Plan Amendment, which was prepared pursuant to 

the National Environmental Policy Act (NEPA). I have also reviewed the Final EIS and the amended 

Forest Plan. All site-specific projects will be subject to additional environmental analysis, which will 

tier to the Final EIS for the amended Forest Plan. 

The amendment I am approving modifies four of the six components of the Forest Plan that are 

required by law and regulations governing forest planning. In addition to the required components, I 

am also approving a Timber Sale Program Adaptive Management Strategy, which is an additional 

step in implementing adaptive management and correcting the deficiencies identified by the Ninth 

Circuit court. As part of this decision, I also direct the Forest Supervisor to strengthen the 

cooperative efforts with the State of Alaska on implementation and monitoring, including efforts to 

improve timber sale economics, by developing cost-sharing and other agreements with the State of 

Alaska. This direction is described in detail in the section of this ROD dealing with implementation. 

Decision Components Required by NFMA 

Goals and Objectives 

Multiple-use goals and objectives for the Tongass are described in Chapter 2 of the Plan. These 

goals and objectives guide the overall management for the Forest, establish the desired conditions 

for implementing the Plan, and satisfy the requirements of 36 CFR 219.11(b). Achievement of these 

goals and objectives will ensure the sustainability of the Tongass National Forest, and the 

ecological, social, and economic values derived from the Forest. These goals and objectives 

describe the mosaic of land and resource conditions desired for the forest in the future. Full 

attainment of these goals and objectives can be influenced by a number of factors, such as 

congressional budget allocations, changed circumstances or new information relative to land 

management. 

The amended Plan includes several changes to the goals and objectives adopted in 1997. A new 

goal has been added to maintain viable plant communities and populations and a mixture of habitats 

capable of supporting the full range of naturally occurring flora. It also includes a new goal to consult 

with Tribes to protect and maintain sacred sites across the Forest. New objectives are included for 

each of these goals. A new objective was added to reduce the introduction, spread, and impact of 

invasive species. Two new objectives related to timber management were also added. One 

addresses “economic timber” in the timber sale program; the other deals with flexibility and stability 

in the sale program. In addition to the new goals and objectives, several others were modified. 

More emphasis was given to ecosystem services values. The goal for karst was re-written to focus 

on maintaining natural processes and productivity while allowing other land uses as appropriate. 

Several goals and objectives were updated to clarify management intent. 

Management Prescriptions 

Chapters 3 and 4 of the amended Plan set forth the management prescriptions and forest-wide 

standards and guidelines that describe how land managers will operate on the Tongass. These 

chapters provide the expectations and limits on how and where activities will be conducted. The 

management prescriptions in Chapter 3 include 16 Land Use Designations, each with its own goals 

and objectives, and specific standards and guidelines designed to ensure achievement of them. 

Management prescriptions for the Wilderness and National Monument Wilderness LUDs have been 

combined to reduce duplication, while retaining separate goals and objectives for National 

Monument Wilderness. Several other management prescriptions have been changed slightly to 

update and clarify them. Many of the forest-wide standards and guidelines (Chapter 4) were also 

edited to update their terminology, clarify them, and improve the consistency of application. New 

standards and guidelines were developed to address invasive species and plants. Another new 

standard was added that requires old-growth forest structure (i.e., live trees, dead trees, and clumps 

of trees) to be retained after timber harvest in areas that have had considerable past harvest, as a 

replacement for standards in the 1997 Forest Plan related to goshawk foraging and marten habitat. 
Record of Decision

4

The 19 LUDs are commonly organized into four groups with similar management direction and 

environmental effects. The first two groups are commonly referred to as “non-development LUDs, 

and the latter two groups as “development LUDs.” The main changes from the 1997 Forest Plan in 

the allocation of land on the Tongass to the various LUDs include: 

1. Updated acreage figures for all LUDs as a result of refinements to the geographic information 

system and better inventory information regarding scenery. 

2. The addition of approximately 90,000 acres2

 to the network of small Old-Growth Habitat 

reserves, as discussed in the section of this ROD dealing with protecting wildlife habitat and 

biodiversity. Some of these additional acres were previously allocated to development LUDs, 

others to non-development LUDs. 

3. Expansion of Geologic Special Interest Areas to protect nearly 47,000 acres of newly identified 

karst lands that are most vulnerable to disturbance from development. 

4. Reallocation of about 97,000 acres on the Juneau Icefield from Remote Recreation to Semiremote Recreation, which would allow minor enclaves to be established above the snow 

accumulation zone. 

5. Reallocation of about 43,000 acres on Chichagof Island at the head of Tenakee Inlet from 

Timber Production, Modified Landscape, and Old-Growth Habitat to Semi-remote Recreation 

to address the high sensitivity of this area to development and timber economics. 

6. Reallocation of about 18,000 acres on Kupreanof Island east of Kake from Timber Production 

to Semi-remote Recreation to address public concerns and timber economics. 

7. Reallocation of development LUDs near Bostwick Inlet on Gravina Island to Semi-remote 

Recreation in response to public concerns, as described in greater detail in the section of this 

ROD dealing with minimizing effects on roadless areas. These are changes that I am making 

through this decision to Alternative 6 as displayed in the Final EIS. 

8. Allocations among the development LUDs were adjusted to reflect improved inventory data 

regarding scenery. These are changes that I am making through this decision to Alternative 6 

as displayed in the Final EIS. 

9. An expansion of the Minerals LUD overlay by approximately 80,000 acres (from 170,514 to 

249,570 acres) to include portions of the Hyder area and areas on Prince of Wales Island 

associated with the Niblack, Ruby Tuesday, and Khayyam minerals prospects. 

The amended Forest Plan’s allocation of all National Forest System lands on the Tongass to the 

various LUDs is shown in Table 1 below. 

Activities consistent with management prescriptions are guided by the application of standards and 

guidelines, which govern resource management activities and are key to successful implementation 

of the Forest Plan. Some of these standards and guidelines apply to all lands, others to specific 

management prescriptions. These standards and guidelines take precedence over annual targets or 

projected outputs; no project or program will be funded for which the applicable standards and 

guidelines cannot be carried out. 

The primary LUDs that allow timber management, Timber Production, Modified Landscape, and 

Scenic Viewshed, total approximately 3.4 million acres, or 20 percent of the Tongass National 

Forest. Three of these LUDs, Timber Production, Modified Landscape, and Scenic Viewshed, 

account for all of the scheduled timber harvest under the Forest Plan. Scenic and Recreational 

River LUDs also allow timber management if the adjacent LUD allows timber harvest and the 

scenery guidelines are met; however, very little harvest has occurred in these LUDs over the last 10 

years. Accordingly, I expect little if any timber harvest in these LUDs over the next 10 to 15 years. 

 

2

 This includes approximately 50,000 acres added by previous amendments to the 1997 Forest Plan. 
Record of Decision 

5

Table 1 

Land Use Designations for the Amended Forest Plan 

Land Use Designation 

Total Acres Allocated 

to Each LUD1

Total Acres 

Allocated to Each 

LUD without 

Overlays2

Wilderness LUD Group 

 Wilderness 2,637,292 2,637,292 

 Wilderness National Monument 3,111,792 3,111,792 

 Nonwilderness National Monument 166,942 166,942 

 Total for Wilderness LUD Group 5,916,026 

Natural Setting LUD Group 

 LUD II 721,002 721,002 

 Remote Recreation 2,033,665 2,033,665 

 Semi-Remote Recreation3 3,023,152 3,023,152 

 Old-Growth Habitat 1,221,173 1,221,173 

 Enacted Municipal Watershed 45,226 45,226 

 Research Natural Area 58,788 26,093 

 Special Interest Area 342,137 221,176 

 Wild River 192,463 62,799 

 Scenic River 27,133 27,133 

 Recreational River 27,387 27,387 

 Total for Natural Setting LUD Group 7,408,806 

Development LUD Group 

 Experimental Forest4 31,405 31,405 

 Scenic Viewshed 307,402 307,402 

 Modified Landscape 728,679 728,679 

 Timber Production 2,381,486 2,381,486 

 Total for Development LUD Group 3,448,972 

Overlay LUD Group5 

 Minerals 249,570 0

 Transportation and Utility Systems -- 0 

TOTAL NATIONAL FOREST 

SYSTEM LAND 16,773,804 1 This column includes the total acreage allocated to each LUD. However, in some cases, more than one LUD can 

be applied to the same area (such as a Special Interest Area within Wilderness); therefore, totaling the acres of 

this column will exceed the total National Forest acreage. 2

 This column counts each acre of the Tongass only once. It includes the total areas allocated to each LUD, 

except for five LUDs that sometimes overlay other LUDs. The Research Natural Area, Special Interest Area, and 

Wild River LUDs sometimes overlay Wilderness, Wilderness National Monument, or LUD II; when this occurs the 

acreage is included under these other LUDs (so as not to double count). Also, the Minerals and Transportation 

and Utility System LUDs always function as overlays and do not have acreage in this column. 3

 The acreage figure for this LUD includes 6,544 acres currently allocated to Experimental Forest, but proposed to 

be converted to Semi-Remote Recreation. 4 The acreage figure for this LUD includes 20,853 acres currently allocated to Scenic Viewshed, but proposed to 

be converted to Experimental Forest. 5 The two LUDs in this group are always overlay LUDs. Areas allocated to these LUDs are managed according to 

the underlying LUD until such time that mineral or transportation/utility development is approved, if at all. The 

Minerals overlay LUD has an area (249,570 acres) associated with it; no acreages are calculated for the 

Transportation and Utility System LUD because it is defined as a series of corridors of undefined width and 

imprecise locations. 
Record of Decision

6

Land Suitable for Timber Production 

The amended Forest Plan also updates the classification of lands suitable for timber production and 

determines where on those lands timber harvesting could be allowed, in accordance with NFMA 

regulations, 36 CFR 219.14(a), and Section 102 of the Tongass Timber Reform Act (TTRA). 

Appendix A of the Forest Plan details the criteria and process used to determine the forest lands 

suitable for timber production. These are the lands capable of producing commercial volumes of 

timber on a sustained-yield basis, and are not in areas legislatively withdrawn from timber harvest. 

They are the only lands where regularly scheduled timber harvest may occur. 

This process uses a computer model that takes into consideration a number of characteristics of 

land across the entire Tongass National Forest. Changes were made to reflect updated geographic 

information system data; the results of a new logging systems and transportation analysis; and a 

new, lower estimate of the Model Implementation Reduction Factor.3

 As a result of these updates, 

the total estimated suitable land area decreased from 781,000 acres under the 1997 Forest Plan (as 

amended) to 773,000 under the 2008 Amendment. In addition, new modeling was conducted to 

identify the maximum acreage of lands from the suitable land base that would need to be scheduled 

for harvest over the next 100 years or so, in order to produce timber each decade at the maximum 

level permitted under the Allowable Sale Quantity. As a result of these updates, the total amount of 

scheduled suitable land decreased from 687,000 acres under the 1997 Forest Plan (as amended) to 

663,000 acres under the 2008 Amendment. 

Commercial timber sales can occur on lands that are not identified as suitable for timber production, 

but only if needed to accomplish other management objectives. Examples include commercial 

thinning of dense young-growth forest stands to improve wildlife habitat, and salvage sales of trees 

damaged or killed by insects or disease, or blown down by wind storms. Such sales are infrequent 

on the Tongass, are not part of the scheduled timber program, and thus do not count toward the 

Allowable Sale Quantity. 

Allowable Sale Quantity 

The Allowable Sale Quantity (ASQ) is the maximum amount of timber that can be sold in the first 

decade following this decision. It has not been changed; the ASQ for timber for the amended Forest 

Plan is established at 2.67 billion board feet per decade, which is equivalent to an annual average of 

267 million board feet (MMBF). This is an upper decadal limit on the amount of timber that may be 

offered for sale from suitable timberland on the Tongass National Forest as part of the regularly 

scheduled timber sale program. As mentioned above, the ASQ is unchanged from that established 

for the 1997 Forest Plan. However, the timber program will be implemented in three phases under 

the Timber Sale Program Adaptive Management Strategy, as explained in detail later in this section 

and in other sections of this ROD. 

Annual offering levels depend on several factors. For the Tongass National Forest to offer timber 

sales at levels near the maximum allowed under the amended Plan, Congress would need to 

consistently appropriate sufficient funding, the Forest Service would need to increase the number of 

timber sales prepared and offered, and the timber industry would need to take advantage of 

additional marketing opportunities, make new capital investments, purchase sales offered, and 

harvest timber at rates higher than current levels. 

As was true under the 1997 Plan, the ASQ consists of two separate Non-Interchangeable 

Components (NICs) called NIC I, which is 2.38 billion board feet of timber per decade, and NIC II, 

which is 0.29 billion board feet per decade. The NIC I component includes land that can be 

harvested with normal logging systems and is typically more economic to harvest. The NIC II 

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

 

3

 The Model Implementation Reduction Factor reduces the amount of land identified by the model as suitable for 

timber production to account for unforeseen factors that arise during implementation of the Plan. The Factor 

was reduced from approximately 32 percent in the 1997 Forest Plan to approximately 23 percent in the 

amended Forest Plan, as a result of updates to the geographic information system and other data. 
Record of Decision 

7

requirements. These NIC components are estimates that do not reflect all of the factors that may 

influence actual sale levels. They are designed to prevent the disproportionate harvest of the most 

economical portions of the Forest over the long term. Thus, the separate limits on each component 

are binding on a decadal basis. The components are non-interchangeable because lower sale 

levels in one component may not be compensated for by higher sale levels in the other. About 89 

percent of the ASQ comes from NIC I land and about 11 percent comes from NIC II. 

Monitoring and Evaluation 

The monitoring plan, required by NFMA regulations, 36 CFR section 219.12 (k), is contained in 

Chapter 6 of the amended Forest Plan. It represents an essential quality control mechanism and 

facilitates learning from Plan implementation. The monitoring plan provides for three types of 

monitoring: (1) implementation monitoring to determine if the standards and guidelines are being 

followed; (2) effectiveness monitoring to determine if standards and guidelines are achieving the 

desired results; and (3) validation monitoring to determine if the underlying assumptions are valid. 

Monitoring and evaluation play a central role in adaptive management. Some monitoring and 

evaluation activities are conducted to ensure appropriate implementation of standards and 

guidelines. Other activities are conducted to deal with uncertainties regarding effects of land 

management activities. This includes gathering additional information to reduce these uncertainties 

by determining whether the effects of various standards and guidelines are consistent with 

predictions, and also to validate key assumptions underlying various standards and guidelines and 

projected outcomes of management. Information gained through monitoring and evaluation will be 

used to adjust management direction in the future where warranted. Accordingly, monitoring and 

evaluation will be a high priority under the amended Forest Plan. The monitoring plan contained in 

the amended Forest Plan specifies the questions to be answered through monitoring. Several 

modifications were made to refine the critical monitoring questions, including more emphasis relative 

to emerging climate change issues. Information on sampling methods and other detailed information 

about how the questions might be answered has been removed, because these provisions tend to 

be frequently updated to respond to new science and information. Details of the monitoring program 

such as data gathering protocols will continue to be developed in consultation with the State of 

Alaska and other interested Federal agencies. 

The Forest Service will conduct an evaluation of the Forest Plan in 5 years, as provided by the 

NFMA planning regulations (36 CFR 219.10(g)). That review will include an evaluation of the Plan’s 

old-growth conservation strategy, which is designed to conserve biodiversity and prevent the need to 

list species under the Endangered Species Act. The evaluation will be conducted in collaboration 

with appropriate Federal and State agencies. Any needed changes in the Plan’s direction will be 

incorporated through the amendment or revision process, just as this amendment was prepared, in 

part, in response to information obtained under the monitoring and evaluation program established 

under the 1997 Forest Plan. 

Recommendations on Special Management Areas

As described in Chapter 1 of the Final EIS, the purpose and need of the 2008 Forest Plan 

Amendment is to respond to the 2005 decision by the U.S. Court of Appeals for the Ninth Circuit, 

and to update the Plan in response to the 5-year evaluation completed in 2005. Accordingly, 

changes to wilderness areas, wild and scenic rivers, and research natural areas are outside the 

scope of the Amendment. During this amendment process, however, I reviewed the decision I made 

in 2003 not to recommend that any new wilderness areas be designated, or any changes to existing 

wilderness areas be made. I made that decision because I found no compelling need for additional 

wilderness on the Tongass at that time. I believe the 2003 decision should remain in effect. 

Consequently, this decision does not include any additional wilderness recommendations. Potential 

wilderness recommendations can be considered again as part of the next revision. 
Record of Decision

8

Similarly, I am making no changes to the recommendations made by the Regional Forester in 1997 

that segments of over 30 rivers be included in the National Wild and Scenic Rivers System.4

 These 

recommendations require action by the Chief of the Forest Service and the Secretary of Agriculture 

before being considered by the President for transmittal to Congress. No changes are being made 

to the network of research natural areas currently designated on the Tongass. 

Although the scope of this Amendment did not include proposals to add new wilderness areas, wild 

and scenic rivers, or research natural areas, or to expand existing units of these systems, there is 

one change to a special management area that I am recommending. In response to a request from 

the Pacific Northwest Research Station, I join the Director of the Station in recommending to the 

Chief of the Forest Service that the designation of Young Bay on Admiralty Island as an 

experimental forest be terminated and that a new experimental forest in the Cowee Creek and 

Davies Creek watersheds on the mainland north of Juneau be established. Admiralty Island is not 

accessible by road, which is needed to fully achieve the objectives of an experimental forest. The 

proposed new experimental forest is accessible from the Juneau road system. Unless and until the 

Chief approves these recommendations, Young Bay will be managed as an experimental forest, and 

the Cowee Creek-Davies Creek area will be managed under the Scenic Viewshed and Old-Growth 

Habitat LUDs. Upon approval by the Chief and execution of any necessary public land orders, 

Young Bay will be managed under the Semi-Remote Recreation LUD, which includes the 

termination of the existing mineral withdrawal, and the Cowee Creek-Davies Creek area will be 

managed as an experimental forest. While only the Chief can make the decision on these 

recommendations, the potential environmental effects of that decision—other than issues related to 

mineral withdrawals--are described in the Final EIS for this Forest Plan Amendment. Upon approval 

by the Chief, we would make a technical correction to the Plan to reflect that approval.5

Changes Adopted in this ROD to Alternative 6 

As mentioned briefly above, I have decided to make four changes to Alternative 6 as displayed in the 

Final EIS. The following changes have been incorporated into the amended Forest Plan: 

• Development LUDs in the vicinity of Bostwick Inlet on Gravina Island have been changed to 

Semi-remote Recreation. 

• Allocations of development LUDs have been changed (e.g., from Scenic Viewshed to 

Modified Landscape) to reflect updated scenery inventory information. 

• The standard and guideline included in Alternative 6 that would allow timber harvest within 

goshawk nest buffers if nests are unoccupied for two years has been changed. The 

amended Forest Plan will continue to protect all known nests; only buffers around “probable 

nests” may be subject to timber harvest, and only if two years of monitoring indicates no 

evidence that goshawks are present or actually nesting. This change is explained further in 

the section of this ROD dealing with protecting fish and wildlife habitat and biodiversity. 

• The standard and guideline in Alternative 6 that requires project-level analysis of ways to 

reduce excessive human-caused wolf mortality has been changed to require such analyses 

to evaluate the effects of human access to the project area via all roads, not just roads open 

to vehicular traffic as included in Alternative 6. This change is explained further in the 

section of this ROD dealing with protecting fish and wildlife habitat and biodiversity. 

 

4

 The 1997 ROD recommended that portions of 32 rivers, lakes, and streams be added to the National Wild and 

Scenic Rivers System. In 1998, the Acting Forest Supervisor determined that the 1997 recommendation for 

Niblack Lakes and Streams was based on incorrect information related to the area’s productivity of anadromous 

fish, and adopted a non-significant amendment rescinding the recommendation that the Niblack Lakes and 

Streams system be designated as a component of the National Wild and Scenic Rivers System. I conclude the 

remaining 31 recommendations should remain in effect. 

5

 If the Forest Service chooses to pursue withdrawing the new Experimental Forest from the mining and mineral 

leasing laws, additional NEPA analysis and public involvement will occur before making that decision.
Record of Decision 

9

Timber Sale Program Adaptive Management Strategy 

I am keenly aware that my decision to approve an amendment that retains the same ASQ as in the 

1997 Forest Plan will be controversial. Some people requested a higher ASQ be adopted, to ensure 

an opportunity for the timber sector to expand into a fully integrated and competitive industry.6

 

Others asked for a lower level, to prevent unnecessary development of roadless areas perceived by 

some as most environmentally sensitive. Multiple use management requires that such competing 

demands be balanced in a sustainable manner. I believe my decision accomplishes this difficult 

task. A detailed explanation for my decision, including why I believe it responds to these concerns 

and how it remedies the inadequacies identified by the court, is provided below in the “Rationale for 

the Decision” section of this ROD. To further balance the competing demands and respond to 

requests for additional protection of roadless areas, I am also approving the Timber Sale Program 

Adaptive Management Strategy. As mentioned above, the decision to approve this Strategy is in 

addition to the decision components that are required by NFMA and its implementing regulations. 

Under the Timber Sale Program Adaptive Management Strategy, actual operation of the timber sale 

program will be implemented in three phases, as determined by actual timber harvest levels. In 

Phase 1, the timber program will be restricted to a portion of the suitable land base that excludes 

moderate and higher value roadless areas7

. The map of the Strategy is included on the CD of the 

Final EIS, and is also available on the internet at www.fs.fed.us/r10/tongass/. This Phase 1 portion 

includes approximately 537,000 suitable acres, or 69 percent of the total suitable land base. Should 

the actual level of timber harvest reach 100 MMBF for two consecutive fiscal years, the Tongass 

could then plan for timber projects in the Phase 2 portion of the approved suitable land base, 

resulting in a program that operates on 680,000 acres of suitable lands, including some moderate 

value roadless areas. Should timber harvest reach 150 MMBF for two consecutive fiscal years, the 

Tongass could then plan for timber projects in Phase 3, which includes the entire suitable land base. 

A more detailed explanation of the Timber Sale Program Adaptive Management Strategy and my 

reasons for adopting it are provided in the Implementation section of this ROD. 

As mentioned previously, the Timber Sale Program Adaptive Management Strategy is an additional 

step being taken in response to concerns that an overestimate of timber demand will lead to timber 

harvest in areas perceived by many as more environmentally sensitive--such as higher value 

roadless areas--that would not have to be developed if the Plan were based on a lower estimate of 

timber demand. It is very difficult to estimate long-term timber demand with a high degree of 

precision and confidence when local, regional, and global market conditions are constantly 

changing. Therefore, the Timber Sale Program Adaptive Management Strategy—in conjunction with 

the amended Forest Plan--addresses the Ninth Circuit court’s finding that, if the 1997 Tongass 

Forest Plan Revision EIS had provided decision makers and the public with the correct market 

demand forecast, an alternative may have been selected with less environmental impact and in less 

environmentally sensitive areas. 

The Forest Service has a statutory obligation to seek to meet market demand for timber from the 

Tongass National Forest, both the annual demand and demand for each planning cycle of 10-15 

years, subject to other applicable law and to the extent consistent with providing for the multiple use 

and sustained yield of all renewable forest resources.8

 I am confident that the amended Forest Plan 

continues to meet these other resource goals, including recreation and the maintenance of biological 

diversity, as described in the Rationale for the Decision section of this ROD. I am also concerned 

that the current timber industry in Southeast Alaska is not sustainable at the current harvest levels, 

or with uncertain future timber harvest levels. Accordingly, it is prudent to keep options open so that 

 

6

 For the purposes of this ROD, an integrated timber industry is one with local milling and processing facilities for 

each kind of log that comes from harvest operations on the Tongass National Forest. Competition is created 

between processors for similar supply needs. 

7

 The term “roadless area” is a generic term that is sometimes used to refer to all areas without roads. For the 

purpose of this ROD, it is used to refer to inventoried roadless areas, as discussed in detail in the section of this 

ROD titled “Rationale for the Decision.” 

8

 See the market demand portion of the Rationale for the Decision section for a detailed discussion of this issue. 
Record of Decision

10

the timber industry in Southeast Alaska can evolve in response to long-term market developments, 

including a significant expansion if demand for timber rises substantially in the future. As long as 

other competing demands are being met, it is important to avoid constraining the lands available for 

timber harvest so much that it is impossible for the timber industry to expand in response to future 

market developments. At the same time, however, it is not necessary to schedule timber harvest in 

higher value roadless areas, unless timber harvest levels rise sufficiently to warrant such an 

expansion into these sensitive areas. 

Adaptive management principles suggest we respond to uncertainty by adopting a flexible 

management system that balances the short- and long-term social, economic, and environmental 

risks and adjusts promptly if conditions change. The Timber Sale Program Adaptive Management 

Strategy, along with all the other conservation measures in the amended Forest Plan, is just such a 

system. Together, the amended Forest Plan and Adaptive Management Strategy do not guarantee 

an expansion of the timber industry; nor do they prohibit development in all roadless areas. Rather, 

they keep options open for expansion of the industry (within the ASQ approved in this Plan), while 

protecting areas that are perceived as more environmentally sensitive as much as possible for as 

long as possible. My confidence in this Strategy is further strengthened by the expected increase in 

young-growth9

 management over the next few planning cycles; and the increasing public interest in 

this conversion, which will ultimately reduce the need for old-growth timber resources and the 

associated need for development in roadless areas. 

This is discussed in greater detail in the section of this ROD describing the rationale for the decision. 

Alternatives Considered 

Numerous EISs have been published as part of the development of the 1997 Forest Plan; together 

these EISs have considered dozens of alternatives. A Draft EIS was published in 1990, a 

Supplement to the Draft EIS in 1991, a Revised Supplement to the Draft EIS in 1996, a Final EIS in 

1997, a Draft Supplemental EIS (addressing only whether additional wilderness should be proposed) 

in 2002, and a Final Supplemental EIS regarding additional wilderness in 2003. As displayed in 

Table 2 below, these EISs considered in detail 39 different alternatives, many of which appeared in 

more than one EIS. Further information on the evolution of the alternatives considered is provided 

below in the discussion of alternatives not analyzed in detail. In addition, Chapter 2 of the Final EIS 

for this Amendment provides a detailed description of the evolution of the alternatives considered. 

 

9

 The term “young growth” refers to areas where trees have been removed by timber harvest, fire, insects, 

disease, or windstorms, and then grown back.
Record of Decision 

11

Table 2 

Statistics for 39 Tongass Forest Plan Alternatives Considered in Detail; 1990 – 2003 

Alternative 

No. and 

Source 

ASQ 1

(MMBF 

annual) 

Suitable 

lands (Acres 

X 1,000) 

Non-Development LUDs 

(Acres X 1,000) 

Development LUDs

(Acres X 1,000) 

 1 1997 0 0 16,700 200 

 1 1996 0 74 16,700 200 

 6 2003 92 344 15,700 1,200 

 8 2003 96 351 15,700 1,200 

 5 1997 122 786 12,100 4,800 

 4 1997 130 845 11,700 5,200 

 5 1996 139 1,400 12,100 4,800 

 4 1996 145 1,507 11,700 5,200 

 7 2003 174 521 14,300 2,600 

 5 2003 209 589 13,800 3,100 

 A 1990 217 536 13,600 3,300 

 3 2003 236 620 13,500 3,400 

 3 1997 256 795 12,700 4,200 

 1 2003 259 664 13,200 3,700 

 2 2003 259 664 13,200 3,700 

 4 2003 259 664 13,200 3,700 

11 1997 267 676 13,200 3,700 

 3 1996 278 1,188 12,600 4,300 

10 1997 300 924 12,700 4,200 

 6 1997 309 1,024 12,100 4,800 

 E 1990 336 717 11,600 5,300 

 A 1991 355 1,173 13,700 3,200 

 6 1996 362 1,400 12,100 4,800 

 8 1996 364 1,389 10,500 6,400 

 B 1991 413 1,360 13,000 3,900 

 B 1990 425 1,101 12,900 4,000 

 2 1997 463 1,180 11,700 5,200 

 F 1990 467 1,111 11,000 5,900 

 G 1990 468 1,112 11,000 5,900 

 2 1996 489 1,526 11,700 5,200 

 P 1991 502 1,649 11,700 5,200 

 9 1996 513 1,869 10,800 6,100 

 C 1990 540 1,200 10,500 6,400 

 C 1991 541 1,732 11,200 5,700 

 9 1997 549 1,390 10,800 6,100 

 D 1991 568 1,818 11,400 5,500 

 7 1997 640 1,575 9,100 7,800 

 D 1990 660 1,575 9,100 7,800 

 7 1996 689 2,044 9,100 7,800 

Notes: 

Sources: 1990 Draft EIS, 1991 Supplement to the Draft EIS, 1996 Revised Supplement to the Draft EIS, 1997 Final EIS, 

and 2003 Supplemental EIS) 

1

 All ASQ figures in this table are shown as total volume, including net sawlog plus utility. The 1990 Draft EIS and the 

1991 Supplement to the Draft EIS display ASQ figures as net sawlog only. Therefore, figures in this table for alternatives 

displayed in those documents do not match the figures originally published. 

Development of Alternatives Included in the Draft EIS 

As noted in the Final EIS, one of the fundamental objectives that guided the development of 

alternatives for the Draft EIS on the 2008 Forest Plan Amendment was to exclude roadless areas 

from the development LUDs (the Land Use Designations that allow timber harvest and road 

construction) as much as possible in each alternative. Because the Tongass has so little developed 
Record of Decision

12

land, this is possible only at very low levels of timber harvest. Therefore, planners assessed each 

inventoried roadless area using the Wilderness Attribute Rating System, the only nationally 

established methodology for evaluating the quality of roadless areas, as well as their fish and wildlife 

values, recreation and subsistence values, and other multiple use values. They also gave extra 

consideration to 18 areas of special interest identified by the Under Secretary of Agriculture in the 

ROD he issued in 1999, and to 23 areas that would have been designated as wilderness under a bill 

passed by the House of Representatives in 1989. The development of alternatives was guided by 

these considerations and, at each stage, as an alternative with a higher level of timber harvest was 

being developed, the minimum amount of roadless acres were added to the development LUDs, 

starting with lower value roadless areas. In this way, at each level of timber harvest associated with 

each of the alternatives, development is allowed in roadless areas only to the extent necessary to 

achieve the multiple use objectives of the alternative, including timber production; each alternative 

excludes the higher value roadless areas from the development LUDs as much as possible. 

Alternatives were modified in response to public comments received on the Draft EIS, as explained 

in the section of this document dealing with minimizing effects on roadless areas. 

In deciding which of the previously evaluated alternatives to analyze in this EIS, consideration was 

also given to alternatives that had been reviewed by the wildlife risk assessment panels that were 

formed during the development of the 1997 Forest Plan. This objective was accomplished for four of 

the seven alternatives. Given that the risk assessment panels showed a high correlation between 

development acres and the risk they assigned to an alternative, coupled with the fact that the 

harvest levels of all alternatives considered in detail in the 2008 Final EIS were bracketed by 

alternatives evaluated by the risk assessment panels, viability risk levels could be readily assigned 

to all alternatives. See Appendix D of the Final EIS for details on the application of the risk 

assessment panels to the alternatives considered in the 2008 Final EIS. 

Alternatives Considered in Detail, Including the No-Action 

Alternative 

Alternative 1 

Compared to the 1997 Forest Plan, Alternative 1 would give much greater emphasis to maintaining 

roadless areas, associated fish and wildlife values, and recreation, tourism, and subsistence 

opportunities in undeveloped areas. In response to public comments on the Draft EIS, this 

alternative was modified to preclude timber harvest in all roadless areas. Development LUDs on 

Kuiu Island, Baranof Island, much of Chichagof Island, the Yakutat area, and essentially all of the 

mainland also were changed to non-development LUDs in response to comments on the Draft EIS. 

Consequently, no scheduled timber harvest or road construction would be allowed on these areas 

under Alternative 1. The standards and guidelines of the 1997 Forest Plan dealing with foraging 

habitat for the northern goshawk and with high value habitat for the American marten would be 

replaced with a new legacy standard and guideline. A total of 839,000 acres of the Tongass would 

be in development LUDs, 15.9 million acres would be in non-development LUDs, and 144,000 acres, 

including 86,000 acres of old growth, would be in the suitable land base. This alternative would 

have an average annual ASQ of 49 MMBF. 

Alternative 2 

Compared to the 1997 Forest Plan, Alternative 2 would give additional emphasis to maintaining 

roadless areas, associated fish and wildlife values, and recreation, tourism, and subsistence 

opportunities in undeveloped areas, but not as much as Alternative 1. Timber harvest would be 

allowed in areas where roads have already been constructed, and in roadless areas with lower 

wilderness attribute ratings (primarily those adjacent to developed areas). The vast majority of 

current roadless areas would remain in a natural condition. The goshawk foraging habitat and high 

value marten habitat standards and guidelines of the 1997 Forest Plan would be replaced with a new 

legacy standard and guideline. A total of 1.9 million acres of the Tongass would be in development 
Record of Decision 

13

LUDs, 14.8 million acres would be in non-development LUDs, and 394,000 acres, including 215,000 

acres of old growth, would be in the suitable land base. This alternative would have an average 

annual ASQ of 151 MMBF, and closely matches the recommendations provided by The Nature 

Conservancy for the protection of intact watersheds. 

Alternative 3 

Compared to the 1997 Forest Plan, Alternative 3 would give some additional emphasis to 

maintaining roadless areas, associated fish and wildlife values, and recreation, tourism, and 

subsistence opportunities in undeveloped areas. Timber harvest would be allowed in areas where 

roads have already been constructed, and in many roadless areas within the suitable land base, 

which excludes higher value roadless areas identified in previous planning or congressional 

wilderness proposals. The vast majority of current roadless areas Forest wide would remain in a 

natural condition. The goshawk foraging habitat and high value marten habitat standards and 

guidelines of the 1997 Forest Plan would be replaced with a new legacy standard and guideline. A 

total of 2.8 million acres of the Tongass would be in development LUDs, 14 million acres would be in 

non-development LUDs, and 514,000 acres, including 313,000 acres of old growth, would be in the 

suitable land base. This alternative would have an average annual ASQ of 204 MMBF. 

Alternative 4 

Compared to the 1997 Forest Plan, Alternative 4 would give greater emphasis to timber production 

and associated economic stability of Southeast Alaska communities. Timber harvest would be 

allowed in a more extensive area than under the 1997 Forest Plan. While the majority of current 

roadless areas would remain in a natural condition, roadless areas outside of wilderness that contain 

substantial productive old growth would be subject to timber harvest and road construction. 

Alternative 4 would use a conservation strategy with a smaller number of reserves than the 1997 

Forest Plan strategy; the old-growth reserve system would be applied within four biogeographic 

provinces (North Central Prince of Wales Island, Kupreanof/Mitkof Islands, Dall Island, and 

Northeast Chichagof Island) plus several individual reserves outside of these provinces. In addition, 

a minimum of 33 percent of productive forest land would be retained in an old-growth condition in 

each Value Comparison Unit.10 The goshawk foraging habitat, high value marten habitat standard 

and guideline and the proposed legacy standard and guideline would not be included in the Forest 

Plan under Alternative 4. The goshawk nesting standard and guideline would also not be included. 

A total of 4.7 million acres of the Tongass would be in development LUDs, 12.0 million acres would 

be in non-development LUDs, and 892,000 acres, including 656,000 acres of old growth, would be in 

the suitable land base. This alternative would have an average annual ASQ of 312 MMBF in the first 

decade (and 360 MMBF in subsequent decades). 

Alternative 5 

This is the No Action alternative. It represents a continuation of the 1997 Forest Plan, as previously 

amended, and would result in a mix of National Forest uses and activities. Timber harvest would be 

allowed in an area more extensive than under Alternative 3, but less extensive than under 

Alternative 4. The vast majority of current roadless areas Forest wide would remain in a natural 

condition. A total of 3.6 million acres of the Tongass would be in development LUDs, 13.2 million 

acres would be in non-development LUDs, and 687,00011 acres, including 463,000 acres of old 

growth, would be in the suitable land base. This alternative would have an average annual ASQ of 

267 MMBF. 

 

10 Value Comparison Units are approximately 950 distinct geographic areas delineated on the Tongass to 

provide a common set of areas for resource inventories and analysis. They generally follow watershed 

boundaries. 

11 This figure does not match that provided in the 1997 Final EIS due to updated inventory information, land 

adjustments, and previous Forest Plan amendments. 
Record of Decision

14

Alternative 6 

This is the alternative identified as the Proposed Action in the Draft EIS. It is very similar to 

Alternative 5 (No Action) in terms of LUD allocations; however, it includes refinements to the 

boundaries of small old-growth reserves, new Geologic Special Interest Areas, a new Experimental 

Forest proposal, the conversion of a large area of Remote Recreation LUD north of Juneau to SemiRemote Recreation, the conversion of development LUD areas on Chichagof and Kupreanof Islands 

to Semi-remote Recreation, and other minor LUD refinements. Timber harvest would be allowed in 

an area more extensive than under Alternative 3, but slightly less extensive than under Alternative 5. 

The vast majority of current roadless areas Forest wide would remain in a natural condition. The 

goshawk foraging habitat and high value marten habitat standards and guidelines of the 1997 Forest 

Plan would be replaced with a new legacy standard and guideline. A total of 3.5 million acres of the 

Tongass would be in development LUDs, 13.3 million acres would be in non-development LUDs, 

and 663,000 acres, including 445,000 acres of old growth, would be in the suitable land base. This 

alternative would have an average annual ASQ of 267 MMBF. 

Alternative 7 

Compared to the 1997 Forest Plan, Alternative 7 would give much greater emphasis to timber 

management. Timber harvest would be allowed in a more extensive area than under the 1997 

Forest Plan. While the majority of current roadless areas would remain in a natural condition, most 

roadless areas outside of wilderness that contain substantial productive old growth would be subject 

to timber harvest and road construction. The Beach and Estuary Fringe buffer would be reduced 

from 1,000 to 500 feet and buffers on Class III streams would not be required. The Old-Growth 

Habitat LUD and its management prescription would not be used. The standards and guidelines for 

goshawk foraging habitat, high value marten habitat, and legacy would not be included in the Forest 

Plan under Alternative 7. The goshawk nesting standard and guideline would also not be included. 

A total of 5.0 million acres of the Tongass would be in development LUDs, 11.7 million acres would 

be in non-development LUDs, and 1,070,000 acres, including 807,000 acres of old growth, would be 

in the suitable land base. This alternative would have an average annual ASQ of 421 MMBF. 

Alternative 7 was incorporated in the NEPA analysis at the request of the Southeast Conference. 

Alternatives Considered but not Analyzed in Detail 

As mentioned above, the Forest Plan revision process started in 1987 and resulted in the 

development of numerous environmental documents, which cumulatively described dozens of 

alternatives. Each of these alternatives was considered for detailed study and comparison in the 

Draft EIS for the 2008 Forest Plan Amendment, in their original form or in a modified form. 

Altogether, 49 alternatives were considered for detailed study prior to the selection of the EIS 

alternatives; 39 based on past alternatives (which formed the basis for Alternatives 1, 3, 4, 5, and 7), 

and 10 new ones (which formed the basis for Alternatives 2 and 6). These alternatives were 

considered in light of the key issues and the purpose and need. They ranged in ASQ, the maximum 

amount of timber that can be sold on an average annual basis, from 0 to almost 700 MMBF per year. 

Development LUD acres in these alternatives ranged from a few hundred acres to almost 8 million 

acres, and suitable forest lands ranged from 0 to over 2 million acres. Chapter 2 of the Final EIS 

contains a more thorough discussion of the alternatives not analyzed in detail. 

The Environmentally Preferable Alternative 

The Council on Environmental Quality (CEQ) regulations for implementing NEPA require that the 

Record of Decision specify “the alternative or alternatives which were considered to be 

environmentally preferable” (40 CFR 1505.2(b)). This alternative has generally been interpreted to 

be the alternative that will promote the national environmental policy as expressed in NEPA’s 

Section 101 (CEQ’s “Forty Most-Asked Questions”, 46 Federal Register, 18026, March 23, 1981). 

Ordinarily, this means the alternative that causes the least adverse effect to the biological and 

physical environment. Alternative 1 of the Final EIS is the environmentally preferable alternative. 
Record of Decision 

15

Rationale for the Decision 

Summary 

I reached my decision to select Alternative 6 with the modifications described in this ROD, and to 

approve the Tongass Timber Sale Program Adaptive Management Strategy, after a comprehensive 

review and careful consideration of the relevant ecological, economic, and social potential effects of 

the Final EIS alternatives. During my consideration of the Final EIS and in reaching my decision, I 

have been guided by a wide variety of factors. Among the most important of these are how best to 

respond to problems identified by the Ninth Circuit Court of Appeals in their 2005 decision, many of 

which were identified as key issues in the EIS, and other considerations including those related to 

national policy. 

The following explanation of why I selected Alternative 6 from among the seven alternatives 

analyzed in the Final EIS addresses each of these factors in great detail. Another key factor in my 

decision is compliance of the Forest Plan with applicable laws, regulations, and executive orders, as 

described in detail in a separate section of this ROD. Here, I want to provide a short summary of my 

thinking. 

When I contemplate all of the information about legal requirements, effects analyses, risk 

assessments, and all the other factors relevant to this decision, it still comes down to sustainability of 

the multiple uses and resources of the Forest: How can we best balance the competing demands 

on the Tongass National Forest, when there is uncertainty about those demands and the effects of 

trying to meet them? Specifically, how can we best balance: 

• Potential risks to fish and wildlife from building roads and harvesting timber with the risks of 

local mills shutting down if their need for that timber cannot be met? 

• Potential adverse effects on recreational use of the Tongass with the level of timber harvest 

allowed? 

• The advantages of an integrated timber industry with the potential resource effects of 

allowing a sufficient level of timber harvest to enable new processing facilities to be built? 

Finally, how do we ensure that higher value roadless areas perceived as most environmentally 

sensitive are being protected from development as much as possible at whatever rate timber is 

harvested and roads are constructed? 

The most logical approach to me is to deal with fish and wildlife issues first, then with recreation 

issues, timber demand, issues related to an integrated industry, and protecting roadless areas in that 

order. This does not reflect any relative value of the issues or the resources, only what I see as the 

logical order of dealing with them. 

Fish and Wildlife Habitat and Biodiversity. The management of habitat to maintain the long-term 

viability of all Tongass fish and wildlife species as well as to sustain subsistence, recreational, and 

commercial uses of these resources is a key factor in my decision. This decision relies heavily on 

the sound scientific foundation developed in the 1997 Tongass Forest Plan, especially the fish and 

riparian standards and guidelines and the comprehensive wildlife conservation strategy prepared 

through an interagency collaborative process. All key components of this conservation strategy 

have been incorporated in the amended Forest Plan. The conservation strategy ensures the 

maintenance of viable populations of all vertebrate species on the Tongass by means of a 

comprehensive approach based on principles of conservation biology. Implementation of this 

strategy also recognizes the State of Alaska’s responsibility to provide for sustainable fish and 

wildlife resources and the human uses of these resources. The old-growth habitat strategy included 

in the amended Forest Plan is fully responsive to our obligations to manage habitat to maintain 

viable populations within a multiple-use context. This strategy has been developed through careful 

analysis and integration of the best scientific information available on this subject, and will minimize 

fragmentation of old-growth habitat on the Forest. 
Record of Decision

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The strategy includes two major components. First is the system of large, medium and small oldgrowth reserves well distributed throughout the Tongass. This system of reserves is made up of 

areas allocated to the Old-Growth Habitat LUD, plus lands in all the rest of the non-development 

LUDs, which essentially maintain the integrity of the old-growth system. This component provides 

adequate habitat for old-growth dependent or associated species, and provide for connectivity 

between reserves in order to prevent genetic isolation of populations. The reserve system protects 

72 percent of the existing productive old-growth habitat on the Tongass. The second major element 

of the wildlife conservation strategy is a series of standards and guidelines applicable to those 

portions of the Tongass open to consideration for potential timber harvest. The standards and 

guidelines regulate how development will occur on those areas open to potential development. 

Standards and guidelines incorporate a species-by-species approach that addresses issues that are 

more localized or not accounted for in the broader, ecosystem context approach that was 

incorporated into the old-growth reserve system. These standards and guidelines protect an 

additional 19 percent of the existing productive old-growth habitat on the Tongass. Between the 

reserve system and the standards and guidelines that apply to the development LUDs, the amended 

Forest Plan will protect 91 percent of the existing productive old-growth habitat on the Tongass. 

The purpose of both components of the strategy is to ensure the viability of old-growth dependent or 

associated species. The 1997 ROD concluded that the strategy provided assurance, subject to an 

acceptable level of risk inherent in projecting management effects, that even if timber were 

harvested and roads were constructed consistently for a period of 100 years at the Plan’s maximum 

allowable levels, viable populations of all vertebrate species on the Tongass would remain at the end 

of that period. Largely because of scientific uncertainty, the conservation strategy (and any other 

conservation strategy) involves some degree of risk. Therefore, the 1997 Plan did not represent a 

“no risk” conservation strategy. It represented a balance of wildlife conservation measures that 

considered the best available scientific information and reflected an acceptable level of risk for 

continued species viability, based on conservative assumptions. 

In the spring of 2006, experts in the field of conservation biology and Tongass-related species came 

together with agency representatives in a workshop to assess new information from conservation 

science and species research; discuss the implications of that new information for the underlying 

assumptions of the conservation strategy; and determine whether there was a need to modify or 

replace the existing strategy. On the basis of the information presented at the workshop, the Forest 

Service concluded that the conservation strategy remains valid and appropriate for the long-term 

management of the Tongass National Forest. Many ideas were discussed at the workshop. The 

Forest Service considered all of these ideas, and incorporated some of them into the analysis 

associated with this Forest Plan Amendment. The status and outcome of all topics considered 

during the workshop can be found in the document titled: Interagency Conservation Strategy 

Review: An Assessment of New Information Since 1997. 

As described in greater detail in a later section of this ROD, the Final EIS describes the potential 

effects of the Forest Plan on the probability of sustaining viable populations of wildlife species on the 

Tongass. As I review that information, I am struck by several key points. First, there are no 

terrestrial species on the Tongass listed as threatened or endangered under the Endangered 

Species Act. Second, the analysis in the Final EIS indicates no species will trend toward listing with 

implementation of the Forest Plan. The conclusion of that analysis is that the amended Forest Plan 

will provide an amount and distribution of habitat adequate to maintain viable populations of 

vertebrate species in the planning area and will maintain the diversity of plant and animal 

communities. In addition, the amended Forest Plan has a high likelihood of sustaining populations 

Forest-wide for the continued subsistence, recreational, and commercial uses of fish and wildlife 

species. 

Recreation and Tourism. As discussed in detail in the section below on this subject, the analysis in 

the Final EIS suggests that relatively minor changes in the mix of recreational opportunity settings 

may occur over the next 150 years under the amended Forest Plan. Changes to settings are related 

to projected levels of future development. The magnitude and rate of these changes will be 

influenced by the level at which timber harvest and associated road construction occurs. Even if 

such development occurs at the maximum level allowed under the amended Forest Plan, some of 
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these changes—an increase in opportunities for road-based recreation—will be desirable to some 

people, and undesirable to others. This may result in users being displaced to other areas where 

the setting and use patterns are more in line with their expectations and needs. The Tongass 

National Forest is overwhelmingly pristine and unroaded, and will remain that way under the 

amended Forest Plan. Therefore, I conclude there will be no significant reduction in recreation and 

tourism opportunities as a result from implementation of the Forest Plan over the next 10 to 15 

years, and some opportunities may be enhanced. 

Timber Demand. Based on my confidence in the assurance of maintaining fish and wildlife viability 

and recreational opportunities, the next question is how to deal with uncertainty related to timber 

demand. Once again, I recognize that I am making a decision for 10 to 15 years, while considering 

potential effects over a longer time horizon. In this case, however, if the decision is inadequate to 

meet the needs of the timber industry over the next 10-15 years, the industry simply will not be 

around for corrections to be made during the next Plan revision. State and private forest lands in 

Southeast Alaska are not able to provide an adequate supply to meet the minimum level needed for 

current mills to remain in operation. There are also questions about whether the industry will expand 

in the future if a supply of timber is available. Such an expansion would allow the industry to 

become more efficient and enhance its competitive position, improving its sustainability. While 

approving a Plan with an ASQ high enough to allow such an expansion will not make it happen; 

adopting an ASQ that meets only current needs will certainly prohibit it. Therefore, once viability 

concerns are met, it makes sense to approve a Plan with an ASQ high enough to allow current mills 

to increase their production to efficient operating levels and provide some room for new processing 

facilities, which will help maintain a vibrant and diverse economy in Southeast Alaska. As explained 

in detail in the section of this ROD dealing with market demand, the amended Forest Plan 

accomplishes that result. 

Need for an Integrated Forest Products Industry in Southeast Alaska. Beyond the question of 

what the market demand for timber is likely to be over the next 10 to 15 years, I also considered 

what supply would be needed to provide an opportunity to reestablish an integrated forest products 

industry in Southeast Alaska. As explained in detail in the section of this ROD on this subject, the 

existing timber industry in the region has been at a competitive disadvantage in world markets since 

the closure of the pulp mills in the 1990s. Reestablishing an integrated industry, including 

processing facilities for all types of material harvested on the Tongass, would require a reliable 

supply of economic timber from the Forest. Providing an opportunity for additional processing 

facilities to be established is an important step to ensuring the economic sustainability of the 

industry. An integrated industry would make commercial thinning more economically feasible, 

allowing more restoration work in watersheds where past practices have led to degraded ecological 

conditions. If local processing facilities can be established for utility12 logs, they would no longer be 

left in the woods. Accordingly, establishment of an integrated industry would further the goals of 

ecological, as well as economic, sustainability. I selected Alternative 6, which has an ASQ 

substantially above recent harvest levels, in part to provide such opportunities—and to ensure they 

are not foreclosed. 

Minimizing Effects on Roadless Areas. Having met requirements dealing with viability, recreation, 

and timber demand, and having provided opportunities for the development of an integrated timber 

industry, we turn finally to minimizing effects on roadless areas. Paramount among these concerns 

is how to ensure that development occurs first on the lower value roadless areas, since the ASQ of 

the Forest Plan is considerably above recent harvest levels, while protecting the higher value 

roadless areas and those perceived as more environmentally sensitive as much as possible. The 

amended Forest Plan and Adaptive Management Strategy limit timber harvest to lower value 

roadless areas unless harvest levels rise sufficiently to warrant allowing timber harvest in moderate 

value and higher value roadless areas. 

 

12 Utility logs are those with so much rot or otherwise of such poor quality that they cannot be sawn into lumber. 

They are relatively common in old-growth forests, comprising approximately 15 percent of the volume of timber 

cut on the Tongass. For safety and logistical reasons, such trees within a timber harvest unit must be 

purchased and cut down, even though the purchaser may have no use for them. In recent years, they have 

often been cut down and left in the woods.
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Conclusion. For the reasons described above, I conclude that my decision to approve the 

amended Forest Plan and the Timber Sale Program Adaptive Management Strategy meets all legal 

requirements, and best balances the many competing demands on the Tongass National Forest. 

The conservation strategy included in the amended Forest Plan ensures that healthy populations of 

wildlife will remain across the Tongass; the Adaptive Management Strategy protects higher value 

roadless areas; the LUD allocations and standards and guidelines minimize effects on recreation 

and tourism; and the ASQ associated with the LUD allocations and management direction provides 

opportunities for the timber industry to expand sufficiently to become more integrated and 

competitive in world markets. In short, my decision ensures the sustainability of the multiple uses of 

the Tongass and of the outstanding natural resources of the Forest that we all treasure. 

I recognize that there is enormous value in maintaining the Tongass for the suite of ecosystem 

services it provides to the world. More detail on the difficulty of monetizing these values is discussed 

below, yet there is no doubt they exist, and I have given them full consideration. People come to 

Alaska to catch salmon; to see bears; to see bears catching salmon; to enjoy the tranquility of an 

old-growth forest – forests with and without roads. People come here to boat on pristine coastal 

waters; to see whales and other marine mammals. Hunters come here to pursue deer and bears on 

these mountainous islands; some of them by car, and others preferring a more rugged and isolated 

experience in our many roadless areas. I believe all of these visitors, like many Alaska residents, 

treasure the abundant populations of fish and wildlife species dependent on the Tongass and its oldgrowth forests. This nature-based tourism is a valuable industry for Southeast Alaska. These 

rainforests are also critical to another important Southeast Alaska industry, commercial fishing. Well 

protected streams and their clean, cool waters are critical for large and lucrative salmon runs, on 

which both humans and animals thrive year after year. Trees are another valuable, renewable 

resource the Tongass has to offer. Trees are valuable in many forms--standing on the ground; 

downed, dead and decomposing on the forest floor; and sitting on a log truck headed for a local saw 

mill. The latter is a form that can provide for an important and sustainable industry that contributes 

to a diverse economy, without detracting from the other values I recognize as important to the public. 

Simply put, on a forest as vast as the Tongass, which is blessed with an abundance of these 

renewable resources, I believe it is important to maintain opportunities for all uses to occur, and at a 

scale which is both beneficial to local communities and respectful of broader national interests. 

Managed in a sustainable and environmentally sensitive manner, I believe the Forest Service can 

provide the raw materials of the Tongass to support a healthy wood products industry, a growing 

tourism industry, and a robust fishing industry in perpetuity. I am confident that the amended Forest 

Plan I am approving today can achieve that result. 

The remaining portions of this section explain in detail the rationale for my decision, starting with an 

elaboration of the considerations described above, including how they relate to problems identified by 

the Ninth Circuit Court of Appeals in its 2005 opinion, and to the key issues identified in the Final EIS. 

Protecting Fish and Wildlife Habitat and Biodiversity 

Background 

NFMA requires the Secretary of Agriculture to specify “guidelines for land management plans 

developed to achieve the goals of the Program which ... provide for diversity of plant and animal 

communities based on the suitability and capability of the specific land area in order to meet overall 

multiple-use objectives...” (16 U.S.C. 1604(g)(3)(B)). In accord with this diversity provision, the 

Secretary promulgated a regulation that provides in part: “Fish and wildlife habitat shall be managed 

to maintain viable populations of existing native and desired non-native vertebrate species in the 

planning area. For planning purposes, a viable population shall be regarded as one which has the 

estimated numbers and distribution of reproductive individuals to insure its continued existence is 

well distributed in the planning area.” (36 CFR 219.19.) 

The scientific community and courts recognize that NFMA does not create a concrete, precise 

standard for diversity. The Committee of Scientists that provided scientific advice to the Forest 

Service on the drafting of NFMA regulations stated that “it is impossible to write specific regulations 
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to ‘provide for’ diversity” and “there remains a great deal of room for honest debate on the translation 

of policy into management planning requirements and into management programs” (44 Fed. Reg. 

26,600-01 & 26,608). 

In this planning context, absolute certainty is not possible. This has led to a planning process which 

involves risk projections regarding the distribution of species over the next 100 years. Numerous 

factors, which vary according to the characteristics of the ecosystem examined, are considered in 

evaluating risk. Some common factors include the life history of the species, the current amount and 

distribution of habitat, the amount and distribution of species’ ranges within the planning area, and 

other reasonably foreseeable protective measures. In as biologically diverse and expansive an area 

as the Tongass, much of this type of information is evolving. Moreover, even absent any humaninduced effects, the likelihood that habitat will continue to support species’ persistence can vary 

among species. For example, the continued persistence of local rare endemic species whose entire 

range may comprise only a few acres is intrinsically insecure. Thus, compliance with the regulation 

is a matter of assessing risk, which is not subject to precise numerical interpretation and cannot be 

fixed at any one single threshold. Because long-term risk varies among species, even when using 

the best scientific projections available, it is also necessary to follow-up with rigorous monitoring of 

select key species and their habitats to ensure that populations remain healthy, particularly in areas 

of the Forest with higher levels of timber harvest. These monitoring expectations and commitments 

are described in Chapter 6 of the Forest Plan, titled “Monitoring and Evaluation.” 

In determining compliance with the NFMA fish and wildlife resource regulation, I have considered 

existing and reasonably foreseeable conservation measures. In addition to the Plan’s land 

allocations (which protect 78 percent of the Forest in non-development LUDs) and standards and 

guidelines, other possible measures include activities undertaken pursuant to internal policy 

directives (e.g., the Forest Service’s sensitive species program) and steps taken during project 

planning. The one issue that remains uncertain and could, in the future, alter assumptions made in 

the Final EIS is the effects of climate change. Consequently, it is important for the Tongass to stay 

abreast of the evolving scientific information related to the effects of climate change and how this 

may affect fish and wildlife populations. However, the state of current knowledge and the 

uncertainty about the specific effects of climate change leads me to conclude that the best course of 

action today is continued management of the Tongass for resiliency in the face of uncertain but 

anticipated change. This will be done primarily through the maintenance of the conservation 

strategy, coupled with a robust monitoring plan that will allow for management intervention if and 

when effects of climate change are more certain. I have determined that the combination of 

providing for an amount and distribution of habitat adequate to maintain viable populations of 

vertebrate species in the planning area and increased emphasis on monitoring climate-related 

changes is a reasonable solution. 

Summary 

The Final EIS describes the potential effects of the Forest Plan on the probability of sustaining viable 

populations of wildlife species on the Tongass. The conclusion of that analysis is that the Forest 

Plan will provide an amount and distribution of habitat adequate to maintain viable populations of 

vertebrate species in the planning area and will maintain the diversity of plant and animal 

communities. That conclusion is based in large part on viability risk assessments prepared by 

panels of experts for the 1997 Plan. Based on these assessments and all the other analyses, the 

1997 Forest Plan EIS estimated that there was a moderate to very high probability of maintaining 

sufficient habitat to maintain viable populations of wildlife species on the Tongass under the 1997 

Plan. The risks associated with the 1997 Plan were related to the scientific uncertainty of projecting 

long-term effects of management actions. I believe those probability estimates are very 

conservative for the following reasons: 

• The viability risk assessments assumed continuous timber harvest at the maximum level 

allowed under the Plan (the ASQ level of 267 MMBF annually) for 100 consecutive years, 

with no change in applicable standards and guidelines during that entire period. In essence, 
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20

they did not assess the risks associated with a 10- to 15-year decision, but with a 100-year 

decision. 

• Risks that viable populations would not be maintained are generally low, would only arise 

several decades into the future, and then only if timber were continuously harvested at or 

near the maximum ASQ level. 

• Timber has not been harvested on the Tongass at or near the maximum ASQ level 

throughout a single planning cycle, let alone several. The first Tongass Forest Plan was 

adopted in 1979, and was in effect through May of 1997. It had an annual average ASQ of 

549 MMBF of total volume.13 Total volume harvested from 1980 through 1996 averaged 327 

MMBF annually, only 60 percent of the ASQ. Since adoption of the 1997 Forest Plan, total 

volume harvested has averaged 84 MMBF annually, only 32 percent of the annual average 

ASQ of 267 MMBF. I do not expect timber to be harvested at a continuous rate of 267 

MMBF over the next planning cycle of 15 years, let alone 100 years. 

• If timber harvest rises to 267 MMBF annually over the next 10-15 years, or even beyond that 

level in the future, the planning process ensures that any issues that may emerge regarding 

sustaining viable populations of wildlife species on the Tongass will be addressed. Plans 

must be revisited through a public process every 10-15 years. Each time, the latest 

scientific information is examined to determine what changes may be needed. The Forest 

Service and other State and Federal agencies will continue to monitor implementation of the 

Forest Plan and its results. If a viability-related problem were to develop, it would not go 

unnoticed—it would be addressed. 

• Standards currently in effect are far more protective than those of 20 or 40 years ago. It is 

highly likely that standards will continue to become more effective over the next several 

decades through adaptive management as the scientific understanding of how to minimize 

the adverse environmental effects of human activities continues to improve. 

I want to be clear that I believe the analysis displayed in the Final EIS of potential effects on wildlife 

is valid. Land management decisions must consider very long-term potential effects to ensure they 

are sustainable. To estimate such potential effects, assumptions must be made about what 

management direction will apply in the future. It would be impossible to predict what changes in 

policy might be made over the next 100 years. Yet I am not making a 100-year decision today; I am 

making a 10- to 15-year decision. Experience tells us that standards do become more effective over 

time, and timber is not harvested at maximum allowable levels for long, if ever. While the members 

of the viability assessment panels may have concluded there is no scientific basis upon which to 

make different assumptions, the ones made are very unlikely to occur, and render the viability 

analyses something close to a “worst case scenario.” Consequently, while I am mindful of the fact 

that there are some long-term viability risks associated with implementing the Forest Plan over the 

next 10 to 15 years, I believe those risks are very small. For example, Chapter 3 of the Final EIS 

indicates that 92 percent of the productive old-growth forest that ever existed on the Tongass 

remains today. Over the next 15 years, even if timber is harvested at the maximum rate allowed 

under the amended Forest Plan over that entire period, less than 3 additional percent would be 

harvested and 89 percent of the original productive old-growth forest (97 percent of the existing 

productive old growth forest) would remain. I believe the risks associated with this level of activity 

are completely acceptable. Moreover, I am confident that any problems that may surface in the 

future will be addressed through the public planning process. Accordingly, I am as certain as I can 

be that this decision ensures the maintenance of viable wildlife populations as required by NFMA. A 

more detailed discussion of issues related to viability is provided below. 

The Old-Growth Habitat Reserves 

The amended Forest Plan strengthens the protection of old-growth habitat in two ways. First, it 

improves the network of small old-growth reserves through work completed by an interagency team. 

 

13 The ASQ of the 1979 Plan was expressed as 450 MMBF, which counted sawlog only. The 549 MMBF figure 

includes utility volume as well, as displayed in the 1997 Final EIS for the Tongass Forest Plan Revision. 
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21

Biologists from the State of Alaska, U.S. Fish and Wildlife Service (FWS), and the Forest Service 

reviewed nearly 300 small old-growth reserves identified in the 1997 Forest Plan and recommended 

reconfigurations for many of them. My decision acts on those recommendations. The amended 

Forest Plan includes an updated set of old-growth reserves that is approximately 90,000 acres larger 

than the old-growth reserve system contained in the 1997 Plan. Some 13 old-growth reserves 

require more analysis at the project level before any changes are made, as described in Appendix K 

of the Forest Plan. My decision enhances the network of small old-growth reserves by incorporating 

habitat protections identified through the interagency review; for example, the need to protect narrow 

habitat corridors known as “pinch points” that connect larger patches of habitat. At the same time, 

the changes in the small old-growth reserves will reduce operational conflicts, such as problems 

encountered when gaining access to suitable timber lands. 

The second enhancement in old-growth protection is a substantial increase in the amount of land 

allocated to other non-development LUDs. By increasing these allocations by 69,000 acres, the 

amended Forest Plan is expected to be more beneficial with respect to wildlife habitat than the 1997 

Plan. 

The Tongass now has an estimated 4,951,000 acres of productive old-growth forest. Changes in 

this amendment will increase the portion of productive old growth in non-development LUDs from 71 

percent under the 1997 Forest Plan to 72 percent. Another 19 percent of productive old-growth 

forest will be protected by the standards and guidelines that apply to the development LUDs. 

Overall, the amended Forest Plan protects 91 percent of the existing productive old growth on the 

Tongass National Forest. Not all of that is of equal value in terms of wildlife habitat quality. Many 

believe that high-volume old growth is higher quality habitat. An even smaller subset of the oldgrowth forest—the large-tree old growth--is also often perceived as higher quality wildlife habitat. 

The large-tree category is characterized by stands that have a coarse canopy texture and typically 

contain the largest trees and the highest timber volumes. The amended Forest Plan protects over 

90 percent of the existing high-volume old growth on the Tongass National Forest, and 89 percent of 

the existing large-tree old growth. Appendix D of the Final EIS discusses these considerations in 

more detail, as does the Biodiversity section of Chapter 3 of the Final EIS. Based on my review of 

these analyses, I am confident that the amended Forest Plan ensures that high quality wildlife 

habitat will remain abundant on the Tongass National Forest. 

Standards and Guidelines That Apply in Development LUDs 

Another component of the old-growth conservation strategy, management standards and guidelines, 

applies to lands not contained within the system of old-growth reserves. Rather, these standards 

and guidelines apply to those lands with LUD allocations that provide for the scheduled harvest of 

timber—the development LUDs. While these LUDs comprise 21 percent of the Forest, only about 4 

percent of the Forest would actually be scheduled for potential harvest over the next 100+ years. 

Within the development LUDs, some standards and guidelines aim to ensure protection of important 

old-growth habitats and connectivity. Key examples are the 1,000-foot buffers along beaches and 

estuaries and the streamside buffers protecting riparian zones. Other standards and guidelines 

preclude or significantly limit logging in areas with high-hazard soils, steep slopes, karst terrain, 

visually sensitive travel routes and use areas, and timber stands technically not feasible to harvest. 

All of these key standards and guidelines are maintained in this decision because they protect 

important resources and serve vital connectivity functions within the network of old-growth reserves. 

Some changes to wildlife standards and guidelines are being adopted in this decision. The purpose 

is to maintain the high level of protections afforded in the 1997 Plan, while also allowing additional 

flexibility during on-the-ground implementation. The minor changes serve to clarify standards and 

guidelines that were being either misinterpreted or inconsistently applied. The adoption of a Forestwide legacy standard and guideline as a replacement of the 1997 goshawk foraging and marten 

habitat standards and guidelines is a major change. The new standard and guideline applies in 

watersheds where the level of past or anticipated timber harvest is high. By requiring the retention 

of forest structural components such as patches of large trees, down logs, and snags (dead trees) 

after timber harvest in more biogeographic provinces, the legacy standard and guideline will provide 
Record of Decision

22

beneficial effects to more species in more areas across the Tongass than the standards and 

guidelines of the 1997 Forest Plan. 

The Queen Charlotte Goshawk 

Conservation organizations petitioned the FWS to list the Queen Charlotte goshawk subspecies of 

the northern goshawk (Accipiter gentilis laingi) as endangered in May 1994. The FWS has 

repeatedly determined that listing is not warranted, largely on the basis of protections provided by 

the conservation strategy in the 1997 Tongass Forest Plan. The most recent status update and 

finding was published in November 2007. The FWS found that the best available information does 

not support the listing of the Alaska population segment as threatened or endangered at this time. 

However, the FWS also concluded that Vancouver Island is a significant portion of the Queen 

Charlotte goshawk’s range and that listing the subspecies in British Columbia is warranted. 

I am mindful that the FWS made its non-warranted determination for Alaska goshawks largely on the 

basis of protections in the 1997 Forest Plan. This is reflected in my decision to maintain the key 

components of the conservation strategy in the amended Forest Plan, so as to continue providing a 

high level of protection for the goshawk. However, the decision does include three changes that 

affect goshawk habitat. These are: 1) adjustments to the network of small old-growth reserves and 

increases in other non-development LUDs, as described in the preceding section; 2) changes to the 

goshawk nest buffer standard and guideline; and (3) adoption of a new Forest-wide legacy standard 

and guideline that replaces the goshawk foraging standard and guideline contained in the 1997 Plan. 

The 1997 Tongass Forest Plan EIS estimated that Alternative 11, as displayed in that EIS, had a 

high likelihood of maintaining viable populations of goshawks well-distributed across the Tongass, 

even if timber were harvested and roads constructed for 100 years at the maximum levels allowed 

by Alternative 11. This estimate did not take into account several goshawk-specific measures that 

were added in the final decision after the assessment was conducted. These measures were added 

to Alternative 11--the Selected Alternative--to further reduce risk to the goshawk, in recognition that 

the species had been considered for listing under the Endangered Species Act. One such measure 

was prescribed for goshawk habitat on Prince of Wales Island, where productive old-growth has 

been fragmented by past management actions such at timber harvest and road construction. This 

goshawk foraging standard and guideline, applicable within the most-fragmented watersheds on 

Prince of Wales Island, sought to retain habitat structure for goshawk nesting, foraging, and 

dispersal between old-growth reserves. 

The Final EIS for the 2008 Forest Plan Amendment considered the cumulative changes in the 

conservation strategy in describing the potential effects on goshawks. Changes that enhance the 

old-growth reserve system, as described in the previous section, figure importantly in this analysis. 

These enhancements include a net addition of acres to the old-growth reserve network; 

improvements in the configuration of small reserves recommended by the interagency team; and the 

additions to other non-development LUDs that are part of this decision. The enhanced reserve 

network in the amended Forest Plan, coupled with the 1,000-foot wide beach buffers and other 

features that provide habitat connectivity, should provide a similar if not stronger foundation for 

maintaining goshawk populations across the Tongass. Overall, at least 91 percent of the existing 

productive old growth (83 percent of all old growth that ever existed on the Tongass) would remain 

on the Tongass, even if timber were harvested at the maximum level allowed by the Forest Plan for 

100 consecutive years. In addition, over this same time period, a significant acreage of young 

growth that is protected from future harvest (equal to about 5 percent of the original amount of old 

growth) will be reaching mature forest stages and will also have value as goshawk habitat. For 

these reasons, I conclude that an abundant supply of habitat suitable for goshawk nesting and 

foraging will persist across the Tongass. 

Because the protection of known goshawk nests is paramount, I am modifying Alternative 6 as 

displayed in the Final EIS to ensure that confirmed nests will continue to be protected by a 100-acre 

buffer of old-growth habitat, as required by the 1997 Forest Plan. The amended Forest Plan does, 

however, make a change to the 1997 Plan to allow some management flexibility in stands where 

goshawks have been observed but no direct or indirect evidence of a confirmed nest is documented. 
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23

Such stands are defined as “probable nest stands.” Under the amended Forest Plan, activities may 

be allowed within the 100 acres surrounding probable nest stands, but only if—after 2 years of 

monitoring—there is no additional evidence of goshawk use. A requirement to survey for goshawks 

prior to timber harvest remains in effect, as does a commitment to monitoring. Therefore, I anticipate 

that management situations enabled by this change would be rare, and that goshawk populations 

would not be affected. 

As another change relating to goshawks, I am adopting a Forest-wide legacy standard and guideline 

in lieu of the goshawk foraging standard and guideline contained in the 1997 Plan. This change 

stems from the desire for a more comprehensive (versus single-species) approach to retaining oldgrowth structural components in areas of timber harvest, and for more consistency in application 

across the Forest. The legacy standard and guideline applies to higher risk VCUs across the Forest, 

whereas the 1997 Plan’s goshawk foraging standard applied just to higher risk VCUs on Prince of 

Wales Island. Therefore, the beneficial effects of retaining old-growth structure, for example in 

retaining connectivity and habitat conditions for prey, will apply to goshawks throughout their range 

on the Tongass National Forest. My decision to adopt this change also responds to operational and 

economic considerations associated with timber harvest, which is another important objective in this 

plan. This standard and guideline will be monitored to ensure it functions as expected. 

The benefits to wildlife of leaving large trees, snags, and downed logs after timber harvest is well 

documented in the scientific literature, including studies on goshawk and their primary prey species. 

However, there is no scientific basis to guide managers as to how much structural material should 

be retained, and in what configurations, to specifically benefit goshawks and their prey in southeast 

Alaska. I am basing my decision on research that suggests that retaining clumps of trees is more 

beneficial than retaining single trees. Clumps receive more use by wildlife and are more windfirm 

than scattered residual trees. Applying the legacy standard and guideline in required VCUs is 

expected to achieve the beneficial effects of residual habitat structure that were intended by 

goshawk standards and guidelines in the 1997 Plan. Additionally, clumped configurations provide 

an increased measure of operability from a timber harvest standpoint. 

An additional feature of the legacy standard and guideline is that it is scaled to take into account the 

cumulative effects from past and planned forest harvesting. The legacy standard and guideline need 

not apply in low and moderate risk watersheds, where cumulative effects are low, because 

protection is afforded by other measures such as non-development LUDs, old-growth reserves, and 

standards and guidelines designed primarily to address other resource concerns. In high-risk 

watersheds, where cumulative effects are greater, the legacy standard and guideline provides 

additional protections, above those other measures. As was intended by the original goshawk 

standards, the new approach will retain important forest structure where it is most needed, in the 

higher-risk VCUs. The legacy standard and guideline applies to 49 VCUs across the Forest, 

including 31 on Prince of Wales Island. This compares to 22 VCUs under the 1997 Plan, under 

which the goshawk foraging standard applied only to that Island. 

I believe that the potential effects to goshawks described in the Final EIS for the 2008 Tongass 

Forest Plan Amendment are fully consistent with the November 2007 status finding by the FWS. I 

also believe that the amended Forest Plan provides as much protection for goshawks as was 

provided by the 1997 Plan. That Plan was estimated to provide a high likelihood of maintaining 

viable populations of goshawks, even before the goshawk foraging standard and guideline was 

added to further reduce risk. Moreover, in my view the estimate of viability risk is based on 

extremely conservative assumptions. This level of risk to goshawk viability would result from this 

Plan only under the following conditions: timber is harvested annually for 100 years at levels near 

the maximum allowed, and any needed corrections identified through monitoring and evaluation are 

not acted on. I believe that such conditions are highly unlikely. During the time the 1979 Forest Plan 

was in effect, annual harvest levels averaged 60 percent of the maximum level allowed. Since the 

1997 Plan was implemented, annual harvest levels have been about one-third of the maximum 

allowed, and young-growth stands have developed suitable habitat conditions for goshawks faster 

than predicted. Under the amended Forest Plan, timber may continue to be harvested at rates less 

than the maximum allowed. A more detailed explanation of the potential effects of the amended 

Forest Plan is provided in Chapter 3 and Appendix D of the Final EIS.
Record of Decision

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Alexander Archipelago Wolf

In this decision the Forest Service maintains its commitment to the conservation of the Alexander 

Archipelago wolf. We will continue to work closely with the Alaska Department of Fish and Game 

and the FWS on issues related to wolf conservation in Southeast Alaska. Details on how the 

amended Forest Plan will provide a high likelihood of maintaining viable wolf populations in 

Southeast Alaska are provided in Appendix D and Chapter 3 of the Final EIS. 

This decision does adopt some minor changes to wolf standards and guidelines to improve their 

effectiveness with respect to near-term and long-term wolf viability concerns described in the 1997 

Forest Plan EIS. These changes relate to density thresholds of deer, a primary prey species of 

wolves; and to potentially unsustainable human-induced mortality. 

Long-term maintenance of a deer herd, capable of providing sustainable wolf populations, is an 

important management objective in the Tongass Forest Plan. The 1997 Plan included a standard 

and guideline setting a deer population objective, where possible, sufficient to maintain sustainable 

wolf populations. The amended Forest Plan updates this standard and guideline to reflect new 

information from wolf research in Southeast Alaska. Additional information is provided in Chapter 3 

and Appendix D of the Final EIS. 

Another concern in some areas is the potentially unsustainable level of hunting and trapping of 

wolves, when both legal and illegal harvest is considered. The 1997 Forest Plan EIS acknowledged 

that open road access contributes to excessive mortality by facilitating access for hunters and 

trappers. Landscapes with open-road densities of 0.7 to 1.0 mile of road per square mile were 

identified as places where human-induced mortality may pose risks to wolf conservation. The 

amended Forest Plan requires participation in cooperative interagency monitoring and analysis to 

identify areas where wolf mortality is excessive, determine whether the mortality is unsustainable, 

and identify the probable causes of the excessive mortality. 

More recent information indicates that wolf mortality is related not only to roads open to motorized 

access, but to all roads, because hunters and trappers use all roads to access wolf habitat, by 

vehicle or on foot. Consequently, this decision amends the pertinent standard and guideline 

contained in Alternative 6 as displayed in the Final EIS in areas where road access and associated 

human caused mortality has been determined to be the significant contributing factor to 

unsustainable wolf mortality. The standard and guideline has been modified to ensure that a range 

of options to reduce mortality risk will be considered in these areas, and to specify that total road 

densities of 0.7 to 1.0 mile per square mile or less may be necessary. The wolf standard also 

requires that both access management on National Forest System lands, and harvest regulations for 

hunting and trapping, be considered in relation to wolf management objectives. 

Chapter 3 and Appendix D of the Final EIS contain details on these plan components relating to wolf 

viability. I am confident that these measures will ensure adequate protection to sustain viable 

populations of the Alexander Archipelago wolf. The Forest Service will continue to work closely with 

the State of Alaska to gather and apply new information to help resolve any future concerns about 

wolf management. 

Endemic Mammals 

This decision continues to give special management consideration to animal taxa that are known or 

suspected of being endemic to Southeast Alaska. Efforts have increased since 1997 to document 

the distribution of endemic mammals on the Tongass. Forest Service partnerships with other 

agencies and universities have significantly increased our knowledge of many species. However, 

gaps remain in the knowledge base, and there is continued concern about risks to species that may 

be endemic to islands within the Alexander Archipelago. 

This decision brings forward from the 1997 Plan the conservation measures for habitat connectivity 

(described in previous sections), as well as the standards and guidelines for landscape connectivity 

and endemic terrestrial mammals. This decision also adopts minor changes to these standards and 

guidelines. For example, it clarifies that the original intent of the landscape connectivity standard was 
Record of Decision 

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to provide connectivity between large and medium old-growth reserves. As described in an earlier 

section, enhancements in the network of small old-growth reserves provide protections to important 

habitat “pinch points,” and give additional consideration to connectivity at the watershed scale. The 

endemic terrestrial mammal standard was modified to allow the use of existing inventory data on 

endemic mammal distribution when analyzing effects of proposed management projects. Surveys 

would still be necessary where existing information is not adequate to assess project-level effects. 

American Marten 

The 1997 Forest Plan EIS estimated that Alternative 11 as displayed in that EIS had a moderate 

likelihood of maintaining viable populations of American marten across the Tongass for 100 years, 

even if timber were harvested and roads constructed at the maximum levels allowed by Alternative 

11 for that entire period. This moderate likelihood estimate did not take account of additional 

conservation measures that were added in the subsequent ROD. Alternative 11 was selected in the 

1997 ROD, and modified to further reduce risk to marten viability. Several protective measures for 

marten habitat were added, including a standard and guideline relating to timber harvest practices. 

The intent of the 1997 marten standard and guideline was to reduce risk in five biogeographic 

provinces. Marten were judged to be vulnerable in these provinces because large areas of young 

conifer growth lack the residual old-growth forest structure that is known to be an important marten 

habitat feature. The standard and guideline aimed to avoid the creation of additional, significant 

gaps in marten habitat that would limit marten movement and population interactions. It required the 

retention of downed logs, snags, and green trees to reduce adverse effects of timber harvest on 

marten habitat, based on research findings that show higher marten use in partially logged areas 

than in clearcut areas that lack large-wood structure. 

Healthy marten populations persist on the Tongass. Recent information suggests that marten 

populations are stable or increasing across most of the Tongass. Areas on the Tongass with the 

highest levels of prior timber harvest continue to have stable or increasing marten populations; for 

example, on Chichagof Island and Prince of Wales Island. Trapping regulations have not changed 

significantly on the Tongass, indicating the marten supply remains stable. In an earlier section I 

expressed my view that the viability panel assessments were highly conservative, reflecting a “worstcase scenario.” While I am mindful that there are some long-term viability risks associated with the 

amended Forest Plan, I believe those risks are very small and would only occur if timber were 

harvested at or near the maximum rate allowed under the Plan throughout the 100-year time horizon. 

Recent marten studies in Southeast Alaska confirm the scientific basis for the finding in 1997 that an 

old-growth reserve system represents a model of marten conservation, especially when 

supplemented by additional measures to protect habitat in areas where timber harvest is allowed. 

Studies show that marten home ranges include some areas where timber harvest and roads have 

reduced the old-growth cover. These and other studies indicate that the quality and quantity of 

available prey are very important factors influencing marten abundance and distribution. 

Reflecting these findings, the amended Forest Plan incorporates three changes that affect marten 

habitat. First, it adopts the enhancements to the network of small old-growth reserves and the 

increases in other non-development LUDs that I have already described. Second, it incorporates the 

Forest-wide legacy standard and guideline as a replacement for the marten standard and guideline. 

And third, it clarifies when to consider road density management for marten. 

As previously mentioned, research supports the network of old-growth reserves as the critical 

foundation for marten conservation on the Tongass National Forest. Enhancements in the network 

of small reserves, coupled with the 1,000-foot wide beach buffers and other measures for habitat 

connectivity, also favor the outlook for marten conservation. 

I have already described the change to the legacy standard and guideline in the section on the 

Queen Charlotte goshawk. Adoption of the legacy standard and guideline will retain important forest 

structure where it is most needed, in the higher-risk VCUs throughout the Forest. The residual 

structure is expected to serve as suitable foraging and dispersal habitat for marten in the short term, 

reducing adverse effects of timber harvest on marten habitat. 
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Marten encounter a mosaic of habitat conditions in Tongass landscapes, including natural patterns 

of fragmentation associated with muskegs, windthrown stands, and other openings. While marten 

spend most of their time in mature and old-growth forests, studies have documented marten 

movements through a variety of habitats including non-commercial forest and clearcuts with 

established conifer cover. When applied in a typical timber sale layout, the legacy standard and 

guideline should produce a mix of openings and clumped residual trees. When the riparian buffers 

and various other standards and guidelines are factored in, most timber sale units will show a 

significant presence of residual-tree patches. I anticipate that the patchy character of harvest units, 

embedded within managed watersheds in which old growth is retained for a variety of reasons 

including operational constraints and beach and riparian buffers, will provide habitat conditions 

adequate to sustain marten prey populations. Forest Plan monitoring will check to ensure that oldgrowth structure is retained within units as directed by the legacy standard and guideline. 

Adjustments can be made through adaptive management if monitoring determines that habitat 

objectives are not being met. 

The 1997 Plan contained a Forest-wide marten standard and guideline relating to road density. This 

standard is clarified in the amended Forest Plan, as follows. Road access is to be considered as an 

issue for marten management only when there is evidence that mortality is exceeding sustainable 

levels and that human access on roads is the most significant factor causing this trend. The intent of 

the standard does not change; rather, the change makes it clearer as to when the standard should 

be implemented. Other minor edits do not change the intent of the standard, but offer clarifications 

to support more consistent implementation. The Forest Service will continue to work closely with the 

State of Alaska to gather new information about marten mortality so that future concerns may be 

addressed in a timely and collaborative manner. 

The mosaic of marten habitat that will be protected under the amended Forest Plan is similar to the 

marten habitat protection analyzed by the 1997 risk assessment panels, except that the network of 

old-growth reserves has been enlarged. Connectivity between reserves will be provided by riparian 

and beach fringe buffers, based on studies that report preferential marten use of riparian zones. The 

development LUDs will retain significant old-growth habitat. An average of 68 percent of the existing 

productive old growth (54 percent of what existed before commercial timber harvest began) will 

remain unharvested in the development LUDs, even if timber is harvested annually at the maximum 

allowable level for 100 years. Forest wide, 91 percent of existing productive old growth would 

remain after a century of maximum-rate harvest (83 percent of what existed before commercial 

timber harvest began). The percent of old growth remaining will vary by biogeographic province; 

however, VCUs within the highest-risk provinces will have additional protections afforded by the 

legacy standard and guideline. In addition to these habitat measures, road access will be managed 

to reduce marten mortality where this factor constitutes a significant risk. Collectively, the various 

elements of the Tongass marten strategy are expected to increase the likelihood of maintaining 

viable marten populations throughout the Forest. While habitat gaps may occur, the likelihood that 

these would cause significant isolation among marten populations is low. The anticipated transition 

to second-growth harvest, combined with thinning conducted for wildlife in young-growth stands, 

should improve the conservation picture for marten and their prey in future decades. 

I believe that the potential effects to marten described in the Final EIS for the 2008 Tongass Forest 

Plan Amendment are well within the range of effects predicted in 1997. The 1997 Tongass Forest 

Plan EIS estimated there would be a moderate likelihood that marten populations would remain 

viable throughout the Tongass, before marten and landscape connectivity standards and guidelines 

were added in the 1997 ROD to further reduce risk. The amended Forest Plan also reduces risks to 

marten viability through increased protective measures for marten above and beyond what the 

viability panels assessed. These additional measures include increased old growth acres retained in 

both old growth reserves and other non-developments LUDs; retention of the marten road density 

and landscape connectivity standards and guidelines; and the addition of the legacy standard and 

guideline. Furthermore, the level of risk to marten viability described in the 1997 EIS would be 

realized only under a certain set of conditions, as follows. Timber harvest occurs at or near the 

maximum limits every year for the next 100 years, and any needed corrections identified through 

monitoring and evaluation are not acted upon. I believe these are extremely conservative 

assumptions. Annual timber harvest levels under the 1979 Forest Plan averaged 60 percent of the 
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maximum level allowed. Under the 1997 Plan, annual harvest levels have fallen to 32 percent of the 

maximum allowed. Timber may continue to be harvested at levels below the maximum allowed 

under the amended Forest Plan. 

For all these reasons, I am confident that the direction implemented by this decision will provide for 

viable populations of marten across the Tongass. 

Management Indicator Species 

Both the 1997 Forest Plan and the 2008 Tongass Forest Plan Amendment were prepared under the 

1982 NFMA planning regulations, which required the identification of management indicator species 

in forest plans. This requirement was based on an assumption that the responses of selected 

species to land management activities could indicate the likely responses of other species with 

similar habitat requirements. The 1997 Tongass Plan identified 13 terrestrial and 4 aquatic 

management indicator species. All the terrestrial management indicator species are associated with 

the coastal spruce and hemlock forests that represent 98 percent of total productive old-growth on 

the Tongass. The 1997 Plan also specified what monitoring information should be gathered 

annually and evaluated after 5 years to see whether population trends could be detected, and how 

those trends might relate to management of the Tongass National Forest. The requirements for 

monitoring population trends and management relationships are contained in the applicable NFMA 

planning regulations. The amended Forest Plan retains all 17 management indicator species. 

Fish Habitat 

The Tongass National Forest contains outstanding fish habitat and aquatic resources. These 

resources support major subsistence, recreational, and commercial fisheries, as well as traditional 

and cultural values. Abundant rainfall, streams with glacial origins, and watersheds with high stream 

densities provide an unusual number and diversity of freshwater fish habitats. These abundant 

aquatic systems of the Tongass provide spawning and rearing habitats for the majority of fish 

produced in Southeast Alaska. Maintenance of this habitat, and associated high-quality water, is of 

great interest to several State and Federal natural resource agencies, as well as user groups, Native 

organizations, and individuals. 

Many of the standards and guidelines in the 1997 Forest Plan were based, to a large extent, on the 

recommendations of the Anadromous Fisheries Habitat Assessment (AFHA). AFHA is considered 

the most comprehensive scientific review available for the Tongass. The 1997 ROD noted that the 

standards and guidelines and other direction included in the 1997 Forest Plan meet or exceed all of 

the recommendations by AFHA. 

In general, the effects of implementing the amended Forest Plan on fish resources are expected to 

be at or below those predicted for the selected alternative in the 1997 Tongass Forest Plan Final 

EIS. I believe that the 1997 Forest Plan’s direction regarding protection of fish habitat will continue 

to maintain high-quality fish resources on the Tongass; therefore, no changes were made. 

Conclusion 

Our understanding of the biological diversity of the complex old-growth ecosystem of the Tongass 

National Forest, including its composition, function and structure, is continually growing. Given the 

complexities involved, management decisions necessarily will involve some degree of uncertainty. 

This uncertainty can be mitigated to a large degree by developing an adaptive management 

approach based on a strong partnership with the State of Alaska and other Federal agencies to 

actively monitor ecosystem functions, fish and wildlife habitat, and populations. Based on my review 

of the record, including the Final EIS and Appendix D, I find that the old-growth strategy and specific 

species management prescriptions represent a balance of fish and wildlife habitat conservation 

measures which consider the best available scientific information. Accordingly, I find that the 

amended Forest Plan will provide fish and wildlife habitat to maintain viable populations of vertebrate 

species in the planning area and maintain the diversity of plants and animals, within an acceptable 
Record of Decision

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level of risk inherent in projecting management effects. Furthermore, the amended Forest Plan has 

a high likelihood of sustaining populations Forest-wide for the continued subsistence, recreational, 

and commercial uses of fish and wildlife species.

Recreation and Tourism 

The potential effects of the proposed Forest Plan alternatives on recreation and tourism are 

evaluated in the Recreation and Tourism section of the Draft and Final EIS documents. As stated in 

a number of locations in that section, recreation and tourism in Southeast Alaska and on the 

Tongass are influenced by a number of factors that are largely independent of forest management 

decisions. While it is difficult to predict future recreation and tourism demand with precision, the 

number of visitors to Southeast Alaska, particularly cruise ship visitors, is generally expected to 

remain at current levels or continue to increase. Southeast Alaska residents also place a high value 

on the quality and availability of outdoor recreation opportunities on the Tongass. Although there is 

limited information that quantifies resident and non-resident recreation use, I know that residents and 

visitors alike seek a wide spectrum of recreation activities – some people enjoy activities requiring 

vast and remote areas in a natural setting, while others prefer developed facilities, utilities, and easy 

access. From a management perspective, the requirements of these activities are often at odds with 

one another and sometimes with other Forest management activities, including timber harvest and 

associated road construction and road management. 

The potential effects on the supply of recreation opportunity settings are easier to predict, because 

they are affected by land management decisions to the extent that different LUD classifications 

influence potential recreation opportunity spectrum (ROS) classes and, therefore, different types of 

recreation. As indicated in the Final EIS, the general trend across all alternatives is toward an 

increase in developed and/or motorized opportunities and a corresponding decrease in primitive 

recreation opportunities. In regard to the Selected Alternative, approximately 79 percent of the 

Forest would fall within the Primitive or Semi-Primitive ROS classes, compared with approximately 

89 percent at present. Approximately 18 percent of the Forest would fall within the Roaded Modified 

ROS class, compared to 10 percent at present. These changes would occur gradually over the next 

150 years, and would be lower in magnitude if future development does not occur at the maximum 

levels allowed by the Forest Plan. 

It is important to note that recreational opportunities do not cease to exist as a result of management 

activities such as timber harvest and road construction. Rather, changes in the supply of recreation 

opportunities could result in changes in recreation demand and use patterns. Southeast Alaska 

residents and visitors seeking solitude and isolation in a natural setting may be displaced to other 

areas of the Forest where the setting and use patterns are more in line with their expectations. This 

effect is a result not only of projected timber harvest and road development, but also due to the 

increases in resident population and tourism that are expected to occur under all of the alternatives. 

Nearly three quarters of the Forest will remain untouched by development activities, even if such 

activities are conducted at the maximum rates allowed under the Plan for 100 years. As described 

in detail in Chapter 3 of the Final EIS and in the section of this ROD dealing with the protection of 

roadless areas, only one-quarter of the land in inventoried roadless areas is allocated to 

development LUDs, and only 3 percent is included in the suitable land base. Finally, development in 

higher value roadless areas will be deferred under the Timber Sale Program Adaptive Management 

Strategy unless the level of timber harvest rises to the point where such development is warranted. 

In this fashion, the amended Forest Plan, in conjunction with the Adaptive Management Strategy, 

protects the areas most commonly identified as most valuable for primitive recreation. 

Those seeking more developed areas and easier access may find increased recreational 

opportunities as forest management activities in development LUDs increase road access and 

facilitate more developed recreation opportunities. Forest-wide standards and guidelines for 

recreation and tourism remain substantially unchanged under the amended Forest Plan, and will 

guide the development of new recreation facilities. The amended Forest Plan also protects the 

scenic quality of heavily traveled cruise ship corridors and recreation and tourism use areas. 
Record of Decision 

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The amended Forest Plan is consistent with national travel management policy by requiring each 

Ranger District to identify and designate those roads, trails and areas that are open to motor vehicle 

use. This will require extensive public involvement and coordination. Working with forest users, 

government officials, and tribal entities at the local level is the most effective way to make route 

designation decisions. The Forest Service will continue to work with the State of Alaska regarding 

access and travel management planning and implementation. 

In summary, my decision provides for a mix of recreation opportunities, with a wide range of 

recreation settings and experiences available throughout the Forest. It balances the competing 

demands of providing sufficient timber for a sustainable forest products industry while also meeting 

the various and wide-ranging recreation demands and user needs of Southeast Alaska residents 

and visitors and the recreation and tourism industry. 

Market Demand 

Introduction: This was key issue 2 in the EIS for the 2008 Tongass Forest Plan Amendment. This 

section reviews the extensive work done to respond to the findings of the Ninth Circuit court regarding 

the error made in 1997 in interpreting projections of market demand for timber from the Tongass 

National Forest. It also describes how I considered other factors related to market demand. 

I understand that estimating long-term market demand is inherently uncertain. This is the primary 

reason I am adopting the Tongass Timber Sale Program Adaptive Management Strategy, which 

restricts timber harvest and associated road construction activities to the lower quality roadless 

areas of the Tongass unless the level of timber harvested warrants allowing such activities to take 

place in higher quality roadless areas that are perceived by many as more environmentally 

sensitive.14 Thus, the Strategy addresses the inherent uncertainty in estimating the long-term future 

demand for timber. By no means does this render the substantial work done to correct the errors 

found by the court unimportant. It does, however, minimize the harm from any potential errors in 

forecasting timber demand. I believe the Final EIS fully remedies the problems identified by the 

Ninth Circuit regarding the treatment of market demand in the 1997 Tongass Forest Plan EIS. I 

recognize, however, that there are differences of opinion on long-term forecasts of market demand. 

The Tongass Timber Sale Program Adaptive Management Strategy is the most reasonable way to 

address such differences of opinion and provide the flexibility required in the face of such 

uncertainty. In doing so, the Strategy makes the differences of opinion regarding market demand 

less relevant to the decision to adopt Alternative 6. 

Background—Tongass Timber Reform Act: The debate concerning the market demand for 

timber from the Tongass National Forest, and how the timber program relates to market demand, 

has been ongoing for decades. Forest Service economists with the Pacific Northwest Research 

Station completed their first study of the issue in 1990. Later that year, Congress enacted TTRA, 

which in Section 101 amended Section 705(a) of the Alaska National Interest Lands Conservation 

Act to read as follows: 

Subject to appropriations, other applicable law, and the requirements of the National Forest 

Management Act of 1976 (Public Law 94-558), except as provided in subsection (d) of this 

section, the Secretary shall, to the extent consistent with providing for the multiple use and 

sustained yield of all renewable forest resources, seek to provide a supply of timber from the 

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

forest and (2) meets the market demand from such forest for each planning cycle. 16 U.S.C. 

539(d)(a). 

Questions about how to interpret and apply this direction slowed the development of procedures to 

comply with it. In the ROD for the 1997 Forest Plan, the Regional Forester directed that procedures 

be developed “to ensure that annual timber sale offerings are consistent with market demand.” 

 

14 See the section of this ROD on minimizing effects on roadless areas for a discussion of the terms “higher 

value” and “lower value” roadless areas.
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Those procedures were completed in 2000, and have become known as the “Morse methodology” 

after their author. These procedures are based on the premise that: 

• Forest product markets are volatile, especially in the short run. 

• Timber purchasers in Southeast Alaska have few alternative suppliers of timber if they 

cannot obtain it from the Tongass National Forest. Oversupplying this market has relatively 

few adverse economic effects; undersupplying it can have much greater negative economic 

consequences. 

• It takes years to prepare National Forest timber for sale, including completion of 

environmental impact statements. 

• It is difficult to estimate demand for timber from the Tongass, even a year or two in advance. 

• Industry must be able to respond to rapidly changing market conditions in order to remain 

competitive. 

Accordingly, the Morse methodology establishes a system that seeks to build and maintain sufficient 

volume of timber under contract15 to allow the industry to react promptly to market fluctuations. 

Industry actions such as annual harvest levels are monitored and timber program targets are 

developed by estimating the amount of timber needed to replace volume harvested from year to 

year. The Morse methodology is adaptive, because if harvest levels drop below expectations and 

other factors remain constant, future timber sale offerings would also be reduced to levels needed to 

maintain the target level of volume under contract. Conversely, if harvest levels rise unexpectedly, 

future timber sale targets would also increase sufficiently to ensure that the inventory of volume 

under contract is not exhausted. By dealing with uncertainty in a flexible, science-based fashion, the 

Morse methodology is an example of adaptive management. The Forest Service adopted the Morse 

methodology as the means by which the agency complies year-by-year with the annual demand 

portion of the TTRA “seek to meet” requirement. Similarly, the agency intended to comply with the 

requirement to seek to meet demand “for each planning cycle” through a series of annual 

applications of the Morse methodology.16

In its 2005 decision, the U.S. Court of Appeals for the Ninth Circuit opined on the interpretation of 

TTRA. The court determined TTRA “imposed additional planning requirements for the Tongass.” 

Among the requirements, according to the appellate court, “Congress imposed a unique duty on the 

Forest Service to consider the ‘market demand’ for timber” in Section 101 of TTRA.” Further, the 

court stated that the duty to consider, or assess, market demand “can be seen as a refinement of the 

general requirement under NFMA that the Forest Service consider timber harvest as one of the 

goals to be balanced with environmental preservation and recreational use.” 

The court also found that reason and logic support a linkage between the ASQ of the Forest Plan 

and market demand. According to the court, “[A] ceiling too low to satisfy demand could 

compromise one of NFMA’s multiple-use goals (timber harvest) without justification in this record.” 

However, the court specifically noted: “[W]e do not suggest that an ASQ can never be too low to 

satisfy market demand, or that the Forest Service must in fact meet demand (as opposed to seek to 

meet market demand).” Likewise, the court stated, “a ceiling higher than needed to satisfy demand, 

could compromise another of NFMA’s multiple-use goals (environmental preservation) without 

justification in this record.” However, the court expressly left open the possibility that the Forest 

Service could adopt an ASQ greater than even the highest market demand scenario in order to allow 

flexibility to respond to changes in market demand, so long as the record shows “how much greater 

the ASQ would need to be, or to what extent other alternatives might have been considered in detail, 

in relation to the actual market demand.” 

 

15 Volume under contract is timber purchased but not yet harvested, the primary indicator of timber inventory 

available to the industry. 

16 Adoption of the Forest Plan Amendment and the Timber Sale Program Adaptive Management Strategy do not 

require any changes in the Morse methodology for estimating annual timber sale offer levels. In particular, the 

Strategy limits the land area within which the Tongass timber program may operate, not the level of volume to 

be planned or offered for sale. The Morse methodology was updated, however, to incorporate new derived 

demand projections from a study described later in this section (Brackley et al). 
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The Role of the Forest Service’s Pacific Northwest Research Station in Estimating Demand: 

As mentioned above, the first Pacific Northwest Research Station study of demand for timber from 

the Tongass was completed in 1990. As explained in Chapter 3 of the Final EIS for the 2008 Forest 

Plan Amendment, a second report with updated projections was issued in 1994, after one of 

Southeast Alaska’s two pulp mills closed in 1993. When the last remaining pulp mill closed in 1997, 

the projections were updated again in the spring of 1997. It was these draft projections that were 

erroneously interpreted in the 1997 Final EIS and ROD for the Revised Tongass Forest Plan. 

The Ninth Circuit court found that, because of the error in interpreting the 1997 market demand 

projections, the 1997 Final EIS failed to provide decision makers and the public with an accurate 

assessment of information relevant to evaluate the Tongass Plan. The court further found that, had 

the accurate market demand forecast and related potential employment and earnings information 

been used, an alternative may have been selected with less environmental impact and in less 

environmentally sensitive areas. 

The Pacific Northwest Research Station prepared a new forecast of market demand for timber from 

the Tongass National Forest, Timber Products Output and Timber Harvests in Alaska: Projections 

for 2005-25, Allen M. Brackley, Thomas D. Rojas, and Richard W. Haynes, 2006 (Brackley et al.). 

This study projects the demand for timber from the Tongass,17 derived from the demand in Pacific 

Rim markets for the end products manufactured from that timber. The Brackley et al. study revises 

projections made in the three previous reports, and reflects changes in Pacific Rim markets and the 

Alaska forest products sector over the last 10 years. 

The study analyzes trends over a historical period of 40 years to forecast trends over 20 years in 

three key parameters: 

1. The level of forest products imports in Pacific Rim nations. Based on other research 

regarding these markets, the Brackley et al. study projects that Pacific Rim imports of sawn 

wood products will increase over the next 20 years. 

2. The share of those markets that will be supplied by North American forest products 

producers, which the study projects will remain constant. 

3. The share of North American exports to the Pacific Rim that will come from Alaska. The 

analysis examines four alternative assumptions regarding future trends of the Alaskan share 

of North American exports to the Pacific Rim. 

Each of these parameters influences demand for timber from Alaska. An increase in any one of 

them will increase demand in Alaska, if other influences remain constant. Likewise, a decrease in 

any of these parameters will decrease demand in Alaska, other things equal. Estimated trends in 

these three parameters result in projected demand for forest products from Southeast Alaska over 

two decades; other assumptions had to be made to convert these estimates into demand for timber 

from the Tongass National Forest. All of these assumptions are described in the study. Based on 

these assumptions, the study projects the market demand for timber from the Tongass National 

Forest under four different scenarios for the future of the Alaska wood products industry. As 

explained in Chapter 3 of the Final EIS, these scenarios are as follows: 

Scenario 1—Limited Lumber Production. The goal of this scenario is to depict the situation the 

industry has faced over the last several years. It assumes no change in the Alaskan share of North 

American exports to the Pacific Rim, and no change in the North American share of Pacific Rim 

imports. Thus, the only increase in demand is a gradual rise resulting from growth over two decades 

in Pacific Rim imports, which are assumed to return to the levels of Japanese imports in 1997. It 

assumes there will continue to be very little market for two decades for low-grade sawlogs harvested 

from the Tongass, and no market for utility logs. The lack of a market for low-quality material (lowgrade sawlogs and utility volume) raises the operating costs of Alaskan sawmills per unit of product, 

 

17 The report projects demand for timber from Alaskan national forests. Because the Chugach National Forest, 

the only other national forest in Alaska, has no commercial timber program, demand for national forest timber in 

Alaska equates to demand for timber from the Tongass. 
Record of Decision

32

making it more difficult for them to compete in global markets with their counterparts in the Pacific 

Northwest and Canada. 

Scenario 2—Expanded Lumber Production. In this scenario, some form of demand stimulus is 

assumed, such that Alaskan producers’ market share of North American exports to the Pacific Rim 

rises somewhat, returning to a level experienced in the last decade. Such a demand stimulus could 

come from an industry marketing program, capital investment to make existing sawmills in Alaska 

more efficient, a change in policy, or some other event that enhances the competitive position of 

Alaskan producers relative to their competitors in the continental United States, or a combination of 

such developments. Other assumptions under this scenario are the same as under Scenario 1. 

Scenario 3—Medium Integrated Industry. In this scenario, events are assumed to occur that 

stimulate demand and develop a market for low-quality material, such that Alaskan producers’ 

market share of North American exports to the Pacific Rim rises more quickly than under Scenario 2. 

Development of a market for low-quality material is referred to as an integrated industry, because all 

of the material resulting from timber harvest would be processed into marketable products. This is 

displayed as the construction of a medium-density fiberboard (MDF) plant, but the authors make it 

clear that an MDF plant is only one way a use for low-quality material could develop. 

Scenario 4—High Integrated Industry. This scenario also assumes demand-stimulating events 

resulting in the development of a market for low-quality material. It also assumes that the Alaskan 

market share of North American exports to the Pacific Rim rise steadily over two decades. 

The Brackley et al. study displays the alternative projections of derived demand for timber from the 

Tongass National Forest in Table 3 of the report. For the first two scenarios, which assume no 

market for low grade sawlogs and utility volume, the figures in that table includes sawtimber only. 

For the two integrated industry scenarios, the projections include total volume, including both 

sawlogs and utility. Utility volume must be cut down along with higher-quality timber even if there is 

no demand for it. It is the total volume of timber cut on the Tongass that is of most interest, in part 

because environmental effects result from total volume cut. In addition, any comparison of 

scenarios must be based on comparable figures. Accordingly, the table below (from Chapter 3 of 

the Final EIS) shows Brackley et al. projections for all four scenarios in terms of total volume: 

Recent Developments: The Brackley et al. study was published in July 2006. In March 2007, I 

approved a new policy under which timber purchasers may ship to the lower 48 states unprocessed 

certain small-diameter and low-quality logs harvested from the Tongass, up to 50 percent of the 

volume harvested on each sale. This interstate shipments policy places purchasers of Tongass 

National Forest timber sales on a more level playing field with their counterparts in the Lower 48, 

where there is no restriction on interstate shipments of any timber harvested from National Forest 

System lands. This policy creates a market opportunity for low-quality material that the Brackley et 

al. study assumed would not be utilized under scenarios 1 and 2. While it is still early in the 

implementation of the new policy, we expect that full implementation of it over the next few years will 

make Alaska forest products producers more competitive with their counterparts in the Lower 48 

States, because it creates a market for low grade and small diameter sawtimber and possibly for 

utility volume. That may allow Alaska producers to increase their share of domestic forest products 

markets, which would stimulate demand for timber from the Tongass without the construction of new 

processing facilities in Southeast Alaska, until adequate volume is available to do so. 
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Table 3 

Volume of Tongass National Forest Timber that Must be Cut to Supply Derived 

Demand Reported in Brackley et al. (Million Board Feet) 

Projected National Forest Timber Harvest—Alaska 

(MMBF; includes Sawlog, Utility, and Shipments from Alaska)1 

Year 

Scenario 1. 

Limited Lumber 

Scenario 2. 

Expanded Lumber

Scenario 3. 

Medium Integrated 

Scenario 4. 

High Integrated 

2007 49.8 61.9 67 67 

2008 49.8 66.4 139 139 

2009 51.3 72.4 151 151 

2010 52.8 78.5 166 166 

2011 52.8 84.5 184 184 

2012 54.3 90.5 204 286 

2013 55.8 98.1 204 291 

2014 57.3 105.6 204 295 

2015 58.9 113.2 204 299 

2016 58.9 122.2 204 303 

2017 60.4 131.3 204 308 

2018 61.9 140.3 204 313 

2019 63.4 150.1 204 317 

2020 64.9 163.0 204 325 

2021 66.4 175.0 204 333 

2022 67.9 187.1 204 342 

2023 69.4 200.7 204 351 

2024 70.9 215.8 204 360 

2025 72.4 230.9 204 370 

Notes: 

1 These figures include total volume that would need to be cut to meet the demand projected by Brackley et al. 

The Pacific Northwest Research Station recently completed an addendum to the Brackley et al. 

study,18 which responds to public comments on the 2006 study, and events since that study was 

completed. The conclusion of the Addendum states that: 

Given the Region 10 shipment policy, the restarting of the veneer mill, and the success of 

Alaska producers in niche or specially markets, our current appraisal is that demand for 

national forest timber in Alaska is on a trajectory more similar to the scenario 2 (expanded 

lumber production). The down side of this development is, however, that part of the harvest 

is moving to mills outside southeast Alaska that have the technology to produce high 

volumes from small material. In our projections we assumed that the new technology would 

move to southeast Alaska. Regardless, the changes have the potential to create higher 

returns to the mills in southeast Alaska. Challenges still remain with the utilization of utility 

logs due to a limited fiber market. Until such markets evolve, it is difficult to see the 

evolution of an integrated industry characteristic of scenarios 3 and 4. 

Other Studies: As described in Chapter 3 of the Final EIS, the Forest Service has considered other 

reports and analyses related to demand. These include a study of installed mill capacity completed 

by the McDowell Group et al for the Southeast Conference in 2004; recent sales and harvest figures; 

and estimates of the minimum timber volume required by various processing facilities made by the 

Juneau Economic Development Council and a subcommittee of the Tongass Futures Roundtable. 

These indicators offer a wide range of estimates of market demand for timber from the Tongass 

National Forest. While I considered all of these indicators, I relied most heavily on the Brackley et al. 

 

18 Brackley, Allen M. and Haynes, Richard W. 2007. Timber Products Output and Timber Harvests in Alaska: 

An Addendum. Res. Note PNW-RN-XXX. Portland, OR: U.S. Department of Agriculture, Forest Service, 

Pacific Northwest Research Station. XX p. 
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study, and the Addendum to that study, because they are the only peer-reviewed scientific analyses 

of market demand for Tongass timber, and because they are the only studies that estimate demand 

derived from demand for end products. As described in the section of this ROD on the need for an 

integrated forest products industry in Southeast Alaska, the studies by the McDowell Group and the 

Juneau Economic Development Council are most helpful in considering what the supply needs for 

such an industry would be. 

Public Input. We received numerous comments from the public regarding timber supply and 

seeking to meet market demand. Some reviewers expressed the view that market demand for 

timber from the Tongass National Forest is 360 MMBF of economic timber volume, that recent 

harvest levels reflect solely supply constraints, and that selecting any alternative with an ASQ below 

360 MMBF would unnecessarily constrain the growth of the timber industry, resulting in significant 

adverse consequences for the economy of Southeast Alaska. 

I believe the most likely demand scenario to develop over the next 15 years is for annual market 

demand to reach 187 MMBF by 2022. The Brackley et al. study describes significant challenges for 

the industry in reaching Scenario 4, under which market demand is projected to reach 360 MMBF in 

2024 and 370 MMBF in 2025. The Addendum to that study reiterates the challenges that make 

scenarios 3 and 4 unlikely to occur. Among these are a resolution of the supply constraints related 

to appeals and litigation, and an investment climate perceived as favorable. Other reviewers point 

out that timber operators in Alaska have considerably higher labor and transportation costs and face 

other competitive disadvantages relative to their counterparts in the Lower 48 States, which 

negatively affects the investment climate in the Alaska forest products sector. In addition, the 

studies most often cited to support the assertion that market demand for Tongass timber is 360 

MMBF were based almost exclusively on mill capacity rather than derived demand for manufactured 

products. The Brackley et al. study is the only derived demand study. Accordingly, I view the other 

studies more as analyses of timber supply needed to operate current and potential future mills, 

rather than projections of market demand. 

For all these reasons, I believe that the ASQ of the selected alternative will provide an opportunity for 

the growth of an integrated and competitive timber industry over the next 10 to 15 years. Moreover, 

if the timber industry grows more rapidly than anticipated in the next few years, such that demand 

exceeds the average annual ASQ of 267 MMBF, existing procedures are flexible enough to respond 

to this possibility. ASQ is a ceiling on the amount of timber that may be sold over a ten-year period. 

While it is most often expressed as an average annual figure, the ASQ of the amended Forest Plan 

is 2.67 billion board feet for the next decade. Thus, if less than the average annual figure of 267 

MMBF is sold in the next five years, the difference could be added to the sale quantity for the 

remainder of the decade, up to the 10-year limit of 2.67 billion board feet. 

If the demand for timber has been substantially underestimated, the forest planning process includes 

procedures for analyzing what is known as departure from the established ASQ ceiling, to determine 

whether harvesting above the ASQ level would better meet multiple-use objectives (see Forest 

Service Manual 1926.15 and Handbook 2409.13). These procedures include several criteria or 

conditions in which evaluation of departure from the ASQ would be warranted. Such consideration 

would be done through the normal forest planning process, which includes public involvement. One 

of the conditions listed is when implementation of the ASQ could have a substantial adverse impact 

in the economic area in which the forest is located. For example, if the level of timber harvest were 

to increase to the point where the cumulative amount of timber sold approached the ASQ, there may 

be insufficient additional sale volume to support an expansion of the industry, should an expansion 

such as a new processing facility be proposed. If this were regarded as too disruptive to the local 

economy, the Handbook allows for consideration through the forest planning and public involvement 

process of an alternative that departs from non-declining flow requirements. Preliminary analysis 

performed as part of this Amendment process has shown that a departure volume of at least 310 

MMBF per year (3.1 billion board feet for 10 years) in the second decade is achievable without 

compromising sustained yield principles in future decades. 

I am also aware of concerns that timber demand has been overestimated, and that adopting an 

alternative with an ASQ substantially higher than recent harvest levels could allow timber harvest 
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and road construction in roadless areas perceived as more environmentally sensitive and therefore 

worthy of protection. The Timber Sale Program Adaptive Management Strategy is designed to 

address that concern by limiting harvest in Phase 1 to the lower quality roadless areas and deferring 

development activities in the higher quality roadless areas until such time as the actual harvest 

levels indicate a need to allow development in these areas. A more detailed description of how 

higher value roadless areas are protected at each phase of the Strategy is included in the next 

section of this ROD. The main point, however, is this: by adopting the Timber Sale Program 

Adaptive Management Strategy we have eliminated the potential harm to more environmentally 

sensitive areas from overestimating long-term market demand for timber. I am convinced that it is 

impossible to estimate the long-term market demand for Tongass timber with complete precision and 

accuracy. I am equally convinced that by adopting the Strategy, those difficulties no longer matter 

very much in choosing among alternatives. I feel secure in selecting Alternative 6, with an ASQ well 

above recent timber harvest levels, because the Timber Sale Program Adaptive Management 

Strategy will ensure that, at whatever level timber is harvested over the next 10-15 years, such 

harvest will be limited to the lowest value roadless areas possible. 

Conclusion 

In 1997, the Regional Forester concluded his analysis of demand issues as follows: 

Market demand is volatile; the projections done by the [Pacific Northwest Research] Station 

scientists have changed considerably each time they have been updated. Different 

economists will often make different projections of future demand because they often make 

different assumptions about the future (see Brooks and Haynes, June 1994, Timber 

Products Output and Timber Harvests in Alaska: Projections for 1992-1010, General 

Technical Report, PNW-GTR-334). Demand also will be influenced by whether or not 

businesses choose to invest in new wood-processing industries in Southeast Alaska over 

the next decade. Such decisions will be determined in part by investors’ subjective 

evaluations of the certainty with which they can rely upon the Tongass as a reliable source 

of timber. 1997 ROD, page 25. 

These statements are still applicable today. 

As I review Table 3, I see annual market demand estimates that range from 50 to 139 MMBF in 

2008; and from 68 to 342 MMBF in 2022. As discussed above, the Pacific Northwest Research 

Station economists who developed the demand projections believe the most likely outcome is 

Scenario 2. That suggests it is most reasonable to expect an annual demand of approximately 187 

MMBF in 2022 unless the industry becomes fully integrated in the interim. It is this last figure that I 

found most instructive and useful for guiding my decision. As described in other sections of this 

ROD, I believe the selected alternative avoids conflicts with other goals, such as environmental 

preservation (especially wildlife viability) or recreation. The ability of the selected alternative to meet 

these other goals gives me the assurance I need to select Alternative 6, which allows the projected 

level of long-term demand to be met. 

Need for an Integrated Industry 

An integrated forest products industry is one that includes processing facilities and markets for all 

types of logs from timber harvest operations conducted in the area, and for byproducts such as chips 

that result from processing those logs into lumber or other products. Such integration substantially 

enhances the economic efficiency of a regional industry as a whole, and the competitive position of 

all producers relative to their counterparts in other areas. Southeast Alaska has not had an 

integrated industry since the closure of the region’s pulp mills in the 1990s. Those mills processed 

utility logs, for which little or no local market has existed since those mills closed. Utility volume must 

still be cut down, primarily for safety reasons. The lack of a local facility to process utility volume 

means timber purchasers are required to cut and handle logs that they must often leave in the 

woods. Thus, some of the material harvested is not utilized; producers’ operating costs are 

increased per unit of material they do process; and the industry’s competitive position is diminished. 
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Consequently, the lack of an integrated industry increases the economic incentive to harvest highvolume timber stands disproportionately in order to make timber sales economic. 

The lack of facilities in Southeast Alaska to process low-grade and small-diameter material also 

makes it more difficult to conduct commercial thinning of young-growth timber stands. Because 

funding for pre-commercial thinning projects has historically been insufficient to meet the need, 

commercial thinning is the most feasible way to improve wildlife habitat quality and restore other 

ecological values in areas previously harvested. Some of these areas have significant restoration 

needs because they were harvested decades ago under standards considerably less protective than 

they are today. The absence of processing facilities in Southeast Alaska for the small-diameter 

material from these stands makes such restoration more difficult to accomplish. 

Further, an integrated industry could enhance the quality of life in Southeast Alaska by providing for 

a sector of sustainable, year-round, family-wage jobs in rural, resource-dependent communities. 

When added to existing industries such as recreation and nature tourism, commercial and 

recreational fishing, and government employment, an integrated wood products industry could 

contribute to a more stable social infrastructure. This includes schools, hospitals, libraries and 

various service industry amenities like hotels and restaurants that support a greater quality of life for 

Alaska residents. 

Consequently, re-developing an integrated industry is an important part of the ecological, economic 

and social components of sustainability. Timber production has been one of the missions of the 

National Forests since enactment of the Organic Administration Act in 1897. If we are to sustain this 

industry in Southeast Alaska, we must provide opportunities for local processors to expand and 

integrate enough to compete more effectively in world markets. Integration would also enhance 

ecological sustainability by reducing the amount of material now left in the woods and facilitating the 

transition to an industry based more on young-growth stands. For all these reasons, I believe it is 

important to provide opportunities for the re-establishment of an integrated forest products industry 

in Southeast Alaska, capable of processing all types of timber products available from the Tongass. 

Having determined that it is important to provide an opportunity for the timber industry to become 

more integrated, the question arises as to what supply from the Tongass National Forest would be 

needed to accomplish that objective. There are many sources of information on this subject, and I 

considered them all. The Brackley et al. study indicates that a partially integrated industry would 

generate a market demand for timber from the Tongass of 204 MMBF in 2022, and a fully integrated 

industry would demand 342 MMBF. 

As mentioned in the market demand section of this ROD, a recent analysis prepared for the 

Southeast Conference—“Timber Markets Update and Analysis of an Integrated Southeast Alaska 

Forest Products Industry” (McDowell Group et al. 2004)—also studied the supply needed to support 

an integrated timber industry in Southeast Alaska. That study considered installed capacity of 

Southeast mills, projected a harvest volume that would allow the mills to operate at an efficient level 

assuming the existence of an integrated industry, and concluded that a minimum of 200 MMBF total 

harvest would be required annually from the Tongass National Forest. However, the most efficient 

use of timber from the Tongass would most likely include other processing facilities, such as a 

veneer mill. The industry would be most efficient with at least two of each type of manufacturing 

facility because this would foster competitive bidding for materials and labor. Depending upon the 

types of facilities, this could require an annual harvest of 350 MMBF or more from all sources of 

wood. On December 30, 2006, the McDowell Group responded to a request by Southeast 

Conference to clarify and update key findings from the 2004 report. They concluded the study done 

in 2004 was still valid, including the estimate that 350 MMBF or more would be required to support 

an integrated and competitive industry. 

The report prepared by Juneau Economic Development Council and an effort by a Tongass Futures 

Roundtable Subcommittee also estimate the minimum timber volume required by various processing 

facilities based on their potential capacity. The estimated sawmill volume is approximately 66 

percent of existing mill capacity (138 MMBF annually), based on the four largest existing sawmills in 

Southeast Alaska, with some allowance for smaller mills. The minimum estimated annual volume 

necessary to supply a veneer plant is 30 MMBF of sawlogs, with 80 to 100 MMBF of No. 3 sawlogs 
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and utility logs required to support an MDF or bioenergy facility. Using these projections, a total of 

248 MMBF to 268 MMBF is the minimum annual supply necessary to support an integrated industry. 

The State of Alaska has also provided information related to the supply of timber needed from the 

Tongass to support the reestablishment of an integrated industry. In the comments provided by the 

State on the Draft EIS, the Governor recommends the Tongass provide a minimum of 168 MMBF of 

economic sawlog timber to support reestablishment of an integrated industry.19 When the utility 

volume associated with this harvest level is accounted for, this equates to an economic (or NIC I) 

annual harvest of approximately 200 MMBF from the Tongass. The NIC I portion of the ASQ of the 

amended Forest Plan is 238 MMBF annually, which is sufficient to meet the needs identified by the 

State. 

As I consider all of this information regarding the supply needs of an integrated industry, I conclude 

that the amended Forest Plan will provide an opportunity for such an industry to be reestablished in 

Southeast Alaska. Alternatives 1 and 2 of the Final EIS would foreclose that option; Alternative 3 

could meet it only during periods of strong markets, when the NIC II volume becomes economically 

viable. However, potential investors in additional processing facilities must make their decisions 

based on long-term projections that include entire market cycles. Therefore, a reliable annual supply 

of at least 200 MMBF of economic timber would be needed from the Tongass to meet the objective 

of providing an opportunity for the reestablishment of an integrated industry. None of the 

alternatives with an ASQ lower than the amended Forest Plan’s meet that criterion. 

Minimizing Effects on Roadless Areas 

This issue was described in the EIS for the 2008 Forest Plan Amendment as key issue 1. As with 

many other issues regarding management of the Tongass National Forest, protecting roadless areas 

is a topic with a long history and many complexities. Consequently, we begin this discussion with 

terminology, then the history, before describing how the Final EIS, the selected alternative, and the 

Timber Sale Program Adaptive Management Strategy respond to this issue. 

Terminology. The following terms are used in this ROD in discussing roadless issues: 

Roadless Area: The term “roadless area” is a generic term that is sometimes used to refer to all 

areas without roads. (The Final EIS uses the term this way, to include all such areas.) For the 

purpose of this ROD, however, it is used to refer only to inventoried roadless areas to simplify the 

discussion. 

Inventoried Roadless Area: An undeveloped area typically exceeding 5,000 acres that meets the 

minimum criteria for wilderness consideration under the Wilderness Act. 

History. The Wilderness Act of 1964 required the Secretary of Agriculture to inventory all roadless 

areas within the National Forest System to determine which of them should be designated as 

Wilderness. Generally speaking, roadless areas must be at least 5,000 acres, or adjacent to 

existing wilderness, to be eligible for such designation. The Forest Service has long recognized that 

not all roadless areas are of equal ecological, scenic, or recreational value. Accordingly, the agency 

developed the Wilderness Attribute Rating System as the process to rate roadless areas according 

to their natural integrity, scenic quality, opportunities for solitude, and primitive recreation 

opportunities. The NFMA implementing regulations later incorporated the inventory requirements 

into the forest planning process. Lands identified through these procedures are referred to as 

Inventoried Roadless Areas. 

A comprehensive inventory of roadless areas on the Tongass that meet the Wilderness Act’s 

minimum criteria was completed in 1996 as part of the development of the 1997 Forest Plan. This 

inventory identified about 9.4 million acres of roadless land on the Tongass in 110 inventoried 

 

19 “Economic timber” is defined as: A fair market value sale of timber wherein the average purchaser can meet 

all contractual obligations, harvest and transport the timber to the purchaser’s site, and have a reasonable 

certainty of realizing a profit from the sale. 
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roadless areas. No inventory is completely accurate for long, however, for a variety of reasons. 

National Forest System lands are sometimes conveyed to non-federal parties, such as conveyances 

to Alaska Native corporations under the Alaska Native Claims Settlement Act. Non-federal lands 

within National Forest boundaries are sometimes acquired by the Forest Service, most often through 

exchange for other Federal lands. Roadless areas also become developed, primarily through timber 

harvest and road construction allowed under the Forest Plan. Finally, geographic information 

system data are updated periodically. Consequently, inventories conducted only a few years apart 

can yield different results. 

Inventories of roadless areas on the Tongass illustrate these points. The Forest Service updated the 

1996 inventory in 2000 as part of the development of the Roadless Area Conservation Rule 

(Roadless Rule), published in 2001. The 2000 inventory identified about 9.3 million acres. The 

inventory was updated again in 2003 as part of the development of the Supplemental EIS regarding 

potential wilderness recommendation; this inventory identified about 9.6 million acres of the Tongass 

as roadless areas. The Final EIS for the 2008 Forest Plan Amendment updates the 2003 inventory, 

and identifies 9,514,185 acres in 109 inventoried roadless areas on the Tongass. A map of these 

roadless areas is available on the CD containing the Final EIS, and on the internet through the 

Forest’s website at www.fs.fed.us/r10/tongass/.

Treatment of the Roadless Issue in the Final EIS, Forest Plan, and Timber Sale Program 

Adaptive Management Strategy. As discussed in the section of this ROD on the alternatives 

considered, the protection of higher value roadless areas was a paramount consideration in the 

development of the alternatives analyzed in detail in the Draft EIS. The Forest Service rated each of 

the 109 inventoried roadless areas on the Tongass using the Wilderness Attribute Rating System. 

Special consideration was also given to areas proposed for wilderness during congressional 

consideration of TTRA, and to areas allocated to non-development LUDS by the Under Secretary of 

Agriculture in the 1999 ROD that was later vacated by the court. The results of that evaluation were 

used to exclude higher value roadless areas from development LUDs of each alternative as much as 

possible, so that timber harvest and road construction activities allowed under each alternative 

would avoid higher value roadless areas to the extent practical, given the balance of multiple use 

objectives of each alternative. 

Refinement of the Alternatives: During the public comment period on the Draft EIS, many reviewers 

recommended that timber harvest and road construction be confined to the portions of the forest 

where roads have already been constructed, so that all currently roadless areas would remain 

undeveloped. Many respondents recommended specific roadless areas be protected from 

development. Some conservation organizations, such as The Nature Conservancy, developed their 

own rankings of watersheds on the Tongass and offered lists of areas that they recommend for 

protection from development. Nearly all of these are within roadless areas. 

Following the public comment period on the Draft EIS, the Forest Service reviewed six different 

ranking systems and lists of areas recommended for protection that represent a wide variety of 

approaches to identifying higher value areas. These include: 

1. The list of High Value Community Use Areas developed by the Alaska Department of Fish 

and Game. 

2. The 18 Areas of Special Interest identified by the Under Secretary of Agriculture in the 1999 

ROD. 

3. Roadless areas identified by the U. S. Fish and Wildlife Service as having outstanding or 

important fish and wildlife values. 

4. Watersheds identified by the Southeast Alaska Conservation Council as Tier 1 or Tier 2 

watersheds. 

5. A list of Conservation Priority Watersheds identified by The Nature Conservancy and the 

Audubon Society and provided in comments on the Draft EIS. 

6. Roadless areas and their relative ranking based on the Wilderness Attribute Rating System. 
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While there is considerable commonality among these lists, there also are some significant 

differences. These differences demonstrate that there is no single definitive process or criterion by 

which to judge the value of individual roadless areas. Accordingly, the Forest Service took all of 

these rating systems and lists into account in developing the Final EIS and the Timber Sale Program 

Adaptive Management Strategy. The Forest Service also considered logistical considerations, such 

as the proximity of roadless areas to developed lands, to account for social and economic values as 

well as biological values in the consideration of roadless values. During this analysis, the Forest 

Service identified three general categories of roadless areas, based largely on how frequently they 

are included in the above ranking systems: 

• Lower Value Roadless: These lands are relatively small areas, and usually located within or 

near developed landscapes. They often lack the resource features and values found in 

larger and more isolated roadless areas. Because of their smaller size and proximity to 

developed landscapes, they often are less manageable as a roadless area by themselves, 

and can often be accessed by logical extensions of existing road systems. These areas 

usually appear on no more than 1 or 2 of the ranking lists described above. For example, 

the 16,000-acre East Zarembo Roadless Area on Zarembo Island is long and irregular in 

shape, is substantially affected by surrounding developments, and does not have high 

ecological or social values when compared to larger and more isolated roadless areas. 

• Moderate Value Roadless: These areas are generally larger and often include portions with 

higher ecological or social values. Examples include high value watersheds, high scenic 

resources, or high recreational values. These areas usually appear on 3 or 4 of the ranking 

lists described above. The southern end of the South Kupreanof Roadless Area is a good 

example, in which the southwestern corner associated with Rocky Pass has very high 

scenic values while most of the remainder has lower values. 

• Higher Value Roadless: These areas are often larger and usually have very high ecological 

and social values. These areas usually appear on 5 or 6 of the ranking lists described 

above. The 190,000 acre Cleveland Roadless Area is a good example.

As described in Chapters 2 and 3 of the Final EIS, the alternatives respond to public concerns 

regarding protection of roadless areas in a progressive fashion. Alternative 1 would allow no 

scheduled timber harvest or road construction in any roadless area. As alternatives progress to 

higher levels of allowable timber harvest and road construction, more roadless areas are allocated to 

the development LUDs, starting with lower and some moderate value roadless areas in Alternative 

2, then incorporating mostly lower and moderate value roadless areas in Alternative 3, and more 

higher value roadless areas in alternatives 4 through 7. 

Further Protection of Higher Value Inventoried Roadless Areas through the Timber Sale Program 

Adaptive Management Strategy: Based on my review of this information and the analyses 

presented in the Final EIS, I believe the selected alternative minimizes the adverse environmental 

effects on roadless areas while still seeking to meet market demand for timber from the Tongass. 

Just over 3 quarters of inventoried roadless acres are included in the 13.3 million acres of nondevelopment LUDs. The Forest Plan allocates 24 percent of the inventoried roadless acres to 

development LUDs. Due to the additional protection offered by the standards and guidelines that 

apply to these LUDs, only 3 percent of the land in inventoried roadless areas would be included in 

the suitable land base. Finally, even if timber were harvested and roads constructed at the 

maximum rates allowed under the Forest Plan for 100 years, at least 80 percent of the Tongass 

would still remain in an undeveloped condition without roads. 

I know some will still be concerned, however, that since the ASQ of the Forest Plan is considerably 

higher than recent harvest levels, some higher value roadless areas may still be unnecessarily 

harmed by including them in the development LUDs before the projected increase in long-term 

demand actually materializes. The Timber Sale Program Adaptive Management Strategy that I am 

adopting today was designed specifically to remedy these concerns. A discussion of how the 

Strategy was developed follows below. 
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After the public comment period on the Draft EIS, the Forest Service reviewed each of the roadless 

Value Comparison Units (VCUs, areas of land delineated for planning purposes) in the development 

LUDs of Alternative 6. Each of these VCUs that contains suitable lands was compared to each of 

the six lists of higher value roadless areas described above, to develop a comprehensive sense of 

the ecological, recreational, and social value of each of these VCUs. As previously mentioned, 

logistical challenges related to timber economics were also considered. Through this process, each 

VCU was assigned to one of the three phases of the Timber Sale Program Adaptive Management 

Strategy. Phase 1 of the Strategy is similar to Alternative 2, in that the scheduled timber sale 

program would be confined to areas already developed and to lower value roadless areas. Phase 2 

of the Strategy, which would be implemented only if the level of timber harvest reached 100 MMBF 

annually for two consecutive years, is similar to Alternative 3, in that the scheduled timber sale 

program would be allowed to operate in some moderate value roadless areas. Phases 1 and 2 are 

also comparable to Alternatives 2 and 3, respectively, regarding the maximum sustainable level of 

timber harvest that could be supported from the amount of suitable land they include. 

Only in Phase 3, which would only be implemented if timber harvest levels reach 150 MMBF for two 

consecutive years, would the scheduled timber harvest program be allowed to operate in higher 

value roadless areas. In this fashion, the Timber Sale Program Adaptive Management Strategy 

offers an extra level of protection for higher value roadless areas, and a more robust response to 

concerns related to allowing such areas to be affected by development activities prematurely. 

I want to reiterate that there is no single definitive process or criterion by which to judge the value of 

individual roadless areas. That is why the Forest Service took into consideration the ratings of other 

organizations to help us design a strategy that seeks to avoid areas most often listed as high value. 

Treatment of Areas of Special Interest to the Public under the Forest Plan and Adaptive 

Management Strategy: As described above, several conservation organizations and numerous 

individuals have provided input recommending protection for specific areas. The areas mentioned 

most frequently are listed below, with a description of how each area is treated under the selected 

alternative and the Adaptive Management Strategy. The map of the areas included in each phase of 

the Timber Sale Program Adaptive Management Strategy can be found on the on the compact disc 

of the Final EIS and is also available on the internet at www.fs.fed.us/r10/tongass/. 

Port Houghton – Public comments on this area requested protection for the southern portion of the 

Windham - Port Houghton Roadless Area, all of the Fanshaw Roadless Area, and the western tip of 

the Spires Roadless Area in the South Arm of Faragut Bay, especially Port Houghton, the salt chuck 

at the head of the North Arm of Port Houghton, Sanborn Canal, and Faragut Bay. The majority of 

these areas remain in non-development LUDs under the amended Forest Plan. While some areas 

within the Windham – Port Houghton and the Fanshaw Roadless Areas are allocated to 

development LUDs, they are included in the Phases 2 and 3 of the Timber Sale Program Adaptive 

Management Strategy, with VCUs 790 and 840 in Phase 3. This means that until the actual level of 

timber harvest on the Tongass reaches 100 MMBF for two consecutive fiscal years in Phase 1, then 

150 MMBF for two consecutive years in Phase 2, no timber sales could be planned for these areas. 

Thomas Bay part of Spires Roadless Area –The development LUDs in the southern tip of the 

Spires Roadless Area and other lands near the southern portion of Thomas Bay are mostly roaded 

and are included in Phase 1 of the Strategy. The development LUDs (VCUs 4830 and 4840) near 

the northern part of Thomas Bay are mostly undeveloped and are included in Phase 2. 

Kake Community Use Area and Kuiu Island – Kuiu Island and the surrounding smaller islands are 

important to the residents of Kake, especially the coastal areas near Kake. Areas most often 

associated with higher values include the Keku Islands, Kadake Bay and Creek, Port Camden, 

Rocky Pass, and the East Kuiu Roadless Area on the south and east side of Kuiu Island. 

The Keku Islands and the lands adjacent and near Kadake Bay are in non-development LUDs. 

Lands adjacent to the Keku Islands in VCU 3990 have been placed in Phase 2 of the implementation 

strategy. This means that until the actual level of timber harvest on the Tongass reaches at least 

100 MMBF for two consecutive fiscal years, no timber sales could be planned for these areas. 
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The adjustments to small old-growth reserves in this area also resulted in a continuous block of nondevelopment LUDs from Kadake Bay to Saginaw Bay. Additionally, about 23 miles of Kadake Creek 

and other major tributary streams that flow into Kadake Bay were recommended in 1997 for 

designation as a Recreational River, and that recommendation is not being changed. Recreational 

River LUDs generally provide recreation opportunities in a pleasing, though modified, free-flowing 

river setting, while allowing timber harvest, transportation and other developments. 

Port Camden has development LUDs on both sides of the bay, with the west side having past timber 

management activities and the east side mostly undeveloped. In response to public comments, the 

west side of Port Camden in VCU 4200 is in Phase 2 of the implementation strategy. The east side 

of Port Camden in VCU 4200 is placed in Phase 3, so no timber sale could be planned for this area 

unless timber harvest levels reach 150 MMBF for two consecutive fiscal years in the future. 

Rocky Pass is nearly entirely in non-development LUDs, including the east side of the peninsula 

between Rocky Pass and Port Camden. The East Kuiu Roadless Area located to the south of the 

developed areas on the east side of the Island is placed in Phase 3. 

The remaining development LUDs on northern Kuiu Island are included in Phase 1 of the Strategy, 

primarily because the area is mostly developed with good infrastructure and timber volumes, all of 

which are important for the current timber industry. I believe the overall mix of land use designations 

for Kuiu Island, when combined with the deferral of many parts of the development LUDs on Kuiu to 

Phases 2 and 3 of the Adaptive Management Strategy, provides a good balance of the commodity 

and noncommodity values and uses for Kuiu Island. 

Upper Tenakee Inlet – In the 1997 Forest Plan, the non-development LUDs along the shoreline 

areas, including several inlets and bays, often resulted in blocked access or significantly increased 

costs of access to the development LUDs in the uplands. In reviewing the small old-growth reserves 

in upper Tenakee Inlet, biologists, logging engineers and managers took a hard look at this area to 

see if a better balance of protecting the high scenic and habitat values associated with the area 

while also addressing the high development costs could be made. In response, VCUs 2240 and 

2250 in the upper end of the Inlet were converted to the Semi Remote Recreation LUD to address 

the scenic values and to strengthen the biodiversity connection, or pinch-point, with the northeastern 

lobe of Chichagof Island as well as the Neka Bay area. Both development and non-development 

LUDs along the west side of the Inlet were consolidated and the development LUDs in VCUs 2260, 

2290, and 2320 are scheduled for Phase 3 of the Strategy. VCU 2310 is scheduled for Phase 2 

because it is easily accessible by extending the current road system from VCU 2300. 

Ushk Bay/Poison Cove – This area of very high public interest is located in the Hoonah Sound 

Roadless Area. Issues in this area relate to Native Allotment claims, subsistence, timber sale 

economics, the proximity of the area to Sitka, high cultural and traditional use values, scenic, and 

other uses. If development projects are proposed in the area, the amended Plan provides 

reasonable options and flexibility to address the high values and potentially competing uses of the 

area. In recognition of this area’s complexity and high values, it is included in the Phase 3 of the 

Strategy, which means that no timber sale can be planned until actual harvest levels on the Tongass 

reach 150 MMBF for two consecutive fiscal years. 

West Duncan Canal – The lands all along the west side of Duncan Canal are in non-development 

LUDs in recognition of the high recreation and scenic resources associated with the area. This width 

of non-development LUDs ranges from about 1 mile in width to several miles inland, such as up the 

Castle River drainage. The inland portions of the northern part of the area where development is 

allowed are included in Phase 1 of the Strategy because they are easily accessible from currently 

roaded areas in the interior of the island by extending existing road systems. Development LUDs 

associated with the southern part of the Canal in VCU 4350 are deferred until Phase 3. Most of the 

remaining land in development LUDs on the southern portion of the Island is in Phase 2, because 

these areas would be easily accessible by extending the existing road system in the interior of the 

Island to the north. The amended Forest Plan provides a well-balanced mix of LUDs that fully 

recognize the many values associated with the lands along the west side of Duncan Canal while 

allowing some timber harvest if and when it is needed. 
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Honker Divide – Honker Divide is a key part of the old-growth conservation strategy for the northern 

half of Prince of Wales Island, with over 200,000 acres in non-development LUDs. The strategy 

includes connections of old-growth habitat in non-development LUDs from the Karta Wilderness 

through Honker Divide and the Sarkar Lakes area and through the Calder Holbrook LUD II area to 

the northern tip of Prince of Wales Island. To further support the protection of this connective area, I 

am including the eastern portions of VCU 5750 and 5780 in Phase 2 of the implementation strategy. 

VCU 5740 is also deferred to Phase 2, which means no timber harvest may be planned until the 

actual harvest levels on the Tongass reach 100 MMBF for two consecutive fiscal years. 

Gravina and Bostwick Inlet – Bostwick Inlet is located on the south and east end of Gravina Island 

near Ketchikan. Many residents of the nearby communities of Ketchikan, Saxman, and Metlakatla 

use this area for recreation and subsistence purposes. Much of the land in the area surrounding 

Bostwick Inlet were previously allocated to development LUDs and no changes were proposed in the 

2007 draft amended Forest Plan. 

Many reviewers of the Draft EIS recommended no timber harvest be allowed on Gravina Island. In 

their comments on the Draft EIS, the Ketchikan Indian Community (KIC) expressed serious concerns 

with timber harvest activities previously proposed on Gravina Island, and referred to ongoing 

collaborative efforts to resolve those concerns. KIC recommended changing the LUDs in the 

Bostwick area from development to non-development. Consequently, I am modifying Alternative 6 

as displayed in the Final EIS to change the LUD allocations in the Bostwick Inlet area to a 

combination of non-development LUDs. I am also deferring timber harvest in the development LUD 

to the west and south of Bostwick inlet to Phase 3 of the Timber Sale Program Adaptive 

Management Strategy. Only if the timber industry expands to levels of harvest sufficient to 

implement this last phase could timber sale planning be done for this area. 

Cleveland Peninsula – The Cleveland Roadless Area has been the center of land use debates for 

some years. Recreation use of Cleveland Peninsula is high, especially on the eastern side of the 

peninsula north of Ketchikan. Some mineral exploration is ongoing on the northern side of the 

peninsula. The Forest Plan allocates the entire southwestern portion, roughly one-half of the area, 

to non-development LUDs. The remainder of the peninsula is allocated to a mix of development and 

non-development LUDs that recognize the old-growth habitat, scenic, and timber values of the area. 

I believe the mix of LUDs and associated standards and guidelines in place with the Forest Plan are 

appropriate to address the high values associated with Cleveland Peninsula. It is not the 

appropriate time to change the mix of LUDs here, primarily because of the amount of suitable and 

available timber included in the development LUDs. However, virtually all of the development LUD 

areas on Cleveland Peninsula are included in Phase 3 of the Strategy, except for VCU 7210 where 

the Emerald Bay project was previously proposed, which will be in Phase 2. No further timber sale 

planning in this area may be done until the actual harvest levels on the Tongass reach 100 MMBF 

for two consecutive fiscal years. 

Salmon Bay Lake – Most of the Salmon Bay Lake area on northern Prince of Wales Island is in a 

congressionally designated LUD II area. Relatively small portions of the watershed outside of the 

LUD II area are in development LUDs, especially in VCUs 5340 and 5341. These portions are 

included in Phase 2 of the Strategy, which means that no timber harvest may be planned until the 

actual harvest level on the Tongass reaches 100 MMBF for two consecutive fiscal years. 

Basket Bay and Kook Lake – This area was identified by The Nature Conservancy, the U.S. Fish 

and Wildlife Service, and others as having very high fish and wildlife values. The area to the north of 

Kook Lake in VCU 2390 is developed while the area to the south in the remainder of VCUs 2390 and 

2400 is not. The development LUD portion of the southern area is included in Phase 2 of the 

Strategy. 

Sitka Community Use Area – The development LUDs in the immediate area surrounding Sitka 

have been heavily developed during past timber management activities. Many residents of Sitka 

have expressed a desire for a greatly reduced level of future timber harvest or none at all. Therefore 

the majority of the development LUDs have been placed in Phase 2 of the Strategy, which means 
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that no timber harvest may be planned until the actual harvest level on the Tongass reaches 100 

MMBF for two consecutive years. 

Kruzof Island – The developed portion of northern Kruzof Island has become popular for recreation 

users from Sitka, especially taking advantage of the roaded access of the area. The Nature 

Conservancy and Audubon Alaska assessment efforts also recognized this area for its multiple use 

values and recommended the area have an integrated management emphasis. All of the Timber 

Production LUD in this area has been changed to Modified Landscape, which better reflects the 

recreation and scenic values of the area while also providing opportunities for smaller timber sales in 

the future. The area is also included in Phase 1 of the Strategy. 

Problems Identified by the Ninth Circuit Court of Appeals 

As described on page one of this ROD, the Ninth Circuit Court of Appeals identified several 

inadequacies with the 1997 ROD and Final EIS for the Forest Plan. Remedying those problems is 

the primary purpose and need for the 2008 Amendment. The section of this ROD regarding market 

demand explains how the Forest Service has corrected the errors made in 1997 by developing new 

projections of market demand. Having corrected those previous errors related to market demand, 

the court’s supposition about choosing an alternative with less environmental effects and in less 

sensitive areas does not apply to this decision. Nonetheless, the discussions above on roadless 

areas and the Timber Sale Program Adaptive Management Strategy explain how the Forest Service 

has taken extra steps to ensure that potential adverse effects on areas perceived as environmentally 

sensitive have been minimized. The discussion below explains why I believe that Alternative 6, 

coupled with the Tongass Timber Sale Program Adaptive Management Strategy, best responds to 

the remaining problems identified by the court, those dealing with the range of alternatives 

considered in the Final EIS, and the cumulative effects of disproportionate harvest of high-volume 

timber on non-federal land. 

Range of Alternatives 

The Court of Appeals for the Ninth Circuit found two deficiencies related to the alternatives 

considered in the 1997 Final EIS for the Revised Tongass Forest Plan. The Forest Service had not 

considered alternatives that set the ASQ equal to the correct demand scenarios. In addition, each of 

the 10 alternatives considered in the EIS allocated some roadless areas to LUDs that allow 

development; the EIS omitted an alternative that allocated less undeveloped land to the 

development LUDs. 

Setting ASQ of the Alternatives Equal to Projected Demand of the Scenarios. In the 1997 Final 

EIS, one alternative had no scheduled timber program, so the ASQ for that alternative was zero. 

With that exception, the ASQ of all alternatives considered in 1997 exceeded demand projections 

under the low and middle market scenarios of the 1997 demand study. For the 2008 Forest Plan 

Amendment, I considered all the demand projections of the Brackley et al. study, as displayed in 

Table 3, which I consider to be the best available science related to market demand projections. As 

previously discussed in the market demand section of this ROD, I found the projections for 2022 

most helpful in guiding my decision to approve the amended Forest Plan, since that is the end of the 

NFMA planning cycle of 10-15 years, and three of the four demand scenarios estimate that demand 

will grow every year throughout the 20-year period of the study. Table 4 below compares the 

demand projections for 2022 with the ASQ for the second decade of each alternative considered in 

detail in the Final EIS. 
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Table 4 

Projected Demand1 in 2022 Under each Brackley et al. Scenario Compared to 

Second-decade Average Annual ASQ for each Final EIS Alternative 

Projected 2022 demanda (MMBF). 

Second-decade ASQ for each alternative 

(MMBF). 

Scenario 1 – 68 Alternative 1 – 49 

Scenario 2 – 187 Alternative 2 – 152 

Scenario 3 – 204 Alternative 3 – 203 

Scenario 4 -- 342 Alternative 4 – 360 

 Alternative 5 – 267 

Alternative 6 – 267 

 Alternative 7 – 421 

Note: 

1 These figures include total volume (sawlog and utility) that would need to be harvested to meet the demand 

projected by Brackley et al. 

Alternatives 1-4 were designed to correspond with scenarios 1-4, respectively. Alternative 1 was 

designed to reflect scenario 1, with modifications to better match recent annual harvest levels 

(approximately 50 MMBF) and to avoid harvesting in roadless areas and areas on Kuiu Island. 

Because of these modifications, the Alternative 1 ASQ is actually 19 MMBF (28 percent) below the 

projected demand of Scenario 1. The ASQ of Alternative 2 is 25 MMBF (19 percent) below the 

projected demand of Scenario 2. The purpose of Alternative 2 is to display an alternative that 

restricts development activities to lower value roadless areas. Alternative 3 differs from Scenario 3 

by only 1 MMBF. The ASQ of Alternative 4 is 18 MMBF (5 percent) above the projected demand of 

Scenario 4. These figures do not match exactly, partly because the second decade ASQ extends 20 

years from the decision, while the projected demand represents an annual figure 15 years out. 

Alternatives Allocating all Roadless Areas to Non-Development LUDs. As mentioned at the 

beginning of this section, the Ninth Circuit found the 1997 Tongass Forest Plan Revision Final EIS 

deficient because all of the alternatives considered in detail allocated some roadless areas to LUDs 

that allow development; the 1997 Final EIS did not include an alternative that allocated less 

undeveloped land to the development LUDs. 

To remedy this deficiency, the Final EIS for the 2008 Tongass Forest Plan Amendment considers 

Alternative 1, which allocates no roadless areas to the LUDs that allow development, as shown in 

Chapter 2 of the EIS. In the interest of clarity, I point out that some activities that might be 

considered “development” may sometimes be allowed in many of the non-development LUDs. The 

most significant of these is the construction of a State highway or utility system connection between 

communities in Southeast Alaska, or between the region and the continental road system and power 

grid. Such development could be allowed in many “non-development” LUDs, including areas that 

are currently roadless. Such development is expected to be quite rare, and would require additional 

project-level NEPA analysis and decision-making before actual construction could begin. 

The Forest Service received several comments from the public concerning the range of alternatives 

considered in the Draft EIS. The most frequent concern expressed was that the Draft EIS did not 

include an alternative with an ASQ lower than 50 MMBF. Several reviewers recommended such an 

alternative be included in the Final EIS, because they believe that timber harvest levels are likely to 

fall below that level. 

As discussed in the section of this ROD on alternatives considered, and in Chapter 2 of the Final 

EIS, all alternatives displayed in all the EISs developed for the 1997 Forest Plan were reviewed for 

consideration in detail in the Draft and Final EIS for the 2008 Tongass Forest Plan Amendment. As 

displayed in Table 2 of this ROD, Alternative 1 of the 1996 Revised Supplement to the Draft EIS for 

the Revised Tongass Forest Plan was analyzed in detail in that EIS, and had an ASQ of zero. This 
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alternative was also considered in detail in the 1997 Final EIS. This alternative was not considered 

in detail in the Draft or Final EIS for the 2008 Forest Plan Amendment for several reasons: 

• The previous consideration in the 1996 and 1997 EISs was deemed adequate. 

• The concern being addressed by alternatives with a low ASQ—avoiding development in 

roadless areas—is addressed by Alternative 1 of the 2008 Final EIS, because this 

alternative avoids timber harvest in roadless areas. 

• Information from a variety of sources (e.g., mill capacity utilization reports and 

communications from operators) gave rise to concerns that the current timber industry in 

Southeast Alaska could not survive if an alternative were selected with an ASQ equal to or 

lower than current harvest levels. 

Cumulative Effects of Disproportionate High-Volume Logging 

The Court of Appeals for the Ninth Circuit found several deficiencies in the 1997 Final EIS for the 

Tongass Plan related to the cumulative effects of disproportionate high-volume logging (a practice 

sometimes called “highgrading”) on non-federal land.20 Specifically, the court found that the 1997 

EIS failed adequately to consider such cumulative effects because the EIS did not include: (1) a 

catalog of past projects; (2) a discussion of how those projects (and differences between the 

projects) have harmed the environment; (3) a discussion of the connection between individual nonfederal high-volume harvests and the prior environmental harm from those harvests; and (4) an 

assessment of the potential impacts of reasonably foreseeable continued highgrading in the future. 

The court also found that a cumulative effects analysis in a new programmatic EIS is necessary for 

the Forest Service and the public to make a rational evaluation of the proposed action balancing the 

competing goals of timber harvest, environmental preservation, and recreational use in the Tongass. 

Catalog of Past Projects on Non-Federal land. Because information about specific projects on 

non-federal land was unavailable in 1997, the cumulative effects analyses in the 1997 EIS assumed 

that all non-national forest land within the boundaries of the Tongass National Forest had no habitat 

value and therefore would not contribute to wildlife viability on the Tongass. In other words, nonfederal land was analyzed as if it contained no vegetation whatsoever. In response to the court’s 

concern regarding the lack of a catalog, the Forest Service worked with the State of Alaska and 

Sealaska Corporation, the regional Native corporation for Southeast Alaska, to develop a 

comprehensive catalog of each timber harvest project conducted on State land and Alaska Native 

corporation lands. 

Appendix E of the Final EIS provides a catalog of past harvest by breaking down all past harvest in 

Southeast Alaska according to landowner category within each of 23 biogeographic provinces and 

identifying the acreage and decade(s) of harvest for each. In addition, the appendix summarizes the 

data provided by the State of Alaska regarding past harvest activities in Southeast Alaska permitted 

under the Alaska Forest Resources and Practices Act. 

While Appendix E of the Final EIS complies with the court’s direction to develop a catalog of past 

projects on non-federal land, this is only a small part of the analysis contained in the Final EIS of the 

potential cumulative effects of the disproportionate harvest of high-volume timber on non-federal 

land. For example, better mapping of current stand conditions on all land ownerships in Southeast 

Alaska has improved the analysis of effects of past timber harvest throughout the region. In 

addition, because complete information on stand types associated with early harvests was not 

documented or available, a method of estimating the proportion of different types in past harvests 

was developed and applied to all past harvest areas. The methodologies used to quantify the 

amounts and types of past harvest and project future harvests on both federal and non-federal lands 

are described in Appendix B of the Final EIS. 

 

20 While this ROD uses the term “highgrading” as it is used in the Ninth Circuit Court’s opinion, it is a silvicultural 

term correctly defined as selective removal of the biggest and highest value trees from a stand. Over time, this 

can reduce the overall genetic quality of the stand. 
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The Biodiversity section of the Final EIS uses the Appendix E information along with geographic 

information system analyses and other information to describe in detail the total amount of past oldgrowth harvest on National Forest System (NFS) lands and non-NFS lands, and the amount within 

each of 23 biogeographic provinces that make up Southeast Alaska. In addition to the total amount 

of productive old-growth harvest, the amount of high-volume and large-tree old-growth harvest, the 

amount of harvest on karst terrain, and other descriptors are provided and discussed. In addition, 

projections are made in order to quantify future harvest levels for each of these categories and the 

effects of cumulative harvests are evaluated. 

These analyses show that 92 percent of the original old growth still exists on NFS lands. When nonNFS lands are also considered, this percentage drops to 87 percent for all of Southeast Alaska. 

Similarly, 87 percent of the original high-volume old growth and 80 percent of the original large-tree 

old growth still exists on NFS lands, but 70 and 68 percent of these categories exist for all of 

Southeast Alaska, respectively. 

Even if timber were harvested for 100 years at the maximum rate allowed under the amended Forest 

Plan, 83 percent of the original productive old growth, 79 percent of the original high-volume old 

growth, and 72 percent of the original large-tree old growth on NFS lands would still remain. If nonNFS lands are also considered, these percentages would decline to 76 percent, 70 percent, and 57 

percent. 

High-volume productive old growth currently makes up approximately 41 percent and large-tree old 

growth makes up 11 percent of the productive old growth on the Tongass. These two categories 

make up the same percentages within the reserves of the conservation strategy. Overall, and once 

standards and guidelines such as riparian and beach protection are applied, about 90 percent of the 

existing high-volume old-growth and 89 percent of the existing large-tree old growth would be 

protected under the amended Plan. This is a conservative estimate, based on the assumption that 

maximum harvest levels allowed under the ASQ are implemented over many decades. 

As discussed in previous sections of this ROD, however, the duration of this decision is 10 to 15 

years, not 100 years. The analyses described above also show that, if timber were harvested at the 

maximum level allowed by the amended Forest Plan for 15 years, 89 percent of the original productive 

old-growth forest would remain on the Tongass (97 percent of the existing old growth); as would 84 

percent of the original high-volume old growth (97 percent of the existing high-volume old growth) and 

77 percent of the original large-tree old growth (96 percent of the existing large-tree old growth). 

This high level of protection for high-volume old growth is in part a direct result of the design criteria 

for the makeup of the reserves, which is just one way in which the 1997 Forest Plan was responsive 

to the disproportionate harvest levels of the past, including harvests on non-NFS lands. For 

example, Appendix K to the Forest Plan (1997 and 2008 Amendment), which establishes criteria for 

old-growth reserves, has specific target levels for high-volume old growth. Additionally, the 

adjustments to the small old-growth reserves and the expansion of other non-development LUDs 

included in this decision add about 149,000 acres to the reserve system relative to the 1997 Forest 

Plan, as amended. These acreages include 45,000 additional acres of productive old growth, 

27,000 acres of which are high-volume old growth (59 percent), and 11,000 acres of which are largetree old growth (25 percent). 

Therefore, past timber harvest, including past disproportionate harvest of high-volume stands, has 

been considered in the design of old-growth reserves and in the development of the conservation 

strategy. Effects analyses for all resources were based on the environmentally conservative 

assumption that all scheduled suitable lands would be harvested at some point over the next 100-

150 years. Because most of the Tongass lands suitable for timber harvest are undeveloped, it is 

reasonable to schedule higher-volume stands, higher in proportion to their existence, for the purpose 

of offsetting high infrastructure development costs. Once the infrastructure is in place, lesser volume 

stands can be accessed at a higher rate because the cost of access is less. Doing otherwise 

creates deficit timber sale projects needing supplemental funding to offset infrastructure costs. 

Appropriation legislation for the last several years has not allowed the offering of deficit timber sale 

projects nor provided funding levels necessary to offset initial entry costs. 
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Comparison of Alternatives 

Wildlife Viability 

Long-term viability for wildlife species has been extensively studied and analyzed, and is discussed 

in detail in the Final EIS (Chapter 3, Biodiversity and Wildlife sections and Appendix D). Panels of 

experts were formed to assess viability risks to key species that could result from each alternative 

considered in the 1997 Forest Plan Revision EIS. These ratings were transferred to the alternatives 

in the 2007 Draft EIS, based on the four alternatives that are similar between the two documents and 

similarities in the amount of timber harvest allowed. Based on this analysis, the alternatives fall 

roughly into three groups. 

Compared to the other alternatives considered in detail, Alternatives 1, 2 and 3 provide the highest 

degree of assurance that the habitat needed for viable, well-distributed wildlife populations would be 

maintained, and that subsistence, recreational, and commercial uses of wildlife resources would be 

sustained. This is due largely to more non-development LUDs and refinements to small old-growth 

reserve boundaries that protect more high quality old-growth habitat, as compared to Alternative 5 

(the 1997 Forest Plan). 

Alternatives 4 and 7 provide the least assurance that the habitat needed for long-term viability of all 

wildlife species would be maintained because more acres are in development LUDs and there would 

be poorer distribution of high quality old-growth reserves in Alternative 4, and none in Alternative 7. 

The U.S. Fish and Wildlife Service, in their comments on the Draft EIS, expressed concerns that 

these alternatives would fail to ensure viable, well-distributed populations and recommended these 

alternatives be eliminated from further consideration. 

Alternatives 5 and 6 provide a moderate to very high degree of assurance that, even if development 

occurs at maximum allowable levels for 100 years, there would still be sufficient habitat to support 

long-term viability of wildlife species because there would be a good to very good distribution of high 

quality old-growth reserves over the long term. Alternative 6 includes improvements to the small oldgrowth reserve system that Alternative 5 does not have, and includes more total acreage in reserves 

than Alternative 5. Alternative 6 as displayed in the Final EIS would apply the revised version of the 

goshawk nest standards and guidelines and the new forest-wide legacy standard and guideline. I 

want a Forest Plan that, in conjunction with all the other multiple-use goals and objectives, has a 

relatively low level of risk—or conversely, gives me good assurance that the habitat needed to 

sustain viable populations of wildlife would be maintained over the long term. As explained in 

greater detail in the section of this ROD regarding wildlife habitat and biodiversity, Alternative 6—

with the changes specified in this ROD--provides this assurance and retains the major components 

of the original conservation strategy. Alternatives 4 and 7 may not provide adequate assurance of 

meeting viability requirements.

Socioeconomic Considerations 

As was true in 1997, maintaining options for a variety of social and economic uses of the Tongass is 

another key factor in my decision. These social and economic uses range from continuing a timber 

harvest program that provides a sustainable supply of timber and other timber products to providing 

for subsistence opportunities and unspoiled settings for recreation and tourism. It is partly a matter 

of finding a balance, within a multiple-use context, of the many public uses and demands on forest 

resources, and partly not foreclosing options for the future to respond to changes in public needs, 

economic conditions, or new technologies as such changes develop. 

Alternatives 1 and 2 would not allow sufficient timber volume to meet the projected market demand 

under the scenario considered most likely to occur over the next 15 years, nor would they allow the 

development of an integrated timber industry. (See the market demand section of this ROD for a 

discussion of the scenarios depicted in the most recent study of demand for timber from the 

Tongass.) 
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Only Alternatives 4 and 7 could provide sufficient timber volume to meet the high integrated industry 

scenario, but with more trade-offs for wildlife habitat (described above), recreation opportunities and 

scenic quality, due to allocating 28 percent and 30 percent of the Tongass to moderate and intensive 

development LUDs, respectively. 

Alternatives 3, 4, 5, 6, and 7 could all provide sufficient timber volume to meet the medium integrated 

scenario, although Alternative 3 could not provide sufficient economic volume. While Alternative 3 

allocates 18 percent of the Tongass to moderate and intensive development LUDs, less than the 22 

percent in Alternative 5 and 21 percent in Alternative 6, it does not provide enough opportunity for 

growth of an integrated timber industry over the next 10 to 15 years, which limits the potential 

socioeconomic development of many rural communities within the Tongass National Forest. 

Recreation opportunities and scenic quality are very similar between Alternatives 5 and 6. 

Alternative 6 changes the wildlife habitat standards and guidelines to reduce their economic impact, 

which leads me to conclude Alternative 6 best balances competing values and uses of the Tongass 

National Forest. 

Present net value calculated for each alternative represents one efficiency measure for those costs 

and benefits that can be assigned monetary values, in this case timber, recreation and tourism and 

program management costs. Alternative 1 is estimated to have the highest present net value and 

Alternatives 4 and 7 the lowest, largely due to the high costs of operating timber programs in Alaska. 

The estimate of present net value for Alternative 6 is in the middle of the range of all the present net 

values for the seven alternatives considered. Given the failure of present net value to consider 

qualitative factors critical to accurately predicting net public benefits, and the ability of Alternative 6 to 

balance many competing values and uses of the Tongass National Forest, I find that Alternative 6 

currently provides the best strategy for maximizing net public benefits. 

Roadless Areas 

Alternative 1 does not allocate any inventoried roadless acres to development LUDs, and has the 

fewest acres suitable for timber harvest. Alternatives 4 and 7 are at the other end of the spectrum, 

with the greatest amounts of the existing roadless areas allocated to moderate and intensive 

development LUDs and suitable for timber harvest. 

Alternatives 2, 3, 6, and 5 show gradual increases in the acreage of existing roadless areas 

allocated to moderate and intensive development LUDs, with Alternative 6 slightly less than 

Alternative 5. With the Timber Sale Program Adaptive Management Strategy, I am confident that the 

highest value roadless areas within the suitable land base will be protected until needed to meet 

demonstrated growth and integration in the timber industry. Alternative 6 best provides the flexibility 

and balance to meet the competing demands for growth and for the protection of roadless character, 

recreation, and other socioeconomic values associated with roadless areas. 

Other Resources 

Alternatives 1, 2, 3, 5 and 6 are better than alternatives 4 and 7 in maintaining scenic quality and 

undisturbed settings, factors important to the continued expansion of the recreation and tourism 

industries, and to most Southeast Alaska communities. 

The abundance and distribution of the majority of subsistence resources (fish and marine 

invertebrates) would not be affected by any alternative. The analysis continues to suggest that deer 

habitat capabilities in the areas of the Tongass with heavier timber harvest may not be adequate to 

sustain current and future deer harvest levels under any alternative, and that increased competition 

for deer harvest may cause a significant possibility of a significant restriction in the future. 

This possibility of future restrictions resulting from changes in abundance and distribution of deer 

and increased competition would be lower for Alternatives 1, 2 and 3 and higher for Alternatives 4 

and 7 compared with Alternative 5 (the 1997 Forest Plan, as amended). Alternative 6 is the same as 

Alternative 5 because similar amounts of acres are proposed for timber harvest. 
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Compared to Alternative 5, all other alternatives expand the Mineral LUD overlay by approximately 

80,000 acres. None of the alternatives includes any changes to the management of mineral 

activities. No land ownership adjustments are proposed under any alternative and all alternatives, 

except Alternative 5, include recommending the Experimental Forest at Young Bay be replaced by a 

larger, more accessible Experimental Forest at Cowee and Davies Creek and that the Geologic 

Special Interest Areas be expanded by about 47,000 acres. 

Alternative 1, the “environmentally preferable” alternative, would result in the least adverse effects to 

the physical and biological environment. With timber harvest scheduled only along the existing road 

system and no development in roadless areas, it has the least effects of the alternatives considered. 

Accordingly, in comparison with other alternatives, it tends always to rate highest when levels of 

resource protection are a consideration. Conversely, when considering timber-related employment 

and community dependence on such employment; infrastructure development and new road access; 

or rural development in a multiple-use context, Alternative 1 generally ranks lowest. Therefore, I 

conclude that it does not provide an acceptable balance between the competing multiple use 

demands for environmental protection and human uses of the natural resources of the Tongass 

National Forest. For the same reasons, it also does not meet the objectives of ecological, economic, 

and social sustainability. 

Conclusion 

Given the many social and economic trade-offs inherent in national forest management, I find that 

Alternative 6 best balances the many interrelated environmental, social, and economic issues that 

arise when managing for multiple uses. 

Other Considerations 

In addition to responding to the decision by the Ninth Circuit Court of Appeals and the key issues 

described above, my decision is based on consideration of several other topics, including invasive 

species, management of young-growth forest stands, climate change, ecosystem services, 

transportation and utility corridors, cooperation with the State of Alaska, public input, areas of special 

interest, and the use of the best available science. 

Invasive Species 

The 1997 Forest Plan did not include the term invasive species. Nationally and regionally, the 

Forest Service is giving high priority to eliminating or preventing adverse impacts caused by invasive 

species. The amended Forest Plan includes new objectives and standards and guidelines that will 

enable the Tongass National Forest to carry out these relatively new national and regional priorities 

on the Tongass. As is true in other program areas, the extent to which these objectives can be met 

is dependent in large part on factors out of the control of the Forest Service, such as congressional 

funding allocations. 

Management of Young-Growth Forest Stands 

The management of young-growth forest stands is becoming more important as young trees located 

in previously harvested areas mature, and as interest grows in transitioning the timber industry in 

Southeast Alaska from one based on the harvest of old-growth forest stands to one based on the 

harvest of young growth. Young-growth forest stands are those that grow after the trees in an area 

have been removed by timber harvest activities or a natural disturbance event such as a landslide or 

windstorm. A substantial amount of new information has become available regarding the 

management of young-growth forests since the 1997 Forest Plan was adopted. For example, forbs 

and shrub populations are more extensive in thinned young-growth stands than was assumed in 

previous forest planning efforts. This information is relevant for the analysis of the effects of timber 

harvest on species like the Sitka black-tailed deer that feed on forbs and shrubs. Management 
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practices of young-growth forest stands, such as thinning, can substantially improve the forage for 

deer, and also promote better growth of the remaining trees for future timber harvest. Precommercial 

thinning involves cutting most of the small trees that naturally grow back in areas where the oldgrowth trees have been removed, usually about 15 to 25 years after the initial removal. When 

thinning is done at this stage, the young-growth trees removed are so small that that they usually 

have no commercial value, so it must be paid for by appropriated funds. Similarly, thinning of younggrowth stands that are 50 to 70 years old can yield commercially marketable trees—hence the name 

“commercial thinning”--while also improving forage for wildlife and higher timber yields in the future. 

Many organizations have encouraged the Forest Service to transition the timber program on the 

Tongass from one based on the harvest of old-growth forest to one that harvests young-growth 

stands. Such a transition would enhance the protection of old-growth forest habitat. 

For all of these reasons, I support the transition of the Tongass timber program to one based more 

on the harvest of young-growth stands. The amended Forest Plan has been carefully reviewed to 

ensure that it contains no provisions that might impede such a transition. Young growth could 

potentially comprise a substantial portion of the Tongass timber program in as little as three 

decades, with initial young-growth operations beginning in earnest by the end of the current planning 

cycle. The ultimate success of this effort, however, will depend on several factors, including 

investments by the timber industry in milling equipment designed for smaller young-growth trees, 

integration of the industry to effectively process all products harvested from the Forest, and funding 

decisions made by Congress. 

Climate Change 

Interest in climate change, and knowledge of this issue, have grown enormously over the last 

decade. The two broad questions relevant to the decision on the 2008 Forest Plan Amendment are 

the extent to which climate change might affect the natural resources of the Tongass National Forest 

and the uses of those resources, and the extent to which management of the Tongass could affect 

climate change. 

As discussed in Chapter 3 of the Final EIS, the effects of climate change on the natural resources of 

the Tongass are highly uncertain, especially over the long run, and likely to be small, especially over 

the next 10 to 15 years. While there is general agreement among scientists that the climate is 

warming, there is considerable uncertainty concerning the exact effects of climate change on the 

forests of Southeast Alaska and how best to deal with possible changes to the many resources on 

the Tongass. There is a risk that climate change may result in increased blowdown, increased tree 

mortality from insects and disease, increased fire frequency and severity, adverse effects on air 

quality, changes to vegetation, streams, fish and wildlife habitat, and subsistence and recreational 

uses of the National Forest. However, there is considerable uncertainty concerning specific 

predictions of how the climate may change, and even more uncertainty regarding the effects of 

climate change on the resources of the Tongass National Forest. 

Consequently, it is important for the Tongass to stay abreast of the evolving scientific information 

related to the effects of climate change. However, the state of current knowledge and the 

uncertainty about specific effects of climate change leads me to conclude that the best course of 

action today is continued management of the Tongass for resiliency in the face of uncertain but 

anticipated change. This will be done primarily by management of the Tongass as a mostly intact 

ecosystem with a robust monitoring plan that will allow for adaptive management intervention if and 

when effects of climate change are more certain. 

The same is true regarding effects on climate change of the alternatives analyzed in the Final EIS. 

For example, as described in the Climate and Air section of Chapter 3, the science regarding the 

effects of timber harvest on carbon sequestration is uncertain. Some studies suggest that timber 

harvest may increase the release of carbon to the atmosphere, which would tend to increase 

greenhouse gasses and global warming. Others indicate that timber harvest may increase the 

amount of carbon sequestered from the atmosphere. In either case, the effects are likely to be 

small, especially compared to other routine human activities. Accordingly, information on climate 

change is not essential to a reasoned choice among the alternatives displayed in the Final EIS. 
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For these reasons, the issue of climate change has played a limited, but important role in this 

decision in the context of monitoring. The Forest Service will continue to monitor potential effects of 

climate change through existing monitoring programs and through the Monitoring and Evaluation 

Plan. Existing monitoring programs include our Regional forest health program that monitors forest 

health changes related to insects, disease, pathogens and windthrow across Region 10, and the 

long-term forest inventory system. In addition, the Forest Plan’s monitoring and evaluation 

provisions have been updated to address the effects of all change, including climate change I 

believe these efforts will detect any significant effects of climate change on the Tongass. If such 

changes are detected, they will be addressed through existing planning procedures to determine 

whether changes in management of the Forest are warranted. 

Ecosystem Services 

Ecosystem services are those services and benefits provided by healthy ecosystems. They can be 

broadly defined to include consumptive uses, such as logging, fishing, and hunting, as well as other 

benefits associated with forests such as watershed services, soil stabilization and erosion control, 

improved air quality, climate regulation, carbon sequestration, and biological diversity. Ecosystem 

services are a topic of growing interest within the Forest Service, its partners and stakeholder 

groups. 

Some members of the public have expressed concerns that ecosystem service values are not 

adequately considered in decision-making processes because they are not valued on a par with 

goods and services that are traded in commercial markets. The Final EIS discusses different 

attempts to measure the value of ecosystem services. While ecosystem services values on the 

Tongass are undoubtedly high, there is uncertainty about the accuracy of these estimates. It is also 

difficult to determine how the alternatives differ in the level of ecosystem services provided. The fact 

that the Final EIS does not assign a monetary value to ecosystem services does not lessen their 

importance in the decision-making process. In fact, a large proportion of the Final EIS is devoted to 

assessing impacts to the forest resources that cannot be readily expressed in monetary terms. This 

decision takes these values into consideration. As previously mentioned, the undeveloped nature of 

the Tongass National Forest, and the ecosystem services provided by the Forest, will be adequately 

protected by the Forest Plan. Even if timber harvest and road construction were conducted at 

maximum allowable levels under the Forest Plan for 100 years, at least 80 percent of the Tongass 

would still be in a roadless, undeveloped condition. 

This Forest Plan Amendment also supports ongoing initiatives in Southeast Alaska to develop 

ecosystem services markets such as the Fuels for Schools program, thinning of young growth for 

wildlife habitat improvement, and implementation of practices and technologies to reduce the carbon 

‘footprint’ of Forest Service operations. 

Transportation and Utility System Corridors 

The Transportation and Utility System (TUS) LUD was originally developed as part of the 1997 Plan 

to: 

• Acknowledge the potential need for major highways or utility systems connecting 

communities in Southeast Alaska with each other, and connecting the region to the 

continental highway system and power grid. 

• Identify likely locations for such connections. 

• Facilitate construction of them. 

The Forest Plan does not, however, approve any of these projects. As with any other proposed sitespecific activity, construction of a TUS requires further project-level NEPA analysis and decisionmaking. During that process, all reasonable alternative routes must be considered, even those that 

may not be foreseeable at the programmatic, Forest Plan stage. Consequently, the objectives of the 

TUS LUD can be met without trying to identify on the LUD map every reasonable alternative route 

for every potential highway or utility system. 
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During the development of the EIS for the 2008 Forest Plan Amendment, State agencies and 

members of the public expressed concerns that not all potential TUS corridors were on the Forest 

Plan LUD map. Specifically, the Alaska Department of Transportation and Public Facilities 

(ADOT&PF) advised that several potential TUS routes identified in the Department’s Southeast 

Alaska Transportation Plan were not included in the Draft EIS map. In response to these concerns, 

the Forest Service added a potential utility route for the community of Pelican to the LUD map in the 

Final EIS, and made other minor changes. In addition, the Plan’s management direction for the TUS 

LUD has been clarified to improve its implementation, and to note that not all reasonable alternative 

routes for all potential TUS connections are—or can be--identified on the map. The Forest Service 

also will retain the information provided by ADOT&PF regarding alternative TUS routes in the 

planning record, to ensure this information will be available for any future land management 

decisions. 

Cooperation with the State of Alaska 

The Forest Service and the State of Alaska signed a Memorandum of Understanding (MOU) 

(January 28, 2006) to include the State as a cooperating agency in the development of the 2008 

Forest Plan Amendment. Under this MOU, the State has participated extensively throughout the 

planning process for the 2008 Forest Plan. This cooperative effort has been essential in clarifying 

and resolving many land management issues. Future cooperation is addressed under the 

implementation section of this ROD. 

Public Input 

As explained in Chapter 1 of the Final EIS, the 2008 Tongass Forest Plan Amendment is based in 

part on public input gathered over the course of many years during previous planning efforts, 

including the development of the 1997 Forest Plan, the 2003 Supplemental EIS, the National 

Roadless Rule and project-level NEPA analyses. Additional public input for the 2008 Amendment to 

the Tongass Forest Plan began in January 2006 when the Forest created a website specific to the 

amendment (www.tongass-fpadjust.net) and requested input on the amendment process. The 

Notice of Intent to prepare the EIS continued the process of gathering public input when it was 

published in the Federal Register in March 2006. Appendix A of the Final EIS summarizes the 

public input process that led to the development of the significant issues. 

The Draft EIS was released for public comment in January, 2007. Twenty-five public meetings were 

held. These meetings included 23 meetings in communities located throughout Southeast Alaska, a 

meeting in Anchorage, and an electronic public meeting held on the internet. These meetings 

included both an open house and a hearing. A total of 204 people provided formal testimony at 

these hearings. 

The 90-day public comment period was scheduled to end in mid-April but was extended an 

additional 18 days because of bad weather in Southeast Alaska and to give people more time to 

comment on the changes made to small old-growth reserves. Approximately 84,500 comments 

were received during the 108-day public comment period. Approximately 98 percent of the 

responses were form letters. Comments were received from all 50 states and 89 other countries. 

This reflects the importance of the Tongass at the national and international level. 

All comments were carefully reviewed, coded, and consolidated into logical comment summaries. 

Responses were developed to each comment summary and revisions made to the analysis or 

Forest Plan as appropriate. These comment summaries and responses can be found in Appendix H 

of the Final EIS. 

Review of the public comments resulted in Alternative 1 being modified between the Draft and Final 

EIS, with all roadless areas and other high interest areas, such as Kuiu Island, being removed from 

the suitable timber land base. The results of the public involvement and comment process led to a 

number of other improvements, clarifications and updates between the Draft and Final EIS. 
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Tribal governments and Alaska Native corporations were also consulted throughout the planning 

process. They participated in the hearings described above and their comments are included in the 

summaries developed for Appendix H. 

There have been numerous collaborative meetings and discussions held between groups with an 

interest in the Tongass. The Tongass Futures Roundtable, a group of 35 diverse stakeholders, 

organized many of these discussions with the intent of finding common ground on Tongass issues. 

These discussions continue and I am encouraged by the willingness of participants to work towards 

solutions that will benefit all of Southeast Alaska. 

Finally, during the course of the development of the 2008 Forest Plan Amendment, the Forest 

Service has had thousands of informal contacts with people interested in the Amendment. The 

Forest Service approach has been thoroughly open and transparent. I am proud of the extent to 

which the Forest Service has involved the public in this process. 

The Use of Science in the Planning Process 

This Forest Plan Amendment builds upon the work previously done to revise and amend the Forest 

Plan. The management direction in the 1997 Tongass Forest Plan was the result of significant 

collaborative efforts throughout Southeast Alaska, the State, and across the nation. The 1997 Plan 

was developed collaboratively with other Federal and State natural resource management agencies, 

including the National Marine Fisheries Service, the Alaska Department of Fish and Game, the U.S. 

Fish and Wildlife Service, the Environmental Protection Agency, and the Forest Service Pacific 

Northwest Research Station. Representatives of the last three agencies were full members of the 

1997 Tongass Forest Plan Revision interdisciplinary planning team. The process for developing the 

1997 Forest Plan included peer reviews of the conservation strategy and review by panels of wildlife 

experts to ensure the Plan would be scientifically credible and resource sustainable. 

The conservation strategy was the subject of a technical interagency workshop held in April 2006, 

which was designed to review and evaluate the conservation strategy in light of new science 

developed since the 1997 Plan. The workshop brought together scientists from a variety of 

organizations, including the Forest Service, the State of Alaska, other agencies, universities, and 

others, along with Tongass land managers, to report on and discuss current research relative to the 

conservation strategy, as well as experiences over the past 10 years relative to its implementation. 

The new science discussed at the workshop was fully considered throughout the planning process 

and in the modifications to the Plan. 

The development of the EIS and the amended Forest Plan has been based on consideration of the 

best available science throughout the planning process. This has occurred by comprehensively 

reviewing available scientific research and other information relevant to the resource areas 

addressed. In addition, the specific modeling and analysis methods used were documented in 

Appendix B of the Final EIS or within other appendices or individual resource sections. Scientific 

sources relied on were cited, responsible opposing views were discussed, incomplete and 

unavailable information was acknowledged, and scientific uncertainty and risk was addressed in 

relevant portions of the Final EIS. 

The amended Forest Plan provides for the sustainability of the resources of the Tongass National 

Forest, while directing the coordination and management of multiple uses of national forest land 

resources in cooperation with the State of Alaska, such as outdoor recreation, timber, mining, 

wildlife, fish, watershed, and wilderness. Recognizing that conditions on the Tongass National 

Forest do not remain static, that new information is constantly surfacing, and that considerable 

scientific uncertainty is associated with many conclusions regarding resource effects, the amended 

Forest Plan embraces an adaptive management approach. The Timber Sale Adaptive Management 

Strategy is a good example of this approach. 

The Tongass National Forest worked closely with the Pacific Northwest Research Station to ensure 

consideration of the best available science throughout the process of amending the Tongass Forest 

Plan. The Station provided various science products to the Tongass Planning Team. Station 
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scientists conducted four advisory science consultations on the topics of timber demand analysis, 

ecosystem services, and the use of deer models. Several Station scientists participated in the 2006 

conservation strategy review workshop to examine new science information relating to the 

conservation strategy, and to identify additional information needs for the Tongass Plan Amendment. 

The Station produced a revised timber demand analysis which was published in July of 2006 

(Brackley et al 2006). The Tongass Planning Team utilized the information from the new report, 

science consultations and the conservation strategy workshop in developing the Draft EIS. 

Following the release of the Draft EIS, the Pacific Northwest Research Station conducted six science 

reviews to determine if relevant science information was considered and reasonably interpreted with 

consequences, uncertainties and risks appropriately identified. Informal science reviews were 

conducted on timber demand analysis, vegetation mapping, young-growth management, carbon 

sequestration and climate change, and ecosystem services. A more formal review was conducted 

on the elements of the conservation strategy dealing with the Queen Charlotte goshawk, American 

marten, Sitka black-tail deer, northern flying squirrel and endemic mammals. Station scientists were 

asked by the Alaska Forest Association (AFA) to describe more fully the timber demand study. In 

response, the scientists met with AFA and held a workshop to explain their methodology. As 

additional follow up, Station scientists also crafted the addendum to the Brackley et al. study of 

timber demand to provide additional details and clarification. 

The Pacific Northwest Research Station provided input to Appendix D of the Final EIS, which deals 

with the science background, description of changes, assumptions and rationale for the old-growth 

conservation strategy, wildlife standards and guidelines, and wildlife viability components of the 

Forest Plan. The Station also provided input to Appendix G of the Final EIS, which describes how 

the Station’s market demand projections are used in timber sale planning. The Tongass Planning 

Team considered all the information from the science reviews, the timber demand addendum, and 

comments on Appendix D in compiling the Final EIS and ROD. A reconciliation table was developed 

to document how the science review input was considered in development of the Final EIS. The 

planners also met directly with Station representatives in July of 2007 to discuss the reconciliation of 

comments and seek additional feedback. The administrative record includes all science advisory 

consultation and science review comments provided by the Station, as well as the reconciliation 

demonstrating how the comments and information were used to inform the Final EIS and ROD. 

Based on the level of rigor employed in reviewing available science and in incorporating and 

documenting this information throughout the planning process, in addition to the involvement of the 

Pacific Northwest Research Station at every step of the planning process, I am confident that the 

Final EIS and this ROD thoroughly consider and use the best available science. 

Potential Land Adjustments 

Appendix C of the Final EIS has been updated regarding new developments relating to potential 

land adjustments that could affect the implementation of the Forest Plan. Conceptual proposals 

from the Trust Land Office, representing the Alaska Mental Health Trust Authority, and Shee Atika 

Corporation are discussed in Appendix C. Additionally, proposed legislation introduced since the 

Draft EIS was published warrants some discussion here. 

Two bills have been introduced in the U.S. House of Representatives that may affect lands within the 

Tongass National Forest, H.R. 3350, the Alaska Native Veterans Land Allotment Act and H.R. 3560, 

the Southeast Alaska Native Land Entitlement Finalization Act. Although a hearing was held by the 

House Natural Resources Committee in November, 2007 regarding these proposed bills, at this time 

no additional hearings or committee assignments have been identified and it is not clear whether 

these proposals will move further through the legislative process. Based on their current status, 

addressing the effects of these proposals relative to this Forest Plan decision is premature given the 

speculative nature of the prospects for legislative enactment. If at a later date one or both of these 

proposals become law, an analysis of the effects will be necessary to determine if a revision or 

amendment of the Forest Plan is warranted. 
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Land adjustments have been and will continue to be important considerations as the new Forest 

Plan is implemented. To continue to meet the conservation strategy and timber management goals 

and objectives of this Forest Plan decision, major discretionary land adjustment proposals will be 

considered if the proposed exchange of lands maintains the conservation strategy, ensures public 

access for subsistence uses, and at least a portion of the timber volume from the lands conveyed 

from the Tongass National Forest contributes to the timber manufacturing industry in Southeast 

Alaska. 

National Policy Considerations 

The Forest Plan reflects several aspects of national policy. Among the most important of these is 

the Forest Service Strategic Plan, developed under the Government Performance and Results Act of 

1993. 

In July 2007, the Forest Service completed a Strategic Plan for Fiscal Years 2007-2012, which 

provides direction to guide the entire agency in delivering its mission. Forest Service programs and 

budgets are aligned with the goals and objectives in this Strategic Plan which supplements the 

USDA Strategic Plan for Fiscal Years 2005-2010. Managing the Nation’s forests and grasslands 

requires the complex integration of several levels of planning and cooperation with State and local 

planning efforts. These levels are defined below. 

• Strategic planning takes place at the highest level and identifies strategic priorities for the 

agency that are implemented over a period of time through annual agency budgets. The 

strategic priorities are based on national assessments of natural resources and are 

responsive to social and political trends. 

• Business planning by national programs, regions, research stations, and the Northeastern 

Area translates the broad strategic direction into the regionally specific work that contributes 

to the agency’s mission. 

• Unit planning (e.g., land and resource management plans for national forests and 

grasslands) provides an inventory of resources and their present conditions on a particular 

management unit. This inventory, coupled with the desired future condition for the 

resources, is the basis for annual work planning and budgeting. 

• Annual work planning identifies the projects that all units propose for funding within a fiscal 

year. This level of planning involves the final application of strategic direction into a unit’s 

annual budget to move its resources toward its desired future condition. 

In addition, monitoring is essential to track resource conditions and human activities over time to 

effectively manage the Nation’s forests and grasslands. 

This amendment to the Tongass Forest Plan fulfills the unit planning level described above, and 

implementation will occur through the annual work planning level. In addition, the monitoring plan 

has been refined as the essential quality control mechanism that facilitates learning from Plan 

implementation. 

I find the amended Tongass Forest Plan to be not only consistent, but strongly supportive of the 

goals in the agency-wide Forest Service Strategic Plan, as follows: 

1. This decision continues to provide a balance between land stewardship services and 

meeting public demands for various uses of the Tongass National Forest. The updates and 

refinements in the Forest Plan multiple-use goals and objectives and management 

prescriptions include direction for rare plants, sacred sites, invasive species, and young 

growth management that will continue to restore, sustain and enhance the Forest’s 

ecosystems and related services. 

2. By keeping the ASQ at a level able to meet the possible future demands of an integrated 

industry, the amended Forest Plan helps maintain or create processing capacity and 

infrastructure in local communities. With the Timber Sale Program Adaptive Management 
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Strategy, I am confident that higher value roadless areas will remain intact unless timber 

harvest levels increase beyond 150 MMBF long enough to implement Phase 3 of the 

Strategy. 

3. While open space is not the same issue in Southeast Alaska as it is in other parts of the 

country, partnerships with the State, Tribes, Native Corporations, and local communities will 

continue to contribute to responsible land management across all lands. 

4. Continued use of the recreation opportunity spectrum to help identify and quantify different 

types of recreation settings on the Tongass National Forest will assure a mix of the highest 

quality outdoor opportunities and experiences. The sense of vastness, wildness and 

solitude will remain, with over three-quarters of the Tongass in natural or undeveloped 

LUDs, and opportunities for other users’ desires to have developed and easy access will 

remain or may be increased in the moderate and intensive development LUDs. 

5. Maintaining basic management capabilities relates to daily operations and accountability on 

the Forest, including continuing to cooperate with other Federal, State, Tribes, Native 

Corporations, local governments and private-sector partners. The objectives in the 

amended Forest Plan continue to emphasize opportunities for rural community and technical 

assistance. 

6. While engaging Urban America may not seem directly applicable to Southeast Alaska, the 

Tongass leadership will continue to engage partners and educators in development and use 

of conservation education materials during implementation of the Forest Plan. One of the 

recreation and tourism objectives continues to emphasize projects that facilitate community 

use or community connections, and another forest plan standard and guideline is to identify 

opportunities and priorities for interpretation of heritage resources for public education and 

recreation. Direction in the amended Forest Plan continues to encourage traditional 

American values such as conservation ethic, appreciation of nature, national and community 

pride, and national and community well-being, including the stability of lifestyle and 

character. 

7. To provide science-based applications, the amended Forest Plan continues the goal to seek 

out and promote research opportunities consistent with identified information needs 

described in Appendix B. Objectives for the nonwilderness national monument LUD 

continue to be to inventory, research, protect and interpret National Monument resources 

and make resource and research information about National Monuments available to other 

forest units where it may be beneficial. 

Means to Avoid Environmental Harm 

Mitigation Measures Adopted 

Extensive measures to avoid or minimize environmental harm were adopted in the 1997 Forest Plan. 

Based on 10 years of experience in implementing and monitoring these measures, many of them 

have been updated in the 2008 Forest Plan Amendment, as previously discussed. These measures 

include forest-wide standards and guidelines, and additional standards and guidelines for each land 

use designation. At a minimum, these standards and guidelines meet all requirements of applicable 

laws, regulations, and State standards. Mitigation measures are an integral part of the standards 

and guidelines. Singularly and collectively, they avoid, rectify, reduce, or eliminate potential adverse 

environmental impacts of forest management activities. Some more significant mitigation measures 

are the beach fringe and riparian buffer zones, and the network of old-growth reserves. Based on 

the analysis in the Final EIS, including the response to comments contained in Appendix H, I 

conclude that all practicable means to avoid or minimize environmental harm from the amended 

Forest Plan have been adopted. 

Mitigation Measures Not Adopted 

The State of Alaska recommended changes to a standard regarding protection of important brown 

bear foraging sites adjacent to salmon streams. Since 1997, this standard has required project-level 
Record of Decision 

57

planning teams to consult with the State to determine where such foraging sites exist, and where 

buffers of approximately 500 feet from the stream should be adopted, within which no timber harvest 

is allowed. The State recommended this be modified to mandate buffers of at least 500 feet on all 

anadromous streams. This change has not been adopted because brown bear populations are 

healthy, the analysis contained in the Final EIS indicates they will remain so, and monitoring 

information suggests the current standard is adequate. In addition, other standards and guidelines 

offer protection related to brown bear foraging sites. For example, the beach and estuary fringe 

standard and guideline requires no-harvest buffers 1,000 feet inland from beach vegetation. When 

applied on the ground, other existing standards often result in stream buffers of 500 feet in the lower 

reaches of salmon streams. For these reasons, I conclude that protection of brown bear foraging 

sites can continue to be ensured at the project level without additional requirements being added to 

the Forest Plan. 

The U.S. Fish and Wildlife Service recommended that goshawk nest buffers be increased from 100 

acres to 500 acres of productive old-growth habitat to protect active and alternate nest sites and 

post-fledging habitat from timber harvest. This measure was not adopted because the Service’s 

recent decision not to list the goshawk as a threatened or endangered species under the 

Endangered Species Act suggests that such action is not essential, and because the analysis 

contained in the Final EIS indicates that nest buffers, in addition to the other protective measures 

included in the Forest Plan, will provide adequate habitat for nesting and fledgling goshawks. 

Additional details on proposed changes to the Forest Plan, and the reasons why such proposals 

were not adopted, are contained in Appendix H of the Final EIS. 

Monitoring and Evaluation 

The Forest Plan includes a monitoring and evaluation plan to continually assess the effectiveness of 

the Forest Plan standards and guidelines. Monitoring results will be used to evaluate the 

assumptions used in developing the Forest Plan, and may be the basis for amendments or revisions, 

just as the information from the monitoring conducted since 1997 helped form the basis for this 

Amendment. The Forest Plan may be amended at any time if changes to the standards and 

guidelines are needed. Monitoring will also ensure that both forest-wide and land use designation 

standards and guidelines are being correctly applied. The monitoring program will include 

monitoring of timber harvest levels under the Timber Program Adaptive Management Strategy to 

determine if and when the timber program can move from one phase of the Strategy to another.21

In addition to the Forest Service, nearly all other State and Federal natural resource agencies, the 

academic community, and numerous organizations and individuals want to know more about the 

social, economic and ecological uses and values, including ecosystem services values, of the 

Tongass National Forest and the environment in which it is located. I believe there are many 

opportunities to better align and coordinate the interests, resources, and efforts of these groups in 

monitoring and evaluating the implementation of the Forest Plan. As previously mentioned, details 

of the monitoring program such as data gathering protocols will continue to be developed in 

consultation with all interested State and Federal agencies. 

Findings Related to Other Requirements 

The Forest Service manages the Tongass National Forest in conformance with many Federal laws 

and regulations. In this section we consider each of the major laws involved in this programmaticlevel decision. 

 

21 All scheduled timber harvest in a fiscal year will count toward the level needed to move the timber sale 

program to a higher phase. 
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National Environmental Policy Act 

NEPA requires that Federal agencies prepare detailed statements on proposed actions that 

significantly affect the quality of the human environment. NEPA’s requirement is designed to serve 

two major functions: 

• To provide decision-makers with a detailed accounting of the likely environmental effects of 

proposed actions prior to adoption. 

• To inform the public of, and allow comment on, such efforts. 

The Forest Service has developed, gathered, and reviewed an enormous amount of information 

regarding the potential effects of each of the alternatives considered in the Final EIS. This 

information expands and refines the data, analyses, and public input described in the NEPA 

documents associated with the 1997 Forest Plan, including the 1989 Analysis of the Management 

Situation (which has been updated as part of the 2008 Forest Plan Amendment and is contained in 

the planning record); the draft, supplemental, and final EISs leading to the 1997 ROD; documents 

associated with the 2003 Supplemental EIS; and the Draft and Final EISs for the 2008 Tongass 

Forest Plan Amendment. My decision also considers the vast array of public input, including public 

meetings, comments from the internet website, and comments received during the 108-day 

comment period on the Draft EIS. 

All substantive comments, written and oral, made on the 2007 Draft EIS have been summarized and 

responded to in Appendix H of the Final EIS. During the course of this effort, this public involvement 

has lead to substantial changes in the analysis and the alternatives. 

I find the environmental analysis and public involvement process the Final EIS is based on complies 

with each of the major elements of the requirements set forth by the CEQ regulations for 

implementing NEPA (40 CFR 1500-1508). My conclusion is supported by the following findings. 

First, the Final EIS considered a broad range of reasonable alternatives. The seven alternatives 

considered in detail in the Final EIS represent only part of the total number of alternatives 

considered over the course of the analysis. As described above in the “Alternatives Considered” 

section, 39 alternatives from previous EISs were considered before selecting the seven analyzed in 

detail in the Draft and Final EIS. These seven alternatives presented in the Final EIS encompass a 

broad range of response to issues, including a timber suitable land base ranging from 0.3 to 1.2 

million acres and an average annual first-decade ASQ from 49 to 421 MMBF. 

Second, the Final EIS reflects consideration of cumulative effects of the alternatives by evaluating 

past, present, and reasonably foreseeable future actions in the planning area including Federal, 

State, Tribal and private lands. The environmental effects analysis estimates the potential effects of 

timber activities and timber-associated activities, such as road construction, for 100 years. The 

analysis of effects to wildlife was based on the assumption that these activities would take place at 

their maximum allowable levels each year for 100 years, an extremely conservative assumption. 

This analysis considers changes to vegetation both temporally and spatially (Final EIS Appendix D). 

Moreover, although non-federal lands are outside the scope of this decision, effects from their 

management have been thoroughly considered in the Final EIS. 

Third, the Final EIS makes use of the best available information. The geographic information system 

database, constructed during the development of the 1997 Forest Plan, has been thoroughly 

updated, and was used to evaluate complex spatial effects resulting from implementation of the 

alternatives, such as maintenance of connectivity corridors for wildlife and how visual condition could 

change over time. The best available science was used to help estimate environmental 

consequences, as evidenced from the extensive reference section of the Final EIS (Chapter 6), the 

multiple appendices that document methods or other technical information, and the involvement of 

other organizations as described in the section of this ROD dealing with the use of science in the 

planning process. Uncertainties connected with environmental impacts and market demand have 

been acknowledged and addressed through the Timber Sale Program Adaptive Management 
Record of Decision 

59

Strategy. A linear optimization model was used to estimate the long-term flow of timber from the 

planning area. All of these tools, taken together, constitute use of the best available information. 

The decision here does not authorize timber sales or any other specific activity on the Tongass 

National Forest. Site-specific decisions will be made on projects in compliance with NEPA, the 

Endangered Species Act, and other environmental laws following applicable public involvement and 

appeal procedures.

National Forest Management Act 

The National Forest Management Act and implementing regulations specify a number of 

requirements that guide Forest Service planning. The Forest Plan complies with each of these 

management requirements, as explained in this ROD and accompanying Final EIS and appendices. 

Certain requirements that received heightened public attention are discussed in further detail below 

and in other sections of this ROD. 

Diversity and Viability Provisions for Fish and Wildlife 

As described in detail in the section of this ROD on protecting wildlife habitat and biodiversity, after 

considering the statute, regulation, case law, and examination of the record, I find that this decision 

satisfies the requirements of the law because it will provide an amount and distribution of habitat 

adequate to maintain viable populations of vertebrate species in the planning area and will maintain 

the diversity of plant and animal communities. I base my determination on the evidence in the 

planning record, as summarized in the above section of this ROD. 

Sensitive Species 

A Forest Plan-level Biological Evaluation was completed for the 24 species/subspecies (4 wildlife, 2 

fish and 17 plant species/subspecies) currently listed in the Alaska Region’s sensitive species list 

that are known or are suspected to occur on the Tongass National Forest. For some species, 

individuals or their habitats may be impacted by the selected alternative, but the impacts are not 

expected to contribute to a trend toward Federal listing or cause a loss of viability to the population 

or species. 

Endangered Species Act 

There are no terrestrial species on the Tongass National Forest that are listed as threatened or 

endangered under the Endangered Species Act. Threatened and endangered species that may be 

affected by future projects, as discussed in the updated Biological Assessment, are limited to marine 

species (mammals and fish). Consultation requirements for these species under Section 7 of the 

Act were met with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service. 

Magnuson-Stevens Fishery Conservation and 

Management Act 

Section 305(b)(2) of the Magnuson-Stevens Fishery Conservation and Management Act states that 

all Federal agencies must consult the National Marine Fisheries Service for actions or proposed 

actions that may adversely affect essential fish habitat. The Act promotes the protection of essential 

fish habitat through project review, assessment, and mitigation of activities that may adversely affect 

these habitats. The Forest Plan itself, including this amendment, does not authorize any specific 

project or actions and therefore does not affect essential fish habitat. Future project activities 

designed to implement the amended Forest Plan that may adversely affect essential fish habitat will 

go through consultation per the Act. The National Marine Fisheries Service was an important 

contributor in the development of the 1997 Forest Plan, participated in informal consultation and 
Record of Decision

60

review of this amendment effort, and continues to be involved in the implementation and monitoring 

of projects and actions implementing the plan. 

Tongass Timber Reform Act 

The Tongass National Forest will continue to be managed in compliance with Section 101 of the 

TTRA, which states in part 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 discussed in detail in the section on market demand, the Forest Service has adopted an adaptive 

management approach to meeting these requirements. The requirement dealing with annual market 

demand is met through implementation of the Morse methodology, which estimates the volume of 

timber to be offered annually. The TTRA requirement regarding market demand for each planning 

cycle is met by adopting the selected alternative as described in the Final EIS and this ROD, and by 

a series of annual applications of the Morse methodology. 

Coastal Zone Management Act 

Under the Coastal Zone Management Act (CZMA), Federal agency activities that affect any land or 

water use or any natural resource of a State’s coastal zone must be carried out in a manner that is 

consistent to the maximum extent practicable with the enforceable policies of that State’s federally 

approved coastal management program. The Forest Plan does not, by itself, authorize activities 

such as timber harvest or road construction that may affect the coastal zone. Thus, the Forest Plan 

does not have coastal effects. Site-specific activities that affect the environment require further sitespecific analysis and public involvement under NEPA, CZMA, and other Federal and State 

environmental laws and regulations. 

This finding of no coastal effects is consistent with the Memorandum of Understanding between the 

Forest Service and the State of Alaska concerning CZMA consistency reviews, which does not list 

forest plans as one of the activities expected to affect the coastal zone. The State of Alaska has 

never conducted a consistency review of a forest plan or a forest plan amendment or revision. 

During the NEPA process for site-specific activities, the Forest Service will continue to determine 

whether the subject project has coastal effects, and whether an individual CZMA consistency review 

is required. Under the General Consistency Determination for Tongass Timber Sales, approved by 

the State of Alaska in December 2006, most timber sales conducted on the Tongass National Forest 

have been determined to meet or exceed the standards of the Alaska Forest Resources and 

Protection Act. Accordingly, most timber sales have been determined to be consistent to the 

maximum extent practicable with the enforceable policies of the Alaska Coastal Management 

Program, and do not require individual consistency review. Only those timber sales that require a 

State or Federal license or permit under a provision of law other than the Alaska Forest Resources 

and Protection Act require individual review under the CZMA for consistency with the Alaska Coastal 

Management Program. 

Alaska National Interest Lands Conservation Act 

The Alaska National Interest Lands Conservation Act (ANILCA), as amended, contains numerous 

provisions, including provisions regarding access, that apply to management of the Tongass 

National Forest. However, it is not necessary to address these provisions in the context of this 

decision. An ANILCA Section 810 evaluation and determination is not required for approval of a 

Forest Plan amendment, a programmatic-level decision that is not a determination whether to 

“withdraw, reserve, lease, or otherwise permit the use, occupancy, or disposition” of National Forest 

lands. However, a forest-wide evaluation and determination is included for the Forest Plan revision 

to facilitate future project-level planning and decisionmaking in compliance with ANILCA Section 810 

(16 U.S.C. § 3120). 
Record of Decision 

61

Consistent with Section 810 of ANILCA, the Forest Plan has been evaluated for potential effects on 

subsistence uses and needs. A cumulative effects analysis of resource developments on 

subsistence resources is included in the Final EIS (Chapter 3, “Subsistence”). Based on this 

analysis, implementation of the Forest Plan may result in a significant restriction to subsistence use 

of deer due to the potential effects of projects on the abundance and distribution of these resources, 

and on competition for these resources. 

Two actions included in Section 810 were completed for the Draft EIS: (1) giving notice to the 

appropriate State agency, local committees and regional councils; and, (2) giving notice of, and 

holding, “a hearing in the vicinity of the area involved.” Because the area is the entire Tongass 

National Forest, such hearings were held in 23 communities throughout Southeast Alaska for the 

Draft EIS. 

Also included in Section 810 is the determination that: “(a) such a significant restriction of 

subsistence uses is necessary, consistent with sound management principles for the utilization of 

the public lands, (b) the proposed activity will involve the minimal amount of public lands necessary 

to accomplish the purposes of such use, occupancy, or other disposition, and (c) reasonable steps 

will be taken to minimize adverse impacts upon subsistence uses and resources resulting from such 

actions.” I will now discuss each of these three points. 

Necessity, Consistent with Sound Management of Public Lands. The amended Forest Plan has 

been examined to determine whether its potential for a significant restriction of subsistence uses is 

necessary, consistent with the sound management of public lands, as required by the Multiple-Use 

Sustained Yield Act, the National Forest Management Act, the Alaska National Interest Lands 

Conservation Act, the Tongass Timber Reform Act, and relevant State laws. The requirements of 

these laws have been reviewed and several of these have been discussed in this ROD. 

The Forest Plan must be designed to provide a mix of resources and uses to best meet the needs of 

the American people. It must be designed to maximize net public benefits, as previously discussed. 

Some of the resource uses necessary to achieve these benefits have the potential to adversely 

affect subsistence uses within the Tongass. However, given the multiple-use mandate and the other 

requirements of law, these effects to subsistence uses are necessary, consistent with the sound 

management of public lands. 

Amount of Public Land Necessary to Accomplish the Proposed Action Purpose. The amount 

of land necessary to implement the Forest Plan is, considering sound multiple-use management of 

public lands and the goals and objectives of the Plan, the minimum necessary. A forest plan must 

involve, by law, the entire forest. The plan does not authorize by itself any land-disturbing activities. 

Most of the Tongass National Forest, except the icefields, is used by one or more rural communities 

for subsistence deer harvesting. Many of the land use designations protect high value subsistence 

areas. 

Reasonable Steps to Minimize Adverse Impacts Upon Subsistence Uses and Resources. The 

continuation of subsistence opportunities, and reasonable steps to minimize effects on subsistence 

resources, are provided for by the forest-wide standards and guidelines for subsistence, as well as 

related standards and guidelines for riparian areas, fish, and wildlife. Many important subsistence 

areas were assigned land use designations that exclude timber harvesting. The beach and estuary 

fringe forest-wide standards and guidelines apply to all beach fringe and estuarine areas not under 

more restrictive designations. Adverse impacts to subsistence uses and resources are minimized 

through these measures. The potential site-specific effects on subsistence uses, and reasonable 

ways to minimize these effects, will be analyzed and considered during project-level planning. 

It is not possible to substantially reduce timber harvest in some areas by concentrating it in other 

areas without affecting subsistence resources and uses important to one or more rural communities. 

Also, concentrating timber harvest outside more important subsistence areas while still meeting the 

timber harvest goals of the Forest Plan could not be done without affecting the natural distribution of 

wildlife species, or without potentially significant effects to watersheds. 
Record of Decision

62

Clean Water Act 

Full implementation of the Plan and this ROD is expected to maintain and improve water quality and 

satisfy all State water quality requirements. I base this finding on the extensive standards and 

guidelines contained in the Plan, the application of State-approved “Best Management Practices” 

specifically designed to protect water quality, and the discussion of water quality and beneficial uses 

contained in Chapter 3 of the Final EIS. Examples include the beach and estuary fringe areas, 

riparian buffers, and road design requirements. Additionally, project level analysis for subsequent 

activities under the Plan will be required to demonstrate compliance with Clean Water Act and State 

water quality standards. 

Clean Air Act 

At the scale of a programmatic plan such as this, the overall level of activities proposed under this 

decision is not anticipated to degrade air quality or violate State implementation plans. This finding 

is based on information presented in the Final EIS. The only non-attainment area within the vicinity 

of the Tongass National Forest is Juneau. Conformity determinations and more detailed air quality 

impact analyses will be made at subsequent levels of planning and analysis, where emissions can 

be more accurately quantified and reasonably forecasted and local impacts assessed. 

Floodplains and Wetlands (Executive Orders 11988 and 

11990) 

These Executive Orders require Federal agencies to avoid, to the extent possible, short- and longterm effects resulting from the occupancy and modification of flood plains, and the modification or 

destruction of wetlands. Forest-wide standards and guidelines are provided for soil and water, 

wetlands, and riparian areas to minimize effects to flood plains and wetlands. They incorporate the 

Best Management Practices of the Soil and Water Conservation Handbook. The forest-wide 

standards and guidelines for beach and estuary fringe apply to all estuaries where less restrictive 

management might otherwise occur. 

Environmental Justice (Executive Order 12898) 

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations 

and Low-Income Populations, requires each federal agency to make the achievement of 

environmental justice part of its mission by identifying and addressing disproportionately high and 

adverse human health or environmental effects of its programs, policies, and activities on minority 

and low-income populations. The Order further stipulates that the agencies conduct their programs 

and activities in a manner that does not have the effect of excluding persons from participating in, 

denying persons the benefits of, or subjecting persons to discrimination under such programs, 

policies, and activities because of their race, color, or national origin. 

The issue of environmental justice is analyzed within Chapter 3, Social and Economic Overview, of 

the Final EIS. The community assessment section indicates the per capita incomes (2000 Census), 

the population (2001, Alaska Department of Labor), the percent of Natives within the population 

(2000 Census), and recent trend and economic events for 32 Southeast Alaska communities. The 

analyses also includes discussions of potential timber harvesting within each community’s use area, 

the potential impacts to the subsistence resources and land base used by each community, as well 

as potential impacts relative to recreation and tourism relative to each community. 

The results of the analyses are very similar to those found in the 1997 Forest Plan Final EIS and the 

2003 Forest Plan Final Supplemental EIS. I have concluded the amended Forest Plan results in a 

very low risk of disproportionate effects on minority or low-income populations in Southeast Alaska. 
Record of Decision 

63

Civil Rights 

Civil Rights are defined as “the legal rights of United States citizens to guaranteed equal protection 

under the law” (USDA Forest Service Manual 1730). Civil rights impact analysis for environmental or 

natural resource actions is part of the social impact analysis package in a necessary environmental 

impact statement and is not a separate report (USDA Forest Service Handbook 1709.11). 

The Forest Service is committed to equal treatment of all individuals and social groups in its 

management programs in providing services, opportunities and jobs. Because no actual or 

projected violation of legal rights to equal protection under the law is foreseen under the Forest Plan 

for any individual or category of people, no civil rights impacts are reported in the Final EIS. 

Implementation 

Plan Effective Date 

There are two different regulatory provisions governing the effective date for the amended Forest 

Plan. The NFMA planning regulations state that “[T]he approved plan shall not become effective 

until at least 30 days after publication of the notice of availability of the final environmental impact 

statement in the Federal Register....” (36 CFR § 219.10(c)(1).) The applicable appeal regulation 

states that “[I]mplementation of any decision subject to appeal pursuant to this part shall not occur 

for 7 calendar days following publication of the legal notice of the decision as required in this part.” 

(36 CFR § 217.10(a).) 

Therefore, the approved Tongass National Forest Land and Resource Management Plan 

Amendment is effective 30 days after the Notice of Availability of the Final EIS is published in the 

Federal Register, or 7 calendar days following publication of the legal notice of this decision in the 

Juneau Empire and the Anchorage Daily News, whichever is later. 

Effective Direction 

During the long and complex history of forest planning on the Tongass, many planning documents 

(forest plans, environmental impact statements, and records of decision) have been prepared. While 

all of these documents are useful and often build upon each other, it can be confusing to the public 

and to Forest Service employees searching for management direction or information to use in 

project level analysis. The planning record for the 2008 Tongass Forest Plan Amendment includes a 

summary of the current status of each of these documents. 

In terms of management direction, this 2008 Record of Decision and the amended Forest Plan 

supersede all past forest plans and records of decision for the Tongass National Forest. 

Continuing the Partnership with the State of Alaska 

As described in a previous section of this ROD, the State of Alaska has participated as a 

cooperating agency in all phases of the planning process for this Forest Plan Amendment, under an 

MOU signed in 2006. The Forest Service and the State find it desirable to continue this relationship 

to promote effective and coordinated implementation of the Plan. Accordingly, as directed in the 

section of this ROD describing the decision, the Forest Supervisor will develop a comprehensive 

cost-sharing agreement with the State of Alaska regarding implementation of the 2008 Forest Plan 

within six months of the effective date of the Plan. I expect the agreement to outline the relationship 

between the Tongass National Forest and the State of Alaska regarding implementation of the 

Forest Plan, monitoring and evaluation, and making changes in response to new information from 

monitoring or other sources within an adaptive management framework. The cost-sharing 

agreement should also outline the roles and responsibilities of the Forest Service and the State 

throughout this process. 
Record of Decision

64

Timber Sale Program Adaptive Management Strategy 

The Timber Sale Program Adaptive Management Strategy restricts timber sales and associated road 

construction to a specified portion, or phase, of the ASQ land base until actual timber harvest 

indicates the need for a larger land base. Land management activities unrelated to timber sales are 

not affected by the Strategy. The map of land included in each phase of the Strategy is included on 

the compact disc of the Final EIS and is also available on the internet at www.fs.fed.us/r10/tongass/. 

The Strategy is an extra step the Forest Service is taking to respond to recommendations from many 

parties that we avoid timber harvest and road construction in areas of the Tongass that are 

perceived as being more environmentally sensitive unless demand materializes to warrant such 

activity in those areas. The Strategy is based on three critical factors: 

1. The long-term demand for timber from the Tongass is inherently very uncertain, and is 

influenced by the ability of all interested parties to work together to stabilize the timber 

supply. 

2. The annual average ASQ of 267 MMBF is considerably higher than the current level of 

timber harvest on the Tongass. 

3. The land base associated with the ASQ includes roadless areas, many of which are highly 

valued by substantial portions of the public. 

As noted earlier, and as depicted in Figure 1, the VCUs in the Alternative 6 suitable land base have 

been evaluated according to each VCU’s roadless values. The land base includes Roaded, Lower 

Value, Moderate Value, and Higher Value Roadless components. The Roadless column on the right 

side of the figure can be compared with the corresponding volume numbers on the left. The volume 

numbers reflect the estimated sustainable level of timber harvest associated with that portion of the 

land base. In general, a sustained harvest level of 100 MMBF would require the Roaded and much 

of the Lower Value Roadless portion of the land base; a level of 150 MMBF would require Roaded, 

Lower Value Roadless and some Moderate Value Roadless portions; a harvest level of 200 MMBF 

would require most of the remaining Moderate Value Roadless portions. Any harvest level over 200 

MMBF would require entry into some of the Higher Value Roadless portions of the suitable land 

base. 

Figure 1 also displays information received from the State of Alaska regarding the threshold levels of 

economically feasible Tongass timber sale volume that the State and the Forest Service believe are 

necessary over the short, medium, and long term. The State estimates that the currently operating 

sawmills need at least 83.5 MMBF of economically feasible sawtimber to remain in operation over 

the next one to two years. Over the longer term, an annual offer level of 167.5 MMBF of economic 

sawtimber from the Tongass would allow existing mills to operate efficiently, meaning two shifts per 

day, which would substantially increase their ability to compete in world markets. This level would 

also provide 30 MMBF annually for the veneer plant in Ketchikan to process low grade sawlogs. 

The majority of this volume would be derived from NIC I lands, which are more economically feasible 

because the timber can be harvested from them using conventional logging systems. Some volume 

from intermixed NIC II lands would also be included. When the utility volume is included, for which 

no processing facilities currently exist in Southeast Alaska, the total annual offer level needed from 

the Tongass to sustain the existing sawmills and veneer mill operating at efficient levels would be 

approximately 200 MMBF. The Strategy includes three phases: 
Record of Decision 

65

Phase 1 – Phase 1 includes most of the roaded portion of the ASQ land base, along with most of the 

lower value inventoried roadless areas. The Phase 1 portion of the land base could sustain a level 

of timber harvest of about 150 MMBF. The scheduled timber sale program will generally be confined 

to this land base until such time as the level of timber harvest reaches at least 100 MMBF for two 

consecutive years. Personal use of timber, micro sales,22 salvage sales, small commercial timber 

sales generally less than one MMBF, young-growth management projects, and the roads associated 

with these activities, would be allowed in development LUDs outside of the Phase 1 portion of the 

ASQ land base. Total scheduled timber harvest will be monitored each fiscal year and will count 

toward both ASQ and the 100 MMBF performance level. Timber harvest conducted in non-

 

22 Micro sales are timber sales on Prince of Wales Island of down or dead trees totaling no more than 50 

thousand board feet, to supply small niche-market timber processors. 
Record of Decision

66

development LUDs for purposes other than timber production (e.g., wildlife habitat improvement) will 

not count toward either ASQ or the Adaptive Management Strategy’s performance levels. 

Phase 2 – Phase 2 includes Phase 1 lands and most of the moderate value roadless areas. The 

Phase 2 portion of the ASQ land base could sustain a level of timber harvest of about 200 MMBF. 

The scheduled timber sale program will generally be confined to this land base until such time as the 

level of timber harvest reaches at least 150 MMBF for two consecutive years. Personal use of 

timber, micro sales, salvage sales, small commercial timber sales generally less than one MMBF, 

young-growth management projects, and the roads associated with these activities, would be 

allowed in development LUDs outside of the Phase 2 portion of the ASQ land base. Total scheduled 

timber harvest will be monitored each fiscal year and will count toward both ASQ and the 150 MMBF 

performance level. Timber harvest conducted in non-development LUDs for purposes other than 

timber production (e.g., wildlife habitat improvement) will not count toward either ASQ or the 

Adaptive Management Strategy’s performance levels. 

Phase 3 – Phase 3 includes the remaining ASQ land base. 

In each phase, timber sale planning and sale preparation will be done within the corresponding 

portion of the land base (with the exceptions noted above for micro sales, small sales, salvage sales, 

and young-growth projects) until actual timber harvest performance indicates transition to the next 

phase is needed. The transition from one phase to the next must occur at a level lower than the 

maximum sustainable harvest level of the phase due to the lag time required for the timber sale 

planning process to be completed. This will allow flexibility for the Forest Service to complete the 

NEPA process and prepare a volume of timber ready to be offered for sale (referred to as shelf 

volume) ahead of actually offering the timber for sale (timber sold but not harvested is referred to as 

volume under contract). Adequate volume must be maintained in each category to respond quickly 

to short-term increases in harvest levels. A portion of shelf volume will normally be offered for sale 

each year to maintain an adequate level of volume under contract. Essentially, shelf volume 

replaces volume harvested each year, and would also be available for any new processing facilities 

that may be built. The amounts needed in these categories are a volume under contract equal to 

three years of volume harvested, and shelf volume equal to an additional three to five years of 

volume harvested. To the degree the Forest Service is successful in maintaining these levels, the 

transition from one phase of the Strategy to another will be seamless. The levels of volume 

available will be determined by the amount of funding appropriated by Congress; the ability of the 

Forest Service to prepare and offer economic timber for sale; and the ability of industry to purchase, 

harvest, process, and sell their products. 

Timber Sale Economics 

Providing economic timber sales in Southeast Alaska has always been a challenge and is expected 

to remain so into the future. The basic lack of infrastructure in a relatively isolated and harsh 

environment significantly affects development and operational costs. Earlier timber sale programs 

included significant investments in infrastructure development to aid individual timber sales be more 

economic. In recent years, investments in deferred road maintenance and construction of long term 

system roads in timber sale project areas has helped ensure timber sales are economic. Timber 

sale planning and the manner in which Forest Plan standards and guidelines are applied to specific 

timber sales can have significant cost consequences on the sales. Since 1997, monitoring of timber 

sale projects and of the implementation of the Forest Plan has revealed inconsistent interpretation 

and application of certain Forest Plan standards and guidelines, with resulting adverse 

consequences on timber sale economics. Similar issues that affect timber sale economics arose 

during the Forest Plan 5-Year Review and the review of the Forest Plan’s conservation strategy. 

Evaluation of this issue during preparation of the 2008 Forest Plan Amendment indicates timber 

sales can be designed to be economic under most market conditions if the Forest Plan standards 

and guidelines are consistently interpreted and applied within the intent of the Forest Plan. Forest 

Plan implementation training will be conducted to ensure that the Plan is implemented consistently, 

effectively, and efficiently. This will include training in planning timber sales to fully meet the intent of 

the Forest Plan and also to be as economic as possible. Implementation of the 2008 Forest Plan will 
Record of Decision 

67

be monitored. If it is determined that the Plan unnecessarily affects the ability to produce economic 

timber sale projects, an amendment following similar processes as this effort will be conducted, 

focusing on opportunities to promote economic timber sales without compromising the Forest Plan 

goals and objectives. It must also be noted that investments in some infrastructure will still be 

necessary, especially as forest plan implementation progresses into phases 2 and 3 of the Adaptive 

Management Strategy. 

Forest Plan Implementation Demonstration Area 

During the Five-year Review of the 1997 Forest Plan, and through our consultation with the State of 

Alaska on this Amendment, it became evident that a more rigorous evaluation of the effectiveness of 

the Forest Plan could be accomplished if done at a scale wider than an individual watershed or a 

single project. Significant components of the Plan that warrant such evaluation include the 

conservation strategy (both the system of old-growth reserves and the set of standards and 

guidelines that apply to the development LUDs), access and travel management planning and 

design, young-growth management in the maturing stands, restoration of habitat in non-development 

LUDs, and effects of invasive species (terrestrial and aquatic). 

Consequently, I direct the Tongass Forest Supervisor to explore developing a demonstration area of 

sufficient scale to test full implementation of the amended Forest Plan. Anticipated results of 

implementing the Forest Plan would be compared with actual results of such implementation. 

Where results differ significantly, modifications of the Forest Plan would be considered through the 

amendment or revision process. The ideal location for the project would be a roaded island with the 

following additional characteristics: 

• No city or town. 

• Low roadless values in portions of the island without roads. 

• An adequate diversity of wildlife and fish species to monitor changes over time. 

• A conservation strategy following the Forest Plan guidance. 

• A wide range of previously harvested areas to provide several age classes of young-growth 

stands. 

• Adequate access to provide for extensive monitoring and visitation of the area. 

For this project to succeed, a collaborative effort would need to be developed between research, 

special interest groups, the State of Alaska, communities in the immediate vicinity of the project 

area, and other agencies interested in the results. The purpose of this collaborative effort would be 

to select the site and to ensure appropriate monitoring is performed to address the main questions 

relative to the effectiveness of the Forest Plan components. 

Transition to the Amended Forest Plan 

The amended Tongass Forest Plan does not provide final authorization for any activity, including 

timber sales, nor does it compel that any contracts or permits be advertised or awarded. Rather, like 

the 1997 Forest Plan, it provides a programmatic framework within which project-level decisions are 

considered. Projects must undergo appropriate site-specific analysis, and comply with applicable 

requirements for public participation, environmental analysis and disclosure, and the administrative 

appeal procedure before final authorization and implementation. 

Exercising my discretion under NFMA, I have determined that it is not necessary to apply the 

amended Plan's standards and guidelines retroactively, and I find that NFMA does not require 

revision of any pre-existing use and occupancy authorizations. However, I have also determined 

that the Forest Service has the discretion, on a case-by-case basis, to modify pre-existing 

authorizations if they are not consistent with newly established standards, including the standards 

and guidelines in the amended Plan. 
Record of Decision

68

Because this was an amendment of the 1997 Plan, much of the management direction of the 1997 

Plan is carried forward relatively unchanged into the amended Forest Plan. Therefore, many 

existing projects and ongoing actions that were consistent with the 1997 Plan will continue to be so 

with the amended Forest Plan. Many management actions decided prior to the issuance of this 

Record of Decision are routine and ongoing. Those decisions will generally be allowed to continue 

unchanged because implementing pre-existing decisions and the associated effects of that 

implementation were considered as part of the baseline and assumed to continue in the 

environmental analysis of alternatives in the Final EIS for the 2008 Forest Plan Amendment. 

Because we considered these earlier decisions in our effects analysis, their implementation is not in 

conflict with the amended Plan. 

Existing timber sale contracts, in most cases, will be completed within three years. Other use and 

occupancy agreements may have a substantially longer life than timber contracts. These use and 

occupancy agreements will be reviewed to determine if or when the Forest Supervisor should 

exercise discretion to bring them into full compliance with the amended Forest Plan. As discussed 

below, recent project decisions that have not yet been implemented will be reviewed and adjusted, if 

necessary, in consideration of the new standards and guidelines in the amended Forest Plan. 

Timber Sales 

The relationship of 3 categories of timber sale projects to the amended Forest Plan is described 

below. Additional work on timber sale projects in Categories 2 and 3 (described below) will be done 

only to the degree such work is consistent with the Timber Sale Program Adaptive Management 

Strategy and any LUD changes included in the amended Forest Plan. If any portion of any project in 

Categories 2 or 3 is in a non-development LUD under the amended Forest Plan, that portion may 

not be implemented and no further planning work may be done unless the project is consistent with 

the management direction of the amended Forest Plan (e.g., it is being proposed for purposes other 

than timber production, such as wildlife habitat improvement). 

The three categories of timber sale projects are as follows: 

1. Timber sales under contract before the effective date of this Plan. I have decided not to 

modify any existing timber sale contracts. As I stated earlier, the effects analyses contained 

in the Final EIS assumed that these contracts would be executed according to their terms. 

Moreover, the environmental effects of these 36 projects have been disclosed to the public 

through their site-specific project-level environmental documents. Since existing timber sale 

contracts will generally be completed within three years, I find it reasonable to allow preexisting standards to remain in effect for that period of time. The sales included in this 

category as of December 31, 2007 are listed below. Any timber sale contract signed 

between that date and the effective date of the amended Forest Plan will also be included in 

Category 1. 
Record of Decision 

69

Timber Sales in Category 1--Under Contract--as of December 31, 2007 

Above Road Microsale #27 

Ambrosia Microsale # 126 

Angel Microsale #136 

Backline Microsale #137 

Beaver Tail Special Microsale #138 

Big Bear Microsale #139 

Blind Slough Midpoint Special Salvage 

Bogo Midway Reoffer II 

Bohemia Mink Tail Special Salvage 

Boomerang Moxie Special Salvage 

Bound Mustang Salvage Reoffer 

Brisket Special Salvage Power Lake 

Buckdance Madder Reoffer Quill 

Bucktooth Special Salvage Red Bull Salvage Sale 

Buster Creek Stringer Red Mountain 

Crane Revilla Road Microsale 

Divide Sandy Cove Special Salvage 

Dogleg Special Salvage Scratchings 

Drumlin Reoffer II Setter Lake 

Finger Point Shady 

Fishsticks Skipping Cow 

Fishtrap Special Salvage Small Otter 

Fourleaf Summore Change 

Kensington Gold Project Swan Tyee Timber Settlement 

Kensington Settlement Swingset Special Salvage 

Kogish Shinaku II Tall Tree 

Kosciusko Stewardship Three Moose 

Last Call Reoffer Turbo Otter 

Licking Creek Tuxekan 

Lindenberg Twin Shovel 

Little Rock Upper Carroll II 

Low Ridge Vientos Cinco #5 

Luck Lac II Wedge 

Lucky Charm Reoffer 11 Permits 

Lucky Duck Reoffer 

2. Timber sale projects: (a) for which NEPA decision documents were signed before the 

effective date of this Plan, but whose timber volumes will not have been sold (wholly 

or in part) before the effective date of this Plan; (b) with a Final Environmental Impact 

Statement and no Record of Decision as a result of the May 18, 2007 Settlement 

Agreement in Natural Resources Defense Council v. Forest Service, Case No. 1:03-cv00029-JKS (approved by the Alaska District Court on May 25, 2007); or (c) now being 

planned and for which a Draft Environmental Impact Statement has been released for 

public comment before the effective date of this Plan. I have reviewed the 43 projects in 

this category and have determined that the 36 projects listed below are consistent with the 

goals and objectives of the amended Plan.23

 

23 The environmental documents for seven projects in Category 2 cannot be found consistent with the amended 

Forest Plan without additional environmental analysis. These projects include Eight Fathom, Southeast 

Chichagof, Alaska Pulp Company Final Supplement to the EISs for the 1986-1990 Operating Periods, Kelp Bay, 

Northwest Baranof, Indian River, and Ushk Bay. Accordingly, any further work on these projects would require 

the issuance of a new draft EIS; therefore, these projects are treated as if they are in category 3. 
Record of Decision

70

Moreover, the environmental effects of these 36 projects have been disclosed to the public 

through their site-specific project-level environmental documents. These projects were also 

assumed to be implemented in the environmental analysis of Alternatives 5 and 6 in the 

2008 Forest Plan Amendment Final EIS. Because the Final EIS considered these projects 

in its effects analysis, their implementation is not in conflict with the amended Plan. 

I am directing the Forest Supervisor to review these projects, and incorporate the new 

direction in the amended Forest Plan to the extent this can be done without causing major 

disruptions in the implementation of these projects. Among the changes to be considered 

are the legacy standard and guideline in lieu of the 1997 Plan’s standards and guidelines for 

goshawk foraging and marten habitat, and the new direction regarding probable goshawk 

nests. The Tongass Change Analysis Process24 will be used on a project-by-project basis to 

determine whether additional environmental analysis and public involvement are necessary, 

and to document any modifications to the project in the project record. 

The amended Forest Plan includes the new scenery management program, which is a 

replacement for the visual management system included in the 1997 Forest Plan. The two 

programs are essentially the same insofar as environmental effects are concerned, and the 

transition should be initiated only for new timber sale projects. I find that projects planned 

under the visual management system do not require changes to the scenery management 

program included in the amended Forest Plan. 

Timber Sales Included in Category 2 

Backline Kosciusko 

Baht Kuiu 

Bohemia Mountain Madan 

Boundary Lab Bay 

Canal Hoya Navy 

Chasina Overlook 

Cholmondeley Roadside 

Control Lake Scott Peak 

Couverden Scratchings 

Crane and Rowan Mountain Sea Level 

Crystal Creek Soda Nick 

Doughnut Todahl Backline 

Emerald Bay Traitors Cove 

Finger Mountain Tuxekan 

Goose Creek Woodpecker 2002 

Gravina Woodpecker 2003 

Heceta Commercial Thinning Yakutat Salvage 

Iyouktug Yakutat Small Sales 

3. Timber sale projects for which a Draft Environmental Impact Statement has not been 

released for public comment before the effective date of this Plan. These projects shall 

be based on the amended Plan and will be consistent with all applicable management 

direction. 

 

24 This process includes a review of new information and circumstances relevant to environmental concerns to 

determine if additional analysis is warranted. 
Record of Decision 

71

Administrative Appeal Rights 

This decision to amend the Tongass Forest Plan is subject to administrative review pursuant to 36 

CFR Part 217. The Notice of Appeal must be in writing, meet the content requirements specified at 

36 CFR 217.9, and be filed with the Reviewing Officer: 

Regular Mail: Abigail Kimbell, Chief 

 USDA Forest Service 

 Attn: EMC Appeals 

 Mail Stop 1104 

 1400 Independence Avenue., SW 

 Washington, DC 20250-1104 

Note that regular mail is irradiated before it is delivered to the National Headquarters, so regular mail 

may take longer than normal to arrive. Anything time sensitive should be sent via FedEx, UPS, 

Courier, etc. to the following address: 

 USDA Forest Service 

 Ecosystem Management Coordination 

 Attn: Appeals 

 Yates Building, 3CEN 

 201 14th Street, SW 

 Washington, DC 20250 

 Email Address: appeals-chief@fs.fed.us 

 Phone: 202-205-0895 

 Fax: 202-205-1012 

Electronic appeals must be submitted in a format such as an email message, plain text (.txt), rich 

text format (.rtf), or Word (.doc). Appeals may also be hand delivered to the courier address above 

between the hours of 8:00 AM and 5:00 PM Monday through Friday, except Federal holidays. 

The Notice of Appeal, including attachments, must be filed (regular mail, fax, email, express delivery, 

courier service, or hand delivered) with the Reviewing Officer at the correct location within 90 

calendar days of the date the legal notice of this decision is published in the Juneau Empire and the 

Anchorage Daily News. The publication date in the newspapers of record is the exclusive means for 

calculating the time to file an appeal. Those wishing to appeal this decision should not rely upon 

dates or timeframe information provided by any other source. 

I encourage anyone concerned about this decision, the Forest Plan, or the Final EIS, to contact the 

officials listed below before submitting an appeal. It may be possible to resolve the concern in a less 

formal manner. 
Record of Decision

72

Contact People 

If you would like more information on the Forest Plan, the Final EIS, or this decision, please contact: 

Forrest Cole or Lee Kramer 

Forest Supervisor Plan Amendment Project Manager 

Tongass National Forest 8510 Mendenhall Loop Road 

Federal Building Juneau, AK 99801 

Ketchikan, AK 99901-6591 907-789-6246 

(907) 225-3101 

Approval 

______________________________ 

DENNIS E. BSCHOR Date 

Regional Forester 

January 23, 2008 
Printed on Recycled Paper

Photograph taken looking northeast with Lindenberg Peninsula on Kupreanof Island and 

the mouth of Petersburg Creek (front cover) in the foreground, Petersburg Mountain (front 

cover) in the middleground, and Frederick Sound and the mainland in the background.
Final EIS 

Impact St

Plan Amendmen

SUMMARY
Final EIS 

6 with minor modifi cations) and the ame

reviewers will receive an electronic vers

CD. The CD contains a cover letter, the 

alternative maps, the Record of Decision 

the Forest Plan, and a number of referen

and maps are described when you open t

A comprehensive Web site covering th

process was developed to assist the pu

commenting on the various documents 

during the process. This site will cont

www.tongass-fpadjust.net for a period 

in the near future, this site will be rem

documents will be transferred to the m

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

Publication of the Notice of Availability 

Federal Register will initiate a 90-day ap

date of the appeal period will also be po

How to Use the CD

The CD-ROM has an “autostart” fea

the application when you put the CD 

the application starts correctly, a W

links to the documents should open 

start by itself shortly after you inser

simply double-click on the Index.htm 
2 

evaluated the wilderness potential of road

in 2003. The revised Forest Plan has bee

1997, primarily to adjust Old-Growth Ha

designate electronic/communication sites

An August 2005 Ninth Circuit Court of A

Forest Plan Review, which was complete

the need to consider amending the Tonga

Final EIS responds to the Court and the 5

six alternatives for amending the Forest P

Action Alternative (Alternative 5). A sep

Proposed Forest Plan was published with 

the complete Forest Plan including all pro

Purpose and Need

The purpose and need for this EIS is to 

Court’s decision in Natural Resources D

Forest Service (421 F.3d 797, August 5

the Court held that the EIS and ROD fo

errors relating to the use of projected m

the range of alternatives considered rela

calculations, and the cumulative effects 

lands. In addition, there is a need to co

Plan based on information generated du

of the Forest Plan. Therefore, the purpo

primarily relates to the August 2005 Co

Review, and other minor clarifi cations a
Final EIS 

oads, eas, oadess aeas, ad oca

Plan Revision Supplemental Draft EIS (

concern: identifying and considering riv

Wild, Scenic, and Recreational rivers.

After the release of the 1991 SDEIS, con

pertaining to the Tongass Forest Plan Re

Out of this information emerged fi ve add

the Regional Forester as needing more s

fi nal revised Forest Plan could be adopte

aspects or extensions of the ten public is

others were new issues or had not been c

themselves. The fi ve issues included wi

karst and caves, alternatives to clearcutti

considerations. These issues were asses

SDEIS and the 1997 Tongass Forest Plan 

The 2003 Supplemental EIS (SEIS) revi

areas and analyzed alternative groupings 

wilderness recommendations. Two broa

to as key issues, were identifi ed as the m

alternatives analysis: 1) the long-term pr

and associated values and 2) the social a

the communities of Southeast Alaska. 

Public Input

The scope of this EIS was initially deter

2005 ruling, and by the 5-Year Review o

information was considered to help clear

use in the development and analysis of a
4 

Public comments generated relative to 

Public input expressed during project-le

Policy Act (NEPA) analyses over approx

Public input received in response to th

Web site for this EIS. 

This record of public input on the manag

a period of more than 12 years. Of spec

public meetings held in Southeast Alask

Revision, the 2001 National Roadless A

the 2003 SEIS. 

In addition to the above, public involvem

development of this EIS. Public involve

the following:

The Notice of Intent was published in 

March 2006.

A Forest Plan Adjustment Web site was 

and has been maintained and continually 

the public since then. Several hundred c

received through the Web site or via em

site during the fi rst several months of its 

A Weblog regarding the Forest Plan ad

established in July 2006 and was main

public communication. 

In response to the three above items, a 

received containing comments regardin

Government-to-government consultati

federally recognized tribes.

•

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•

•

•

•
Final EIS 

Input received prior to issuance of the 

and synthesized and a summary of thi

Appendix A (Issue Identifi cation) to th

A Draft EIS and Proposed Forest Pla

12, 2007. This began a 90-day comm

later extended to 108 days. The com

April 30, 2007. 

During the comment period, open hou

held in 24 Alaska communities. In ad

Draft EIS, the hearings provided oppo

related to subsistence and Alaska Nati

On March 22, 2007, an open house an

on the internet to solicit public comme

individuals living anywhere in the wo

More than 84,000 comment documents w

individual letters, form letters, emails, h

comments submitted directly via the For

site. Slightly more than 2,000 of these w

comment documents and the others were 

and emails. The individual comment do

into approximately 5,500 individual com

received from all 50 states and 89 foreig

of the substantive comments and Forest 

comments is presented in Appendix H to 

•

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•

•
6 

need of this EIS and public input receive

process, some issues are more likely to i

among alternatives and represent the ma

These issues were grouped into three bro

to as the key issues. These key issues ar

alternatives and analyses.

Key Issue 1 – Protection of high v

from road development and timbe

Tongass is of local and national im

for wildlife and biodiversity, recrea

Many people believe that roadless areas 

evolve naturally through their own dyna

be afforded protection to ensure that this 

includes very large undeveloped land are

of the Forest consisting of contiguous ro

1 million acres and represent large, unfra

wildlife habitat. This large scale of road

anywhere else in the NFS, except on the 

Southcentral Alaska. 

Roadless areas are considered important 

habitat and recreation values and their im

are also important because of the passive 

services values they provide. Passive us

that individuals assign to a resource inde

that resource and typically include existe

values. These values represent the value 

from knowing that expansive roadless ar
Final EIS 

whole. Examples of ecosystem services 

soil stabilization and erosion control, im

regulation, carbon sequestration, and bio

Indicators: Analysis relative to this issu

and proportion of land protected in non-

designations (LUDs); the amount of inve

that would be protected under each alter

productive old-growth forest that would 

alternative. The values of the lands prot

use or ecosystem services values are dis

examples provided from other studies.

Key Issue 2 – The Tongass Nation

provide a suffi cient timber supply 

demand and help maintain a vibra

Southeast Alaska.

The Tongass Timber Reform Act (TTRA

Forest Service to seek to provide a suppl

National Forest that meets annual marke

demand for each planning cycle, consist

multiple-use and sustained yield of all re

cancellation of long-term contracts and t

Alaska pulp mills, the timber industry in 

in a period of transition. Future or plann

however, cover a wide range and depend 

in key markets, conditions faced by com

investment and innovation in manufactu
8 

meet that demand. It considers the type 

wood) made available and the usefulnes

local industry. The analysis also conside

national economies and on local commu

Key Issue 3 – Protection of wildlif

biodiversity on the Tongass is of 

signifi cance and is affected by ro

timber harvest activities.

The Tongass National Forest supports a 

assemblage of wildlife, including the lar

bears and breeding bald eagles in the wo

importance for subsistence (e.g., Sitka b

extensive array of endemic mammals an

number of species that are at least partia

habitats (e.g., marten and goshawk). Po

species and the biodiversity of Southeas

timber harvest and the development of r

Although less than 10 percent of the pro

on the Tongass have been converted to y

is much higher for certain types of old g

and large-tree old growth. In addition, a 

lands have been harvested and the rate o

these lands. Therefore, the cumulative e

building on wildlife of Southeast Alaska 

of harvest and road construction on the T
Final EIS 

road development on nonNFS lands is q

conjunction with harvest and road devel

Alternatives 

Each alternative described in Chapter 2 

following components:

A framework; 

A general description of the desired co

A table with the acreages allocated to 

A map (included in the map packet ac

copy or in the map section of the CD v

distribution of LUDs across the Forest

A map showing the distribution of dev

and wilderness LUD groups; 

A description of proposed changes to 

standards and guidelines and managem

A quantifi cation of outputs and measu

alternative. 

The management prescriptions (i.e., LUD

guidelines) for each LUD are included in 

amended, for Alternative 5 (No Action) 

Forest Plan (see below) for the action alt

wide standards and guidelines that apply 

included in these Forest Plans. 

Chapter 2 of the Final EIS identifi es the go

In addition, the TTRA (Section 101) direct

•

•

•

•

•

•

•
10 

Plan Revision, as amended to date. A nu

Forest Plan text are being proposed unde

based on the Forest Plan 5-Year Review 

recommendations. Most changes were i

Proposed Forest Plan that accompanied 

were modifi ed and updated for the Final 

being proposed are summarized below. 

descriptions on the following pages only 

consistent with the Final Proposed Fores

the Proposed Forest Plan that accompan

in this section. A summary of the main c

into the Final Proposed Forest Plan are p

Management Prescriptions

Edits and clarifi cations were made reg

programs, sacred site protection, mine

highway vehicle use, scenery managem

most LUD prescriptions.

Substantial edits and clarifi cations we

and Wilderness National Monument L

Forest-wide Standards and Guidelines

Clarifi cations were made to the standa

steep slopes and soil stability in the So

Clarifi cations were made to the standa

III and IV streams and edits were mad

guidelines in the Fish section.

The detailed stream process group-spe

and guidelines are presented in an app

•

•

•

•

•
Final EIS 

accompanied the Draft EIS.

The goshawk foraging habitat and the 

and guidelines in the Wildlife section w

with a Forest-wide legacy standard an

Forest Plan that accompanied the Draf

standard and guideline for the Final Pr

revised further. The revised standard 

forest structure to be left only in harve

and only in higher risk VCUs, as prev

The goshawk nesting habitat standard a

section was revised in the Proposed Fo

the Draft EIS. In addition, the goshawk 

guideline for the Final Proposed Forest 

The revised standard and guideline per

measures to be removed if, after 2 cons

evidence of confi rmed or probable nest

The requirement to conduct inventorie

of nesting goshawks for proposed proj

habitat is included in the Final Propos

inadvertently removed from the Propo

accompanied the Draft EIS). 

New standards and guidelines on sacre

in the Heritage Resources and Sacred 

Extensive edits were made to the Karst 

and guidelines and the Karst and Cave R

Substantial edits were made to the Mi

and guidelines.

•

•

•

•

•

•
12 

Edits were made to off-highway vehic

the Lands section.

Edits were made to the road storage an

standards and guidelines in the Transp

In addition, there are a number of chang

sections. These include changes to the G

(Chapter 2 of the Plan) and Monitoring a

the Plan) chapters, as well as a number o

including Appendix B (Information Nee

Priority Routes and Use Areas), Append

Appendix K (Old-Growth Habitat Reser

L (Resource Schedules). The Monitorin

the Final Proposed Plan was revised to b

the version in the Proposed Forest Plan t

EIS. In addition, it is anticipated that the 

Indicator Species (MIS) may be revised 

MIS is not part of the Final Proposed Pla

Proposed LUD Changes Commo

The LUD allocations for each alternative 

alternative-specifi c descriptions. The alte

of the acreage allocated to congressionall

Wilderness, National Monument, and LU

terms of allocations to Research Natural A

Watersheds, or Wild, Scenic, or Recreatio

they do vary with respect to the other non

all of the development LUDs. The LUDs 

displayed on alternative LUD maps that a

•

•
Final EIS 

Service to conduct a comprehensive revi

small old-growth reserves (OGRs). The 

Alternatives 1, 2, 3, and 6 of the Final E

1997 Plan (as amended) reserve network 

under Alternatives 4 and 7 are not affect

information on the refi nement of small O

D (Volume II).

Alternative 1

Under this alternative, forest manageme

national forest uses and activities, but w

inventoried roadless areas, associated fi s

unroaded recreation, tourism, and subsis

to the current Forest Plan. Timber woul

roaded land base and inventoried roadle

natural condition. In addition, a number 

including all of Kuiu, Baranof, and Kruz

of Chichagof Island, all mainland areas, 

excluded from commercial timber mana

acres of the Tongass would be in develop

acres would be in non-development LUD

changed to non-development LUDs from 

1997 Plan) would be designated Semi-R

LUD changes under this alternative wou

and modifi cation of a number of Geolog

recommendations to change the Young B

Semi-Remote Recreation and the Cowee

from Scenic Viewshed to Experimental F
14 

correspond with Scenario 1 (limited lum

Brackley et al. (2006a) timber demand s

Alternative 8 of the 2003 SEIS in terms 

development LUDs. 

Alternative 2 

Under this alternative, forest manageme

of national forest uses and activities, but 

emphasis to roadless areas, associated fi 

and unroaded recreation, tourism, and su

relative to the current Forest Plan. Timb

the roaded land base as well as within ro

wilderness attribute ratings (primarily th

areas). The vast majority of current road

in a natural condition. A total of 1.9 mil

would be in development LUDs and 14.

non-development LUDs. The majority o

development LUDs from development L

would be designated Semi-Remote Recr

as development LUDs in Alternative 1 w

LUDs in this alternative, in addition to o

LUD changes under this alternative wou

and modifi cation of a number of Geolog

recommendations to change the Young B

Semi-Remote Recreation and the Cowee

from Scenic Viewshed to Experimental F

area of Remote Recreation LUD north o

Recreation. It also would include extens
Final EIS 

national forest uses and activities, but w

emphasis to roadless areas, associated fi 

unroaded recreation, tourism, and subsis

to the current Forest Plan. Timber woul

roaded land base as well as within additi

these additional areas would not include 

identifi ed in the 1999 Record of Decisio

1999) as the 18 Areas of Special Interest 

wilderness in H.R. 987. The vast majori

would remain in a natural condition. A t

the Tongass would be in development LU

would be in non-development LUDs. T

changed to non-development LUDs from 

the current Plan) would be designated Se

All areas identifi ed as development LUD

also be development LUDs in this altern

areas. Specifi c LUD changes under this 

addition and modifi cation of a number o

Areas, recommendations to change the Y

Forest to Semi-Remote Recreation and t

watersheds from Scenic Viewshed to Ex

converting a large area of Remote Recre

to Semi-Remote Recreation. It also wou

refi nements to the boundaries of the sma

based on a recently completed interagen

Alternative 3 would have an estimated s

661,000 acres and an ASQ of 204 MMB
16 

Alaska communities, relative to the curre

would be managed within an area expand

Plan. The vast majority of current roadle

natural condition; however, the majority o

substantial productive old growth (POG), 

could be developed. A total of 4.7 million 

be in development LUDs and 12.0 millio

development LUDs. Almost all areas ide

in Alternative 5 would also be developme

in addition to other areas. Specifi c LUD 

would include the addition and modifi cat

Special Interest Areas, recommendations 

Experimental Forest to Semi-remote Rec

Creek watersheds from Scenic Viewshed 

converting a large area of Remote Recrea

Semi-Remote Recreation.

Alternative 4 would have an estimated s

999,000 acres and an ASQ of 360 MMB

alternative would approximately corresp

integrated industry) of the Brackley et al

study. It is similar to Alternative 6 of th

Alternative 5 

This is the No-Action alternative. It rep

current Forest Plan and would result in a 

and activities. Timber would be manage

than under Alternative 3, but less extens

4. The vast majority of current roadless 
Final EIS 

1997 Final EIS plus amendments). 

Alternative 6 

This is the Proposed Action alternative. 

Alternative 5 (No Action) alternative in 

however, it includes extensive refi nemen

the small Old-Growth Reserves (based o

interagency evaluation), new Geologic S

new Experimental Forest, the conversion 

Recreation LUD north of Juneau to Sem

other minor LUD refi nements. Timber w

area more extensive than under Alternati

than under Alternative 4. The vast majo

areas would remain in a natural conditio

roadless areas that contain substantial PO

could be partially developed. A total of 

Tongass would be in development LUD

would be in non-development LUDs. Sp

this alternative would include the additio

a number of Geologic Special Interest A

to change the Young Bay Experimental F

Recreation and the Cowee-Davies Creek 

Viewshed to Experimental Forest, and c

of Remote Recreation LUD north of Jun

Recreation. It also would include extens

boundaries of the small Old-Growth Res

completed interagency evaluation.
18 

compared with the current Forest Plan. 

roadless areas would remain in a natural 

majority of roadless areas that contain su

wilderness, could be developed. A total 

Tongass would be in development LUD

would be in non-development LUDs. A

as development LUDs in Alternative 5 w

LUDs in this alternative, in addition to o

changes under this alternative would inc

modifi cation of a number of Geologic Sp

recommendations to change the Young B

Semi-Remote Recreation and the Cowee

from Scenic Viewshed to Experimental F

Alternative 7 would have an estimated s

of 1,174,000 acres and an ASQ of 421 M

similar to Alternative 2 of the 1997 Fina

Comparison of the Alterna

This section briefl y compares the enviro

the seven alternatives with respect to the 

Prior to presenting the effects compariso

help the reader compare the differences 

summarizes the LUD allocations of the a

Group combinations. The four LUD Gr

LUDs in terms of similarities in manage
Final EIS 

1234

40%

30%

20%

10%

0%

Altern

Percent o

Intensive Development

Moderate Development

Key Issue 1 – Protection of high v

from road development and timbe

Tongass is of local and national im

for wildlife and biodiversity, recrea

The Tongass includes very large undeve

portions of the Forest consisting of conti

exceed 1 million acres and represent larg

of wildlife habitat. This scale of roadles

elsewhere in the NFS, except on the Chu

Roadless areas are considered important 

habitat and recreation values and their im

are also important because of the passive 

services values they provide. 
20 

9.51 million acres, or about 57 percent. 

reduction in roadless plus wilderness acr

all of Southeast Alaska (all Alaska land

under each alternative are discussed in th

the alternatives are compared in Figure 2

Alternative 1 is designed to avoid inve

because of this, after 100+ years of ma

percent of the Tongass and 85 percent 

still be in roadless areas or wilderness

Alternatives 2 and 3 would progressively 

with 0.8 million acres and 1.7 million ac

in roadless areas, respectively. Alternati

in 87 percent of the Tongass and 82 perc

roadless or wilderness and Alternative 3 

and 79 percent. 

Next in progression into roadless areas, A

include 2.4 and 2.3 million acres of deve

respectively. Alternative 5 would ultima

the Tongass and 76 percent of Southeast 

wilderness. These percentages would be 

Finally, Alternatives 4 and 7 both enter r

degree. Alternative 4 would have 3.4 m

LUDs in roadless and Alternative 7 wou

100 years or more of implementation, A

in 76 percent of the Tongass and 73 perc

and Alternative 7 would result in 75 perc

percent of Southeast Alaska continuing a
Final EIS 

1234

50%

40%

30%

20%

10%

0%

Altern

Percent in Roadles

Tongass Southeas

Distribution of Roadless Areas

Signifi cant acreages of roadless areas wo

biogeographic provinces under all altern

maintain a higher percentage than others

and 2, none of the 21 biogeographic pro

boundary would have less than 50 perce

development LUDs. Alternative 1 woul

containing 90 percent or more acreage in 

and Alternative 2 would have 13 provinc

Alternative 3 would have 2 biogeographi

5 and 6 would have 3 provinces with less 
22 

demand and help maintain a vibra

Southeast Alaska.

Timber from the Tongass National Fores

materials for the region’s wood products 

Demand may be thought of as the differ

that buyers are willing to purchase at di

is not a single number, but instead a ser

relationships. The same is true of suppl

supply and demand that determines the 

produced and consumed. 

Accurately projecting future demand is d

Southeast Alaska timber and wood produ

diffi cult to predict, factors, including cha

and exchange rates in key markets, chan

preferences, as well as developments in 

whose products compete with those of A

The average timber sale on the Tongass 

and cedar and results in a variety of log 

forested conditions, the tree species, tre

all mixed together. When a timber sale 

usually required to purchase all of the v

of the composition. At present, none of 

to effi ciently process all grades and spe

is the local industry set up to process al

timber sales. In the absence of a facilit
Final EIS 

processed profi tably by sawmills in Sout

The wood products analysis prepared fo

long- and short-term effects. The long-

evaluates the alternatives with respect t

developed by the Pacifi c Northwest Res

Service, and b) current production leve

the minimum volumes required by vari

These benchmarks are used to evaluate 

the alternatives. Long-term effects are 

projected under each alternative.

The short-term effects analysis discusses 

the “timber pipeline:” volume under con

(i.e., sales that have approved NEPA doc

sold), and timber volume in preparation 

currently being evaluated under the NEP

Long-Term Effects 

Pacific Northwest Research Station Pr

Service commissioned the Pacifi c North

develop a series of demand projections. 

demand” analysis that projected various 

scenarios based upon differing assumpti

and future processing facilities in Southe

2006a). These future visions of the Sout

industry are hypothetical and are used in 

type of developments that might take pla

volumes are made available for harvest. 
24 

ability of the alternatives to meet each sc

Scenario 1 – Limited Lumber Product

approximates the status of the timber ind

the time that the Brackley et al. study wa

demand is projected to be 68 MMBF in 

It is likely that this volume would be pri

economical (non-interchangeable compo

Alternative 1, with a projected tota

could not provide sufficient volume 

currently modeled. 

Alternatives 2, 3, 4, 5, 6, and 7 could 

to meet this scenario in 2022.

Scenario 2 – Expanded Lumber Produ

projects that only higher value logs are p

investments in the existing mills in Sout

demand is projected to be 187 MMBF in 

As in Scenario 1, it is likely that this vol

higher value logs from the more econom

Alternatives 1 and 2, with projected 

and 151 MMBF, could not provide s

this scenario.

Alternatives 3, 4, 5, 6, and 7 could al

meet this scenario. 

Scenario 3 – Medium Integrated Indu

on Scenario 2 and would establish proce

sawlogs and low grade and utility logs fr

sales. Under this scenario the current sa
Final EIS 

Scenario 4 – High Integrated Industry

Scenario 3 and provides an estimate of t

the foreseeable future. In order for this 

new investments in processing capacity 

and additional market shares established

projected to be 342 MMBF in 2022 unde

Alternatives 1, 2, 3, 5 and 6, with proje

MMBF, 151 MMBF, 205 MMBF, 267 M

respectively, could not provide suffi cien

Alternatives 4 and 7 could provide s

this scenario.

Current Production Levels, Installed C

Volumes Required by Various Process

mills in Southeast Alaska had an estimat

capacity of 261 MMBF in 2006 and a to

361 MMBF. The estimated NIC I comp

projected under each alternative range fr

installed processing capacity under Alter

Alternative 7. The NIC I volume projec

Action) represents about 46 percent of th

capacity. The projected NIC I compone

shares of the total installed capacity, ran

Alternative 1 to 51 percent under Altern

Two of the future demand scenarios eva

(2006a) involve an integrated industry. 

on the assumption that as stable volumes 

will develop in an integrated fashion, wi
26 

would provide suffi cient volume to supp

that consisted of the existing sawmills, a 

Bioenergy facility. Under Alternative 5 

suffi cient volume to support the existing 

be suffi cient volume to support one or m

or other chip-related operation, but not b

A number of timber projections were rev

analysis. Based on this review, the Fore

potential upper planning cycle demand o

sources. Only Alternative 7 includes suf

level of demand only from NFS acres.

Direct Employment and Income. Dir

employment estimates are presented in 

the equivalent of one year’s employmen

employment would not necessarily occu

estimated job totals do not directly tran

of affected workers. These estimates as

between harvest and employment level

harvest resulting in a 1 percent change 

changes in volume will have a lagged r

the assumed linear relationship is an ap

to compare alternatives.

Based on projected harvest volumes, ave

products employment would range from 

Alternative 1 to 1,922 jobs under Altern

274 of these annualized jobs would be a

harvest under each alternative. Viewed 
Final EIS 

The following discussion provides an 

term effects. Actual effects would dep

pool when the decision is implemented

under contract, potential impacts woul

potentially affected sales were cancell

the decision.

Volume under Contract. Alternative 

majority of the Inventoried Roadless A

natural condition and would not allow 

areas. Alternative 1 would affect 52 p

volume under contract as of August 20

volume currently under contract would 

the other alternatives.

NEPA-Cleared Volume. Alternative 1 

MMBF) of the current NEPA-cleared vo

MMBF). It should be noted that not all 

economic under current market conditio

affect 44 percent or 198 MMBF of this v

volume that has passed through the NEP

be available for sale in the near future. N

would affect this volume.

Timber Volume in Preparation. Altern

percent (298 MMBF) of the timber volu

September 2006 (536 MMBF). Alternat

affect approximately 7 percent or 40 MM

Alternatives 4, 5, 6, and 7 would not affe
28 

number of species that are at least partia

habitats (e.g., marten and goshawk). Po

species and the biodiversity of Southeas

timber harvest and the development of r

Old-Growth Harvest

The amount of productive old growth (P

indicator of effects on many species, inc

endemic mammals, and deer. The range 

wide among the alternatives. Alternativ

harvest of POG at 86,000 acres, while A

maximum at 807,000 acres. After 100 y

90 percent of the original POG on NFS l

Alternative 1 and 77 percent would rema

Percentages for all of Southeast Alaska, 

would be 82 percent for Alternative 1 an

7. The other fi ve alternatives would rank 

7; their order from lowest to highest harv

at the low end progressing to Alternative 

For large-tree POG after 100+ years, a m

original amount would remain on the To

and 64 percent would remain under Alte

of Southeast Alaska, including non-NFS 

for Alternative 1 and 52 percent for Alte

the percentages for all POG and large-tr

Alaska, by alternative.
Final EIS 

1234

50%

40%

30%

20%

10%

0%

Altern

Percent Rema

All POG Large-tree 

Road Development

The Tongass currently has 4,941 miles o

closed and non-system roads). This tota

open roads, plus 913 miles of closed roa

1,409 miles of non-system roads. Road 

affect wildlife by eliminating habitats an

access, which can result in larger harves

predator interactions. 

Under Alternative 1, an estimated maxim

would be developed over 100 years. Fo

estimated maximum new road construct

miles, respectively. The majority of thes
30 

would increase in many areas after 100+ 

the alternatives. Under Alternative 1, the 

that a maximum of 11 percent of the WAA

greater than 1.0 mile per square mile. Alt

have a maximum of 16 to 18 percent, Alt

maximum of 19 percent, and Alternatives 

percent. These percentages would increa

road development, including future road 

lands, is considered. The percentage of W

lands (including non-NFS lands) greater t

would be 20 percent for Alternative 1, 23 

2, 3, 5, and 6, and 28 to 31 percent for Al

Representation of Old-Growth For

The percentage of POG remaining in eac

is an indication of the degree to which a

ecological communities remain fully rep

After 100 years of Alternative 1 implem

biogeographic provinces covering South

percent or more of their POG remaining 

than 50 percent (minimum value = 55 pe

16 out of 23 provinces would have at lea

amount remaining (minimum value = 32

At the other end of the spectrum, after 1

of Alternatives 4 or 7, 11 to 12 of the 23 

would have 75 percent or more of their P

would have less than 50 percent (minim

Alternative 7). Considering large-tree P
Final EIS 

value = 31%).

Conservation Strategy and Landsc

An adequate amount and distribution of 

blocks with good landscape connectivit

“coarse fi lter” aspect of the Old-Growth 

Strategy and is important for the mainte

distributed populations of many species 

spacing of old-growth reserves and othe

Alternatives 1 and 2 would result in a g

of high quality old-growth blocks over 

have little to no effects on landscape “p

3, 5, and 6 would have good to very go

reserves and other non-development LU

affect only one “pinch-point.” 

Under Alternative 4, the long-term resul

distribution of high quality old-growth b

biogeographic provinces with old-growt

distribution in the other provinces over t

growth retention requirement would mit

would not necessarily result in blocks or 

retained. This alternative would also neg

landscape “pinch-points.”

Alternative 7 would result in a poor distr

growth blocks over the long term throug

because of the lack of old-growth reserv

retention requirement, and the high acre
32 

1997- Alternative 11 is similar to 2007-

1997-Alternative 2 is similar to 2007-A

harvest acreage similarities. The rating

a relative qualitative description of the 

viable, well-distributed populations so t

more easily be compared.

Under Alternative 1, the likelihood of m

distributed populations on the Tongass a

to be very high for the goshawk, marten

moderate for endemic mammals. Altern

as high. Under Alternative 3, this likelih

high for the goshawk; high for the marte

moderate for endemic mammals.

Alternatives 5 and 6 would have similar 

maintaining viable, well-distributed pop

100 years is estimated to be high for the 

bear; and moderate for the marten and en

Alternatives 4 and 7 rate the lowest amo

Alternative 4, the likelihood of maintain

populations on the Tongass after 100 yea

the wolf; moderately high for the goshaw

for the marten; and moderately low for e

Alternative 7, the likelihood is estimated 

the wolf and brown bear; moderate for th

very low for endemic mammals.

Deer habitat capability expressed in term

can be used to identify the amount of ha
Final EIS 

The U.S. Department of Agriculture 

discrimination in all its programs a

basis of race, color, national origin

where applicable, sex, marital statu

parental status, religion, sexual or

information, political beliefs, repris

or part of an individual’s income is 

public assistance program. (Not a

apply to all programs.) Persons w

require alternative means for comm

information (Braille, large print, au

contact USDA’s TARGET Center at 

and TDD). To fi le a complaint of di

USDA, Director, Offi ce of Civil Righ

Avenue, S.W., Washington, DC 202

795-3272 (voice) or (202) 720-6382 

opportunity provider and employer
34 

Photograph taken looking northeast with Lindenberg Pe

Kupreanof Island and the mouth of Petersburg Creek (f

the foreground, Petersburg Mountain (front cover) in th

and Frederick Sound and the mainland in the backgrou
Tongass Land and

Resource Management Plan

Final Environmental

Impact Statement

Plan Amendment

United States

Department of

Agriculture

Forest Service

R10-MB-603c

January 2008

Volume I 
Tongass Land Management Plan 

Amendment

Final Environmental Impact Statement 

January 2008 

Lead Agency: USDA Forest Service 

Cooperating Agency: State of Alaska 

Responsible Official: Dennis E. Bschor, Regional Forester 

USDA Forest Service, Alaska Region 

For Further Information: Visit the Forest Web site at: www.fs.fed.us/r10/tongass 

or Contact: 

 Lee Kramer 

Project Team Leader 

8510 Mendenhall Loop Road 

Juneau, AK 99801 

(907) 789-6246 

Abstract:

A Ninth Circuit Court ruling (2005) and the 5-Year Forest Plan Review (completed in 

January 2005) indicated the need to consider amending the Tongass National Forest 

Land and Resource Management Plan. This Final EIS responds to the Court and the 5-

Year Review by analyzing seven alternatives for amending the Plan, including the NoAction alternative. Maps accompanying this Final EIS depict the land use designations 

proposed under each alternative. A separate document, called the Proposed Land and 

Resource Management Plan (Forest Plan), was published with the Draft EIS and was 

revised, as indicated in Chapter 2 of this Final EIS, to represent the Final Proposed 

Forest Plan. The action alternatives incorporate this Final Proposed Plan entirely, or 

with modifications. A number of issues are addressed, but three key issues are 

identified: 1) protecting high-value roadless areas from road development and timber 

harvest activity in order to protect roadless area values; 2) providing a sufficient timber 

supply to meet the market demand and help maintain a vibrant economy in Southeast 

Alaska; and 3) protecting the wildlife habitat and biodiversity of the Tongass, which is 

affected by road development and timber harvest activities. The seven alternatives are 

designed to provide a range of options for addressing these issues. Direct, indirect, and 

cumulative effects of the alternatives are quantified and compared in Chapters 2 and 3, 

based on inventory data and modeling. 

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the 

basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, 

parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or 

part of an individual’s income is derived from any public assistance program. (Not all prohibited bases apply 

to all programs.) Persons with disabilities who require alternative means for communication of program 

information (Braille, large print, audiotape, etc.) should contact USDA's TARGET Center at (202) 720-2600 

(voice and TDD). To file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 

Independence Avenue, S.W., Washington, DC 20250-9410, or call (800) 795-3272 (voice) or (202) 720-6382 

(TDD). USDA is an equal opportunity provider and employer. 
 Contents 

Final EIS Contents iii 

CONTENTS 

CHAPTER 1 PURPOSE AND NEED ........................................................................................................1-1

Introduction ......................................................................................................................1-1 

Forest Planning History on the Tongass National Forest ................................................1-1 

Purpose and Need ...........................................................................................................1-2 

Forest Location and Description ......................................................................................1-3 

Public Issues....................................................................................................................1-3 

The Three Focus Issues ..................................................................................................1-6 

Changes Between the Draft EIS and Final EIS ...............................................................1-8 

Organization of the Document .........................................................................................1-9 

CHAPTER 2 ALTERNATIVES ..................................................................................................................2-1

Introduction ......................................................................................................................2-1 

Alternative Development Process....................................................................................2-1 

Alternatives Eliminated from Detailed Study....................................................................2-6 

Alternatives Considered in Detail.....................................................................................2-9 

Alternative 1.............................................................................................................2-15

Alternative 2.............................................................................................................2-19

Alternative 3.............................................................................................................2-23

Alternative 4.............................................................................................................2-27

Alternative 5.............................................................................................................2-31

Alternative 6.............................................................................................................2-35

Alternative 7.............................................................................................................2-39

Comparison of the Alternatives......................................................................................2-43 

CHAPTER 3 ENVIRONMENT AND EFFECTS.........................................................................................3-1

Introduction ......................................................................................................................3-1 

Analyzing Effects .......................................................................................................3-1 

Land Use Designation Groupings .............................................................................3-5 

General Forest Description........................................................................................3-7 

Organization of Chapter 3 .........................................................................................3-9 

Physical and Biological Environment.............................................................................3-11 

Climate and Air ........................................................................................................3-11 

Affected Environment ....................................................................................3-11 

Environmental Consequences.......................................................................3-16 

Geology, Karst, and Caves......................................................................................3-21 

Affected Environment ....................................................................................3-21 

Environmental Consequences.......................................................................3-26 

Soils.........................................................................................................................3-31 

Affected Environment ....................................................................................3-31 

Environmental Consequences.......................................................................3-35 

Water .......................................................................................................................3-41 

Affected Environment ....................................................................................3-41 

Environmental Consequences.......................................................................3-47 

Wetlands..................................................................................................................3-53 

Affected Environment ....................................................................................3-53 

Environmental Consequences.......................................................................3-55 

Fish..........................................................................................................................3-63 

Affected Environment ....................................................................................3-63 

Environmental Consequences.......................................................................3-78 

Plants.......................................................................................................................3-95 

Affected Environment ....................................................................................3-95 

Environmental Consequences.....................................................................3-105 

Forest Health .........................................................................................................3-119 
Contents 

Contents iv Final EIS

Affected Environment ..................................................................................3-119 

Environmental Consequences.....................................................................3-122 

Biodiversity ............................................................................................................3-127 

Affected Environment ..................................................................................3-127 

Environmental Consequences.....................................................................3-173 

Wildlife ...................................................................................................................3-219 

Affected Environment ..................................................................................3-219 

Environmental Consequences.....................................................................3-252 

Human Uses and Land Management ..........................................................................3-299 

Lands.....................................................................................................................3-299

Affected Environment ..................................................................................3-299 

Environmental Consequences.....................................................................3-307 

Transportation and Utilities....................................................................................3-309 

Affected Environment ..................................................................................3-309 

Environmental Consequences.....................................................................3-314 

Timber....................................................................................................................3-319

Affected Environment ..................................................................................3-319 

Environmental Consequences.....................................................................3-336 

Minerals .................................................................................................................3-353 

Affected Environment ..................................................................................3-353 

Environmental Consequences.....................................................................3-360 

Recreation and Tourism ........................................................................................3-365 

Affected Environment ..................................................................................3-365 

Environmental Consequences.....................................................................3-386 

Scenery..................................................................................................................3-403 

Affected Environment ..................................................................................3-403 

Environmental Consequences.....................................................................3-406 

Subsistence ...........................................................................................................3-419 

Affected Environment ..................................................................................3-419 

Environmental Consequences.....................................................................3-427 

Heritage Resources and Sacred Sites ..................................................................3-437 

Affected Environment ..................................................................................3-437 

Environmental Consequences.....................................................................3-440 

Roadless Areas .....................................................................................................3-443 

Affected Environment ..................................................................................3-443 

Environmental Consequences.....................................................................3-450 

Wilderness.............................................................................................................3-455 

Affected Environment ..................................................................................3-455 

Environmental Consequences.....................................................................3-467 

Other Special Land Use Designations ..................................................................3-469 

Affected Environment ..................................................................................3-469 

Environmental Effects..................................................................................3-479 

Economic and Social Environment ..............................................................................3-489 

Affected Environment ............................................................................................3-490 

Introduction ..................................................................................................3-490 

Regional Economic Overview......................................................................3-491 

Natural Resource-Based Industries 3-494 

Wood Products ............................................................................................3-499 

Overview 3-499 

Harvest 3-500 

Production and Employment 3-501 

Current Status of the Industry 3-502 

Market Demand 3-504 

Recreation and Tourism ..............................................................................3-511 

Recreation and Tourism in Southeast Alaska 3-511 
 Contents 

Final EIS v Contents 

Recreation and Tourism on the Tongass National Forest 3-513 

Commercial Fishing and Seafood Processing.............................................3-518 

Mining and Mineral Development ................................................................3-520 

Natural Amenities and Quality of Life ..........................................................3-521 

Payments to the State .................................................................................3-524 

Environmental Consequences ..............................................................................3-525 

Economic Impact Analysis...........................................................................3-526 

Wood Products and Timber Demand—Long-Term Effects 3-526 

Wood Products and Timber Demand—Short-Term Effects 3-537 

Recreation and Tourism 3-539 

Mining 3-541 

Transportation and Utilities 3-542 

Salmon Harvesting and Processing 3-542 

Natural Amenities and Quality of Life 3-542 

Summary of Impacts 3-543 

Economic Efficiency Analysis ......................................................................3-544 

Introduction 3-544 

Comments on the Draft EIS 3-545 

Revised Economic Efficiency Analysis 3-546 

Timber 3-546 

Recreation and Tourism 3-548 

Management Costs 3-549 

Salmon Harvesting and Processing 3-550 

Mining 3-550 

Subsistence 3-550 

Non-use Values and Ecosystem Services 3-551 

Natural Amenities and Quality of Life 3-556 

Tongass National Forest Budget .................................................................3-557 

Payments to the State .................................................................................3-558 

Cumulative Effects.......................................................................................3-558 

Subregional Overview and Communities.....................................................................3-561 

Introduction............................................................................................................3-562 

Subregional Overview ...........................................................................................3-562 

Southeast Alaska Boroughs and Census Areas .........................................3-562 

Alaska DOL Community Groups .................................................................3-568 

Communities..........................................................................................................3-571 

Community Assessments ............................................................................3-571 

Analyzing Impacts to Communities .............................................................3-574 

Potential Effects by Resource Area.............................................................3-574 

Individual Community Assessments............................................................3-576 

Angoon 3-576 

Coffman Cove 3-580 

Craig 3-585 

Edna Bay 3-589 

Elfin Cove 3-594 

Gustavus 3-598 

Haines 3-602 

Hollis 3-607 

Hoonah 3-611 

Hydaburg 3-616 

Hyder 3-620 

Juneau and Vicinity 3-624 

Kake 3-627 

Kasaan 3-632 

Ketchikan 3-636 

Klawock 3-641 

Metlakatla 3-645 
Contents 

Contents vi Final EIS

Meyers Chuck 3-650 

Naukati Bay 3-653 

Pelican 3-657 

Petersburg and Kupreanof 3-661 

Point Baker 3-665 

Port Alexander 3-670 

Port Protection 3-673 

Saxman 3-677 

Sitka 3-681 

Skagway 3-686 

Tenakee Springs 3-690 

Thorne Bay 3-694 

Whale Pass 3-699 

Wrangell 3-703 

Yakutat 3-708 

Environmental Justice ...........................................................................................3-712 

CHAPTER 4 LIST OF PREPARERS ........................................................................................................4-1

CHAPTER 5 LIST OF DOCUMENT RECIPIENTS ...................................................................................5-1

CHAPTER 6 REFERENCES .....................................................................................................................6-1

CHAPTER 7 GLOSSARY..........................................................................................................................7-1

CHAPTER INDEX......................................................................................................................................8-1

VOLUME II 

APPENDIX A ISSUE IDENTIFICATION 

APPENDIX B MODELING AND ANALYSIS 

APPENDIX C POTENTIAL LAND ADJUSTMENTS 

APPENDIX D OLD-GROWTH HABITAT CONSERVATION STRATEGY, WILDLIFE STANDARDS AND 

GUIDELINES, AND WILDLIFE VIABILITY 

APPENDIX E CATALOGUE OF PAST HARVEST 

APPENDIX F BIOLOGICAL ASSESSMENT 

APPENDIX G TIMBER DEMAND AND SUPPLY 

APPENDIX H COMMENTS AND RESPONSES 
 Contents 

Final EIS vii Contents 

LIST OF TABLES 

Table 2-1 Projected Demand for 2022 under Brackley et al.’s Four Timber Demand 

Scenarios 2-5

Table 2-2 Tongass Forest Plan Alternatives Considered in Detail: 1990 – 2003 2-7

Table 2-3 Land Use Designations for Alternative 1 2-16

Table 2-4 Selected Outputs and Measures Associated with Alternative 1 2-18

Table 2-5 Land Use Designations for Alternative 2 2-20

Table 2-6 Selected Outputs and Measures Associated with Alternative 2 2-22

Table 2-7 Land Use Designations for Alternative 3 2-24

Table 2-8 Selected Outputs and Measures Associated with Alternative 3 2-26

Table 2-9 Land Use Designations for Alternative 4 2-28

Table 2-10 Selected Outputs and Measures Associated with Alternative 4 2-30

Table 2-11 Land Use Designations for Alternative 5 2-32

Table 2-12 Selected Outputs and Measures Associated with Alternative 5 2-34

Table 2-13 Land Use Designations for Alternative 6 2-36

Table 2-14 Selected Outputs and Measures Associated with Alternative 6 2-38

Table 2-15 Land Use Designations for Alternative 7 2-40

Table 2-16 Selected Outputs and Measures Associated with Alternative 7 2-42

Table 2-17 Land Use Designation Group Comparison by Alternative (million acres) 2-43

Table 2-18 Alternative Components 2-45

Table 2-19 Comparison of Alternatives 2-46

Table 2-20 Summary of Effects Matrix 2-57

Table 3.1-1 Land Use Designation Groupings Used to Discuss Effects 3-6

Table 3.2-1 Estimated Maximum Future Tongass Harvest on Karst Lands under the 

Alternatives 3-28

Table 3.2-2 Estimated Maximum New Road Construction on Karst Lands under the 

Alternatives 3-29

Table 3.3-1 Estimated Percent of the Productive Forestland on the Tongass by Site Index 

Category 3-32

Table 3.3-2 Estimated Percent of the Tongass National Forest, POG, and Young Growth by 

Slope Category 3-33

Table 3.3-3 Estimated Cumulative Acreage Covered by Road Surfaces on NFS Lands after 

the first 15 Years and after Full Implementation of the Forest Plan (100+ Years) 

by Alternative (currently there are 14,823 acres covered) 3-37

Table 3.3-4 Estimated Maximum Increase in Landslide Frequency over the First 15 Years 

of Forest Plan Implementation 3-38

Table 3.4-1 Mapped Stream Miles by Process Group and Stream Class for each Ranger 

District Group 3-43

Table 3.4-2 Estimated Number of Road Miles on All Lands within the Tongass Forest 

Boundary for Each Alternative after Full Implementation of the Forest Plan 

(approximately 100+ years) 3-49

Table 3.4-3. Percent of Original POG Remaining on All Lands within the Tongass Forest 

Boundary and Percent of All Lands inside the Boundary that are Not Directly 

Disturbed by Timber Harvest after Full Implementation of the Forest Plan 

(approximately 100+ years) 3-50

Table 3.5-1 Mapped Acres of Wetlands on the Tongass National Forest by Wetland System 

and Class 3-54
Contents 

Contents viii Final EIS

Table 3.5-2 Existing Roads and Maximum Miles of New Roads in Wetlands by Alternative 

after 100+ Years 3-56

Table 3.5-3 Maximum Harvest Area in Mapped Wetlands by Alternative before after 100+ 

Years of Full Implementation 3-58

Table 3.5-4 Cumulative Percent of Original POG Remaining on All Ownerships in 2006 and 

Estimated Minimum Percent Remaining after 100+ Years for All Lands within 

the Tongass Forest Boundary 3-59

Table 3.5-5 Existing and Estimated Future Maximum Road Density (miles per square mile) 

for NFS Lands and for All Ownerships within the Forest Boundary by 

Alternative after 100+ Years 3-60

Table 3.6-1 Commonly Harvested Sport, Subsistence, and Commercial Fish 3-64

Table 3.6-2 Estimated Road Miles and Percent of VCUs in Road Density Categories on 

NFS Lands under Existing Conditions and after 100+ years of Full 

Implementation 3-80

Table 3.6-3 Estimated Maximum Road Miles on Potentially Unstable Soils Based on Slopes 

Greater Than 67 Percent over the Length of the Project (approximately 100+ 

years) 3-81

Table 3.6-4 Estimated Number of Existing and Maximum New Stream Crossings for New 

Roads by Alternative over the Length of the Project (approximately 100+ years) 3-82

Table 3.6-5 Estimated Maximum Acres of Timber Harvest after 100+ Years of Full Forest 

Plan Implementation 3-83

Table 3.6-6 Mapped Stream Miles within Development LUDs by Alternative 3-83

Table 3.6-7 Estimated Maximum Acres of Old-Growth Harvest on Potentially Unstable Soils 

(Slopes > 67%) after Full Implementation of the Forest Plan (approximately 

100+ years) 3-84

Table 3.6-8 Estimated Average Total Road Density on Tongass NFS Lands and Non-NFS 

Lands within the Tongass National Forest Boundary by Alternative over 100+ 

years 3-91

Table 3.6-9 Estimated Road Miles and Percent of VCUs in Road Density Categories on 

NFS Lands and on All Lands Combined within the Tongass National Forest 

Boundary by Alternative after 100+ years of Full Implementation 3-92

Table 3.7-1 Regional Forester Sensitive Plant Species that are Known or Suspected to 

Occur on the Tongass National Forest 3-99

Table 3.7-2 Number of Non-Native Species Recorded by District 3-102

Table 3.7-3 Non-Native Plants on the Tongass: Number of Occurrences and Invasiveness 

Ranking 3-103

Table 3.7-4 Maximum Acres of Harvest and Maximum Miles of Road Construction by 

Alternative 3-107

Table 3.7-5. Maximum Effects on Potential Suitable Habitat for Sensitive Plant Species by 

Alternative (contributing effect of roads shown in parentheses) 3-112

Table 3.7-6 Cumulative Percent of the Original (1954) POG Remaining on All Ownerships 

in 2006 and after 100+ Years under Full Implementation of the Forest Plan for 

Each Alternative with Estimated Future Harvest on State, Private, and Other 

Lands 3-115

Table 3.7-7 Future Average Road Density by Alternative (miles per square mile) 3-115

Table 3.8-1 Approximate Projected Annual Harvest During First Decade (acres) 3-123 

Table 3.9-1 Biogeographic Provinces Identified within the Tongass National Forest 3-130

Table 3.9-2 General Cover Types on the Tongass by Biogeographic Province (in thousands 

of acres) 3-135

Table 3.9-3 Non-Forest Cover Types on the Tongass by Biogeographic Province 

(thousands of acres) 3-136
 Contents 

Final EIS Contents ix 

Table 3.9-4 Conifer Old-Growth Acres of the Tongass within Three Elevation Zones 3-143

Table 3.9-5 Distribution of Existing POG Acres by SDM Category across the 21 

Biogeographic Provinces on the Tongass National Forest 3-144

Table 3.9-6 Distribution of POG Acres by SDM Category across the 73 Ecological 

Subsections on the Tongass National Forest 3-145

Table 3.9-7 Total POG, High-Volume POG (SD5S, SD5N, SD67), Large-Tree POG (SD67), 

and Low-Elevation High-Volume and Large-Tree POG: Original Acres and 

Percent Remaining by Biogeographic Province on National Forest System 

Lands 3-147

Table 3.9-8 Past Harvest by Decade on the Tongass National Forest 3-148

Table 3.9-9 Past Harvest Relative to Management Practices on the Tongass National 

Forest 3-148

Table 3.9-10 Existing POG, Past Harvest, and Percent of Original POG Remaining for NFS, 

Non-NFS and All Lands by Biogeographic Province for Southeast Alaska 3-153

Table 3.9-11 Number and Acreage of Existing Intact* Large Watersheds (VCUs) by 

Biogeographic Province within the Tongass Forest Boundary 3-170

Table 3.9-12 Estimated Acreage and Percentage of All Existing POG, High-Volume POG, 

and SD67 POG in Reserves and Matrix Lands (minimum protected vs. 

maximum harvested) by Alternative 3-176

Table 3.9-13 Estimated Acreage and Percentage of Young Growth in Reserves and in Matrix 

Lands (minimum protected vs. maximum harvested) by Alternative4

 3-177

Table 3.9-14 Estimated Percent of Original POG Remaining Forest-wide (1st number) and in 

Reserves (2nd number) in 100+ Years Assuming Maximum POG Harvest1

under Each Alternative by Biogeographic Province 3-178

Table 3.9-15 Estimated Percent of Original High-Volume POG Remaining Forest-wide (1st

number) and in Reserves (2nd number) in 100+ Years Assuming Maximum 

POG Harvest1

 under Each Alternative by Biogeographic Province 3-180

Table 3.9-16 Estimated Percent of Original Large-Tree POG (SD67) Remaining Forest-wide 

(1st number) and in Reserves (2nd number) in 100+ Years Assuming Maximum 

POG Harvest1 under Each Alternative by Biogeographic Province 3-181

Table 3.9-17 Estimated Percent of Original Karst POG Remaining Currently and in 100+ 

Years Assuming Maximum POG Harvest under Each Alternative 3-182

Table 3.9-18 Estimated Percentage of Original POG Remaining Forest-wide in 100+ Years 

Assuming Maximum POG Harvest1

 under Each Alternative by Ecological 

Subsection 3-183

Table 3.9-19 Estimated Percent of All Large Watersheds in each Biogeographic Province 

Defined as Intact After 100+ Years of Forest Plan Implementation under Each 

Alternative 3-186

Table 3.9-20 Cumulative Percent of Original POG Remaining on All Ownerships after 100+ 

Years of Maximum Forest Plan Implementation under Each Alternative, 

incorporating Future Harvest on Non-NFS Lands by Biogeographic Province 3-201

Table 3.9-21 Cumulative Percent of Original High-Volume POG Remaining on All 

Ownerships after 100+ Years of Maximum Forest Plan Implementation under 

Each Alternative, incorporating Future Harvest on Non-NFS Lands by 

Biogeographic Province 3-202

Table 3.9-22 Cumulative Percent of Original SD67 POG Remaining on All Ownerships after 

100+ Years of Maximum Forest Plan Implementation under Each Alternative, 

incorporating Future Harvest on Non-NFS Lands by Biogeographic Province 3-204

Table 3.10-1 Wildlife Species in Southeast Alaska that are Federally Listed Species or 

Candidate for Listing under the ESA (NMFS or USFWS), Management 

Indicator Species (USDA Forest Service), or Sensitive Listed Species (USDA 

Forest Service) 3-224
Contents 

Contents x Final EIS

Table 3.10-2 Relative Importance of Conifer Successional Stages as Habitats for 

Management Indicator Species 3-231

Table 3.10-3 Migratory and Resident Birds Identified as Species of Concern in Southeast 

Alaska 3-247

Table 3.10-4 Summary of Acres in Matrix and Reserve Lands by Alternative 3-257

Table 3.10-5. Percentage of Existing Productive Old-Growth Acreage in Reserves, 

Protected/Unscheduled in the Matrix, and Suitable for Timber Harvest in 2008 3-258

Table 3.10-6 Maximum Percentage of Existing High-Volume (SD5N, SD5S, and SD67) and 

Large-Tree (SD67) Productive Old-Growth Proposed for Harvest by Elevation 

Category and Alternative after 100+ years 3-263 

Table 3.10-7 Relative Changes in Deer Habitat Capability by Wildlife Analysis Area (WAA) 

by Alternative 3-269

Table 3.10-8 High Quality Deer Winter Range Suitable for Harvest by Alternative 3-274

Table 3.10-9. Comparison of Alternatives in terms of their Long-term Ability to Meet the Wolf 

Guideline of Providing Sufficient Habitat to Support 18 Deer per Square Mile 

after 100+ Years of Forest Plan Implementation 3-284

Table 3.10-10. Estimated Maximum Average Road Density and Percent of WAAs in Road 

Density Categories on NFS Lands and on All Lands Combined for All Roads 

and for Open Roads Only within the Tongass National Forest Boundary by 

Alternative over 100+ Years 3-297

Table 3.11-1 Land Ownership Distribution, Tongass National Forest 3-300

Table 3.12-1 Estimated Maximum Road Construction and Cumulative Miles of National 

Forest System Roads by Alternative After Full Implementation (100+ years) 3-314

Table 3.12-2 Estimated Miles of Road to be Reconstructed by Alternative 3-315

Table 3.12-3 Estimated Maximum Road Construction and Cumulative Miles of Roads for All 

of Southeast Alaska by Alternative After Full Implementation (100+ years) 3-317

Table 3.13-1 Land Classification (thousands of acres) of Tentatively Suitable and Suitable 

Lands 3-321

Table 3.13-2 Estimated Gross Acres and Volume by Logging System for Productive Old 

Growth Based on 2007 LSTA 3-322

Table 3.13.3 Estimated Age Class Distribution of All Productive Forest Land and Suitable 

Productive Forest Land (acres) 3-323

Table 3.13.4 Estimated Age Class Distribution of Harvested Stands (acres) 3-323

Table 3.13-5 Tongass National Forest Strata Characteristics–Productive Old-Growth Forest 3-327

Table 3.13-6 Volume of Timber Offered, Sold, and Harvested from the Tongass National 

Forest for FY 2002-2006 (MMBF) 3-335

Table 3.13-7 Timber Harvest and Imports for Southeast Alaska, 1992-2005 (MMBF) 3-335

Table 3.13-8 Land Classification (thousands of acres), Tentatively Suitable and Suitable 

Lands 3-337

Table 3.13-9 Vegetative Management Practices 3-339

Table 3.13-10 Timber Management Intensity by Alternative over 100+ Years (acres) 3-340

Table 3.13-11 Allowable Sale Quantity (First Decade, Average Annual) 3-344

Table 3.13-12 Estimated Harvest by Operability Class (NIC I and NIC II) in the First Decade 

(MMBF1

 and percent) 3-347

Table 3.13-13 Allowable Sale Quantity and Long-term Sustained Yield Capacity (MMBF) 3-348

Table 3.13-14 Age Class Distribution of Mapped Suitable Acres after 160 years 3-349

Table 3.13-15 Forest-wide Stand Structures after 160 Years (acres) 3-349

Table 3.13-16 Maximum Estimated Annual Timber Harvest in Southeast Alaska during the 

First Decade (MMBF) 3-350
 Contents 

Final EIS xi Contents 

Table 3.14-1 Identified Mineral Resources of the Tongass National Forest Displayed by 

Mineral Activity Tract 3-357

Table 3.14-2 Economic Availability of Minerals Relative to Land Use Designations 3-361

Table 3.14-3 Effects on Economic Availability of Identified Mineral Resources 3-362

Table 3.14-4 Effects on Economic Availability of Rank 1 Identified Mineral Resources 3-362

Table 3.14-5 Effects on Economic Availability of Undiscovered Mineral Resources 3-362

Table 3.14-6 Effects on Economic Availability of Class 1 and 2 Undiscovered Mineral 

Resources 3-363

Table 3.14-7 Effects on Economic Availability of Areas Covered by the Minerals LUD Overlay 3-363

Table 3.15-1 Tongass Recreation Facilities 3-366

Table 3.15-2 Comparison of ROS Classes 3-368

Table 3.15-3 Forest-wide Recreation Opportunity Spectrum Acres, 2006 3-370

Table 3.15-4 Forest-wide Recreation Opportunity Spectrum Acres by LUD Group, 2006 3-370

Table 3.15-5 Distribution of Recreation Place Acres by Recreation Opportunity Spectrum 

Class 3-371

Table 3.15-6 Distribution of Recreation Places by General Use 3-371

Table 3.15-7 Important Recreation Places by Category 3-372

Table 3.15-8 Activity Participation and Primary Activities Identified in the 2004 Tongass 

NVUM Survey 3-373

Table 3.15-9 Reasons for Visiting Southeast Alaska 3-375

Table 3.15-10 Most Common Non-Business Activities for Visitors to Alaska, 2001 3-376

Table 3.15-11 Reasons for Visiting and Most Enjoyed Activities for Rural (Non-Cruise) Visitors 

to Central Southeast Alaska, 2005 3-377

Table 3.15-12 Most Enjoyed Activities for Cruise Visitors to Juneau, 2001, 2003, and 2005 3-377

Table 3.15-13 Southeast Alaska Visitation, 1990 to 2005 3-379

Table 3.15-14 Alaska Arrivals by Transport Type and Visitor/Resident, Summer 2004 3-380

Table 3.15-15 Juneau Icefield and Mendenhall Glacier Visitation, 1990 to 2005 3-381

Table 3.15-16 Principle Activities Engaged in by Southeast Alaska Commercial Recreation 

Businesses in 1999 3-383

Table 3.15-17 Helicopter Tour Locations by Client and Group, 2005 3-384

Table 3.15-18 Outfitter/Guide Use by Ranger District, 2004 and 2005 3-385

Table 3.15-19 Forest-wide ROS Acres after 150 Years of Implementation, by Alternative 3-387

Table 3.15-20 Home Range Recreation Places by LUD and Alternative (percent of acres) 3-388

Table 3.15-21 Recreation Places Important for Facilities by LUD and Alternative (percent of 

acres) 3-388

Table 3.15-22 Recreation Places Important for Marine Recreation by LUD and Alternative 

(percent of acres) 3-389

Table 3.15-23 Recreation Places Important for Hunting by LUD and Alternative (percent of 

acres) 3-389

Table 3.15-24 Recreation Places Important for Fishing by LUD and Alternative (percent of 

acres) 3-390

Table 3.15-25 Forest-Wide LUD Allocations and Net Change in Development LUDs by 

Alternative (percent) 3-391

Table 3.15-26 Recreation Places Important for Tourism by LUD and Alternative (percent of 

acres) 3-394

Table 3.15-27 Major and Minor Recreation Developments by LUD 3-396

Table 3.15-28 Percent of Tongass Acres Available for Tourism Developments 3-397

Table 3.16-1 The Existing Scenic Integrity of the Tongass National Forest (percent) 3-405
Contents 

Contents xii Final EIS

Table 3.16-2 Adopted Scenic Integrity Objectives for the Tongass (percent) 3-406

Table 3.16-3 Scenery Integrity Objectives (percent) 3-407

Table 3.16-4 Distance Zone breakdown of the Estimated Suitable Forest Land for Each 

Alternative by Development LUD 3-409

Table 3.16-5 Estimated Percentage of Selected Viewsheds Classified by Adopted SIOs 

under Each Alternative 3-411

Table 3.17-1 Deer Harvest by Game Management Unit and Transportation Type, 2003 3-430

Table 3.18-1 Approximate Maximum Acres Likely to be Disturbed over 100+ Years 3-441

Table 3.19-1 National Forest System Land, Non-National Forest System Land, and 

Productive Old Growth within Each of the Legislated LUD II Areas Designated 

by the Tongass Timber Reform Act (in acres) 3-444

Table 3.19-2 Tongass National Forest Inventoried Roadless Areas Analyzed in the Final 

2003 SEIS Compared with Roadless Areas Covered by the Roadless Area 

Conservation Rule 3-446

Table 3.19-3 Tongass National Forest Inventoried Roadless Area Descriptors (2003) 3-448

Table 3.19-4 Allocation of Inventoried Roadless Areas by LUD and Alternative (acres) 3-451

Table 3.19-5 Allocation of Inventoried Roadless Area Acreage by LUD and Alternative 

(percent) 3-451

Table 3.19-6 Acres of Development LUDs and Forest Land Suitable for Harvest within 

Current Inventoried Roadless Areas1 by Alternative 3-452

Table 3.20-1 Existing Wildernesses on the Tongass National Forest 3-458

Table 3.20-2 Percent of Each Biogeographic Province in Wilderness, LUD II, or other Natural 

Setting LUD (within the Tongass National Forest boundary) 3-461

Table 3.20-3 Percent of Each Ecological Subsection in Wilderness, LUD II, or Other Natural 

Setting LUD (within the Tongass National Forest boundary) 3-462

Table 3.21-1 Rivers (Segments) Recommended for Inclusion in National Wild and Scenic 

River Program (in miles) 3-477

Table 3.21-2 Summary of LUDs Surrounding Research Natural Areas by Alternative 3-481

Table 3.21-3 LUDs Adjacent to Wild, Scenic, and Recreational Rivers by Alternative 3-486

Table 3.22-1 Southeast Alaska Economic Overview 3-492

Table 3.22-2 Southeast Alaska Employment by Sector, 2001 and 2005 3-493

Table 3.22-3 Natural Resource-Based Industry Employment, 2005 3-495

Table 3.22-4 Employment and Income Multipliers 3-496

Table 3.22-5 Active Timber Processors in Southeast Alaska in Calendar Years 2005 and 

2006 3-504

Table 3.22-6 Timber Production 1983 to 2002 and Demand Projections for 2003 to 2025 

(MMBF) 3-506

Table 3.22-7 Projected Demand for National Forest Timber from Brackley et al. (MMBF) 3-507

Table 3.22-8 Tongass National Forest ASQ compared to Actual Harvest, 1994 to 2006 

(MMBF) 3-508

Table 3.22-9 Tongass-Related Recreation and Tourism: Historic and Predicted 

Consumption in Recreation Visitor Days (RVDs) 3-517

Table 3.22-10 Components of Per Capita Income, 2000 3-522

Table 3.22-11 Components of Per Capita Income 2005 3-522

Table 3.22-12 Components of Per Capita Transfer Payments, 1980 and 2000 3-523

Table 3.22-13 Components of Per Capita Transfer Payments, 2005 3-523

Table 3.22-14 Federal Payments to Alaska from NFS Receipts 1986 to 2006 (Amounts in 

$1,000s) 3-525

Table 3.22-15 Estimated Timber Supply (second decade annual average) 3-527
 Contents 

Final EIS xiii Contents 

Table 3.22-16 Ability of the Alternatives to meet the Timber Demand Scenarios in 2022 3-530

Table 3.22-17 Minimum Timber Volumes Required by Various Processing Facilities 3-531

Table 3.22-18 Log Utilization by Facility 3-531

Table 3.22-19 Projected Second Decade NIC I Volumes and Active and Total Installed 

Capacity 3-532

Table 3.22-20 Projected Timber Industry Employment at Maximum Allowable Timber Harvest 

Levels (First Decade, Annual Average) 3-537

Table 3.22-21 Recreation/Tourism Supply, Demand, and Consumption (First Decade, Annual 

Average) 3-540

Table 3.22-22 Recreation/Tourism Related Employment and Income (First Decade, Annual 

Average) 3-541

Table 3.22-23 Projected Annual Average Employment and Income Effects by Alternative 

(First Decade, Annual Average) 3-544

Table 3.22-24 Projected Change in Direct Employment by Sector as a Percent of Current 

Totals 3-544

Table 3.22-25 Economic Efficiency Analysis (million 2006$) 3-547

Table 3.22-26 Summary of Willingness-to-Pay Estimates of Existence Values 3-552

Table 3.22-27 Land Use Designations and Mapped Suitable Lands by Alternative (1,000s 

Acres) 3-556

Table 3.22-28 Fiscal Year 2007 Budget Allocation by Resource Item 3-559

Table 3.23-1 Borough/Census Area Population, 1990, 2000, and 2006 3-563

Table 3.23-2 Borough/Census Area Employment, 1990 and 2000 3-564

Table 3.23-3 Borough/Census Area Employment, 2000 and 2005 3-566

Table 3.23-4 Per Capita Income, 1996 to 2005 3-567

Table 3.23-5 Components of Personal Income, 1996 to 2005 (percent of total) 3-568

Table 3.23-6 Alaska DOL Community Groups Defined 3-569

Table 3.23-7 Employment by Community Group, 1990 to 1999 3-570

Table 3.23-8 Southeast Alaska Community Statistics 3-573

Table 3.23-9 LUD Groups in Angoon’s Community Use Area by Alternative 3-578

Table 3.23-10 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where 

Angoon Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-580

Table 3.23-11 LUD Groups in Coffman Cove’s Community Use Area by Alternative 3-582

Table 3.23-12 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where 

Coffman Cove Residents Obtain Approximately 75% of their Average Annual 

Deer Harvest* 3-584

Table 3.23-13 LUD Groups in Craig’s Community Use Area by Alternative 3-587

Table 3.23-14 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where Craig 

Residents Obtain Approximately 75% of their Average Annual Deer Harvest* 3-588

Table 3.23-15 LUD Groups in Edna Bay’s Community Use Area by Alternative 3-592
Contents 

Contents xiv Final EIS

Table 3.23-16 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where Edna 

Bay Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-593

Table 3.23-17 LUD Groups in Elfin Cove’s Community Use Area by Alternative 3-596

Table 3.23-18 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where Elfin 

Cove Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-597

Table 3.23-19 LUD Groups in Gustavus’ Community Use Area by Alternative 3-600

Table 3.23-20 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where 

Gustavus Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-601

Table 3.23-21 LUD Groups in Haines’ Community Use Area by Alternative 3-604

Table 3.23-22 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where Haines 

Residents Obtain Approximately 75% of their Average Annual Deer Harvest* 3-606

Table 3.23-23 LUD Groups in Hollis’ Community Use Area by Alternative 3-609

Table 3.23-24 LUD Groups in Hoonah’s Community Use Area by Alternative 3-614

Table 3.23-25 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where 

Hoonah Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-615

Table 3.23-26 LUD Groups in Hydaburg’s Community Use Area by Alternative 3-618

Table 3.23-27 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where 

Hydaburg Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-619

Table 3.23-28 LUD Groups in Hyder’s Community Use Area by Alternative 3-622

Table 3.23-29 LUD Groups in Juneau’s Community Use Area by Alternative 3-626

Table 3.23-30 LUD Groups in Kake’s Community Use Area by Alternative 3-630

Table 3.23-31 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where Kake 

Residents Obtain Approximately 75% of their Average Annual Deer Harvest* 3-631

Table 3.23-32 LUD Groups in Kasaan’s Community Use Area by Alternative 3-634

Table 3.23-33 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where 

Kasaan Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-635

Table 3.23-34 LUD Groups in Ketchikan’s Community Use Area by Alternative 3-639

Table 3.23-35 LUD Groups in Klawock’s Community Use Area by Alternative 3-643
 Contents 

Final EIS xv Contents 

Table 3.23-36 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where 

Klawock Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-645

Table 3.23-37 LUD Groups in Metlakatla’s Community Use Area by Alternative 3-648

Table 3.23-38 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where 

Metlakatla Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-649

Table 3.23-39 LUD Groups in Meyers Chuck’s Community Use Area by Alternative 3-651

Table 3.23-40 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where 

Meyers Chuck Residents Obtain Approximately 75% of their Average Annual 

Deer Harvest* 3-653

Table 3.23-41 LUD Groups in Naukati Bay’s Community Use Area by Alternative 3-655

Table 3.23-42 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where 

Naukati Bay Residents Obtain Approximately 75% of their Average Annual 

Deer Harvest* 3-656

Table 3.23-43 LUD Groups in Pelican’s Community Use Area by Alternative 3-659

Table 3.23-44 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where 

Pelican Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-660

Table 3.23-45 LUD Groups in Petersburg’s Community Use Area by Alternative 3-663

Table 3.23-46 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where 

Petersburg Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-665

Table 3.23-47 LUD Groups in Point Baker’s Community Use Area by Alternative 3-668

Table 3.23-48 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where Point 

Baker Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-669

Table 3.23-49 LUD Groups in Port Alexander’s Community Use Area by Alternative 3-672

Table 3.23-50 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where Port 

Alexander Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-673

Table 3.23-51 LUD Groups in Port Protection’s Community Use Area by Alternative 3-675

Table 3.23-52 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where Port 

Protection Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-677
Contents 

Contents xvi Final EIS

Table 3.23-53 LUD Groups in Saxman’s Community Use Area by Alternative 3-680

Table 3.23-54 LUD Groups in Sitka’s Community Use Area by Alternative 3-684

Table 3.23-55 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where Sitka 

Residents Obtain Approximately 75% of their Average Annual Deer Harvest* 3-685

Table 3.23-56 LUD Groups in Skagway’s Community Use Area by Alternative 3-688

Table 3.23-57 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where 

Skagway Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-689

Table 3.23-58 LUD Groups in Tenakee Springs’ Community Use Area by Alternative 3-692

Table 3.23-59 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where 

Tenakee Springs Residents Obtain Approximately 75% of their Average Annual 

Deer Harvest* 3-694

Table 3.23-60 LUD Groups in Thorne Bay’s Community Use Area by Alternative 3-697

Table 3.23-61 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where Thorne 

Bay Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-698

Table 3.23-62 LUD Groups in Whale Pass’ Community Use Area by Alternative 3-701

Table 3.23-63 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where Whale 

Pass Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-703

Table 3.23-64 LUD Groups in Wrangell’s Community Use Area by Alternative 3-706

Table 3.23-65 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where 

Wrangell Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-707

Table 3.23-66 LUD Groups in Yakutat’s Community Use Area by Alternative 3-711

Table 3.23-67 Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 

2005 and After 100+ Years of Full Implementation under Each Alternative, 

Expressed as a Percent of 1954 Habitat Capability, for the WAAs where 

Yakutat Residents Obtain Approximately 75% of their Average Annual Deer 

Harvest* 3-712

Table 3.23-68 Race/Ethnicity by Borough/Census Area, 2000 3-713
 Contents 

Final EIS xvii Contents 

LIST OF FIGURES 

Figure 1-1. Tongass National Forest Vicinity Map 1-4 

Figure 2-1 Wilderness, Natural Setting, and Development LUDs on the Tongass National 

Forest under Alternative 1 2-17 

Figure 2-2 Wilderness, Natural Setting, and Development LUDs on the Tongass National 

Forest under Alternative 2 2-21 

Figure 2-3 Wilderness, Natural Setting, and Development LUDs on the Tongass National 

Forest under Alternative 3 2-25 

Figure 2-4 Wilderness, Natural Setting, and Development LUDs on the Tongass National 

Forest under Alternative 4 2-29 

Figure 2-5 Wilderness, Natural Setting, and Development LUDs on the Tongass National 

Forest under Alternative 5 2-33 

Figure 2-6 Wilderness, Natural Setting, and Development LUDs on the Tongass National 

Forest under Alternative 6 2-37 

Figure 2-7 Wilderness, Natural Setting, and Development LUDs on the Tongass National 

Forest under Alternative 7 2-41 

Figure 2-8 Land Use Designation Group Comparison by Alternative (percent) 2-44 

Figure 3.9-1 Map of Biogeographic Provinces of Southeast Alaska 3-132 

Figure 3.9-2 Ecological Sections (numbered areas) and Subsections (dashed lines) of 

Southeast Alaska 3-133 

Figure 3.9-3 General Cover Types on the Tongass National Forest 3-134 

Figure 3.9-4 Tree Size and Density Model used to Describe Forested Conditions across the 

Tongass National Forest 3-141 

Figure 3.9-5 Comparison of SDM Categories, the Four Volume Classes from the 1979 

Forest Plan, and the Three Volume Strata Approach Used for the 1997 Forest 

Plan 3-142 

Figure 3.13-1 Estimated Tentatively Suitable Forest Land (millions of acres) in the Tongass 

National Forest, 1907 to Present 3-322 

Figure 3.13-2 Product Components of a Tree 3-325 

Figure 3.13-3 Tongass National Forest Timber Harvest Histogram for 1980 to 2006 3-332 

Figure 3.13-4 Tongass National Forest Timber Harvest Line Graph for 1980 to 2006 3-333 

Figure 3.15-1 Southeast Alaska Visitation, 1990 to 2005 3-380 

Figure 3.17-1 Native/Non-Native Components of Southeast Communities, 2000 3-423 

Figure 3.17-2 Per Capita Subsistence Harvest by Community and Resource Type 3-425 

Figure 3.20-1. Acres of Wilderness by State 3-459 

Figure 3.20-2. Percentage of Land Area in Wilderness by State 3-460 

Figure 3.22-1 Direct Resource-Dependent Employment by Sector 2005 3-495 

Figure 3.22-2 1994 Nonresident Share of Direct Employment in Southeast Alaska, Total and 

Resource-Dependent Industries 3-497 

Figure 3.22-3 Average Annual Seasonal Variation in Employment 2001-2005 (percent) 3-499 

Figure 3.22-4 Southeast Alaska Total Timber Harvests by Ownership, 1986-2006 3-500 

Figure 3.22-6 Southeast Alaska Timber Sector Direct Employment by Type, 1986-2006 3-502 

Figure 3.22-7 Historical and Projected Recreational Activity on the Tongass National Forest in 

RVDs 3-516 

Figure 3.22-8 Historical Consumption, Projected Demand, and 2006 Supply for Recreation 

Activity on the Tongass National Forest by ROS Group 3-516 
Contents 

Contents xviii Final EIS

Figure 3.22-8 Southeast Alaska Salmon Harvest: Gross Landings and Gross Revenue, 1984 

to 2005 3-519 

Figure 3.22-9 Direct Salmon Harvesting and Fish Processing Employment in Southeast 

Alaska, 1984 to 2005 3-520 

Figure 3.22-11 Minimum Timber Volumes Required by Various Processing Facilities and 

Estimated Average Annual Supply (NIC I), Second Decade 3-531 

Figure 3.23-1 Wood Products and Lodging, Restaurant, and Recreation Services Share of 

Total Employment by Borough, 2005 (Percent) 3-567 

Figure 3.23-2 Angoon’s Community Use Area 3-578 

Figure 3.23-3 Coffman Cove’s Community Use Area 3-582 

Figure 3.23-4 Craig’s Community Use Area 3-587 

Figure 3.23-5 Edna Bay’s Community Use Area 3-592 

Figure 3.23-6 Elfin Cove’s Community Use Area 3-596 

Figure 3.23-7 Gustavus’ Community Use Area 3-600 

Figure 3.23-8 Haines’ Community Use Area 3-604 

Figure 3.23-9 Hollis’ Community Use Area 3-609 

Figure 3.23-10 Hoonah’s Community Use Area 3-614 

Figure 3.23-11 Hydaburg’s Community Use Area 3-618 

Figure 3.23-12 Hyder’s Community Use Area 3-622 

Figure 3.23-13 Juneau’s Community Use Area 3-626 

Figure 3.23-14 Kake’s Community Use Area 3-629 

Figure 3.23-15 Kasaan’s Community Use Area 3-634 

Figure 3.23-16 Ketchikan’s Community Use Area 3-639 

Figure 3.23-17 Klawock’s Community Use Area 3-643 

Figure 3.23-18 Metlakatla’s Community Use Area 3-647 

Figure 3.23-19 Meyers Chuck’s Community Use Area 3-651 

Figure 3.23-20 Naukati Bay’s Community Use Area 3-655 

Figure 3.23-21 Pelican’s Community Use Area 3-659 

Figure 3.23-22 Petersburg’s Community Use Area 3-663 

Figure 3.23-23 Point Baker’s Community Use Area 3-668 

Figure 3.23-24 Port Alexander’s Community Use Area 3-672 

Figure 3.23-25 Port Protection’s Community Use Area 3-675 

Figure 3.23-26 Saxman’s Community Use Area 3-680 

Figure 3.23-27 Sitka’s Community Use Area 3-684 

Figure 3.23-28 Skagway’s Community Use Area 3-688 

Figure 3.23-29 Tenakee Springs’ Community Use Area 3-692 

Figure 3.23-30 Thorne Bay’s Community Use Area 3-697 

Figure 3.23-31 Whale Pass’ Community Use Area 3-701 

Figure 3.23-32 Wrangell’s Community Use Area 3-706 

Figure 3.23-33 Yakutat’s Community Use Area 3-711 
 Contents 

Final EIS Acronyms and Abbreviations xix 

ACRONYMS AND ABBREVIATIONS 

ACHP Advisory Council on Historic Preservation 

ACMP Alaska Coastal Management Program 

ADEC Alaska Department of Environmental Conservation 

ADF&G Alaska Department of Fish and Game 

ADNR Alaska Department of Natural Resources 

AFHA Anadromous Fisheries Habitat Assessment 

AHRS Alaska Heritage Resource Survey 

AKEPIC Alaska Exotic Plants Information Clearinghouse 

AMHS Alaska Marine Highway System 

AMS Analysis of the Management Situation 

ANCSA Alaska Native Claims Settlement Act of 1971 

ANHP Alaska Natural Heritage Program 

ANILCA Alaska National Interest Lands Conservation Act of 1980 

APC Alaska Pulp Company 

ASQ allowable sale quantity 

AVSP Alaska Visitor Statistics Program 

BIA U.S. Bureau of Indian Affairs 

BLM Bureau of Land Management 

BMP Best Management Practice 

BP before present 

BTU British Thermal Unit 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

CMAI Culmination of Mean Annual Increment 

Corps U.S. Army Corps of Engineers 

DBH diameter at breast height 

DCBD Division of Community and Business Development 

DCED Department of Community and Economic Development 

DEIS Draft Environmental Impact Statement 

DGC Division of Governmental Coordination 

DOL Department of Labor 

DOT&PF Department of Transportation and Public Facilities 

EA environmental assessment 

EFH Essential Fish Habitat 

EIS Environmental Impact Statement 

EPA U.S. Environmental Protection Agency 

ESA Endangered Species Act 

EVC existing visual condition 

°F degrees Fahrenheit 

FCRPA Federal Cave Resources Protection Act 

FERC Federal Energy Regulatory Commission 

FG foreground 

F.I.R.E. finance, insurance, and real estate 

FORPlan Previous Forest Planning Model 
Contents 

Acronyms and Abbreviations xx Final EIS 

FRESH Forest Resource Evaluation System for Habitat 

FSM Forest Service Manual 

FY fiscal year 

GIS geographic information system 

GMU Game Management Unit 

GSA General Services Administration 

HCA Habitat Conservation Area 

HSI Habitat Suitability Index 

IDT Interdisciplinary Team 

IFA Inter-Island Ferry Authority 

IPM Integrated Pest Management 

IRA Inventoried Roadless Area 

km kilometer 

KMDA known mineral deposit area 

KPC Ketchikan Pulp Company 

kV kilovolt 

LSTA Logging Systems and Transportation Analysis 

LTF log transfer facility 

LTSY long-term sustained yield 

LUD Land Use Designation 

LWD large woody debris 

MG middleground 

MM LUD Minerals Land Use Designation 

MBF thousand board feet 

MDP mineral development potential 

MEP mineral exploration potential 

MIRF Model Implementation Reduction Factor 

MIS Management Indicator Species 

MMBF million board feet 

MOU Memorandum of Understanding 

National Register National Register of Historic Places 

NEPA National Environmental Policy Act 

NFMA National Forest Management Act of 1976 

NHPA National Historic Preservation Act 

NIC non-interchangeable component 

NMFS National Marine Fisheries Service 

NFS National Forest System 

NPS National Park Service 

NRDC Natural Resources Defense Council 

NVCS National Vegetation Classification Standard 

NVUM National Visitor Use Monitoring 

NWI National Wetland Inventory 

OGR old-growth reserve 

OHV off-highway vehicle 

ORV off-road vehicle 

P Primitive 
 Contents 

Final EIS Acronyms and Abbreviations xxi 

PAOT persons at one time 

PNV Present Net Value 

POG productive old growth 

POW Prince of Wales 

PPI Producer Price Index 

ppm parts per million 

R Rural 

RARE Roadless Area Review and Evaluation 

RM Roaded Modified 

RN Roaded Natural 

RNA Research Natural Area 

ROD Record of Decision 

ROS Recreation Opportunity Spectrum 

RPA Resources Planning Act of 1974 

RVD Recreation Visitor Day 

SATP Southeast Alaska Transportation Plan 

SDEIS Supplemental Draft Environmental Impact Statement 

SEACC Southeast Alaska Conservation Council 

SEIS Supplemental Environmental Impact Statement 

SHPO State Historic Preservation Office 

SIO Scenic Integrity Objective 

SPM Semi-Primitive Motorized 

SPNM Semi-Primitive Non-Motorized 

TES threatened, endangered, and sensitive 

TRUCS Tongass Resource Use Cooperative Survey 

TTRA Tongass Timber Reform Act of 1990 

U Urban 

USGCRP U.S. Global Change Research Program 

USDA United States Department of Agriculture 

USDI United States Department of the Interior 

USFWS U.S. Fish and Wildlife Service 

USGS U.S. Geological Survey 

VCU Value Comparison Unit 

VQO Visual Quality Objective 

WAA Wildlife Analysis Area 

WARS Wilderness Attribute Rating System 

WTP willingness to pay 
Contents 

Acronyms and Abbreviations xxii Final EIS 

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CHAPTER 1 

PURPOSE AND NEED
Purpose and Need 1

Final EIS 1-1 Purpose and Need

Purpose and Need 

Forest land and resource management planning is a process for developing, 

amending, and revising land and resource management plans for each of the 

National Forests in the National Forest System (NFS). Forest plans are required by 

the National Forest Management Act of 1976 (NFMA). The 16.8-million-acre 

Tongass National Forest was the first forest to complete a Land and Resource 

Management Plan (Forest Plan or Plan) under the NFMA in 1979. The original 

Forest Plan was amended in 1986 and 1991 and revised in 1997. A Supplemental 

Environmental Impact Statement (SEIS) was completed in 2003, which further 

evaluated roadless areas for their wilderness potential. The revised Plan has been 

amended 24 times since 1997, primarily to adjust Old-Growth Habitat Reserve 

boundaries and for electronic/communication site designation. 

A recent Ninth Circuit Court ruling (2005) and the 5-Year Plan Review (completed in 

January 2005) indicated the need to amend the current Tongass National Forest 

Land and Resource Management Plan. This Final EIS responds to the Court and 

the 5-Year Review by thoroughly analyzing six alternatives for amending the Plan in 

addition to the No-Action Alternative (Alternative 5). The analysis is being published 

in two volumes: the first volume contains the main EIS, and the second volume 

contains the appendices to the EIS. A separate document titled Land and Resource 

Management Plan (Forest Plan or Plan) is also being published and represents the 

complete Forest Plan including all amendments. This document represents the 

Forest Plan that is used in all alternatives, except for differences that are outlined in 

Chapter 2. Finally, the Record of Decision (ROD), describing the decision and 

rationale for that decision, is also being published. 

This EIS analyzes a possible amendment to the current Forest Plan and is tiered to 

the 1997 Tongass Land Management Plan Revision EIS and the 2003 

Supplemental EIS for Roadless Area Evaluation for Wilderness Recommendations. 

NFMA, passed in 1976, required each national forest to develop a land and 

resource management plan and revise its plan every 10 to 15 years. The Tongass 

became the first forest to complete a Forest Plan under NFMA in April 1979. The 

Alaska National Interest Lands Conservation Act (ANILCA) passed December 2, 

1980. The 1979 Forest Plan was amended in 1986, reflecting changes mandated 

by ANILCA. The Forest Plan revision process began in 1987 and a Draft EIS was 

published in June 1990. In November 1990, the Tongass Timber Reform Act 

(TTRA) was passed. The Forest Plan was amended in February 1991 to 

incorporate the TTRA changes. The Forest Plan Revision process continued with a 

Supplement to the Draft EIS published in September 1991, which incorporated all 

changes required by TTRA and evaluated a new set of alternatives. Because 

Congress had just acted on the wilderness issue following completion of the June 

1990 Draft EIS, the Forest Service did not reconsider roadless areas for potential 

wilderness recommendation. The Forest Service prepared a Final EIS in the fall of 

1992, but did not publish an associated Record of Decision (ROD). The Regional 

Forester found there was new information that should be collected to respond to 36 

CFR 219.19. That process led to the 1997 Final EIS and the Forest Plan Revision 

ROD (1997 ROD). 

The 1997 Forest Plan was the subject of 33 separate appeals by organizations and 

individuals. In 1999, the Under Secretary of Agriculture affirmed the Regional 

Forester’s decision regarding all 33 appeals, based on the 1997 Tongass Forest 

Plan Revision Final EIS and planning record. The Under Secretary also issued a 

new ROD (1999 ROD) for the 1997 Tongass Land Management Plan Revision. 

Introduction 

Forest Planning 

History on the 

Tongass 

National Forest 
Purpose and Need Final EIS

1 Purpose and Need

1-2 

Two lawsuits challenged the 1997 and 1999 RODs in the U.S. District Court for the 

District of Alaska. The Alaska Forest Association and some Southeast Alaska 

communities challenged many aspects of the 1997 Plan and the process by which 

the 1999 ROD was issued. The Sierra Club and other environmental groups 

challenged the lack of wilderness area consideration and potential 

recommendations in the 1997 Plan Revision, FEIS and ROD. The Court issued a 

single opinion for both cases in March 2001. 

In the Alaska Forest Association case (Alaska Forest Ass’n v. United States Dep’t of 

Agric. No. J99-0013 CV [JKS] [D. Alaska]), the U.S. District Court upheld the 1997 

ROD against all challenges, but held that the 1999 ROD was not properly adopted. 

The Court vacated the 1999 ROD and enjoined the Forest Service from 

implementation. The Court further directed the Forest Service to prepare an SEIS 

addressing the changes from the 1997 Tongass Forest Plan. Because of the 

extensive public involvement and scientific review in the 1997 ROD, and its 

thorough policy and legal review of the administrative appeal process and by the 

District Court, the Forest Service did not propose changes to the 1997 ROD similar 

to those enjoined by the District Court. 

In the Sierra Club challenge of the 1997 Tongass Forest Plan Revision FEIS (Sierra 

Club v. Lyons, No. J00-0009 CV [JKS] [D. Alaska]), the Ninth Circuit Court found the 

1997 Tongass Forest Plan should have considered making wilderness 

recommendations in the Final EIS. The Court ordered the Forest Service to prepare 

an SEIS evaluating wilderness recommendations for roadless areas on the Tongass 

and provide the relative contribution to the National Wilderness Preservation System 

in its Analysis of the Management Situation. The Forest Service issued a Final SEIS 

and ROD for Roadless Area Evaluation for Wilderness Recommendations in February 

2003. 

The Natural Resources Defense Council (NRDC) filed a lawsuit (referred to as 

NRDC I) in the U.S. District Court of Alaska in December 2003 challenging the 1997 

Forest Plan and six timber sales. In January they filed a separate lawsuit on a 

seventh timber sale (referred to as NRDC II) and another lawsuit challenging an 

eighth sale in March 2004 (referred to as NRDC III). The District Court upheld the 

1997 Forest Plan and related National Environmental Policy Act (NEPA) documents 

on all claims in September 2004. NRDC appealed this ruling to the Ninth Circuit 

Court of Appeals. The Ninth Circuit Court issued a ruling on NRDC I and NRDC II in 

August 2005. It found inadequacies primarily relating to the NEPA process for the 

1997 Forest Plan. These inadequacies dealt with the timber demand estimates, the 

range of alternatives related to timber demand, and the cumulative effects analysis 

related to activities on non-NFS lands. While this process was taking place, the 

Forest completed a 5-Year Review of the Forest Plan. This review identified a 

number of items that could lead to adjustments to the Plan. 

The purpose and need for this EIS is to respond to the Ninth Circuit Court's decision 

in Natural Resources Defense Council vs. U.S. Forest Service (421 F.3d 797, 

August 5, 2005). In that decision, the Court held that the EIS and ROD for the 

Forest Plan adopted in 1997 had errors relating to the use of projected market 

demand for timber, the range of alternatives considered relative to the market 

demand calculations, and the cumulative effects of activities on non-NFS lands. In 

addition, there is a need to consider adjustments to the Plan based on information 

generated during the recent 5-Year Review of the Forest Plan. Therefore, the 

purpose and need for this EIS primarily relates to the August 2005 Court decision, 

the 5-Year Plan Review, and other minor clarifications and updates. 

Purpose and 

Need 
Purpose and Need 1

Final EIS 1-3 Purpose and Need

The 16.8-million-acre Tongass National Forest (Tongass or Forest) occupies about 

7 percent of the area of Alaska. The Tongass is located in the southeastern portion 

of the state (the area commonly called the panhandle of Alaska or Southeast 

Alaska) and extends from Dixon Entrance in the south to Yakutat Bay in the north, 

and is bordered on the east by Canada and on the west by the Gulf of Alaska. The 

Tongass extends approximately 500 miles north to south and approximately 120 

miles east to west at its widest point. Figure 1-1 is a vicinity map of the Forest. 

The Tongass includes a narrow mainland strip of steep, rugged mountains and 

icefields and more than 1,000 offshore islands known as the Alexander Archipelago. 

Together, the islands and mainland have nearly 11,000 miles of meandering 

shoreline, with numerous bays and coves. A system of seaways separates the 

many islands and provides a protected waterway called the Inside Passage. 

Federal lands comprise about 95 percent of Southeast Alaska, with about 80 

percent in the Tongass National Forest and most of the rest in Glacier Bay National 

Park and Preserve. The remaining land is held in state, Native corporations, and 

other private ownerships. 

Most of the area of the Tongass is wild and undeveloped. Approximately 73,000 

people inhabit Southeast Alaska, primarily in 32 communities located on islands or 

mainland coastal areas. Only eight of the communities have populations greater 

than 1,000 persons. Most of these communities are surrounded by, or adjacent to, 

NFS land. Only three communities are connected to other parts of the mainland by 

road: Haines and Skagway in the north, and Hyder in the southeast. 

The economies of Southeast Alaska’s communities rely on the Tongass National 

Forest to provide natural resources for uses such as fishing, timber harvesting, 

recreation, tourism, mining, and subsistence. Maintaining the abundant natural 

resources of the Forest, while providing opportunities for their use, is a major 

concern of Southeast Alaska residents. 

Ranger District offices on the Tongass National Forest are located in Yakutat, 

Juneau, Hoonah, Sitka, Petersburg, Wrangell, Thorne Bay, Craig, and Ketchikan. 

There are also two National Monuments, Admiralty Island with an office in Juneau 

and Misty Fiords with an office in Ketchikan (Figure 1-1). 

Identification of issues helps define or predict the resources or uses that could be 

most affected by the management of NFS lands. These issues are used as a basis 

to formulate management alternatives or to measure differences between 

alternatives. 

Ten public issues were originally identified in 1988 for the Forest Plan Revision. 

These original issues included scenic quality, recreation, fish habitat, wildlife habitat, 

subsistence, timber harvest, roads, minerals, roadless areas, and local economy. 

The 1991 Forest Plan Revision Supplemental Draft EIS (SDEIS) added an 

additional concern, identifying and considering for recommendation potential wild, 

scenic, and recreational rivers. 

After the release of the 1991 SDEIS, considerable new information pertaining to the 

Tongass Forest Plan Revision became available. Out of this information emerged 

five additional issues, determined by the Regional Forester to need more study and 

evaluation before a final revised Forest Plan could be adopted. Some of these 

issues were aspects or extensions of the ten public issues previously considered; 

others were new as issues or had not been considered as issues in themselves. 

The five issues were wildlife viability, fish habitat, karst and caves, alternatives to 

clearcutting, and socioeconomic considerations. These issues were assessed in 

the 1996 Revised SDEIS and the 1997 Tongass Forest Plan Revision Final EIS. 

Forest Location 

and Description 

Public Issues 
Purpose and Need Final EIS

1 Purpose and Need

1-4 

Figure 1-1. 

Tongass National Forest Vicinity Map 
Purpose and Need 1

Final EIS 1-5 Purpose and Need

The 2003 SEIS reviewed and evaluated roadless areas and analyzed alternative 

groupings of roadless areas for wilderness recommendations. Two broad issue 

categories, referred to as key issues, were identified as the major issues driving the 

alternatives of the SEIS analysis. They included 1) the long-term protection of 

roadless areas and associated values, and 2) the social and economic well-being of 

the communities of Southeast Alaska. 

Public Input 

The scope of this EIS was initially determined by the Court in its 2005 ruling, and by 

the 5-Year Review of the Forest Plan. Additional information was considered to help 

clearly define the issues and for use in the development and analysis of alternatives. 

For this Final EIS, comments and information from a wide variety of public input that 

related to amending the Forest Plan were considered. This information included the 

following: 

• Public comments generated during the 1997 Tongass Forest Plan Revision 

process; 

• Tongass Forest Plan Revision appeals; 

• Public input specific to the Tongass National Forest on the Forest Service’s 

2001 National Roadless Area Conservation Rule; 

• Public comments generated relative to the 2003 Supplemental EIS; 

• Public input expressed during project-level NEPA analyses over the past 10 

years or so; and 

• Public input received in response to the Notice of Intent and the Web site for this 

EIS. 

The planning record of the Tongass includes public input encompassing most of the 

last 2 decades. Of special note are the extensive public meetings held in Southeast 

Alaska for the 1997 Forest Plan Revision, the 2001 National Roadless Area 

Conservation Rule, and the 2003 SEIS. 

In addition to the above, public involvement has occurred during the development of 

this EIS. Public involvement activities that have taken place during this time frame 

include the following: 

• The Notice of Intent was published in the Federal Register in March 2006. 

• A Forest Plan Adjustment Web site was developed in January 2006 and has 

been maintained to inform and engage the public since then. It is updated as 

new information is developed or published and provides a mechanism for public 

input. Several hundred comments and questions were received through the 

Web site or via emails associated with the Web site in the first few months of 

operation. 

• A Weblog regarding the Forest Plan adjustment effort was established in July 

2006 and was continually maintained as another method of public 

communication. 

• In response to the above items, a number of letters were received containing 

comments regarding the issues and alternatives. These included letters from 

environmental organizations, the timber industry, Southeast Alaska community 

organizations, and a number of individuals from Southeast Alaska and across 

the nation. 
Purpose and Need Final EIS

1 Purpose and Need

1-6 

• Government-to-government consultation has been conducted throughout the 

process, and is ongoing, with federally recognized Tribes. 

• A number of group-specific meetings have also occurred with various 

organizations (including Alaska Native groups). 

• A variety of news releases were issued relative to the Forest Plan adjustment 

throughout the process. 

• A series of ongoing meetings, hosted by the National Forest Foundation and 

The Nature Conservancy, known as the Tongass Futures Roundtable, have 

resulted in considerable discussion of Tongass management issues among a 

broad spectrum of individuals and groups interested in the future of Southeast 

Alaska since May 2006. 

• The input received prior to issuance of the Draft EIS was reviewed and a 

summary of this synthesis is presented as Appendix A (Issue Identification) to 

the Final EIS. 

• A Draft EIS and Proposed Forest Plan were released on January 12, 2007. This 

began a 90-day comment period, which was later extended to 108 days. The 

comment period closed on April 30, 2007. 

• During the comment period, open houses and public hearings were held in 24 

Alaska communities. In addition to comments on the Draft EIS, the hearings 

provided opportunity to hear concerns related to subsistence and Alaska Native 

issues. 

• On March 22, 2007, an open house and public hearing was held on the internet, 

to solicit public comment in an open forum from individuals living anywhere in 

the world. 

• Over 84,000 comment documents were received, including individual letters, 

form letters, emails, hearing testimony, and comments submitted directly via the 

Forest Plan Adjustment Web site. Slightly more than 2,000 of these were 

classified as individual comment documents and the others were classified as 

form letters and emails. The individual comment documents were subdivided 

into approximately 5,500 individual comments. Responses were received from 

all 50 states and 89 foreign countries. A summary of the substantive comments 

and Forest Service responses to those comments can be found in Appendix H. 

Key Issues 

Any alternative that proposes to change the Forest Plan could affect resources 

and/or outputs relative to the current Forest Plan. Therefore, Chapter 3 of the EIS 

shows the effects of the various alternatives on all relevant resources and evaluates 

their effects relative to all of the issues and concerns previously identified during the 

1997 plan revision process. However, based on the purpose and need of this EIS 

and the public input received during the current EIS process, some issues are more 

likely to influence the comparison among alternatives and represent the major 

issues to be evaluated. These issues were grouped into three broad issue 

categories, referred to as the key issues. These key issues are the major issues 

driving the alternatives and analyses. 

The Three 

Focus Issues 
Purpose and Need 1

Final EIS 1-7 Purpose and Need

Key Issue 1 – Protection of high value roadless areas from road development 

and timber harvest activity on the Tongass National Forest is of local and 

national importance, particularly for wildlife and biodiversity, recreation, and 

tourism. 

Many people believe roadless areas should be allowed to evolve naturally through 

their own dynamic processes and should be afforded protection that ensures this 

will occur. The Tongass includes very large undeveloped land areas with several 

portions of the Forest consisting of contiguous roadless areas that exceed 1 million 

acres and represent large, unfragmented blocks of wildlife habitat. This large scale 

of roadless lands does not exist on any other National Forest, except the Chugach 

National Forest in Southcentral Alaska. 

Roadless areas are considered important because of their wildlife habitat and 

recreation values and their importance for tourism. They are also important 

because of the passive-use and ecosystem services values they provide. 

Passive-use values represent values that individuals assign to a resource 

independent of their use of that resource. Typically this includes existence, option, 

and bequest values, and represents the value individuals obtain from knowing that 

expansive roadless areas exist, knowing that they are available to visit in the future 

should they choose to do so, and knowing that they are available for future 

generations to inherit. There is interest in preserving large portions of the Tongass 

because so much of it is in a natural condition, unlike most other national forests, 

and because the Forest represents a significant portion of the world’s remaining 

temperate rainforests. 

Ecosystem services represent the services provided to society by healthy 

ecosystems. These services and benefits include what some consider to be longterm life support benefits to society as a whole. Examples of ecosystem services 

include watershed services, soil stabilization and erosion control, improved air 

quality, climate regulation and carbon sequestration, and biological diversity. 

Indicators: Analysis relative to this issue compares the amount and proportion of 

land protected in non-development Land Use Designations (LUDs); the amount of 

inventoried roadless areas that would be protected under each alternative; and the 

amount of productive old-growth forest that would be protected under each 

alternative. Also, the values of the lands protected are considered. Non-use or 

passive-use values are discussed qualitatively and with examples provided from 

other studies. 

Key Issue 2 – The Tongass National Forest needs to seek to provide a 

sufficient timber supply to meet the market demand and help maintain a 

vibrant economy in Southeast Alaska. 

TTRA (Section 101) requires the Forest Service to seek to provide a supply of 

timber from the Tongass National Forest that meets the annual market demand and 

the market demand for each planning cycle, consistent with providing for the 

multiple-use and sustained yield of all renewable resources. With the cancellation of 

long-term timber contracts and the closure of two Southeast Alaska pulp mills in the 

1990s (discussed in detail in Chapter 3 Environment and Effects), current demand 

for Alaska’s National Forest timber depends on markets for sawn wood and the 

option of exporting manufacturing residues and lower grade logs. Future or 

planning cycle demand scenarios cover a wide range of issues and depend on rates 

of economic growth in key markets, conditions faced by competitors, and the rate of 

investment and innovation in Alaskan manufacturing. 
Purpose and Need Final EIS

1 Purpose and Need

1-8 

Over the past half a century, the timber industry has been a major component of the 

economy of Southeast Alaska. However, with the closure of two Southeast Alaska 

pulp mills and the growth of tourism, timber has played a lesser role. Because the 

economy of Southeast Alaska is based on relatively few industries, maintaining an 

active timber industry is important for maintaining a well-diversified economy. 

Indicators: Analysis relative to this issue compares the likely demand for timber 

based on capacity of the local industry and the amount of harvest made available to 

meet that demand. It also considers the type of wood (sawlogs and utility wood) 

made available and the usefulness of that wood type to the local industry, as well as 

the amount of timber that would be available from state and private sources. Finally, 

it considers the effects on the regional and national economies and the effects on 

the local communities. 

Key Issue 3 – Protection of the wildlife habitat and biodiversity of the Tongass 

National Forest is of local and national significance and is affected by road 

development and timber harvest activities. 

The Tongass National Forest supports a unique and important assemblage of 

wildlife including the largest population of brown bears and breeding bald eagles in 

the world, species of high importance for subsistence (e.g., Sitka black-tailed deer), 

an extensive array of endemic mammals and other species, and a large number of 

species that are at least partially dependent on old-growth habitats (e.g., marten and 

goshawk). Populations of many of these species and the biodiversity of Southeast 

Alaska are affected by timber harvest and the development of roads. 

Although less than 10 percent of the productive old-growth habitat on the Tongass 

has been converted to young growth, the percentage is much higher for certain 

types of old growth, such as lowland and large-tree old growth. In addition, a high 

percentage of non-NFS lands have been harvested at a much higher rate. 

Therefore, the cumulative effects of harvest and road building on wildlife in 

Southeast Alaska are greater than the effects for the Tongass by itself. 

Indicators: Analysis relative to this issue compares the amount of productive oldgrowth forest that would be protected under each alternative, as well as the 

percentages of biogeographic provinces that would be protected in reserves. It also 

considers the role of the managed lands (development LUDs) in providing wildlife 

habitat. It rates the alternatives in terms of the expert panel ratings conducted for 

the 1997 Forest Plan Revision EIS. Habitat changes, as documented by habitat 

amounts, changes in road densities, and habitat models are also used as indicators. 

Finally, cumulative harvest and road development on non-NFS lands is quantified 

and evaluated in conjunction with harvest and road development on NFS lands. 

A number of updates and changes were made in the Final EIS in response to new 

information and to comments received on the Draft EIS. The main areas of change 

are described below: 

1. Refinements were made to base Geographic Information System (GIS) 

coverages such as ownership, past harvest, roads, and LUDs to reflect updates 

due to changes in the existing condition and refinement of inventory data. 

2. Because of refinements made to the base GIS coverages, the acreages and 

mileages associated with the existing condition and the alternatives changed, in 

many cases, and were updated throughout the document. Sometimes analysis 

methods were also refined, which resulted in changes to the quantification of 

effects. 

Changes 

between the 

Draft EIS and 

Final EIS 
Purpose and Need 1

Final EIS 1-9 Purpose and Need

3. Expanded discussion and analysis and incorporation of additional scientific 

references and studies were included in many sections of the Final EIS. This 

expanded discussion and analysis included elaboration on the risk and scientific 

uncertainty associated with issues. 

4. The Biodiversity section of Chapter 3 was expanded to more fully address 

issues related to disproportionate past harvest, harvest on non-NFS lands and 

related cumulative effects, and effects on intact watersheds. 

5. Alternative 1 was modified in response to comments on the Draft EIS. It now 

has a significantly smaller timber management land base, and excludes all 

inventoried roadless areas and many higher value roaded areas from 

commercial timber management. Examples include areas such as all of Kuiu, 

Baranof, and Kruzof Islands, much of Chichagof Islands, and all mainland 

areas. 

6. Alternative 7 was modified in response to comments on the Draft EIS. It now 

deletes the requirement for buffers on Class III streams. 

7. Further refinements and changes to the proposed Forest Plan were developed 

between the Draft EIS and Final EIS. 

8. Appendix B was substantially updated and additional information on modeling 

and analysis techniques was added. 

9. Appendix C was substantially revised based on updated and new information on 

the likelihood of various land adjustments. 

10. A new Appendix D was developed, which presents background, rationale, 

assumptions, and additional analyses related to the old-growth conservation 

strategy, Wildlife Standards and Guidelines, and wildlife viability analyses as 

they relate to the Final EIS alternatives. 

11. Although extensive mapping, quantification, and analysis of past harvest on 

non-NFS lands was completed for the Draft EIS, a more extensive analysis of 

past old-growth harvest, including the past disproportionate harvest of several 

categories of old growth, and the effects of this harvest, was completed and 

documented in the Final EIS, primarily in the Biodiversity section of Chapter 3;,a 

catalogue of past harvest is presented in Appendix E. 

12. The Biological Assessment for threatened and endangered species that was 

originally developed for the 1997 Forest Plan Revision was updated and refined 

and included as Appendix F. 

13. Appendix G was developed to summarize new information on timber demand 

and supply on the Tongass National Forest. 

14. A new Appendix H was developed, which summarizes the comments received 

on the Draft EIS and the Forest Service responses to these comments. Copies 

of the letters received from agencies and elected officials, including tribal 

governments, are also included.. 

This Final EIS is organized into several chapters and a number of appendices. 

Chapter 1, “Purpose and Need,” describes the reasons for proposing and 

completing a plan amendment. Chapter 2, “Alternatives,” describes the process 

used to develop alternatives, explains the components of a Forest Plan, discusses 

alternatives not considered in detail, and describes the No-Action Alternative and 

Proposed Action Alternative as well as five other alternatives. Maps of the proposed 

LUDs under each alternative are also displayed in Chapter 2. Finally, a comparison 

Organization of 

the Document 
Purpose and Need Final EIS

1 Purpose and Need

1-10

of these alternatives based on the issues and significant environmental effects is 

presented. 

The discussions of the “Affected Environment” and the “Environmental 

Consequences” are combined in Chapter 3, “Environment and Effects.” This is 

done so the environmental consequences (effects) of the alternatives on forest 

resources, and the background information needed to understand these 

consequences, are discussed together for each resource. The focus is on 

significant effects, with the analysis centered on the public issues. Chapter 3 also 

begins with a general description of the Tongass National Forest. 

The Final EIS also includes a list of preparers; a list of agencies, organizations, and 

persons receiving copies of the document; a bibliography; a glossary; and an index 

(Chapters 4 through 8). Appendices to the Final EIS are contained in a separate 

volume (Final EIS Volume II). They provide more background on planning actions, 

certain resources and analyses, modeling and analysis techniques, a catalogue of 

past harvest, and a summary of the comments on the Draft EIS with Forest Service 

responses (Appendix H). 

In addition to the two Final EIS volumes, three separate documents are associated 

with the Final EIS. First, a separate Summary booklet is included within the CD 

case. Second, the Record of Decision (ROD), which discloses the decision and its 

rationale, is published along with the Final EIS. Third, the Forest Plan, which 

includes goals and objectives, the management prescriptions for each LUD, Forestwide standards and guidelines, plan implementation direction, a monitoring and 

evaluation plan, and related appendices, accompanies the ROD. In addition, a map 

packet includes color maps of the LUDs for each alternative and a ROD map that 

displays the LUDs associated with the decision. 

The CD version of the Final EIS, Forest Plan, and ROD includes all of the 

documents described above, plus additional maps. As noted above, a Summary 

booklet is included in the CD case. Additional information, maps, and reference 

documents used in the Tongass Forest Plan Amendment process are contained in 

the planning record. Many of these documents and records are also available on 

the Forest Plan Adjustment Web site (http://tongass-fpadjust.net/). These can also 

be accessed through the main Tongass Web site (www.fs.fed.us/r10/tongass). The 

planning record in its entirety is incorporated here by reference. 
CHAPTER 2 

ALTERNATIVES CHAPTER 1 PURPOSE AND NEED
Alternatives 2

Final EIS 2-1 Alternatives 

Alternatives 

Chapter 2 is divided into four parts: 

1. A discussion of how alternatives were developed and of what constitutes an 

alternative; 

2. A discussion of alternatives considered but eliminated from detailed study; 

3. A full description of the alternatives that are considered in detail; and 

4. A comparison of the alternatives considered in detail. 

A color map for each of the seven alternatives considered in detail is included in the 

Map Section of the CD version of the EIS and in the Map Packet accompanying the 

hard copy version. These maps are also available on the EIS Web site at 

www.tongass-fpadjust.net. Each alternative map shows the locations of the Land 

Use Designations (LUDs) for that alternative. 

What a Forest Plan Includes 

Land management planning may be compared to city, county, or borough zoning. 

Just as areas in a community are zoned as commercial (allowing business uses), 

industrial (allowing factories), or residential (allowing only homes, schools, etc.), the 

forest is also zoned to allow, or not allow, various uses and activities. Land 

management (forest plan) zoning is done through the use of LUDs. This Forest 

Plan only applies to federal lands within the Tongass National Forest. 

Land Use Designations specify ways of managing an area of land and the resources 

it contains. LUDs may emphasize certain resources (such as remote recreation or 

old-growth wildlife habitat) or combinations of resources (such as providing for 

scenic quality in combination with timber harvesting). Each LUD has a detailed 

management prescription, which includes standards and guidelines. 

Prescriptions are specific actions or treatments used in the management of forest 

resources, such as two-age timber harvest methods. Each management 

prescription specifies what is allowed to be considered for site-specific project 

proposals, and under what conditions. Standards and guidelines impose limitations 

on how, where, and when management activities are carried out, usually for specific 

resource protection purposes. Management prescriptions and standards and 

guidelines only apply to federal lands. 

LUDs are assigned, or allocated, to specified areas of land. Under any one 

alternative, a given area of land will generally have only one LUD assigned to it; 

however, the Minerals and Transportation and Utility Systems LUDs are overlay 

LUDs and can apply to a given piece of ground when and if minerals or 

transportation/utility systems are to be developed on that piece of ground. In some 

other cases, two LUDs may apply to the same area, such as a Wild River within a 

Wilderness. In these cases, the more restrictive direction always applies. Some 

LUDs, such as Wilderness and LUD II, are congressionally designated and 

represent permanent allocations. 

Forest resource use opportunities, such as timber harvesting or recreation, can be 

made available in different amounts. What lands to make available for timber 

harvest or how much of a particular kind of recreation opportunity to provide are 

questions that land management planning must also address. It is not always 

possible to provide all resource use opportunities in the amounts desired by 

Introduction 

Alternative 

Development 

Process 
2 Alternatives 

Alternatives 2-2 Final EIS

everyone. The National Forest Management Act mandates the Forest Service to 

provide for multiple use and the sustained yield of the products and services 

obtained from the Forest. 

The alternatives themselves are usually designed around a “framework” that 

establishes how much emphasis is placed on each of the key issues or other issues. 

The EIS alternatives are directly related to the issues described in Chapter 1. How 

alternatives were developed to address the issues is discussed below. The 

Comparison of Alternatives section at the end of this chapter also discusses ways in 

which the alternatives address the issues. 

How Alternatives are Described 

Each alternative for this EIS is presented in the same format. This includes the 

following components: 

• Framework. The basis for alternative design. 

• Desired Condition. A general description of the ecological, physical, and 

economic/social conditions that are expected in the future under each 

alternative framework. 

• Land Use Designations. The acreages allocated to each Land Use 

Designation. 

• Standards and Guidelines and Management Prescriptions. What changes 

to the existing Forest-wide standards and guidelines and management 

prescriptions are proposed? 

• Selected Outputs and Measure. A summary of predicted outputs and 

measures associated with each alternative. 

Land Use Designations 

The alternatives are constructed using the LUD allocations defined in the 1997 

Tongass Forest Plan as the base. This base represents the current Tongass Forest 

Plan and consists of Alternative 11 in the 1997 Tongass Forest Plan Revision Final 

EIS, adjusted by the 1997 Record of Decision (ROD) and subsequent nonsignificant Forest Plan Amendments made for projects since 1997. 

The LUD allocations of the current Tongass Forest Plan define the No-Action 

Alternative (Alternative 5). The LUD allocations for the Proposed Action alternative 

(Alternative 6) are very similar to the No Action, but incorporate some adjustments. 

The other five alternatives differ more substantially from the No Action and 

Proposed Action in terms of their LUD allocations. 

The management prescriptions for each specific LUD under the No Action 

alternative are the same as under the current Forest Plan (see Chapter 3 of the 

current Forest Plan, USDA Forest Service 1997b). These management 

prescriptions are summarized below, following a discussion of current Forest Plan 

LUDs. The management prescriptions for the other alternatives incorporate very 

slight modifications; these modifications are fully described in the amended Forest 

Plan that accompanies this Final EIS, and are summarized in the alternative 

descriptions, along with the exceptions to the amended Forest Plan. 
Alternatives 2

Final EIS 2-3 Alternatives 

Wilderness and National Monument

• Wilderness and Wilderness National Monument – Manage for the protection 

and perpetuation of essentially natural biophysical and ecological conditions and 

provide outstanding opportunities for solitude, primitive recreation, and scientific 

and educational uses, consistent with ANILCA, the Wilderness Act, and TTRA. 

Roads are normally not permitted and use of mechanical transport and 

motorized equipment is limited. 

• Non-wilderness National Monument – Manage the non-wilderness portions of 

Admiralty Island and Misty Fiords National Monuments to facilitate development 

of significant mineral resources and to ensure that mining activities are 

compatible, to the maximum extent feasible, with the purposes for which the 

Monuments were established. 

Mostly Natural Setting

• LUD II – Manage these Congressionally designated areas in a roadless state to 

retain the wildland character. Wildlife and fish habitat improvement and 

primitive recreational facility development may be permitted. Timber harvesting 

is limited to insect and disease control. Roads will not be built except to serve 

mining and other authorized activities and vital Forest transportation and utility 

system linkages. (These areas are sometimes referred to as “legislated LUD II.”) 

• Research Natural Area – Manage forest resources for research and education 

and/or to maintain natural diversity. Current natural conditions are maintained 

where possible. No timber harvest is allowed. 

• Enacted Municipal Watershed – Manage enacted municipal watersheds to 

meet State Water Quality Standards for domestic use. Timber harvest is limited 

to insect and disease control; however, timber may be removed under 

conditions that safeguard the quantity and quality of water. Roads are generally 

limited to those needed to administer the municipal watersheds. 

• Old-growth Habitat – Maintain a diversity of old-growth conifer habitats in their 

natural condition to favor old-growth associated fish and wildlife species. No 

timber harvesting will be scheduled and roads will be located outside the area 

when possible. 

• Semi-remote Recreation – Provide motorized and non-motorized recreation 

opportunities in natural and natural-appearing environments where interaction 

with others is low and the opportunity for independence and self-reliance is 

moderate to high. Allow occasional concentrated recreation and tourism 

facilities in a natural-appearing setting. When present, roads are few and used 

primarily to expand and improve access to recreation opportunities or to permit 

access to other parts of the Forest and other ownerships. Timber harvest is 

limited to salvage of catastrophic events or beach log recovery. 

• Remote Recreation – Provide recreation opportunities and experiences outside 

Wilderness in unmodified natural environments where interaction with other 

visitors is infrequent, and the opportunity for independence and self-reliance is 

high. Timber harvesting is limited to insect and disease control. Roads are 

generally absent. 

• Special Interest Area – Provide for the inventory, maintenance, protection, and 

interpretation of areas with unique archeological, historical, recreational, scenic, 

geological, botanical, zoological, or paleontological features. No timber harvest 

is scheduled. Roads are normally not permitted unless compatible with 

interpretive objectives. 
2 Alternatives 

Alternatives 2-4 Final EIS

• Wild River – Maintain and enhance the outstandingly remarkable values of river 

segments that qualify the river to be classified a Wild River and recommended in 

the 1997 Tongass Forest Plan ROD. Shorelines are primitive and undeveloped. 

Timber harvesting is limited to insect and disease control. Roads are generally 

not present. Access is by trail, airplane, or boat. 

• Scenic River – Maintain and enhance the outstandingly remarkable values of 

river segments which qualify the river to be classified a Scenic River and 

recommended in the 1997 Tongass Forest Plan ROD. Shorelines are largely 

undeveloped but may be accessible in places by roads. Timber harvesting is 

limited by the ability of the landscape to visually absorb the activity. Roads are 

designed to be compatible with the landscape. 

• Recreational River – Maintain and enhance the outstandingly remarkable 

values of river segments that qualify the river to be classified a Recreational 

River and recommended in the 1997 Tongass Forest Plan ROD. Shoreline 

development may occur and the river may be readily accessible by road. 

Timber harvesting is allowed with priority to maintain existing and proposed 

recreation sites within the corridor. Roads are permitted. 

Moderate Development

• Experimental Forest – Manage to provide a variety of long-term opportunities 

for Forest research and demonstration areas. Timber harvesting will occur only 

for these purposes. Roads may be developed to facilitate ongoing research. 

• Scenic Viewshed – Management activities are not visually apparent to the 

casual observer in the near distance from visual priority travel routes and use 

areas. In the middle to background distance, activities are subordinate to the 

landscape character of the area. Timber harvest is allowed and roads are 

permitted. 

• Modified Landscape – Manage for a variety of uses. Management activities 

are subordinate to scenic quality as seen in the near distance. In the middle to 

background distance, activities may dominate but are designed to be compatible 

with features found in the characteristic landscape. Timber harvest is allowed 

and roads are permitted. 

Intensive Development

• Timber Production – Manage the area to maintain and promote industrial wood 

production. These lands will be managed to advance conditions favorable for 

the timber resource and for long-term timber production. Roads are permitted. 

Overlay LUDs

• Minerals – Encourage the exploration and development of mineral resources in 

areas having high potential for mineral commodities, including nationally 

designated strategic and critical minerals. Until mineral activities are initiated, 

the area will be managed according to the underlying LUD. 

• Transportation and Utility Systems – Emphasize existing and potential stateidentified major public transportation and utility systems. Until transportation or 

utility systems are constructed, the area will be managed according to the 

underlying LUD. 
Alternatives 2

Final EIS 2-5 Alternatives 

Development of Potential Alternatives 

As indicated by the Ninth Circuit Court of Appeals, there is a need to evaluate a 

wide range of alternatives that relate to varying degrees of development of roadless 

lands, while at the same time providing a supply of timber that corresponds with the 

full range of timber demand scenarios. Therefore, the array of EIS alternatives was 

designed to address a full range of roadless development and timber 

supply/demand levels. Adjustments to the standards and guidelines of the Forest 

Plan were also incorporated into various alternatives to address clarifications and 

updates identified as needed in the 5-Year Review and by Forest Service staff. 

Basic tools used in the development of the alternatives were the recent timber 

demand projections (Brackley et al. 2006), the existing inventory of roadless lands, 

and various sources of information regarding the qualities of the roadless lands. In 

addition, because of the rigorous level of scientific review that went into designing 

the current conservation strategy, strong consideration was given to maintaining its 

elements. Other alternative proposals considered during the 1997 Forest Plan 

Revision and the 2003 Supplemental EIS processes were given consideration. 

A total of 49 alternatives were considered as part of the alternative development 

process. Of these, 42 alternatives were eliminated from detailed study and are 

discussed in the following section (Alternatives Eliminated from Detailed Study). 

The remaining seven alternatives are considered in detail in this EIS. 

The set of alternatives that are analyzed in detail were designed to fully bracket the 

range of timber demand scenarios identified by Brackley et al. (2006). Equally 

important, they were designed to range from very limited development of inventoried 

roadless areas to more intensive development within roadless areas. This range is 

captured by the seven alternatives. 

Brackley et al. (2006) described four timber demand scenarios: limited lumber 

production, expanded lumber production, medium integrated industry, and high 

integrated industry. The following table compares the projected demand for 2022 

under these four scenarios with the Allowable Sale Quantity (ASQ) identified for the 

second decade of each of the alternatives considered in detail (ASQ is discussed in 

more detail below in the Alternatives Considered in Detail section). 

Table 2-1 

Projected Demand for 2022 under Brackley et al.’s Four Timber 

Demand Scenarios 

Brackley et al. Demand Scenarios & 

Projected 2022 Demand1

 (MMBF) 

Alternatives Considered in Detail & 

Second-Decade ASQ (MMBF) 

 Alternative 1 – 49 

Scenario 1 – 68 

 Alternative 2 – 152 

Scenario 2 – 187 

 Alternative 3 – 203 

Scenario 3 – 204 

 Alternative 5 – 267 

Alternative 6 – 267 

Scenario 4 – 342 Alternative 4 – 342 

Alternative 7 – 421 1 These figures include total volume that would need to be harvested to meet the demand 

projected by Brackley et al. 2006
2 Alternatives 

Alternatives 2-6 Final EIS

Alternatives 1 through 4 were designed to correspond with Scenarios 1 through 4, 

respectively, while also responding to other concerns. The discrepancies between 

the second decade ASQs for Alternatives 1 and 2 and projected demand for 2022 

under Scenarios 1 and 2 reflect these concerns. 

The ASQ for Alternative 1 is 19 MMBF (28 percent) below the projected demand of 

Scenario 1. There are several reasons for this difference. First, the purpose of 

Alternative 1 is to depict the current situation, meaning annual timber harvest levels 

over the last few years of around 50 MMBF. In addition, Alternative 1 responds to 

the court’s direction and public comments by scheduling no timber harvest in 

roadless areas, as discussed below. This alternative also responds to 

recommendations from the public to avoid harvest on Kuiu Island. The ASQ of 

Alternative 2 is 25 MMBF (19 percent) below the projected demand of Scenario 2. 

The purpose of Alternative 2 is to display an alternative that restricts development 

activities to lower value roadless areas. Alternative 3 differs from Scenario 3 by only 

1 MMBF; Alternative 4 matches Scenario 4 exactly. 

The Forest Plan revision process started in 1987 and resulted in the development of 

dozens of alternatives that were described in the Draft EIS (1990), Supplement to 

the Draft EIS (1991), Revised Supplement (1996), Final EIS (1997), and 

Supplemental EIS (2003). In addition, a 1992 draft version of the Final EIS included 

alternatives that became the basis of some 1996 Revised Supplement and 1997 

Final EIS alternatives. Each of these alternatives was considered for detailed study 

and comparison in this EIS, in their original form or in a modified form. Altogether, 

41 alternatives were considered for detailed study prior to the selection of the EIS 

alternatives—39 of these were based on previous alternatives and 2 were new 

ones. The 39 previous alternatives are summarized in Table 2-2. 

These alternatives were considered in light of the key issues and the purpose and 

need. They ranged in allowable sale quantity (which is the maximum annual 

average amount of timber that can be sold from the suitable forest land base) from 0 

to almost 700 MMBF per year. Development LUD acres in these alternatives 

ranged from a few hundred acres to almost 8 million acres and forest lands suitable 

for timber harvest ranged from 0 to over 2 million acres. 

Five alternatives, which were largely based on previously developed alternatives, 

and two new alternatives were selected for detailed study. Therefore, 34 of the 

previously developed alternatives were considered, but eliminated from detailed 

study. The reasons for not selecting them were either that they were similar to and 

within the range of the selected alternatives, they were outside the range of timber 

demand estimates, or they would result in substantial changes to the current Forest 

Plan standards and guidelines that are not warranted based on the purpose and 

need or the key issues. 

In addition to the 41 alternatives discussed above, 8 other alternatives were 

considered, but not evaluated in detail. Therefore, overall, 49 alternatives were 

considered and evaluated to varying degrees, with 7 of these being analyzed in 

detail and 42 being eliminated from further detailed study. The eight additional 

alternatives that were not analyzed in detail include three alternatives with timber 

volumes below the volume to be harvested under Alternative 1, one alternative 

described by The Nature Conservancy and Audubon Alaska, modified versions of 

Alternatives 4 and 7, an alternative proposed by the Southeast Conference, and a 

partial alternative proposed by the City and Borough of Yakutat. These eight 

alternatives are described in the following paragraphs. 

Alternatives 

Eliminated from 

Detailed Study 
Alternatives 2

Final EIS 2-7 Alternatives 

Table 2-2 

Tongass Forest Plan Alternatives Considered in Detail: 1990 – 2003 

Alternative 

and 

Source 

ASQ 

(MMBF 

annual) 

Suitable lands 

(Acres X 

1,000) 

Non-Development 

LUDs (Acres X 

1,000) 

Development 

LUDs (Acres X 

1,000) 

 1 1997 0 0 16,700 200 

 1 1996 0 74 16,700 200 

 6 2003 92 344 15,700 1,200 

 8 2003 96 351 15,700 1,200 

 5 1997 122 786 12,100 4,800 

 4 1997 130 845 11,700 5,200 

 5 1996 139 1,400 12,100 4,800 

 4 1996 145 1,507 11,700 5,200 

 7 2003 174 521 14,300 2,600 

 A 1990 181 536 13,600 3,300 

 5 2003 209 589 13,800 3,100 

 3 2003 236 620 13,500 3,400 

 3 1997 256 795 12,700 4,200 

 1 2003 259 664 13,200 3,700 

 2 2003 259 664 13,200 3,700 

 4 2003 259 664 13,200 3,700 

 11 1997 267 676 13,200 3,700 

 3 1996 278 1,188 12,600 4,300 

 E 1990 280 717 11,600 5,300 

 A 1991 298 1,173 13,700 3,200 

 10 1997 300 924 12,700 4,200 

 6 1997 309 1,024 12,100 4,800 

 B 1991 343 1,360 13,000 3,900 

 B 1990 354 1,101 12,900 4,000 

 6 1996 362 1,400 12,100 4,800 

 8 1996 364 1,389 10,500 6,400 

 F 1990 389 1,111 11,000 5,900 

 G 1990 390 1,112 11,000 5,900 

 P 1991 418 1,649 11,700 5,200 

 C 1990 450 1,200 10,500 6,400 

 C 1991 451 1,732 11,200 5,700 

 2 1997 463 1,180 11,700 5,200 

 D 1991 472 1,818 11,400 5,500 

 2 1996 489 1,526 11,700 5,200 

 9 1996 513 1,869 10,800 6,100 

 9 1997 549 1,390 10,800 6,100 

 D 1990 640 1,575 9,100 7,800 

 7 1997 640 1,575 9,100 7,800 

 7 1996 689 2,044 9,100 7,800 

Sources: 1990 Draft EIS, 1991 Supplement to the Draft EIS, 1996 Revised Supplement to the Draft EIS, 

1997 Final EIS, and 2003 Supplemental EIS. 
2 Alternatives 

Alternatives 2-8 Final EIS

Zero to Very Low Volume (ASQ) Alternatives 

Consideration was initially given to evaluating zero to very low volume alternatives 

and recommendations were also made in Draft EIS comments that various zero to 

very low volume alternatives should be considered for detailed evaluation. As a 

result, a no-commercial harvest alternative was considered, an alternative with an 

ASQ at a stable level significantly below Alternative 1 was considered, and a 

declining volume alternative that started with an ASQ near the Alternative 1 level, 

but declined over time, was considered. Partially in response to these comments, 

the development land base of Alternative 1 was significantly reduced and the ASQ 

was slightly reduced between the Draft EIS and the Final EIS. As a result, even 

Alternative 1 would produce only 28 MMBF of NIC I sawlogs (the type that could be 

utilized by the existing sawmills) on an annual basis. This volume is equivalent to 

less than 15 percent of the estimated mill capacity of the four largest existing 

sawmills, 11 percent of the estimated active installed processing capacity of all 

existing Southeast Alaska mills, and only 7 percent of the total processing capacity 

of existing Southeast Alaska mills. In addition, the recent actual mill output level has 

been about 35 MMBF. Even Alternative 1 is considered to be a non-sustainable 

alternative for the existing timber industry because it does not meet these volume 

levels (see Economic and Social Environment, Regional and National Economy, in 

Chapter 3). Because the three additional alternatives under consideration, by 

definition, would produce a significantly lower volume than Alternative 1, they would 

clearly not be sustainable for even a portion of the existing timber industry. 

The Tongass Timber Reform Act requires the Forest Service “to seek to meet the 

market demand.” Providing a timber volume that would meet neither the current 

estimated annual demand nor the recent actual mill output levels, and which would 

produce only a fraction of estimated existing mill capacities, would clearly not be 

consistent with TTRA and, therefore, is determined to not be a reasonable 

alternative. Alternative 1 provides an alternative “sideboard” at the low end of the 

timber volume range that is already in the “non-sustainable” category. 

The Nature Conservancy/Audubon Alaska Alternative 

A number of organizations suggested that they might generate a low-harvest 

alternative for consideration. The only low-harvest alternative that was described 

was one by The Nature Conservancy and Audubon Alaska in their Conservation 

Assessment for Southeast Alaska (Albert and Schoen 2007). 

This alternative was defined based on modeling of relative ecological values and the 

ranking of relative suitability for timber production. It includes conservation priority 

watersheds, other watersheds to be managed for intact conditions, as well as timber 

production and integrated management watersheds. The EIS team determined that 

Alternatives 1, 2, and 3 captured the range defined by this alternative and they also 

represented alternatives that were similar to others that would be developed by 

other groups (e.g., they avoid the roadless areas and intact watersheds or different 

combinations of high-value roadless areas or intact watersheds). 

Modified Alternatives 4 and 7 

A modified version of Alternatives 4 and 7 were evaluated for consideration. The 

modification involved replacing portions of the development LUDs in these 

alternatives with the Old-Growth Habitat LUDs from Alternative 6. It was determined 

that the modified Alternative 4 did not produce significantly more timber volume than 

Alternatives 5 and 6 and the modified Alternative 7 was not substantially different 

than Alternative 4. Therefore, these modified alternatives were well within the range 

of the existing alternatives and it was decided they did not need to be analyzed in 

detail. 
Alternatives 2

Final EIS 2-9 Alternatives 

Southeast Conference Alternative 

In its comments on the Draft EIS, the Southeast Conference (an association of 

municipalities, businesses, Native corporations and village councils, civic 

organizations, and individuals from Southeast Alaska) identified specific lands they 

believe should be allocated to the Timber Management LUD to allow for 

reestablishment of an integrated timber industry in Southeast Alaska. These lands 

were reviewed by the EIS team and it was determined that the vast majority of these 

lands (plus additional lands) were included as development LUDs in Alternative 7 

and most of them were also included in several other alternatives. The lands that 

were not included were identified as Old-Growth Habitat, Special Interest Area, or 

Experimental Forest LUDs in most of the alternatives. It was determined that the 

current range of alternatives captured these lands and there was no need to develop 

a new alternative based on them. 

City and Borough of Yakutat Alternative 

In its comments on the Draft EIS, the City and Borough of Yakutat recommended a 

modification of Alternative 2 for the Yakutat Ranger District. This alternative 

involved reducing the development LUDs in the ranger district and changing them to 

Semi-Remote Recreation. Between the Draft EIS and the Final EIS the 

development LUDs of Alternative 1 in this ranger district were converted to SemiRemote Recreation. Therefore, it was determined that the City and Borough of 

Yakutat recommendation was bracketed by the revised Alternative 1 and Alternative 

2 in the Final EIS and, therefore, it was not necessary to add an additional 

alternative for this specific area. 

The following section defines terminology and presents information regarding 

several aspects of the alternatives. The alternatives considered in detail are 

presented afterward. 

The Allowable Sale Quantity 

The amount of timber that could be sold under a Forest Plan is expressed as an 

Allowable Sale Quantity (ASQ). The ASQ is the maximum amount of timber that 

may be sold from the area of suitable land contained under the Forest Plan within a 

given decade (although it is usually expressed in average annual terms). It is 

neither a targeted amount, nor is it a required amount. It is a ceiling. The amount of 

timber offered for sale in any year can exceed the annual average as long as the 

total decade’s ASQ is not exceeded, and can also be anywhere below the annual 

average; the amount offered for sale over a decade can be below the decadal ASQ. 

Many factors can result in timber sale offerings that are below the average annual 

ASQ, including lack of program funding, new resource issues that need to be 

addressed, changes in timber markets, sales delayed by appeals or lawsuits, or 

other factors that reduce the actual volume. 

In some situations, timber can be harvested from unsuitable lands and can 

contribute to satisfying timber demand, but cannot contribute to the ASQ. An 

example is the timber produced from thinning of second-growth stands for wildlife 

habitat enhancement, within LUDs identified as not suitable for timber production. 

Non-interchangeable Components 

Economics is an important consideration in determining what land can be harvested; 

however, economic conditions can fluctuate greatly from year to year, shifting 

specific forest stands from being economic to uneconomic to harvest. As a result, 

the Tongass National Forest uses the concept of non-interchangeable components 

Alternatives 

Considered in 

Detail 
2 Alternatives 

Alternatives 2-10 Final EIS

(NIC) to consider economics. NICs allow the separation of ASQ into discrete, 

individually accountable categories. All seven alternatives have an ASQ for the first 

decade made up of two NICs: 

NIC I. Normal operable volume scheduled from suitable lands that are available 

for harvest using standard logging systems. This is the most economically 

operable ground and is typically where the Tongass National Forest has been 

offering most sales. 

NIC II. Non-standard (difficult and isolated) operable volume scheduled from 

suitable lands that are available for harvest using logging systems not in 

common use. These lands are currently considered economically and 

technologically marginal. In the past, this land has rarely been economical to 

harvest. 

Chargeable timber volume from one NIC cannot be substituted for the achievement 

of the volume limit of another NIC, nor can the limits on the sale of chargeable 

timber volume associated with each NIC be exceeded. 

Standards and Guidelines and Management Prescriptions 

The Forest-wide standards and guidelines in Chapter 4, the management 

prescriptions in Chapter 3, and other chapters of the current Tongass Forest Plan 

(USDA Forest Service, 1997b) apply to Alternative 5, the No-Action Alternative in 

this EIS, and are not repeated here. An updated and edited version of the 1997 

Forest Plan (as amended) was developed for Alternative 6, the Proposed Action, 

and for Alternatives 1, 2, and 3. A Proposed Forest Plan was released in January 

2007 with the Draft EIS at the beginning of the comment period. This Proposed 

Forest Plan is modified and updated further for this Final EIS, and is referred to as 

the Final Proposed Forest Plan (see below). Alternatives 4 and 7 also follow the 

updated Forest Plan , with the exceptions noted in their alternative descriptions 

(see below). 

Applicable LUD management prescriptions and Forest-wide standards and 

guidelines are discussed throughout the environmental consequences sections of 

Chapter 3 because they serve as the basic mitigation measures for individual 

projects under the Forest Plan. The Forest-wide standards and guidelines, and the 

LUD-specific standards and guidelines that constitute the management 

prescriptions, are the full set of mitigation measures for each alternative. 

Goals Common to All Alternatives 

Air. Maintain the current air resource condition to protect the Forest's ecosystems 

from on- and off-Forest air emission sources. 

Biodiversity. Maintain healthy forest ecosystems; a mix of habitats at different 

spatial scales (site, watershed, island, province, and forest) capable of supporting 

the full range of naturally occurring flora, fauna, and ecological processes native to 

Southeast Alaska. 

Ecosystem Services and Non-Use Values. Maintain the broad range and high 

level of ecosystem services (e.g., watershed, water quality, air quality, biodiversity), 

and non-use values (e.g., existence, option, and bequest values associated with 

natural areas) that are provided by the Tongass National Forest. 

Fish. Maintain or restore the natural range and frequency of aquatic habitat 

conditions on the Tongass National Forest to sustain the diversity and production of 

fish and other freshwater organisms. 
Alternatives 2

Final EIS 2-11 Alternatives 

Heritage Resources. Identify, evaluate, preserve, and protect heritage resources. 

Local and Regional Economies. Provide a diversity of opportunities for resource 

uses that contribute to the local and regional economies of Southeast Alaska. 

Rare Natural Areas. Protect a variety of areas with natural, scenic, or geologic 

features distinct to the region, including areas set aside specifically for future 

research needs.

Research. Continue to seek out and promote research opportunities that are 

consistent with identified information needs. 

Soil and Water. Maintain soil productivity Forest-wide, and minimize soil erosion 

resulting from land-disturbing activities. Minimize sediment transported to streams 

from land-disturbing activities. Maintain and restore the biological, physical, and 

chemical integrity of Tongass National Forest waters. 

Subsistence. Provide for the continuation of subsistence uses and resources by all 

rural Alaskan residents. 

Wetlands. Minimize the destruction, loss or degradation of wetlands, and preserve 

and enhance the associated wetland functions and values. 

Wilderness. Manage designated Wilderness to maintain an enduring wilderness 

resource while providing for public access and uses consistent with the Wilderness 

Act of 1964 and the Alaska National Interest Lands Conservation Act of 1980 

(ANILCA). 

Descriptions of the Alternatives 

Each alternative description includes the following components: 1) a framework; 2) a 

general description of the desired condition; 3) a table with the acreages allocated to 

each LUD; 4) a map (included in the Map Packet accompanying the EIS hard copy 

or in the Map Section of the CD version) showing the composition of LUDs across 

the Forest; 5) a map showing the distribution of development, natural setting, and 

wilderness LUDs; 6) a description of proposed changes to the current Forest-wide 

standards and guidelines and management prescriptions; and 7) a quantification of 

outputs and measures associated with each alternative. 

The management prescriptions (i.e., LUD-specific standards and guidelines) for 

each LUD are included in the 1997 Forest Plan, as amended, or in the Final 

Proposed Forest Plan (see next section), as are the Forest-wide standards and 

guidelines that apply to each alternative. Details on the modeling of each alternative 

are included in Appendix B to this EIS (included Volume II). 

In the LUD tables for each alternative, the changes from existing acreages represent 

the differences between the decisions made in the 1997 Tongass Forest Plan 

Revision ROD, as amended, and the Forest Plan Amendment EIS alternatives. 

The goals common to all alternatives are provided below. In addition, the Tongass 

Timber Reform Act (Section 101) direction for the Tongass to “seek to provide a 

supply of timber 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” 

will be followed by each alternative “to the extent consistent with providing for the 

multiple use and sustained yield of all renewable forest resources,” as determined 

by that alternative, and subject to appropriations and applicable law. 

Summary of Final Proposed Forest Plan 

The 1997 Forest Plan (USDA Forest Service 1997b), as amended, is the plan 

associated with Alternative 5, the No-Action Alternative. A number of changes to 

the Forest Plan text are being proposed under the other alternatives, based on the 
2 Alternatives 

Alternatives 2-12 Final EIS

Forest Plan 5 Year Review and Forest Service staff recommendations. Most 

changes were incorporated into a Proposed Forest Plan (Land and Resource 

Management Plan), which accompanied the Draft EIS. These changes were 

modified and updated for the Final EIS and the major changes being proposed are 

summarized in this section. The individual alternative descriptions on the following 

pages only identify items that are not consistent with the Final Proposed Forest 

Plan, which is defined by the Proposed Forest Plan that accompanied the Draft EIS, 

as modified in this section. A summary of the main changes that are incorporated 

into the Final Proposed Forest Plan are provided below. 

Management Prescriptions

• Edits and clarifications were made regarding karst management programs, 

sacred site protection, minerals and geology, off-highway vehicle use, scenery 

management, and other areas for most LUD prescriptions 

• Substantial edits and clarifications were made to the Wilderness and Wilderness 

National Monument LUD prescriptions 

Forest-wide Standards and Guidelines

• Clarifications were made to the standards and guidelines regarding steep slopes 

and soil stability in the Soils and Water section. 

• Clarifications were made to the standards and guidelines on Class III and IV 

streams and edits were made to the other standards and guidelines in the Fish 

section 

• The detailed stream process group-specific riparian standards and guidelines 

are presented in an appendix in the Final Proposed Forest Plan, instead of in 

the main body of the standards and guidelines, which is the way they were 

presented in the Proposed Forest Plan that accompanied the Draft EIS. 

• A new section was added to Chapter 4 on Invasive Species. 

• A new section was added to Chapter 4 on Plants. 

• The Threatened, Endangered, and Sensitive Species standards and guidelines 

are incorporated into subsections under Fish, Wildlife, and Plants (as 

appropriate) in the Final Proposed Plan, instead of in a separate section as in 

the Proposed Plan that accompanied the Draft EIS. 

• The goshawk foraging habitat and the marten habitat standards and guidelines 

in the Wildlife section were deleted and replaced with a Forest-wide legacy 

standard and guideline in the Proposed Forest Plan that accompanied the Draft 

EIS. In addition, the legacy standard and guideline for the Final Proposed 

Forest Plan is revised further. The revised standard and guideline requires 

legacy forest structure to be left only in harvest units greater than 20 acres and 

only in higher risk VCUs, as previously defined (49 VCUs). 

• The goshawk nesting habitat standard and guideline in the Wildlife section was 

revised in the Proposed Forest Plan that accompanied the Draft EIS. In 

addition, the goshawk nesting habitat standard and guideline for the Final 

Proposed Forest Plan is revised further. The revised standard and guideline 

permits nesting habitat protection measures to be removed if, after 2 

consecutive years of monitoring, evidence of confirmed or probable nesting is 

no longer observed. 

• The requirement to conduct inventories to determine the presence of nesting 

goshawks for proposed projects that affect goshawk habitat is included in the 
Alternatives 2

Final EIS 2-13 Alternatives 

Final Proposed Forest Plan (this was inadvertently removed from the Proposed 

Forest Plan that accompanied the Draft EIS). 

• New standards and guidelines on sacred site protection were added in the 

Heritage Resources and Sacred Sites section. 

• Extensive edits were made to the Karst and Cave Resources standards and 

guidelines and the Karst and Cave Resources appendix. 

• Substantial edits were made to the Minerals and Geology standards and 

guidelines. 

• Substantial edits were made to the Recreation and Tourism standards and 

guidelines. The detailed Recreation Opportunity Spectrum-specific standards 

and guidelines are presented in an appendix in the Final Proposed Forest Plan, 

instead of in the main body of the standards and guidelines, which is the way 

they were presented in the Proposed Forest Plan that accompanied the Draft 

EIS. 

• The Scenery standards and guidelines were converted from the Visual 

Management System to the Scenery Management System. 

• Edits were made to off-highway vehicle standards and guidelines in the Lands

section. 

• Edits were made to the road storage and decommissioning standards and 

guidelines in the Transportation and Utilities section. 

In addition, there are a number of changes to other Forest Plan sections. These 

include changes to the Goals and Objectives (Chapter 2 of the Plan) and Monitoring 

and Evaluation (Chapter 6 of the Plan) chapters and to a number of the Forest Plan 

appendixes, including Appendix B (Information Needs), Appendix F (Visual Priority 

Routes and Use Areas), Appendix I (Karst and Caves), Appendix K (Old-Growth 

Habitat Reserve Criteria), and Appendix L (Resource Schedules). 

Finally, the 1982 Planning Regulations implementing NFMA include identification of 

Wildlife Management Indicator Species (MIS) in Forest Plans. The primary intent of 

MIS was to monitor populations of selected species to see if longer term trends were 

indicating they could become threatened or endangered across the national forest. 

The 1997 Forest Plan identified 13 wildlife and 4 fish MIS species with associated 

monitoring guidelines. The Tongass National Forest has analyzed MIS monitoring 

information assembled since 1997. Chapter 3 includes information for each of the 

species. It has been determined this information is lacking in sufficient detail to help 

guide management of the selected species on the Forest. The Tongass hosted an 

interagency review of the Forest Plan Conservation Strategy in April of 2006, which 

included updated information related to most of the MIS species. Much discussion 

at the review and in other related venues locally and nationally indicate monitoring 

should be more focused on wildlife habitats instead of species population trends by 

themselves. Interagency discussions related to wildlife monitoring and the MIS 

themselves are ongoing. As a result, the Monitoring and Evaluation chapter in the 

Final Proposed Plan is revised to be more focused, relative to the version in the 

Proposed Forest Plan that accompanied the Draft EIS. It is anticipated that the 

current list of MIS may be revised in the future, but a change in MIS is not part of the 

Final Proposed Plan. 
2 Alternatives 

Alternatives 2-14 Final EIS

Proposed LUD Changes Common to Most Alternatives 

The LUD allocations for each alternative are described in the following alternativespecific descriptions. The alternatives do not vary in terms of the acreage allocated 

to congressionally designated areas (i.e., Wilderness, National Monument, and LUD 

II), nor do they vary in terms of allocations to Research Natural Areas, Enacted 

Municipal Watersheds, or Wild, Scenic, or Recreational River LUDs. However, they 

do vary with respect to the other non-development LUDs and all of the development 

LUDs. The LUDs for each alternative are displayed on alternative LUD maps that 

accompany this EIS. 

Proposed changes to the Special Interest Area and Experimental Forest LUDs are 

common under all alternatives except Alternative 5, which would follow the 1997 

Forest Plan (as amended) for these two LUDs. The proposed changes to Special 

Interest Area and Experimental Forest LUDs are quantified in the following 

alternative description sections and shown on the alternative LUD maps, and are 

described in detail in the Other Special Land Use Designation section of Chapter 3. 

Proposed changes to the Old-Growth Habitat LUD are common under Alternatives 

1, 2, 3, and 6, and are as a result of an interagency process that took place in 

parallel with this EIS, and was initiated in 2006 and completed in 2007. Under this 

process, the Tongass worked with the Alaska Department of Fish and Game and 

the U.S. Fish and Wildlife Service to conduct a comprehensive review and mapping 

effort for all small old-growth reserves (OGR). The objective of the interagency 

team review was to develop a consensus biological recommendation on small OGR 

composition and locations that was consistent with the Forest Plan. This process 

included the development of a biological recommendation, the refinement of that 

proposal with Forest Service Ranger District staff, and further refinement by the 

Forest Supervisor. The refinement process was conducted in order to consider 

multiple-use objectives in addition to pure biological ones. The final proposal is 

included in Alternatives 1, 2, 3, and 6 of the Final EIS. Alternative 5 retains the 1997 

Plan (as amended) reserve network and the reserves proposed under Alternatives 4 

and 7 are not affected by this proposal. Further information on the refinement of 

small OGRs is included in Appendix D. 
Alternatives 2

Final EIS 2-15 Alternatives 

Alternative 1 

Under this alternative, forest management would provide a mix of National Forest 

uses and activities, but would emphasize maintaining inventoried roadless areas, 

associated fish and wildlife values, and unroaded recreation, tourism, and 

subsistence opportunities, relative to the current Forest Plan. Timber would be 

managed within the roaded land base and all inventoried roadless areas would 

remain in a natural condition. In addition, a number of higher value roaded areas, 

including all of Kuiu, Baranof, and Kruzof Islands, many portions of Chichagof 

Island, all mainland areas, and other areas, would be excluded from commercial 

timber management. A total of 840,000 acres of the Tongass would be in 

development LUDs and 15.9 million acres would be in non-development LUDs. The 

majority of the lands changed to non-development LUDs from development LUDs 

(in the current Plan) would be designated Semi-Remote Recreation. Specific LUD 

changes under this alternative would include the addition and modification of a 

number of Geologic Special Interest Areas, recommendations to change the Young 

Bay Experimental Forest to Semi-Remote Recreation and the Cowee-Davies Creek 

watersheds from Scenic Viewshed to Experimental Forest, and converting a large 

area of Remote Recreation LUD north of Juneau to Semi-Remote Recreation. It 

also would include extensive refinements to the boundaries of the small Old-Growth 

Reserves, based on a recently completed interagency evaluation. 

This alternative would approximately correspond with Scenario 1 (limited lumber 

production) of the Brackley et al. (2006) timber demand study. It is similar to 

Alternative 8 of the 2003 SEIS in terms of the areas allocated to non-development 

LUDs. 

The vast majority of the currently undisturbed areas of the Forest remain in a natural 

state and all existing inventoried roadless areas remain roadless. Old-growth 

conditions prevail on forest lands within these roadless areas. A small, but 

predictable and sustainable supply of forest products contributes to a very limited 

Southeast Alaska timber industry, probably based primarily in Ketchikan and Prince 

of Wales Island. A mixture of old growth, recently harvested areas, and various 

ages of young growth occurs within roaded areas. Recreation, tourism, and 

subsistence opportunities emphasize natural setting types, although roaded 

opportunities expand slightly from current conditions due to construction of 

additional roads primarily in already roaded areas. 

If Alternative 1 is selected, the LUD allocation acres shown in Table 2-3 would 

result. Figure 2-1 shows the distribution of LUDs across the Tongass under 

Alternative 1 according to three LUD groups (see Table 2-3 for definitions of the 

LUD groups). A complete LUD map is provided as the Alternative 1 map in the Map 

Section of the CD version of this EIS or in the Map Packet accompanying the EIS 

hard copy. 

Under Alternative 1, the management prescriptions and standards and guidelines 

identified in the Final Proposed Land and Resource Management Plan would be 

adopted. These are generally the same as the management prescriptions and 

standards and guidelines in the 1997 Forest Plan, as amended; however, a number 

of changes and refinements are proposed. A summary of the main changes to the 

1997 Forest Plan, as amended, is provided above in the section titled “Final 

Proposed Forest Plan.” 

Table 2-4 displays selected outputs and other measures associated with this 

alternative. 

Framework 

Desired 

Conditions 

Land Use 

Designations 

Management 

Prescriptions 

and Standards 

and Guidelines 

Selected 

Outputs 
2 Alternatives 

Alternatives 2-16 Final EIS

Table 2-3 

Land Use Designations for Alternative 11

Land Use Designation Acres Allocated 

Net Change from 

Current Forest 

Plan Acres2 

Wilderness LUD Group 

 Wilderness 2,637,292 0 

 National Monument3 3,278,734 0 

 Total for Wilderness LUD Group 5,916,026 0 

Natural Setting LUD Group 

 LUD II 721,002 0 

 Research Natural Area 26,093 0 

 Old Growth 1,221,174 38,749 

 Special Interest Area 221,174 46,712 

 Enacted Municipal Watershed 45,226 0 

 Wild, Scenic, and Recreational River 117,319 0 

 Remote Recreation 2,369,831 238,776 

 Semi-Remote Recreation 5,296,773 2,442,548 

 Total for Natural Setting LUD Group 10,018,592 2,766,786 

Development LUD Group 

 Experimental Forest 31,405 14,310 

 Scenic Viewshed 59,296 (417,923) 

 Modified Landscape 188,357 (413,005) 

 Timber Production 560,129 (1,950,169) 

 Total for Development LUD Group 839,187 (2,766,786) 

 Total National Forest System Lands 16,773,804 0 1 When more than one LUD is applied to the same area, such as a Special Interest Area within 

Wilderness, only the acreage of the more restrictive LUD is included, except that total Wilderness, 

Wilderness National Monument, and LUD II acres are always shown. The acreage for the Minerals 

LUD would be 249,570; these acres are not included in the table because the Minerals LUD is an 

overlay. No acreages have been calculated for the Transportation and Utility Systems LUD because 

it is a series of corridors with undefined width and imprecise locations. Totals may not exactly equal 

the sum of individual entries due to rounding. 2

 These changes from current Forest Plan acres are the differences from the decision made in the 

1997 Tongass Forest Plan Revision ROD, as amended, which is represented by Alternative 5. 3

 The majority of the National Monument acres are wilderness; only 166,942 acres are non-wilderness. 4 Small old-growth reserves and Special Interest Area LUDs increased relative to Alternative 5; 

however, they overlap extensively, especially on Heceta, Kosciusko, and northeast Chichagof 

Islands, and the acreages where they overlap were counted with Special Interest Areas. 
Alternatives 2

Final EIS 2-17 Alternatives 

Figure 2-1 

Wilderness, Natural Setting, and Development LUDs on the Tongass National Forest 

under Alternative 1 
2 Alternatives 

Alternatives 2-18 Final EIS

Table 2-4 

Selected Outputs and Measures Associated with Alternative 11

Resource/Category Output/Measure 

Percent in Wilderness LUD Group 35% 

Percent in Natural Setting LUD Group 60% 

Percent in Development LUD Group 5% 

Amount of Development LUDs in Inventoried Roadless Areas 

(millions of acres) 2 0.0 

Percent of Current Productive Old Growth Protected in Reserves 

(Wilderness/Nat. Mon. and Natural Setting LUDs) 93% 

Productive Old Growth after 100+ Years (millions of acres) 4.9 

Estimated Forest Land Suitable for Timber Production (acres)3 312,000 

Scheduled Suitable Forest Land (acres)3 144,000 

Allowable Sale Quantity or ASQ (millions of board feet)4

 1st Decade ASQ 49 

 2nd Decade ASQ 49 

Maximum New Road Construction after 100+ Years (miles) 774 

Maximum Average Annual Timber Harvest during 1st Decade, 

based on the ASQ (acres) 1,774 

Potential Short-term Effects on Timber Industry5

 

 Effect on Timber Volume Under Contract High 

 Effect on NEPA-cleared Volume Low 

 Effect on Timber Volume in Preparation Low 

Percent of Identified Mineral Tracts and Undiscovered Mineral Areas 

in Open LUDs with Higher Development Costs 

 Percent of Identified Mineral Tracts 36% 

 Percent of Undiscovered Mineral Areas 57% 

Recreation Opportunity Spectrum Classes after 150 Years 

(millions of acres) 

 Primitive and Semi-Primitive Non-Motorized 13.2 

 Semi-Primitive Motorized 1.4 

 Roaded Natural and Roaded Modified 2.1 

1

 Totals may not add exactly due to rounding. 

2 No lands suitable for timber management and no lands within Timber Production, Modified 

Landscape, or Scenic Viewshed LUDs are included in inventoried roadless areas under Alternative 1. 

Approximately 27,000 acres of Experimental Forest are included. 3

 Estimated forest land suitable for timber production represents the mapped suitable forest land minus 

the estimated portion that is unsuitable, but not mapped as such. The scheduled suitable forest land 

is the portion of the estimated suitable forest land that is scheduled for harvest by ASQ modeling. 4 ASQ volumes expressed as annual averages and include sawlog plus utility. 5 This evaluation provides an indication of potential effects; actual effects would depend on the volume 

that is under contract when the decision is implemented and whether potentially affected existing 

sales are cancelled or exempted as part of the decision. 
Alternatives 2

Final EIS 2-19 Alternatives 

Alternative 2 

Under this alternative, forest management would provide a mix of National Forest 

uses and activities, but would give additional emphasis to roadless areas, 

associated fish and wildlife values, and unroaded recreation, tourism, and 

subsistence opportunities, relative to the current Forest Plan. Timber would be 

managed within the roaded land base as well as within roadless areas with lower 

wilderness attribute ratings (primarily those adjacent to developed areas). The vast 

majority of current roadless areas would remain in a natural condition. A total of 1.9 

million acres of the Tongass would be in development LUDs and 14.8 million acres 

would be in non-development LUDs. The majority of the lands changed to nondevelopment LUDs from development LUDs (in the current Plan) would be 

designated Semi-Remote Recreation. All areas identified as development LUDs in 

Alternative 1 would also be development LUDs in this alternative, in addition to other 

areas. Specific LUD changes under this alternative would include the addition and 

modification of a number of Geologic Special Interest Areas, recommendations to 

change the Young Bay Experimental Forest to Semi-Remote Recreation and the 

Cowee-Davies Creek watersheds from Scenic Viewshed to Experimental Forest, 

and converting a large area of Remote Recreation LUD north of Juneau to SemiRemote Recreation. It also would include extensive refinements to the boundaries 

of the small Old-Growth Reserves, based on a recently completed interagency 

evaluation. 

This alternative would approximately correspond with Scenario 2 (expanded lumber 

production) of the Brackley et al. (2006) timber demand study. 

The vast majority of the currently undisturbed areas of the Forest remain in a natural 

state and most existing roadless areas remain roadless. However, some roadless 

areas adjacent to existing roaded areas are developed. Old growth conditions 

prevail on forest lands within roadless areas. A moderate, predictable, and 

sustainable supply of forest products contributes to a limited Southeast Alaska 

timber industry, probably based in Ketchikan, Prince of Wales Island, and other 

communities. A mixture of old growth, recently harvested areas, and various ages 

of young growth occurs within roaded areas. Recreation, tourism, and subsistence 

opportunities emphasize natural setting types, although roaded opportunities 

expand from current conditions. 

If Alternative 2 is selected, the LUD allocation acres shown in Table 2-5 would 

result. Figure 2-2 shows the distribution of LUDs across the Tongass under 

Alternative 2 according to three LUD groups (see Table 2-5 for definitions of the 

LUD groups). A complete LUD map is provided as the Alternative 2 map in the Map 

Section of the CD version of this EIS or in the Map Packet accompanying the EIS 

hard copy. 

Under Alternative 2, the management prescriptions and standards and guidelines 

identified in the Final Proposed Forest Plan would be adopted. These are generally 

the same as the management prescriptions and standards and guidelines in the 

current Forest Plan; however, a number of changes and refinements are proposed. 

A summary of the main changes to the current Forest Plan is provided above in the 

section titled “Final Proposed Forest Plan.” 

Table 2-6 displays selected outputs and other measures associated with this 

alternative. 

Framework 

Desired 

Conditions 

Land Use 

Designations 

Management 

Prescriptions 

and Standards 

and Guidelines 

Selected 

Outputs 
2 Alternatives 

Alternatives 2-20 Final EIS

Table 2-5 

Land Use Designations for Alternative 21 

Land Use Designation Acres Allocated 

Net Change from 

Current Forest 

Plan Acres2 

Wilderness LUD Group 

 Wilderness 2,637,292 0 

 National Monument3 3,278,734 0 

 Total for Wilderness LUD Group 5,916,026 0 

Natural Setting LUD Group 

 LUD II 721,002 0 

 Research Natural Area 26,093 0 

 Old Growth 1,221,173 38,749 

 Special Interest Area 221,176 46,713 

 Enacted Municipal Watershed 45,226 0 

 Wild, Scenic, and Recreational River 117,319 0 

 Remote Recreation 2,344,149 213,095 

 Semi-Remote Recreation 4,232,082 1,377,857 

 Total for Natural Setting LUD Group 8,928,220 1,676,414 

Development LUD Group - 

 Experimental Forest 31,405 14,310 

 Scenic Viewshed 213,193 (264,026) 

 Modified Landscape 331,955 (269,407) 

 Timber Production 1,353,006 (1,157,291) 

 Total for Development LUD Group 1,929,559 (1,676,414) 

 Total National Forest System Lands 16,773,805 0 1 When more than one LUD is applied to the same area, such as a Special Interest Area within 

Wilderness, only the acreage of the more restrictive LUD is included, except that total Wilderness, 

Wilderness National Monument, and LUD II acres are always shown. The acreage for the Minerals 

LUD would be 249,570; these acres are not included in the table because the Minerals LUD is an 

overlay. No acreages have been calculated for the Transportation and Utility Systems LUD because 

it is a series of corridors with undefined width and imprecise locations. Totals may not exactly equal 

the sum of individual entries due to rounding. 2

 These changes from current Forest Plan acres are the differences from the decision made in the 

1997 Tongass Forest Plan Revision ROD, as amended, which is represented by Alternative 5. 3

 The majority of the National Monument acres are wilderness; only 166,942 acres are non-wilderness. 4 Small old-growth reserves and Special Interest Area LUDs increased relative to Alternative 5; 

however, they overlap extensively, especially on Heceta, Kosciusko, and northeast Chichagof 

Islands, and the acreages where they overlap were counted with Special Interest Areas. 
Alternatives 2

Final EIS 2-21 Alternatives 

Figure 2-2 

Wilderness, Natural Setting, and Development LUDs on the Tongass National Forest 

under Alternative 2 
2 Alternatives 

Alternatives 2-22 Final EIS

Table 2-6 

Selected Outputs and Measures Associated with Alternative 21 

Resource/Category Output/Measure 

Percent in Wilderness LUD Group 35% 

Percent in Natural Setting LUD Group 53% 

Percent in Development LUD Group 12% 

Amount of Development LUDs in Inventoried Roadless Areas 

(millions of acres) 0.8 

Percent of Current Productive Old Growth Protected in Reserves 

(Wilderness/Nat. Mon. and Natural Setting LUDs) 84% 

Productive Old Growth after 100+ Years (millions of acres) 4.7 

Estimated Forest Land Suitable for Timber Production (acres)2 545,000 

Scheduled Suitable Forest Land (acres)2 403,000 

Allowable Sale Quantity or ASQ (millions of board feet)3

 1st Decade ASQ 151 

 2nd Decade ASQ 151 

Maximum New Road Construction after 100+ Years (miles) 2,079 

Maximum Average Annual Timber Harvest during 1st Decade, 

based on the ASQ (acres) 5,387 

Potential Short-term Effects on Timber Industry4

 

 Effect on Timber Volume Under Contract None 

 Effect on NEPA-cleared Volume Low 

 Effect on Timber Volume in Preparation Very Low 

Percent of Identified Mineral Tracts and Undiscovered Mineral Areas 

in Open LUDs with Higher Development Costs 

 Percent of Identified Mineral Tracts 29% 

 Percent of Undiscovered Mineral Areas 51% 

Recreation Opportunity Spectrum Classes after 150 Years 

(millions of acres) 

 Primitive and Semi-Primitive Non-Motorized 12.8 

 Semi-primitive Motorized 1.3 

 Roaded Natural and Roaded Modified 2.6 

1

 Totals may not add exactly due to rounding. 

2 Estimated forest land suitable for timber production represents the mapped suitable forest land minus 

the estimated portion that is unsuitable, but not mapped as such. The scheduled suitable forest land 

is the portion of the estimated suitable forest land that is scheduled for harvest by ASQ modeling. 3 ASQ volumes expressed as annual averages and include sawlog plus utility. 4 This evaluation provides an indication of potential effects; actual effects would depend on the volume 

that is under contract when the decision is implemented and whether potentially affected existing 

sales are cancelled or exempted as part of the decision. 
Alternatives 2

Final EIS 2-23 Alternatives 

Alternative 3 

Under Alternative 3, forest management would provide a mix of National Forest 

uses and activities, but would give some additional emphasis to roadless areas, 

associated fish and wildlife values, and unroaded recreation, tourism, and 

subsistence opportunities, relative to the current Forest Plan. Timber would be 

managed within the roaded land base as well as within additional roadless areas; 

but these additional areas would not include the high value roadless areas identified 

in the 1999 Record of Decision (USDA Forest Service 1999) as the 18 Areas of 

Special Interest or the 23 areas proposed for wilderness in H.R. 987. The vast 

majority of current roadless areas would remain in a natural condition. A total of 2.8 

million acres of the Tongass would be in development LUDs and 14.0 million acres 

would be in non-development LUDs. The majority of the lands changed to nondevelopment LUDs from development LUDs (in the current Plan) would be 

designated Semi-Remote Recreation. All areas identified as development LUDs in 

Alternative 2 would also be development LUDs in this alternative, in addition to other 

areas. Specific LUD changes under this alternative would include the addition and 

modification of a number of Geologic Special Interest Areas, recommendations to 

change the Young Bay Experimental Forest to Semi-Remote Recreation and the 

Cowee-Davies Creek watersheds from Scenic Viewshed to Experimental Forest, 

and converting a large area of Remote Recreation LUD north of Juneau to SemiRemote Recreation. It also would include extensive refinements to the boundaries 

of the small Old-Growth Reserves, based on a recently completed interagency 

evaluation. 

This alternative would approximately correspond with Scenario 3 (medium 

integrated industry) of the Brackley et al. (2006) timber demand study. It is similar to 

Alternative 5 of the 2003 SEIS in terms of the areas allocated to non-development 

LUDs. 

The vast majority of the currently undisturbed areas of the Forest remain in a natural 

state and most existing roadless areas remain roadless. However, over half of the 

roadless areas to be developed under the current Forest Plan are developed. Old 

growth conditions prevail on forest lands within the roadless areas. A predictable 

and sustainable supply of forest products contributes to a medium integrated timber 

industry in Southeast Alaska, probably based in Ketchikan, Prince of Wales Island, 

Wrangell, and Hoonah. A mixture of old growth, recently harvested areas, and 

various ages of young growth occurs within roaded areas. Recreation, tourism, and 

subsistence opportunities occur in natural setting types, but roaded opportunities 

are considerably expanded from current conditions, although not as much as under 

the current Plan. 

If Alternative 3 is selected, the LUD allocation acres shown in Table 2-7 would 

result. Figure 2-3 shows the distribution of LUDs across the Tongass under 

Alternative 3 according to three LUD groups (see Table 2-7 for definitions of the 

LUD groups). A complete LUD map is provided as the Alternative 3 map in the Map 

Section of the CD version of this EIS or in the Map Packet accompanying the EIS 

hard copy. 

Under Alternative 3, the management prescriptions and standards and guidelines 

identified in the Final Proposed Forest Plan would be adopted. These are generally 

the same as the management prescriptions and standards and guidelines in the 

current Forest Plan; however, a number of changes and refinements are proposed. 

A summary of the main changes to the current Forest Plan is provided above in the 

section titled “Final Proposed Forest Plan.” 

Table 2-8 displays selected outputs and other measures associated with this 

alternative. 

Framework 

Desired 

Conditions 

Land Use 

Designations 

Management 

Prescriptions 

and Standards 

and Guidelines 

Selected 

Outputs 
2 Alternatives 

Alternatives 2-24 Final EIS

Table 2-7 

Land Use Designations for Alternative 31 

Land Use Designation Acres Allocated 

Net Change from 

Current Forest 

Plan Acres2 

Wilderness LUD Group 

 Wilderness 2,637,292 0 

 National Monument3 3,278,734 0 

 Total for Wilderness LUD Group 5,916,026 0 

Natural Setting LUD Group 

 LUD II 721,002 0 

 Research Natural Area 26,093 0 

 Old Growth 1,221,173 38,749 

 Special Interest Area 221,176 46,712 

 Enacted Municipal Watershed 45,226 0 

 Wild, Scenic, and Recreational River 117,319 0 

 Remote Recreation 2,182,091 51,036 

 Semi-Remote Recreation 3,519,753 665,527 

 Total for Natural Setting LUD Group 8,053,833 802,025 

Development LUD Group 

 Experimental Forest 31,405 14,309 

 Scenic Viewshed 320,457 (156,763) 

 Modified Landscape 478,541 (122,820) 

 Timber Production 1,973,542 (536,755) 

 Total for Development LUD Group 2,803,945 (802,025) 

 Total National Forest System Lands 16,773,803 0 1 When more than one LUD is applied to the same area, such as a Special Interest Area within 

Wilderness, only the acreage of the more restrictive LUD is included, except that total Wilderness, 

Wilderness National Monument, and LUD II acres are always shown. The acreage for the Minerals 

LUD would be 249,570; these acres are not included in the table because the Minerals LUD is an 

overlay. No acreages have been calculated for the Transportation and Utility Systems LUD because 

it is a series of corridors with undefined width and imprecise locations. Totals may not exactly equal 

the sum of individual entries due to rounding. 2

 These changes from current Forest Plan acres are the differences from the decision made in the 

1997 Tongass Forest Plan Revision ROD, as amended, which is represented by Alternative 5. 3

 The majority of the National Monument acres are wilderness; only 166,942 acres are non-wilderness. 4 Small old-growth reserves and Special Interest Area LUDs increased relative to Alternative 5; 

however, they overlap extensively, especially on Heceta, Kosciusko, and northeast Chichagof 

Islands, and the acreages where they overlap were counted with Special Interest Areas. 
Alternatives 2

Final EIS 2-25 Alternatives 

Figure 2-3 

Wilderness, Natural Setting, and Development LUDs on the Tongass National Forest 

under Alternative 3 
2 Alternatives 

Alternatives 2-26 Final EIS

Table 2-8 

Selected Outputs and Measures Associated with Alternative 31

Resource/Category Output/Measure 

Percent in Wilderness LUD Group 35% 

Percent in Natural Setting LUD Group 48% 

Percent in Development LUD Group 17% 

Amount of Development LUDs in Inventoried Roadless Areas 

(millions of acres) 1.7 

Percent of Current Productive Old Growth Protected in Reserves 

(Wilderness/Nat. Mon. and Natural Setting LUDs) 78% 

Productive Old Growth after 100+ Years (millions of acres) 4.6 

Estimated Forest Land Suitable for Timber Production (acres)2

 661,000 

Scheduled Suitable Forest Land (acres)2 526,000 

Allowable Sale Quantity or ASQ (millions of board feet)3

 1st Decade ASQ 204 

 2nd Decade ASQ 205 

Maximum New Road Construction after 100+ Years (miles) 2,799 

Maximum Average Annual Timber Harvest during 1st Decade, 

based on the ASQ (acres) 6,824 

Potential Short-term Effects on Timber Industry4

 

 Effect on Timber Volume Under Contract None 

 Effect on NEPA-cleared Volume None 

 Effect on Timber Volume in Preparation Very Low 

Percent of Identified Mineral Tracts and Undiscovered Mineral Areas 

in Open LUDs with Higher Development Costs 

 Percent of Identified Mineral Tracts 26% 

 Percent of Undiscovered Mineral Areas 45% 

Recreation Opportunity Spectrum Classes after 150 Years 

(millions of acres) 

 Primitive and Semi-Primitive Non-Motorized 12.4 

 Semi-Primitive Motorized 1.3 

 Roaded Natural and Roaded Modified 3.1 

1

 Totals may not add exactly due to rounding. 

2 Estimated forest land suitable for timber production represents the mapped suitable forest land minus 

the estimated portion that is unsuitable, but not mapped as such. The scheduled suitable forest land 

is the portion of the estimated suitable forest land that is scheduled for harvest by ASQ modeling. 3 ASQ volumes expressed as annual averages and include sawlog plus utility. 4 This evaluation provides an indication of potential effects; actual effects would depend on the volume 

that is under contract when the decision is implemented and whether potentially affected existing 

sales are cancelled or exempted as part of the decision. 
Alternatives 2

Final EIS 2-27 Alternatives 

Alternative 4 

Under Alternative 4, forest management would provide a mix of National Forest 

uses and activities, but would give additional emphasis to timber management and 

associated economic stability of Southeast Alaska communities, relative to the 

current Forest Plan. Timber would be managed within an area expanded beyond 

the current Forest Plan. The vast majority of current roadless areas would remain in 

a natural condition; however, the majority of roadless areas that contain substantial 

productive old growth (POG), outside of wilderness, would be developed. A total of 

4.7 million acres of the Tongass would be in development LUDs and 12.0 million 

acres would be in non-development LUDs. Almost all areas identified as 

development LUDs in Alternative 5 would also be development LUDs in this 

alternative, in addition to other areas. Specific LUD changes under this alternative 

would include the addition and modification of a number of Geologic Special Interest 

Areas, recommendations to change the Young Bay Experimental Forest to Semiremote Recreation and the Cowee-Davies Creek watersheds from Scenic Viewshed 

to Experimental Forest, and converting a large area of Remote Recreation LUD 

north of Juneau to Semi-Remote Recreation. 

This alternative would approximately correspond with Scenario 4 (high integrated 

industry) of the Brackley et al. (2006) timber demand study. It is similar to 

Alternative 6 of the 1997 FEIS. 

The vast majority of the currently undisturbed areas of the Forest remain in a natural 

state and most existing roadless areas remain roadless. However, all of the 

roadless areas to be developed under the current Forest Plan are developed along 

with some additional roadless areas. Old growth conditions prevail on forest lands 

within roadless areas. The Tongass produces a predictable and sustainable supply 

of forest products that contributes to a high integrated timber industry in Southeast 

Alaska, probably based in Ketchikan, Prince of Wales Island, Wrangell, Hoonah, 

and other communities; however, private and state lands also contribute to 

satisfying the demand for timber. A mixture of old growth, recently harvested areas, 

and various ages of young growth occurs within roaded areas. Recreation, tourism, 

and subsistence opportunities occur in natural setting types, but roaded 

opportunities are substantially expanded from current conditions. 

If Alternative 4 is selected, the LUD allocation acres shown in Table 2-9 would 

result. Figure 2-4 shows the distribution of LUDs across the Tongass under 

Alternative 4 according to three LUD groups (see Table 2-9 for definitions of the 

LUD groups). A complete LUD map is provided as the Alternative 4 map in the Map 

Section of the CD version of this EIS or in the Map Packet accompanying the EIS 

hard copy. 

Under Alternative 4, the management prescriptions and standards and guidelines 

identified in the Final Proposed Forest Plan would be adopted, with the exceptions 

noted below. The Alternative 4 management prescriptions and standards and 

guidelines are generally the same as those in the current Forest Plan; however, a 

number of changes and refinements are proposed. The summary, presented above 

(Final Proposed Forest Plan section), of the main changes to the current Forest 

Plan, reflects the proposal under Alternative 4, with the following exceptions: 

• The Old-Growth Habitat LUD (and the system of large, medium, and small oldgrowth reserves) is applied only within four biogeographic provinces (Northern 

Prince of Wales Island, Kupreanof/Mitkof Islands, Dall Island, Northeast 

Chichagof Island) plus several individual reserves outside of these provinces 

Framework 

Desired 

Conditions 

Land Use 

Designations 

Management 

Prescriptions 

and Standards 

and Guidelines 
2 Alternatives 

Alternatives 2-28 Final EIS

• In Value Comparison Units (VCUs) not within the four biogeographic provinces 

identified above, retain a minimum of 33 percent of the productive forest land in 

an old-growth forest condition 

• The goshawk foraging habitat standard and guideline, the high-value marten 

habitat standard and guideline, and the proposed Legacy standard and 

guideline would not be implemented 

Table 2-10 displays selected outputs and other measures associated with this 

alternative. 

Table 2-9 

Land Use Designations for Alternative 41 

Land Use Designation Acres Allocated 

Net Change from 

Current Forest 

Plan Acres2 

Wilderness LUD Group 

 Wilderness 2,637,292 0 

 National Monument3 3,278,734 0 

 Total for Wilderness LUD Group 5,916,026 0 

Natural Setting LUD Group 

 LUD II 721,002 0 

 Research Natural Area 26,093 0 

 Old Growth 393,360 (789,064) 

 Special Interest Area 221,176 46,712 

 Enacted Municipal Watershed 45,226 0 

 Wild, Scenic, and Recreational River 117,319 0 

 Remote Recreation 2,089,331 (41,724) 

 Semi-Remote Recreation 2,516,591 (337,634) 

 Total for Natural Setting LUD Group 6,130,098 (1,121,714) 

Development LUD Group 

 Experimental Forest 31,405 14,309 

 Scenic Viewshed 725,820 248,601 

 Modified Landscape 745,903 144,541 

 Timber Production 3,224,559 714,262 

 Total for Development LUD Group 4,727,686 1,121,714 

 Total National Forest System Lands 16,773,806 0 1 When more than one LUD is applied to the same area, such as a Special Interest Area within 

Wilderness, only the acreage of the more restrictive LUD is included, except that total Wilderness, 

Wilderness National Monument, and LUD II acres are always shown. The acreage for the Minerals 

LUD would be 249,570; these acres are not included in the table because the Minerals LUD is an 

overlay. No acreages have been calculated for the Transportation and Utility System LUD because it 

is a series of corridors with undefined width and imprecise locations. Totals may not exactly equal the 

sum of individual entries due to rounding. 2

 These changes from current Forest Plan acres are the differences from the decision made in the 

1997 Tongass Forest Plan Revision ROD, as amended, which is represented by Alternative 5. 3

 The majority of the National Monument acres are wilderness; only 166,942 acres are non-wilderness. 

Selected 

Outputs 
Alternatives 2

Final EIS 2-29 Alternatives 

Figure 2-4 

Wilderness, Natural Setting, and Development LUDs on the Tongass National Forest 

under Alternative 4 
2 Alternatives 

Alternatives 2-30 Final EIS

Table 2-10 

Selected Outputs and Measures Associated with Alternative 41

Resource/Category Output/Measure 

Percent in Wilderness LUD Group 35% 

Percent in Natural Setting LUD Group 37% 

Percent in Development LUD Group 28% 

Amount of Development LUDs in Inventoried Roadless Areas 

(millions of acres) 3.4 

Percent of Current Productive Old growth Protected in Reserves 

(Wilderness/Nat. Mon. and Natural Setting LUDs) 60% 

Productive Old growth after 100+ Years (millions of acres) 4.3 

Estimated Forest Land Suitable for Timber Production (acres)2

 999,000 

Scheduled Suitable Forest Land (acres)2 874,000 

Allowable Sale Quantity or ASQ (millions of board feet)3

 1st Decade ASQ 312 

 2nd Decade ASQ 360 

Maximum New Road Construction after 100+ Years (miles) 4,890 

Maximum Average Annual Timber Harvest during 1st Decade, 

based on the ASQ (acres) 11,647 

Potential Short-term Effects on Timber Industry4

 

 Effect on Timber Volume Under Contract None 

 Effect on NEPA-cleared Volume None 

 Effect on Timber Volume in Preparation None 

Percent of Identified Mineral Tracts and Undiscovered Mineral Areas 

in Open LUDs with Higher Development Costs 

 Percent of Identified Mineral Tracts 20% 

 Percent of Undiscovered Mineral Areas 35% 

Recreation Opportunity Spectrum Classes after 150 Years 

(millions of acres) 

 Primitive and Semi-Primitive Non-Motorized 11.3 

 Semi-Primitive Motorized 1.2 

 Roaded Natural and Roaded Modified 4.3 

1

 Totals may not add exactly due to rounding. 

2 Estimated forest land suitable for timber production represents the mapped suitable forest land minus 

the estimated portion that is unsuitable, but not mapped as such. The scheduled suitable forest land 

is the portion of the estimated suitable forest land that is scheduled for harvest by ASQ modeling. 3 ASQ volumes expressed as annual averages and include sawlog plus utility. 4 This evaluation provides an indication of potential effects; actual effects would depend on the volume 

that is under contract when the decision is implemented and whether potentially affected existing 

sales are cancelled or exempted as part of the decision. 
Alternatives 2

Final EIS 2-31 Alternatives 

Alternative 5 

This is the No Action alternative. It represents a continuation of the current Forest 

Plan and would result in a mix of National Forest uses and activities. Timber would 

be managed in an area more extensive than under Alternative 3, but less extensive 

than under Alternative 4. The vast majority of current roadless areas would remain 

in a natural condition; however, the majority of roadless areas that contain 

substantial POG, outside of wilderness, would be partially developed. A total of 3.6 

million acres of the Tongass would be in development LUDs and 13.2 million acres 

would be in non-development LUDs. This alternative is the same as the current 

Forest Plan (Alternative 11 from the 1997 FEIS plus amendments). 

The vast majority of the currently undisturbed areas of the Forest remain in a natural 

state and most existing roadless areas remain roadless. Old growth conditions 

prevail on forest lands within roadless areas. A predictable and sustainable supply 

of forest products contribute to a limited integrated timber industry in Southeast 

Alaska, probably based in Ketchikan, Prince of Wales Island, Wrangell, and 

Hoonah. There would be sufficient volume under this alternative to support the 

existing sawmills. There would also be sufficient volume to support one or more 

veneer plants or an MDF or other chip-related operation, but probably not both. A 

mixture of old growth, recently harvested areas, and various ages of young growth 

occurs within roaded areas. Recreation, tourism, and subsistence opportunities 

occur in natural setting types, but roaded opportunities are considerably expanded 

from current conditions. 

If Alternative 5 is selected, the LUD allocation acres shown in Table 2-11 would 

result. Figure 2-5 shows the distribution of LUDs across the Tongass under 

Alternative 5 according to three LUD groups (see Table 2-11 for definitions of the 

LUD groups). A complete LUD map is provided as the Alternative 5 map in the Map 

Section of the CD version of this EIS or in the Map Packet accompanying the EIS 

hard copy. 

Under Alternative 5, the standards and guidelines identified in the current Forest 

Plan would be adopted. These represent the 1997 Forest Plan with amendments 

(USDA Forest Service 1997b). 

Table 2-12 displays selected outputs and other measures associated with this 

alternative. 

Framework 

Desired 

Conditions 

Land Use 

Designations 

Standards and 

Guidelines 

Selected 

Outputs 
2 Alternatives 

Alternatives 2-32 Final EIS

Table 2-11 

Land Use Designations for Alternative 51 

Land Use Designation Acres Allocated 

Net Change from 

Current Forest 

Plan Acres2 

Wilderness LUD Group 

 Wilderness 2,637,292 0 

 National Monument3 3,278,734 0 

 Total for Wilderness LUD Group 5,916,026 0 

Natural Setting LUD Group 

 LUD II 721,002 0 

 Research Natural Area 26,093 0 

 Old Growth 1,182,424 0 

 Special Interest Area 174,463 0 

 Enacted Municipal Watershed 45,226 0 

 Wild, Scenic, and Recreational River 117,319 0 

 Remote Recreation 2,131,055 0 

 Semi-Remote Recreation 2,854,225 0 

 Total for Natural Setting LUD Group 7,251,808 0 

Development LUD Group 

 Experimental Forest 17,095 0 

 Scenic Viewshed 477,219 0 

 Modified Landscape 601,362 0 

 Timber Production 2,510,298 0 

 Total for Development LUD Group 3,605,974 0 

 Total National Forest System Lands 16,773,808 0 1 When more than one LUD is applied to the same area, such as a Special Interest Area within 

Wilderness, only the acreage of the more restrictive LUD is included, except that total Wilderness, 

Wilderness National Monument, and LUD II acres are always shown. The acreage for the Minerals 

LUD would be 170,514; these acres are not included in the table because the Minerals LUD is an 

overlay. No acreages have been calculated for the Transportation and Utility System LUD because it 

is a series of corridors with undefined width and imprecise locations. Totals may not exactly equal the 

sum of individual entries due to rounding. 2

 These changes from current Forest Plan acres are the differences from the decisions made in the 

1997 Tongass Forest Plan Revision ROD, as amended, which is represented by Alternative 5. 3

 The majority of the National Monument acres are wilderness; only 166,942 acres are non-wilderness. 
Alternatives 2

Final EIS 2-33 Alternatives 

Figure 2-5 

Wilderness, Natural Setting, and Development LUDs on the Tongass National Forest 

under Alternative 5 
2 Alternatives 

Alternatives 2-34 Final EIS

Table 2-12 

Selected Outputs and Measures Associated with Alternative 51

Resource/Category Output/Measure 

Percent in Wilderness LUD Group 35% 

Percent in Natural Setting LUD Group 43% 

Percent in Development LUD Group 21% 

Amount of Development LUDs in Inventoried Roadless Areas 

(millions of acres) 2.4 

Percent of Current Productive Old Growth Protected in Reserves 

(Wilderness/Nat. Mon. and Natural Setting LUDs) 71% 

Productive Old Growth after 100+ Years (millions of acres) 4.5 

Estimated Forest Land Suitable for Timber Production (acres)2

 757,000 

Scheduled Suitable Forest Land (acres)2 702,000 

Allowable Sale Quantity or ASQ (millions of board feet)3

 1st Decade ASQ 267 

 2nd Decade ASQ 267 

Maximum New Road Construction after 100+ Years (miles) 3,874 

Maximum Average Annual Timber Harvest during 1st Decade, 

based on the ASQ (acres) 10,308 

Potential Short-term Effects on Timber Industry4

 

 Effect on Timber Volume Under Contract None 

 Effect on NEPA-cleared Volume None 

 Effect on Timber Volume in Preparation None 

Percent of Identified Mineral Tracts and Undiscovered Mineral Areas 

in Open LUDs with Higher Development Costs 

 Percent of Identified Mineral Tracts 29% 

 Percent of Undiscovered Mineral Areas 41% 

Recreation Opportunity Spectrum Classes after 150 Years 

(millions of acres) 

 Primitive and Semi-Primitive Non-Motorized 11.9 

 Semi-Primitive Motorized 1.3 

 Roaded Natural and Roaded Modified 3.6 

1

 Totals may not add exactly due to rounding. 

2 Estimated forest land suitable for timber production represents the mapped suitable forest land minus 

the estimated portion that is unsuitable, but not mapped as such. The scheduled suitable forest land 

is the portion of the estimated suitable forest land that is scheduled for harvest by ASQ modeling. 

Slight differences in suitable acres between Alternative 5 (shown above) and Alternative 11 of the 

1997 Final EIS are caused by: 1) changes in ownership, 2) changes in LUDs, and 3) the use of 

different estimation methods. 3 ASQ volumes expressed as annual averages and include sawlog plus utility. 4 This evaluation provides an indication of potential effects; actual effects would depend on the volume 

that is under contract when the decision is implemented and whether potentially affected existing 

sales are cancelled or exempted as part of the decision. 
Alternatives 2

Final EIS 2-35 Alternatives 

Alternative 6 

This is the Proposed Action alternative. It is very similar to the Alternative 5 (No 

Action) alternative in terms of LUD allocations; however, it includes extensive 

refinements to the boundaries of the small Old-Growth Reserves (based on a 

recently completed interagency evaluation), new Geologic Special Interest Areas, a 

new Experimental Forest, the conversion of a large area of Remote Recreation LUD 

north of Juneau to Semi-Remote Recreation, and other minor LUD refinements. 

Timber would be managed in an area more extensive than under Alternative 3, but 

less extensive than under Alternative 4. The vast majority of current roadless areas 

would remain in a natural condition; however, the majority of roadless areas that 

contain substantial POG, outside of wilderness, would be partially developed. A 

total of 3.5 million acres of the Tongass would be in development LUDs and 13.3 

million acres would be in non-development LUDs. Specific LUD changes under this 

alternative would include the addition and modification of a number of Geologic 

Special Interest Areas, recommendations to change the Young Bay Experimental 

Forest to Semi-remote Recreation and the Cowee-Davies Creek watersheds from 

Scenic Viewshed to Experimental Forest, and converting a large area of Remote 

Recreation LUD north of Juneau to Semi-Remote Recreation. It also would include 

extensive refinements to the boundaries of the small Old-Growth Reserves, based 

on a recently completed interagency evaluation. 

This alternative is similar to Alternative 11 of the 1997 FEIS. 

The vast majority of the currently undisturbed areas of the Forest remain in a natural 

state and most existing roadless areas remain roadless. Old growth conditions 

prevail on forest lands within roadless areas. A predictable and sustainable supply 

of forest products contribute to a limited integrated timber industry in Southeast 

Alaska, probably based in Ketchikan, Prince of Wales Island, Wrangell, and 

Hoonah. There would be sufficient volume under this alternative to support the 

existing sawmills. There would also be sufficient volume to support one or more 

veneer plants or an MDF or other chip-related operation, but probably not both. 

Populations of wildlife dependent on old-growth and/or unroaded habitats have a 

moderately high likelihood of being maintained as viable and well-distributed across 

the Tongass. A mixture of old growth, recently harvested areas, and various ages of 

young growth occurs within roaded areas. Recreation, tourism, and subsistence 

opportunities occur in natural setting types, but roaded opportunities are 

considerably expanded from current conditions. 

If Alternative 6 is selected, the LUD allocation acres shown in Table 2-13 would 

result. Figure 2-6 shows the distribution of LUDs across the Tongass under 

Alternative 6 according to three LUD groups (see Table 2-13 for definitions of the 

LUD groups). A complete LUD map is provided as the Alternative 6 map in the Map 

Section of the CD version of this EIS or in the Map Packet accompanying the EIS 

hard copy. 

Under Alternative 6, the management prescriptions and standards and guidelines 

identified in the Final Proposed Forest Plan would be adopted. These are generally 

the same as the management prescriptions and standards and guidelines in the 

current Forest Plan; however, a number of changes and refinements are proposed. 

A summary of the main changes to the current Forest Plan is provided above in the 

section titled “Final Proposed Forest Plan.” 

Table 2-14 displays selected outputs and other measures associated with this 

alternative. 

Framework 

Desired 

Conditions 

Land Use 

Designations 

Management 

Prescriptions 

and Standards 

and Guidelines 

Selected 

Outputs 
2 Alternatives 

Alternatives 2-36 Final EIS

Table 2-13 

Land Use Designations for Alternative 61 

Land Use Designation Acres Allocated 

Net Change from 

Current Forest 

Plan Acres2 

Wilderness LUD Group 

 Wilderness 2,637,292 0 

 National Monument3 3,278,734 0 

 Total for Wilderness LUD Group 5,916,026 0 

Natural Setting LUD Group 

 LUD II 721,002 0 

 Research Natural Area 26,093 0 

 Old Growth4 1,221,173 38,749 

 Special Interest Area4 221,176 46,712 

 Enacted Municipal Watershed 45,226 0 

 Wild, Scenic, and Recreational River 117,319 0 

 Remote Recreation 2,033,665 (97,390) 

 Semi-Remote Recreation 3,014,704 160,479 

 Total for Natural Setting LUD Group 7,400,359 148,551 

Development LUD Group 

 Experimental Forest 31,405 14,309 

 Scenic Viewshed 442,101 (35,118) 

 Modified Landscape 590,338 (11,024) 

 Timber Production 2,393,576 (116,721) 

 Total for Development LUD Group 3,457,420 (148,551) 

 Total National Forest System Lands 16,773,806 0 1 When more than one LUD is applied to the same area, such as a Special Interest Area within 

Wilderness, only the acreage of the more restrictive LUD is included, except that total Wilderness, 

Wilderness National Monument, and LUD II acres are always shown. The acreage for the Minerals 

LUD would be 249,570; these acres are not included in the table because the Minerals LUD is an 

overlay. No acreages have been calculated for the Transportation and Utility System LUD because it 

is a series of corridors with undefined width and imprecise locations. Totals may not exactly equal the 

sum of individual entries due to rounding. 2

 These changes from current Forest Plan acres are the differences from the decision made in the 

1997 Tongass Forest Plan Revision ROD, as amended, which is represented by Alternative 5. 3

 The majority of the National Monument acres are wilderness; only 166,942 acres are non-wilderness. 4 Small old-growth reserves and Special Interest Area LUDs increased relative to Alternative 5; 

however, they overlap extensively, especially on Heceta, Kosciusko, and northeast Chichagof 

Islands, and the acreages where they overlap were counted with Special Interest Areas. 
Alternatives 2

Final EIS 2-37 Alternatives 

Figure 2-6 

Wilderness, Natural Setting, and Development LUDs on the Tongass National Forest 

under Alternative 6 
2 Alternatives 

Alternatives 2-38 Final EIS

Table 2-14 

Selected Outputs and Measures Associated with Alternative 61

Resource/Category Output/Measure 

Percent in Wilderness LUD Group 35% 

Percent in Natural Setting LUD Group 44% 

Percent in Development LUD Group 21% 

Amount of Development LUDs in Inventoried Roadless Areas 

(millions of acres) 2.3 

Percent of Current Productive Old Growth Protected in Reserves 

(Wilderness/Nat. Mon. and Natural Setting LUDs) 72% 

Productive Old Growth after 100+ Years (millions of acres) 4.5 

Estimated Forest Land Suitable for Timber Production (acres)2

 775,000 

Scheduled Suitable Forest Land (acres)2 689,000 

Allowable Sale Quantity or ASQ (millions of board feet)3

 1st Decade ASQ 267 

 2nd Decade ASQ 267 

Maximum New Road Construction after 100+ Years (miles) 3,744 

Maximum Average Annual Timber Harvest during 1st Decade, 

based on the ASQ (acres) 9,806 

Potential Short-term Effects on Timber Industry4

 

 Effect on Timber Volume Under Contract None 

 Effect on NEPA-cleared Volume None 

 Effect on Timber Volume in Preparation None 

Percent of Identified Mineral Tracts and Undiscovered Mineral Areas 

in Open LUDs with Higher Development Costs 

 Percent of Identified Mineral Tracts 25% 

 Percent of Undiscovered Mineral Areas 41% 

Recreation Opportunity Spectrum Classes after 150 Years 

(millions of acres) 

 Primitive and Semi-Primitive Non-Motorized 12.0 

 Semi-Primitive Motorized 1.3 

 Roaded Natural and Roaded Modified 3.5 

1

 Totals may not add exactly due to rounding. 

2 Estimated forest land suitable for timber production represents the mapped suitable forest land minus 

the estimated portion that is unsuitable, but not mapped as such. The scheduled suitable forest land 

is the portion of the estimated suitable forest land that is scheduled for harvest by ASQ modeling. 3 ASQ volumes expressed as annual averages and include sawlog plus utility. 4 This evaluation provides an indication of potential effects; actual effects would depend on the volume 

that is under contract when the decision is implemented and whether potentially affected existing 

sales are cancelled or exempted as part of the decision. 
Alternatives 2

Final EIS 2-39 Alternatives 

Alternative 7 

Under Alternative 7, forest management would provide a mix of National Forest 

uses and activities, but would give much additional emphasis to timber 

management, relative to the current Forest Plan. Timber would be managed on a 

considerably expanded land base compared with the current Forest Plan. The vast 

majority of current roadless areas would remain in a natural condition; however, the 

majority of roadless areas that contain substantial POG outside of Wilderness, 

would be fully developed. A total of 5.0 million acres of the Tongass would be in 

development LUDs and 11.7 million acres would be in non-development LUDs. 

Almost all areas identified as development LUDs in Alternative 5 would also be 

development LUDs in this alternative, in addition to other areas. Specific LUD 

changes under this alternative would include the addition and modification of a 

number of Geologic Special Interest Areas and recommendations to change the 

Young Bay Experimental Forest to Semi-remote Recreation and the Cowee-Davies 

Creek watersheds from Scenic Viewshed to Experimental Forest. 

This alternative is similar to Alternative 2 of the 1997 FEIS. 

The vast majority of the currently undisturbed areas of the Forest remain in a natural 

state and most existing roadless areas remain roadless. However, all of the 

roadless areas to be developed under the current Forest Plan are developed along 

with additional roadless areas. Old growth conditions prevail on forest lands within 

roadless areas. The Tongass produces a predictable and sustainable supply of 

forest products that completely satisfies the demand from a high integrated timber 

industry in Southeast Alaska, probably based in Ketchikan, Prince of Wales Island, 

Wrangell, Hoonah, and other communities. Timber from private and state lands is 

not required to satisfy timber demand. A mixture of old growth, recently harvested 

areas, and various ages of young growth occurs within roaded areas. Recreation, 

tourism, and subsistence opportunities occur in natural setting types, but roaded 

opportunities are substantially expanded from current conditions. 

If Alternative 7 is selected, the LUD allocation acres shown in Table 2-15 would 

result. Figure 2-7 shows the distribution of LUDs across the Tongass under 

Alternative 7 according to three LUD groups (see Table 2-15 for definitions of the 

LUD groups). A complete LUD map is provided as the Alternative 7 map in the Map 

Section of the CD version of this EIS or in the Map Packet accompanying the EIS 

hard copy. 

Under Alternative 7, the standards and guidelines identified in the current Forest 

Plan would be adopted, with the exceptions noted below. The current Forest Plan 

represents the 1997 Forest Plan with amendments (USDA Forest Service 1997b). 

The exceptions include: 

• The Beach and Estuary Fringe buffer is changed to 500 feet. along the beach 

fringe and 1,000 feet. around estuaries. 

• The Riparian Standards and Guidelines are modified so that buffers are not 

required along Class III streams. 

• The Old-Growth Habitat LUD and its management prescription is not used and 

is deleted. 

• The goshawk foraging habitat standard and guideline, the high-value marten 

habitat standard and guideline, and the proposed Legacy standard and 

guideline would not be implemented. 

• The goshawk nesting standard and guideline would not be implemented. 

Framework 

Desired 

Conditions 

Land Use 

Designations 

Management 

Prescriptions 

and Standards 

and Guidelines 
2 Alternatives 

Alternatives 2-40 Final EIS

Table 2-16 displays selected outputs and other measures associated with this 

alternative. 

Table 2-15 

Land Use Designations for Alternative 71 

Land Use Designation Acres Allocated 

Net Change from 

Current Forest 

Plan Acres2 

Wilderness LUD Group 

 Wilderness 2,637,292 0 

 National Monument3 3,278,734 0 

 Total for Wilderness LUD Group 5,916,026 0 

Natural Setting LUD Group 

 LUD II 721,002 0 

 Research Natural Area 26,093 0 

 Old Growth 0 (1,182,424) 

 Special Interest Area 221,176 46,712 

 Enacted Municipal Watershed 45,226 0 

 Wild, Scenic, and Recreational River 117,319 0 

 Remote Recreation 2,088,185 (42,870) 

 Semi-Remote Recreation 2,589,082 (265,143) 

 Total for Natural Setting LUD Group 5,808,083 (1,433,725) 

Development LUD Group 

 Experimental Forest 31,405 14,310 

 Scenic Viewshed 781,705 304,486 

 Modified Landscape 840,342 238,980 

 Timber Production 3,396,243 885,946 

 Total for Development LUD Group 5,049,695 1,443,725 

Total National Forest System Lands 16,773,804 0 1 When more than one LUD is applied to the same area, such as a Special Interest Area within 

Wilderness, only the acreage of the more restrictive LUD is included, except that total Wilderness, 

Wilderness National Monument, and LUD II acres are always shown. The acreage for the Minerals 

LUD would be 249,570; these acres are not included in the table because the Minerals LUD is an 

overlay. No acreages have been calculated for the Transportation and Utility System LUD because it 

is a series of corridors with undefined width and imprecise locations. Totals may not exactly equal the 

sum of individual entries due to rounding. 2

 These changes from current Forest Plan acres are the differences from the decision made in the 

1997 Tongass Forest Plan Revision ROD, as amended, which is represented by Alternative 5. 3

 The majority of the National Monument acres are wilderness; only 166,942 acres are non-wilderness. 

Selected 

Outputs 
Alternatives 2

Final EIS 2-41 Alternatives 

Figure 2-7 

Wilderness, Natural Setting, and Development LUDs on the Tongass National Forest 

under Alternative 7 
2 Alternatives 

Alternatives 2-42 Final EIS

Table 2-16 

Selected Outputs and Measures Associated with Alternative 71

Resource/Category Output/Measure 

Percent in Wilderness LUD Group 35% 

Percent in Natural Setting LUD Group 35% 

Percent in Development LUD Group 30% 

Amount of Development LUDs in Inventoried Roadless Areas 

(millions of acres) 3.7 

Percent of Current Productive Old Growth Protected in Reserves 

(Wilderness/Nat. Mon. and Natural Setting LUDs) 57% 

Productive Old Growth after 100+ Years (millions of acres) 4.1 

Estimated Forest Land Suitable for Timber Production (acres)2

 1,174,000 

Scheduled Suitable Forest Land (acres)2 1,088,000 

Allowable Sale Quantity or ASQ (millions of board feet)3

 1st Decade ASQ 421 

 2nd Decade ASQ 421 

Maximum New Road Construction after 100+ Years (miles) 5,825 

Maximum Average Annual Timber Harvest during 1st Decade, 

based on the ASQ (acres) 15,827 

Potential Short-term Effects on Timber Industry4

 

 Effect on Timber Volume Under Contract None 

 Effect on NEPA-cleared Volume None 

 Effect on Timber Volume in Preparation None 

Percent of Identified Mineral Tracts and Undiscovered Mineral Areas 

in Open LUDs with Higher Development Costs 

 Percent of Identified Mineral Tracts 18% 

 Percent of Undiscovered Mineral Areas 33% 

Recreation Opportunity Spectrum Classes after 150 Years 

(millions of acres) 

 Primitive and Semi-Primitive Non-Motorized 11.1 

 Semi-Primitive Motorized 1.2 

 Roaded Natural and Roaded Modified 4.5 

1

 Totals may not add exactly due to rounding. 

2 Estimated forest land suitable for timber production represents the mapped suitable forest land minus the 

estimated portion that is unsuitable, but not mapped as such. The scheduled suitable forest land is the 

portion of the estimated suitable forest land that is scheduled for harvest by ASQ modeling. 3 ASQ volumes expressed as annual averages and include sawlog plus utility. 4

 This evaluation provides an indication of potential effects; actual effects would depend on the volume that 

is under contract when the decision is implemented and whether potentially affected existing sales are 

cancelled or exempted as part of the decision. 
Alternatives 2

Final EIS 2-43 Alternatives 

This section briefly compares the environmental consequences of the seven 

alternatives with respect to the key issues described in Chapter 1. This comparison 

is based on the effects analysis presented in Chapter 3. 

Prior to presenting the effects comparison, four tables and a figure are displayed to 

help the reader compare the differences among the alternatives. Table 2-17 and 

Figure 2-8 summarize the LUD allocations of the alternatives using LUD Group 

combinations. The four LUD Groups combine the individual LUDs in terms of 

similarities in management and/or potential effects as described in the Introduction 

to Chapter 3. The other components that help define each alternative beyond LUD 

allocations are summarized in Table 2-18. 

Table 2-19 displays some of the key indicators or measures that are used to 

quantitatively compare the alternatives relative to the key issues. In addition, Table 

2-20, located at the end of this chapter, represents a “Summary of Effects Matrix.” 

This table allows the reader to compare the effects of the alternatives on essentially 

all resource areas simultaneously, so that a cumulative picture of the net effects can 

be obtained. This table presents many quantitative measures, but it uses qualitative 

comparisons where quantitative measures are not feasible. In this regard, it may be 

used to help consider the net public benefits associated with each alternative. 

Key Issue 1 – Protection of high value roadless areas from road development 

and timber harvest activity on the Tongass National Forest is of local and 

national importance, particularly for wildlife and biodiversity, recreation, and 

tourism. 

The Tongass includes very large undeveloped land areas, with several portions of 

the Forest consisting of contiguous roadless areas that exceed one million acres 

(and are often many times larger than that) and represent large, unfragmented 

blocks of wildlife habitat. This scale of roadless lands is not available elsewhere in 

the National Forest System, except on the Chugach National Forest. 

Roadless areas are considered important because of their wildlife habitat and 

recreation values and their importance for tourism. They are also important 

because of the passive use values and ecosystem services values they provide. 

Passive use values represent the value that individuals assign to a resource 

independent of their use of that resource and typically include existence, option, and 

bequest values. 

Table 2-17 

Land Use Designation Group Comparison by Alternative (million acres)1

Alternative Wilderness2 Natural Setting 

Moderate 

Development 

Intensive 

Development 

1 5.9 10.0 0.3 0.6 

2 5.9 8.9 0.6 1.4 

3 5.9 8.1 0.8 2.0 

4 5.9 6.1 1.5 3.2 

5 5.9 7.3 1.1 2.5 

6 5.9 7.4 1.1 2.4 

7 5.9 5.8 1.7 3.4 1

 LUD Group combinations are described in the Introduction to Chapter 3 (Table 3.1-1). 2

 Wilderness LUD group includes 166.942 acres of Nonwilderness National Monument. 

 Note: Roadless area acreages are correlated with, but not the same as the LUD Group acreages. For example, some roads 

 exist within portions of some Natural Setting LUDs and no roads exist in many areas of development LUDs. 

Comparison of 

the Alternatives 
2 Alternatives 

Alternatives 2-44 Final EIS

Figure 2-8 

Land Use Designation Group Comparison by Alternative (percent) 

Direct Effects on Roadless Areas 

The Tongass National Forest is about 91 percent roadless, including wilderness. 

Only small areas where communities are developing, or where road construction 

and timber harvest have occurred, are “developed” to any noticeable degree. 

Developed areas and small unroaded areas (not included in inventoried roadless 

areas) cover about 1.51 million acres, or about 9 percent of the Tongass, wilderness 

covers about 5.75 million acres, or about 34 percent, and inventoried roadless areas 

(outside of wilderness) cover about 9.51 million acres, or about 57 percent. 

Alternative 1 is designed to avoid inventoried roadless areas. Because of this, after 

100 years or more (and full development of these LUD areas) 91 percent of the 

Tongass and 85 percent of Southeast Alaska (all Alaska lands southeast of Yakutat 

Bay) would still be in roadless or wilderness. 

Alternatives 2 and 3 would progressively enter more roadless areas with 0.8 million 

acres and 1.7 million acres of development LUDs in roadless areas, respectively. 

Alternative 2 would ultimately result in 87 percent of the Tongass and 82 percent of 

Southeast Alaska in roadless or wilderness and Alternative 3 would result in 83 

percent and 79 percent. 

Next in progression into roadless areas, Alternatives 5 and 6 would include 2.4 and 

2.3 million acres of development LUDs in roadless, respectively. Alternative 5 would 

ultimately result in 80 percent of the Tongass and 76 percent of Southeast Alaska 

being in roadless or wilderness. These percentages would be 81 and 77 for 

Alternative 6. 

Finally, Alternatives 4 and 7 both enter roadless areas to a higher degree. 

Alternative 4 would have 3.4 million acres of development LUDs in roadless and 

Alternative 7 would have 3.7 million. After 100 years or more of implementation, 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

12345678

Alternatives

Percent of Total Acres

Intensive

Development

Moderate

Development

Natural Setting

Wilderness
Alternatives 2

Final EIS 2-45 Alternatives 

Alternative 4 would result in 76 percent of the Tongass and 73 percent of Southeast 

Alaska and Alternative 7 would result in 75 percent of the Tongass and 72 percent 

of Southeast Alaska continuing as roadless or in wilderness. 

Distribution of Roadless Areas 

Significant acreages of roadless areas would remain in all biogeographic provinces 

under all alternatives; however, some would maintain a higher percentage than 

others. Under Alternatives 1 and 2, none of the 21 biogeographic provinces within 

the Tongass boundary would contain less than 50 percent of their areas in Nondevelopment LUDs. Alternative 1 would have 17 of the 21 provinces containing 90 

percent or more acreage in non-development LUDs and Alternative 2 would have 13 

provinces. 

Table 2-18 

Alternative Components 

Alternative 

Component 1 2 3 4 5 6 7 

Alternative Base1 2003 – Alt 8 None 2003 – Alt 5 1997 – Alt 6 1997 – Alt 

11 1997 – Alt 11 1997 – Alt 2 

Old-Growth Reserve 

Strategy2

All, plus 

refined 

Small OGRs 

All, plus 

refined 

Small OGRs 

All, plus 

refined 

Small OGRs 

4 Biogeo. 

Provinces All 

All, plus 

refined Small 

OGRs 

None 

OG Retention/VCU None None None 33% None None None 

Beach & Estuary Fringe 

Buffer 

Beach = 

1,000’ 

Estry.= 

1,000’ 

Beach = 

1,000’ 

Estry.= 

1,000’ 

Beach = 

1,000’ 

Estry.= 

1,000’ 

Beach = 

1,000’ 

Estry.= 

1,000’ 

Beach = 

1,000’ 

Estry.= 

1,000’ 

Beach = 

1,000’ 

Estry.= 1,000’ 

Beach = 500’ 

Estry.= 

1,000’ 

Riparian S&Gs 

Same as 

1997 Forest 

Plan 

Same as 

1997 Forest 

Plan 

Same as 

1997 Forest 

Plan 

Same as 

1997 Forest 

Plan 

Same as 

1997 Forest 

Plan

Same as 

1997 Forest 

Plan 

Same as ’97 

Plan, but no 

Class III 

buffers 

1997 Goshawk & 

Marten S&Gs No No No No Yes No No 

New Forest-wide 

Legacy S&G Yes Yes Yes No No Yes No 

Goshawk Nest S&Gs 

Apply 

Revised 

Version 

Apply 

Revised 

Version 

Apply 

Revised 

Version 

Apply 

Revised 

Version 

Apply 

Original 

Version 

Apply 

Revised 

Version 

Apply 

General 

Raptor S&Gs 

Only 

Modified Small OldGrowth Reserve 

Boundaries 

Yes Yes Yes No No Yes No 

Experimental Forest 

Replacement Yes Yes Yes Yes No Yes Yes 

Additional/Modified 

Geologic Special 

Interest Areas 

Yes Yes Yes Yes No Yes Yes 

Other S&G Changes in 

Proposed Forest Plan Yes Yes Yes Yes No Yes No 

1 Identifies the previous Forest Plan NEPA document and the specific alternative that the current alternative is largely based on (1997 

= the 1997 FEIS; 2003 = 2003 SEIS). However, many changes have been made. 2 This component refers to the use of the system of old-growth habitat reserves to address wildlife viability. Such a system is in 

addition to reserves that already exist, such as within Wilderness or Legislated LUD II areas. 

Definitions

Reserves: 

All = Large, Medium, and Small reserves identified in the current Forest Plan 

4 Biogeo. Provinces = N. POW, Kupreanof/Mitkof, Dall Island, NE Chichagof, and individual reserves (Myers Chuck, Lake Eva, 

Wright Lake). 

S&Gs = Standards and Guidelines 

VCU = Value Comparison Unit (roughly a watershed) 
2 Alternatives 

Alternatives 2-46 

Table 2-19 Comparison of Alternatives 

Alternative 

Resource/Category Unit of Measure 1 2 3 4 5 6 Key Issue 1 – Long-term Protection of High-value Roadless Areas 

Millions of Acres 0.0 0.8 1.7 3.4 2.4 2.3 

Inventoried Roadless Areas in development LUDs 

(acres and percent of all roadless areas) Percent 0 9 18 36 26 24 

Amount of Timber Harvest in current Inventoried 

Roadless Areas after 100+ years 

Thousands of 

Acres 0 89 186 498 316 307 

Minimum Percent of Tongass in Inventoried 

Roadless Areas after 100+ years 

(assumes 75% of development LUD areas and 0% 

of non-development LUD areas become roaded) 

Percent 57 53 49 41 46 46 

Percent of Tongass in Wilderness (including 

Wilderness National Monument)

Percent 34 34 34 34 34 34 

Percent of Tongass in Wilderness and Inventoried 

Roadless Areas after 100+ years

Percent 91 87 83 76 80 81 

Percent of Southeast Alaska in Wilderness and 

Inventoried Roadless Areas after 100+ years (assumes all non-NFS lands become roaded, except for Glacier Bay NP and 50% of non-NFS lands in the Haines/Skagway area)

Percent 85 82 79 73 76 77 

Number of the 21 Biogeographic Provinces with 

Less than 50% of Tongass Lands in Nondevelopment LUDs 

Count 0 0 2 5 3 3 

Key Issue 2⎯Provision of Sufficient Timber to Meet Market Demand

Long-Term Effects (Second Decade On)

 Percent Change in Suitable Acres Percent

 ASQ (average annual) MMBF 49 151 205 360 267 267 

 NIC I Component of the ASQ MMBF 49 143 187 314 239 236 

Ability to Meet the Timber Demand Scenarios 

in 2022 

 Scenario 1—Limited Lumber Industry Yes/No No Yes Yes Yes Yes Ye

 Scenario 2—Expanded Lumber Industry Yes/No No No Yes Yes Yes Ye

 Scenario 3—Medium Integrated Industry Yes/No No No Yes Yes Yes Ye Scenario 4—High Integrated Industry Yes/No No No No Yes No No Annual Harvest as a Percent of Processing 

Capacity 

Active Installed Processing Capacity (261 MMBF) Percent 9 27 36 60 46 45 Total Installed Processing Capacity (361 MMBF) Percent 7 20 26 43 33 33 
Final EIS 2-47 Table 2-19 (continued) Comparison of Alternatives

Alternative 

Resource/Category Unit of Measure 1 2 3 4 5 Key Issue 2⎯Provision of Sufficient Timber to Meet Market Demand (continued)

Direct Employment 

Logging Job-Years 365 583 680 880 803 Sawmills Job-Years 129 336 428 616 544 Total Job-Years 494 919 1,108 1,496 1,346 

Total Net Change from Alternative 5 (No Action) Percent -63 -32 -18 11 0 Direct Income 

Logging $ million 15.4 24.6 28.7 37.2 33.9 

Sawmills $ million 4.1 10.6 13.6 19.5 17.2 

Total $ million 19.5 35.3 42.3 56.7 51.1 

Potential Short-Term Effects (2007 to 2009) 1

Effect on Timber Volume Under Contract Percent High None None None None 

Effect on NEPA-Cleared Timber Volume Percent Low Low None None None Effect on Timber Volume in Preparation Percent Low Very Low Very Low None None 

Key Issue 3 – Protection of Wildlife Habitat and Biodiversity 

Harvest of Productive Old GrowthMaximum Harvest of Productive Old Growth on 

NFS Lands after 100+ years 

Thousands of 

Acres 

86 215 313 656 463 

Minimum Percent of Original Productive Old 

Growth Remaining on NFS Lands after 100+ years

Percent 90 88 86 79 83 

Minimum Percent of Original Productive Old 

Growth Remaining on All Lands in SE Alaska after 100+ years

Percent 82 80 78 73 76 

Road Development 

Maximum New Road Miles Developed on NFS 

lands after 100+ years (4,942 miles of existing roads)

Miles 774 2,079 2,799 4,890 3,874 

Percent of WAAs with Total Road Density on NFS 

Lands greater than 1.0 mile/sq.mile after 100+ 

years (currently 8% of 188 WAAs) 

Percent 11 16 18 23 19 

Number of WAAs with Total Road Density on All 

Lands (Inside Forest Boundary) greater than 1.0 mile/sq.mile after 100+ years (currently 14% of 191 WAAs) 

Percent 20 23 24 28 26 

1 This evaluation provides an indication of potential effects; actual effects would depend on the volume that is under contract when the decision is implemen

affected existing sales are cancelled or exempted as part of the decision. 
2 Alternatives 

Alternatives 2-48 Table 2-19 (continued) Comparison of Alternatives

Alternative 

Resource/Category Unit of Measure 1 2 3 4 5 Key Issue 3 – Protection of Wildlife Habitat and Biodiversity (continued) 

Representation of Old Growth Forests Number of Biogeographic Provinces with 75% or 

more of the Original Productive Old Growth Remaining after 100+ years – All Lands in SE Alaska (currently 22 out of 23)* 

Count 19 18 16 12 13 

Number of Biogeographic Provinces with less than 

50% of the Original Productive Old Growth Remaining after 100+ years – All Lands in SE Alaska (currently 0 out of 23)*

Count 0 0 0 1 0 

Number of Biogeographic Provinces with more 

than 50% of the Original Large-tree Productive Old Growth Remaining after 100+ years – All Lands in SE Alaska (currently 4 out of 23)

Count 16 16 16 14 16 

Conservation Strategy and Landscape ConnectivityLandscape connectivity: Number of critical pinchpoints with negative effects Count 0 1 1 3 1 

Abundance and distribution of high quality oldgrowth forest blocks in OGRs and other Nondevelopment LUDs after 100+ years Qualitative Good to Excellent Good to Excellent Good to Very Good Poor to Good Good to Very Good 

V

Species-Specific Effects

Goshawks – Likelihood of maintaining viable, welldistributed populations after 100+ years Rating Very High Very High Very High Moderately High High 

Marten – Likelihood of maintaining viable, welldistributed populations after 100+ years Rating Very High High High Moderate Moderate 

Wolf – Likelihood of maintaining viable, welldistributed populations after 100+ years Rating Very High Very High High High High 

Brown Bear – Likelihood of maintaining viable, 

well-distributed populations after 100+ years 

Rating Very High High High Moderately 

High 

High 

Endemic Mammals – Likelihood of maintaining 

viable, well-distributed populations for all endemics after 100+ years 

Rating Moderate Moderate Moderate Moderately 

Low 

Moderate 

Deer habitat capability on NFS Lands after 100+ 

years in Terms of Percent of Original (1954) Habitat Capability (88% currently) 

Percent 86 84 83 79 81 

* 21 Biogeographic Provinces inside the Forest Boundary plus 2 outside (Chilkat River Complex and Glacier Bay/Fairweather Range) 
Alternatives 2

Final EIS 2-49 Alternatives 

Alternative 3 would have two biogeographic provinces and Alternatives 5 and 6 

would have three provinces with less than 50 percent their acreage in nondevelopment LUDs. The lowest percentage would be for the Etolin Island and 

Vicinity province with 43 percent under Alternative 3 and for the Kupreanof/Mitkof 

Island province with 36 percent under Alternative 5 and 39 percent under Alternative 

6. Alternative 3 would have 9 of the 21 provinces and Alternative 5 and 6 would 

have 6 of the 21 provinces with 90 percent or more of their acreage in nondevelopment LUDs. 

Alternatives 4 and 7 would each result in five biogeographic provinces with less than 

50 percent in non-development LUDs. The lowest percentage would be for the 

Etolin Island and Vicinity province with 20 percent under Alternative 4 and for the 

Kupreanof/Mitkof Island province with 18 percent under Alternative 7. Alternatives 4 

and 7 would have 6 of the 21 provinces containing 90 percent or more of their 

acreage in non-development LUDs. 

Key Issue 2 – The Tongass National Forest needs to provide a sufficient 

timber supply to meet the market demand and help maintain a vibrant 

economy in Southeast Alaska. 

Timber from the Tongass National Forest is the main source of raw materials for the 

region’s wood products industry. 

Demand may be thought of as the different amounts of a product buyers are willing 

to purchase at different prices. Demand is not a single number, but instead a series 

of price-quantity relationships. The same is true of supply. It is the combination of 

supply and demand that determines the quantity and price of goods produced and 

consumed. 

Accurately projecting future demand is difficult. Market demand for Southeast 

Alaska timber and wood products depends upon numerous difficult to predict 

factors, including changes in technology, growth and exchange rates in key markets, 

changes in consumer tastes and preferences, as well as developments in other 

producing regions whose products compete with those of Alaska. 

The average timber sale on the Tongass includes spruce, hemlock, and cedar and 

results in a variety of log grades and species. In most forested conditions, the tree 

species, tree sizes and tree quality are all mixed together. When a timber sale is 

purchased by a sawmill owner, they are usually required to purchase all of the 

volume in that sale regardless of the composition. At present, none of the 

purchasers are set up to efficiently process all grade and species from such sales, 

nor is the local industry set up to process all of the components of the timber sales. 

In the absence of a facility to use utility and lower grade logs, a timber sale must be 

sustained solely on the profits made from the higher grade sawlogs, even though 

the operator must harvest and pay for the lower grade logs. 

It should be noted that the Alaska Regional Forester (Region 10) signed a new 

policy in March 2007 that approved limited interstate shipments of unprocessed 

Sitka spruce and western hemlock. This policy is expected to increase the 

utilization of timber harvested on the Tongass and improve overall timber sale 

economics by providing a market for smaller diameter and low grade material that 

cannot be processed profitably by sawmills in Southeast Alaska. 

The wood products analysis prepared for this EIS is divided into long- and shortterm effects. The long-term effects analysis evaluates the alternatives with respect 

to a) the projections developed by the Pacific Northwest Research Station of the 

Forest Service, and b) current production levels, installed capacity, and the 

minimum volumes required by various processing facilities. These benchmarks are 
2 Alternatives 

Alternatives 2-50 Final EIS

used to evaluate the long-term effects of the alternatives. Long-term effects are 

assessed based on the ASQ projected under each alternative. 

The short-term effects analysis discusses three key components of the “timber 

pipeline”: volume under contract, NEPA-cleared volume (i.e., sales that have 

approved NEPA documents but have not yet been sold), and timber volume in 

preparation (i.e., proposed sales that are currently being evaluated under the NEPA 

process). 

Long-Term Effects 

PNW Projections. The Forest Service commissioned the Pacific Northwest 

Research Station to determine the maximum amount of timber product volume that 

could be sold over time (planning cycle market demand) and to develop a series of 

demand estimates as the industry grew to meet this output level. This resulted in a 

“derived demand” analysis that projected various demand figures for four scenarios 

based upon differing assumptions about future markets and future processing 

facilities in Southeast Alaska (Brackley et al. 2006). These future visions of the 

Southeast Alaska wood products industry are hypothetical and presented here to 

illustrate the type of developments that might take place in cases where different 

volumes are made available for harvest. The transition from one scenario to the 

next involves new private investment and market development. A key factor in 

attracting new investment is whether or not a supply of timber “shelf volume” is 

available for purchase. 

Alternatives 1 through 4 were designed to correspond with Scenarios 1 through 4, 

respectively, while also responding to other concerns. The discrepancy between 

the second decade ASQs for Alternatives 1 and 2 and projected demand for 2022 

under Scenarios 1 and 2 reflects these other concerns. These scenarios are briefly 

summarized in the following paragraphs, along with the ability of the alternatives to 

meet each scenario in 2022. 

Scenario 1 – Limited Lumber Production. This scenario approximates the status 

of the timber industry in Southeast Alaska at the time that the Brackley et al. study 

was completed. Total derived demand is projected to be 68 MMBF in 2022 under 

this scenario. It is likely that this volume would be primarily logs from more 

economical (NIC I) lands. 

Alternative 1, with a projected total output of 49 MMBF, could not provide 

sufficient volume to meet this scenario as currently modeled. 

Alternatives 2, 3, 4, 5, 6, and 7 could all provide sufficient volume to meet this 

scenario in 2022. 

Scenario 2 – Expanded Lumber Production. This scenario also projects that only 

higher value logs are processed, with limited new investments in the existing mills in 

Southeast Alaska. Total derived demand is projected to be 187 MMBF in 2022 

under this scenario. As in Scenario 1, it is likely that this volume would be primarily 

higher value logs from the more economical (NIC I) lands. 

Alternatives 1 and 2, with projected total outputs of 49 MMBF and 151 MMBF, 

respectively, could not provide sufficient volume to meet this scenario. 

Alternatives 3, 4, 5, 6, and 7 could all provide sufficient volume to meet this 

scenario. 

Scenario 3 – Medium Integrated Industry. This scenario builds on Scenario 2 and 

would establish processing capacity to fully utilize sawlogs and low grade and utility 
Alternatives 2

Final EIS 2-51 Alternatives 

logs from federal and state timber sales. Under this scenario the current sawlog 

milling capacity would operate efficiently and new processing capacity would be 

developed to utilize the material that has formerly been left in the woods or 

exported. Total derived demand is projected to be 204 MMBF in 2022 under this 

scenario. 

Alternatives 1 and 2 with projected total outputs of 49 MMBF and 151 MMBF, 

respectively, could not provide sufficient volume to meet this scenario. 

Alternatives 3, 4, 5, 6, and 7 could provide sufficient volume to meet this 

scenario. 

Scenario 4 – High Integrated Industry. This scenario builds on Scenario 3 and 

provides an estimate of the upper market level for the foreseeable future. In order 

for this situation to be realized, new investments in processing capacity would need 

to be made and additional market shares established. Total derived demand is 

projected to be 342 MMBF in 2022 under this scenario. 

Alternatives 1, 2, 3, 5 and 6 with projected total outputs of 49 MMBF, 151 

MMBF, 205 MMBF, 267 MMBF, and 267 MMBF respectively, could not provide 

sufficient volume to meet this scenario. 

Alternatives 4 and 7 could provide sufficient volume to meet this scenario. 

The ability of the seven alternatives to supply enough timber to satisfy the projected 

demand for timber under each scenario is summarized in Table S-1. 

Current Production Levels, Installed Capacity, and Minimum Volumes 

Required by Various Processing Facilities. The existing mills in Southeast 

Alaska had an estimated active installed processing capacity of 261 MMBF in 2006 

and a total processing capacity of 361 MMBF. The estimated NIC I components of 

the harvest volumes projected under each alternative range from 9 percent of the 

active installed processing capacity under Alternative 1 to 71 percent under 

Alternative 7. The NIC I volume projected under Alternative 5 (No Action) 

represents about 46 percent of the existing active processing capacity. The 

projected NIC I components represent smaller shares of the total installed capacity, 

ranging from 7 percent under Alternative 1 to 51 percent under Alternative 7. 

Two of the future demand scenarios evaluated by Brackley et al. (2006a) involve an 

integrated industry. These scenarios are based on the assumption that as stable 

volumes get higher, the industry will develop in an integrated fashion, with 

operations and production that utilize materials that are inefficient or excess to one 

another’s production. The potential components of an integrated industry could 

include sawmills, a veneer plant, and a medium density fiberboard (MDF) or 

bioenergy facility, among others. The different facilities would process different 

types of log. Sawmills would generally process higher quality material (high grade 

sawlogs), with the other types of facility processing lower quality material (low grade 

sawlogs and utility logs). 

Based on the projected harvest volumes, only Alternatives 4 and 7 would provide 

sufficient volume to support an integrated industry that consisted of the existing 

sawmills, a veneer plant, and an MDF or Bioenergy facility. Under Alternative 5 (No 

Action), there would be sufficient volume to support the existing sawmills. There 

would also be sufficient volume to support one or more veneer plants or an MDF or 

other chip-related operation, but not both. 

A number of timber projections were reviewed as part of this analysis. Based on 

this review, the Forest Service identified a potential upper planning cycle demand of 
2 Alternatives 

Alternatives 2-52 Final EIS

360 MMBF from all sources. Only Alternative 7 includes sufficient volume to meet 

this level of demand only from NFS acres. 

Direct Employment and Income. Direct sawmill and logging employment 

estimates are presented in job-years, which represent the equivalent of one year’s 

employment. This potential employment would not necessarily occur all in one year 

and estimated job totals do not directly translate into estimated numbers of affected 

workers. These estimates assume a linear relationship between harvest and 

employment levels, with a one percent change in harvest resulting in a one percent 

change in employment. In reality, changes in volume will have a lagged response in 

employment, but the assumed linear relationship is an approximation that can be 

used to compare alternatives. 

Based on projected harvest volumes, average annual direct wood products 

employment would range from 494 annualized jobs under Alternative 1 to 1,922 jobs 

under Alternative 7. Approximately 274 of these annualized jobs would be 

associated with non-Tongass harvest under each alternative. Viewed in relation to 

Alternative 5 (No Action), projected direct employment would range from a 63 

percent decrease under Alternative 1 to an increase of approximately 43 percent 

under Alternative 7. 

Projected annual direct income, which is calculated based on the projected number 

of jobs, would range from $19.5 million under Alternative 1 to $72.5 million under 

Alternative 7. These totals also include income that would be generated by nonTongass harvest. 

Short-Term Effects 

The following discussion provides an indication of potential short-term effects. 

Actual effects would depend on the volumes in each pool when the decision is 

implemented. In the case of the volume under contract, potential impacts would 

also depend on whether potentially affected sales were cancelled or exempted as 

part of the decision. 

Volume under Contract. Alternative 1 would maintain the majority of the 

Inventoried Roadless Areas on the Tongass in a natural condition and would not 

allow timber harvest in those areas. Alternative 1 would affect 52 percent (54 

MMBF) of the volume under contract as of August 2006 (104 MMBF). The volume 

currently under contract would not be affected by any of the other alternatives. 

NEPA-Cleared Volume. Alternative 1 would affect 56 percent (255 MMBF) of the 

current NEPA-cleared volume as of August 2006 (454 MMBF). It should be noted 

that not all this volume is considered economic under current market conditions. 

Alternative 2 would affect 44 percent or 198 MMBF of this volume, which represents 

the volume that has passed through the NEPA process and is scheduled to be 

available for sale in the near future. None of the other alternatives would affect this 

volume. 

Timber Volume in Preparation. Alternative 1 would affect 56 percent (298 MMBF) 

of the timber volume in preparation as of September 2006 (536 MMBF). 

Alternatives 2 and 3 would each affect approximately 7 percent or 40 MMBF of this 

volume. Alternatives 4, 5, 6, and 7 would not affect this volume. 
Alternatives 2

Final EIS 2-53 Alternatives 

Key Issue 3 – Protection of the wildlife habitat and biodiversity of the Tongass 

National Forest is of local and national significance and is affected by road 

development and timber harvest activities. 

The Tongass National Forest supports a unique and important assemblage of 

wildlife including the largest population of brown bears and breeding bald eagles in 

the world, species of high importance for subsistence (e.g., Sitka black-tailed deer), 

an extensive array of endemic mammals and other species, and a large number of 

species that are at least partially dependent on old-growth habitats (e.g., marten and 

goshawk). Populations of many of these species and the biodiversity of Southeast 

Alaska are affected by timber harvest and the development of roads. 

Old-Growth Harvest 

The amount of harvest of POG is a key indicator of effects on many species, 

including goshawks, marten, endemic mammals, and deer (to some degree). The 

range of old-growth harvest is broad among the alternatives. Alternative 1 has the 

lowest maximum harvest of POG at 86,000 acres, while Alternative 7 has the 

highest maximum at 807,000 acres. After 100 years or so, a minimum of 90 percent 

of all POG on NFS lands would remain under Alternative 1 and 77 percent would 

remain under Alternative 7. Percentages for all of Southeast Alaska, including nonNFS lands, would be 82 percent for Alternative 1 and 71 percent for Alternative 7. 

The other five alternatives would rank between Alternatives 1 and 7; their order from 

lowest to highest harvest would have Alternative 2 at the low end progressing to 

Alternative 3, then 6, then 5, and then 4. 

Road Development 

The Tongass currently has 4,941 miles of existing roads (including closed and nonsystem roads). This total includes 2,619 miles of open roads, plus 913 miles of 

closed roads that are in storage and 1,409 miles of non-system roads. Road 

construction can negatively affect wildlife by eliminating habitats and by permitting 

increased access, which can result in increased harvests and human-large predator 

interactions. 

Under Alternative 1, an estimated maximum of 774 new road miles would be 

developed over 100 years. For Alternatives 2 and 3 the estimated maximum new 

road construction would be 2,079 and 2,799 miles, respectively. The majority of 

these road miles would be closed after harvest activities are completed, and 

reopened at the next entry. The maximum road miles to be constructed under 

Alternatives 5 and 6 would be 3,874 and 3,744, respectively. Alternative 4 would 

construct a maximum of 4,890 miles of new road and Alternative 7 would construct a 

maximum of 5,825 miles of new road. 

A better indicator of road effects on wildlife is the road density within Wildlife 

Analysis Areas (WAA). On Tongass NFS lands, 8 percent of the WAAs that make 

up the Tongass have a road density greater than 1.0 mile per square mile under 

existing conditions. Road density would increase in many areas after full 

implementation of the alternatives. Under Alternative 1, the density would increase 

so that a maximum of 11 percent of the WAAs would have a density greater than 1.0 

mile per square mile. Alternatives 2, 3, and 6 would have a maximum of 16 tp 18 

percent, Alternative 5 would have a maximum of 19 percent, and Alternatives 4 and 

7 would have 23 to 25 percent. These percentages would increase further when 

cumulative road development, including future road development on non-NFS lands, 

is considered. The percentage of WAAs with road density on all lands (including 

non-NFS lands) greater than 1.0 mile per square mile would be 20 percent for 
2 Alternatives 

Alternatives 2-54 Final EIS

Alternative 1, 23 to 26 percent for Alternatives 2, 3, 5, and 6, and 28 to 31 percent 

for Alternatives 4 and 7. 

Representation of Old-Growth Forests 

The percentage of POG remaining in each biogeographic province and in each 

ecological subsection is an indication of the degree to which all potentially valuable 

ecological communities remain fully represented. 

After 100 years of Alternative 1 implementation, 19 of the 23 biogeographic 

provinces covering Southeast Alaska would have 75 percent or more of their POG 

remaining and none would have less than 50 percent (minimum value = 55 percent). 

For large-tree POG, 16 out of 23 provinces would have at least 50 percent of the 

original amount remaining (minimum value = 32%). 

At the other end of the spectrum, after 100 years of implementation of Alternatives 4 

or 7, 11 to 12 of the 23 biogeographic provinces would have 75 percent or more of 

their POG remaining and one would have less than 50 percent (minimum value = 44 

percent for Alternative 7). Considering large-tree POG, 13 to 14 of the provinces 

would have at least 50 percent of the original amount remaining (minimum value = 

29 percent under Alternative 7). 

The other four alternatives (Alternatives 2, 3, 5, and 6) would all have values within 

these ranges; they would have 13 to 18 of the 23 biogeographic provinces covering 

Southeast Alaska with 75 percent or more of their POG remaining. None of these 

alternatives would have any biogeographic provinces with less than 50 percent of 

their POG. Each of them would also have 16 out of 23 provinces with least 50 

percent of the original large-tree POG remaining (minimum value = 31%). 

Conservation Strategy and Landscape Connectivity 

An adequate amount and distribution of high quality old-growth blocks with good 

landscape connectivity is fundamental to the “coarse filter” aspect of the Old-Growth 

Forest Conservation Strategy and is important for the maintenance of viable, welldistributed populations of many species of wildlife. Because of the spacing of oldgrowth reserves and other non-development LUDs, Alternatives 1 and 2 would 

result in a good to excellent distribution of high quality old-growth blocks over the 

long term, and would have little to no effects on landscape “pinch-points.” 

Alternatives 3, 5, and 6 would have good to very good spacing of old-growth 

reserves and other non-development LUDs and would similarly effect only one 

“pinch-point.” 

Under Alternative 4, the long-term result would be a good distribution of high quality 

old-growth blocks in the four biogeographic provinces with old-growth reserves, but 

a poor to fair distribution in the other provinces over the long term. The old-growth 

retention requirement would mitigate this to some degree, but would not necessarily 

result in blocks or large patches of POG being retained. This alternative would also 

negatively affect three critical landscape “pinch-points.” 

Alternative 7 would result in a poor distribution of high quality old-growth blocks over 

the long term throughout most of the Tongass because of the lack of old-growth 

reserves, the lack of an old-growth retention requirement, and the high acreage of 

development LUDs. It would negatively affect four critical landscape “pinch-points” 

and result in a lower degree of landscape connectivity due to narrower beach 

buffers. 
Alternatives 2

Final EIS 2-55 Alternatives 

Species-Specific Effects 

Expert panel viability assessments were conducted for key species to rate the 

alternatives considered in the 1997 Forest Plan Revision EIS. These ratings were 

transferred to the alternatives in this EIS, based on the four alternatives that are 

similar between EISs (i.e., 1997-Alternative 6 is similar to 2007-Alternative 4, 1997- 

Alternative 11 is similar to 2007-Alternatives 5 and 6, and 1997-Alternative 2 is 

similar to 2007-Alternative 7), and based on harvest acreage similarities. The 

ratings were also transferred into a relative qualitative description of the likelihood of 

maintaining viable, well-distributed populations so that the alternatives could more 

easily be compared. 

Under Alternative 1, the likelihood of maintaining viable, well-distributed populations 

on the Tongass after 100 years is estimated to be very high for the goshawk, 

marten, wolf, and brown bear, and moderate for endemic mammals. Alternative 2 

would rate almost as high. Under Alternative 3, this likelihood is estimated to be 

very high for the goshawk; high for the marten, wolf, and brown bear; and moderate 

for endemic mammals. 

Alternatives 5 and 6 would have similar ratings. The likelihood of maintaining viable, 

well-distributed populations on the Tongass after 100 years is estimated to be high 

for the goshawk, wolf and brown bear; and moderate for the marten and endemic 

mammals. 

Alternatives 4 and 7 rate the lowest among the alternatives. For Alternative 4, the 

likelihood of maintaining viable, well distributed populations on the Tongass after 

100 years is estimated to be high for the wolf; moderately high for the goshawk and 

brown bear; moderate for the marten; and moderately low for endemic mammals. 

For Alternative 7, the likelihood is estimated to be moderately high for the wolf and 

brown bear; moderate for the goshawk and marten; and very low for endemic 

mammals. 

Deer habitat capability expressed in terms of percent of 1954 values can be used to 

identify the amount of habitat change over time (current habitat capability = 88 

percent of 1954 value, based on the deer model). After 100 years of Forest Plan 

implementation, the percentage for Alternative 1 could drop as low as 86 percent, 84 

percent under Alternative 2, 83 percent under Alternative 3, 82 percent under 

Alternative 6, 81 percent under Alternative 5, 79 percent under Alternative 4, and 77 

percent under Alternative 7. These percentages could be increased somewhat with 

more intensive management of young-growth forests. 
2 Alternatives 

Alternatives 2-56 Final EIS

This page is intentionally left blank. 
Final EIS 

Table 2-20 Summary of Effects Matrix 

Value/Resource Alternative 1 Alternative 2 Alternative 3 Alternative 4 

PHYSICAL AND BIOLOGICAL ENVIRONMENT 

KarstKarst Resources: Forest Plan S&Gs fully protect high vulnerability karst lands and other karst areas also have S&Gs for protection. However, some effects may occur as a result of timber harvest and road construction. The relative effects on karst resources are proportional to the amount of karst lands in the mapped suitable forest land base.

Maximum harvest after 100+ years on karst lands is 12,000 acres of old growth and 17,000 acres of young growth. Implementation of S&Gs and site-specific mitigation measures will mitigate potential effects. 

Maximum harvest after 100+ years on karst lands is 18,000 acres of old growth and 43,000 acres of young growth. Implementation of S&Gs and site-specific mitigation measures will mitigate potential effects. 

Maximum harvest after 100+ years on karst lands is 20,000 acres of old growth and 46,000 acres of young growth. Implementation of S&Gs and site-specific mitigation measures will mitigate potential effects.

Maximum harvest after 100+ years on karst lands is 33,000 acres of old growth and 53,000 acres of young growth. Implementation of S&Gs and site-specific mitigation measures will mitigate potential effects. 

Maximlands 52,00Implemitigaeffect

SoilsSoil Productivity, Erosion, and Mass Wasting: Changes in soil productivity are proportional to the extent of road development, with road development removing land from productive status. Soil erosion and mass wasting potential is also proportional to the extent of road development, as well as the amount of harvest on steep slopes.

Cumulative acres covered by road surfaces on NFS lands are estimated to increase by a maximum of 2,300 after 100 yrs. Amount of additional harvest on slopes ≥ 67% would be 

a maximum of 2,400 acres after 100 yrs. 

Cumulative acres covered by road surfaces on NFS lands are estimated to increase by a maximum of 6,200 after 100 yrs. Amount of additional harvest on slopes ≥ 67% would be a maximum of 8,200 acres after 100 yrs. 

Cumulative acres covered by road surfaces on NFS lands are estimated to increase by a maximum of 8,400 after 100 yrs. Amount of additional harvest on slopes ≥ 67% would be 

a maximum of 12,400 acres after 100 yrs. 

Cumulative acres covered by road surfaces on NFS lands are estimated to increase by a maximum of 14,700 after 100 yrs. Amount of additional harvest on slopes ≥ 67% would be 

a maximum of 21,600 acres after 100 yrs. 

Cumuon NFmaximadditi

a max

Water and WetlandsStream Flows: Effects on stream flows are expected to vary by watershed and are difficult to predict, but are expected to be small. Any effects that do occur are expected to be proportional to the extent of road development and harvest.

See cumulative acres covered by road surfaces under Soils, road development under Fish, and old-growth forest harvest under Biodiversity and Plants. 

See cumulative acres covered by road surfaces under Soils, road development under Fish, and old-growth forest harvest under Biodiversity and Plants. 

See cumulative acres covered by road surfaces under Soils, road development under Fish, and old-growth forest harvest under Biodiversity and Plants. 

See cumulative acres covered by road surfaces under Soils, road development under Fish, and old-growth forest harvest under Biodiversity and Plants. 

See csurfacundeunde

Wetlands: Effects of timber harvest and road construction are proportional to the extent of road development and harvest.

See cumulative acres covered by road surfaces under Soils, road development under Fish, and old-growth forest harvest under Biodiversity and Plants. 

See cumulative acres covered by road surfaces under Soils, road development under Fish, and old-growth forest harvest under Biodiversity and Plants. 

See cumulative acres covered by road surfaces under Soils, road development under Fish, and old-growth forest harvest under Biodiversity and Plants. 

See cumulative acres covered by road surfaces under Soils, road development under Fish, and old-growth forest harvest under Biodiversity and Plants. 

See csurfacundeunde

Public Water Supplies: The supply and quality of water produced by municipal watersheds.

No change in municipal watershed LUD. No change in municipal watershed LUD. No change in municipal watershed LUD. No change in municipal watershed LUD. No ch

FishFish Passage: Effects of road-stream crossings on fish passage are proportional to the length of roads constructed. However, Forest Plan S&Gs and monitoring are expected to reduce this impact to low levels for all alternatives over the long term.

Cumulative road development on NFS lands is expected to increase by a maximum of 774 miles after 100 yrs. This represents a 16% increase over existing conditions. 

Cumulative road development on NFS lands is expected to increase by a maximum of 2,079 miles after 100 yrs. This represents a 42% increase over existing conditions. 

Cumulative road development on NFS lands is expected to increase by a maximum of 2,799 miles after 100 yrs. This represents a 57% increase over existing conditions. 

Cumulative road development on NFS lands is expected to increase by a maximum of 4,890 miles after 100 yrs. This represents a 99% increase over existing conditions. 

Cumuis exp3,874 78% 

Fish Habitat: Effects on fish habitat can be measured by the amount of road development, road density, and timber harvest activity. However, Forest Plan S&Gs associated with riparian areas, wetlands, beach and estuary fringe, etc., are expected to reduce these effects to nonsignificant levels. 

After 100 yrs, average road density would be a maximum of 0.22 mi/sq mi with 96% of VCUs having a density < 2 mi/sq mi. on NFS lands. Cumulative average road density on NFS and non-NFS lands combined would be a maximum of 0.42 mi/sq mi with 90% of VCUs having a density < 2 mi/sq mi. Also see road development under Fish Passage and harvest acres under Biodiversity. 

After 100 yrs, average road density would be a maximum of 0.27 mi/sq mi with 94% of VCUs having a density < 2 mi/sq mi. on NFS lands. Cumulative average road density on NFS and non-NFS lands combined would be a maximum of 0.47 mi/sq mi with 88% of VCUs having a density < 2 mi/sq mi. Also see road development under Fish Passage and harvest acres under Biodiversity. 

After 100 yrs, average road density would be a maximum of 0.30 mi/sq mi with 93% of VCUs having a density < 2 mi/sq mi. on NFS lands. Cumulative average road density on NFS and non-NFS lands combined would be a maximum of 0.49 mi/sq mi with 88% of VCUs having a density < 2 mi/sq mi. Also see road development under Fish Passage and harvest acres under Biodiversity. 

After 100 yrs, average road density would be a maximum of 0.38 mi/sq mi with 92% of VCUs having a density < 2 mi/sq mi. on NFS lands. Cumulative average road density on NFS and non-NFS lands combined would be a maximum of 0.57 mi/sq mi with 86% of VCUs having a density < 2 mi/sq mi. Also see road development under Fish Passage and harvest acres under Biodiversity. 

After a maxVCUs landsNFS a maxVCUs see roand h

Biodiversity and PlantsOld-Growth Forest Harvest: Because of the importance of old-growth forests to the biodiversity of Southeast Alaska and because it is the habitat that is affected the most on both NFS and non-NFS lands, a measure of effects on biodiversity and plants is the maximum amount of productive old growth (POG) harvest. 

A maximum of 86,000 acres of POG would be harvested on NFS lands after 100 yrs. Assuming all of these acres were harvested, approximately 90% of original POG on NFS lands and 82% of original POG on all lands in SE Alaska would remain (past and future harvest on non-NFS lands is included). 

A maximum of 215,000 acres of POG would be harvested on NFS lands after 100 yrs. Assuming all of these acres were harvested, approximately 88% of original POG on NFS lands and 80% of original POG on all lands in SE Alaska would remain (past and future harvest on non-NFS lands is included). 

A maximum of 313,000 acres of POG would be harvested on NFS lands after 100 yrs. Assuming all of these acres were harvested, approximately 86% of original POG on NFS lands and 78% of original POG on all lands in SE Alaska would remain (past and future harvest on non-NFS lands is included). 

A maximum of 656,000 acres of POG would be harvested on NFS lands after 100 yrs. Assuming all of these acres were harvested, approximately 79% of original POG on NFS lands and 73% of original POG on all lands in SE Alaska would remain (past and future harvest on non-NFS lands is included). 

A mabe haAssuapprolands SE Aharve

Old-Growth Distribution and Representation: The percentage of POG and large-tree POG remaining in each biogeographic province for all of Southeast Alaska (including non-NFS lands) is an indication of the degree to which all potentially valuable ecological communities remain fully represented.

After 100 yrs, 19 of the 23 biogeographic provinces would have 75% or more of their POG remaining and none would have less than 50% (minimum value = 55%). For largetree POG, 16 of the 23 would have at least 50% remaining and none would have less than 30% (minimum value = 32%). 

After 100 yrs, 18 of the 23 biogeographic provinces would have 75% or more of their POG remaining and none would have less than 50% (minimum value = 54%). For largetree POG, 16 of the 23 would have at least 50% remaining and none would have less than 30% (minimum value = 32%). 

After 100 yrs, 16 of the 23 biogeographic provinces would have 75% or more of their POG remaining and none would have less than 50% (minimum value = 52%). For largetree POG, 16 of the 23 would have at least 50% remaining and none would have less than 30% (minimum value = 32%). 

After 100 yrs, 12 of the 23 biogeographic provinces would have 75% or more of their POG remaining and 1 would have less than 50% (minimum value = 49%). For large-tree POG, 14 of the 23 would have at least 50% remaining and none would have less than 30% (minimum value = 31%). 

After provinPOG than 5tree P50% than 3

WildlifeConservation Strategy and Landscape Connectivity: An adequate amount and distribution of high quality old-growth blocks with good landscape connectivity is fundamental to the “coarse filter” aspect of the Old-Growth Forest Conservation Strategy and is important for the maintenance of viable, well-distributed populations of many species of wildlife 

This alternative would result in a good to excellent distribution of high quality oldgrowth blocks over the long term, and would not have a major effect on landscape “pinchpoints.” In addition to more non-development LUDs, it would improve the protection of high quality old growth due to refinements in small old-growth reserve boundaries, relative to Alternative 5. 

This alternative would result in a good to excellent distribution of high quality oldgrowth blocks over the long term, and would have some effect on one critical landscape “pinch-point.” In addition to more nondevelopment LUDs, it would improve the protection of high quality old growth due to refinements in small old-growth reserve boundaries, relative to Alternative 5. 

This alternative would result in a good to very good distribution of high quality old-growth blocks over the long term, and would have some effect on one critical landscape “pinchpoint.” In addition to more non-development LUDs, it would improve the protection of high quality old growth due to refinements in small old-growth reserve boundaries, relative to Alternative 5. 

This alternative would result in a good distribution of high quality old-growth blocks in the four biogeographic provinces with oldgrowth reserves, but a poor to fair distribution in the other provinces over the long term. It would negatively affect three critical landscape “pinch-points.” 

This agood blocksome point” 

Key Species Distribution and Viability: Expert panel viability assessments were made for key species to rate the alternatives considered in the 1997 Forest Plan Revision EIS. These ratings can be transferred to the alternatives in this EIS, based on the four alternatives that are similar between EISs and harvest acreage similarities. 

The likelihood of maintaining viable, well distributed populations on the Tongass after 100 years is estimated to be very high for the goshawk, marten, wolf, and brown bear, and moderate for endemic mammals. 

The likelihood of maintaining viable, well distributed populations on the Tongass after 100 years is estimated to be very high for the goshawk and wolf; high for the marten and brown bear; and moderate for endemic mammals. 

The likelihood of maintaining viable, well distributed populations on the Tongass after 100 years is estimated to be very high for the goshawk; high for the marten, wolf, and brown bear; and moderate for endemic mammals. 

The likelihood of maintaining viable, well distributed populations on the Tongass after 100 years is estimated to be high for the wolf; moderately high for the goshawk and brown bear; moderate for the marten; and moderately low for endemic mammals. 

The ldistrib100 ygoshamodemam

Deer Habitat: Deer habitat capability expressed in terms of percent of 1954 values can be used to identify the amount of habitat change over time (current habitat capability = 88% of 1954 value, based on the deer model). 

After 100 years, deer habitat capability would be a minimum of 86% of 1954 value on NFS lands. This value has the potential to be increased with young-growth management. 

After 100 years, deer habitat capability would be a minimum of 84% of 1954 value on NFS lands. This value has the potential to be increased with young-growth management. 

After 100 years, deer habitat capability would be a minimum of 83% of 1954 value on NFS lands. This value has the potential to be increased with young-growth management. 

After 100 years, deer habitat capability would be a minimum of 79% of 1954 value on NFS lands. This value has the potential to be increased with young-growth management. 

After be a landsincrea
Final EIS 

Table 2-20 (continued) Summary of Effects Matrix

Value/Resource Alternative 1 Alternative 2 Alternative 3 Alternative 4 

HUMAN USES AND LAND MANAGEMENT 

Lands and Other Special Land Use DesignationsLands: No significant environmental consequences from NFS land ownership administration activities under any alternatives. No land ownership adjustments are proposed under any alternatives. Potential changes to areas designated as Experimental Forest and Special Interest Area. No changes to Research Natural Areas; Wild, Scenic, or Recreational Rivers; or Municipal Watershed LUDs.

Forest Service would conduct land administration under the proposed Forestwide standards and guidelines, which reflect minimal changes from the current (1997) Forest Plan. Recommended replacement of Young Bay Experimental Forest. Proposed designation of 23 new Special Interest Areas, with net increase of 47,000 acres. 

Forest Service would conduct land administration under the proposed Forestwide standards and guidelines, which reflect minimal changes from the current (1997) Forest Plan. Recommended replacement of Young Bay Experimental Forest. Proposed designation of 23 new Special Interest Areas, with net increase of 47,000 acres. 

Forest Service would conduct land administration under the proposed Forestwide standards and guidelines, which reflect minimal changes from the current (1997) Forest Plan. Recommended replacement of Young Bay Experimental Forest. Proposed designation of 23 new Special Interest Areas, with net increase of 47,000 acres. 

Forest Service would conduct land administration under the proposed Forestwide standards and guidelines, which reflect minimal changes from the current (1997) Forest Plan. Recommended replacement of Young Bay Experimental Forest. Proposed designation of 23 new Special Interest Areas, with net increase of 47,000 acres. 

Lands accorstandaltern

Transportation and UtilitiesNational Forest Transportation System Roads: The level of projected timber harvest would affect the road system needed to manage the timber land base.

A maximum of 774 miles would be constructed over 100 yrs, resulting in a cumulative total of 5,716 total miles of open and closed roads at the end of this period. 

A maximum of 2,079 miles would be constructed over 100 yrs, resulting in a cumulative total of 7,021 total miles of open and closed roads at the end of this period. 

A maximum of 2,799 miles would be constructed over 100 yrs, resulting in a cumulative total of 7,741 total miles of open and closed roads at the end of this period. 

A maximum of 4,890 miles would be constructed over 100 yrs, resulting in a cumulative total of 9,832 total miles of open and closed roads at the end of this period. 

A maconstcumuand c

Southeast Alaska Transportation Plan (SATP): The Forest Service signed a Memorandum of Understanding (MOU) with the State of Alaska in 2006 to provide rights-ofway for the road corridors covered by Public Law 109-59. The MOU also grants easements to the Forest Service for marine access points and LTFs listed on Map 92337. 

There would be no effect on the SATP under this alternative. 

There would be no effect on the SATP under this alternative. 

There would be no effect on the SATP under this alternative. 

There would be no effect on the SATP under this alternative. 

There this a

TimberSuitable Forest Lands: Forest lands which are biologically capable of producing commercial wood products without irreversibly harming resources, have a reasonable assurance of adequate reforestation, and for which there is management direction that timber production is appropriate.

312,000 acres are estimated to be suitable; 144,000 acres of these are scheduled suitable lands. 

545,000 acres are estimated to be suitable; 394,000 acres of these are scheduled suitable lands. 

661,000 acres are estimated to be suitable; 514,000 acres of these are scheduled suitable lands. 

999,000 acres are estimated to be suitable; 892,000 acres of these are scheduled suitable lands. 

781,0687,0suitab

Allowable Sale Quantity (ASQ): The ASQ is the maximum quantity of timber that may be scheduled from Suitable Forest lands for a 10-year period expressed as an annual average.

The ASQ for the 1st decade and after would be slightly over 49 MMBF. 

The ASQ for the 1st decade and after would be 152 MMBF. 

The ASQ for the 1st decade would be 185 MMBF. The ASQ for the 2nd decade and after would be 203 MMBF. 

The ASQ for the 1st decade would be 312 MMBF. The ASQ for the 2nd decade and after would be 342 MMBF. 

The Abe 26

Non-Interchangeable Component (NIC)I: NIC I is the portion of the ASQ that may be harvested using existing logging systems. 

NIC I for the 1st and 2nd decades is estimated to be slightly less than 49 MMBF. 

NIC I for the 1st and 2nd decades is estimated to be 144 MMBF. 

NIC I for the 1st and 2nd decades is estimated to be 168 and 186 MMBF, respectively. 

NIC I for the 1st and 2nd decades is estimated to be 270 and 294 MMBF, respectively. 

NIC I estimrespe

Existing Timber Volume Under Contract: Changing suitable land to non-development LUDs could affect timber sales that have been sold. 

There is potential for a high effect on timber volume under contract; but this is dependent on the decision. 

There would be no effect on the volume under contract under this alternative. 

There would be no effect on the volume under contract under this alternative. 

There would be no effect on the volume under contract under this alternative. 

There contra

Minerals

Identified Mineral Tracts: Identified Mineral Tracts: Identified Mineral Tracts: Identified Mineral Tracts: IdentWithdrawn: 25% Withdrawn: 25% Withdrawn: 25% Withdrawn: 25% WithdHigher Cost Open Areas: 36% Higher Cost Open Areas: 29% Higher Cost Open Areas: 26% Higher Cost Open Areas: 20% Highe

cUndiscovered Mineral Areas: Undiscovered Mineral Areas: cUndiscovered Mineral Areas: Undiscovered Mineral Areas: Undis

Withdrawn: 35% Withdrawn: 35% Withdrawn: 35% Withdrawn: 35% Withd

Mineral Resources: No modification of Forest Service management of mineral activities specific to any alternative. No change in acreage withdrawn from mineral entry, or lands assigned to Minerals LUD. Distribution of other LUD assignments by alternative could affect costs of mineral exploration, development, production or reclamation activities, which could influence level of future mineral activity,

Higher Cost Open Areas: 57% Higher Cost Open Areas: 51% Higher Cost Open Areas: 45% Higher Cost Open Areas: 35% Highe

Recreation and Tourism

Primitive: 61% Primitive: 61% Primitive: 59% Primitive: 55% Primi

Semi-Primitive Non-Motorized: 18% Semi-Primitive Non-Motorized: 16% Semi-Primitive Non-Motorized: 15% Semi-Primitive Non-Motorized: 13% SemSemi-Primitive Motorized: 8% Semi-Primitive Motorized: 8% Semi-Primitive Motorized: 8% Semi-Primitive Motorized: 7% SemRoaded Natural: 2% Roaded Natural: 2% Roaded Natural: 3% Roaded Natural: 3% Road

Recreation Opportunity Spectrum: Current projections suggest that demand currently exceeds supply for SemiPrimitive Motorized settings in inventoried recreation places. The alternatives affect the supply of different recreation settings over time. The percentages shown here are for 150 years after implementation.

Roaded Modified: 10% Roaded Modified: 13% Roaded Modified: 16% Roaded Modified: 23% Road

Wilderness: 22% Wilderness: 22% Wilderness: 22% Wilderness: 22% Wilde

Natural Setting: 67% Natural Setting: 58% Natural Setting: 53% Natural Setting: 37% NaturModerate Development: 5% Moderate Development: 9% Moderate Development: 12% Moderate Development: 19% Mode

Home Range Recreation Places: Home range recreation places are those inventoried recreation places within an approximate 20-mile radius from one or more communities. The alternatives affect the LUD groups that these places would be managed under. The percentages shown here are percent of total home range recreation place acres by alternative. Intensive Development: 6% Intensive Development: 10% Intensive Development: 13% Intensive Development: 21% Intens

Wilderness: 46% Wilderness: 46% Wilderness: 46% Wilderness: 46% Wilde

Natural Setting: 51% Natural Setting: 47% Natural Setting: 43% Natural Setting: 34% NaturModerate Development: 2% Moderate Development: 4% Moderate Development: 5% Moderate Development: 10% Mode

Recreation Places Important for Tourism: The alternatives affect the LUD groups that recreation places that are important for tourism would be managed under. The percentages shown here are percent of total home range recreation place acres by alternative.

Intensive Development: 1% Intensive Development: 3% Intensive Development: 6% Intensive Development: 10% Intens

SceneryScenic Integrity Objectives (SIOs): SIOs define the degree to which the natural landscape can be altered. Visual priority routes and use areas were used to identify seen and seldom seen areas and to map the appropriate SIO.

Visual priority routes and use areas would be protected. Approximately 62% of the Forest would be managed under the High SIO and 4% under Low and Very Low. 

Visual priority routes and use areas would be protected. Approximately 62% of the Forest would be managed under the High SIO and 9% under Low and Very Low. 

Visual priority routes and use areas would be protected. Approximately 61% of the Forest would be managed under the High SIO and 14% under the Low and Very Low. 

Visual priority routes and use areas would be protected. Approximately 56% of the Forest would be managed under the High SIO and 23% under Low and Very Low. 

Visuaprotewould 18% 
Final EIS 

Table 2-20 (continued) 

Summary of Effects Matrix 

Value/Resource Alternative 1 Alternative 2 Alternative 3 Alternative 4 

SubsistenceAbundance and Distribution: The majority of subsistence resources (fish and marine invertebrates) would not be affected. However, analysis suggests that deer habitat capabilities in portions of the Tongass may not be adequate to sustain current/future harvest levels under any of the alternatives. The possibility of a significant restriction in harvest resulting from changes in abundance and distribution is assessed in relation to Alternative 5 (No Action).

The possibility of a significant restriction would be lower relative to Alternative 5 (No Action) because of a 77% reduction in development LUD acreage under this alternative. 

The possibility of a significant restriction would be lower relative to Alternative 5 (No Action) because of a 46% reduction in development LUD acreage under this alternative. 

The possibility of a significant restriction would be slightly lower relative to Alternative 5 (No Action) because of a 22% reduction in development LUD acreage under this alternative. 

The possibility of a significant restriction would be higher relative to Alternative 5 (No Action) because of a 31% increase in development LUD acreage under this alternative. 

The presultdistribalternFores

Competition: The subsistence analysis concluded that there could be a significant possibility of a significant restriction of subsistence use through increased competition. The possibility of a significant restriction in harvest resulting from a change in competition is assessed in relation to Alternative 5 (No Action).

The possibility of a significant restriction, resulting from a change in competition, would be lower relative to Alternative 5 (No Action) because of a 80% reduction in proposed new road construction under this alternative. 

The possibility of a significant restriction, resulting from a change in competition, would be lower relative to Alternative 5 (No Action) because of a 46% reduction in proposed new road construction under this alternative. 

The possibility of a significant restriction, resulting from a change in competition, would be lower relative to Alternative 5 (No Action) because of a 28% reduction in proposed new road construction under this alternative. 

The possibility of a significant restriction, resulting from a change in competition, would be higher relative to Alternative 5 (No Action) because of a 26% increase in proposed new road construction under this alternative. 

The presultbe the Altern

Heritage Resources and Sacred SitesHeritage Resources and Sacred Sites: Potential for effects on these resources is proportional to the amount of harvest and road construction expected to occur. However, because of inventory and tribal consultation that is required, the risk of effects is relatively low.

See road development under Fish and oldgrowth forest harvest under Biodiversity and Plants as measures of the amount of disturbance. However, because of required inventory and tribal consultation, the risk of effects is relatively low. 

See road development under Fish and oldgrowth forest harvest under Biodiversity and Plants as measures of the amount of disturbance. However, because of required inventory and tribal consultation, the risk of effects is relatively low. 

See road development under Fish and oldgrowth forest harvest under Biodiversity and Plants as measures of the amount of disturbance. However, because of required inventory and tribal consultation, the risk of effects is relatively low. 

See road development under Fish and oldgrowth forest harvest under Biodiversity and Plants as measures of the amount of disturbance. However, because of required inventory and tribal consultation, the risk of effects is relatively low. 

See rgrowtPlantdisturinveneffect

Roadless AreasRoadless Areas: Roadless areas within moderate and intensive development LUDs would change from roadless to developed status over time.

No acres (0%) of existing roadless areas would be identified as suitable for harvest. The only acres in development LUDs would be Experimental Forests. 

0.8 million acres (9%) of the existing roadless areas would be allocated to moderate and intensive development LUDs. Approximately 89,000 acres (0.9%) would be suitable and scheduled for harvest. 

1.7 million acres (18%) of the existing roadless areas would be allocated to moderate and intensive development LUDs. Approximately 186,000 acres (2.0%) would be suitable and scheduled for harvest. 

3.4 million acres (36%) of the existing roadless areas would be allocated to moderate and intensive development LUDs. Approximately 498,000 acres (5.2%) would be suitable and scheduled for harvest. 

2.4 mroadlemodeApprobe su

WildernessWilderness: None of the alternatives involve recommending new areas for wilderness or LUD II designation. Roadless areas within the Tongass National Forest were evaluated for recommendations as potential wilderness in the 2003 Forest Plan SEIS (USDA Forest Service 2003).

Wilderness and LUD II areas would be managed under the updated and edited version of the current Forest Plan presented as the Proposed Land and Resource Management Plan. 

Same as Alternative 1. Same as Alternative 1. Same as Alternative 1. Wilde

mana

ECONOMIC AND SOCIAL ENVIRONMENT 

Economic Impact AnalysisLong-Term Wood Products Effects: Long-term employment projections are based on the NIC I Component of the ASQ and include a projected non-Tongass harvest of 109 MMBF, which is the same under all the alternatives. Projections are average annual equivalents for the next 10 years and assume full implementation. These totals do not include indirect or induced employment effects.

Projected average annual direct employment would be 365 logging jobs and 129 sawmill jobs under this alternative. 

Projected average annual direct employment would be 583 logging jobs and 336 sawmill jobs under this alternative. 

Projected average annual direct employment would be 680 logging jobs and 428 sawmill jobs under this alternative. 

Projected average annual direct employment would be 880 logging jobs and 616 sawmill jobs under this alternative. 

Projewould jobs u

Recreation and Tourism: Employment projections are based on a linear projection of demand and projected supply based on changes to ROS settings (see above). Projections are average annual equivalents for the next 10 years, based on the estimated non-resident share of recreation and tourism activity. These totals do not include indirect or induced employment effects. 

Projected average annual direct employment would be 4,327 jobs under this alternative. 

Projected average annual direct employment would be 4,323 jobs under this alternative. 

Projected average annual direct employment would be 4,321 jobs under this alternative. 

Projected average annual direct employment would be 4,312 jobs under this alternative. 

Projewould 

Salmon Harvesting and Processing: There is not expected to be any significant change to the commercial fishing or fish processing industries over the next decade as a result of National Forest activities. 

The Forest Plan Riparian and other S&Gs and monitoring are expected to reduce the effects of potential development activities on fish passage and habitat to low levels over the long-term and are not expected to have significant effects on the commercial fishing and fish processing industries. 

Same as Alternative 1. Same as Alternative 1. Same as Alternative 1. Same 

Economic Efficiency AnalysisPresent Net Value (PNV): Economic efficiency analysis measures the costs and benefits to society associates with a given alternative. PNV figures are calculated by subtracting discounted costs from discounted benefits to yield a net value. PNV is calculated for those costs and benefits that can be assigned monetary values, in this case timber, recreation and tourism, and program management costs.

The estimated PNV for this alternative is $7,112 million. 

The estimated PNV for this alternative is $6,884 million. 

The estimated PNV for this alternative is $6,782 million. 

The estimated PNV for this alternative is $6,472 million. 

The e$6,65

Non-Use Values: Non-use values are values that individuals assign to a resource independent of their use of that resource and include existence, option, and bequest values. These types of values are typically associated with undeveloped areas. Impacts to roadless areas are summarized above.

Approximately 1.2 million acres (7%) of the Tongass would be allocated to moderate and intensive development LUDs. Approximately 435,000 acres are estimated to be suitable for harvest. 

Approximately 2.0 million acres (12%) of the Tongass would be allocated to moderate and intensive development LUDs. Approximately 563,000 acres are estimated to be suitable for harvest. 

Approximately 3.0 million acres (18%) of the Tongass would be allocated to moderate and intensive development LUDs. Approximately 697,000 acres are estimated to be suitable for harvest. 

Approximately 4.7 million acres (28%) of the Tongass would be allocated to moderate and intensive development LUDs. Approximately 1.01 million acres are estimated to be suitable for harvest. 

ApproTongintens809,0harve
CHAPTER 3 

ENVIRONMENT AND EFFECTS 
Environment and Effects 3

Final EIS 3-1 Introduction 

Environment and Effects 

Introduction 

This chapter combines the affected environment and environmental consequences 

discussions required by the National Environmental Policy Act (NEPA) implementing 

regulations (40 Code of Federal Regulations [CFR] 1500-1508). The discussions 

are combined so that the environmental consequences (effects) of the alternatives 

on forest resources and the background information needed to understand these 

consequences are discussed together for each resource. Each resource is first 

described by its current condition, uses, supply, and demand, or expected use, 

along with an explanation of how each resource is measured and evaluated. The 

descriptions are limited to providing the background information necessary for 

understanding how the Environmental Impact Statement (EIS) alternatives may 

affect the resource. Methodology and scientific accuracy is discussed for most 

resources. 

Many of the relationships established and discussed in the 1997 Tongass Forest 

Plan Revision Final EIS and in the 2003 Supplemental EIS (SEIS), in particular, 

Chapter 3 of these documents, are still valid and, therefore, are incorporated by 

reference in this EIS. However, this EIS uses updated relevant information to better 

reflect current conditions and focuses on the potential effects most relevant to the 

potential changes that could occur from proposed amendment to the current 

Tongass Forest Plan standards and guidelines and Land Use Designations (LUDs). 

Analyzing Effects 

Following each resource description is a discussion of the potential effects 

(environmental consequences) to the resource associated with implementation of 

each EIS alternative. All significant or potentially significant effects, including direct, 

indirect, and cumulative effects, are disclosed. Effects are quantified, where 

possible, although qualitative discussions are also included. The means by which 

any identified potential adverse effects will be reduced or mitigated are also 

described. 

Environmental consequences are the effects of implementing an alternative on the 

physical, biological, social, and economic environment. Direct environmental effects 

are defined as those occurring at the same time and place as the initial cause or 

action. Indirect effects are those that occur later in time, or are spatially removed 

from the activity but would be significant in the foreseeable future. Cumulative 

effects result from the incremental effects of actions, when added to other past, 

present, and reasonably foreseeable future actions, regardless of what agency 

(federal or non-federal) or person undertakes such other actions. Cumulative 

effects can result from individually minor, but collectively significant, actions taking 

place over a period of time. 

Potential adverse environmental effects that cannot be avoided are discussed. 

Unavoidable adverse effects are those resulting from managing the land for one 

resource at the expense of the use or condition of other resources. Many adverse 

effects can be reduced or mitigated by limiting the extent or duration of effects. The 

current Tongass Forest Plan is designed to mitigate potential adverse effects on 

forest resources and uses, especially through its mix of management prescriptions 
3 Environment and Effects

Introduction 3-2 Final EIS 

and Forest-wide standards and guidelines. Mitigation measures within standards 

and guidelines are specified for project activities to be implemented under the 

current Tongass Forest Plan. 

Short-term uses, and their effects, are those that occur annually or within the first 10 

years of Forest Plan implementation. Long-term productivity refers to the capability 

of the land and resources to continue producing goods and services for 50 years 

and beyond. Long-term and cumulative effects may be projected out 100 years or 

more, as needed, to fully analyze the potential consequences for particular 

resources. 

Irreversible and irretrievable resource commitments are normally not made at the 

programmatic level of a Forest Plan. Irreversible commitments are decisions 

affecting nonrenewable resources, such as soils, minerals, plant and animal 

species, and heritage resources. Such commitments of resources are considered 

irreversible because the resource has deteriorated to the point that renewal can 

occur only over a long period of time or at a great expense, or the resource has 

been destroyed or removed. While the application of LUDs allowing land-altering 

activities can indicate the potential for such commitments, the actual commitment to 

develop, use, or affect nonrenewable resources is made at the project level. The 

gradual decline in old-growth habitat may be considered an irreversible commitment. 

Irretrievable commitments represent opportunities foregone for the period during 

which resource use or production cannot be realized. These decisions are 

reversible, but the production opportunities foregone are irretrievable. An example 

of such commitments is the allocation of LUDs that do not allow timber harvest to 

areas containing suitable and accessible timberlands. For the time over which such 

allocations are made, the opportunity to obtain timber from those areas is foregone, 

thus irretrievable. Irreversible and irretrievable commitments are not identified, as 

such, in the discussions. 

For estimating the effects of alternatives at the programmatic Forest Plan level, the 

assumption is made that the kinds of resource management activities allowed under 

the LUDs will in fact occur to the extent necessary to achieve the goals and 

objectives of each alternative. The actual location, design, and extent of such 

activities are, however, not known at this time because that is a project-by-project 

decision. In many cases, the discussions refer to the potential for effects to occur, 

realizing that in many cases these are only estimates. 

The effects analysis is useful in comparing and evaluating alternatives, but should 

not be applied per se to any specific location within the Forest. Land management 

plans are tools for further agency planning and guide, but do not direct future 

management activities. The land management plan is a strategic plan that 

establishes a long-term management framework for the Tongass National Forest. 

Within that framework, specific projects and activities will be proposed, approved, 

and implemented depending on specific conditions, budgets, needs, proposals, and 

circumstances at that time. The plan can only speculate about the projects that may 

be proposed and budgeted and the events that may occur that will force changes in 

the projects and the effects of these projects. Thus, the effects presented here are 

comparative in nature. Specific effects that can be meaningfully measured and 

evaluated generally occur at the project and activity stage. 

A strong effort was made throughout the current Tongass Forest Plan development 

process to obtain and use the best available information to evaluate and compare 

the effects of alternatives. NEPA implementing regulations (40 CFR 1502.22) state 

that when “there is incomplete or unavailable information, the agency shall always 

make clear that such information is lacking.” This was done where appropriate. The 

NEPA requirement goes on to say that if the incomplete information “is essential to a 
Environment and Effects 3

Final EIS 3-3 Introduction 

reasoned choice among alternatives” then considerations, such as the cost of 

obtaining it, apply. The 1997 Tongass Forest Plan Revision Final EIS, the 2003 

SEIS, and this EIS, along with their planning records, will provide the Forest 

Supervisor and Regional Forester with the “essential” information needed to make a 

reasoned choice among alternatives. 

Cumulative Effects 

As noted above, cumulative effects result from the incremental effects of actions, 

when added to other past, present, and reasonably foreseeable future actions, 

regardless of what agency (federal or non-federal) or person undertakes such other 

actions. For this analysis, the region or study area considered for cumulative effects 

varied according to the resource being assessed. 

For most aquatic or watershed-related resources, the area within the proclaimed 

Forest boundary (approximately 17.87 million acres, including 1.09 million acres of 

non-National Forest System [NFS] lands) was used, as defined by the Value 

Comparison Unit (VCU) map (see below for more detail on VCUs and see the VCU 

map on the CD version of this EIS). VCUs generally correspond with watersheds so 

basing the analysis of cumulative effects on watershed boundaries is most relevant 

to aquatic and watershed-related resources. 

For wildlife and other terrestrial resources, all of Southeast Alaska from Yakutat Bay 

southeast to the southeastern end of Alaska (approximately 21.56 million acres, 

including 4.79 million acres of non-NFS lands) was used as the study area, although 

some analyses were based on the area within the Forest boundary, depending on 

the availability and quality of available information. The Southeast Alaska area 

includes all of Glacier Bay National Park and the State, Bureau of Land 

Management, and other lands in the vicinity of Haines and Skagway. Often Wildlife 

Analysis Areas (WAAs) were used to summarize information within these study 

areas (see below for more detail on WAAs and see the WAA map on the CD version 

of this EIS). In addition, biogeographic provinces and ecological subsections (see 

descriptions below) were also used to summarize cumulative effects information for 

wildlife and other terrestrial resources. 

For social and economic, recreation, and related human uses, all of Southeast 

Alaska and beyond, were given consideration for cumulative effects, especially 

regarding economic, market, and other factors. 

Cumulative effects analyses are presented throughout the effects sections. Many 

times, direct and indirect effects are presented in the context of past, present and 

future actions. For example, many of the analyses address past harvest and road 

construction on NFS lands along with future NFS harvest and road construction. 

These are cumulative effects analyses because they deal with past, present, and 

reasonably foreseeable actions on NFS lands. These are typically presented under 

Direct and Indirect Effects because it is logical to discuss the harvest and road 

construction plans along with the past harvest and road construction on the lands 

where the proposed action will take place. However, there are specific cumulative 

effects sections that reference these analyses and present additional analyses that 

take into account past, present, and future harvest and road construction on nonNFS lands when added to the NFS land harvest and road construction. 

Generally, for the physical and biological resources, the actions considered in 

assessing cumulative effects included the following: 

• Past, present, and future timber harvest and road construction on NFS lands; 
3 Environment and Effects

Introduction 3-4 Final EIS 

• Past, present, and future timber harvest on adjacent private, state, and Native 

corporation lands. (These usually represent more intensive harvest and road 

development than for NFS lands; however, consideration was given to the 

Alaska Forest Resources and Practices Act which is designed primarily to 

protect fish habitat and water quality and promote rapid reforestation); 

• Existing mining at Greens Creek on Admiralty Island and other existing sites, as 

well as possible future sites, including the proposed Kensington Mine at Berners 

Bay north of Juneau; 

• Electrical intertie and other utility corridor construction, including the Swan LakeLake Tyee Transmission Intertie project; 

• Regional transportation development as defined by the State Transportation 

Plan; 

• Growth in the cruise ship and guiding industries and general outdoor recreation. 

Development of fishing and other lodges; 

• Human settlements – expansion of cities like Juneau and Ketchikan. Also, 

recreational cabin development and land auctions by the State; and 

• Existing and limited future hydroelectric developments (e.g., Angoon 

hydroelectric project). 

Geographic Information System Database and 

Quantification for this EIS 

The Forest Service developed a computerized geographic information system (GIS) 

database for the revision of the Tongass Forest Plan, and that system continues to 

be improved upon and used. This system makes it possible to conduct spatial 

analysis of alternatives and effects, and to rapidly display resource information in 

map format. The GIS is a very large database, containing information on many of 

the resources of the Forest. Much of the data consist of map “layers,” each 

representing a particular resource or attribute (such as forest type, soil type, or 

recreation places). Numerical data can also be stored, displayed, and analyzed. 

Computer technology and capability continues to improve and the Forest GIS 

program, especially at the project level, reflects such growth. Additional information, 

as well as improved information, is now available for many resource areas. This EIS 

takes advantage of the new technology capability and information. This EIS 

validated and updated various GIS layers used in the 1997 Forest Plan Revision 

Final EIS and the 2003 SEIS. This existing condition information is what has been 

used as a baseline for the EIS and Alternative 5, No Action. 

The baseline numbers used in Alternative 5 do not always match the numbers for 

Alternative 11 of the 1997 Forest Plan Revision Final EIS, which is the 1997 

alternative that is most like the current Forest Plan. This is primarily because of 

ongoing management of the Tongass National Forest. Examples include changes 

in land ownership, changes in resource conditions resulting from timber harvest and 

road construction, and nonsignificant amendments to the 1997 Forest Plan Revision 

Final EIS. In addition, the use of newer computer mapping and measurement 

techniques that are more accurate than earlier methods also affects the numbers. 

In general, the relative differences among the 1997 Forest Plan Revision Final EISgenerated numbers, the 2003 SEIS-generated numbers, and the baseline numbers 

used in this EIS are small, and do not affect the analysis relationships among these 

documents. 
Environment and Effects 3

Final EIS 3-5 Introduction 

It should be noted that in some cases where the acreages are measured that 

depend on overlaying of multiple coverages, the acreage measurements for 

individual categories sometimes need to be adjusted to account for the fact that 

coverages do not always line up exactly in places where they should (e.g., along 

property boundaries, saltwater shorelines, lake edges). Very slight misalignment of 

the coverages can result in polygon slivers between the coverages, which can 

produce acreage differences initially. These differences can amount to tens or 

hundreds of acres or more, especially because we are dealing with such a large 

area (i.e., 17 million acres). However, on a percentage basis, these slivers and the 

adjustments that are necessary are insignificant. 

It should also be noted that the figures presented are generally rounded to the 

nearest whole acre, whole mile, or whole percent. No attempt has been made to 

adjust the numbers to force the sums of rounded numbers to equal the expected 

totals. Therefore, the sum of rounded individual numbers will often be one digit 

higher or lower than the expected sum. The sums that are presented are the sums 

of the unrounded numbers. 

Land Use Designation Groupings 

For many resources, the effects and the differences in effects among the 

alternatives are best identified through the LUD allocations. While each LUD has a 

different purpose and management emphasis, many are similar in the kinds of 

effects they would potentially create. Based on this concept, and in order to simplify 

the identification of effects, the LUDs have been grouped into four categories: 

Wilderness, Natural Setting, Moderate Development, and Intensive Development. 

For some analyses, the LUDs are grouped into two categories: Wilderness and 

Natural Setting LUDs make up the non-development LUDs and Moderate and 

Intensive Development LUDs make up the development LUD category. Note that 

the Minerals and Transportation and Utility System LUDs are overlay LUDs and are 

managed according to the underlying LUD until such time that development is 

approved, if at all. Therefore, acreages in this EIS generally reflect the underlying 

LUD acreages. Table 3.1-1 displays these LUD groupings. 

Land Divisions 

The land area of the Tongass National Forest has been divided in several different 

ways to describe the different resources and how they are affected by Forest Plan 

alternatives. These divisions vary by resource because the relationship of each 

resource to geographic conditions and zones also varies. Several of these divisions 

are described briefly here. 

These are seven large land areas that are distinguished by differences in ecological 

processes. They are defined by a combination of climatic and geographic features. 

Geographic provinces are used in the evaluation of Research Natural Areas and 

Wild and Scenic Rivers. See the Research Natural Areas section of the 1997 Forest 

Plan Revision Final EIS for a description of each province.

Biogeographic provinces are areas within which certain kinds of plants and animals 

tend to occur together. They are defined by a combination of similarity in species, 

patterns of distribution of species, and natural characteristics or barriers. Twentyone biogeographic provinces occur on the Tongass. They are used in the 

Biodiversity and Wildlife sections and described in the Biodiversity section of this 

chapter. 

Geographic 

Provinces 

Biogeographic 

Provinces 
3 Environment and Effects

Introduction 3-6 Final EIS 

Table 3.1-1 

Land Use Designation Groupings Used to Discuss Effects 

LUD Group Land Use Designation 

Non-development LUDs 

Wilderness LUD Group Wilderness 

 Wilderness National Monument 

 Nonwilderness National Monument 

Natural Setting LUD Group LUD II 

Remote Recreation 

Semi-Remote Recreation 

Old-Growth Habitat 

Enacted Municipal Watershed 

Research Natural Area1 

Special Interest Area1

Wild River1

Scenic River 

Recreational River 

Development LUDs 

Moderate Development LUD Group Experimental Forest 

 Scenic Viewshed 

 Modified Landscape 

Intensive Development LUD Group Timber production 

Overlay LUDs2 

Overlay LUD Group Minerals 

 Transportation and Utility Systems 

1 These three LUDs function as overlay LUDs (see footnote 2) when they occur within Wilderness, 

Wilderness National Monument, or LUD II areas. 2 The Minerals and Transportation and Utility Systems (TUS) LUDs are overlay LUDs. Areas 

allocated to these LUDs are managed according to the underlying LUD until such time that mineral 

or transportation or utility development is approved, if at all. Generally, acreages in this EIS do not 

include the Minerals or TUS LUDs, but rather the underlying LUD. 

Ecological sections and subsections are two classification levels within a 

hierarchical system for subdividing ecosystems according to the National 

Hierarchical Framework of Ecological Units (see Biodiversity section of this chapter). 

The framework consists of eight nested mapping levels that serve a variety of 

purposes. Within the hierarchy, ecological sections characterize medium to large 

ecosystems (on the order of 1,000 square miles) and ecological subsections 

characterize mid-sized ecosystems (10 to 1,000 square miles). Fourteen ecological 

sections and 73 ecological subsections occur on the Tongass. 

Value Comparison Units (VCUs) are distinct geographic areas, roughly analogous to 

watersheds, each encompassing a drainage basin containing one or more large 

stream systems. The boundaries usually follow watershed divides. VCUs were 

used for the 1979 Tongass Forest Plan and have since been updated. The Forest 

currently has about 945 VCUs averaging 18,000 acres in size. They are used to 

describe the locations of specific resources on the Forest. A map of the VCUs on 

the Tongass is provided on the CD version of this EIS. 

Wildlife Analysis Areas (WAAs) are land divisions used by the Alaska Department of 

Fish and Game (ADF&G). Approximately 190 WAAs apply to the Tongass National 

Forest; they average slightly less than 90,000 acres in size. In general, WAA 

boundaries correspond with VCU boundaries and they typically include three to 

eight VCUs (averaging just under five). They are used in the Subsistence and 

Wildlife sections. A map of the WAAs on the Tongass is provided on the CD version 

of this EIS. 

Ecological 

Sections and 

Subsections 

Value 

Comparison 

Units 

Wildlife Analysis 

Areas 
Environment and Effects 3

Final EIS 3-7 Introduction 

General Forest Description 

A brief description of the physical, biological, and socioeconomic settings of the 

Tongass National Forest is presented in this section. Chapter 1 and the alternative 

maps include a vicinity map. 

Physical Setting 

The mainland and many of the islands of Southeast Alaska are mountainous, often 

rising abruptly from sea level to several thousand feet. Elevations of forested areas 

extend up to approximately 3,000 feet in the southern sections of the Tongass 

National Forest and up to 2,500 feet further north. The mountain valleys provide 

reservoirs for huge ice fields and glaciers, located primarily on the mainland. 

More than 1 million years ago, all but the highest mountain peaks and some outer 

coastal areas in Southeast Alaska were covered by ice. The great erosional powers 

of these vast expanses of ice molded and shaped the landscape as the glaciers 

moved downhill under their own weight, carving the bedrock below them. When the 

ice receded and uncovered the land, the more resistant mineral-rich rocks 

remained, revealing a network of islands dissected by numerous streams, U-shaped 

valleys, and fiords. This modification by glaciers gives Southeast Alaska’s 

landscape its unique character. 

The configuration of the coastline, the warm Japanese ocean current, and the high 

coastal mountains provide the factors necessary to produce abundant rainfall. The 

annual precipitation of Southeast Alaska averages more than 100 inches 

throughout. Precipitation is highest in the southern areas and decreases as one 

moves north. At higher elevations, more than 200 inches of snow may fall annually, 

perpetuating the existing ice fields and glaciers. Storms and moderate to heavy 

precipitation occur year-round, but most commonly from September through 

November. The abundant moisture feeds numerous streams, rivers, and lakes that 

dot the landscape. 

Southeast Alaska has a maritime climate, resulting from the moderating influence of 

the Pacific Ocean. In the summer, this provides a cooling influence, while in winter, 

temperatures are warmer than would be expected for these latitudes. Normal 

temperatures range from mid-40 degrees Fahrenheit (°F) to mid-60 °F in the 

summer, and from the high teens to the low-40s in the winter. During the warmer 

months, temperatures are highest inland and lowest along the coasts, while in the 

colder months, the reverse is true. 

Biological Setting 

The coastal forest of Southeast Alaska is part of the cool, temperate rain forest that 

extends along the Pacific coast from Northern California to Cook Inlet in Alaska. 

Most of the Forest is composed of old-growth conifers, primarily western hemlock 

and Sitka spruce, with a scattering of mountain hemlock, western redcedar (in the 

south), and Alaska yellow-cedar. Red alder is common along streams, beach 

fringes, and on soils recently disturbed by management activities and landslides. 

Black cottonwood grows on the floodplains of major rivers and recently deglaciated 

areas. 

Blueberry, huckleberry, Sitka alder, Devil’s club, and salal are common shrubs in the 

Forest. The Forest floor is composed of plants, such as deerheart, dogwood, single 

delight, and skunk cabbage. Because of the high rainfall and resulting high 
3 Environment and Effects

Introduction 3-8 Final EIS 

humidity, mosses grow in great profusion on the ground, on fallen logs, on the lower 

branches of trees, and in forest openings. 

Grass-sedge meadows usually lie at low elevations, often along the coast. Stands 

of willows border many of the stream channels. Muskeg (bog plant) communities, 

dominated by sphagnum mosses and sedges, occur throughout the Forest. 

The alpine zone usually lies above 2,500 to 3,000 feet. It occupies the area above 

the coastal forest and is separated from the Forest by a subalpine or transition zone. 

Resident plants have adapted to snowpack and wind abrasion by evolving lowgrowth forms. Low, mat-forming vegetation covers most of the area, with cushionlike plants occupying crevices on exposed rock outcrops and talus slopes. 

The forests, shorelines, streams, and rivers of Southeast Alaska provide habitat for 

over 300 species of birds and mammals, including game and non-game animals, 

such as brown and black bear, Sitka black-tailed deer, moose, wolf, mountain goat, 

beaver, otter, and marten. The coastline provides ideal habitat for a large 

population of bald eagles, and wetlands provide nesting habitat for many waterfowl. 

A highly productive marine environment includes an abundance of marine 

mammals, halibut, herring, and hundreds of shellfish. Both resident and 

anadromous fish are found within and adjacent to the Forest. 

Socioeconomic Setting 

Southeast Alaska’s communities and individuals make up a variety of cultures. The 

abundant resources of the forests and waters have provided food, shelter, and 

livelihood for its peoples for thousands of years. The first inhabitants of the area, 

the Tlingit and Haida, adapted well to the coastal environment and developed a rich 

culture. The numerous waterways allowed for mobility, which aided in expanding 

trade and gathering food. 

In the 1700s, Russian exploration began in Alaska. The fur trade, primarily sea otter 

pelts, was the main force driving colonization. When most of the sea otter 

populations were depleted, the fur industry declined and Russia lost interest in its 

North American colony. Alaska was sold to the United States in 1867. 

Colonization continued under U.S. ownership, and new industries developed. In the 

late 1800s, commercial fish canning became an important part of the economy of 

Southeast Alaska. During that same period, the discovery of gold brought 

thousands of miners to the area, and many were followed by their families. The 

most important of the early gold discoveries occurred in Juneau. In the early 1900s, 

the Depression brought a decline in mining employment, and the impact of World 

War II resulted in the closures of the last remaining mines. 

The timber resource was used by the earliest inhabitants in a variety of ways. The 

Russians harvested timber for building ships and structures, but commercial timber 

harvest was not developed until the 1900s. In the earlier part of the century, small 

timber mills operated in a few communities. During the 1950s, two large-scale pulp 

mills were developed in Ketchikan and Sitka, and the timber industry became a 

major economic component of Southeast Alaska’s economy. 

In the 1950s, Alaska focused its attention on statehood, and on January 3, 1959, 

became the 49th state of the United States. This resulted in an increase in 

government employment and, coupled with the growth of the timber industry, a 

gradual shift towards a more diversified economy, with less dependence on 

nonrenewable resources. 
Environment and Effects 3

Final EIS 3-9 Introduction 

More than 70,000 people live in the towns, communities, and villages of Southeast 

Alaska. Most of the region’s population is concentrated in a few communities, the 

largest being Juneau, Ketchikan, Sitka, and Petersburg. Services, state and local 

government, and retail trade were the largest economic sectors by employment in 

Southeast Alaska in 2005, accounting for 28, 21, and 12 percent of total 

employment, respectively. Employment in natural resource-based industries 

remains important in many of the region’s communities. Tourism, which has 

increased in recent years, provides another important source of regional 

employment and income. Many small, rural communities continue to depend 

primarily on fishing, timber production, and subsistence uses. 

Organization of Chapter 3 

The remainder of Chapter 3 is divided into three parts. First, the resources that 

make up the physical and biological environment are described and the effects of 

the alternatives are analyzed. This part sets the stage for the next part⎯the 

evaluation of human uses and land management. Finally, both of these parts set 

the stage for the final part⎯the economic and social environment. The focus is on 

significant effects, with the analysis centered on the public issues related to the 

Forest Plan amendment. 
3 Environment and Effects

Introduction 3-10 Final EIS 

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 Environment and Effects 3 

Final EIS 3-11 Climate and Air 

Physical and Biological Environment 

Climate and Air 

Affected Environment.....................................................................................3-11

Climate........................................................................................................3-11

Climate Change ..........................................................................................3-11

Air Quality ...................................................................................................3-14

Environmental Consequences.......................................................................3-16

Direct and Indirect Effects...........................................................................3-16

Cumulative Effects......................................................................................3-17

Affected Environment 

The Tongass National Forest occupies a series of islands and a narrow strip of the 

mainland between the Pacific Ocean and the crest of the coastal mountains. The 

configuration of the coastline, the warm Japanese ocean current, and the high 

coastal mountains combine to produce a cool, wet environment. Precipitation at sea 

level in Southeast Alaska ranges from 30 inches per year at Skagway to 220 inches 

per year at Little Port Walter. Precipitation increases with elevation. It is estimated 

that the average annual precipitation may be as high as 400 inches on the 

mountains of southern Baranof Island and about 260 inches over the Juneau 

Icefield. Southeast Alaska has complete cloud cover approximately 85 percent of 

the year. Snowfall varies according to elevation and distance inland from the coast. 

October is generally the wettest month. May through July are, on average, the drier 

months. The Pacific maritime influence holds the daily and seasonal temperatures 

within a narrow range. Temperatures average 32 degrees Fahrenheit (°F) in the 

winter and 60°F in the summer. During the warmer months, temperatures are 

highest inland and lowest along the coasts, while in the colder months, the reverse 

is true. Storms and moderate to heavy precipitation occur year-round, but most 

commonly from September through November. The abundant moisture supports an 

extensive temperate rain forest and feeds numerous streams, rivers, and lakes, 

which in turn provide valuable fish habitat. 

Southeast Alaska has had considerable year-to-year and decade-to-decade 

variability in its weather, associated with large-scale shifts in ocean temperatures, 

salinity levels, and ice conditions. Even with these short-term variations in weather, 

some longer-term trends are evident. Southeast Alaska’s climate has shown a 

strong warming trend since the middle of the 19th century (the end of the little ice 

age), as has much of the northern hemisphere. This trend accelerated in the late 

1970s due to cyclical shift of the Pacific decadal oscillation (Parson et al. 2001). In 

addition to this natural change, anthropogenic change (human-caused change) has 

accelerated climate changes during the last several decades (Intergovernment 

Panel on Climate Change [IPCC] 2007). 

Changes to the climate in Southeast Alaska have already resulted in changes to 

ecosystem processes and services on the Tongass National Forest. The number of 

days with gale-force winds has more than doubled since 1950 (U.S. Global Change 

Research Program [USGCRP] 2003). Juday et al. (1998) state that as of their 

report, the increased frequency of storms had not corresponded to an increase in 

large-scale blowdowns in Southeast Alaska, although the authors state that they do 

Climate 

Climate Change 
3 Environment and Effects

Climate and Air 3-12 Final EIS

not know if it resulted in an increase in canopy gap formation. The 2006 Forest 

Health report noted very little blowdown in aerial and ground surveys (USDA Forest 

Service and ADNR 2007) 

The Muir Glacier has retreated more than 9 miles since 1941, exposing large areas 

of bare rock that are starting to colonize with alder and willow. Warmer summers 

have led to longer growing seasons for trees and other vegetation. Warmer winters 

have meant more insects survive the winter, triggering insect outbreaks that affected 

trees on over 300,000 acres of forest in Southeast Alaska (including all ownerships) 

during the 1990s (USGCRP 2003). The warming trend has also reduced snowpack 

in low-elevation areas, which may contribute to ongoing yellow-cedar decline 

affecting over 500,000 acres in Southeast Alaska (Hennon and Shaw 1997). Drier 

summers may have contributed to the number and duration of low stream flow 

episodes, which can adversely affect salmon, and the increase in the amount of 

precipitation falling as rain instead of snow since the 1970s has reduced the 

frequency of low- and moderate-elevation avalanches, allowing mountain hemlock to 

colonize some alpine areas (Parson et al. 2001). 

There are several models that have attempted to predict future trends in Alaska’s 

climate. Most models predict warmer, wetter weather for Alaska and they generally 

agree that rainfall will increase and snowfall will decrease at lower elevations in 

Southeast Alaska over the next 50 to 100 years (Bonsal and Prowse 2006). 

However, these models do not always agree on the extent of climate change in 

Southeast Alaska. For example, two models were compared in a study by Parson et 

al. (2001), one from the Canadian Climate Center and the other from the Hadley 

Center. Both predict rising temperatures and a 10 percent decrease in summer 

precipitation in some portions of Southeast Alaska, but the models differ in 

projecting the areas affected. The Canadian scenario predicts that drier summer 

weather will extend across all of Southeast Alaska, while the Hadley scenario 

predicts that these effects will be confined to the extreme southeast. Both models 

predict the expansion of forests into higher elevation areas, as well as increased 

insect problems and decreased soil moisture, due to increased evaporation during 

warmer, drier summer weather. These factors may lead to an increase in fire 

frequency and adversely affect fish. These models are not specific to Southeast 

Alaska; therefore, the predicted effects may not be relevant for Southeast Alaska. 

While the 2007 report by the Intergovernmental Panel on Climate Change (IPCC 

2007) predicts higher stream runoff at the higher latitudes, as well an increase in 

heavy precipitation events, a decrease in glacier size, and a slight increase in tree 

growth, it also concludes that not all areas will be effected the same and limits 

forecasts to large regions, such as western North America. 

A scientific panel on climate change convened by the City and Borough of Juneau 

(Kelly et al. 2007) has made some site-specific predictions based on a review of 

several models. They concluded that the Juneau area will see overall warmer and 

wetter weather, particularly in fall and winter. The Juneau Icefield will continue to 

retreat. Global sea level will continue to rise as a result of the melting of glaciers 

and ice sheets and the warming of ocean waters (thermal expansion). Over the next 

century, global sea level is projected to rise 0.3 foot to 3.0 feet. In the City and 

Borough of Juneau, however, the land surface is rising as a result of the loss of 

glacial ice (isostatic rebound), and the rate of uplift is greater than the projected rate 

of global sea level rise. Over the next century, the relative sea level in the Juneau 

area likely will decrease between 1.0 and 3.6 feet. 
 Environment and Effects 3 

Final EIS 3-13 Climate and Air 

Carbon Sequestration 

Carbon, primarily in the form of carbon dioxide, is one of the major greenhouse 

gases being released into the atmosphere (McPherson and Simpson 1999). The 

global carbon cycle involves the earth’s atmosphere, fossil fuels, the oceans, and 

the vegetation and soils of the earth’s terrestrial ecosystems. Gases that make up 

the earth’s atmosphere, such as carbon dioxide, methane, nitrous oxide, and water 

molecules, trap the sun’s heat, creating a natural “greenhouse effect” that makes life 

on earth possible (McPherson and Simpson 1999). These gases are released into, 

and removed from, the atmosphere by a variety of natural sources and sinks. 

The Tongass National Forest, like most forests, is considered a carbon sink, storing 

more carbon in its systems than is released by natural processes. As such, a critical 

ecosystem service sustained by the forest is carbon sequestration, or removal of 

carbon dioxide from the atmosphere and keeping that carbon inactive by storing it in 

biomass (live and dead plant structures, primarily) and soil organic matter. D’Amore 

and Lynn (2002) believed that previous methods may have underestimated the 

amount of carbon stored in Southeast Alaska. Subsequently, Smith et al. (2004a) 

estimated that mature hemlock-Sitka spruce forests of the Pacific Northwest store 

184.4 tons of carbon per acre. Leighty et al. (2006) estimate that the Tongass 

contains approximately 2.8 billion metric tons of carbon in both above and below 

ground living and dead material (an estimated 83,500,000 billion metric tons of 

carbon are stored world-wide, primarily in the oceans and marine sediment, based 

on United Nations estimates). Leighty et al. (2006) also estimate that between 6.4 

and 17.2 million metric tons (0.2 to 0.6 percent) of stored carbon has been lost on 

the Tongass since timber harvest began in the early part of the 20th century. For 

comparison, approximately 4.5 million metric tons of carbon was released every day 

to produce electric power in the United States in 2005 (DOE 2006). 

Generally, the capacity for a system to sequester and store carbon depends on the 

location, age, and species mix of the forest (Birdsey et al. 1993). Newly established 

forests accumulate carbon rapidly for many years, slowing as trees mature, growth 

slows, and decaying material accumulates. However, the cool conditions on the 

Tongass inhibit decomposition, drastically slowing biomass breakdown and carbon 

release. Decaying plant matter is incorporated into the system’s soil profile, where it 

accumulates and may reside indefinitely. As a result, old forests generally store 

considerable amounts of carbon on the forest floor, approximately 70 tons per acre 

in hemlock-Sitka spruce ecosystems (Smith et al. 2004a). Janisch and Harmon 

(2002) suggest that it can take more than 200 years following timber harvest for 

forests to reach equilibrium, the point where carbon released from decay equals 

carbon stored in the system. 

Interest in enhancing ecosystem carbon sequestration and storage has intensified 

recently, as concerns about how to mitigate climate change have increased. This 

question of how active ecosystem management may contribute to, or detract from, 

the mitigation effort is being explored, with varying results. A few studies have 

shown that management of some forests with certain parameters being met, such as 

fertilization, may result in heightened capacity for carbon sequestration and storage 

(Schroeder 1991, Binkley et al. 1997). A study in the eastern United States found 

that thinning a 50-year-old stand from below (removing the smallest trees) resulted 

in more stored carbon after 25 years than resulted from thinning stands from the 

middle or from above (Hoover and Stout 2007). A recent Pacific Northwest study 

(Perez-Garcia et al. 2005) concluded that the use of wood resulted in “significant 

atmospheric carbon reductions by displacing more fossil fuel-intensive products in 

housing construction.” They estimate that a rotation of 80 years would sequester 

the most carbon. Other studies, particularly two with application to Southeast 

Alaskan ecosystems (Harmon et al. 1990, Leighty et al. 2006), indicate that the 
3 Environment and Effects

Climate and Air 3-14 Final EIS

Tongass would generate a net loss of carbon to the atmosphere if active harvest of 

old growth is pursued. Ultimately, a net loss or gain of carbon in active management 

situations depends on use of harvested timber, the substitute material available, the 

amount of carbon emitted in harvesting activities, and the amount of carbon emitted 

via decomposition of on-site wood waste and soil organic matter losses. If the 

emissions are less than the carbon stored in utilized wood, and if the system can 

rapidly replace losses from decomposition through tree growth, the activity may yield 

a net gain of stored carbon. Whether active management of old-growth forests on 

the Tongass results in a net gain or loss of carbon is currently unknown. 

In addition to the effects of timber management, climate change may also affect 

carbon sequestration in Southeast Alaska. D’Amore and Lynn (2002) note that 

numerous studies have shown that carbon stored in soils, including peatlands, may 

be released to the atmosphere in the form of carbon dioxide or methane as climate 

warms and that dissolved carbon may be transported to streams and the ocean due 

to increased rainfall. If warmer, wetter conditions occur, climate change could result 

in additional carbon losses. 

The air quality of Southeast Alaska and the Tongass National Forest is generally 

good. The prevalent airflow from the Pacific Ocean, the relatively small amount of 

industrial development in Southeast Alaska, the lack of large population centers, the 

absence of slash burning following harvest, and environmental regulations all 

contribute to maintaining clean air. Forest activities have historically had little direct 

effect on air quality on the Tongass (USDA Forest Service 1997a). However, cruise 

ship emissions in certain locations and trans-Pacific pollutants such as persistent 

semi-volatile organic pollutants and greenhouse gases are a growing concern. 

Air quality and sources of air pollution on the Tongass are described in Air Quality 

Monitoring on the Tongass National Forest: Methods and Baselines Using Lichens 

(Geiser et al. 1994) and Air Quality Biomonitoring with Lichens-Tongass National 

Forest (Dillman 2007). The Tongass has 127 permanent lichen biomonitoring plots 

that can be used to detect possible trends in the elemental content of lichen tissue 

and changes in lichen communities over time. Lichen biomonitoring plots are 

distributed across the Forest, including all but one Wilderness. Lichens serve as 

dynamically representative samples of the environmental conditions in which they 

are growing. Elements and compounds in the air are absorbed by lichens along with 

moisture from the surrounding environment and become concentrated in the lichen 

tissue. Roughly 10 percent of the biomonitoring plots on the Tongass were recently 

re-visited, all in wilderness areas. Little or no change in the elemental content of the 

lichens was detected between the first monitoring effort (Geiser et al. 1994) and the 

recent one (a span of about 15 years). Provisional threshold levels were generated 

from the most pristine areas on the Tongass for 27 elements, including sulfur and 

nitrogen, in four target lichen species (Dillman 2007). A provisional threshold level is 

the level of a pollutant of interest per lichen species that can be expected at a clean 

air site on the Tongass (expressed in parts per million, or ppm). Nearly half of the 

127 biomonitoring plots are elevated above the threshold level in one or more 

elements due to natural or anthropogenic sources. Natural sources include the 

mineral content of the local rock and soil and salt spray from the ocean (a major 

factor in sites near the coast). Anthropogenic sources include dust from roads (the 

most comment human-cause source) as well as wood stoves, fossil fuels 

(specifically near Juneau), and mining (specifically near the Greens Creek Mine). 

Monitoring plans call for lichen biomonitoring to be done on a 5 to 10 year interval to 

better detect pollution trends, especially for trans-Pacific sources of nitrogen. 

The Tongass National Forest partnered with the National Park Service Western 

Airborne Contaminants Assessment Program (WACAP), which quantifies regional 

and trans-Pacific semi-volatile and persistent organic pollutants in lichens, vascular 

Air Quality 
 Environment and Effects 3 

Final EIS 3-15 Climate and Air 

plants, and other organisms. Results from the WACAP samples collected from the 

Stikine-LeConte Wilderness are being analyzed by the National Park Service. An 

aerosol sampler near Petersburg was installed in 2004 as part of the Interagency 

Monitoring of Protected Visual Environment (IMPROVE) program. This is the only 

IMPROVE site in Southeast Alaska, with the next nearest station in Tuxedni 

Wilderness near Anchorage. Data from the IMPROVE site will be collected for 5 

years to observe trends and to determine regional, state, and national significance. 

Visual inspections of cruise ship emissions by rangers in Tracy Arm/Fords Terror 

Wilderness occur during the summer tourist season as part of an agreement with the 

State using U.S. Environmental Protection Agency (EPA)-approved methods. Also, 

the Tongass is working with the National Park Service in the Southeast Alaska 

Network and Forest Service Air Resource Program in Region 6 to coordinate a 

Southeast Alaska cruise ship emissions monitoring effort using passive air samplers 

in remote locations. 

Juneau Air Quality 

Juneau’s Mendenhall Valley is the only area in Southeast Alaska that is known to 

have exceeded National Ambient Air Quality Standards. The EPA listed Juneau City 

and Borough as a non-attainment area for particulate matter less than or equal to 10 

micrometers in 1990. The area is classified as Moderate for this component of air 

quality, with an average daily rating of 110 out of a maximum of 500. Monitoring 

data indicate that air quality in Juneau has met state and federal ambient air quality 

standards in recent years. No state or federal ambient air quality standards have 

been exceeded since 1997. The last time particulate matter standards were 

exceeded in Juneau was in 1993. The State and EPA are currently considering redesignating the Juneau area as a maintenance area, an area in transition between 

non-attainment and attainment (Alaska Department of Environmental Conservation 

[ADEC] 2007). The ADEC has conducted ambient air monitoring in other locations 

in Southeast Alaska. These studies indicate these areas are within national 

standards for the pollutants monitored. 

Lichen tissues were collected on Mt. Roberts in the downtown Juneau area at five 

different elevations as part of the Tongass lichen biomonitoring program and in 

collaboration with the State. The lichen tissues analyzed were elevated above 

provisional threshold levels in all five plots in three or more elements including 

sulfur, nitrogen, and heavy metals. Lichens from the plot at 175 feet above sea level 

had the greatest number of elements above threshold (12), indicating that the 

sources are probably local and anthropogenic (Dillman 2007). 

Sources of Air Pollution 

There are 36 stationary sources of air pollution in Southeast Alaska that require air 

quality control permits. These include diesel power plants, asphalt plants, 

incinerators, mining facilities, and other facilities. Some of these sources operate 

intermittently (e.g., back-up power plants may operate during power failures or 

during peak demand periods, and asphalt plants may operate seasonally), and 

others may be operating at full capacity (e.g., Greens Creek mine). 

Other sources of air pollution in Southeast Alaska include mobile sources (such as 

cars, trucks, boats, cruise ships, airplanes, and helicopters) and area sources (such 

as home furnaces, wood stoves, and open burning). Under certain weather 

conditions, wildfires in Canada can affect air quality and visibility (i.e., regional haze) 

in parts of Southeast Alaska. The State issued an air quality advisory in July of 

2004 due to extensive wildfires in western Canada. 
3 Environment and Effects

Climate and Air 3-16 Final EIS

Cruise ship traffic has greatly increased in Southeast Alaska over the last several 

years. More than 600 cruise ship visits occurred in Juneau during 2006, with an 

annual average number of visits of 591 ships for the 2003 to 2006 seasons. Cruise 

ship emission monitoring in Juneau by ADEC indicates that ship emissions are well 

within federal and state standards. The Mt. Roberts biomonitoring plots contain 

lichens that were elevated above threshold levels in three or more elements. 

Possible sources of the elevated elements are urbanization of downtown Juneau, 

past mining activities, and cruise ship emissions. 

Cruise ship traffic in Tracy Arm creates a particular concern for air quality in 

Wilderness. Tracy Arm/Fords Terror Wilderness received more than 1,000 cruise 

ship visits between 2003 and 2006. Tracy Arm is less than a mile wide (on average) 

and is surrounded by high mountains. Cruise ship emissions may linger above the 

fiord for hours. The emissions are most heavily concentrated in upper Tracy Arm, 

where vessels stop near the South Sawyer Glacier for 1 to 4 hours (depending on 

ice conditions). Ship emissions often increase because of rapid changes in engine 

loading necessary for the ship to maneuver through ice and turn around. The Forest 

Service has received an increased number of public complaints concerning air 

quality within the Tracy Arm-Fords Terror Wilderness. In an effort to better address 

the air quality concerns in the Wilderness, the Forest Service and ADEC enters into 

a Memorandum of Understanding each year to train Forest Service wilderness 

rangers to visually monitor cruise ship emissions with EPA approved standards. 

ADEC annually reviews the visible emission observations and takes action on any 

that exceed the State Marine Vessel Emission standard (18 AAC 50.070). 

Two lichen biomonitoring plots were established in 2003 near the entrance of Tracy 

Arm, where target lichen species are found. Results indicate no elements were 

elevated above threshold from this area of Tracy Arm (Dillman 2007). Future efforts 

to monitor air quality in the wilderness may utilize passive air samplers that measure 

SO2, NHO3, NH3, and NOX closer to where the cruise ships linger. 

Environmental Consequences 

Air Quality 

The expected direct effects on air quality from forest management activities are 

temporary and limited in nature, resulting from dust and vehicular emissions from 

logging operations, administrative and harvest-related use of Forest roads, mineral 

development, and smoke from a limited prescribed fire program. None of the 

alternatives includes broadcast burning of slash following harvest. Alternatives 1, 2, 

3, 6, 5, 4, and 7 would result in progressively more harvest, road construction, 

harvest-related vehicle use, and wood processing, as well as more emissions. No 

significant adverse effects on air quality are anticipated from these activities under 

any of the alternatives. 

Indirect effects on air quality can result from the use of trees harvested from the 

Tongass National Forest, such as in the operation of industrial processing sites and 

firewood burning, as well as emissions from private vehicles using Forest unpaved 

roads. These indirect effects on air quality can be aesthetically displeasing or have 

potential health risks to both humans and the Forest. EPA and ADEC have 

regulatory responsibility, under the Clean Air Act, for air quality related to these 

kinds of sources. The enforcement of the applicable regulations by these agencies 

is anticipated to keep any potential adverse effects within the standards for air 

quality; therefore, no significant indirect effects from the uses of the Tongass 

National Forest should occur. 

Direct and 

Indirect Effects 
 Environment and Effects 3 

Final EIS 3-17 Climate and Air 

Carbon Sequestration 

Estimating the effects of the proposed alternatives on carbon sequestration is 

complex. There are many factors that affect sequestration and storage; some 

components of an alternative contribute to a net removal of carbon, while some 

components offset those gains. Further, sequestration and carbon release happen 

at different time scales; therefore, while an activity may result in an immediate loss 

of carbon, over time, the net balance may reach zero or result in a net gain of 

storage. 

It is generally assumed that old-growth forests considered for harvest in this analysis 

are currently in a “steady-state,” meaning no net loss or gain of carbon. These 

systems are simply maintaining their storage capacity. Alternatives that propose 

less harvest, especially Alternatives 1 and 2, would allow this process to continue 

throughout most of the Tongass. In addition, much of the wood in harvested areas 

would be left in the Forest because there is no market for low-quality logs. Much of 

this wood, and the carbon it contains, would remain on the site as large woody 

debris for a long period of time under Alternatives 1 and 2. 

Alternatives that harvest more old-growth forest have the potential to either increase 

or decrease the amount of stored carbon, depending on the time scale of 

consideration, how much of the wood is removed from the Forest for utilization, how 

the wood is used, and how much carbon is released in cutting, yarding, transporting, 

and processing the wood and in soil carbon and woody debris decomposition. 

Alternatives 4 and 7 have the potential to harvest the most wood and would convert 

both the saw timber and much of the utility wood into lumber and other building 

materials, such as medium density fiberboard (MDF board), assuming facilities to 

produce MDF board are built. This material would continue to store the 

sequestrated carbon for a relatively long period of time (perhaps 75 years), although 

this storage may be offset by harvest emissions and carbon released by on-site 

decomposition. If, on the other hand, the low-value logs are used to fuel bio-energy 

plants, carbon storage would be reduced. New stands would be regenerated and, in 

time, commercially thinned; these thinning activities may lead to a net gain or a net 

release of carbon as well, depending on how the thinning is conducted, how the 

products are used, and how much carbon is released during harvest, transportation, 

and processing. Alternatives 3, 5, and 6 are expected to be intermediate in their 

effects relative to Alternatives 4 and 7. 

All alternatives include standards and guidelines that protect soils, such as limits on 

harvest on steep slopes, limits on roads built across steep slopes, and on soil 

disturbance. These measures would help retain carbon stored as organic material 

in the soil. Unlike many areas of the country, broadcast burning to reduce slash is 

not practiced on the Tongass; therefore, much more of carbon stored on the forest 

floor and in the upper layers of soil is retained compared to sites that are broadcast 

burned.

Cumulative effects on air quality include harvest-related emissions from state and 

private land, vehicle and maritime emissions, permitted uses such as community 

incinerators, industrial operations, cruise ship emissions, and electricity generation. 

If plans for hydropower production and transmission lines linking communities are 

implemented, such as the Swan Lake-Lake Tyee project scheduled for completion in 

2010, long-term reductions in both air pollution and carbon emissions could result 

because many communities would no longer rely on diesel generators. The Alaskan 

Energy Authority estimates that the Swan Lake-Lake Tyee intertie alone would 

reduce carbon dioxide emissions by approximately 486,000 tons and carbon 

monoxide by 3,150 tons by 2046 (comment letter submitted April 30, 2007). Most of 

the logs harvested on private land are expected to be exported; therefore, little 

Cumulative 

Effects 
3 Environment and Effects

Climate and Air 3-18 Final EIS

additional emissions are expected due to processing wood from state and private 

land locally. Because of the temporary and limited effects associated with timber 

harvest on National Forest System (NFS) lands, the alternatives are not expected to 

contribute significantly to cumulative effects on air quality. Air pollution from wood 

processing is likely to remain low, but could increase somewhat if more wood is 

burned to produce energy. Air pollution from forest fires in western Canada could 

adversely affect air quality in Southeast Alaska, as occurred in 2004. 

The cumulative effects from climate change alone and in combination with other 

stochastic events and with timber harvest are difficult to predict. Warmer 

temperatures are expected to result in a loss of carbon stored in leaf litter and soil 

organic matter, due to increased soil respiration (Bachelet et al. 2005). Other 

changes are more difficult to predict. Species will respond to changing climates 

individually; some species and some individuals will be more sensitive and 

vulnerable than others (Millar et al. 2006). Effects on forests could include 

expansion into alpine areas, increased loss of trees from insects, disease, 

windthrow, and/or fire, as well as changes in stream flow and vegetation and the 

animal species these habitats support; however, the degree of change is uncertain. 

If significant changes do occur over the next several decades, they may affect the 

range of wildlife, fish, and plant species in Southeast Alaska, as well as human use 

of these resources. 

Cumulative effects on carbon sequestration depend on the amount of forest land 

harvested, the use to which harvested wood is put, how the non-NFS land is 

managed, on the amount of carbon released during harvest, processing, and 

transporting wood products, on-site decomposition, and factors such as the amount 

of new hydroelectric power (replacing diesel generated power), community 

expansion, and cruise ship emissions. It is likely that most of the state and private 

commercial forest land in Southeast Alaska, except for state parks and some other 

state lands, would be managed for the production of forest products under any of the 

alternatives considered in this analysis. The maximum amount of suitable land on 

the Tongass that is likely to be scheduled for harvest over the next 10 years would 

vary from nearly 18,000 acres under Alternative 1 to nearly 160,000 acres under 

Alternative 7. Higher levels of harvest would only occur if additional manufacturing 

facilities and markets are developed and on many other factors, such as funding and 

staff levels. If the products resulting from harvest are primarily lumber and other 

building materials, there is a potential that the carbon in these products would be 

stored for the life of the buildings, longer if the wood is recycled or placed in landfills. 

If the wood is used for paper products or fuel, carbon storage would be short term. 

Any temporary storage of carbon in lumber products may be completely off set by 

carbon released during and after harvest, transportation, and processing. Whether 

carbon sequestration would actually increase or decrease is unknown. 

Additional research and monitoring is needed to effectively manage carbon in the 

forests of Southeast Alaska. In particular, information is needed on how changes in 

climate may affect plants, insects, and fungi in Southeast Alaska. Effects may 

include longer growing seasons due to warmer temperatures or shorter growing 

seasons due to dryer summer weather. Longer growing seasons and forest 

expansion into alpine areas may lead to additional carbon sequestration, though this 

may not always be the case. Carbon incorporated into needles, leaves, twigs, 

cones, and herbaceous plants that decompose quickly will not sequester much 

carbon (Millar et al. 2006). Carbon incorporated in the boles and main roots will be 

sequestered for at least the life of the tree. Climate change may result in changes in 

fire frequency and/or severity or may speed decomposition of dead material, either 

of which would release additional stored carbon. As information is gathered, 

adaptive management strategies can be developed to respond the environmental 

changes. 
 Environment and Effects 3 

Final EIS 3-19 Climate and Air 

One monitoring effort that tracks changes in vegetation is the Forest Inventory and 

Analysis-Forest Health Monitoring (FIA FHM) program. The existing FIA plots 

containing lichen and vascular plant data could be combined with Tongass air 

quality biomonitoring plot data to develop air pollution and climate gradient models 

that predict changes in lichen communities and other vegetation due to projected 

climate change scenarios. Annual insect and disease surveys also provide 

information on how climate change may be affecting forests. Stream gauges, some 

of which provide long-term data on stream flow, are another tool. The Tongass will 

work with Pacific Northwest scientists to develop other monitoring measures to alert 

the Forest Service to trends that may affect the health of the Forest and the species 

that depend on it. 

No significant cumulative effects on global carbon sequestration levels are expected 

under any of the alternatives considered in this analysis. Leighty et al. (2006) 

estimate that all the carbon stored in the forests of the Tongass represents 

approximately one quarter of 1 percent of the stored carbon in forests world wide. 

Carbon stored in forests, including forest soils, represent a small portion of total 

global carbon storage (terrestrial, ocean, atmospheric, and fossil carbon pools). For 

example, the oceans store approximately 20 times as much carbon as all terrestrial 

systems (IOC 2007). Therefore, it is reasonable to conclude that small changes in 

carbon sequestration on the Tongass, whether positive or negative, would have a 

minor effect on atmospheric carbon levels. 

While there is general agreement among scientists that the climate is warming, there 

is considerable uncertainty concerning the exact effects of climate change on the 

forests of Southeast Alaska and how best to deal with possible changes to the many 

resources on the Tongass. There is a risk that climate change may result in 

increased blowdown, increased tree mortality from insects and disease, increased 

fire frequency and severity, adverse effects on air quality, changes to vegetation, 

streams, and fish and wildlife habitat, and, therefore, on subsistence and recreation. 

The rate of decline and mortality of yellow-cedar in Southeast Alaska may be 

increased as a result of climate change. The snowpack in low-elevation areas may 

continue to be reduced as a result of the warming trend, resulting in greater 

exposure of fine roots to freezing, especially in the southern portion of the region 

(see Forest Health section). 

The current warming trend may increase the number of severe windstorms, 

increasing the risk of catastrophic blowdown events. Juday et al. (1998) state that 

as of the date of their report, the increased frequency of storms in the last few 

decades has not corresponded to an increase in large-scale blowdown in Southeast 

Alaska and the 2006 Forest Health report noted very little blowdown in aerial and 

ground surveys (USDA Forest Service and ADNR 2007); however, this does not rule 

out the risk of increased windthrow in the future as additional warming occurs. 

As noted above, climate models from both the Canadian Climate Center and the 

Hadley Center predict rising temperatures and a 10 percent decrease in summer 

precipitation in portions of Southeast Alaska. Both models also predict decreased 

soil moisture due to increased evaporation during warmer, drier summer weather. 

These factors may lead to an increase in fire frequency and severity. Both of these 

climate models predict an increase in the mean seasonal severity rating for fires in 

Southeast Alaska by 2060, ranging from 10 to 30 percent, depending on the model 

(Dale et al. 2001). Currently, fire is not a factor in the ecology of Southeast Alaska, 

and an increase of 30 percent would still result in very few fires. Given the high 

rainfall levels in Southeast Alaska (Ketchikan had only 2 days without rain in July 

2006), a 10 percent decrease in summer rainfall would still result in wet conditions in 

most years. However, Southeast Alaska does occasionally experience drier 
3 Environment and Effects

Climate and Air 3-20 Final EIS

conditions. For example, in July 1971 there were 23 days without rain. If warmer 

winter weather results in higher insect populations and increased tree defoliation (as 

discussed above), there is a risk that increased dead material and warmer, drier 

weather may spawn more fires than are normal for the area. As Berman et al. 

(1998) state, it is difficult to predict the magnitude of area likely to be burned in a 

region without an historic fire record, but they estimate that most fires would be 

small and of low intensity, suggesting a scenario in which 5,000 acres might burn 

over a period of decades (an average of approximately 100 acres per year). Juday 

et al. (1998) also suggest that the effects of fires on resources are likely to be low. 

In addition to adversely affecting wildlife habitat and releasing additional carbon into 

the air, fires, either in Southeast Alaska or in neighboring British Columbia, could 

adversely affect air quality, as fires in western Canada did in 2004. Many scientists 

(Neilson 2007, Millar et al. 2006) recommend keeping forest density below full 

stocking to reduce stress on individual trees; this in turn may reduce insect and 

disease mortality, which may reduce fire risk and severity. Whether this strategy 

would be useful (or effective) in Southeast Alaska is uncertain. 

Forest losses, either from insects, diseases, or fire, could harm wildlife habitat, 

which in turn could adversely affect subsistence resources. Conversely, Juday et al. 

(1998) suggest that warmer winters will result in sustained higher populations of 

Sitka black-tailed deer, one of the most important subsistence resources for 

residents of Southeast Alaska and a major prey species for wolves. Juday et al. 

(1998) also postulate that warmer, drier conditions could increase stream 

temperatures and cause seasonal low flows, both of which could adversely affect 

salmon. Berman et al. (1998) estimated that a 25 percent decline in salmon stocks 

would result in a loss of $25 million a year (approximately $31 million in current 

dollars). However, Oswood et al. 1992 state that melting glaciers would result in 

more runoff entering streams. This could offset any decrease in summer flows due 

to reduced summer precipitation, at least in the short run. In time, glacial mass 

would be reduced and their contribution to stream flow would decrease. Oswood et 

al. also believe that climate change would result in changes to the nutritional levels 

of leaf material entering streams, but could not predict whether this would have a 

positive or negative effect of fish. 

In summary, general agreement exists that the climate is warming and indications 

are that summer precipitation may decline. However, there is considerable 

uncertainty surrounding specific predictions and even more uncertainty regarding 

the effect of these changes on the extent of fire, tree mortality, blowdown, air quality, 

fish and wildlife, subsistence, and recreation. 
Environment and Effects 3

Final EIS 3-21 Geology, Karst, and Caves 

Geology, Karst, and Caves 

Affected Environment.....................................................................................3-21

Geology.......................................................................................................3-21

Karst and Caves .........................................................................................3-22

Environmental Consequences.......................................................................3-26

Geology.......................................................................................................3-26 

Karst and Caves .........................................................................................3-26 

Cummulative Effects...................................................................................3-29 

Affected Environment 

The Tongass National Forest is underlain by complex geology. Southeast Alaska is 

located near the boundary between the Pacific and North American tectonic plates. 

During the past 170 million years, tectonic movements have brought massive crustal 

blocks from across the Pacific Ocean and lodged and welded them onto the edge of 

the North American plate. The resulting southeast-northwest trending rock belts, or 

accreted terranes, include a wide variety of geologic materials (Nowacki et al. 2001). 

As the Pacific and North American plates collided, the coastal mountains of 

Southeast Alaska were uplifted. More recently, fault movements have offset the 

accreted terranes, adding further geologic complexity to the region. This tectonic 

plate boundary forms part of the “Ring of Fire,” the area around the Pacific Ocean 

that is high in volcanic, mountain-building, and seismic activities. Evidence of 

relatively recent volcanic activity exists within the Tongass National Forest. The last 

certain activity of the Edgecumbe volcanic field occurred between 4 and 6 thousand 

years ago (Alaska Volcano Observatory 2006). Many volcanic features are also 

found on southwestern Suemez Island, including several surface flow types, 

obsidian sources, volcanic vents, and unique geomorphic features. 

Together these tectonic, seismic, and volcanic forces have resulted in many 

different geologic formations in Southeast Alaska. Within the Tongass National 

Forest, generalized lithologies have been delineated and include granitics, 

noncarbonated sedimentary, carbonate sedimentary, metasedimentary, complex 

sedimentary and volcanics, volcanics, and mafics/ultramafics (Nowacki et al. 2001). 

During the past 12.5 million years, many of these lithologies have been affected by 

glaciers. 

Within the Tongass National Forest, recurrent ice sheets formed and spilled from the 

St. Elias and Coast Mountains onto adjacent surfaces (Nowacki et al. 2001). 

Pushing seaward, these continental ice sheets combined with smaller alpine 

glaciers descended from isolated island peaks. Together, the ice sheets and 

glaciers reworked the topography of the land by rounding mountains, scouring 

bedrock, depositing glacial sediments, and carving U-shaped valleys and submarine 

trenches. In some areas, unconsolidated sediments were left, including glacial till 

(ice-contact deposits), glacial outwash, and glacial marine sediments. During the 

last glacial maximum, ice flowed all the way to the continental shelf. As glaciers 

retreated worldwide, the ice sheet receded first at coastal margins, then north and 

eastward along major channels and valleys into the mountains. Deglaciation was 

rapid and largely complete by 13,500 years ago. 

The group of islands and fjords that currently make up the Tongass National Forest 

developed after the last major glacial retreat as seawater flooded the deeply incised 

valleys and trenches. Since deglaciation, coastlines have shifted dramatically due 

Geology 
3 Environment and Effects

Geology, Karst, and Caves 3-22 Final EIS

to tectonic events, worldwide sea level changes, and land rebound in the absence of 

the glaciers’ massive weight. Elevated fossil-bearing marine beaches and deltas 

along the coastline indicate an uplift of the land relative to the sea since the last 

glacial maximum. 

There are multiple sites with important vertebrate and invertebrate paleontological 

resources throughout the Tongass, including 220 million year-old sites on Gravina 

Island and the islands in Keku Strait (Baichtal 2006). Many important 

paleontological resources have been identified in caves on the Tongass National 

Forest. 

As a result of the geological processes in Southeast Alaska, the region’s 

physiography is topographically complex. Broad physiographic areas in the 

Tongass National Forest include icefields, recently deglaciated areas, large 

mainland river systems, angular mountains, rounded mountains, hills, lowlands, and 

recent volcanic fields. These distinct areas reflect the geomorphic and glacial 

history of the land. Continental ice sheets flowed, scoured, and deposited materials, 

tectonics added blocks of distinct geology, and volcanism superimposed younger 

rocks. 

The geology and climate of Southeast Alaska are particularly favorable for karst 

development. Karst is a comprehensive term that applies to the unique topography, 

surface and subsurface drainage systems, and landforms that develop by the action 

of water on soluble rock (primarily limestone and marble [carbonates] in Southeast 

Alaska). The dissolution of the rock results in the development of internal drainage, 

producing sinking streams (streams that sink into the stream bed or karst features), 

closed depressions, sinkholes, collapsed channels, and caves. 

There are approximately 538,000 acres of very pure carbonates within the 

boundaries of the Tongass National Forest. This area includes carbonate bedrock 

on federal, state, and private lands. Approximately 458,000 acres of karst are on 

National Forest System (NFS) lands. 

Because of fractures in the carbonates, high annual precipitation, and peatlands 

adjacent to the carbonate bedrock, karst has developed, to varying extents, within 

all carbonate blocks. The Tongass National Forest contains the largest known 

concentration of dissolution caves in Alaska. 

In Southeast Alaska, the karst landscape can be characterized as an ecological unit 

found atop carbonate bedrock in which karst features and drainage systems have 

developed as a result of differential solution by surface and ground waters. These 

acidic waters are a direct product of abundant precipitation and passage of these 

waters through the organic-rich forest soil and adjacent peatlands. Recharge areas 

may be on carbonate or adjacent noncarbonate substrates. A few characteristics of 

this ecological unit include mature, well-developed spruce and hemlock forests 

along valley floors and lower slopes, increased productivity for plant and animal 

communities, extremely productive aquatic communities, well-developed subsurface 

drainage, and the underlying unique cave resources (Baichtal and Swanston 1996). 

The visible karst landscape also contains “epikarst,” or surface features, particularly 

in the alpine and sub-alpine zones. These include deep shafts and fissures, eroded 

rills, and spires or spikes of limestone. 

Karst lands add a vertical, underground dimension to land use planning. Karst 

subsurface drainage networks generally operate independently of, and with more 

complexity than, the surface drainage systems above, and the watershed 

characteristics of the surface may have little or no relationship to the subsurface 

system. On karst lands, the many solution-widened fissures at the surface become 

entry points into the subsurface drainage system, where water and sediment from 

Karst and Caves 

Karst: A type of 

topography, drainage 

system, and landform 

that develops in areas 

underlain by soluble 

rocks, primarily 

limestone and marble 

(carbonates). About 3 

percent of the land 

within the Tongass 

boundary is underlain 

by karst. 
Environment and Effects 3

Final EIS 3-23 Geology, Karst, and Caves 

surface sources move vertically downward into the underground lateral systems. 

Sediment and water from disturbed lands or roads may enter this system at a single 

point and emerge unexpectedly at one or more distant springs, sometimes crossing 

surface watershed boundaries. Karst groundwater systems routinely transport 

water for several thousands of feet to receiving caves, springs, and surface streams. 

Most Tongass National Forest caves pre-date the most recent glaciation, as 

evidenced by the presence of glacial clays, glacial sediments, wood, Pleistocene 

vertebrate remains, and possibly ancient ice. Speleothems (i.e., secondary mineral 

deposits such as stalactites, stalagmites, flowstone, and crystal growths) from El 

Capitan Cave, on Prince of Wales Island, have been radiometrically dated to 

between 107,000 and 115,000 years old, or during the last interglacial period. 

Speleothem dates from other caves in the Tongass National Forest range from 

53,000 to 185,800 years old. The most recent glaciation modified a pre-existing 

karst landscape, collapsing some passages and systems, gouging into others, and 

filling some with sediments. The epikarst (surface karst), which is well developed in 

higher elevations, has been removed in places at lower elevations by glaciation. 

Where low-elevation epikarst is present, primarily on the outer coast of islands 

seaward of Prince of Wales Island, vegetation has been re-established and a 

forested epikarst created. With the development of forested epikarst and peatlands, 

and the entrance of associated acidic waters into underground tributaries, a system 

of enlarged caves and vertical shafts has developed. 

There is a definite tie between the karst landscape and the productivity of the spruce 

and hemlock forests found there. Dense stands of very large diameter spruce and 

hemlock at lower elevations are characteristic of many karst landscapes. The major 

contributors are believed to be the nutrient rich soils, well-developed subsurface 

drainage, and dissected bedrock surface, which allows the tree roots to hold fast 

and become more windfirm. The old-growth forest on this low-elevation karst 

provides a well structured, multi-layered canopy resulting in high-quality winter 

habitat for many wild species. The structure of the forest provides many forbs and 

shrubs, which provide forage. It is possible that this forage contains, at a minimum, 

higher calcium levels allowing for better bone, muscle, and antler development. The 

combination of quality forest structure and abundant nutritional browse make the 

karst landscape, in general, exceedingly important habitat. 

Many wildlife species, including mammals, birds, and invertebrates, find the surface 

karst features and the stable environment and shelter provided within the caves to 

be valuable habitat (Baichtal and Swanston 1996). Cave systems provide critical 

summer and winter roosting and hibernating habitat for bats (Baichtal and Swanston 

1996). Preliminary studies suggest that aquatic habitats associated with karst 

landscapes may be 8 to 10 times more productive than adjacent non-karst aquatic 

habitats (Baichtal and Swanston 1996). Karst aquatic habitats support a greater 

abundance, distribution, density, and variety of invertebrate species than noncarbonate habitats, have higher growth rates for smolts and resident fish, have less 

variable water temperatures and flow regimes, and contain unique habitat affecting 

species distribution, abundance, and adaptation. 

The potential cultural and paleontological significance of the caves and karst 

landscape is high (Baichtal and Swanston 1996). The Pleistocene paleontology of 

the area is primarily known from cave and rock shelter deposits, which are often 

intimately related to archaeological sites. The cool, stable, non-acid environments in 

the caves result in exceptionally good preservation of bone and organic materials. 

To date, significant archaeological and paleontological materials have been 

discovered in over 30 caves and rock shelters within the Tongass National Forest. 

Evidence of human habitation, the oldest dating to nearly 9,730 years before 

present (BP), has been discovered in several caves on Prince of Wales and nearby 
3 Environment and Effects

Geology, Karst, and Caves 3-24 Final EIS

seaward islands. Eighteen black bears (Ursus americanus), one dating to 

approximately 39,000 years BP, and 13 brown bears (Ursus arctos) ranging in age 

from 35,363 to 7,205 years BP and now extinct on Prince of Wales Island, have 

been found. 

Of the 458,000 acres of NFS karst lands, approximately 303,000 acres were 

originally productive old growth (POG). Based on GIS queries, 95,000 of these 

POG acres (31 percent) have been harvested, leaving 208,000 acres of existing 

POG on NFS karst lands. Outside of NFS lands, approximately 77,000 acres of 

karst have been mapped, and about 26,000 of these acres were originally POG. At 

least half of these non-NFS POG acres on karst have been harvested. 

Aerial and on-the-ground observations are revealing the effects of past resource 

management on karst systems. Hydrologic evidence suggests that timber harvest 

increases the amount and changes the timing of peak surface flow, resulting in 

accelerated sediment and debris transport. Passages have flooded, which had not 

flooded for centuries, and many cave entrances were infilled and/or blocked by 

logging slash, sediment, and debris, resulting in surface flows being rerouted into 

different passages. In the past, runoff generated from road surfaces commonly was 

diverted into karst features. It is not yet fully known what cumulative effects past 

timber harvest have had on the epikarst landscape. In some portions of the 

Tongass National Forest, 70 to 80 percent of the commercial forest land within 

specific karst blocks has been harvested. Overall, 38 percent of original POG on 

karst lands below 800 feet in elevation have been harvested on the Tongass. In the 

North Central Prince of Wales Biogeographic Province (which includes most of 

Thorne Bay Ranger District and part of the Craig Ranger District), 51 percent of the 

original POG on karst lands below 800 feet have been harvested. 

One of the five additional “emphasis areas” identified during the 1997 Tongass 

Forest Plan Revision was karst and cave resource management. Responding to the 

need for a management strategy, standards and guidelines were developed that 

provided for other land uses while taking into account the function and biological 

significance of the karst and cave resources within the landscape. This strategy 

was developed during the 4 years prior to completion of the 1997 Tongass Forest 

Plan, beginning with the recommendations of a karst and cave resource significance 

assessment completed by Aley et al. (1993, as cited in USDA Forest Service 1997a) 

and combining the most current thinking on karst management issues. The Forest 

began adopting a land management strategy for the karst lands similar to “hazard 

area mapping” or “risk assessment.” Referred to as “vulnerability mapping” or “karst 

vulnerability,” this strategy assesses the susceptibility of the karst resources to any 

land use. Vulnerability mapping utilizes the fact that some parts of a karst 

landscape are more sensitive than others to planned land uses. The key elements 

of the strategy focus on the openness of the karst system and its ability to transport 

water, nutrients, soil and debris, and pollutants into the underlying hydrologic 

systems. The strategy strives to maintain the capability of the karst landscape to 

regenerate a forest after harvest, to maintain the quality of the waters issuing from 

the karst hydrologic systems, and to protect the many resource values within the 

underlying cave systems as per the requirements of the Federal Cave Resources 

Protection Act (FCRPA). 

On the low to moderate vulnerability karst lands (defined in the Karst and Cave 

Resources Standards and Guidelines of Chapter 4 in the Forest Plan), where 

mineral or glacially derived soils fully or partially cover the epikarst, forest 

regeneration is exceptional. In these areas, even the complete loss of soil and litter 

from the surface of the limestone will not prohibit the re-establishment of a forest 

because the displaced surface materials are retained within the epikarst channels 

(Harding and Ford 1993, as cited in USDA Forest Service 1997a). On highly 
Environment and Effects 3

Final EIS 3-25 Geology, Karst, and Caves 

sensitive karst lands, the epikarst channels are too deep to allow conifer seedlings 

to establish themselves even if the displaced soil is retained. The bottom of the 

channels may also be open, directly transporting sediment and debris into the karst 

groundwater system. Highly sensitive or vulnerable karst areas are generally found 

at higher elevations, have thin organic soils that are easily displaced, are on steeper 

slopes, or are in areas of intense karst development. Previous harvest in such 

areas has increased the percentage of bare rock, resulting in less-than-desirable 

forest regeneration. 

Recent implementation and effectiveness monitoring (USDA Forest Service 2004a) 

found that the Karst and Cave Standards and Guidelines outlined in Forest Plan 

were being implemented to the fullest extent practicable. Karst resource input was 

provided for a number of sales, including those on the Thorne Bay Ranger District, 

where forested karst lands are most extensive. 

Although most caves found to date on the Tongass are not suitable for recreation 

purposes because of frequent flooding, instability, or presence of fragile structures, 

the Forest Service is seeking opportunities for surface and subsurface public access 

and interpretation. 

Karst areas in Southeast Alaska are most comparable to those of karst lands found 

on Vancouver Island and the Queen Charlotte Islands of British Columbia (Canada), 

portions of Patagonia (Chile), Tasmania, and the west coast of the South Island of 

New Zealand. All of these areas have very steep surface slopes and subsurface 

hydraulic gradients, and very high levels of rainfall. These characteristics put them 

among the most dynamic karst terrains on earth, evolving and changing more 

rapidly and abruptly than karst in more moderate settings. The Karst Panel Report 

(Aley et al. 1993, as cited in USDA Forest Service 1997a) found the karst lands of 

the Tongass National Forest to be of national and international significance for a 

variety of reasons. The Karst Review Panel in the summer of 2002 confirmed these 

findings (Griffiths et al. 2002). Both of these panels consisted of world renowned 

karst experts with a breadth of karst resource backgrounds and a wide variety of 

international exposure to karst areas and management considerations. Not only is 

the level of karst development and the karst hydrology and mineralogy globally 

significant, the paleontological and archaeological discoveries have provided 

information on the prehistory of Southeastern Alaska and contributed to and 

challenged theories of the peopling of North America. 

The natives and local inhabitants of Southeast Alaska have long known of the 

presence of caves. The existence of well-developed cave systems was first 

reported in 1975 and mapping of the caves began in 1987. The existence of vast 

areas in which karst had developed was fully recognized in 1990. Though noted by 

early foresters and geologists, the relationship between high site productivity and 

the presence of karst landscape became apparent at about this same time. With the 

passing of the FCRPA in 1988, the Forest struggled with methods to protect the 

many caves throughout the landscape. At first, protection focused on the large, 

significant karst features and cave entrances. Subsequent measures tended to look 

at entire karst hydrologic systems. 

As of 2006, the Tongass inventory includes 611 caves (plus one state cave). Of 

these, 290 were listed in 1996 during the initial process of identifying significant cave 

resources. An additional 87 caves were added in 2003. The Tongass National 

Forest has received another 57 nominations that are pending. The remaining 177 

caves do not have nominations. Intense karst development has been identified on 

northern, central, and south-central Prince of Wales Island, Kosciusko Island, Dall 

Island, Heceta Island, Revillagigedo Island, and on the mainland southeast of 

Wrangell (Baichtal 2006). 
3 Environment and Effects

Geology, Karst, and Caves 3-26 Final EIS

Approaches to characterizing karst areas on the Tongass National Forest in recent 

years have included tracer dye studies to define karst watersheds and water quality 

parameters, physical monitoring of karst springs, and measurement of rainfall 

(USDA Forest Service 2004a). These efforts provided preliminary data on how karst 

groundwater systems and water chemistry relates to precipitation and runoff. These 

data will be used to establish baseline conditions, and will be compared with karst 

conditions monitored after implementation of management activities. In addition, 

Light Distancing and Ranging (LiDAR) technology has been used in ongoing 

inventories of karst and cave resources. 

Environmental Consequences 

Updates to the Forest Plan standards and guidelines would apply under all 

alternatives except the Alternative 5 (No Action). The standards and guidelines 

related to geology would be updated under the proposed Forest Plan. The focus of 

the revisions would be to identify and find solutions to management problems 

related to geologic resources, and to develop geologic resources on the Tongass 

National Forest. Geologic inventories would be conducted to cover bedrock 

geology, surficial geology, stratigraphy, hydrogeology, geomorphic features, 

geological hazards, karst features, caves, and paleontology, including potential for 

geologic formations to yield fossil resources of scientific and other values. The 

focus on geologic resources could result in greater protection of unique features and 

greater utilization of geological resources. Refer to the Minerals section for more 

information on potential effects related to mining and mineral resources. 

Karst lands have separate issues and concerns compared with other landforms 

because karst is a three-dimensional landform with closely integrated surface and 

subsurface processes. Groundwater flows relatively slowly through porous rock and 

soil, or via fracture flow, in non-karst terrain. In karst terrain, groundwater may flow 

relatively quickly through complex underground systems of solution-widened 

conduits that vary from fissures a few inches wide to cave systems many feet wide. 

Potential effects to karst systems and caves and associated drainages from timber 

harvest and road building include changes in hydrology, infiltration rates, sediment 

production, debris transport, pollutants, and introduction of organics that can lead to 

oxygen depletion. Issues and concerns related to karst lands primarily revolve 

around potential changes to groundwater flow in the underground system. Any 

management activity that causes sediment or organic debris to build up in the 

subsurface conduits decreases the capacity of these conduits and makes the 

formation of surface streams more likely. Similarly, any management activity that 

increases groundwater recharge may also affect the capacity of the conduits in the 

underground system and make formation of surface streams more likely. Changes 

in the presence of surface water can produce broad ecosystem changes both above 

and below ground. Groundwater recharge in karst lands occurs by either discrete or 

diffuse recharge. Discrete recharge refers to losing or sinking streams that enter the 

subsurface at specific insurgence points. Diffuse recharge refers to subsurface 

entry of water through the forest floor and the epikarst. Losing or sinking streams 

can rapidly deliver sediment into subsurface passageways. 

Sediment transport into karst systems also produces concern. This concern is 

primarily attributed to the size of past harvest blocks and the rate at which the 

landscape was harvested prior to the early 1990s, when the extensiveness and 

significance of karst terrain on the Tongass National Forest became more fully 

recognized. The current standards and guidelines address these concerns to a high 

degree. 

Geology 

Karst and Caves 
Environment and Effects 3

Final EIS 3-27 Geology, Karst, and Caves 

Potential effects on karst lands from planned timber harvesting, associated road 

construction, and quarry development may occur; however, with careful 

implementation of the current or proposed standards and guidelines (as modified 

through ongoing monitoring and adaptive management), and site-specific mitigation 

measures (designed and implemented at the project level), the Forest expects to 

mitigate the effects of any proposed activity. Site-specific mitigation measures 

include protection of the high vulnerability karst areas and features, partial cutting, 

reduced harvest unit size, use of logging systems that achieve at least partial 

suspension, reductions in rate of harvest, and other changes in logging practices. 

The Karst Review Panel in the summer of 2002 found that implementation of the 

Karst and Cave Standards and Guidelines from the current Forest Plan had ensured 

a high level of protection for karst resources overall (Griffiths et al. 2002). The Panel 

noted high standards in both the philosophy of management and the way that 

specific management practices were formulated and applied. Implementation of 

specific policies and procedures was found to be very good and in general 

compliance with the stated goals and objectives of the karst program. The Panel 

also noted the extent to which high vulnerability karst had been protected since 

1997. In addition, the Panel outlined the action required to more actively manage 

karst landscapes covered with second-growth stands and recommended a new 

procedure for assessing the autogenic (precipitation on carbonate rocks) recharge 

component of karst units. 

Implementation and effectiveness monitoring of these karst and cave standards 

have brought to light a few discrepancies (USDA Forest Service 2004a). 

Specifically, the definition of low, moderate, and high vulnerability karst lands; the 

application of appropriate mitigation; the approach to catchment area management; 

and the resolution of conflicts with riparian management standards have surfaced as 

topics that need clarification. These have been addressed in the proposed Forest 

Plan, as discussed below. In addition, continued training and involvement of karst 

specialists, hydrologists, soil scientists, and other resource specialists has been 

identified as essential to implementing the standards and guidelines. 

Several elements of the Karst and Cave Standards and Guidelines would be 

updated under the proposed Forest Plan as part of all alternatives except Alternative 

5 (No Action). Most importantly, the issues identified as unclear in the current 

Forest Plan would be clarified, as described with the following explanations. The 

four-step process to complete a karst landscape assessment would be described in 

detail, including specific guidance for determining low, moderate, and high 

vulnerability karst. Depending on level of vulnerability, some management activities 

would be restricted on karst lands, and mitigation measures would be specified. 

Catchment areas would be explained, including allogenic (precipitation on noncarbonate rocks) and autogenic (precipitation on carbonate rocks) recharge areas. 

The potential effects related to second growth management (including commercial 

thinning), salvage of windthrown timber, and mineral development on karst lands 

would be addressed, and restrictions detailed based on the level of karst land 

vulnerability. The proposed standards and guidelines would provide detailed 

descriptions of factors to evaluate implementing management activities on or near 

karst lands; however, they also would allow flexibility depending on the professional 

judgment of karst-trained specialists. 

The Karst Review Panel in the summer of 2002 found that implementation of the 

Karst and Cave Standards and Guidelines from the current Forest Plan had ensured 

a high level of protection for karst resources overall (Griffiths et al. 2002). The Panel 

suggested the proposed changes to define appropriate resource management 

activities in areas of karst management that were unclear in the current version of 

the Forest Plan. The action alternatives (Alternatives 1, 2, 3, 4, 6, and 7) would 
3 Environment and Effects

Geology, Karst, and Caves 3-28 Final EIS

incorporate some of these changes in revised standards and guidelines and through 

proposed designation of new geologic Special Interest Areas. These new Special 

Interest Areas include all identified high vulnerability karst lands that are not already 

protected within non-development Land Use Designations (LUDs). Refer to the 

Other Special Land Use Designations section for more information. Significant 

effects to karst lands and caves have been avoided during implementation of the 

current Forest Plan. The proposed changes would likely protect karst lands and 

caves to an even greater extent. 

Much of the karst land within development LUDs has been designated as high 

vulnerability karst land and is protected by standards and guidelines or included 

within geologic Special Interest Areas. It is estimated that 30 percent of the other 

karst lands will be determined to be high vulnerability karst with ground verification 

in the future. 

Approximately 457,765 acres of karst underlies NFS lands inside the Tongass 

National Forest. Under Alternative 5 (No Action), the estimated maximum future 

harvest on NFS karst lands would be approximately 76,459 acres, including POG 

and young growth on suitable karst lands (Table 3.2-1). Alternative 6 would involve 

slightly less area, and Alternatives 1, 2, and 3 would include fewer areas of 

estimated maximum future harvest on karst lands. Alternatives 4 and 7 would 

include the most area of karst lands open for timber harvest activities (Table 3.2-1). 

Based on the current Forest Plan and proposed changes, karst inventories and 

vulnerability assessments would be required before timber harvest could occur on 

suitable lands. 

Table 3.2-1 

Estimated Maximum Future Tongass Harvest on Karst Lands under 

the Alternatives 

Alternative 

Old Growth on Karst 

Lands (acres) 

Young Growth on Karst 

Lands (acres) Total Area (acres) 

Alternative 1 11,941 17,198 29,140 

Alternative 2 17,745 42,737 60,482 

Alternative 3 19,813 46,358 66,170 

Alternative 4 32,512 53,310 85,822 

Alternative 5 24,946 51,513 76,459 

Alternative 6 22,549 50,079 72,628 

Alternative 7 44,121 59,287 103,408 

No additional harvest is anticipated in any areas mapped as high vulnerability karst 

under any of the alternatives. These areas are included in the 42,873 acres of 

Special Interest Areas under Alternatives 1, 2, 3, 4, 6, and 7, and are not suitable for 

harvest under Alternative 5. The estimated maximum amount of future POG harvest 

that could occur on NFS karst lands would vary by alternative, ranging from 11,941 

acres under Alternative 1 to 44,121 acres under Alternative 7 (Table 3.2-1). 

The maximum amount of construction of new roads on karst lands would also vary 

by alternative, ranging from 115 miles under Alternative 1 to 329 miles under 

Alternative 7 (Table 3.2-2). The percentage of new roads that would be constructed 

on karst lands ranges from 5 or 6 percent under Alternatives 4, 5, 6, and 7 to 15 

percent under Alternative 1, where fewer roads would be constructed but a larger 

percentage of them would be constructed on karst lands. Of these proposed new 

roads on karst lands, from 1 to 2 miles would occur on slopes greater than 67 

percent (Table 3.2-2). 
Environment and Effects 3

Final EIS 3-29 Geology, Karst, and Caves 

Table 3.2-2 

Estimated Maximum New Road Construction on Karst Lands under the 

Alternatives

New Roads on Karst 

Lands Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Alt. 6 Alt. 7 

Length of New Roads on 

Karst Lands (miles) 115 183 194 259 216 206 329 

Percent of New Roads on 

Karst Lands 15% 9% 7% 5% 6% 5% 6% 

Length of New Roads on 

Slopes >67% on Karst 

Lands (miles) 

1 2 2 2 2 2 2 

There are approximately 537,588 acres (840 square miles) of karst lands within the 

boundaries of the Tongass National Forest. Approximately 457,765 acres (715 

square miles) are on NFS lands. Of this, approximately 247,680 acres (387 square 

miles) are protected in Wilderness, LUD II, or other non-development LUDs under 

the current Forest Plan. The remaining high vulnerability karst on NFS lands are 

protected by standards and guidelines that include substantial no-harvest buffers. 

Past timber harvest has affected the epikarst landscape on the Tongass National 

Forest. In some portions of the Tongass, 70 to 80 percent of the commercial forest 

land within specific karst blocks has been harvested. It is estimated that about 21 

percent (95,479 acres) of the karst lands on NFS lands have been harvested (based 

on the GIS database). Approximately 133 square miles of karst land have been 

harvested on Prince of Wales Island alone. In addition, 575 miles of authorized or 

system roads have been mapped on karst lands (out of 3,532 total authorized road 

miles). These 575 miles include 116 miles at Maintenance Level 1 (closed), 338 

miles at Maintenance Level 2 (for high-clearance off-road vehicles), and 112 miles 

at Maintenance Levels 3, 4, and 5 (the highest maintenance levels, maintained for 

passenger vehicles). It is likely that a few hundred miles of unauthorized roads also 

exist on karst terrain. Of the 575 miles of roads mapped on karst lands, 87 percent 

occur on slopes of less than 35 percent, 13 percent occur on slopes of between 35 

and 67 percent, and less than 1 percent occur on slopes of greater than 67 percent. 

Baichtal and Swanston (1996) observed sediment deposits and waterline marks in 

underground systems that suggested that past timber harvesting had increased 

sediment and debris transport and flooding of underground passages, many of 

which had not previously flooded for centuries. These timber harvests were 

conducted prior to the Karst and Cave Resources Standards and Guidelines 

implemented in the 1997 Forest Plan. As a result, they had more significant effects 

on karst lands than current and future harvest activities. At that time, many cave 

entrances were filled or blocked by logging slash, sediment, and debris. Additional 

runoff generated from road surfaces commonly had been diverted into karst 

features. They also noted strong evidence of greatly increased surface runoff on 

karst landscapes and adjacent surfaces after timber harvest, which increased 

sediment, nutrient, and debris transport capability of associated drainage networks. 

Based on information from Prince Wales Island, Baichtal and Swanston (1996) 

noted few tree regeneration problems in low-elevation stands on karst landscapes. 

As a consequence, most easily accessible, low-elevation karst areas on the island 

had been harvested. After the initial timber harvests, harvest activities concentrated 

on steeper, higher elevation karst landscapes characterized by shallower, 

excessively well-drained soils. Baichtal and Swanston (1996) suggested that trees 

Cumulative 

Effects 
3 Environment and Effects

Geology, Karst, and Caves 3-30 Final EIS

were smaller and regeneration problems were greater at these steep, upper 

elevation sites. This condition possibly resulted from shallow soils with low nutrient 

availability, excessive drainage of surface and soil waters into subsurface karst 

systems, removal of much of the shallow soil because of inadequate log 

suspension, and continued desiccation of the soil once the protective forest canopy 

was removed. After timber removal, high rainfall rapidly transported fragile soils into 

the well-developed epikarst. 

More recent monitoring of karst lands near harvested areas (USDA Forest Service 

2004a) have confirmed that current timber harvest practices have adjusted 

substantially to accommodate Karst and Cave Standards and Guidelines. For 

example, karst resource input was provided for timber sales projects throughout the 

Tongass. 

Extensive landscape changes and ground disturbance have occurred and are likely 

to continue to occur on non-federal lands in Southeast Alaska. These include timber 

harvest and road construction, mining, recreation and tourism, growth of human 

settlements, transportation projects, and energy and transmission projects. Forest 

Service regulations requiring protection of karst resources do not apply to nonfederal lands. Approximately 88,000 of the nearly 538,000 acres of karst lands 

within the Tongass National Forest boundary are on state or private lands. 

Assuming that none of the karst on state or private lands is protected, an estimated 

69 to 74 percent of all the karst lands in Southeast Alaska would be protected in 

non-development LUD areas under the alternatives. 

Transfers of karst lands from NFS lands to other land managers or private owners 

could also occur under any of the alternatives through land exchanges or other 

types of land adjustments (see the Lands section and Appendix C to the Final EIS). 

The karst forest lands on Prince of Wales and neighboring islands are among the 

candidate lands that have been discussed in the past. This type of future action 

could increase the amount of karst lands in Southeast Alaska that are not in a 

protected LUD. Any exchange or other type of adjustment (outside of legally 

required conveyances) would require NEPA analysis, most likely an EIS, which 

would include public involvement and would disclose any adverse effects to karst 

and cave resources, as well as to other resources.
Environment and Effects 3

Final EIS 3-31 Soils 

Soils 

Affected Environment.....................................................................................3-31

Environmental Consequences ......................................................................3-35

Direct and Indirect Effects...........................................................................3-25 

Cumulative Effects......................................................................................3-38

Mitigation.....................................................................................................3-40

Affected Environment 

Soils in Southeast Alaska develop in parent materials originating from a variety of 

geological or vegetative sources. Parent material is the inorganic or organic matter 

in which soils develop, and in the Tongass National Forest includes volcanic ash; 

glacial deposits; hillslope, stream, and uplifted marine sediments; rock; and deposits 

of decomposed plant materials. Soils are commonly divided on the basis of their 

parent material. Both mineral and organic soils occur extensively within the 

Tongass National Forest, where more than 100 different soils have been identified. 

Soils cover 84 percent of the inventoried land surface area of the Tongass; the 

remainder consists of ice, exposed bedrock, and bodies of water. 

From a resource management perspective, soil productivity (i.e., a soil’s ability to 

support vegetative growth) and the potential loss of soils or off-site effects from 

erosion and landslides are the principle concerns. The productivity of soils directly 

or indirectly affects the productivity of other forest resources. Tree growth, wildlife 

and fish habitat quality, and recreation uses and potentials depend in part on the 

quality of soils. In Southeast Alaska, soil productivity, in terms of tree growth, is high 

on well-drained soils (e.g., on steep slopes and in karst areas) and decreases as 

latitude and elevation increase and as drainage becomes poorer. 

Soil, or site, productivity is generally measured by the rate of biomass accumulation, 

and site index is commonly used to give a relative indication of this productivity. Site 

index is determined by the height of dominant trees at a specified age. The site 

index tables or curves available for use in Southeast Alaska were developed from 

trees in even-aged stands, not the uneven-aged or old-growth stands that 

predominate here; consequently, the resulting site index categories are more useful 

for comparison than as absolute numbers. Soil productivity also can be estimated 

from the characteristics of individual soil types. The principal characteristics are soil 

depth, drainage, acidity, and coarse fragment content. Over one-quarter of the total 

productive forest land in the Tongass National Forest has been mapped in the 

highest site index category (Category 4), which means that on average these sites 

will grow trees greater than 80 feet tall in 50 years (Table 3.3-1). Less than 10 

percent of the Tongass falls into the lowest site index category (Category 1), which 

corresponds with trees less than 40 feet high in 50 years. Almost one-quarter of the 

productive old growth (POG) and two-thirds of the harvested young growth have 

been mapped as Category 4 (Table 3.3-1). 
3 Environment and Effects

Soils 3-32 Final EIS

Table 3.3-1 

Estimated Percent of the Productive Forestland on the Tongass by Site Index 

Category 

 Site Index Category 

1 2 3 4 

Productive 

Forest Land 

Category

 Avg. Site 

Index 

= 0-40 

 Avg. Site 

Index 

= 41-60 

 Avg. Site 

Index 

= 61-80 

 Avg. Site 

Index 

> 80 Unmapped1 Total 

Productive 

Old Growth 

9% 14% 23% 24% 29% 100% 

Young 

Growth – 

Harvested 

4% 6% 21% 66% 2% 100% 

Young 

Growth – 

Natural 

13% 6% 16% 39% 26% 100% 

Total 

Productive 

Forest land 

9% 13% 23% 28% 26% 100% 

1

 Unmapped areas are mostly in Wilderness or National Monument.

Soil erosion in the form of gully, sheet, and rill erosion is a minor occurrence under 

natural, undisturbed conditions in Southeast Alaska, because the thick surface duff 

layers that cover the mineral soils protect them from surface erosion. Mineral soils 

can be disturbed and exposed either by natural causes, such as landslides and 

blowdown, or management activities, such as timber harvest and road construction. 

Surface erosion can become active once the duff layer is removed and can remain 

active until revegetation occurs. 

Landslides, both naturally occurring and human-caused, dominate soil movement 

processes on steep forest lands in Southeast Alaska (Swanston 1969, 1974). 

Although conducted more than 30 years ago, Swanston’s papers present excellent 

characterizations of landslides in Southeast Alaska. Landslides deliver eroded 

material to streams more quickly, and in greater quantity, than surface erosion. 

Landslides can seriously retard soil productivity for forest regeneration on slopes by 

removing the soil mantle down to bedrock or glacial till. It can take 50 to 100 years 

for soil layers to be rebuilt on exposed bedrock in these landslide areas. Debris 

deposited on lower slopes and valley bottoms may improve site productivity locally 

because of incorporation of organic nutrients and improved drainage. Regeneration 

at such sites is rapid. 

In the Tongass National Forest, several factors control soil stability on steep terrain. 

On steep forested slopes, the dominant failure type is debris avalanche (the failure 

of a finite mass of water-charged overburden material along a relatively flat surface). 

These landslides occur primarily at shallow depths (1 to 3 feet) in the soil 

overburden. The texture of the soil overburden is characteristically gravelly silt or 

gravelly silty sand; less commonly the texture might be sandy gravel (Swanston 

1997). The dominant steep-slope soil types with these textural characteristics in 

Southeast Alaska have little or no cohesion. Organic content may exceed 30 

percent locally because of the downward migration of organic particles into the 

mineral soil zone, which substantially increases cohesion at some sites. A 

qualitative system of indexing mass failure provides an indication of the relative 

frequency of mass failures when vegetation is cleared or the land is disturbed. 
Environment and Effects 3

Final EIS 3-33 Soils 

Approximately half of the Tongass is made up of lands with slopes less than 35 

percent (Table 3.3-2). Approximately one-third of the Tongass ranges in slope from 

35 to 67 percent, and the remaining 18 percent exceeds 67 percent slope. Only 13 

and 3 percent of POG and harvested young growth exceed 67 percent slope, 

respectively. In general, these steep slopes pose greater risks for soil erosion through 

landslides. 

Table 3.3-2 

Estimated Percent of the Tongass National Forest, POG, and Young 

Growth by Slope Category 

Percent Slope Category 

 Acres 0-35% 35-67% >67% Total 

Productive Old Growth 4,951,154 49% 38% 13% 100% 

Young Growth – 

Harvested 454,725 68% 29% 3% 100% 

Young Growth – Natural 233,844 81% 14% 4% 100% 

Other Areas 11,134,085 49% 30% 22% 100% 

Tongass National Forest 16,773,808 50% 32% 18% 100% 

Landslides are thought to be an important natural process by which fish habitat 

structures and stream substrates are replenished (Meehan 1991, Reeves et al.1995, 

Wing 2000). Sediments and large woody debris, including gravels, are deposited in 

stream headwater areas. During high flow periods, some of that sediment and wood 

is transported through the stream system, although much wood may be stored in 

headwater channels. A recent study by Martin and Benda (2001) in the Game Creek 

Watershed found that only about 1 percent of the wood (by volume) from landslides 

reaches mainstem fish habitat. The wood is typically entrained in the upper reaches 

of fish habitat on alluvial fans and in transition channels. Sediments may more 

commonly flush through the stream system. Settled gravel can provide fish spawning 

habitat. Large wood that does reach mainstem aquatic habitat forms structures for 

hiding and resting. The frequency of delivery and quantity of the material delivered 

will determine the effect (either positive or negative) landslides will have on stream 

channels and fish habitat (Meehan 1991, Reeves et al. 1995, Wing 2000). It is 

generally thought that increased frequency of slides and quantity of material delivered, 

above the natural range of occurrence, moves the streams out of equilibrium and 

degrades fish habitat (Meehan 1991, Reeves et al. 1995, Wing 2000). 

One inventory of landslides that occurred between 1963 and 1983 in Southeast 

Alaska (Swanston and Marion 1991) showed that roughly 10 percent (118) of the 

landslides occurred in clearcut harvest areas or were directly associated with timber 

harvesting, whereas roughly 90 percent (1,277) occurred in unlogged areas. On a 

per-acre basis, however, landslides occurred in clearcut areas about three times as 

frequently as in unlogged areas. Landslides in unlogged areas appear to be larger 

and longer than those in logged areas. Of the 1,277 landslides that occurred on 

unlogged areas, 37 affected fish streams (3 percent), while 7 of the 118 landslides 

on logged areas affected fish streams (6 percent). It is important to note that 

clearcut timber harvests conducted between 1963 and 1983 did not include the 

restrictions that were implemented during the past 15 years or would be 

implemented in the future. These harvests often involved logging large portions of 

watersheds with very large clearcuts and almost no buffers, slope restrictions, or 

other restrictions. One would expect to find more landslides after these earlier 

clearcuts than after the types of clearcuts expected under the current Forest Plan. 
3 Environment and Effects

Soils 3-34 Final EIS

The Soil and Water Standards and Guidelines in the current Forest Plan are 

important for minimizing potential detrimental soil disturbance. According to results 

of 2004 soil and water implementation and effectiveness monitoring (USDA Forest 

Service 2004b), the Tongass National Forest is implementing the standards and 

guidelines for soil disturbance successfully during timber sale administration and 

road construction. Data collected on Prince of Wales Island and on the Wrangell 

and Petersburg Ranger Districts indicate that all timber harvest units, including 

cable, helicopter, and shovel yarding systems, are within the established Region 10 

soil quality guideline of less than 15 percent soil disturbance that is considered 

potentially detrimental (as set forth in Forest Service Manual 2554). 

The current Forest Plan takes a relatively conservative approach to avoid potential 

effects on soil resources. Seven specific items are listed in the proposed Forest 

Plan to ensure that land use activities avoid irreversible or serious and adverse 

effects on soil resources. These are based on research on the effects of 

management activities on soils in Southeast Alaska. For example, at the Forest 

Plan level, slope gradients of 72 percent or more are removed from the tentatively 

suitable timber base because of the high risk of soil mass movement and 

accelerated erosion of Class IV channel systems (see the Water section for more 

information regarding channel classes). At the project planning level, the Forest 

Supervisor or District Ranger may approve timber harvest on slopes of 72 percent or 

more on a case-by-case basis, after on-site analysis of slope and Class IV channel 

stability and an assessment of potential impacts of accelerated erosion on 

downslope and downstream fish habitat, other beneficial uses of water, and other 

resources. The threshold of 72 percent comes from the applicable research 

conducted in Southeast Alaska (Swanston 1997). 

As another example, the effectiveness of standards and guidelines related to 

yarding methods were monitored in Landwehr (1993). This study involved 199 soil 

disturbance transects in timber harvest units on the Thorne Bay Ranger District. 

Mineral soil disturbance on individual transects averaged 4.6 percent. Shovel 

yarding averaged slightly higher levels of disturbance, 5.1 percent, as compared to 

cable yarding systems that averaged 4.0 percent. In the Coffman Cove area, where 

operators were less experienced, shovel yarding averaged 7.1 percent mineral soil 

disturbance. After operators in the Coffman Cove area were directed to reduce soil 

disturbance, conditions improved and total disturbance was reduced. Standards 

and guidelines for overall mineral soil disturbance were met in all the units involved 

in the study. 

A Forest-wide inventory to identify, delineate, and digitize all landslides was initiated 

in 2001. Landslides are being digitized as an independent layer in GIS. As of 2004, 

landslide inventories have been completed for approximately 2.9 million acres of the 

Ketchikan, Petersburg, Sitka, and Wrangell Ranger Districts. Additional landslide 

inventories are being conducted. To date, the density of landslides is greater in 

managed stands than in unmanaged areas, which is consistent with the results of 

the Swanston and Marion (1991) inventory. However, the majority of past harvest 

activities were conducted under substantially lower protections than current-day 

harvest activities (see the subsection titled Past Old-Growth Harvest in the Affected 

Environment portion of the Biodiversity section). Continued emphasis is necessary 

during timber harvests to implement measures that minimize mass failures and 

landslides. 
Environment and Effects 3

Final EIS 3-35 Soils 

Environmental Consequences 

Forest management activities can cause soil erosion and subsequent loss of site 

productivity through the exposure of mineral soil, alteration of subsurface drainage, 

and the concentration of soil and rock material at unstable sites. The management 

activities that have the greatest potential to affect soil erosion, including sheet, rill, 

gully, or mass movement erosion, are timber harvest-associated activities, such as 

road and log-landing construction, rock pit development, and some yarding 

methods. Forest-wide standards and guidelines protect all areas of the Forest to a 

high degree, as indicated by 2004 soil and water implementation and effectiveness 

monitoring (USDA Forest Service 2004b). Monitoring indicates that the Region 10 

soil quality standard of less than 15 percent soil disturbance was achieved during 

timber harvest activities. Soil erosion and loss of productivity would be expected to 

be even lower if lands are converted from development LUDs to non-development 

LUDs, which prohibit timber harvest and most road construction. 

Due to the substantial amount of vegetative groundcover remaining on harvest units 

during and following timber harvest, surface erosion from these areas is usually 

small (Martin and Kirtland 1995, Swanston 1969). The larger effect of harvest 

activities on soil erosion occurs as landslides. More than 300 landslides and debris 

flows were triggered by an October 1993 storm on basin-scale clearcuts on Prince 

of Wales Island (Johnson et al. 2000). Eroded soil from these landslides was 

transported as sediment in nearby channels. Channel bedload sediment after the 

1993 events was 2 to 10 times greater and relatively finer compared with bedload 

transport in a channel that had last experienced a landslide and debris flow in 1961 

(Gomi et al. 2004). Swanston and Marion (1991) mapped landslides in the Tongass 

National Forest during the 21-year period, 1963 through 1983. They noted an 

occurrence rate of 118 landslides per 980 square kilometers (242,163 acres) in 

harvested or roaded areas over 21 years. Based on this count, an average of one 

landslide occurred per 2,052 acres of harvest over 21 years, or one landslide per 

43,092 acres (on average) per year. They found that landslides were 3.5 times 

more likely on harvested areas. A more recent study (Johnson et al. 2007) 

compared the effects from 100 percent tree removal to partial cuts (25, 50, and 75 

percent removals). They focused on effects to soil saturation (groundwater levels) 

and found increasing soil saturation with increasing percent tree removal. Increased 

soil saturation likely correlates with increased potential for soil erosion through 

landsliding, although they did not model this possibility directly because of 

uncertainties in estimating loss of cohesion as a result of changes in root strength in 

partial cuts. 

The effects of timber harvest on soil productivity are described in several papers in 

Slaughter and Gasborro 1988. Regeneration after clearcutting is excellent on all but 

a few sites in coastal Alaska, and, once established, growth rates of hemlock and 

spruce are relatively high (Farr and Ford, in Slaughter and Gasborro 1988). New 

stands contain several thousand stems per acre, and crown closure begins to take 

place by age 15 to 20 years. Crown closure approaches 100 percent by 25 to 30 

years of age and remains so for 100 years or more. Silen (in Slaughter and 

Gasborro 1988) also states that more than 90 percent of clearcut areas densely 

restock naturally in Southeast Alaska. Precommercial thinnings aid in achieving 

desired stocking levels and increased growth (Pawuk, in Slaughter and Gasborro 

1988). Klock (in Slaughter and Gasborro 1988) notes that soil compaction, most 

frequently by ground skidding operations, leads to reduced timber volume growth. 

The current and proposed Forest Plan includes standards and guidelines to avoid 

these effects. 

Direct and Indirect 

Effects 
3 Environment and Effects

Soils 3-36 Final EIS

Blowdown, or windthrow, can increase along the edges of regeneration harvest 

units, and this may expose mineral soil. Blowdown increases the potential for soil 

erosion and may increase the potential for landslides. According to a study by 

Kramer (2001), watersheds in the Tongass National Forest that experience more 

intense soil mixing from windthrow have lower levels of strongly humified soil carbon 

pools (e.g., lower levels of reprecipitated acid) than areas that have not experienced 

windthrow. The disturbed watersheds include more organic matter in a partially 

decomposed particulate form, which translates to less acidic carbon forms, higher 

ion exchange capacity, higher soil pH, and lower bulk density in the soil (Kramer et 

al. 2004). The disturbed soils are more aerated, better drained, and have higher 

nutrient status. 

Soil productivity decreases from the construction of roads because land is taken “out 

of production” (i.e., removed, covered over, or compacted). Erosion increases from 

the construction of roads because of the destabilizing effect of cuts, fills, and 

drainage alterations, and the lack of protective vegetation cover on road surfaces 

and other disturbed areas. 

The amount of road construction by alternative is used as a measure of both soil 

productivity losses and erosion potential. In one attempt to quantify road erosion, 

Kahklen and Hartsog (1999) developed a multiple regression analysis based on 

road erosion studies in the Tongass National Forest. They found that road erosion 

was highly variable. The primary variables that correlated with greater sediment 

yields were heavier traffic volumes, more rainfall, higher road gradients, and lack of 

road resurfacing. These and other site-specific variables are evaluated more 

precisely during project planning, based on the specific conditions found at the 

project site, and will vary based on soil parent materials, rock durability, slope, 

location within a watershed, mass movement hazard, and other factors. Paustian 

(1987) measured short-term effects of road building on soil erosion in the Kadashan 

watershed that resulted in increased suspended sediment yield equivalent to 2 

percent of the estimated annual sediment yields. Potential increases in total 

estimated sediment yield over a 2-year post-road construction period ranged from 

20 to 66 percent in three Kadashan study streams. Montgomery (1994) found that 

drainage concentration from ridgetop roads caused both landsliding and integration 

of the channel and road networks. Road drainage concentration increased the 

effective length of the channel network and strongly influenced the distribution of 

erosional processes in Southeast Alaska. 

Standards and guidelines, Best Management Practices (BMPs), and other relevant 

mitigation measures are applied at the project level to minimize potential adverse 

effects. At the Forest Plan level, the overall difference in acres disturbed by roads is 

a good indication of how site-specific effects are likely to vary between alternatives. 

Refer to the Water and Fish sections for more detailed analyses of potential effects 

related due to roads. Table 3.3-3 displays the maximum acres to be covered by 

road surfaces after the first 15 years of Forest Plan implementation. In addition, it 

presents the cumulative acres of road surfaces—the total amount of land area 

covered by all roads after 100+ years - full implementation of the Forest Plan 

(assuming none of the roads is completely obliterated). 

Under all but Alternatives 4 and 7, the cumulative acres of road surfaces would be 

equal to or less than expected under the current Forest Plan. The cumulative acres 

of road surfaces would be smallest under Alternatives 1, 2, and 3. Reductions in 

soil productivity losses and soil erosion would correlate with smaller cumulative 

roaded acres. 
Environment and Effects 3

Final EIS 3-37 Soils 

Table 3.3-3 

Estimated Cumulative Acreage Covered by Road Surfaces on NFS 

Lands after the first 15 Years and after Full Implementation of the 

Forest Plan (100+ Years) by Alternative1 (currently there are 14,823 

acres covered) 

Alternative 

Estimated Maximum 

Cumulative Acres Covered 

by Road Surfaces after 

First 15 Years of 

Implementation 

Estimated Maximum 

Cumulative Acres Covered by 

Road Surfaces after Full 

Implementation (100+ years) 

1 15,239 17,148 

2 16,155 21,063 

3 16,822 23,223 

4 18,050 29,495 

5 17,848 26,448 

6 17,713 26,058 

7 18,903 32,300 1

 Acres covered by road surfaces are calculated based on an average of 3 acres per 1 mile of road. 

Soil mass movements (e.g., slumps, earthflows, debris avalanches, and debris 

flows) constitute the most potentially damaging type of erosion. They are thought to 

be the major cause of accelerated erosion resulting from resource management 

activities. Landslides may adversely affect soil quality. They have the potential to 

affect aquatic habitats both positively and negatively. Landslides have a positive 

effect by providing new sources of woody debris and gravel. They negatively affect 

aquatic habitats by destroying viable eggs by smothering and bed load overturn, and 

by destroying habitat elements for fish (pools, riffles, log discharge, etc.). Resource 

management activities would be eliminated if lands were switched from 

development LUDs to Recommended Wilderness or LUD II, reducing the risk of soil 

mass movements. Under all alternatives, Forest-wide standards and guidelines limit 

timber harvest on slopes over 72 percent gradient, as well as on soils classified with 

an extreme mass movement index. 

As part of the effects analysis, the average landslide frequency from the Swanston 

and Marion (1991) study was applied to the estimated harvest levels likely under 

each alternative over the first 15 years of Forest Plan implementation. The 

proposed Forest Plan includes standards and guidelines and mitigation measures 

that were not in effect during the period of the landslide study (e.g., Riparian 

Standards and Guidelines, the removal of extreme hazard soils from the suitable 

land base, and BMPs). The Swanston and Marion (1991) landslide study was 

based primarily on large-scale clearcut logging with almost no buffers. Fewer 

landslides would be expected, on average, under the current or proposed Forest 

Plan. 

For the purposes of this comparison, the life of the Forest Plan (up to about 15 

years) is used because the landslide occurrences reported by Swanston and Marion 

(1991) reflect long-term averages. Landslides typically are associated with storm 

events and large amounts of precipitation, which are highly variable from one year to 

another. For example, widespread landsliding in headwater tributaries following 

basin wide clear-cut logging on Prince of Wales Island was triggered by intense 

rainstorms in 1961 and 1993 (Gomi et al. 2004). The numbers in Table 3.3-4 are 

used to compare the long-term landslide estimates that may result from the 

individual harvest levels proposed under each alternative. Despite the limitations 
3 Environment and Effects

Soils 3-38 Final EIS

listed in the footnotes (i.e., landslide frequencies are anticipated to be lower for each 

alternative than those displayed in the table), Table 3.3-4 provides a means to 

compare the relative level of effects under each alternative. 

Table 3.3-4 

Estimated Maximum Increase in Landslide Frequency over the First 

15 Years of Forest Plan Implementation1

Alternative 

Projected Maximum Acres Old 

Growth Harvested in First 15 Years2

Estimated Maximum Increase in Number 

of Landslides over First 15 Years 

1 26,600 7 

2 81,610 20 

3 108,764 27 

4 186,410 46 

5 152,329 38 

6 148,210 37 

7 242,168 60 1 This table uses the landslide frequency of one landslide per 2,052 acres in harvested and roaded 

areas cited in Swanston and Marion (1991) and subtracts off an estimated 0.289 landslide per 2,052 

acres for unharvested acreas (based on their estimate of landslides being 3.5 times more prevalent in 

harvested vs. unharvested areas), in order to estimate the increase due to harvest and roading. It 

should be noted that Swanston and Marion (1991) measured landslide frequency based on largescale clearcutting of large portions of watersheds that occurred between 1963 and 1983. Almost no 

harvest buffers were implemented during that time. The standards and guidelines protective of soil 

resources that are included in the current and proposed Forest Plans were not implemented. As a 

result, the estimates represent a maximum that likely far exceeds the landslide frequency that would 

likely occur under current and proposed timber management. 2 Based on the acres of old growth scheduled for harvest by the Spectrum model over the first 15 

years. These numbers assume that the maximum allowable acres would be harvested during this 

period, an unlikely scenario. Most likely, fewer acres would be harvested, particularly in the first 

decade. Any harvest would comply with the Forest Plan standards and guidelines, including buffers, 

unstable slope restrictions, smaller opening sizes, and BMPs. 

Alternatives 1, 2, and 3 would have lower landslide potentials, and Alternative 6 

would have a slightly lower landslide potential than under the current Forest Plan 

(Alternative 5). Alternatives 4 and 7 would result in increased potential, with the 

trend of increasing risk by alternative shown in Table 3.3-4. 

Soil conditions could improve with the proposed changes to off-highway vehicle 

(OHV) management under each action alternative. Reflecting new national policy, 

the revised Forest Plan would close the Tongass National Forest to OHV use except 

where designated as open based on resource concerns and other criteria; however, 

the designation of open roads will need to be consistent with ANILCA. This 

approach would likely reduce the localized damage caused by OHV routes. In 

limited parts of the Tongass National Forest, soil degradation from steadily 

increasing OHV use over the last 15 years has been documented (USDA Forest 

Service 2006). Recently developed OHVs have enough power and traction to 

displace several inches of wet soil in a single pass (USDA Forest Service, 2006, 

unpublished). Avoiding routes that cross saturated soils with low-bearing strength 

would prevent ruts, soil compaction, and other resource damages (USDA Forest 

Service 2006, unpublished). OHV routes on the Yakutat Forelands have changed 

wetlands, created chronic soil disturbance, and caused sedimentation (USDA Forest 

Service, 2006, unpublished). By limiting OHV users to defined areas, the revised 

Forest Plan would address these issues before degradation occurred, the preferable 

option both ecologically and financially (USDA Forest Service 2006). 

Cumulative effects to soils would include both the effects discussed above and other 

potential effects related to activities outside of NFS lands. The total area within the 

Tongass National Forest boundary, including both NFS and non-NFS lands, is about 

Cumulative 

Effects 
Environment and Effects 3

Final EIS 3-39 Soils 

17.8 million acres. Of this area, non-NFS lands make up approximately 6 percent 

(1.06 million acres). A high percentage of the productive old growth on the non-NFS 

lands has been or can be expected to be harvested over the next 100+ years (see 

Biodiversity section Cumulative Effects subsection). Other reasonably foreseeable 

future activities on these lands include mining, recreation and tourism, growth of 

human settlements, transportation projects, and energy and transmission projects. 

Management activities on non-NFS lands are not held to the Region 10 soil 

standards; however, BMPs are required under the Alaska Forest Resources and 

Practices Act, including detailed regulations related to providing notification prior to 

timber harvests and managing riparian areas. The state forester must protect 

riparian areas from the significant adverse effects of timber harvest activities on fish 

habitat and water quality. These measures are designed to avoid soil erosion and 

sedimentation near streams. Martin (1996) compared pre- and post-harvest basins 

on non-NFS lands and found short-term effectiveness of these BMPs. Martin (1997) 

evaluated BMP effectiveness, including those designed to reduce soil erosion to 

mitigate turbidity. He found BMPs minimized sediment delivery and effectively 

maintained turbidity at comparable non-harvest levels. Arians (2003) includes 

several studies that compared pre- and post-harvest basins and indicated that 

logging with the BMPs does not result in significant effects to soils that would result 

in stream sedimentation and damage to fish. Despite these BMPs, some landslides, 

soil erosion related to duff removal, and losses in site productivity likely have 

occurred and will continue to occur on non-NFS lands. However, cumulatively, nonNFS lands represent only 6 percent of all of the soil resources in Southeast Alaska 

within the Tongass boundary. Potential impacts to the remaining 94 percent of soil 

resources would be mitigated through implementation of standards and guidelines 

and BMPs associated with each of the alternatives. The 2005 monitoring (USDA 

Forest Service 2005b) found that overall soil and water BMPs were implemented 

and found to be effective in Tongass timber harvest and road construction activities. 

Based on monitoring results, no changes were recommended to Forest Plan 

standards and guidelines for attaining State of Alaska water quality standards. 

Furthermore, effects of harvest on soil resources would ultimately be considered at 

the project-specific levels, ensuring minimal adverse cumulative effects to soil 

resources. 

Similarly, roads are more prevalent on non-NFS lands than on NFS lands. 

Projected future road miles and densities under each alternative on both NFS and 

non-NFS lands are shown in Tables 3.6-8 and 3.6-9 of the Fish section of this 

chapter. In addition to approximately 4,942 total road miles currently on NFS lands, 

an additional 3,762 miles currently exist on non-NFS lands within the Forest 

boundary, and most of these roads are associated with timber harvest activities. 

Road densities are relatively high (2.27 miles per square mile) on non-NFS lands, 

resulting in commitment of soil resources; however, cumulative future road densities 

inside the Forest boundary are considerably lower, ranging from 0.39 mile per 

square mile under Alternative 1 to 0.57 mile per square mile under Alternative 7 (see 

the Fish section for additional information). As described earlier under the 

discussion of the potential direct and indirect effects to soils from roads, at the 

Forest Plan level, the overall difference in roaded area is a good indication of how 

site-specific effects are likely to vary among alternatives. This approach also 

applies to cumulative effects. Standards and guidelines, BMPs, and other relevant 

mitigation measures are applied at the project level to minimize potential adverse 

effects. Under all but Alternatives 4 and 7, the cumulative acres of road surfaces 

would be equal to or less than under the current Forest Plan. Reductions in soil 

productivity losses and soil erosion would correlate with lower cumulative road 

densities. 
3 Environment and Effects

Soils 3-40 Final EIS

Overall, the cumulative effects of considered alternative actions combined with other 

non-NFS lands actions would increase the potential for cumulative effects to soil 

resources. Potential cumulative effects of harvest, road building, and other actions 

would be evaluated on a project-specific basis ensuring that any adverse effects to 

soil resources would be reduced, moderated, mitigated, or eliminated. 

Forest-wide standards and guidelines for the soils resource are the same in all 

alternatives (see the Chapter 4 of the current Forest Plan and the proposed Forest 

Plan), and will apply to all site-specific projects. Forest-wide standards and 

guidelines are followed to mitigate the effects of management activities. They are 

designed to minimize accelerated soil erosion and maintain long-term soil 

productivity. They include soil conservation practices and incorporate the applicable 

BMPs (see Soil and Water Handbook). Annual monitoring (described in Forest 

Service Manual 2554) of BMP implementation and effectiveness helps ensure that 

water quality goals, and standards and guidelines, are met during project 

implementation (see Forest Plan, Chapter 6). 

Mitigation 
Environment and Effects 3

Final EIS 3-41 Water 

Water 

Affected Environment.....................................................................................3-41

Streams, Lakes, and Flow Regimen...........................................................3-41

Water Quality ..............................................................................................3-42

Floodplains..................................................................................................3-45

Riparian Areas ............................................................................................3-45

Watershed Condition ..................................................................................3-46

Water Use...................................................................................................3-47

Direct and Indirect Effects...........................................................................3-47

Environmental Consequences ......................................................................3-47

Cumulative Effects......................................................................................3-48

Affected Environment 

The Tongass National Forest can be characterized by its abundance of water. The 

maritime climate brings precipitation nearly year-round, with the heaviest amounts 

occurring from September through January. Coastal low-elevation rain forests thrive 

in this maritime climate. Thousands of miles of shoreline and hundreds of bays and 

inlets characterize the marine environment of the Tongass. An important 

consideration for all water-related issues is the effect that changes in water flow and 

quality have on important aquatic resources, especially fish. 

The water environment of the Forest can be described in terms of climate, 

streamflow regimen, water quality, floodplains, wetlands, riparian areas, watershed 

condition, and water use. There are literally thousands of watersheds within the 

26,000 square miles that make up the Tongass National Forest. Climate is 

described in the Climate and Air section; other factors are summarized in the 

following subsections. 

Streams and rivers on the Tongass produce a large volume of water per unit of land. 

Much of the flow originates or passes through thousands of small to large lakes. 

Both glacial and non-glacial river and stream systems occur on the Tongass, and 

runoff varies greatly between the two stream systems. Runoff from glacially fed 

streams usually starts in June in response to snow and ice melt, reaching peak 

flows in July and August. Runoff drops rapidly in October and low flows occur from 

December through April. Runoff from non-glacial streams tends to respond to high 

precipitation events; therefore, the highest flows tend to be in October and 

December and the lowest flows between January and March, and mid-May to 

August. Many factors influence how timber management activities may affect runoff, 

and most are site-specific. Roads and timber harvest can affect the amount and 

timing of the runoff. In studies conducted in the Pacific Northwest, factors, 

especially those relating to roads, affect runoff patterns; although, site-specific 

conditions including hillslope gradient, topography, soil type, and rainfall all influence 

the level of effect (Coe 2004). 

Stream channels and lakes are categorized by class based on their fish production 

values. Although there are additional details (see the Glossary for full definitions), 

stream classes are generally defined as follows: 

• Class I streams and lakes have anadromous or adfluvial fish or fish habitat: or, 

high-quality resident fish waters, or habitat above fish migration barriers known 

to provide reasonable enhancement opportunities for anadromous fish. 

Streams, Lakes, 

and Flow 

Regimen 
3 Environment and Effects

Water 3-42 Final EIS

• Class II streams and lakes have resident fish or fish habitat and generally steep 

gradients (6 to 25 percent or higher) where no anadromous fish occur, and 

otherwise not meeting Class I criteria. 

• Class III streams are perennial and intermittent streams that have no fish 

populations or fish habitat, but have sufficient flow or sediment and debris 

transport to directly influence downstream water quality or fish habitat capability. 

• Class IV streams are intermittent, ephemeral, and small perennial channels with 

insufficient flow or sediment transport capability to directly influence downstream 

water quality or fish habitat capability. Class IV streams do not have 

characteristics of Class I, II, or III streams, and have a bankfull width of at least 

0.3 meter (1 foot). 

In addition, the Tongass uses a stream channel classification system based on the 

Alaska Region Channel Type Classification System (Paustian et al. 1992). Streams 

are categorized into channel types, which are grouped into nine process groups, or 

combinations of similar channel types based on major differences in landform, 

gradient, and channel shapes (see Appendix D in the Forest Plan for a full 

description). These are used to assess watershed conditions, fish habitat 

production capabilities, and sensitivity to management activities (see the Fish

section of this chapter for additional information). Approximately 65 percent of the 

stream channels on the Tongass are classified in the high gradient contained 

process group (Table 3.4-1). 

Approximately 44,000 miles of stream have been mapped on the Forest (Table 3.4-

1). There are also streams on the Forest that have not been mapped because they 

require ground surveys to locate. Many of these are small low-flow, high-gradient 

Class III and IV headwater streams, but others contain valuable aquatic habitat. 

Additionally, some 250,000 acres of lakes are present on the Forest lands. 

The State of Alaska sets water quality standards for chemical, physical, and 

biological parameters for waters on National Forest System (NFS) lands. The 

Alaska Department of Environmental Conservation (ADEC) and the Forest Service 

have agreed that the USDA Forest Service is the agency responsible for monitoring 

and protecting water quality on the NFS lands of Alaska for the purpose of meeting 

the Clean Water Act, as amended. Best Management Practices (BMPs), as 

described in the Soil and Water Conservation Handbook (Forest Service Handbook 

2509.22, Region 10 Amendment, July 2006), the Alaska Nonpoint Source Pollution 

Control Strategy, and the Alaska Water Quality Standards (18 AAC 70) together 

form the “Forest Service Alaska Region Water Quality Management Plan,” as 

agreed to in the Memorandum of Agreement dated April 6, 1992 (ADEC and USDA 

Forest Service 1992). With implementation of this Plan, the State of Alaska 

recognizes that the Forest Service BMPs are the primary means to protect water 

quality from nonpoint sources of pollution. In 1997, ADEC determined that the 

Forest Service BMPs meet or exceed the BMPs contained in the Alaska Forest 

Resources and Practices Act and Regulations (11 AAC 95) (Brown 1997). 

Stream Temperature 

Maintaining proper water temperature is critical for the health of aquatic ecosystems. 

Anadromous fish and other aquatic species are sensitive to water temperature with 

very low or high temperatures causing adverse conditions. Often in streams with 

salmon and trout, high water temperature is of greatest concern. Timber harvest 

and road construction have the potential to reduce stream shade and raise water 

temperatures. Forest Plan standards and guidelines minimize riparian harvest (see 

the subsection on Riparian Areas below) in order to maintain stream-side shade. 

Water Quality 
Environment and Effects 3

Final EIS 3-43 Water 

Table 3.4-1 

Mapped Stream Miles by Process Group and Stream Class1

 for each Ranger 

District Group2 

Stream Process Group Class 

Northern 

Ranger 

Districts 

Central 

Ranger 

Districts 

Southern 

Ranger 

Districts Total 

I 236 47 134 416 

II 602 90 129 820 

III 82 70 101 253 

Alluvial Fan 

IV 0 1 1 2 

I 44 11 8 63 

II 0 0 0 0 

III 0 0 0 0 

Estuarine 

IV 0 0 0 0 

I 2,046 600 1,008 3,653 

II 51 119 61 231 

III 1 10 9 20 

Flood Plain 

IV 1 0 0 1 

I 345 212 242 799 

II 77 81 7 165 

III 61 48 10 119 

Glacial Outwash 

IV - 0 - 0 

I 64 75 131 270 

II 2,985 712 2,115 5,812 

III 7,707 4,733 8,783 21,223 

High Gradient Contained 

IV 354 138 291 783 

I 226 148 234 607 

II 15 31 19 65 

III 0 0 0 0 

Large Contained 

IV - 0 - 0 

I 576 366 931 1,873 

II 339 180 193 711 

III 7 35 76 118 

Moderate Gradient 

Contained 

IV 1 0 1 3 

I 755 775 1,147 2,677 

II 312 233 223 768 

III 6 13 50 69 

Moderate Gradient Mixed 

Control 

IV 5 2 5 11 

I 1,338 374 549 2,261 

II 46 71 76 194 

III 4 7 31 41 

Palustrine 

IV 3 1 6 9 

I 56 1 4 61 

II 43 0 0 43 

III 17 0 0 17 

Unclassified3

IV 19 0 - 19 

I 5,684 2,608 4,388 12,680 

II 4,470 1,517 2,823 8,810 

III 7,884 4,916 9,061 21,860 

Total 

IV 382 142 304 828 

Grand Total 

All 

Streams 18,420 9,182 16,576 44,178 1

 Miles are only those currently mapped and in the GIS database excluding lake channels. Additional unmappable streams are 

present, but have not been located through on-the-ground surveys, especially Class 3 and 4 streams that are greatly 

underrepresented in the database. Numbers may not add up precisely because of rounding. See Paustian et al. 1992 for a 

description of the stream process groups and the glossary for a definition of stream classes. 2

 Northern Districts=Admiralty, Hoonah, Juneau, Sitka, and Yakutat; Central Districts=Petersburg and Wrangell; Southern 

Districts=Ketchikan-Misty Fiords, Thorne Bay, and Craig 3 Includes areas such as ice fields, connector streams not field surveyed, braided glacial river channels, culverts, and karst 

Source: GIS database, July 2006
3 Environment and Effects

Water 3-44 Final EIS

An analysis of legacy stream temperature data collected on Prince of Wales Island 

was completed in 2004. From 1997 to 2002, state water quality criteria for stream 

temperature were exceeded during warm weather in both harvested and 

unharvested watersheds (Walters and Prefontaine 2005). In 2004, state water 

quality criteria were exceeded in all three case study watersheds, two of which are 

unharvested (USDA Forest Service 2004c). Konopacky Environmental (1996) also 

did not detect stream temperature increased that could be characterized as differing 

significantly between logged and unlogged watersheds. High stream temperatures 

in Southeast Alaska are likely to occur under natural conditions during warm, 

rainless weather and result in low stream flow periods regardless of watershed 

harvest levels or extent of past riparian harvest. 

Sediment and Other Factors 

Sediment is solid materials that were derived from the natural weathering of rock or 

from erosion of areas modified by man, such as roads, agricultural lands, or urban 

areas. Sediments are carried and deposited by wind, water, and ice, and may be 

transported as either suspended load or bedload in streams. Suspended sediment 

is carried within the water column, while bedload material moves via rolling or 

bouncing along the bottom of the stream or riverbed. Suspended sediment causes 

water to have a turbid or murky appearance. Under natural conditions, the great 

majority of suspended load and bedload transport occurs during storm runoff events. 

Soil mass movements (landslides), streams cutting new channels, and bank erosion 

are the main natural processes creating sediment. Landslides cause large, but 

temporary, increases in suspended and bedload sediments. Stream and riverbed or 

bank erosion may contribute to sediment over long periods of time. Steep terrain 

and large amounts of rainfall make the soil sensitive to erosion if the organic 

material covering the soil is disturbed. High rainfall also makes soils sensitive to 

sediment production by road construction and timber harvest activities. 

In Southeast Alaska, suspended sediment loads in non-glacial streams in 

undisturbed watersheds are very low. Concentrations of suspended sediments 

range from less than 10 parts per million (ppm) in the winter to occasionally over 

100 ppm in the fall during storm runoff periods (Schmeige et al. 1974). Suspended 

sediment in glacial streams is highly dependent on the volume of water flow from 

snow and ice melt. At high flows, concentrations may reach from 200 to more than 

600 ppm; at low flows during winter, suspended sediment concentrations seldom 

exceed 20 ppm (Schmeige et al. 1974). 

ADEC has established numeric criteria for turbidity standards (ADEC 2006a). 

Turbidity in Alaska correlates with suspended sediment, although the exact 

relationship varies by region and stream type (Lloyd 1987, Lloyd et al. 1987) and 

has not been determined in Southeast Alaska. Turbidity data collected during 

culvert installation or road construction suggests few instances where the state 

criteria have been exceeded (USDA Forest Service 2004c). 

Changes in any of the physical or chemical properties of water can directly affect 

water use by people, fish, and wildlife. Sediment input to streams and turbidity are 

the two water quality factors most likely to be affected by alternatives. Other 

factors, such as temperature and dissolved oxygen, are not expected to change 

appreciably by alternative and, therefore, they are not discussed further in this 

section. 

Current road construction methods and culvert installation activities have little 

effects on stream turbidity. The most recent monitoring of turbidity relative to 

various forestry activities have found few exceedances of the state turbidity 
Environment and Effects 3

Final EIS 3-45 Water 

standards (USDA Forest Service 2004, Monitoring reports). Of 12 replacement 

culvert installations monitored in 2004, 10 always met the turbidity standard for 

drinking water and 11 of the sites met the standard for fish propagation within 48 

hours of the construction activity. Typically water returned to less than 5 

nephelometric turbidity unit (NTUs) over background shortly after construction. 

Recent monitoring was conducted to determine effects of road construction 

(including a bridge) on meeting turbidity criteria. The study was done on Upper 

Shaheen Creek in 2004 using the more stringent drinking water criteria. The results 

are preliminary, but suggest some short-term exceedance of the 5 NTU criteria. Of 

50 days of continuous monitoring (when upstream and downstream sites were both 

monitored) , 11 days had some exceedance; of these, 9 were short term (less than 

15 minute spikes in turbidity), while the remaining 2 exceedances were up to 30 

minutes. Similar results were found in 2003, when 32 and 51 of 54 monitored 

culvert installations met drinking water, and fish production turbidity criteria, 

respectively (Monitoring Report summary for 2003) 

Executive Order 11988 directs federal agencies to provide leadership and take 

action on federal lands to avoid, to the extent practicable, the long- and short-term 

adverse impacts associated with the occupancy and modification of floodplains. 

The Forest’s floodplains are typically found in broad, flat, alluvial U-shaped valleys, 

are forested, and usually support plant communities having an overstory of Sitka 

spruce or Sitka spruce and western hemlock. The shrub understory is variable and 

may include blueberry, skunk cabbage, devil’s club, salmonberry, and alder. 

Supporting this vegetation are well-, moderately well-, or somewhat poorly-drained, 

deep mineral soils with thin organic surface layers. Based on channel type 

characteristics, floodplains are associated with 9 percent of the 42,700 linear miles 

of the streams mapped on the Forest and are typically protected through 

identification and designation of riparian management areas and associated 

Riparian Standards and Guidelines. 

Riparian areas include the stream channel and any stream-associated vegetation 

(plants dependent on a continuous source of water), and may include additional 

stream channel features such as floodplains and alluvial fans. Riparian ecosystems 

previously harvested for timber are now in various stages of secondary plant 

succession. With the exception of where the ground is highly disturbed, the species 

composition on these secondary successional riparian areas is very similar to the 

riparian vegetation prior to timber harvest, with Sitka spruce, red alder, and western 

hemlock dominating the tree canopy (USDA Forest Service 1997a). On the more 

disturbed sites, the vegetation is often similar to primary successional species, such 

as what occurs following deglaciation, with red alder the most common component. 

Current management emphasis under the current Forest Plan is to maintain riparian 

areas in mostly natural conditions for fish and other riparian-associated resources. 

Management direction requires no-harvest buffers for Class I, II, and III streams with 

the widths depending on stream channel process groups. In addition, reasonable 

assurance of windfirmness must be provided for buffers, which may or may not 

include additional buffer width depending on site conditions. An evaluation of how 

well reasonable assurances of wind-firm buffers are working in high-gradient 

streams on the Tongass was recently conducted (Paustian et al. 2006). 

Additionally, recent literature was reviewed as part of this study to help assess the 

need for buffers on these streams (Landwehr 2006). Although field survey 

information is preliminary, blowdown has averaged about 5 percent in these buffers, 

which include standard buffers to slope break. The reasonable assurance of windfirm buffer portion could not be determined at most of the sites. Based on the 

relative stability of these buffers, and considering recent literature that helps indicate 

the likely benefit to water and ecology of the systems from these buffers, the 

Floodplains 

Riparian Areas 
3 Environment and Effects

Water 3-46 Final EIS

recommendation by these authors was to retain these wind-firm buffers as part of 

the standards and guidelines. 

Prior to implementation of the current Forest Plan, approximately 66,000 acres of 

riparian productive old-growth forest were harvested, including approximately 295 

acres that are now within Wilderness (USDA Forest Service 1997a). This 

represents about 13 percent of the original 490,000 acres of riparian productive old 

growth (POG) outside wilderness (USDA Forest Service 1997a). Most of this 

harvest, approximately 63,800 acres, took place between 1950 and 1997. This is 

approximately 1,329 acres per year. However, following implementation of the 

current Forest Plan, beginning in 1997, recent harvest in riparian areas has been 

much lower because it has been limited to road crossings (because no other harvest 

is allowed in riparian areas). 

For land within the Tongass National Forest boundary, including all ownerships, 77 

percent of the watersheds were classified as healthy in 1992 (i.e., having watershed 

functions and conditions generally in balance) (USDA Forest Service 1995a). For 

Tongass NFS land in 1992 (excluding other ownerships), 87 percent of the 

watersheds were classified as having satisfactory watershed conditions, 10 percent 

were classified as having declining watershed conditions, and 3 percent were 

classified as having unsatisfactory watershed conditions (USDA Forest Service 

1995b). Watershed evaluation, has continued in recent periods. Assessments have 

included a GIS database evaluation that identified 25 watersheds of concern (USDA 

Forest Service 2001a). Follow-up on these evaluations are underway (Paustian 

2005). The 1997 Forest Plan included increased protection for headwater streams 

and their watersheds. Standards and guidelines considered to be important for 

protection of watersheds by the Alaska Anadromous Fisheries Habitat Assessment 

(USDA Forest Service 1995a) have been implemented Forest-wide. Also, harvest 

and road construction have greatly decreased since the early 1990s (refer to the 

Timber section), and 94 miles of roads have been decommissioned between 1997 

and 2005 (refer to the Transportation and Utilities section); therefore, watershed 

conditions (e.g., sediment input, stream temperature, fish passage) in many 

watersheds on the Tongass are likely to have remained stable or improved, 

although some ongoing impacts remain (e.g., large woody debris input, road and 

hillslope failures). 

There has been about 28,000 acres of harvest in Riparian Management Areas 

across the Tongass (USDA Forest Service 2006a, Tongass Young-Growth 

Management Strategy, Exhibit 7). Approximately 15,000 acres of the total contain 

riparian young-growth stands that will potentially benefit from thinning treatments 

designed to promote future large wood recruitment. Sustained input of large wood 

is necessary to maintain stream channel functions and productive fish habitat 

conditions in Southeast Alaska watersheds. Storing and decommissioning of 

additional roads would improve habitat quality, fish passage, and water quality as 

they are treated. 

ADEC is responsible for providing a list to the U.S. Environmental Protection Agency 

(EPA) of the status of water quality within the state. The state makes a 

determination of which state waters (e.g., streams, rivers, bays) exceed state water 

quality standards and are limited by point and/or non-point sources of pollution, 

which may require additional controls to meet state water quality standards. Waters 

that fit this definition are put on a list as designated under Section 303(d) of the 

Clean Water Act, which is published by the state and sent to EPA. State waters in 

this category are known as waters on the 303(d) list. The most recent list for 2004 

(ADEC 2006b) includes seven water bodies in Southeast Alaska that are directly or 

indirectly impaired due to forest management practices. This includes two water 

bodies (Katlian River and Nakwasina River) listed as impaired for non-attainment of 

Watershed 

Condition 
Environment and Effects 3

Final EIS 3-47 Water 

the sediment and turbidity standards due to harvest activities, including road 

maintenance and riparian harvest. Four locations (Hobart Bay, Schultz Cove, 

Thorne Bay, and Twelve Mile Arm) have marine nearshore bottom areas impaired 

from past log transfer facility operations. One location, Ward Cove, is indirectly 

affected from log processing operations as part of the local pulp mill activity that is 

no longer occurring. All five exceed state residue standards; Ward Cove also 

exceeds dissolved gas standards. However, water quality conditions at sites 

formerly affected by forest practices have been improving because three sites that 

were included on the previous 303(d) 2 years earlier were removed in the latest 

report. These include Cube Cove, East Port Frederick, and Klawock Inlet, which are 

all log transfer facilities. Additionally, part of Ward Cove has been removed due to 

restoration actions related to pulp mill water quality impacts. 

Key water uses on the Forest include public water supply, recreation, growth and 

propagation of fish, and hydroelectric power generation. The Forest supplies 

domestic water for 23 permanent communities, and about 55 Class A and B public 

water systems are located in the vicinity of the Tongass National Forest Boundary. 

Ketchikan, Sitka, and Petersburg have congressionally designated municipal 

watersheds, and another six communities have non-congressionally designated 

municipal watersheds. In addition, water is supplied from the Forest to fish 

hatcheries, industrial sites, and resorts. Hydroelectric generation continues to be 

used in many places throughout the Forest to provide electricity for mining, sawmills, 

communities, and other uses. There are six major power installations on the 

Tongass National Forest: the Snettisham and Gold Creek south of Juneau; Beaver 

Falls, Ketchikan Lakes, and Swan Lake east of Ketchikan; Lake Tyee near the 

Bradfield River; and Blue and Green Lakes south and east of Sitka. Additional 

installations and interties between installations are proposed. The Lands and the 

Transportation and Utilities sections of this chapter address planned hydroelectric 

projects. 

Environmental Consequences 

This section considers the effects of forest management activities on stream flows, 

wetlands, public and private water supplies, water quality, and cumulative effects. 

The effects of timber harvest and roads on fish habitat and riparian resources are 

discussed in the Fish section of this chapter. The effects of sedimentation caused 

by soil erosion and landslides are discussed in the Soils section of this chapter. The 

effects on potential hydroelectric projects are discussed in the Lands section, and 

the effects of log transfer facilities on the marine environment are discussed in the 

Transportation and Utilities section of this chapter. 

Forest management activities affect water quality and quantity, as well as the timing 

of water flows through alteration of soil and watershed conditions. Most watersheds 

are in a state of dynamic equilibrium where changes occur naturally because of 

changes in weather patterns. Because of the overriding influence of climate and 

basin resiliency, changes in streamflow and sediment delivery resulting from 

management activities (e.g., timber harvest) are difficult to measure. 

Water Quantity 

Little is known about the effects of timber harvest and roads on stream flows in 

Southeast Alaska watersheds. However, many studies in the Pacific Northwest 

indicate roads and harvest may affect runoff timing and quantity of peak flow 

depending on many factors, including precipitation, soil depth, lithology, road design, 

hillslope gradient, and topography (Coe 2004). The potential effects of changes in 

Water Use 

Direct and 

Indirect 

Effects 
3 Environment and Effects

Water 3-48 Final EIS

stream flows within watersheds Forest-wide are expected to vary depending on the 

noted factors, as well as the relative amount of harvest and roads and the applicable 

Forest-wide standards and guidelines. The effects from changes in stream flows in 

a particular watershed can only be estimated during project planning, at which point 

the rate of entry into watersheds and locations of proposed roads and harvest units 

would be analyzed. The actual effects on stream flows can only be determined by 

site-specific monitoring. 

Water Use 

The Municipal Watershed Land Use Designation (LUD) is applied to 45,236 acres in 

11 watersheds serving 9 incorporated cities and boroughs (Ketchikan, Petersburg, 

Sitka, Juneau, Wrangell, Kake, Klowock, Craig, and Hydaburg [see the amended 

Forest Plan, Chapter 3, Municipal Watershed under all Alternatives]). All of the 

alternatives would include the same protections to these watersheds. Watersheds 

serving unincorporated communities and other non-municipal water systems would 

be managed under Forest-wide standards and guidelines (see the amended Forest 

Plan, Chapter 4, Soil and Water). These stream locations are designated by ADEC 

as drinking water streams Class A or B, which include municipal and non-municipal 

water intakes. Other than the municipal sites, other streams could be affected by 

Forest Service actions that include harvest and road building in the watersheds 

where these streams are located. While most of the current sites have LUD 

designations that do not allow timber harvest under any alternative, many of the 

watersheds where these sites occur (Class A and B drinking water designations) 

have LUD designations of timber harvest. Among sites with timber harvest LUD 

designation in watersheds with these Class A or B designations, Alternative 1 has 

the least and Alternative 7 has the most. Prior to actions in any of these 

watersheds, the Forest Plan (Chapter 4, Soils and Water Standards) requires the 

Forest Service to conduct a watershed analysis and consult with ADEC as well as 

with owners and operators of public water systems prior to authorizing management 

activities that may cause pollution. 

Water Quality 

Riparian areas, as a component of aquatic and riparian ecosystems, would continue 

to be protected through use of the Riparian Standards and Guidelines under all 

alternatives, which protects water quality parameters such as stream turbidity, 

temperature, and nutrients. Protection for riparian areas would be the same under 

all alternatives at site levels. In addition, the application of BMPs would minimize or 

prevent adverse effects on water quality from the limited amount of riparian area 

within yarding corridors and stream road crossings, and from any non-commercial 

timber harvest that may occur. See the Soils section for further discussion on 

potential affects to water quality. 

One of the main cumulative factors affecting water quantity, use, and quality, in 

addition to actions taken on NFS lands, is ongoing and additional regional land 

development actions on non-NFS lands. These actions, in addition to the various 

effects of the considered alternatives, may have compounding effects on water 

conditions. While BMPs applied on NFS lands would moderate these effects, some 

effects on water may remain, and with the addition of other actions, may increase 

risk to water resources. One of the factors associated with potentially adverse 

effects to water are roads and associated actions such as timber harvest, culvert 

and bridge installation, and potential hazardous substance spills. While the effects 

would vary with location and type of activity, the amount of road miles is a partial 

indicator of cumulative effects region-wide. Table 3.4-2 shows the change in road 

Cumulative 

Effects 
Environment and Effects 3

Final EIS 3-49 Water 

miles on a regional basis, including non-NFS roads. Currently, there are about 

4,941 total road miles (including all authorized and non-system roads) on NFS lands 

and an additional 3,756 miles on non-NFS lands within the Forest boundary. Many 

of these roads are associated with non-NFS timber harvest activities. In general, 

timber harvest activities on non-NFS areas are not as protective of stream riparian 

areas. Reduced protection of these areas has a greater risk of increasing impacts 

to water quality. Therefore, roads constructed on non-NFS lands may be associated 

with greater water quality and quantity impacts per mile of road than on NFS lands. 

Generally, however, the amount of roads may be an indicator of cumulative effects 

on water resources of the Tongass National Forest and adjacent areas; therefore, 

the cumulative effects to water resources would generally be proportional to overall 

changes in road miles. NFS road development under Alternative 1 would have the 

lowest contribution to cumulative effects by increasing total NFS road miles by about 

16 percent over existing conditions; however, road construction on both NFS and 

non-NFS lands together would result in a total increase in road miles of 34 percent 

because non-NFS road development would likely increase substantially. 

Alternatives 4 and 7 would have the largest cumulative effect when including all 

roads, resulting in an increase in road miles equal to about 82 and 92 percent over 

existing conditions, respectively. The other alternatives (2, 3, 5, and 6) would result 

in a cumulative increase in road miles between 49 and 70 percent over existing 

conditions, when both NFS and non-NFS roads are included. 

Table 3.4-2 

Estimated Number of Road Miles on All Lands within the Tongass Forest Boundary 

for Each Alternative after Full Implementation of the Forest Plan (approximately 100+ 

years)1 

 Alternative 

Road Categories Existing 1 2 3 4 5 6 7 

Total New Miles 

on NFS Lands 774 2,079 2,799 4,890 3,874 3,744 5,825 

Total Miles on 

NFS Lands 4,941 5,715 7,020 7,740 9,831 8,815 8,685 10,766 

Total Miles on 

Non-NFS Lands2 3,756 5,970 5,970 5,970 5,970 5,970 5,970 5,970 

Total Miles on All 

Lands 8,697 11,685 12,990 13,710 15,801 14,785 14,655 16,736 1

 Assumes full implementation of Forest Plan at ASQ levels plus future non-NFS harvest. Roads on NFS lands adjusted for 

fall down. 2

 Assumes an increase of 2,214 road miles on non-NFS lands over 100+ years. Annette Island is included because it is 

surrounded by areas within the Forest boundary. 

While less directly tied to water quality and quantity conditions, the amount of timber 

harvest may also be an indicator of cumulative effects to water conditions because 

of potential effects on sediment input, water temperature, stream detritus input, and 

flow patterns. Tree harvest areas in the Tongass National Forest are primarily 

characterized as POG vegetation regions. POG in 1954 accounted for about 34 

percent of the land area within the Tongass National Forest boundary, which 

includes NFS lands as well as state and private lands. Therefore, land disturbance 

related to harvest is primarily limited to a small portion of the total land area. NonPOG areas include areas with small trees, muskeg, or wetlands; all regions where 

streams may be common; and ice fields and rocky mountainous areas where few 

streams may be present. 
3 Environment and Effects

Water 3-50 Final EIS

Table 3.4-3 indicates the cumulative portion of POG area that would be harvested 

within the Forest boundary (including all non-NFS lands) under each alternative, and 

the portion of all lands inside the Forest boundary that would potentially be disturbed 

by timber harvest. (This latter analysis represents an index of overall watershed 

disturbance associated with vegetation removal by timber harvest and does not 

consider roads outside of harvest units, urban areas, etc., which are a minor portion 

of the total disturbance area.) Currently, most (87 percent) of the POG acreage 

within the Forest boundary has not been harvested. Considering all lands inside the 

Forest boundary, 95 percent of the total land base has not been subjected to 

vegetation removal by timber harvest (Table 3.4-3). Alternative 1, including nonNFS harvest, would result in a reduction in POG area to 82 percent of the original 

acreage; 94 percent of all lands inside the Forest boundary would remain 

undisturbed by direct timber harvest. Alternatives 2, 3, 5, and 6 would result in 76 to 

80 percent of the POG remaining; 92 to 93 percent of all lands would remain 

undisturbed by direct timber harvest after over 100 years of projected harvest. 

Alternatives 4 and 7 would have the greatest effect; POG would be reduced to 70 to 

72 percent of the original area; 90 to 91 percent of the total land base would remain 

undisturbed by direct harvest. It is likely some local effects on water quality and, 

possibly, quantity, from all alternatives. On a Forest-wide basis, however, the 

overall effects would be very minor for all alternatives. As noted above for roads, 

lesser riparian protections on state and private lands would have a greater likelihood 

of causing adverse effects to water quality and quantity in watersheds on non-NFS 

lands, which could be compounded if NFS lands are harvested in the same 

watersheds. Potential cumulative effects of harvest, road building, and other actions 

would be evaluated at the project-specific level in order to ensure that any adverse 

effects to water resources would be reduced, moderated, mitigated, or eliminated. 

Table 3.4-3. 

Percent of Original POG Remaining on All Lands within the Tongass Forest 

Boundary and Percent of All Lands inside the Boundary that are Not 

Directly Disturbed by Timber Harvest after Full Implementation of the 

Forest Plan (approximately 100+ years)1

Alternative 

Percent of All Original POG 

Remaining 2

Approximate Percent of All Lands Not 

Disturbed by Timber Harvest 3

Existing 87% 95% 

1 82% 94% 

2 80% 93% 

3 78% 92% 

4 72% 91% 

5 76% 92% 

6 76% 92% 

7 70% 90% 1

 Assumes full implementation of Forest Plan at ASQ levels plus future non-NFS harvest. 2

 Original POG equals about 34 percent of all land area (17,869,000 acres) of this region. 3

 Value represents the percent of all 17,869,000 acres inside the Tongass boundary (plus Annette Island) that 

would be disturbed by timber harvest and is used as an index of overall watershed disturbance associated 

with timber harvest. It does not include the acreage of other forms of ground disturbance (e.g., roads, towns) 

beyond the harvest of POG. 

The potential for future climate change is a factor that could affect water quality and 

quantity conditions on the Tongass. Some of the models developed for the region 

predict both changes in precipitaion and air temperature. The details of recent 

climate models (see the Cumulative Effects subsection in the Fish section) project 

slight decreases in summer rainfall (about 10 percent) and increased temperature. 
Environment and Effects 3

Final EIS 3-51 Water 

Southeast Alaska is characterized by high rainfall, so small reductions have limited 

potential to significantly reduce stream flows. Streams, both in harvested and 

unharvested watersheds, have occasionally been documented with brief periods of 

temperature standard exceedances. Theoretically, if air temperature changes were 

large enough, these exceedances could become more frequent. Currently there are 

no 303(d) streams listed for temperature exceedance. Whether temperature 

changes would be large enough to cause changes to this level are unknown. 

However, in the short term that the amended Forest Plan will be in place before 

being modified again (likely 10 to 15 years), large magnitude changes in both 

stream flow and stream temperature are hightly unlikely. In summary, there is 

general agreement that the climate is warming and that summer precipitation is 

likely to decline. However, there is considerable uncertainty surrounding specific 

predictions of when and the magnitude, and even more uncertainty regarding the 

effect of these changes on water quantity and quality. 
3 Environment and Effects

Water 3-52 Final EIS

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3 Environment and Effects

Final EIS 3-53 Wetlands 

Wetlands 

Affected Environment................................................................................3-53

Definition and Regulatory Aspects............................................................3-53

Wetland Classification...............................................................................3-53

Wetland Mapping and Distribution............................................................3-54

Environmental Consequences..................................................................3-55

Direct and Indirect Effects.........................................................................3-55

Cumulative Effects ....................................................................................3-58

Affected Environment 

The U.S. Environmental Protection Agency (EPA) and the U.S. Army Corps of 

Engineers (Corps) jointly define wetlands as “those areas that are inundated or 

saturated by surface or groundwater with a frequency and duration sufficient to 

support, and that under normal circumstances do support, a prevalence of 

vegetation typically adapted for life in saturated soil conditions. Wetlands generally 

include swamps, marshes, bogs, and similar areas.” Wetlands are considered to be 

ecologically important for the physical, biological, and chemical functions they 

provide. The functions include flood flow moderation, groundwater recharge and 

discharge, wildlife and fish habitat, and water quality protection. 

The Corps’ Wetlands Delineation Manual (Experimental Laboratory 1987) provides 

the standards for determining areas of wetlands and deepwater habitats. Land 

areas are defined as wetlands when soil, hydrology, and vegetation all meet the 

technical criteria for establishing wetlands. 

For federal regulatory purposes, wetlands are considered a subclass of Special 

Aquatic Sites (40 Code of Federal Regulations [CFR] Section 230.3) and have been 

deemed Waters of the United States (33 CFR 328.3). All waters of the United 

States are subject to regulation through the Clean Water Act by the Corps and EPA. 

Sections 404 and 401 of the Clean Water Act were created specifically with the 

intent “to restore and maintain the chemical, physical, and biological integrity of our 

Nation’s waters.” Executive Order 11990, as amended (42 U.S.C. 4321 et. seq.), 

requires federal agencies “to avoid...adverse impacts associated with the 

destruction or modification of wetlands...wherever there is a practicable alternative” 

and to “include all practicable measures to minimize harm to wetlands.” Further, the 

agencies are required to preserve and enhance the natural and beneficial values of 

wetlands in carrying out their responsibilities. 

The classification system, as described below, is based on U.S. Fisn and Wildlife 

Service’s (USFWS’s) classification of wetlands and deepwater habitats of the United 

States, developed by Cowardin et al. (1979). 

Palustrine wetlands include the vegetated wetlands traditionally referred to as 

marshes, swamps, bogs, fens, and prairies. They include all nontidal wetlands 

dominated by trees, shrubs, persistent emergent plants, mosses or lichens, and all 

such wetlands that occur in tidal areas where salinity due to ocean-derived salts is 

below 0.5 percent. Palustrine wetland classes on the Tongass include emergent 

wetlands (including peatlands), scrub-shrub wetlands, and forested wetlands. 

Classes are described in the following paragraphs. 

Forested class. Over half (53 percent) of the National Wetland Inventory (NWI)-

mapped wetland acres on the Tongass are forested wetlands. Vegetation ranges 

from scrubby mixed conifer forests (greater than 20 feet high) to moderately 

Definition and 

Regulatory 

Aspects 

Wetland 

Classification 
3 Environment and Effects

Wetlands 3-54 Final EIS

productive mixed conifer, western, or mountain hemlock stands. Shrubs and forbs 

dominate the understory. 

Emergent class. Approximately 25 percent of the NWI-mapped wetland acres are 

emergent. The emergent class is characterized by erect, rooted herbaceous plants, 

and mosses and lichens. Peatlands (muskegs) are included in the emergent class 

of wetland area on the Forest. In Southeast Alaska, all relatively open bogs that 

have a groundcover high in sphagnum mosses and/or sedges are called “muskegs,” 

and are a type of peatland. 

Scrub-Shrub class. Approximately 13 percent of the NWI-mapped wetland acres 

are scrub-shrub. This class is the most vegetatively varied wetland class in 

Southeast Alaska. Plant species may include true shrubs, young trees, and tree 

and/or shrubs that are small or stunted because of environmental conditions. 

Scrub-shrub wetlands are associated with three broad wetland plant communities: 

scrub-shrub alder/willow, scrub-shrub evergreen/emergent, and forested scrubshrub evergreen/emergent. 

Lacustrine wetlands include all permanently flooded lakes, reservoirs, and tidal 

lakes with ocean-derived salinities below 0.5 parts per thousand. Approximately 5 

percent of the NWI-mapped wetland acres are lacustrine. 

Estuarine wetland system. Estuarine wetlands are those areas that are 

predominantly intertidal, and are those parts of the rivers or streams or other bodies 

of water having an unimpaired connection with the open sea, where the sea water is 

diluted with freshwater derived from land drainage. Less than 2 percent of the NWImapped wetland acres are estuarine. 

Riverine wetland system. The riverine wetland system includes all channelcontained streams and rivers. These areas are bounded by uplands, channel 

banks, or palustrine wetlands dominated by trees, shrubs, emergent mosses or 

lichens. In braided streams, the riverine wetland system is bounded by the banks 

forming the outer limits of the depression within which the braiding occurs. Less 

than 2 percent of the NWI-mapped wetland acres are riverine. 

On the Tongass, wetlands may be found from sea level to alpine elevations, and may 

include estuaries and riparian areas. Wetland acreage shown in Table 3.5-1 is from 

the NWI, which is available through USFWS. The NWI database wetland 

identification map is based on geography, visible hydrology, and vegetation as seen in 

high altitude imagery (USFWS 2006). 

Table 3.5-1 

Mapped Acres of Wetlands on the Tongass National Forest by Wetland 

System and Class 

Wetland Systems Wetland Classes Acres 

Palustrine Forested 2,123,440 

Emergent (including peatlands/muskegs) 1,009,777 

 Scrub-shrub 535,325 

Palustrine - undistinguished 51,675 

Lacustrine 181,746 

Estuarine 64,792 

Riverine 46,427 

Marine 9,092 

Total Wetlands 4,022,272 

Source: National Wetland Inventory database, USFWS 2006. 

Wetland Mapping 

and Distribution 
3 Environment and Effects

Final EIS 3-55 Wetlands 

Environmental Consequences 

The physical, biological, and chemical integrity of wetlands in the Tongass is 

affected mainly through timber harvest operations, which include the construction 

and maintenance of roads, landings, stream crossing structures, marine access 

points, and log transfer facilities (LTFs). The magnitude of timber harvest-related 

effects to wetlands depends, in part, on the intensity, location, and duration of the 

timber harvest activity or road construction. 

Limited research studies have been conducted on the effects of timber harvest or 

road building on wetlands in Southeast Alaska. The research on the effects of 

harvest on wetland systems have been primarily focused on regeneration of trees 

(Julin and D’Amore 2003, Duncan 2002). Studies on road construction on wetland 

sites have been focused on the effects to hydrology, and only a few wetland sites 

were studied (Glaser 1999, Kahklen and Moll 1999, McGee 2000). Wetlands are 

complex natural systems and these few studies may not represent the breadth of 

the potential effects to wetland functioning that could occur across the Tongass 

National Forest. Additionally, processes in a complex natural system, such as 

regrowth of a forest after harvest, contain random components and are not 

predictable at every scale or for every location. 

Silvicultural operations, such as harvesting trees, are generally exempted from Corps 

permitting requirements. The construction or maintenance of forest roads in support 

of silvicultural practices, and temporary roads for moving mining equipment, are also 

generally covered under this exemption for the discharge of dredged or fill material 

into waters of the United States. This exemption is contingent on the construction and 

maintenance being conducted in accordance with the Corps’ Best Management 

Practices (BMPs) as stated in 33 CFR 323.4(a)(6). These practices have been 

incorporated into BMP 12.5 of the Alaska Region’s BMP Handbook (Forest Service 

Handbook 2509.22). 

In each of the seven alternatives, the Forest-wide standards and guidelines (including 

BMPs) would be applied to activities in and around wetlands. The standards and 

guidelines that apply to wetlands are the same for all alternatives. They provide 

direction to avoid development activities in wetlands to the extent feasible, minimize 

effects on wetlands, and locate and design roads to minimize effects on wetlands. 

Project-level analysis and planning would be used to avoid construction in wetlands, 

and would provide site-specific plans to minimize effects. 

Tree harvesting on wetland sites would have direct effects on the sites themselves 

and indirect effects on adjacent or nearby wetlands. The effects would include 

potentially altering hydrology, changing nutrient pathways, delivering sediment 

(which can diminish water quality), changing plant species composition and growth, 

and reducing shading. Harvesting trees in wetlands is not expected to convert 

wetlands to uplands. However, harvest would result in a short-term reduction in 

hydrologic and biogeochemical wetland functions that begin to return as soon as 

there is tree revegetation. The habitat functions provided by forest areas may 

require more time and forest regrowth to return. Habitat values for many species 

using forested habitat are discussed in the Wildlife section of this chapter. 

In Southeast Alaska, forested wetlands have been found to successfully regenerate 

and grow into dense, differentiated stands after clearcutting (Julin and D’Amore 

2003, Duncan 2002). Some of the habitat functions are dependant on, or related to, 

characteristics of the old-growth ecosystem, which would not develop over the life of 

the Forest Plan (10 to 15 years). 

According to a study on regeneration of forested wetlands, tree growth was slow in 

Histosols (wet, organic soils), but it proceeded regularly and exceeded the minimum 

USDA Forest Service volume-production standard for commercial timberland (Julin 

Direct and 

Indirect Effects 
3 Environment and Effects

Wetlands 3-56 Final EIS

and D’Amore 2003). Revegetation of forested wetland sites is expected to occur in 

the same timeframe as other forested sites, usually within 3 to 5 years. Site quality 

on wetland soils, however, may be lower than on sites with better drainage, and 

may require additional time for trees to reach merchantable size on wetlands 

compared to drier sites. 

Construction of roads within wetlands permanently removes the wetland area and 

its functions under the roadbed itself. Additionally, crossing wetlands with roads 

without adequate provision for cross-drainage could lead to sedimentation from road 

construction or changes in hydrologic patterns. 

There are approximately 1,079 existing road miles on wetlands on the Tongass, 

including non-system roads and closed roads. This represents 22 percent of the 

4,941 total road miles. Table 3.5-2 shows the road miles by wetland classification 

that exist on the Tongass. The majority of these roads were constructed as part of 

forestry activities. There have been limited research studies done on the effects of 

forestry roads constructed in the past on wetlands or uplands in the Tongass 

National Forest. The results of the wetland and upland studies on the Tongass 

suggest that the hydrologic effects of roads remain within a few meters of the road 

(Glaser 1999, Kahklen and Moll 1999, McGee 2000). The results are similar to 

studies done in other areas with similar climates (cool, moist, and year-round 

precipitation). Researchers have studied the effects of ditching on peatlands in 

northern climates. In northern England, they found that the measurable effects of 

ditches on peatland hydrology were limited to less than 3 meters from the ditches 

(Stewart and Lance 1991, Coulson et al. 1990). 

Table 3.5-2 

Existing Roads and Maximum Miles of New Roads in Wetlands by 

Alternative after 100+ Years1 

Palustrine Wetlands 

Alternatives Forested 

ScrubShrub

Emergent 

(including 

peatlands/ 

muskegs) 

Lacustrine 

Wetlands

Estuarine 

Wetlands

Riverine 

Wetlands

Total 

Wetlands

1 192 5 29 0 0 0 226 

2 492 29 86 0 0 0 608 

3 683 45 121 0 0 0 849 

4 1,363 97 212 0 33 0 1,680 

5 1,001 72 166 0 2 0 1,240 

6 972 68 163 0 0 0 1,204 

7 1,674 116 238 0 61 0 2,048 

Existing Roads 807 56 201 1 10 4 1,079 1

 Totals may not appear to sum correctly due to rounding. 

 Source: NWI database (USFWS 2006) and Tongass National Forest GIS database. 

Reconstruction of a road for timber harvest maintains the original investment and 

makes it suitable and safe for the intended use. Reconstruction involves 

rehabilitation of the original roadbed. It can include cleaning ditches, replacing 

drainage structures, reinstalling bridges, and grading and shaping. Generally, 

reconstruction of existing roadbeds for timber harvest would not add impermeable 

surface to wetlands. However, some reconstruction can include upgrading a road 

and widening the roadbed. In the Forest-Level Roads Analysis, a few roads, 

specifically on Prince of Wales Island, have been recommended for upgrading and 

widening the roadbed (USDA Forest Service 2003c). Widening an existing roadbed 

in wetlands would add to the impermeable surface and increase the total effects to 

wetlands. The recommendations in the Forest-Level Roads Analysis would be the 

same for all alternatives. The estimated road miles to be reconstructed would vary 
3 Environment and Effects

Final EIS 3-57 Wetlands 

by alternative, however, ranging from 925 total miles under Alternative 1 to 2,371 

miles under Alternative 7. Alternatives 2 through 6 would reconstruct an estimated 

1,784 to 2,100 total road miles (see Table 3.12-2 in the Transportation and Utilities

section). 

Some activities in road reconstruction have potential to affect wetland hydrology, 

such as replacing drainage structures or cleaning road ditches. This may have a 

positive or negative effect on wetland hydrology, depending on the condition of the 

existing road in the wetland. Road maintenance can include reconditioning the 

original road template, grading the road surface, cleaning roadside ditches, and 

removing vegetation that may encroach upon the road or block vision. In general, 

this would have no effect, or it could improve wetland hydrology in areas where 

drainage has become blocked. 

The difference between alternatives in effects to wetlands generally falls within two 

categories: 1) short-term or long-term effects due to timber harvest, and 2) loss of 

wetland acres and function due to road construction. Acres of harvest and miles of 

roads proposed in wetlands can be used to provide comparisons between 

alternatives. However, actual acres of harvest in wetlands are likely to be lower, 

particularly in scrub-shrub and emergent wetlands, when acres are dropped in units 

with poor volume. Miles of road would likely be less than shown in this analysis 

because road layout for individual projects would avoid wetlands to the extent 

feasible, as required in the Forest-wide standards and guidelines. Also, there are 

standards and guidelines to protect beach and estuarine, riverine, and lacustrine 

areas. The beach and estuary fringe, an area of 1,000 feet slope distance around 

all identified estuaries and from all saltwater shorelines, is classified as unsuitable 

for timber activities and roads are discouraged. Riparian area protection varies 

depending on the classification of the stream. The Forest-wide standards and 

guidelines include a restriction on programmed timber harvest in riparian 

management zones and within 100 feet of Class I fish-bearing streams as well as 

Class II streams that flow into Class I streams. These standards and guidelines 

would provide further protection for wetlands that occur in estuarine, riparian, and 

lacustrine areas. 

Tables 3.5-2 and 3.5-3 show the proposed maximum miles of road and acres for 

harvest under the alternatives. Alternative 5, the No-Action Alternative, would 

conduct harvest activities on a maximum of 123,000 acres and construct a maximum 

of 1,240 new miles of roads in wetlands. Alternatives 1 and 2 would maintain the 

most acres of undisturbed forest with less risk of adverse effects to wetlands due to 

harvest. Alternatives 1 and 2 include harvesting on approximately 18 and 52 percent 

of the wetland acreage proposed in Alternative 5, respectively. Alternatives 1 and 2 

also propose constructing approximately 18 and 50 percent of the road miles in 

wetland proposed by Alternative 5, respectively. Alternative 3 is in the middle of the 

alternatives in terms of harvest acres and road construction in wetlands. It would 

include harvest activity on 71 percent of the acres in wetlands shown in Alternative 5 

and construct 68 percent of the road miles. Alternative 6 proposes slightly less 

harvesting and road construction (97 percent of Alternative 5 for both). Alternatives 

4 and 7 propose the highest level of harvest and road construction in wetlands. They 

would include approximately 36 and 65 percent more acres of harvest in wetlands 

than in Alternative 5, respectively, and 35 and 65 percent more miles of roads in 

wetlands to achieve that harvest, respectively. 

Therefore, over time, Alternatives 7 and 4 would have a higher risk of direct and 

indirect effects to wetlands due to harvest and road work than Alternative 5, the 

current Forest Plan. Alternatives 1 and 2 would have the least risk of effects to 

wetlands. The acres of harvest and miles of road construction for Alternative 3 

would be intermediate and its potential to affect wetlands would be somewhat lower 

than Alternative 5, while Alternative 6 would have slightly lower effects. 
3 Environment and Effects

Wetlands 3-58 Final EIS

Table 3.5-3 

Maximum Harvest Area in Mapped Wetlands by Alternative before 

after 100+ Years of Full Implementation1 

Palustrine Wetlands 

Alternative Forested 

ScrubShrub 

Emergent 

(including 

peatlands and 

muskegs) 

Lacustrine 

Wetlands

Estuarine/

Marine2

Wetlands

Riverine 

Wetlands

Total 

Wetlands

1 19,604 399 1,921 4 0 8 21,936 

2 55,605 2,096 5,975 15 0 47 63,737 

3 76,066 3,397 8,452 23 2 51 87,991 

4 144,981 7,237 14,269 60 238 86 166,871 

5 106,507 5,333 11,179 35 11 77 123,142 

6 103,423 5,076 10,976 37 2 68 119,583 

7 178,142 8,644 16,048 67 448 91 203,440 1

 Totals may not appear to sum correctly due to rounding. 

2

 Less than 50 acres mapped as marine wetlands occur in Alternatives 4 and 7 only. 

 Source: NWI database, USFWS 2006; Tongass National Forest GIS database. 

When considering effects to wetlands, it is important to look at both the land outside 

the National Forest System (NFS) lands and the cumulative effects of past, present, 

and reasonably foreseeable future activities. Individual wetlands provide important 

physical, biological, and chemical functions, and are not isolated from other 

resources when viewed on a larger scale. Surface and subsurface water, along 

with many organisms, move through the landscape. As discussed in the direct and 

indirect effects section, changes to or loss of functions in an individual wetland can 

have effects that extend beyond individual wetlands as they contribute to the overall 

functioning within a watershed and landscape. 

Each landscape area or watershed has different physical, chemical, and biological 

characteristics and vegetation patterns. The significance of an addition to 

cumulative effects from a change in an individual wetland would depend on the 

amount and type of disturbance in the analysis area, wetland locations and 

distribution in the watersheds, the distance to other wetlands and waterbodies, and 

connectivity of hydrology and habitat between them. Assessing cumulative effects 

to wetlands will be done for individual projects for the relevant analysis area as part 

of the National Environmental Policy Act process in all alternatives. However, past 

plus expected harvest and road construction for forestry and other uses on all land 

ownerships can be used to compare the risk of the alternatives adding to cumulative 

effects. 

Non-NFS lands comprise approximately 6 percent of the lands within the Tongass 

National Forest boundary and 22 percent of Southeast Alaska. Silviculture on nonNFS lands are generally exempt from the Corps’ permitting requirements contingent 

on the construction and maintenance of roads being conducted in accordance with 

the general Corps’ BMPs as stated in 33 CFR 323.4(a)(6). Timber harvesting on 

state, municipal, and private land is also governed by the Alaska Forest Resources 

and Practices Act of 1979 (AS 41.17). Alaska Forest Resources and Practices 

Regulations (Alaska Department of Natural Resources [ADNR] 2004) includes 

regulations designed to prevent adverse impacts to fish habitat and water quality 

from timber operations. The regulations are less extensive than the standards and 

guidelines that direct activities on the Forest. The state regulations provide direction 

to avoid and minimize road building, sedimentation, establishment of landings, and 

damage to vegetative cover when yarding across marshes and non-forested 

muskegs. The regulations also provide buffers for forested wetlands if classified as 

anadromous water bodies or tributaries to anadromous water bodies. Harvest and 

associated activities are not specifically regulated on forested wetlands that are 

otherwise classified. 

Cumulative 

Effects 
3 Environment and Effects

Final EIS 3-59 Wetlands 

Timber harvest can alter wetland function and type but is not expected to convert 

wetlands to uplands. The hydrologic and biogeochemical functions begin to return 

as soon as there is tree revegetation, but the habitat functions provided by forested 

areas may take longer and more forest regrowth to return. Some of the habitat 

functions are dependent on, or related to, characteristics of the old-growth 

ecosystem, which will not develop during the life of the Forest Plan (10 to 15 years). 

Therefore, the effects of a project may add to cumulative effects to wetlands or their 

functions, particularly habitat functions in an area. Habitat and habitat changes are 

discussed in greater depth in the Biodiversity section. 

To compare the potential for cumulative effects due to harvest on wetlands, harvest 

was analyzed on lands of all ownerships within the Tongass Forest Boundary (plus 

Annette Island, which is surrounded by the Forest). There are approximately 17.87 

million acres of land inside the Forest boundary. Approximately 30 percent of that 

land is currently in productive old growth (POG). Approximately 13 percent of the 

original POG on all ownerships in this area has been harvested through 2006. 

Thus, approximately 87 percent of POG on all ownerships is remaining. The 

percent of POG remaining on NFS lands is higher than for non-NFS lands (92 and 

66 percent, respectively) due to the concentrated timber harvest areas on non-NFS 

lands. Looking at all land ownerships within the Forest boundary, the POG 

remaining in 100 years under full implementation of the Forest Plan would be 

greatest for Alternative 1, followed by Alternatives 2, 3, 6, 5, 4, and 7 in that order 

(Table 3.5-4). Therefore, the risk of cumulative effects to wetlands due to harvest 

would follow that same order. 

Alteration of water flow in wetlands through increases in impervious surfaces 

reduces the time that water resides in wetlands or streams in a watershed and can 

lead to more severe flooding or more dry spells in streams. The effect of a road on 

an individual wetland, when added to other alterations to the hydrology in an area, 

could result in water flow alterations. In the Tongass, the impervious surfaces are 

generally forestry roads. These can be used to examine cumulative effects. 

Table 3.5-4 

Cumulative Percent of Original POG Remaining on All Ownerships in 

2006 and Estimated Minimum Percent Remaining after 100+ Years1

 for 

All Lands within the Tongass Forest Boundary2

Remaining POG after 100+ Years as a Percent of Original POG 

Alternative 

Remaining POG on 

All Ownerships in 

2006 as a Percent of 

all Original POG 1 2 3 4 5 6 7 

87% 82% 80% 78% 72% 76% 76% 70% 1 Assumes full implementation of Forest Plan at ASQ levels plus future non-NFS harvest. 2 Annette Island is included because it is surrounded by areas within the Forest boundary. 

 Source: Tongass National Forest GIS database. 

Road density is greater on the non-NFS lands within the Forest boundary than on 

the Tongass NFS lands due to concentrated harvest and more populated areas. 

Road density averages 0.19 mile per square mile on the Tongass NFS and 2.19 

miles per square mile for non-NFS lands. The average for land of all ownerships is 

0.31 mile per square mile; however, those are averages over a very large area and 

there is considerable variability. Table 3.6-9 in the Fish section of this chapter 

(percent frequency of Value Comparison Units [VCUs]) by road density categories 

for the Tongass and land of all ownerships) shows the large variability in road 

density across the Tongass. VCUs are roughly equal to a watershed.

No documentation was found regarding a threshold at which impervious surfaces 

interact to an extent to have a qualitatively or quantitatively different effect for 

wetlands in Southeast Alaska. In Washington State, a literature search to 
3 Environment and Effects

Wetlands 3-60 Final EIS

determine the best available science with which to evaluate cumulative effects of 

activities in wetlands revealed that there is disagreement about a specific threshold. 

The opinions in one report about the threshold to use, range from 10 to 20 percent 

impervious surfaces within a watershed. There were also scientists whose opinion 

was that specific thresholds were not accurate and that deterioration began 

immediately (Sheldon et al. 2005). The most conservative idea is that there is no 

accurate threshold, and that deterioration begins immediately. While cumulative 

effects will be analyzed during project analysis, comparisons can be made about the 

risk of adding to cumulative effects on wetlands associated with each alternative. 

Table 3.5-5 shows the average future road density for each alternative for all 

ownerships. It includes forestry and other roads proposed for construction on NFS 

land and reasonably foreseeable roads on non-NFS lands. Alternatives 7 and 4 

would result in the highest average road density. Therefore, in those alternatives, 

there is a greater risk of management actions adding to cumulative effects to 

wetlands. The average road densities for Alternatives 3, 5, and 6 are intermediate 

and their risk of cumulative effects would fall in the mid-range when compared to the 

other alternatives. Alternatives 1 and 2 would have the lowest risk of cumulative 

effects due to an individual project. 

Table 3.5-5 

Existing and Estimated Future Maximum Road Density (miles per square 

mile) for NFS Lands and for All Ownerships within the Forest Boundary by 

Alternative after 100+ Years1

Alternative 

 Existing 1 2 3 4 5 6 7 

National 

Forest Land 0.19 0.22 0.27 0.30 0.38 0.34 0.33 0.41 

All 

Ownerships 0.31 0.42 0.47 0.49 0.57 0.53 0.52 0.60 

1 Assumes full implementation of Forest Plan at ASQ levels plus future non-NFS harvest. Annette Island is included because it is surrounded by areas within the Forest boundary. 

 Source: Tongass National Forest GIS database 

Other activities also need to be considered when determining cumulative effects for 

past, present, and foreseeable future effects to wetlands. They include mineral 

extraction, transmission line projects, hydroelectric projects, transportation 

developments, expansion of cities, and recreational site development. Existing 

mining is at Greens Creek on Admiralty Island, Berner’s Bay north of Juneau, and 

other locations. Given the level of world pricing, an increase in exploration is 

expected. There are also several regional transportation projects and regional 

energy and transmission projects planned for construction. Each of these activities 

can include clearing vegetation and disturbing wetlands with construction and 

maintenance. Therefore, the activities have the potential to affect wetlands and their 

functions and would be considered during individual project analysis. The effects of 

these projects would be the same for each alternative. 

Changes in Southeast Alaska’s climate (discussed in the Climate and Air section) 

could affect the size, type, and functions of wetlands and, therefore, could add to 

cumulative effects. While the models do not fully agree on the climate change 

predictions for Southeast Alaska, they generally predict warmer weather, with more 

winter rainfall, less snowfall, and a decrease in summer rain in some areas. That 

would likely result in lower soil moisture due to increased evaporation during 

warmer, dryer summer months. Also, a precipitation shift from snow to rain could 

lead to more water running off the landscape rather than being stored as snow. 

Snowmelt is an important water source for wetlands in the spring and summer. 
3 Environment and Effects

Final EIS 3-61 Wetlands 

Thus, increased evaporation and less water storage could lead to drier meadows or 

bogs and, possibly, fewer wetlands. 

Changes in temperature could favor some plants and stress others. Longer growing 

seasons with warmer temperatures would likely result in faster growth. Those 

conditions would also favor more decomposition that could lead to changes in the 

organic matter in soils and bogs. Changes in climate could shift wetlands from 

being carbon sinks to sources of aerial and aquatic carbon due to more rapid 

decomposition during warmer summers. All of these factors could lead to changes 

in wetland types, such as shifts in vegetation from herbaceous to shrub, from shrubs 

to trees, or from bogs to more productive forests. However, as discussed in the 

Climate and Air section, the models do not always agree and the predictions for 

total precipitation in portions of Southeast Alaska differ. 
3 Environment and Effects

Wetlands 3-62 Final EIS

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Environment and Effects 3 

Final EIS 3-63 Fish 

Fish 

Affected Environment................................................................................3-63

Fish Habitat ...............................................................................................3-66

Fish Habitat Enhancement........................................................................3-72

Fisheries Habitat Enhancement Opportunities .........................................3-74

Fish Management Indicator Species.........................................................3-74

Threatened and Endangered Fish Species ..............................................3-75

Essential Fish Habitat (EFH).....................................................................3-76

Sensitive Fish Species ..............................................................................3-76

Invasive Aquatic Species ..........................................................................3-77

Environmental Consequences..................................................................3-78

Direct and Indirect Effects.........................................................................3-78

Species Assessments...............................................................................3-87

Cumulative Effects ....................................................................................3-90

Affected Environment 

Fish and the aquatic resources on the Tongass National Forest provide major 

subsistence, commercial, and sport fisheries, as well as support traditional and 

cultural values. Abundant rainfall, streams with glacial origins, and watersheds with 

high stream densities provide an unusual number and diversity of freshwater fish 

habitats. These abundant aquatic systems of the Tongass provide spawning and 

rearing habitats for the majority of fish produced in Southeast Alaska. Maintenance 

of this habitat, and associated high-quality water, is a focal point of public, state, and 

federal natural resource agencies, as well as user groups, Native organizations, and 

individuals. 

Approximately 12,700 stream miles and 4,100 lakes and ponds are mapped as 

Class I water bodies (based on Tongass GIS data); these water bodies are 

considered to be anadromous or high-value resident fish habitat. Another 8,800 

stream miles and 4,700 lakes and ponds are mapped as resident fish habitat. Most 

of the Forest's streams and rivers empty into bays or estuaries, which are important 

during some life stages of anadromous species, as well as for many saltwater fish 

species. Marine invertebrates, such as clams and crabs, are commonly found in the 

estuaries and nearshore marine environment of Southeast Alaska. Some marine 

animals, including, Dungeness (Cancer magister), butter clams (Saxidomes 

giganteus), and other benthic and epibenthic organisms may be affected by upland 

management activities, such as timber harvest, road construction, and related log 

transfer and storage facilities. 

Subsistence, commercial, and sport fisheries are all important to the way of life for 

Southeast Alaskan residents. Sport fishing is a favorite activity of residents and 

visitors. Hatcheries, and the enhancement of wild fish, among other aquaculture 

projects, contribute to resource availability and abundance. The primary fish 

species harvested in these fisheries are shown in Table 3.6-1. 
3 Environment and Effects

Fish 3-64 Final EIS

Table 3.6-1 

Commonly Harvested Sport, Subsistence, and Commercial Fish

Species1 Sport Subsistence Commercial 

Pink salmon (Oncorhynchus gorbuscha) X X X 

Chum salmon (Oncorhynchus keta) X X X 

Coho salmon (Oncorhynchus kisutch) X X X 

Sockeye salmon (Oncorhynchus nerka) X X X 

Chinook salmon (Oncorhynchus 

tshawytscha) 

X X X 

Cutthroat trout (Oncorhynchus clarki) X X 

Rainbow trout and steelhead 

(Oncorhynchus mykiss) 

X X 

Dolly Varden char (Salvelinus malma) X X 

Eulachon smelt (Thaleichthys pacificus) X 1

 Alternate names commonly used for the same species include pink or humpback; chum or dog; coho 

or silver; sockeye or red; Chinook or king; and eulachon, hooligan, or candlefish.

Commercial fish harvest in the waters of Southeast Alaska can fluctuate widely from 

year to year. For example, salmon harvest in Southeast Alaska averaged 

approximately 50 million fish between 1935 and 1940. It then declined steadily to 

less than 20 million fish in 1950. From 1950 to 1975, harvests were generally low, 

falling below 6 million fish in 1975 (Figures 3.6-1 and 3.6-2). Since 1975, harvest 

has been increasing in Southeast Alaska. Recent years where record harvest 

occurred for each of the main species were: Chinook (2004), sockeye (1993), coho 

(1994), pink (1999), and chum salmon (1996) (Bachman et al. 2005). Overall record 

harvest of total salmon occurred in 1999, when 98 million salmon were captured 

(Bachman et al. 2005). Overall, recent commercial salmon harvest (since early to 

mid-1990s) has remained high (Figures 3.6-1 and 3.6-2). 

Source: Bachman et al. 2005 

Figure 3.6-1 

Commercial Harvest of Chinook, Sockeye and Coho Salmon in Southeast 

Alaska 1960 to 2005 

0

1

2

3

4

5

1960 1965 1970 1975 1980 1985 1990 1995 2000 2005

Yea

Harvest Numbers (millions)

Chinook

Sockeye

Coho
Environment and Effects 3 

Final EIS 3-65 Fish 

Source: Bachman et al. 2005 

Based on estimated portions of each species originating from the Tongass National 

Forest, over 70 percent of the total harvested fish began their life in streams and 

lakes within the Forest boundaries. Fluctuations in commercial harvest trends are 

partly attributable to changes in ocean productivity. The productivity of marine 

waters in the Gulf of Alaska, and the survival of salmon and steelhead trout, is both 

highly variable and cyclic. From the mid-1970s into the mid-1990s, favorable ocean 

currents have resulted in high productivity and, consequently, high marine survival 

of salmon (USDA Forest Service 1995a). These favorable conditions have been 

more variable in more recent years and may not be following past cyclic patterns 

(Kruse 1998). 

Based on the estimate of salmon produced from streams originating in the Tongass 

National Forest, estimated annual commercial salmon harvest (1984 to 2005) 

averaged over 164 million pounds, with a wholesale value (ex-vessel value) over 

$68 million (adjusted to 2005 dollars). The harvesting and processing of these 

salmon provided a substantial number of direct and indirect jobs in Southeast 

Alaska. In the most recent year reported, 2005, more than 210 million pounds of 

salmon were harvested worth more than $41 million in Southeast Alaska (Figure 

3.6-3) 

Hatchery production has also contributed substantially in overall fish production 

regionally. Hatchery production state-wide has greatly increased since 1977 with 

releases of more than 1 billion fish occurring annually since 1988, peaking in 2003 

with more than 1.6 billion juvenile fish released state-wide (White 2006). These 

hatchery-released fish have contributing substantially to harvest statewide, with the 

number of returning fish increasing from less than 5 million in 1980 to more than 80 

million statewide in both 2003 and 2005. A substantial portion of hatchery 

Figure 3.6-2 

Commercial Harvest of Pink, Chum and Total Salmon in Southeast Alaska 

1960-2005 

0

10

20

30

40

50

60

70

80

90

100

1960 1965 1970 1975 1980 1985 1990 1995 2000 2005

Yea

Harvest Numbers (Millions)

Pink

Chu

Total
3 Environment and Effects

Fish 3-66 Final EIS

Figure 3.5-3. Commercial Harvest and Wholesale (Exvessel) CPI Adjusted 

Value of Salmon Produced from the Tongass National Forest, Southeast 

Alaska (1984-2005)

$0

$20

$40

$60

$80

$100

$120

$140

$160

1984198519861987198819891990199119921993199419951996199719981999200020012002200320042005

Year

Gross Earnings (Millions of $2005)

0

50

100

150

200

250

300

Gross Landings (Millions of Pounds)

Gross Earnings

Gross Landings

Data Sources: Don Martin, Personal Communication, July 2006: Backman et al. 

2005,http://w w w .cf.adfg.state.ak.us/geninfo/finfish/salmon/catchval/blusheet/94exvesl.php;http://w w w .cf.adfg.state.

ak.us/geninfo/finfish/salmon/catchval/history/1970-2004s.php, Duffy (2004) 

http://w w w .cf.adfg.state.ak.us/geninfo/pubs/csepseak/csepseak.pdf

production and harvest occurs in Southeast Alaska with juvenile salmon releases 

equaling about one-third of total state release in 2005 (White 2006). Harvest of 

hatchery fish is a substantial portion of total salmon harvest in the Southeast Alaska 

region, averaging about 13 percent of the total number of commercially harvest fish 

(including cost recovery harvest) in recent years (1994 to 2005), or about 12 million 

fish annually (Alaska Department of Fish and Game [ADF&G] 2004a, White 2006). 

In some recent years, over 90 percent of the total commercial harvest of chum 

salmon, and a lesser percentage other salmon species, have resulted from 

enhancement projects in Southeast Alaska (ADF&G 2004a). 

Approximately 85 percent of Southeast Alaska's sport fishing occurs in the vicinity of 

the Tongass National Forest. Sport fishing use has increased over the last four 

decades. For example, sport harvest of salmon in Southeast Alaska more than 

doubled in the last decade (from 1995 to 2004) (ADF&G 2004b). The economics of 

commercial and sport fishing is discussed in detail in the 1997 Tongass Forest Plan 

Revision Final EIS (USDA Forest Service 1997a) and updated in the Economics and 

Social Environment section of this chapter. 

With more than 42,700 miles of streams and 250,000 acres of ponds and lakes 

(based on GIS measurements), the Forest provides abundant fish habitat. The 

habitat has been inventoried and classified, and estimates have been made of fish 

production. This section begins with a description of key habitat components, then 

presents a review of information on the effects of past harvest in Southeast Alaska 

on salmonid stocks, and finishes with a description of how fish habitat is mapped 

and classified on the Tongass. 

Fish Habitat 

Figure 3.6-3 

Commercial Harvest and Wholesale (Exvessel) CPI Adjusted Value of 

Salmon Produced from the Tongass National Forest, Southeast 

Alaska (1984-2005) 
Environment and Effects 3 

Final EIS 3-67 Fish 

Important Components of Fish Habitat 

Stream Temperature and Dissolved Oxygen 

Salmon and trout have optimum temperature ranges for rearing, spawning, and 

adult migration. Generally salmonid require cool stream temperature to thrive in 

most stream conditions (Bjornn and Reiser 1991). While very cool water conditions 

can be a limiting factor to salmon and trout survival and production, warmer 

temperatures are most often the more limiting condition within most of the range of 

Pacific salmon. However, in much of Southeast Alaska, increased summer 

temperature is much less of a concern than for more southerly regions due to the 

normal cool climatic conditions (Murphy and Milner 1997). Heating of streams also 

affects the amount of dissolved oxygen in the water, another important component 

for salmonid production and survival. 

Stream temperatures are affected by solar radiation, evaporation, advection, 

conduction, and convection (Adams and Sullivan 1989, Brown 1983). Streams have 

a general tendency to warm as flow moves from upstream to downstream. The 

natural heating from solar radiation, increased air temperatures, and natural 

decreased stream flow tend to result in higher temperatures in the summer 

(Zwieniecki and Newton 1999). Timber harvest can have its greatest effect on 

stream temperature by removal of shade trees that reduce direct solar heating. 

Increased temperature results in reduced oxygen, but other factors such as 

decaying organic matter or abundance of salmon in a stream can also have large 

effects on dissolved oxygen concentrations (Pentec Environmental 1991, Welch et 

al. 1998, Spence et al. 1996). 

Lack of stream shading buffers has been found to cause increases in stream 

temperature over 10 degrees Celcius (°C) in some small streams of the Pacific 

Northwest (Everest and Reeves 2007). Additionally lack of buffers can result in 

elevated microclimate temperatures that contribute to this heating (Spence et al. 

1996, Chen 1991, Chen et al. 1992, Sullivan et al. 1990). However, effects in 

Southeast Alaska on stream temperature from past and resent harvest have not 

been of this magnitude and are often not significantly different than similar 

unaffected streams. 

Murphy and Milner (1997) summarized the results of many of the studies on effects 

on stream temperature, of earlier past harvest in Southeast Alaska, when streams 

were typically not buffered. They noted a wide range of results. Some very small 

streams with timber harvest approached lethal levels (over 25°C). But most studies 

found no effect or only modest (e.g., 2°C) increases with stream temperatures not 

approaching lethal levels. These studies were all on streams that were harvested 

under old rules that did not require buffers. Effects on winter temperature also 

showed varied results in Southeast Alaska, some ranging from a slight increase, to 

no change, to a slight decrease in temperature in streams traversing clearcuts 

(Meehan et al. 1969 and Thedinga et al. 1989). Recent watershed monitoring on 

the Tongass (1997 to 2002) found that state water temperature standards were 

exceeded at similar rates in both harvested and unharvested watersheds (Walters 

and Prefontaine 2005). This suggests that elevated summer stream temperature is 

affected more by other environmental conditions than past timber and riparian 

harvest. 

Situations where elevated temperature and low dissolved oxygen have been found 

to occur, and associated with fish die-offs, have been related mostly to the 

characteristics of stream morphology, hydrology, season, and number of fish 
3 Environment and Effects

Fish 3-68 Final EIS

present, not past timber harvest (Pentec 1991, Murphy 1985, Murphy and Milner 

1997). Generally small basins of low elevation, low stream flow, confined intertidal 

conditions, with high numbers of adult fish, during warm weather periods were areas 

that occasionally had die-offs of adult salmon due to low oxygen (Murphy and Milner 

1997). 

Sediment 

Sediment, includes both the coarse (gravel, cobble, bolder, bedrock) and fine (sand, 

silt) substrate composition in the stream channel. The relative composition affects 

many factors in stream production, including spawning areas and spawning success 

for salmon and trout, and benthic organism composition, which is an important food 

resource for fish. The amount of coarse sediment affects available spawning habitat 

and influences pool filling and bank stability (Spence et al. 1996). High levels of 

fines also affect pool filling, but also greatly influence survival of eggs and fry in 

spawning nests of salmon and trout (Chapman and McLeod 1987, Chapman 1988, 

Iwamoto et al. 1978, Gregory and Bisson 1997, McNeil 1964). Generally, the 

greater the portion of fines in spawning areas, the lower the survival of eggs and fry 

(McNeil 1964, Koski 1972, Chapman 1988). Increased fines in streams also reduce 

interstitial spaces in large substrate that are important habitat for many common 

cool water mountain stream aquatic insects. 

Sources of sediment include input from banks, downstream movement from 

tributaries, and slumping and slides that enter or are near streams. The stream bed 

composition is a function of stream slope, roughness elements (e.g., amount and 

size of large woody debris [LWD]), and local adjacent geomorphic composition. 

Several timber harvest related activities may affect stream substrate composition, 

including road construction, road drainage structures, level of use and maintenance 

of roads, number of stream crossings by roads, density of roads in the watershed, 

erosion and slumping of hill slopes following harvest, bank erosion where trees have 

been removed, and hydrology changes (Swanson et al. 1987, Furniss et al. 1991, 

Spence et al. 1996, Everest et al. 1987). 

Past timber harvest practices have affected sediment levels in Southeast Alaska 

streams in some situations (Pentec 1990, Murphy and Milner 1997). Timber harvest 

in other regions have produced substantial increases in sediment and changes in 

composition; these are generally related to intensive timber harvest activities (Holtby 

and Scrivener, 1989, Cederholm et al. 1981). However, many studies of the effects 

of timber harvest and amount of sediment in Southeast Alaska streams have been 

inconclusive (Murphy and Milner 1997, Sheridan et al. 1984). Nevertheless, models 

developed by the Forest Service suggest that timber harvest activities, especially 

related to road construction, would increase fine sediment inputs to streams 

potentially affecting spawning success (Murphy and Milner 1997). 

Large Woody Debris 

LWD in stream channels includes entire trees, rootwads, and larger branches. LWD 

is an important component of fish habitat for good trout and salmon habitat, 

especially in heavily wooded regions (Swanson et al. 1976, Bisson et al. 1987, 

Naiman et al. 1992, Beechie and Sibley 1997, Spence et al. 1996, Murphy et al. 

1986). LWD provides channel complexity, cover, and is especially important in the 

formation of pools (Bisson et al. 1987, Sullivan et al 1987, Benda et al. 2003). LWD 

has been found to form over 70 percent of all pools in a typical Alaskan valley 

bottom stream (Heifetz et al. 1986). The benefits of LWD in streams include critical 

sediment retention (Keller and Swanson 1979, Sedell et al. 1988), structural 

diversity (Ralph et al. 1994), gradient modification (Bilby 1979), nutrient production 

(Cummins 1974), and protective cover from predators. Its presence is often critical 
Environment and Effects 3 

Final EIS 3-69 Fish 

for overwinter habitat for various salmon and trout (Murphy and Milner 1997, 

Murphy et al. 1985, Koski et al.1984). Wood controls sediment movement 

downstream, minimizing the risk of debris flows in small headwater streams. In 

large streams, coarse sediment accumulated behind LWD often provides spawning 

gravels (Bilby and Bisson 1998, Montgomery et al. 2003). Newly entered LWD 

plays an important role in stream by providing inputs of leaf litter and needles and as 

it ages enhances nutrient dynamics. 

Sources of LWD to streams include a variety of processes such as windthrow, 

wildfires, stream bank erosion, tree natural mortality, and debris slides, deep-seated 

mass soil movement, and input from upstream areas (Swanson and Lienkamper 

1978, Benda et al 2003). Small headwater streams can provide wood to larger 

channels downstream (Potts and Anderson 1990, Prichard et al. 1998, Coho and 

Burges 1991, Benda et al 2003, Reeves et al. 2003). 

Debris flows and dam-break floods during high flow occurrences can cause the 

transport of wood from upstream to downstream regions (Swanson and 

Lienkaemper, 1978). Because of the large size of much of the wood that enters 

streams, its ability to float during this type of event is limited to larger third- to fifthorder streams (Swanson and Lienkaemper 1978). While much less frequent than 

high flow events, large amounts of LWD can be added by debris torrents (Lamberti 

et al. 1991). The entry of LWD and coarse sediment at tributary junctions by debris 

torrents can form complex habitat, including pools and cover, and add spawning 

gravel to the main channel (Benda et al. 2003). 

In streams of the Tongass, Murphy and Koski (1986) found that 40 percent of LWD 

in streams originated within 3 feet of the bank and 99 percent within 100 feet of 

stream channel. Martin et al. (1998) found similar results estimating that 94 percent 

of LWD entered streams in unharvested Southeast Alaska areas originated within 

98 feet of the stream channel. There may be exceptions to this in certain streams. 

Reeves et al. (2003) found that about 65 percent of the LWD pieces in Oregon 

coastal streams originated in upslope areas, primarily from steep intersecting stream 

channel. Reeves et al. (2003) noted that similar conditions were observed in 

California and Washington states. The width of the stream valley and the slope of 

intersecting tributaires were the main factors determining the portion of wood 

entering from side streams. 

The primary timber-related actions that may affect LWD supply to streams include 

buffer width along streams, stream class and channel characteristics that buffers are 

placed on, size of trees remaining in the buffer area, and effects on windthrow from 

adjacent harvest. 

Murphy and Koski (1989) used a model to estimate that for moderate-sized valley 

bottom streams in Southeast Alaska with no buffers, LWD would decrease to about 

30 percent of pre-harvest levels in about 90 years. Some studies have documented 

reduced LWD in Alaska clearcut streams relative to old-growth stream channels 

over time (Heifetz et al. 1986, Johnson et al. 1986, Murphy et al. 1986, Murphy and 

Milner 1997). But in the short term, LWD may be higher in clearcut areas (Lisle 

1986). Limited long-term monitoring has occurred on Southeast Alaska streams to 

document changes. However, it was found that Maybeso Creek had a decrease in 

number and size of LWD, 30 years after harvest (Bryant 1980) with similar changes 

in Harris River (Bryant 1985, cited in Murphy and Milner 1997). However, these 

watersheds were intensively logged under conditions that had no buffer strips on 

streams; buffers were almost completely absent during timber harvest until the late 

1980s. Buffer strips have greatly increased in frequency and size since then. 

Buffer strip blowdown affects timing of LWD entry to streams. Several studies have 

shown that blowdown in buffers increases after harvest, primarily in the short term 
3 Environment and Effects

Fish 3-70 Final EIS

(Pentec 1996, Martin 1996). Effects were short term, however, with rate of 

blowdown decreasing over time and the effects on total LWD loading to streams 

slight. There has been some documentation of a large increase in rootwads in a 

stream due to blowdown, which was considered beneficial to fish habitat (Murphy 

and Milner 1997). Recent monitoring of harvest areas since 2000 have found highly 

variable rates and amounts of windthrow adjacent to harvest units, but effects on 

stream LWD supply was not assessed (USDA Forest Service 2007). However, 

Martin and Grotefendt (2007) found that windthrow on non-NFS lands with 20-meter 

buffers would, on average, reduce the long-term LWD supply in Southeast Alaska 

forest streams by about 5 percent relative to unharvested areas (an additional 5 

percent would be lost due to harvest). 

Food Sources 

Food sources for stream fish can originate directly within the stream or enter from 

the adjacent terrestrial environment or upstream aquatic environment. The main 

sources are from leaf and litter deposits from the adjacent riparian vegetation, algae 

growth and production on the stream bottom, and from returning salmon carcasses. 

This is ultimately the food base for smaller aquatic organisms (e.g., aquatic insects) 

that become food sources for stream fish. Detrital input is the main source from 

heavily shaded small- and medium-sized streams (Richardson 1992, Gregory et al. 

1991). Larger streams in contrast derive much more of their food sources from 

algae production. Nutrient and organic input from returning salmon are also 

important (Wipfli et al. 1998). Small streams, many of which are not fish-bearing, 

supply nutrients that contribute substantially to larger streams (Independent 

Multidisciplinary Science Team 1999). When riparian trees are removed, the 

primary source of food is initially shifted to algae production within the stream and is 

derived less from leaf and needle organic matter (Murphy and Milner 1997). Overall 

production along many streams with canopy removal in Southeast Alaska actually 

increased (those where light was limiting), while in some there was no change 

(Murphy and Milner 1997). When second-growth areas regrow, however, 

production may be reduced due to shade greater than was produced by the original 

old growth. Small streams in Alaska have been found to also contribute 

substantially to larger streams through downstream transport of terrestrial and 

aquatic prey directly and detritus resources indirectly for fish (Wipfli 1996, Wipfli and 

Gregovich, Piccolo and Wipfli 2002). The type of riparian forest along these small 

streams affects both the amount and type of resources passed down stream. In 

some cases, the regrowth of alder trees along streams following harvest has 

resulted in higher amount of resources to downstream fish streams (Piccolo and 

Wipfli 2002). While changes to riparian areas will change the composition of the 

downstream transported food sources, the final overall effect of total removal, or 

complete retention of riparian vegetation on fishless streams on downstream fish 

streams over the long term is not clear, as actions near these small stream may 

have additional effects (e.g. sedimentation) on stream production (Wipfli and 

Gregovich 2002). 

Effects of Past Forest Management Practices on Salmonid Fish Stocks 

Past timber harvest practices and related actions in many regions of native Pacific 

salmon distribution range have been associated with declines of fish stocks (Everest 

and Reeves 2007). Similar reductions in stocks, however, have not been observed 

in Alaska (Byrant and Everest 1998). This may be partly because other humaninduced disturbances (e.g. agriculture, dams, urban development), which are 

common in other regions, are rare in Southeast Alaska. As noted above, older 

forest practices (mostly prior to 1980) in the Tongass National Forest have had 

documented adverse effects to anadromous fish habitat conditions, including 
Environment and Effects 3 

Final EIS 3-71 Fish 

spawning habitat, rearing habitat, and migration conditions (Murphy and Milner 

1997). Harvest during this timeframe accounts for about 60 percent of all timber 

harvest on the Tongass National Forest (see Tables 3.9-8 and 3.9-9 in the 

Biodiversity section). In one study of multiple streams in Southeast Alaska, summer 

fry numbers of coho salmon increased in clearcut areas, but had reduced or similar 

numbers of fall and winter stages of juveniles relative to old-growth systems 

(Murphy et al 1986). In another study, increased summer abundance of coho 

juveniles in clearcut areas had reduced the number of outmigrating coho smolts 

relative to old-growth areas (Thedinga et al. 1989). Similarly, juvenile steelhead 

abundance, while high in unbuffered clearcut streams in the summer, became very 

low in the winter as these fish moved to buffered and old-growth habitats where 

cover was higher (Johnson et al. 1986). 

However, studies addressing potential long-term effects of timber harvest and 

related actions on actual numbers of fish produced are rare within the range of 

Pacific salmon, including Alaska (Brant and Wright in press). Brant and Wright (in 

press) compiled and analyzed the data from multiple juvenile fish studies in 26 

streams in Southeast Alaska in an attempt to determine what long-term effects past 

harvest management actions have had on fish production by comparing fish 

abundance in managed and old-growth watershed streams. The managed 

watershed all had timber harvest activity prior to 1980, which generally included 

clearcutting of riparian trees. Partly because most studies examined were not 

specifically designed to address long-term effects, overall results of this analysis 

were limited. They examined population densities of juvenile fish from studies 

conducted from 1978 to 2000, including data on coho salmon, Dolly Varden char, 

steelhead, and cutthroat trout. Even with the variability of data, they found 

statistically significant differences between the managed and old-growth 

watersheds. Coho salmon and Dolly Varden densities were significantly lower in 

harvested areas, while steelhead density was greater in harvested areas. Where 

long-term trends were significant, they were downward in harvested areas. There 

were many differences in overall production among regions, differences between 

seasons, and morphological differences among streams that contributed to much 

overlap in abundance between treatment groups and the lack of clear results. 

Overall, this study suggests some negative effects on some populations from older 

harvest practices (prior to 1980). New forest practices in the Tongass National 

Forest are intended to prevent the habitat degradation in riparian areas and 

headwater streams that have contributed to these adverse effects on populations 

(Bryant and Wright in press). 

Recent monitoring of stream fish populations, based on specific sampling designs 

intended to assess effects of recent timber harvest practices, is not at the stage 

where determinations can be made about effects of these newer practices on fish 

populations (USDA Forest Service 2007), but, as shown earlier (Figures 3.6-1, and 

3.6-2), overall trends in Southeast Alaska commercial harvests from 1960 to 2005, 

including coho, pink, chum, and sockeye salmon, do not indicate specific downward 

trends in these populations, or specific trends that could be correlated with amounts 

of timber harvest activity. While many factors outside of forest management 

practices in Southeast Alaska (e.g., ocean conditions, weather, hatchery releases, 

harvest management, watershed conditions in other areas) influence these 

numbers, no obvious effects can be discerned from harvest data. However, the 

effects of these moderating factors may be too great to permit harvest data to 

demonstrate any effects on fish populations resulting from timber harvest in specific 

Southeast Alaska watersheds, particularly if they are relatively small (Bryant and 

Wright in press, Bryant and Everest 1998). 
3 Environment and Effects

Fish 3-72 Final EIS

Stream Classification on the Tongass 

Fish habitat on the Tongass is classified, for management purposes, using two 

classification systems (see the Water section of this chapter). The first is stream 

class, which relates primarily to presence or absence of fish, type of fish, and water 

quality. The second category is stream process group, which characterizes streams 

based on channel and drainage basin morphological conditions. 

Stream Class Inventory 

Streams are categorized by stream class, a classification primarily associated with 

fish use. Stream classes describe stream values, such as whether anadromous or 

resident fish inhabit a particular stream. Class I streams are anadromous and highvalue resident fish streams, Class II streams are other resident fish streams, Class 

III streams are managed for water quality and, where appropriate, downstream 

aquatic resources, and Class IV are small streams that do not influence downstream 

water quality or fish habitat. Refer to the Water section for more detailed 

descriptions (also see the Glossary in the Proposed Forest Plan volume for more 

complete definitions.) 

Channel Type Inventory 

Perennial and many intermittent streams on the Forest have been inventoried for 

channel-type. The channel types provide a system to estimate the amount and 

quality of fish habitat, and can be used to predict their physical response and 

sensitivity to different management activities. Channel types have been categorized 

into distinct groups, called “stream process groups.” Process groups describe the 

interrelationship between watershed runoff, landform relief, geology, and glacial or 

tidal influences on fluvial erosion or depositional processes. They are described in 

Channel Type User Guide Tongass National Forest Southeast Alaska (Paustian et 

al. 1992). Process groups, in conjunction with stream class, are used for assigning 

the Riparian Standards and Guidelines. The estimated miles of stream by process 

group and class within the Tongass National Forest are shown in Table 3.4-1 in the 

Water section of this chapter. 

Much emphasis has been placed on the enhancement of fish habitat on the 

Tongass National Forest. From 1980 to 1995, the Forest Service implemented 176 

fisheries habitat enhancement projects on the Tongass (USDA Forest Service 

1997a). 

Many of the fish habitat enhancement projects implemented on the Tongass 

National Forest are cooperative projects involving multiple agencies and 

organizations, including the Forest Service, ADF&G, Regional Aquaculture 

Associations, timber companies, and other non-profit hatcheries. 

Types of enhancement projects have included: 

• Fishways 

• Falls Modification 

• Spawning Channels 

• Debris Removal 

• Lake Fertilization 

Fish Habitat 

Enhancement 
Environment and Effects 3 

Final EIS 3-73 Fish 

• Lake Stocking 

• Stream Stocking 

• Rearing Ponds 

• Incubation Boxes 

• Large Woody Debris (LWD) Management 

In more recent years, emphasis has included a reduced array of projects across the 

Forest. Specific ongoing projects include the following: 

• Fishways: Currently one is actively being developed at Snow Pass Creek; 

• Falls Modification: One site is being evaluated at Kanalku Creek; 

• Spawning Channels: One new site is being evaluated at Fish Creek; 

• Lake Fertilization: Currently one lake (Redoubt) is being fertilized annually; 

• Lake Fish Stocking: One pen-rearing/lake stocking site is planned for 

implementation in 2007 at Bakewell Lake; and 

• LWD: Several LWD projects are being implemented associated with watershed 

restoration. 

Additionally, habitat access to streams has been improved through replacement of 

culverts that did not meet current juvenile fish passage design criteria. About 88 

percent of all stream crossings (about 80 percent of the crossings are culverts or 

similar structures) have been assessed as to suitability to ensure juvenile fish 

passage. Among the crossings assessed, about 1,200 crossings, or 37 percent of 

all crossings (mostly culverts), did not meet current juvenile fish passage standards 

(USDA Forest Service 2006b). Of those not meeting standards, more than 75 

percent were on Class II streams. Habitat above the crossings with potential 

passage problems was estimated to equal about 0.5 percent and 3.2 percent of all 

Class I and Class II stream miles on the Tongass, respectively. Based on the 

restrictive criteria used to determine whether a culvert is suitable for juvenile fish 

passage, the known distribution of fish above culverts designated as not meeting 

passage criteria (about 85 percent of those reaches have fish populations), and the 

small size of most of these streams, the habitat area affected would actually be 

much less than the percentages imply (USDA Forest Service 2006b). However, 

even though the habitat area may be small, the effect on an individual stock may be 

important. Most of these culverts were installed prior to implementation of the 1997 

Forest Plan standards and guidelines for culvert installation. A recent survey of 29 

culverts installed since the 1997 standards and guidelines began to be implemented 

found that two (7 percent) did not meet current juvenile fish passage criteria (Dick 

Aho, USDA Forest Service Biologist, Personal Communications August 23, 2007). 

To reduce these effects, culverts are being replaced, removed, or bypassed. 

Approximately 240 culverts have been replaced through 2006 to improve fish 

passage. The Tongass National Forest estimated that it spent $1.5 to $2.0 million a 

year for culvert replacement for approximately 50 sites per year through 2005 

(USDA Forest Service 2006b). The culvert replacement program declined in 2006 

due to funding reductions, and is projected to continue to decline in future years. 

However, the intention is to continue this program of culvert replacement when 

funding supply is reinstated as part of road maintenance funding. 
3 Environment and Effects

Fish 3-74 Final EIS

The anticipated salmon production from fish habitat enhancement projects on the 

Tongass National Forest is calculated based on site-specific habitat conditions and 

an analysis of limiting factors for salmon production. The test for these habitat 

production estimates consists of monitoring conducted on individual projects and the 

subsequent feedback of the monitoring results into the project planning process. 

The 1997 Tongass Land Management Plan Revision Final EIS identified 158 

potential projects for initiation during the first 10 years of implementation of the 

Forest Plan (USDA Forest Service 1997a). The extent of implementation of these 

projects has been considerably less. The public continues to expect the 

maintenance or improvement of fish habitat values. Public interest for subsistence, 

commercial, and sport-harvested fish remains high. 

Demand for subsistence fish is discussed in the Subsistence section of this chapter, 

while commercial and sport fish demand are reviewed in this section. Commercial 

fish demand is calculated based on goals set by Regional Salmon Planning Teams 

for annual fish production for several species. Some of the “year 2000” goals were 

set in 1981 in the Comprehensive Salmon Plan for Southeast Alaska, Phase I, and 

have not been updated. Annual common property commercial harvest usually 

achieved these goals for pink salmon (92 percent), coho salmon (61 percent), and 

sockeye salmon (58 percent), but infrequently for chum salmon (31 percent) for the 

period of 1991 through 2003 (ADF&G 2004a). Harvest has been highly variable 

during this period. National Forest habitats were estimated to contribute 

approximately 80 percent of the fisheries in Southeast Alaska (USDA Forest Service 

1997a), although the relative contribution has decreased in more recent years due 

to increased hatchery production. 

There has been a tenfold increase in state-wide angler participation from 1961 

through 2004, with total license sales in Alaska increasing from 55,564 to 503,422 

during this period (Jennings et al. 2007). Overall, the number of anglers increased 

in Southeast Alaska by about 40 percent between 1991 and 2004 (from about 

93,000 to 130,000 angler licenses) (Howe et al. 1995, Howe et al. 2001, Jennings et 

al. 2006, 2007). This equates to about a 4.5 percent increase in total licenses sales 

in Southeast Alaska annually. However, the number of Southeast Alaska resident 

anglers declined slightly since 1991 (about 10 percent), while the number of nonresident anglers increased from about 58,000 to 98,000 between 1991 and 2004; a 

70 percent increase. The rate of increase exceeds that for sport fishing participation 

in all of Alaska for this same period (1991 to 2004) with total state fishing license 

sales increasing about 29 percent (from about 391,000 to over 503,000) (Jennings 

et al. 2007). 

National Forest Management Act (NFMA) regulations direct the use of Management 

Indicator Species (MIS) in forest planning to help display the effects of forest 

management. MIS are species whose population changes are believed to indicate 

the effects of land management activities. For the 1997 Forest Plan, pink salmon, 

coho salmon, Dolly Varden char, and cutthroat trout were selected as MIS. Pink 

salmon were selected to represent anadromous fish that are limited in their 

freshwater life period by spawning gravel quality and quantity; coho salmon to 

represent anadromous fish that are generally limited in their freshwater life period by 

stream and lake rearing area; Dolly Varden char because of their ubiquitous 

distribution in freshwater habitats; and cutthroat trout because of their dependency 

on small freshwater stream systems, which are most susceptible to effects from 

management activities. These MIS fish species, and their habitats, are described in 

the 1997 Forest Plan Revision Final EIS. 

Fisheries Habitat 

Enhancement 

Opportunities 

Fish Management 

Indicator Species 
Environment and Effects 3 

Final EIS 3-75 Fish 

Federally listed threatened and endangered species are those plant and animal 

species formally listed by the U.S. Fish and Wildlife Service (USFWS) or the 

National Marine Fisheries Service (NMFS), under authority of the Endangered 

Species Act (ESA) of 1973, as amended. An endangered species is defined as one 

that is in danger of extinction throughout all or a significant portion of its range. A 

threatened species is defined as one that is likely to become an endangered 

species within the foreseeable future throughout all or a significant portion of its 

range. 

No federally listed fish species or stocks originate from Alaska streams. However, 

some federally listed fish stocks may occur in marine waters within the boundary of 

the Tongass National Forest. These fish include the following: 

Endangered species: 

• Snake River sockeye salmon 

• Upper Columbia River spring-run Chinook salmon 

• Upper Columbia River steelhead 

Threatened species: 

• Snake River spring/summer Chinook salmon 

• Snake River fall Chinook salmon 

• Puget Sound Chinook salmon 

• Lower Columbia River Chinook salmon 

• Upper Willamette River Chinook salmon 

• Columbia River chum salmon 

• Snake River Basin steelhead 

• Lower Columbia River steelhead 

• Upper Willamette River steelhead 

• Middle Columbia River steelhead 

• Puget Sound steelhead 

These listed stocks of salmon and steelhead do not spawn in Alaska, but are known 

to seasonally inhabit marine waters on the outside coast to the west and 

occasionally in inside waters of the Tongass National Forest. They may feed on fish 

that are dependent on coastal marine waters of the Tongass National Forest at 

some stages of their lives. 

Pursuant to Section 7 of the ESA, a biological assessment was prepared to assess 

the effects of the 1997 Forest Plan revision on the endangered Snake River sockeye 

salmon and the threatened Snake River spring/summer Chinook salmon and Snake 

River fall Chinook salmon, and submitted to NMFS for review and concurrence in 

the Tongass Forest Plan process (Appendix J of the 1997 Tongass Forest Plan 

Revision EIS). This assessment has been updated to address the currently listed 

fish species relative to the alternatives considered in the Forest Plan amendment 

(Appendix F). 

Threatened and 

Endangered Fish 

Species 
3 Environment and Effects

Fish 3-76 Final EIS

The Magnuson–Stevens Fishery Conservation and Management Act mandates that 

agencies initiate consultation with NMFS for any activities that could affect essential 

fish habitat (EFH). EFH has been broadly defined by Congress for federally 

managed species to be “those waters and substrate necessary to fish for spawning, 

breeding, feeding, or growth to maturity”. 

NMFS (2005) clarified what the specific definition is for EFH in Alaskan waters. EFH 

is the general distribution of a species described by life stage. It is generally the 

habitat area that includes 95 percent of that life stage, where it is known, to occur. 

Where distribution data is unknown, surrogate species may be assumed. Maps 

were presented in NMFS (2005) defining EFH for species and life stages; other than 

for salmon species, little EFH is present in the inside waters of Southeast Alaska. 

Those groundfish species that are present include some sole species life stages 

only. Several other species, however, have some life stages located in the marine 

waters offshore of Southeast Alaska and some enter outer nearshore waters. In 

general, EFH for marine groundfish species (e.g., rockfish, sablefish, sole, plaice, 

cod, pollock), are extremely limited near Tongass waters. 

Salmon EFH covers freshwater, estuarine, and marine waters from the high tide 

level to 200 meters deep and out to the 200 nautical mile U.S. exclusion zone, 

depending on life stage. The freshwater EFH is defined primarily by what is present 

in the ADF&G’s Catalogue of Waters Important for Spawning, Rearing, or Migrations 

of Anadromous Fishes (ADF&G 1998). Freshwater EFH for salmon in the Tongass 

would include all streams, lakes, ponds, and wetlands currently or historically 

accessible to salmon. The shallow marine waters adjacent to forest lands are 

considered EFH for salmon, but little of this area is EFH for most groundfish 

species. 

Sensitive species are those plant and animal species identified by the Regional 

Forester for which population viability is a concern on National Forest Service (NFS) 

lands within the region. The goal of the Forest Service Sensitive Species Program 

(Forest Service Manual 2670) is to ensure that species numbers and population 

distribution are adequate so that no federal listing will be required and no extirpation 

will occur on NFS lands. 

The Alaska Region Sensitive Species List was updated in June 2002. There are 

three fish species currently designated as sensitive species in the Alaska Region. 

Northern Pike 

Northern pike are found in five lakes, referred to as Pike Lakes, approximately 

23 miles east of Yakutat in Roadless Area 341 (Browning 1986). These lakes are 

shallow, with high concentrations of humic acid and peat-filled margins. The 

northern pike in Pike Lakes are the only naturally occurring pike in Southeast Alaska 

and are probably remnant populations that survived only because the most recent 

glacial advance missed the Pike Lakes area. Relatively little information is available 

on the life history and population dynamics of these pike populations. Their 

presence in any other regional waters would be considered as an invasive species 

(see the Invasive Aquatic Species subsection below). 

Large Chum Salmon 

Near Hyder on the Portland Canal, Fish Creek produces very large chum salmon, 

probably the largest chum salmon in North America. Several fish over 38 pounds 

have been weighed by biologists; fish weighing 25 pounds are common. The 

average size of large chum salmon is close to 20 pounds (the average chum salmon 

Essential Fish 

Habitat 

Sensitive Fish 

Species 
Environment and Effects 3 

Final EIS 3-77 Fish 

from other areas weighs around 10 pounds). A high percentage of the returning fish 

have spent 4 and 5 years in the ocean, accounting for the large average size. 

Normally, chum salmon stay at sea for 2 to 5 years (Salo 1991). Fish Creek is a 

low-gradient stream, dominated by high-quality spawning gravels and extensive 

areas of groundwater upwelling. The predominant upwelling and high-quality 

spawning gravels appear to be the reasons for the remarkable production levels. 

Populations have been stable or increasing, with a reported escapement of more 

than 60,000 in 1993. 

Island Run King Salmon 

King Salmon River and Wheeler Creek populations of king salmon are island 

genetic stocks. No other naturally occurring runs of island king salmon stocks are 

known to exist in Southeast Alaska. King Salmon River and Wheeler Creek are 

both within Kootznoowoo Wilderness. Information on these populations is limited, 

although recent escapement counts suggest the population is stable or slightly 

decreasing. The King Salmon River stock serves as an important king salmon 

transplant source for other streams and rivers. 

Species are considered invasive if they are not native to an ecosystem, and if they 

are likely to cause harm to human health, the economy, or the environment 

(Executive Order 13112). Due to its remote landscape, northern climate, small 

human population, and few concentrated disturbed habitat areas, Alaska has 

relatively few invasive species compared to the rest of the United States, according 

to ADF&G’s Alaska Aquatic Nuisance Species Management Plan (Fay 2002). 

However, factors such as altered disturbance patterns, constant flow of marinebased shipping and cruise ships, fishing and recreational boating traffic, and climate 

change may increase the prevalence of invasive aquatic species. Global climate 

change may create conditions suitable for new invasives, as well as range 

expansions, by altering geographic range limits and making habitats no longer as 

suitable for existing native species. 

Invasive aquatic species can affect native species by eating them, competing with 

them, hybridizing with them, disrupting or destroying their habitat, or introducing 

pathogens or parasites that sicken or kill them (Schrader and Hennon 2005). In 

addition to natural range extension, several potential pathways exist for introduction 

of invasive aquatic species. These pathways included fish farms, international and 

local movement of bait and game fish, trade in live seafood, aquaculture, and 

contaminated sport angle gear brought into Alaska, as well as ballast discharge from 

international vessels (Fay 2002, Schrader and Hennon 2005). Several aquatic 

species have been noted as potential threats to Alaska, including fish (northern pike, 

Atlantic salmon, yellow perch, ornamental aquarium fish), invertebrates (green crab, 

New Zealand mudsnail, Chinese mitten crab, zebra mussel, signal crayfish, spiny 

water flea), plant (cordgrass), and several additional miscellaneous taxa (Fay 2002, 

Schrader and Hennon 2005). Additionally, eastern brook trout (non-native) and nonendemic rainbow trout have been stocked in many areas where they were not native 

and compete or hybridize with native trout (Schrader and Hennon 2005). Of these 

fish, transplanted northern pike and Atlantic salmon are the two fish species of 

greatest concern (Fay 2002). The invertebrates Chinese mitten crab, green crab, 

and New Zealand mudsnail, even though they have not been found in Alaska, are of 

major concern because of their potential to do serious damage to the Alaskan 

ecosystems (Hines et al. 2004, Schrader and Hennon 2005). Atlantic salmon that 

have escaped from fish farms pose a threat to native salmon by competing for 

habitat and introducing diseases and parasites. This species has been observed in 

Southeast Alaska marine waters and, rarely, in streams (Fay 2002). Also, northern 

pike, which has not appeared in Southeast Alaska (with the exception of a native 

Invasive Aquatic 

Species 
3 Environment and Effects

Fish 3-78 Final EIS

stock in Yakutat), have caused widespread damage to resident trout where they 

have been introduced, and could potentially affect coho salmon through predation. 

Northern pike have the potential to cause serious environmental and economic 

damage to highly productive salmon streams in Southeast Alaska (Fay 2002). In 

the Tongass, there is a risk that these and possibly other non-native sport fish may 

be introduced into lakes and rivers by individuals seeking to increase sport fishing 

opportunities. As the road network is extended into more areas of Southeast 

Alaska, this risk increases. Refer to the ADF&G aquatic species management plan 

for additional details. 

Environmental Consequences 

Many of the standards and guidelines in the current Forest Plan were based, to a 

large extent, on the recommendations of the Anadromous Fisheries Habitat 

Assessment (AFHA) (USDA Forest Service 1995a). AFHA is considered the most 

comprehensive scientific review available for the Tongass. The 1997 ROD notes 

that the standards and guidelines and other direction included in the current Forest 

Plan meet or exceed all of the recommendations by AFHA. The AFHA evaluation is 

still relevant for the current EIS. 

Additionally, two separate panels assessed effects of alternatives on fish-related 

issues (Dunlap 1996, 1997). The two panel assessments were completed, one in 

1996, which was used for the 1997 EIS assessment, and a more limited assessment 

completed in 1997 that added additional panel assessments for a subset of the 

alternatives included in the 1997 EIS. While the current alternatives being evaluated 

have differences from the alternatives evaluated by these panels, four of them are 

based on the 1997 alternatives and differ only in specific ways. Where the 

similarities are comparable, the results of the assessments can be used to help 

evaluate relative effects of the considered alternatives. 

The panel assessments were based on activities that are part of timber 

management among the alternatives. The main activities included roads and 

harvest. The location and amount of road miles have historically affected slope 

stability and runoff to steams having major effects on water quality and fish passage, 

which are both factors that affect fish habitat and abundance. Additionally, the 

location and amount of timber harvest can affect riparian vegetation and slope 

stability, especially on unstable soils, which also have substantial influence fish 

habitat. These two items, as well as aquatic habitat enhancement, will be discussed 

first under General Effects. They will set the stage for the discussion of how the 

alternatives compare to the past panel assessments. The Fish/Riparian 

Assessment Panel summary reports (Dunlap 1996, 1997) serve as the basis for the 

second part of the following discussion of environmental consequences. 

In general, with the exception of Alternatives 4 and 7, the effects of all alternatives 

on fish resources are expected to be at or below those predicted for the selected 

alternative in the 1997 Tongass FEIS, which represents the current Forest Plan. 

The Forest Plan is very similar to Alternatives 5 and 6. 

General Effects 

Roads 

Roads pose the greatest risk to fish resources on the Tongass (Dunlap 1996, USDA 

Forest Service and U.S. Department of the Interior (USDI), Bureau of Land 

Management 1995), partly because they pose the largest risk of managementcaused sediment input to streams (Reid and Dunne 1984, Furniss et al. 1991, Gomi 

Direct and 

Indirect Effects 
Environment and Effects 3 

Final EIS 3-79 Fish 

et al. 2005, Hassan et al. 2005). Roads can potentially create areas of hillslope 

instability resulting in landslide generation, contribute fine sediment from surface 

erosion, and alter surface and subsurface water flow patterns. Landslide debris 

(sediment, large wood) that enters streams may block or shift channels, fill pools, 

and increase fines in spawning areas. Increased sediment yield, including yields 

during road construction, road use during timber harvest activities, and lack of 

sufficient maintenance or proper closure following timber harvest activities, are all 

viewed as potential areas of risk for maintaining fish resources. Roads may also 

increase risk to fish movement due to improper construction relative to fish passage 

(Gibson et al 2005) and blocked culverts. Stream-rearing fish, particularly cutthroat 

trout and Dolly Varden, that occupy the smaller headwater streams during some 

parts of their lives are at the greatest risk. Juveniles of stream-rearing fish are often 

highly mobile during their freshwater stage, moving seasonally between stream 

reaches. 

While riparian protection (e.g., buffers) can greatly reduce sediment delivery to 

streams (Belt et al. 1992, Chamberlin et al. 1991), they provide little reduction in the 

risks to fish or stream channels caused by roads during construction. Road 

construction practices require additional attention to ensure that risks to fish and 

stream channels are not excessively high. Roads also increase the risk that 

improved access would contribute to over-harvest of fish by anglers. These 

potential effects are best addressed at the site-specific level during project design.

USDA Forest Service and USDI, Bureau of Land Management (1995) concluded 

that watersheds with fewer roads generally have healthier fish populations. NMFS, 

as part of their working guidance document for comprehensive salmon restoration 

initiatives on the Pacific coast, developed a matrix of key habitat indicators of 

watershed conditions to determine where adverse effects may occur, and identify 

factors that limit salmonid production (NMFS 1996). NMFS indicted that these 

factors are appropriate for use at watershed, reach, and site scales. One of these 

habitat indicators was road density. NMFS noted the following: 1) a watershed with 

road density of less than 2 miles per square mile and no valley bottom roads would 

be considered “properly functioning,” 2) watersheds with road density of 2 to 3 miles 

per square mile and some valley bottom roads were “at risk,” and 3) watersheds 

with road density greater than 3 miles per square mile and many valley bottom 

roads were rated as “not properly functioning.” Based on this information, the 

frequency of occurrence of road densities exceeding the “properly functioning” value 

of 2 miles of road per square miles, not considering road location, was used as a 

general index of relative effects of roads on aquatic resources. 

Total road miles and road density would increase under all alternatives and follow a 

similar pattern (Table 3.6-2). The increase in road miles over existing conditions 

could range from 16 to 118 percent for the alternatives over the next 100+ years. 

This percentage increase would be 16 to 57 percent for Alternatives 1, 2, and 3; 76 

to 78 percent for Alternatives 5 and 6; and 99 to 118 percent for Alternatives 4 and 

7. Currently, the Value Comparison Units (VCUs) containing at least some harvest 

account for about 41 percent of all VCUs on the Tongass; however, total harvest in 

each VCU is highly variable ranging from just a few acres to several thousand. 

Currently, the average road density on NFS lands on all VCUs is 0.19 mile per 

square mile, while the average road density in only VCUs with some past harvest is 

approximately 0.46 mile per square mile. After more than 100 years of Forest Plan 

implementation, the estimated overall road density on NFS lands would range from 

0.22 mile per square mile under Alternative 1 to 0.41 mile per square mile under 

Alternative 7. On average, all of these densities are within the range of what NMFS 

(1996) characterized as “properly functioning” watershed road densities for west 

coast salmon. Currently, about 98 percent of all VCUs have road densities in the 

“properly functioning” range (less than 2 miles of road per square mile) for NFS 
3 Environment and Effects

Fish 3-80 Final EIS

lands. The alternatives would reduce the portion of VCUs with this road density on 

NFS lands to about 96 percent (Alternative 1) to 90 percent (Alternative 7) (Table 

3.6-2). Alternatives 1 and 2 would have the lowest frequency of VCUs with road 

density over 2 miles per square mile. The largest relative increase in the 

percentage of VCUs with high road density would occur between existing conditions 

and Alternative 7. Additionally, the number of VCUs that have no roads on NFS 

lands is currently about 68 percent; this percentage would remain about the same 

under Alternative 1 and decrease to 60 to 66 percent under Alternatives 2, 3, and 6, 

and to 51 to 59 percent under Alternatives 4, 5, and 7. Increases in road densities 

are primarily in watersheds that already have roads. Potential effects that additional 

road construction and increases in density would have on any specific VCU and 

related watershed condition would ultimately be addressed on a project-specific 

level. 

Table 3.6-2 

Estimated Road Miles and Percent of VCUs in Road Density Categories on NFS Lands under 

Existing Conditions and after 100+ years of Full Implementation1

Alternative 

Road Type Existing 1 2 3 4 5 6 7 

Existing Roads 4,941 4,941 4,941 4,941 4,941 4,941 4,941 4,941 

New Road Construction - 774 2,079 2,799 4,890 3,874 3,744 5,825 

Road Reconstruction2 - 925 1,784 1,932 2,182 2,100 2,046 2,371 

Total Roads 4,941 5,716 7,021 7,741 9,832 8,816 8,686 10,767 

Percent Increase - 16% 42% 57% 99% 78% 76% 118% 

Road Density Categories 

(Mi /Sq. Mi.)3 

0 68.0% 67.8% 66.0% 63.6% 52.1% 58.9% 60.0% 51.4% 

>0 - 1.0 21.5% 20.4% 19.4% 20.2% 26.1% 22.4% 21.1% 24.9% 

>1.0 - 2.0 8.0% 7.3% 8.7% 9.3% 13.5% 11.0% 11.4% 13.5% 

>2.0 - 3.0 2.0% 3.5% 4.8% 5.5% 6.6% 6.3% 6.1% 7.6% 

>3.0 - 4.0 0.4% 1.0% 1.2% 1.4% 1.7% 1.4% 1.4% 2.5% 

>4.0 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 

Percent of VCUs with 

Average Road Density less 

than 2 miles/mi2

 

98% 96% 94% 93% 92% 92% 93% 90% 

Average Road Density 

(miles /mi2) for all NFS Lands 0.19 0.22 0.27 0.30 0.38 0.34 0.33 0.41 

1

 Assumes full implementation of Forest Plan at ASQ levels plus future non-NFS harvest. Includes adjusted road miles estimated to be 

needed to harvest all suitable timber in the alternative allowing for approximation of fall down (the reduction between the planned and 

the actual roads needed due to discovering additional streams, soils issues, etc, during timber sale layout). See Appendix B for details 

of estimating methods. 2

 Estimated existing road miles that would need to be reconstructed. 3

 Percentages are based on 935 VCUs that contain at least 100 acres of NFS lands. 

It should be noted that these projected road densities are based on harvesting at the 

ASQ level, including both non-interchangeable components (NIC) I and II, over the 

next 100 years or so. Some adjustment has been made to the harvest acres to 

account for normal “fall down” that would result from actual on-the-ground surveys 

during layout when more streams, unsuitable soils, and other factors greatly reduce 

the actual amount of road and harvest that would occur on these lands. However, 

based on past harvest practices, even these adjustments may overestimate the 

future amount of harvest area, these road densities represent maximums and are 

not likely to be achieved. 
Environment and Effects 3 

Final EIS 3-81 Fish 

Soils of high risk for landslide or mass wasting failure are those indicated as a mass 

movement index of 3 (MMI 3) (generally gradient of 55 to 72 percent). The upper 

ranges of these soils (65 to 72 percent) generally have the higher risk of slope 

failure. Those soils with slopes greater than 72 percent mass movement index of 4 

(MMI 4) are removed from the suitable timber base, but may have small inclusions 

within the MMI 3 layer. Also, current standards and guidelines, in consideration of 

these concerns, recommend avoiding building roads on slopes greater than 67 

percent. Therefore, roads built on soils with slopes greater than about 67 percent 

are considered at greater risk of slumping or mass failure, increasing the chance of 

large amounts of sediment entering streams. The miles of road likely to be 

constructed on soils of this type are shown in Table 3.6-3. While the area is small 

among all alternatives, due to standards and guidelines that restrict construction of 

roads in regions of this slope category, there are differences among the alternatives. 

Overall, Alternative 1 has the lowest portion of new roads in this category. 

Table 3.6-3 

Estimated Maximum Road Miles on Potentially Unstable Soils Based 

on Slopes Greater Than 67 Percent over the Length of the Project 

(approximately 100+ years)1

Alternative 

Road Type 1 2 3 4 5 6 7 

Road mile > 67% 

Slope 9 30 41 66 53 51 80 1

 Includes adjusted roads miles estimated to be needed to harvest all suitable timber in the alternative 

allowing for approximation of fall down (the reduction between the planned and the actual roads 

needed due to discovering additional streams, soils issues, etc, during timber sale layout). 

Alternative 2 and 3 areas are also moderately low, while Alternatives 5 and 6 are 

intermediate and Alternatives 4 and 7 are the highest. 

The number of road crossings of streams increases the risk of both adding sediment 

to streams and impeding fish passage (Class I and II streams). While the BMP for 

construction methods of culverts and bridges reduce these risk for sediment and 

turbidity, monitoring of some streams, which have mostly compliance with water 

quality standards, have found occasional increases in turbidity at least in the short 

term as described in the USDA Forest Service Tongass Monitoring Reports (USDA 

Forest Service 2004c). Also, new fish passage guidelines (Forest Service 

Handbook 2090.21 Aquatic Habitat Management Handbook as USDA Forest 

Service 2001a) for culvert design greatly reduce risk of new culvert installation 

impeding fish passage on Class I and II streams. But some risks still remain. An 

index of these risks to both added sediment from road crossings and impedance of 

fish passage is shown in Table 3.6-4. Currently about 3,600 fish stream crossings 

exist on the Tongass. The various alternatives would add moderately to this number 

increasing risk. Alternative 1 would have the least risk, while Alternatives 4 and 7 

would have the most risk. Alternatives 5 and 6 would be similar, and intermediate. 

In general the trend follows that of road miles constructed. 
3 Environment and Effects

Fish 3-82 Final EIS

Table 3.6-4 

Estimated Number of Existing and Maximum New Stream Crossings for New 

Roads by Alternative over the Length of the Project (approximately 100+ years)1

Alternative 

Stream Class Existing2

1 2 3 4 5 6 7 

I 1,300 47 137 193 377 296 293 472 

II 2,300 121 293 389 769 621 603 958 

III - 650 1,783 2,371 3,917 3,186 3,093 4,899 

Total 3,600 817 2,213 2,952 5,064 4,103 3,989 6,328 1

 Based on adjusted roads estimated to be needed to harvest all suitable timber in the alternative allowing for 

approximation of fall down (the reduction between the planned and the actual roads needed due to discovering 

additional streams, soils issues, etc, during timber sale layout). See Appendix B for details of estimation methods. 2

 Approximate estimate based on USDA Forest Service 2006 data. Values expanded based on portion of road miles 

assessed and known portion of Class I and II crossing in the Tongass. Class III stream crossing not assessed. 

Timber Harvest 

Timber harvest activities can increase risk to fish resources. Protection of riparian 

areas, including floodplains, areas of riparian vegetation, and certain wetlands 

associated with riparian systems are of particular concern. As discussed earlier, 

riparian vegetation serves many important functions for stream fish habitat, including 

supplying LWD, food input, and stream shade to name a few. Also of concern is the 

amount of protection afforded steeper channels (often not fish-bearing) in the 

headwaters areas and protection of steep hillslope areas. These streams (e.g. 

class III streams) also require LWD to properly function (Paustian et al. 2006), as 

well as contributing nutrients, food resources, and, in some situation, LWD to 

downstream fish streams. Protection of estuaries is also important when locating 

roads and timber harvest units. Although Forest Plan standards and guidelines 

associated with riparian areas, wetlands, and beach and estuary fringe are expected 

to protect fish resources from significant impacts associated with timber harvest, 

there is still some level of risk. The risk is related to the level of harvest, portion of 

streams in the harvest area, and quantity of potentially unstable slopes in the 

harvest area associated with each alternative. 

Timber harvest activities on the Forest could potentially affect as many as 144,000 

(Alternative 1) to 1,070,000 total acres (Alternative 7) after full implementation of the 

Forest Plan (100+ years) (Table 3.6-5). Alternatives 1, 2, and 3 would harvest the 

least acreage and Alternatives 4 and 7 the most, while Alternative 5 (No Action) and 

Alternative 6 (Proposed Action) would be in the higher portion of the intermediate 

range of alternatives. Projected acreages are based on harvesting at the Allowable 

Sale Quantity (ASQ) level, but with adjustment for probable fall down rates to 

account for reductions from on the ground surveys during project examination during 

specific project National Environmental Policy Act (NEPA) evaluation and final 

project layout. Therefore, the values are expected to reasonably approximate 

Forest-wide harvest (see the Timber section). 

As harvested forest areas mature, young growth is predicted to become an 

increasingly larger portion of the harvest. When this occurs, the alternatives with 

lowest overall harvest have the highest portion of second-growth harvest reducing 

areas of new ground disturbance related to harvest. Alternatives 1, 2, and 3 would 

have at least 39 percent as young-growth harvest, while Alternatives 5 and 6 would 

have 33 percent. Altenatives 4 and 7 would have only 25 to 26 percent of the 

harvest as young growth. Actual acres of young growth would range from about 

58,000 under Alternative 1 to 262,000 under Alternative 7. 
Environment and Effects 3 

Final EIS 3-83 Fish 

Table 3.6-5 

Estimated Maximum Acres of Timber Harvest after 100+ Years of Full 

Forest Plan Implementation1

Alternative 

Maximum Acres Likely to be Harvested 

Over the Life of the Forest Plan2

Percent of Likely 

Harvest that is Young 

Growth 

Alternative 1 144,265 40% 

Alternative 2 393,937 46% 

Alternative 3 513,676 39% 

Alternative 4 891,986 26% 

Alternative 5 686,583 33% 

Alternative 6 663,471 33% 

Alternative 7 1,069,624 25% 

1

 Based on the ASQ. Incorporates adjustments for falldown. 

2

 Includes productive old growth and young-growth harvest. 

The number of stream miles within development LUDs can be used as an index to 

risk for fish resources from harvest-related actions. As shown in Table 3.6-6, the 

stream habitat at risk closely follows the quantity of harvest. The total stream miles 

in development LUDs ranges from a low of 4,300 miles for Alternative 1 to 19,900 

miles for Alternative 7 (Table 3.6-6). Class I streams are considered most important 

because these are anadromous and high-quality resident fish streams. Class I 

stream miles range from about 1,300 miles under Alternative 1 to 5,300 miles under 

Alternative 7. Total fish stream miles (Class I and II) range from 2,300 under 

Alternative 1 to 9,500 under Alternative 7. Streams receive substantial protection 

from riparian buffers and the beach fringe under all of the alternatives. In general, 

the riparian protections would greatly reduce direct effects to fish resources. 

However, the greater the miles of streams in development LUDs, the greater the risk 

to fish resources. The lower reaches of all streams under Alternatives 1, 2, 3, 4, 5, 

and 6 would be protected within a 1,000-foot beach fringe and Class I, II, and III 

streams would all receive buffers. Alternative 7 would fully protect a smaller portion 

of lower stream reaches because of only a 500-foot beach fringe. Alterntive 7 would 

not require buffers on Class III streams, which may affect downstream fish-bearing 

streams through a reduction in LWD contributions in certain situations 

(Paustian et al. 2006). 

Table 3.6-6 

Mapped Stream Miles1

 within Development LUDs by Alternative 

 Alternative 

Stream Class 1 2 3 4 5 6 7 

I 1,341 2,364 3,037 4,841 3,752 3,628 5,274 

II 951 1,772 2,321 3,912 3,117 2,983 4,216 

III 2,004 4,582 6,318 9,657 7,618 7,344 10,425 

Total 4,295 8,718 11,676 18,411 14,487 13,954 19,915 1

 Note: Streams have been inventoried more completely in areas that were proposed as Development LUDs 

compared with areas in Non-development LUDs. Development LUDs include Timber Management, Modified 

Landscape, Scenic Viewshed, and Experimental Forest. 

As noted under the road section, disturbance to hillslope regions with potentially 

unstable soils could cause slumping and mass wasting. While most of the soil types 

of highest risk potential would be excluded from the timber base, some areas may 

still be harvested. Regions greater than 67 percent slope are areas with higher 

potential for slumping (see the Roads discussion in this section). The old-growth 
3 Environment and Effects

Fish 3-84 Final EIS

acreage of these areas that may be harvested is shown in Table 3.6-7. Because of 

very limited harvest, Alternative 1 has the least area of potential harvest on steep 

slopes and Alternative 2 is also relatively low. The larger area of harvest on steep 

slopes would be under Alternatives 4 and 7, while Alternatives 3, 5, and 6 are 

intermediate. 

Table 3.6-7 

Estimated Maximum Acres of Old-Growth Harvest on Potentially 

Unstable Soils (Slopes > 67%) after Full Implementation of the Forest 

Plan (approximately 100+ years)1

 Alternative 

 Hill Slope 1 2 3 4 5 6 7 

Harvest Acres on 

Slopes > 67% 

 

2,414 

 

8,176 

 

12,391 

 

21,592 

 

17,445 

 

16,626 

 

30,036 1

 Includes adjusted harvest acres estimated in the alternatives allowing for approximation of fall down (the 

reduction between the planned and the actual harvest area due to discovering additional streams, soils 

issues, etc, during timber sale layout). See Appendix B for details of estimating methods. 

Fish Habitat Enhancement and Log Tranfer Facilities 

Fish enhancement projects, such as fish passage, stream and lake stocking, and 

lake fertilization would not be affected by any of the considered alternatives. Project 

enhancement funding and selection of projects is primarily independent of amount 

or location of timber harvest; therefore, all alternatives would have similar effects on 

enhancement activities. 

Effects of LTFs on marine aquatic species are addressed in the Transportation and 

Utilities section of this chapter. Generally, effects would be somewhat proportional 

to the amount of harvest and include slight coverage of shallow (less than 60 feet 

deep) regions of nearshore habitat with wood debris (primarily bark), affecting 

primarily benthic marine organisms in very small areas of tidal and subtidal habitat. 

Fish/Riparian Panel Assessment Elements 

The panel process is described in the Introduction to this chapter. The 1995 

Fish/Riparian Assessment panel included four fisheries scientists and two physical 

scientists (hydrology and geomorphology). The 1997 assessment meeting included 

just the original four fisheries scientists. The first panel assessed both effects to fish 

and stream physical attributes (relating to riparian conditions), while the second 

panel only assessed effects to fish of a subset of the alternatives included in the 

1997 EIS. 

The detailed results of the first assessment panel analysis is presented in the 1997 

FEIS (USDA Forest Service 1997a) and will only be summarized here because 

many of the factors among current and past alternatives differ. At the time of the 

first panel meeting, the 1997 Alternative 11 (Alternative 5 [No Action] in this 

analysis) was not available to the panels. The second panel, however, included this 

alternative in its assessment. The 2007 alternatives that are based on a 

corresponding 1997 alternative are as follows: 

• 2007 Alternative 4 was based on 1997 Alternative 6 

• 2007 Alternative 5 was based on 1997 Alternative 11 

• 2007 Alternative 6 was based on 1997 Alternative 11 

• 2007 Alternative 7 was based on 1997 Alternative 2 
Environment and Effects 3 

Final EIS 3-85 Fish 

The extension of the panel assessments from the 1997 alternatives to the 

corresponding 2007 alternatives are primarily based on similarities in acres and 

locations of potential harvest, miles of proposed roads, and the level of riparian 

protection and beach/estuary protection between the alternative pairs. In general, 

the acres and locations of harvest and the miles of proposed roads are very similar 

for each alternative pair. Similarly, the beach/estuary protection level is the same 

within each pair. The level of riparian protection is also the same between the 2007 

Alternatives 5 and 6 and the 1997 Alternative 11. However, the 2007 Alternative 4 

has slightly greater riparian protection than the 1997 Alternative 6, and the 2007 

Alternative 7 has the same riparian protection as the 1997 Alternative 2. The 

extension of panel assessment conclusions is qualified below, where appropriate. 

The fisheries and physical scientists rated five possible outcomes for each of eight 

species of fish, including both resident and anadromous life strategies for two of the 

species. The fish considered included all five salmon species, cutthroat trout, 

steelhead, and Dolly Varden char. The physical scientist rated the effects of each 

alternative on natural stream conditions based on stream attributes, including 

amount of large woody debris, percent pool area, and stream width-to-depth ratio; 

residual pool depth; and stream bed grain size for a similar five possible outcomes.

The panels for fish and riparian estimated the effect of each alternative in one of five 

outcomes (categories) of effects to fish and riparian conditions. Alternatives rated in 

the first two outcomes (Outcome I and II) generally had mostly no or minimal 

adverse effects to fish or riparian conditions. Alternatives that had greater portion of 

ratings in Outcomes III, IV, and V had moderate to severe rated adverse effects to 

fish or riparian conditions (Dunlap 1996, 1997). 

Generally, adverse effects of any alternative in the 1997 EIS were lower and varied 

less among alternatives on Chinook and sockeye salmon than other species. This 

is because most Chinook salmon in the Tongass region are present in large river 

systems (mostly flowing out of Canada) or on Admiralty Island, and most of these 

systems would have little management activity that could affect them. Sockeye 

salmon primarily spawn and rear in lakes (although some stream spawning does 

occur), and lake areas are well protected under all alternatives. Other species, 

including coho, pink and chum salmon, cutthroat trout, steelhead, and Dolly Varden 

char are more at risk from management activities because of their greater reliance 

on stream habitats for spawning, rearing (fry, juvenile), and immigration. The 

outcome rating for these species was more varied among alternatives and varied 

among species, mostly based on the amount time and number of life stages spent 

within streams of the Tongass. Generally, the panel assessments concluded that 

the level of road construction and timber harvest was positively related to the level of 

risk to fish and fish habitats. This same trend would hold for the 2007 alternatives. 

The scientists in the panels noted several factors they considered important in their 

evaluation of risks for these alternatives (Dunlap 1996, 1997). These parameters 

are relevant for evaluation of the current alternatives. Generally, roads were 

considered the greatest risk to fish resources. Amount, location, and type of timber 

harvest, especially relative to steep slopes, soil type, stream type, and estuaries 

were also considered very important in affecting risk. Watershed analysis was 

important where guidelines would be modified. Also, high levels of riparian 

protection were a major item considered important for protection of fish resources 

and their habitat. Firm standards, guidelines, and adequate monitoring were all 

considered important. Most of the panel’s concerns and recommendation were 

considered and adopted into the final alternative selected for 1997 and are 

incorporated into Alternatives 1, 2, 3, 5, and 6, to a slightly lesser extent into 

Alternative 4, and even less into Alternative 7. 
3 Environment and Effects

Fish 3-86 Final EIS

The panels described the significant characteristics of each of the alternatives that 

affected their evaluation. Below is a summary of the 2007 alternatives presented 

with reference to the panel assessments. 

Alternative 1: This alternative would have future harvest and road construction 

concentrated in a relatively small part of the Forest, which would reduce additional 

degradation and facilitate recovery of degraded habitat in some watersheds. 

Riparian and beach/estuary protection would be high because the Alternative’s 

Riparian and Beach/Estuary Standards and Guidelines are essentially the same as 

the current Forest Plan standards and guidelines. These are the same as the 1997 

Alternative 11 standards and guidelines, which were highly rated by the expert 

panel. Overall, harvest and road construction levels would be the lowest among the 

alternatives. Because of the low level of harvest and road construction as well as 

the level of riparian protection, if this alternative were to be evaluated by the panel 

today, it would likely rank as the lowest risk alternative among the alternatives 

considered in this EIS, and would generally rank between the two lowest risk 

alternatives of the 1997 alternatives. 

Alternative 2: This alternative is similar to Alternative 1, but with moderately 

greater distribution of harvest area and increase in roads. Riparian and 

beach/estuary protection would remain high for the same reasons as for Alternative 

1. Harvest and road construction would be increased moderately over Alternative 1 

expanding into some new area, but still remain relatively low. It would rank second 

lowest risk among alternatives evaluated in this EIS and would likely have been 

between the second and third lowest risk alternative evaluated by the panel in the 

1997 EIS. 

Alternative 3: This alternative increases harvest considerably over Alternative 1 by 

expanding into many more watershed areas. However, riparian and beach/estuary 

protection would remain high for the same reasons as Alternative 1. The moderate 

network of roads and harvest would increase likelihood of areas of habitat 

degradation and reduce likelihood of habitat recovery. This alternative, based on 

riparian protections and moderate harvest, would be ranked third lowest for risk 

among this EIS alternatives and likely would have been ranked between the third 

and fourth among alternatives for the 1997 EIS by the panel.

Alternative 4: This alternative is based on the 1997 Alternative 6. The panel 

assessments concluded that the relatively large area harvested and moderate road 

network in this alternative would increase the chance of gaps in fish distribution and 

fish habitat recovery (Dunlap 1996). The old-growth reserves and retention 

proposed in this alternative may offset some of the harvest and road effects. 

However, if this alternative were evaluated by the panel today, it would likely rank as 

the second highest risk alternative among the alternatives considered in this EIS; it 

ranked in the middle of the 1997 alternatives evaluated (Dunlap 1996). 

Alternative 5 (No Action): This alternative is the 1997 Forest Plan (Alternative 11) 

as amended. The panel assessment concluded that the relatively few miles of 

roads and moderate levels of timber harvest over the next 100 years in this 

alternative would reduce risk to fish habitat (Dunlap 1997). Further, the panel noted 

that the Forest-wide relatively high riparian protections would have relatively low 

risks to fish habitat (Dunlap 1997). If this alternative were evaluated by the panel 

today, it would likely rank as the third highest risk alternative among the alternatives 

considered in this EIS; it ranked in the lower risk group of alternatives in 1997 

(Dunlap 1997). 

Alternative 6 (Proposed Action): This alternative was based on the 1997 

Alternative 11. This alternative would have very slightly lower harvest and roads 
Environment and Effects 3 

Final EIS 3-87 Fish 

than the current Alternative 5. The panel assessment concluded that the relatively 

few miles of roads and moderate levels of timber harvest over the next 100 years in 

this alternative would have relatively low risk to fish habitat (Dunlap 1997). Further, 

the panel noted that the Forest-wide relatively high riparian protections would 

reduce the risks to fish habitat (Dunlap 1997). If this alternative were evaluated by 

the panel today, it would likely rank as the fourth highest risk alternative among the 

alternatives considered in this EIS; it would have ranked in the lower risk group of 

alternatives in 1997 (Dunlap 1997). 

Alternative 7: This alternative was based on the 1997 Alternative 2. The panel 

assessment concluded that the road network and area harvested would increase 

the likelihood of areas of future habitat degradation and reduce the likelihood of 

habitat recovery (Dunlap 1996). Of particular concern was harvest on MMI 3 soils, 

which has greater potential to increase stream habitat degradation and increase 

risks to stream channels and fish habitat due to lower riparian protection along 

Class III streams (Dunlap 1996, 1997). In addition, the 1997 panel assessment 

concluded that management of slopes around steep-gradient Class III streams 

could change the rate of wood and sediment delivery and affect downstream fish 

habitat over the long term (Dunlap 1997). This alternative was thought to result in 

degradation of fish habitat and increase gaps in fish distribution in the next 100 

years (Dunlap 1997). Estuary protection would be high because of the essential 

continuation of current Forest Plan standards and guidelines for estuaries, which 

were highly rated by the panel (Dunlap 1997). Although beach protections are 

reduced for this alternative relative to others. Overall, harvest and road 

development would be the highest, and riparian protections the lowest, of all 

alternatives. If the panel were to assess this alternative it would likely rate it as the 

highest risk to fish resources of any in this EIS. The comparable 1997 alternative 

was rated second highest for risk among all alternatives evaluated in 1997. 

Threatened and Endangered Species 

Consultation requirements for the Forest Plan Revision under Section 7 of the ESA, 

as amended, were completed with the USFWS and NMFS for the 1997 Forest Plan 

EIS. Both USFWS and NMFS reviewed the biological assessments for threatened 

and endangered species under their regulatory jurisdiction and concluded that the 

Tongass Forest Plan Revision was “not likely to adversely effect” threatened or 

endangered species occurring on the Tongass for the 1997 Plan. These findings 

were made subject to the programmatic scope of the Forest Plan Revision and 

following the associated Forest-wide standards and guidelines (see Chapter 4 of the 

1997 Forest Plan).

Formal and informal consultation procedures (as directed by the ESA, as amended 

in 50 CFR 17.7, and Forest Service Manual 2670) are used with NMFS and USFWS 

on all projects that implement the 1997 Forest Plan. Forest-wide standards and 

guidelines (see Chapter 4 of the amended Forest Plan) for threatened, endangered, 

and sensitive species direct that all projects would comply with requirements of the 

ESA, as amended, and Forest Service policy (Forest Service Manual 2670). 

Because Alternative 11 of the 1997 Forest Plan Revision Final EIS was deemed not 

likely to adversely affect threatened or endangered species occurring on the 

Tongass, the alternatives being examined in this EIS would also likely fall in this 

category because they have the same or similar protective measures as Alternative 

11 from the 1997 Final EIS, with the exception of greater acreage harvested under 

Alternatives 4 and 7. 

Most of the currently ESA-listed salmon and steelhead are unlikely to be in marine 

waters near the Tongass Forest because their migration routes and rearing areas 

Species 

Assessments 
3 Environment and Effects

Fish 3-88 Final EIS

mostly to the west of the forest boundaries, although a small number may be 

present in the inner waters. Because of this very limited distribution relative to the 

project and lack of affects to the marine environment, it is not anticipated that 

adverse effects would occur to listed fish species from any of the alternatives. The 

Biological Assessment for the considered actions is presented in Appendix F. The 

conclusion of this Biological Assessment is that the considered actions for the 

Tongass Land and Resource Management Plan are “not likely to adversely effect” 

any endangered or threatened salmon or steelhead ESU/DPS. 

Essential Fish Habitat Assessment 

Section 305(b)(2) of the Magnuson-Stevens Act requires all federal agencies to 

consult with the Secretary on all actions or proposed actions authorized, funded, or 

undertaken by the agency that may adversely affect EFH. This consultation is done 

for site-specific projects with ground-disturbing activity. The application of Forestwide standards and guidelines and BMPs developed to meet soil protection, water 

quality standards, and fish habitat protection will help protect EFH on the Tongass 

National Forest and adjacent estuarine and marine waters. Because adoption of the 

Forest Plan does not specifically result in any actions that could affect EFH, and any 

action that would be taken following adoption of the Plan that could affect EFH 

would have a formal EFH developed, no formal EFH was developed for the 

considered actions in this EIS. 

Sensitive Species 

Northern Pike 

Northern Pike are found in five lakes east of Yakutat. Forest-wide standards and 

guidelines for wetlands and riparian management generally cover these areas. 

Although road access exists within 0.5 mile of Pike Lakes, there is no land suitable 

for timber harvest immediately around the lakes. Natural habitat conditions 

associated with the lakes are expected to be maintained under all alternatives; 

therefore, no effects are anticipated. 

Fish Creek Chum Salmon 

The habitat for the Fish Creek chum salmon, near Hyder on the Portland Canal, 

would be managed in accordance with the Forest-wide standards and guidelines for 

wetlands and riparian management (see Chapter 4 of the amended Forest Plan) 

under all alternatives; one exception is the elimination of Class III stream buffers 

under Alternative 7. Additional standards and guidelines for chum salmon that apply 

to the Fish Creek chum salmon include coordination with appropriate agencies to 

protect, maintain, and preserve this run of chum salmon, and to provide for habitat 

improvement as necessary to maintain the viability of the run. Alternative 1 is 

expected to have no effect on the Fish Creek chum salmon. Alternatives 2, 3, 4, 5, 

and 6 would have a slight risk of effects, but if effects occur, they are not expected 

to be significant. Alternative 7 would have a larger risk of effects because of the 

elimination of Class III stream buffers under this alternative; but the potential for 

significant effects is still small. 

There have been improvement projects to increase spawning habitat for this 

population. With these improvement projects, the habitat for these chum salmon is 

expected to be improved in the future. Alternatives 2, 3, 4, 5, 6, and 7 would 

maintain the current LUD as Scenic Viewshed, which would allow continued habitat 

improvements. Alternative 1 would convert this area to Remote Recreation, which 
Environment and Effects 3 

Final EIS 3-89 Fish 

may limit continued enhancement activities and/or the ability to conduct stream 

habitat improvement projects. 

Island Run King Salmon 

King Salmon River and Wheeler Creek habitats for island run king salmon are both 

within Kootznoowoo Wilderness. Natural habitat conditions are to be maintained, 

and specific Forest-wide standards and guidelines also apply (see Chapter 4 of the 

amended Forest Plan). None of the alternatives would change how this area would 

be managed. Application of the wilderness prescription and Forest-wide standards 

and guidelines to sustain habitat conditions would not result in any affects on these 

island run king salmon. 

Invasive Aquatic Species 

ADF&G lists four species of fish that are non-native to Alaska found in Alaskan 

waters (Fay 2002). Only two, the Eastern Brook trout and Atlantic salmon, have 

been found in the aquatic habitats of the Tongass National Forest. Additionally, 

northern pike, which has only been found in apparently native waters in the Yakutat 

area in the Tongass, is of greatest concern because of its potential to directly impact 

native salmon species. Other aquatic species, including the Chinese mitten crab and 

New Zealand mudsnail, both of which can inhabit freshwater, are a major concern for 

impacts they would cause if they invaded these aquatic habitats (Schrader and 

Hennon 2005, Fay 2002). While no alternative would have substantial effects on 

invasion or establishment of non-native aquatic species, some actions could have 

potential indirect effects. One of the biggest concerns for invasive fish is active 

stocking of waters primarily with species often considered game fish in other areas. 

This would apply primarily to northern pike, which can inhabit lakes and rivers. In 

general then, alternatives that increase human access to fresh waters within the 

Forest would have the greatest risk of increasing invasive aquatic species in aquatic 

habitat of the Forest. The major form of increased access to aquatic habitats of the 

Forest would be through increased roads where people may travel with invasive 

species either intentionally, such as northern pike, or by accident, such as in the 

case of some aquatic species, like the New Zealand mudsnail. Based on this 

criterion, the relative risk would be proportional to road miles (Table 3.6-2) with 

Alternative 1 having the least and Alternative 7 having the most risk. 

Some negative effects, or more appropriately, increased risk to, the natural range of 

variation in stream processes and fish habitat would likely occur by management 

activities over the long term for all alternatives. The extent of harvest activity and 

associated road development are likely to result in decreases of some fish 

populations in managed watersheds. Measures taken to mitigate, or moderate, the 

negative effects have been incorporated into the alternatives in ways to reduce 

levels of risk to the fisheries resource. All alternatives have the same or 

substantially similar standards and guidelines that influence fish habitat as were 

adopted following the 1997 EIS. While the standards and guidelines do supply 

substantial protection of fisheries resources, some risk of impacts would remain, 

and these are generally proportional primarily to the amount of road miles and to a 

lesser degree on acres harvested. Therefore, the major difference between the 

alternative is the relative risk from the construction of roads and harvest, which are 

directly proportional to the quantity of these two parameters by alternative. In 

general, Alternatives 1, 2, and 3 would have the lowest risk because of low harvest 

and road miles, 5 and 6 would be intermediate and similar because harvest is very 

similar, and Alternative 4 and especially 7 would have most risk to fish resources 

due to the relatively high portion of harvest and road building. 
3 Environment and Effects

Fish 3-90 Final EIS

Conclusions – Direct and Indirect Effects 

Much of this EIS evaluation has been based on the conclusions, derived from 

scientific literature, monitoring reports, and expert evaluations, that current Forest 

Plan standards and guidelines, practices, and related BMPs are adequate to ensure 

minimal or no harm to fish resources, at least for most of the alternatives 

considered. However, there is a degree of scientific uncertainty associated with 

these conclusions. The current Plan has only been in place for 10 years, although 

many of the practices have been in place longer. The active monitoring that has 

been occurring does not suggest marked problems with water quality or fish 

resources as a result of these actions (USDA Forest Service 2004c, 2006b). While 

active monitoring has been occurring, the full effect of these types of actions has not 

had an extensive period of evaluation. Even though relevant information indicates 

protections would be adequate under most of the alternatives, there is some risk to 

fisheries resources in implementing any of the considered alternatives. 

Based on best available science, it can be concluded that there is a relatively low 

long-term risk to fish habitat from Alternatives 1, 2, 3, 5, and 6 because of low to 

moderate levels of timber harvest and road construction, and the relatively high 

riparian protections offered by Forest Plan standards and guidelines. Under 

Alternative 4, the risks are higher because of an increase in harvest and road 

development, and the risks are higher yet under Alternative 7 because of further 

increases in harvest and road development, and a decrease in riparian protections 

for Class III streams. 

General 

The effects of the alternatives on fish resources may be influenced by other actions 

occurring in the project area. The main cumulative factors affecting fish are related 

to land development actions that occur regionally. This includes primarily other 

timber harvest-related actions on non-NFS lands, especially associated roads. The 

total lands within the Tongass National Forest boundary, which includes all NFS 

lands and other non-NFS lands, equals about 17.8 million acres. Of this, only about 

6 percent (1.1 million acres) are non-NFS lands. However, development actions on 

these non-NFS lands, which include most cities and towns in Southeast Alaska, are 

moderately intense. 

As discussed previously, one of the main factors affecting fish resources in the 

Tongass is the level of road development. Generally, the greater the density of 

roads in the watershed, the greater risk there is to fish resources. Among several 

indicators used by NMFS (1996) to characterize status of watershed conditions, they 

recommended a maximum road density threshold levels for maintaining “properly 

functioning” watersheds for coastal salmon as 2 miles per square mile, with 

increased risk to salmon as road densities increase beyond this value. There are 

947 VCUs inside the Tongass boundary, including both NFS and non-NFS lands. 

VCUs approximate watershed sizes, so road densities by VCU would be 

comparable for evaluating conditions relative to NMFS threshold road densities. 

The average road densities by alternative and for the region are shown in Table 

3.6-8. For this assessment, we have assumed an increase in road miles on nonNFS lands for the life of the project (100+ years). The average road density on nonNFS lands is much higher than on NFS lands. This high average density is partly the 

result of the high number of road miles in city areas, as well as concentrated timber 

harvest areas. Even though the amount of non-NFS land area is relatively low, high 

density on these lands results in the overall average densities increasing sharply 

relative to NFS lands. However, even with these increases, overall averages 

remain relatively low for any alternative, ranging from 0.42 (Alternative 1) to 0.60 

(Alternative 7). 

Cumulative 

Effects 
Environment and Effects 3 

Final EIS 3-91 Fish 

Table 3.6-8 

Estimated Average Total Road Density on Tongass NFS Lands and Non-NFS Lands 

within the Tongass National Forest Boundary by Alternative over 100+ years1

Road Density as Miles/Square Mile 

Alternative 

Road Density on NFS 

Lands 

Road Density on Non-NFS 

Lands2

Total Road 

Density All 

Lands 

Existing 0.19 2.19 0.31 

Alternative 1 0.22 3.49 0.42 

Alternative 2 0.29 3.49 0.47 

Alternative 3 0.32 3.49 0.49 

Alternative 4 0.40 3.49 0.57 

Alternative 5 0.35 3.49 0.53 

Alternative 6 0.35 3.49 0.52 

Alternative 7 0.43 3.49 0.60 

1

 Assumes full implementation of Forest Plan at ASQ levels plus future non-NFS harvest. Includes adjusted roads miles 

estimated to be needed to harvest all suitable timber in the alternative allowing for approximation of fall down (the 

reduction between the planned and the actual roads needed due to discovering additional streams, soils issues, etc, 

during timber sale layout). Annette Island is included because it is surrounded by areas within the Forest boundary. 2

 Assumes an estimated the increase in non-NFS road miles within the Forest boundary from 3,756 miles at present to 

5,970 after 100+ years. 

However, there are VCUs that have higher road densities that are increased by the 

addition of roads from the alternatives (Table 3.6-9). Currently, most (68 percent) of 

the VCUs on NFS lands have no roads and only just over 2 percent have road 

densities exceeding 2 miles per square mile. The inclusion of non-NFS lands 

reduces the percentage of VCUs with no roads to 61 percent and pushes the portion 

of VCUs exceeding 2 miles per square mile to almost 6 percent under existing 

conditions. Under Alternatives 1 and 2 for all lands combined, the percentage of 

VCUs exceeding 2 miles per square mile would increase to a maximum of 10 to 12 

percent after 100+ years. The largest increase in the percentage of VCUs with high 

density would occur under Alternative 7, which would have a maximum of 16 percent 

of VCUs exceeding the 2 miles per square mile threshold. 

After 100+ years, Alternatives 3 through 6 would have a maximum of 12 to 14 

percent of VCUs with density greater than 2 miles per square mile when roads on 

non-NFS lands are included. When roads on all lands are included, a minimum of 

about 37 to 46 percent of the VCUs would still have no roads after 100+ years 

(Table 3.6-9). 

The effect on fish resources are less directly tied to amount of harvest than to roads, 

but harvest may influence them through effects on water quality, riparian 

management, and regions where harvest is allowed, as discussed under direct 

effects. The cumulative effects of timber harvest were discussed in the Water

section on water quality for all lands (including non-NFS lands) within the Forest 

boundary and relate to potential effect to fish resources. Existing conditions include 

retention of 87 percent of the original productive old-growth forest inside the Forest 

boundary and with 95 percent of the land area remaining undisturbed from direct 

timber harvest (Table 3.4-3 of the Water section). Overall the cumulative effects to 

fish relating directly to quantity of timber harvest would be least for Alternative 1 as 

82 percent of the original productive old growth on all lands within the Forest 

boundary would be retained and greatest for Alternative 7 as productive old growth 

would be reduced to 70 percent, in addition to reduced riparian protections for 

Alternative 7. Even with highest harvest alternative, the majority of productive old 
3 Environment and Effects

Fish 3-92 Final EIS

Table 3.6-9 

Estimated Road Miles and Percent of VCUs in Road Density Categories on NFS Lands and on 

All Lands Combined within the Tongass National Forest Boundary by Alternative after 100+ 

years of Full Implementation1

Road Density Alternative 

Categories2

Existing 1 2 3 4 5 6 7 

Road Miles 

Per Sq. Mi. 

NFS 

Lands 

NFS 

Lands 

NFS 

Lands 

NFS 

Lands 

NFS 

Lands 

NFS 

Lands 

NFS 

Lands 

NFS 

Lands 

0 68.0% 67.8% 66.0% 63.6% 52.1% 58.9% 60.0% 51.4% 

>0 - 1.0 21.5% 20.4% 19.4% 20.2% 26.1% 22.4% 21.1% 24.9% 

>1.0 - 2.0 8.0% 7.3% 8.7% 9.3% 13.5% 11.0% 11.4% 13.5% 

>2.0 - 3.0 2.0% 3.5% 4.8% 5.5% 6.6% 6.3% 6.1% 7.6% 

>3.0 - 4.0 0.4% 1.0% 1.2% 1.4% 1.7% 1.4% 1.4% 2.5% 

>4.0 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 

New Miles - 774 2,079 2,799 4,890 3,874 3,744 5,825 

Total Miles 4,941 5,715 7,020 7,740 9,831 8,815 8,685 10,766 

Road Miles 

Per Sq. Mi. 

All Lands All Lands All Lands All Lands All Lands All Lands All Lands All Lands 

0 60.8% 45.1% 44.6% 43.3% 37.2% 41.0% 41.6% 36.9% 

>0 - 1.0 22.4% 35.2% 33.2% 32.9% 34.1% 32.7% 32.0% 32.5% 

>1.0 - 2.0 11.4% 9.7% 10.7% 11.4% 14.9% 12.9% 13.3% 15.1% 

>2.0 - 3.0 4.4% 6.5% 7.5% 7.9% 9.1% 8.9% 8.6% 9.9% 

>3.0 - 4.0 1.0% 2.3% 3.0% 3.3% 3.6% 3.4% 3.4% 4.2% 

>4.0 0.0% 1.2% 1.2% 1.2% 1.2% 1.2% 1.2% 1.4% 

New Miles - 2,988 4,293 5,013 7,104 6,088 5,958 8,039 

Total Miles 8,697 11,685 12,990 13,710 15,801 14,785 14,655 16,736 1

 Assumes full implementation of Forest Plan at ASQ levels plus future non-NFS harvest. Roads on NFS lands adjusted for fall down. 

Estimated the increase in non-NFS road miles within the Forest boundary from 3,756 miles at present to 5,970 after 100+ years. Annette 

Island is included as a VCU because it is surrounded by areas within the Forest boundary. 2

 For NFS lands, percentages are based on 935 VCUs that contain at least 100 acres of NFS lands. For all lands, percentages are based 

on all 947 VCUs inside the Forest boundary, including Annette Island. 

growth would remain unaffected for the full implementations of the Forest Plan over 

more than a 100-year period (Table 3.4-3 of the Water section). Total cumulative 

effects to fish resources, based on relative amount of area disturbed, would be 

relatively low as 90 to 94 percent of the land base would remain undisturbed by 

direct timber harvest for all alternatives. However, some local regions may have fish 

resources affected where watershed harvest levels and road density are high. 

Additionally, with less protections for riparian areas on state and private land (e.g., 

no required buffers on non-fish bearing streams, and some fish bearing streams), a 

greater risk to fish resources would occur in watersheds that have a high portion of 

non-NFS harvest occurring. Again, effects of harvest activities on fish resources 

would ultimately be considered at the project-specific levels, ensuring minimal 

adverse cumulative effects. 

Climate Change 

Climate change is one factor that has some unquantifiable potential to affect fishery 

resources on the Tongass. While the models do not fully agree on the climate 

change predictions for Southeast Alaska, they generally predict warmer weather, 

with more winter rainfall, less snowfall, and a decrease in summer rain in some 

areas. Both factors, if large enough, have the potential to affect fish resources. 

Climate models from both the Canadian Climate Center and the Hadley Center 
Environment and Effects 3 

Final EIS 3-93 Fish 

predict rising temperatures and a 10 percent decrease in summer precipitation in 

portions of Southeast Alaska (though they differ on the areas affected). Given the 

high summer rainfall levels in Southeast Alaska (Ketchikan averages over 7 inches 

of rain per month in the summer), a 10 percent decrease in summer rainfall would 

still result in wet conditions in most years. However, Southeast Alaska does 

occasionally experience dryer conditions. For example, in July 1971 there were 23 

days without rain. Juday et al. (1998) postulate that warmer, dryer conditions could 

increase stream temperatures and cause reduced seasonal low flows, both of which 

could adversely affect salmon. Reduced stream flow in summer months and high 

water temperatures during this same period have been a common concern for 

salmonid populations in much of their native range. These types of concerns are 

less prominent in the cool wet environment common in Southeast Alaska, although 

some conditions of low flow and higher stream temperature resulting in adverse 

effects have been observed. Specific concerns, for example, include changes in the 

timing of emerging pink and chum salmon and the potential for not being properly 

timed with early marine planktons supplies (Heard and Salo 1991), and elevated 

temperatures and lower summer flows reducing holding pool survival of adults 

because of dissolved oxygen depletion. 

In the case of coho salmon, sidechannels may have lower flows and increased 

temperatures, which could reduce their usability. However, increased temperature 

could reduce rearing time in freshwater for coho salmon from 2 years to 1, which 

may have advantages (less overwinter mortality) and disadvantages (smaller size 

on marine water entry, reducing marine survival). Sea-level rise could inundate 

estuarine rearing areas. However, the Southeast Alaska land mass is rising in many 

areas, and the potential change in water level over the next century is 0.3 to 3 feet, 

while some areas, particularly in northern Southeast Alaska, may rise several feet 1 

to 4 feet (Kelly et al 2007). Changes in the next decade or two, will obviously be 

much less. So overall effects on estuarine areas and fish stocks will vary 

considerably and, within the timeframe covered by this Forest Plan amendment (i.e., 

10 to 15 years) changes are difficult to predict and may even be difficult to detect. 

In summary, there is general agreement that the climate is warming and that 

summer precipitation is may decline. However, there is considerable uncertainty 

surrounding specific predictions and even more uncertainty regarding the effect of 

these changes on resources including fish. 

Conclusions – Cumulative Effects 

Overall, the cumulative effects of considered alternative actions in conjunction with 

other non-NFS lands and actions associated with timber harvest would increase the 

regions of greatest risk for fish resources. While all alternatives would increase high 

road density areas, overall the number of VCUs of increased risks to fish remains 

relatively small, at 16 percent for the entire region, even for Alternative 7, which has 

the highest average density and the highest frequency of high road density areas. 

Other alternatives would have less risk with high road density areas ranging from 

about 10 to 14 percent for all lands combined. Cumulative effects of actual timber 

harvest would follow a similar trend among the alternatives; however, the potential 

cumulative effects of harvest, road building, and other actions would be evaluated 

on a project-specific basis so that the potential for adverse cumulative effects to fish 

resources within a given watershed could be reduced or eliminated. 
3 Environment and Effects

Fish 3-94 Final EIS

This page is intentionally left blank. 
Environment and Effects 3

Final EIS 3-95 Plants 

Plants 

Affected Environment................................................................................3-95

Plant Communities ....................................................................................3-95

Vegetation Classification...........................................................................3-96

Vegetation Mapping ..................................................................................3-97

Threatened, Endangered, Sensitive, and Rare Plants .............................3-97

Invasive Plant Species ........................................................................... 3-101

Environmental Consequences............................................................... 3-105

Direct and Indirect Effects...................................................................... 3-105

Cumulative Effects ................................................................................. 3-114

Affected Environment 

This section describes the affected environment for plants on the Tongass National 

Forest. It is divided into three areas of focus: Plant Communities, Threatened, 

Endangered, and Sensitive (TES) Species, and Invasive Plants. The Plant 

Communities subsection below provides an overview of vegetation and describes 

the process and status of vegetation classification and vegetation mapping on the 

Tongass. The Threatened, Endangered, Sensitive, and Rare Plant and Invasive 

Plant Species subsections below include an overview of current conditions. 

The composition, age, and structure of the plant communities present today on the 

Tongass are the result of interactions between biological and physical environments, 

natural disturbances, and land use history. This subsection introduces the 

ecological context for the occurrence of common forested and non-forested plant 

communities. 

The coastal forest of Southeast Alaska is part of the cool, temperate rain forest that 

extends along the Pacific coast from Northern California to Cook Inlet in Alaska. 

Most of the Forest is composed of old-growth conifers, primarily western hemlock 

(Tsuga heterophylla) and Sitka spruce (Picea sitchensis), with a scattering of 

mountain hemlock (Tsuga mertensiana), Alaska yellow-cedar (Chamaecyparis 

nootkatensis), and western redcedar (Thuja plicata) in the south. Red alder (Alnus 

rubra) is common along streams, beach fringes, and on soils recently disturbed by 

management activities and landslides. Black cottonwood (Populus balsamifera ssp. 

trichocarpa) grows on the floodplains of major rivers and recently deglaciated areas. 

Blueberry and huckleberry (Vaccinium spp.), Sitka alder (Alnus viridis spp. sinuata), 

devil’s club (Oplopanax horridus), and salal (Gaultheria shallon) are common shrubs 

in forested communities. The Forest floor is habitat for a variety plants, such as 

false lily-of-the-valley (Maianthemum dilitatum), bunchberry (Cornus canadensis), 

five-leaf bramble (Rubus pedatus), and skunk cabbage (Lysichiton americanum). 

Because of the high rainfall and resulting high humidity, a large variety of mosses 

grow in great profusion on the ground, fallen logs, the lower trunks and branches of 

trees, as well as in forest openings. Hundreds of epiphytic lichen species can also 

be found on tree trunks and branches, especially in old-growth forests, riparian 

areas, and maritime beach fringe forests. 

Grass and sedge meadows usually lie at low elevations, often along the coast and 

toeslopes of hills and mountains. Stands of willows (Salix spp.) border many of the 

stream channels. Muskeg (peatland) communities, dominated by shore pine (Pinus 

contorta var. contorta), peat moss (Spaghnum spp.), and sedges (Carex spp.), 

Plant 

Communities 
3 Environment and Effects

Plants 3-96 Final EIS

occur throughout the Forest. These non-forest vegetation types are also described 

in the Wetlands and Biodiversity sections of this chapter. 

Alpine and sub-alpine vegetation usually occurs above 2,500 feet elevation. The 

sub-alpine zone is often dominated by mountain hemlock (Tsuga mertensiana) 

where the coastal forest treeline begins to decline into low-lying and krumholtz 

vegetation between 2,500 and 2,800 feet elevation. Resident plants have adapted 

to persistent snow cover and wind desiccation by evolving low-growth forms. Matforming heaths, such as mountain heather (Cassiope spp. and Phyllodoce spp.), 

cover much of the area, with cushion-like flowering plants and non-vascular plants 

(lichens, mosses, and liverworts) occupying exposed rock outcrops, crevices, and 

talus slopes. 

The detailed description and effects analysis to vegetation on a habitat/landscape 

scale can be found in the Biodiversity section of this chapter. 

Integrating vegetation information in analysis, planning, and decisionmaking 

includes the development of vegetation classifications, the use of the classifications 

to map vegetation with remotely sensed imagery, and ecological models. 

Classification of vegetation types is an effective tool for studying, understanding, 

and communicating habitat information. Vegetation classifications at appropriate 

scales have been widely used in wildlife management, forest planning, project 

planning, and silviculture in the National Forests. Vegetation classifications can be 

used to identify realistic objectives and management opportunities, determine 

capability and suitability, and evaluate forest health. They can be used to streamline 

monitoring design and facilitate extrapolation of monitoring interpretations; assess 

risks for the introduction of invasive species, fire, insects, and disease; and describe 

current habitats for plant and animal species based on current vegetation 

composition, structure, and function. Function refers to the interactions and 

influences between plant and animal species within an area and their environment, 

including natural processes of change or disturbance (wind, aging, etc.). 

On the Tongass National Forest, fine-scale vegetation communities known as plant 

associations have historically been used for project-level planning and analysis of 

silvicultural treatments. Work on describing forested plant communities on the 

Tongass began in the early 1980s. Three guides, one each for the former 

Ketchikan, Stikine, and the Chatham Areas, were developed to identify and describe 

forested plant associations (DeMeo et al. 1992, Pawuk and Kissinger 1989, Martin 

et al. 1995). They provide a key for identifying the plant associations based on 

dominant and diagnostic species in the tree, shrub, and herb layers of the Forest. 

Plant association names consist of the dominant tree species that occurs in the 

overstory canopy, along with dominant or diagnostic species found in the shrub 

and/or herb strata (layers). Plant association descriptions include species cover and 

constancy (how often a species occurs in a particular association), productivity 

estimates, and management considerations to guide the interpretation of effects of 

actions on an area with a specific plant association. 

In the Tongass plant association guides, forested plant associations are grouped 

into the following series based on the dominant tree species in the overstory 

canopy: 

• Mixed-Conifer Series 

• Mountain Hemlock Series 

• Shore Pine (Lodgepole Pine) Series 

• Sitka Spruce Series 

Vegetation 

Classification 
Environment and Effects 3

Final EIS 3-97 Plants 

• Western Hemlock Series 

• Western Hemlock-Western Red Cedar Series 

• Western Hemlock-Yellow Cedar Series 

The Federal Geographic Data Committee established the National Vegetation 

Classification Standards (NVCS), which is a hierarchical existing vegetation 

classification with nine levels (Federal Geographic Data Committee 1997). The 

seven upper levels are primarily based on physiognomy. The two lowest levels, 

alliance and association, are based on floristic attributes. This hierarchy has been 

incorporated into the recently published Forest Service Existing Vegetation 

Classification and Mapping Technical Guide (Brohman and Bryant 2005). All of the 

forested plant associations of Southeast Alaska have been crosswalked to the 

NVCS. A list of the crosswalked forested plant associations can be found on the 

Alaska Natural Heritage Program (ANHP) Web site at: 

http://aknhp.uaa.alaska.edu/ecology/Ecology_Plant_Association_Tracking_List.htm. 

Development of a non-forested vegetation classification for the Tongass is currently 

in progress. The Yakutat Forelands plant community classification (Shephard 1995) 

included a classification of non-forested vegetation types. In order to produce a 

consistent product for the rest of the Tongass that is compatible with the NVCS and 

meets the needs of the Forest Service, the protocols in the Forest Service Existing 

Vegetation Classification and Mapping Technical Guide are being followed. Once 

the non-forested classification is complete, a guide containing descriptions of plant 

associations will be developed. 

The only Forest-wide vegetation map currently available is the Tongass Existing 

Veg map, a GIS-based data set that was derived from the former TimberType 

database. In Existing Veg, forested stands are identified by broad forest canopy 

cover types. Information for forested stands includes dominant overstory species, 

type for low productivity stands, size class (e.g., seedling, sapling, young growth, or 

old growth), and volume class for productive stands. Generic non-forested types 

are also mapped (e.g., ice, shrub, muskeg, beach, alpine, and sand). 

A new, interim model for classifying productive forests of the Tongass has been 

developed that organizes forested stands in the Existing Veg map into seven sizedensity categories (Caouette and DeGayner 2005). This system, referred to as the 

Size-Density Model (SD7), is described in the Biodiversity section of this chapter, 

and may be useful for describing forest structural diversity and wildlife habitats. 

Mapping vegetation communities at the plant-association level has not occurred on 

the Forest. Producing plant-association maps requires large amounts of field data 

and high-resolution imagery combined with modeling; therefore, plant-association 

maps will most likely need to be developed on a project-specific basis, while still 

meeting Forest-wide standards for vegetation mapping. New and updated mid-level 

(alliance and/or dominance type) maps of vegetation types sufficient for Forest- or 

watershed-scale analysis may be developed in the near future. 

There are no federally listed or proposed Threatened or Endangered plants that are 

known to occur or are likely to occur on the Tongass National Forest. The only 

federally listed or proposed plant in Alaska is the Aleutian hollyfern (Polystichum 

aleuticum), which is listed as endangered; however, it is only known to occur on 

Adak Island and is not expected to occur on the Tongass National Forest. 

Sensitive plant species are those plant species identified by the Regional Forester 

for which population viability is a concern on National Forest System (NFS) lands 

within the region. A viability concern is identified by either a significant current or 

predicted downward trend in population numbers or density, or a significant current 

Vegetation 

Mapping 

Threatened, 

Endangered, 

Sensitive, and 

Rare Plants 
3 Environment and Effects

Plants 3-98 Final EIS

or predicted downward trend in habitat capability that would reduce a species’ 

existing distribution. The goal of the Forest Service Sensitive Species Program 

(Forest Service Manual 2670) is to ensure that species numbers and population 

distribution are adequate so that no federal listing will be required and no extirpation 

will occur on NFS lands. 

ANHP’s Rare Species Global Rankings Criteria is the primary source of information 

used to rank rare plant species in Alaska. The Regional Sensitive Plant Species List 

identifies certain rare plants on the ANHP list as sensitive and are known or 

suspected to occur on the Tongass. There are currently 17 plant species listed as 

sensitive on the Tongass National Forest. Revisions to the Regional Sensitive Plant 

Species list are periodically recommended based on new information derived from 

recent publications, field work, and laboratory analysis concerning rare plants. 

The sensitive plants known or suspected to occur in the Tongass National Forest 

are listed in Table 3.7-1. This table includes a general range and habitat description 

for each species. In addition, it includes a preliminary estimate of the potential 

number of acres of habitat for each species. These estimates are likely to be 

overestimates of available habitat, because the habitat requirements of sensitive 

plant species are often not well known and, even when they are well known, the 

habitat requirements are generally tied to micro-habitat characteristics. These 

estimates are based on available Tongass Forest GIS mapping and, as a result, are 

tied to macro-habitat information that is currently available. Nevertheless, they 

provide a means or an index of measuring the effects of the alternatives by 

assessing the percentage of each habitat affected. 

Sensitive plant surveys are conducted as part of project planning to identify 

populations or habitats of sensitive species within planning areas. An understanding 

of the distributions of sensitive and rare plants on the Tongass is limited because 

most botanical surveys are focused on project areas. As a result, very few Forestwide inventories have been conducted. 

ANHP maintains a list of plants that are considered rare within Alaska. This list 

currently contains 86 plants (including those with sensitive or rare designations, or with 

significant range extensions on the Tongass) documented to occur on the Tongass 

National Forest. Rare plant species are those that are inherently rare or not naturally 

well distributed on the Forest; however, rare plants do not have the same protection in 

the Forest-wide standards and guidelines or the same determination language as 

sensitive plants. The State of Alaska list of rare plants, with global and state rankings, 

is used as guidance for determining which rare plants may be addressed in the projectlevel analysis. The State list with state and global rankings is available online at: 

http://aknhp.uaa.alaska.edu/botany/Botany_tracking_page.htm. Generally, plants with 

a state ranking of S1 (critically imperiled in state) or S2 (imperiled in state) are given 

consideration during project analysis. 
Environment and Effects 3

Final EIS 3-99 Plants 

Table 3.7-1 

Regional Forester Sensitive Plant Species that are Known or Suspected to Occur on the 

Tongass National Forest1

Common Name 

(Scientific Name) Range and Habitat2

Eschscholtz’s little nightmare 

(Aphragmus eschscholtzianus) 

This plant is confined to southern Alaska and adjacent areas in Canada in a band 

extending from the Aleutians through the southwest Yukon. The plant is known from 

about 30 sites throughout its range. It is suspected to occur in mountainous areas on 

the northern mainland of the Tongass. It grows in moist mossy areas, seeps, heaths, 

and scree slopes in the subalpine and alpine. Because the plant is so small, it is easily 

overlooked. This plant has not been documented on the Tongass. The Tongass 

contains a high estimate2 of approximately 1,424,000 acres of habitat that is potentially 

suitable for Eschscholtz’s little nightmare. 

Norberg arnica 

(Arnica lessingii ssp. Norbergii) 

This plant has been found in less than 20 sites in a range extending from Prince 

William Sound through the northern panhandle. The plant grows from sea level to 

subalpine in meadows, shrublands, dry meadows, and open forest. This plant has 

been identified in five locations on the Yakutat Ranger District. The Tongass contains 

a high estimate2

 of approximately 502,000 acres of habitat that is potentially suitable 

for Norberg arnica. 

Moonwort fern, no common name 

(Botrychium tunux) 

This fern has a specific habitat found on well-drained open areas on maritime beaches 

or upper beach meadows. Six populations have been found on the Yakutat Ranger 

District. The Tongass contains a high estimate2 of approximately 16,000 acres of 

habitat that is potentially suitable for Botrychium tunux. 

Moonwort fern, no common name 

(Botrychium yaaxudakeit) 

This plant is found on well-drained open areas on maritime beaches or upper beach 

meadows. Five populations are known on the Yakutat Ranger District. The Tongass 

contains a high estimate2

 of approximately 16,000 acres of habitat that is potentially 

suitable for Botrychium yaaxudakeit. 

Goose-grass sedge 

(Carex lenticularis var. dolia) 

The sedge ranges from the Aleutians east to the Alaska-Canada Coast Range, through 

the Rockies south to Glacier National Park. It grows in wet meadows, along 

lakeshores and snowbeds, generally at high elevations. There are seven known 

locations on the Juneau, Ketchikan, and Sitka Ranger Districts. Recent research has 

recognized Carex enanderi as the same species as Carex lenticularis var. dolia. 

Consequently, goose-grass sedge is more common than thought, although still rare. It 

is proposed to remove this plant from the sensitive species list. The Tongass contains 

a high estimate2 of approximately 526,000 acres of habitat that is potentially suitable 

for goose-grass sedge. 

Edible thistle 

(Cirsium edule) 

This plant ranges from southern Southeast Alaska, through western Washington, to 

extreme northwestern Oregon. It grows in open meadows, scree slopes, and along 

glacial streams and lakeshores. There are three documented locations in the Misty 

Fiords National Monument. This plant is expected to occur elsewhere in the southeast 

portion of the Tongass National Forest. The Tongass contains a high estimate2

 of 

approximately 695,000 acres of habitat that is potentially suitable for edible thistle. 

Davy mannagrass 

(Glyceria leptostachya) 

This plant has a range from central Southeast Alaska, disjunctly south through central 

California. It grows in shallow freshwater and along stream and lake margins. In 

Alaska, it has been identified at five sites in Ketchikan, Wrangell, and Sitka areas. The 

Tongass contains a high estimate2 of approximately 1,314,000 acres of habitat that is 

potentially suitable for Davy mannagrass. 

Wright filmy fern (Hymenophyllum 

wrightii) 

This fern's range is disjunct from Russian Far East, Korea, and Japan to the 

Petersburg and Sitka areas in the Tongass National Forest, south to about four sites in 

British Columbia coastal areas and the Queen Charlotte Islands. Only the 

gametophyte stage has been recorded in Alaska, while the sporophyte stage has been 

documented on the Queen Charlotte Islands. It grows on shaded cliff faces; bases of 

trees; decaying wood and rootwads; and in the dense, humid coastal forests near 

saltwater and low elevation areas. It has been found on Biorka, Baranof, Chichagof, 

Mitkof, Etolin, and Kupreanof Islands The Tongass contains a high estimate2 of 

approximately 8,845,000 acres of habitat that is potentially suitable for Wright filmy 

fern. 

Truncate quillwort 

(Isoetes truncata) 

This plant grows immersed in shallow fresh water pools or ponds. It is known from 

Kodiak and Vancouver Islands, with a disjunct population at Pyramid Lake, Alberta. It 

is suspected to occur from Prince William Sound through the Tongass National Forest. 

There are three documented locations on the Sitka Ranger District. The plant on the 

Tongass is thought to be a hybrid of more common species: Isoetes occidentalis, I. 

maritima and possibly I. echinospora. Therefore, it is proposed that this plant be 

removed from the sensitive species list. The Tongass contains a high estimate2 of 

approximately 31,000 acres of habitat potentially suitable for wright filmy fern within the 

Tongass. 
3 Environment and Effects

Plants 3-100 Final EIS

Table 3.7-1 (continued) 

Regional Forester Sensitive Plant Species that are Known or Suspected to Occur on the 

Tongass National Forest1

Common Name 

(Scientific Name) Range and Habitat2

Calder lovage 

(Ligusticum calderi) 

This plant is known from Vancouver Island north through the southern part of the 

Tongass National Forest (Dall and Prince of Wales Islands) and disjunct to Kodiak 

Island. It occurs in alpine and subalpine meadows, boggy slopes, and rocky areas. It 

has been identified in 10 locations in the Craig Ranger District. The Tongass contains 

a high estimate2

 of approximately 681,000 acres of habitat that is potentially suitable for 

Calder lovage. 

Pale poppy 

(Papaver alboroseum) 

A rather spectacular poppy, this species has been identified in three disjunct areas: 

Kamchatka and northern Kurile Islands; Cook Inlet, Kenai Peninsula, Portage Glacier; 

and northern British Columbia and southern Yukon. The plant grows in open areas, 

recently deglaciated areas, rock outcrops, sand, gravel, and on well-drained soils. In 

the Tongass National Forest, it is suspected on the mainland in the Skagway and 

Juneau areas. It has been identified in seven locations on the Sitka Ranger District. 

The Tongass contains a high estimate2 of approximately 1,598,000 acres of habitat 

that is potentially suitable for the pale poppy. 

Bog orchid 

(Platanthera gracilis) 

This orchid is known from a limited range in the southernmost part of the Tongass and 

adjacent British Columbia. It has been identified at four sites in wet meadows and is 

expected in peat bogs. Little is known about this plant. Distributions, population size, 

population trends, existence of historical populations, and habitat requirements have 

not yet been determined. This plant has been synominized with the common 

Platanthera stricta and is proposed to be removed from the sensitive list. The Tongass 

contains a high estimate2

 of approximately 84,000 acres of habitat that is potentially 

suitable for the bog orchid. 

Loose-flowered bluegrass (Poa 

laxiflora) 

This grass ranges from the Hoonah area south to Oregon. The plant grows in upper 

beach meadows, open areas, open forests, and along riparian areas. It is suspected to 

occur throughout the Tongass National Forest from the Juneau Ranger District south. 

There are over 20 populations on the Juneau, Craig, Petersburg, and Ketchikan 

Districts, and Admiralty Island National Monument. The Tongass contains a high 

estimate2 of approximately 7,287,000 acres of habitat that is potentially suitable for 

loose-flowered bluegrass. 

Kamchatka alkali grass (Puccinellia 

kamtschatica) 

This grass ranges from the Aleutians through the central Tongass National Forest. It 

grows on tidal flats, salt marshes, and sea beaches. The status of this species is in 

question. Some authors recognize it as a distinct species; others do not. Current 

research on Puccinellia may conclude that this species is the same as the much more 

common Puccinellia nutkaensis. The Tongass contains a high estimate2

 of 

approximately 26,000 acres of habitat that is potentially suitable for Kamchatka alkali 

grass. 

Unalaska mist-maid (Romanzoffia 

unalaschcensis) 

This plant ranges from the Aleutian Islands through Prince William Sound, disjunct to 

the Tongass National Forest. The plant grows in cracks in rock outcrops; along stream 

banks; beach terraces; open rocky areas; and on grassy, mossy rock cliffs along 

shores. There are two documented occurrences on Thorne Bay and Sitka Ranger 

Districts. At a very broad scale, the Tongass contains a high estimate2 of 

approximately 3,158,000 acres of habitat that is potentially suitable for Unalaska mistmaid. 

Queen Charlotte butterweed 

(Senecio moresbiensis) 

This plant has been found in the southern half of the Tongass National Forest, Queen 

Charlotte Islands, and northern Vancouver Island. It grows in alpine and subalpine 

meadows, boggy or rocky slopes, open rocky heaths, or grassy areas. It has been 

found adjacent to a road on Prince of Wales Island. Less than 15 populations have 

been documented on the Thorne Bay and Craig Ranger Districts. The Tongass 

contains a high estimate2 of approximately 681,000 acres of habitat that is potentially 

suitable for Queen Charlotte butterweed. 

Circumpolar starwort (Stellaria 

ruscifolia ssp. aleutica) 

This plant ranges from the eastern Aleutians east across southern coastal Alaska to 

the northern Tongass. This plant is inconspicuous and difficult to identify. It grows in 

open gravely sites and along creeks in the mountains. It has been identified in one 

location on the Yakutat Ranger District. The Tongass contains a high estimate2 of 

approximately 176,000 acres of habitat that is potentially suitable for circumpolar 

starwort. 1 Sensitive Plant list updated June 2002. 

2 Habitat acreage estimates for each species are approximate and tend to overestimate the potential habitat because they 

are based on macro-habitat information currently available in GIS. Nevertheless, they provide a means of measuring the 

effects of the alternatives by assessing the percentage of each habitat affected. 
Environment and Effects 3

Final EIS 3-101 Plants 

In the past, Alaska’s remoteness and relatively low disturbance level has protected it 

from infestations of non-native plants. Compared to the lower 48 states, Alaska has 

a low level of invasive plants, but it is growing. As inventories have increased, more 

non-native species have been documented in Southeast Alaska on NFS lands 

(Schrader and Hennon 2005). Not all non-natives are invasive. Executive Order 

13112 (1999) defines an “invasive species” as a species that is 1) non-native (or 

alien) to the habitat under consideration, and 2) whose purposeful or accidental 

introduction causes or is likely to cause economic or environmental harm or harm to 

human health. Executive Order 13112 directs all federal agencies to address 

invasive species concerns and refrain from actions likely to increase invasive 

species problems. 

Many existing laws and directives provide management direction for “noxious” 

plants. Noxious is a political designation used by state or federal governments and, 

in the past, has primarily been driven by threats to agriculture or rangelands. Laws 

pertaining to only “listed noxious species” are inadequate in addressing threats to 

NFS lands in Alaska. The Forest Service recognizes this and refers to species of 

concern as “invasive.” Invasive species terminology, in this document, includes 

noxious and invasive alien plant species. 

There are two programs in Alaska that were created to track occurrences of nonnative plants and rank the invasiveness of non-native species. The first program is 

Alaska Exotic Plants Information Clearinghouse (AKEPIC), a database administered 

and coordinated by ANHP. AKEPIC is a cooperative project between the USDA 

Forest Service, State and Private Forestry, the National Park Service, U.S. 

Geological Survey, University of Alaska, and other federal, state, and local agencies 

in support of the Alaska Committee for Noxious and Invasive Plants Management 

and the Strategic Plan for Noxious and Invasive Plants Management in Alaska. The 

Tongass National Forest maintains an inventory of occurrences of non-native plants 

in the AKEPIC database to track and monitor occurrences. The database is 

available online at: http://akweeds.uaa.alaska.edu/. 

The second statewide program is the Weed Ranking Project that was created to 

better assess what species could be most problematic in the Alaska system. The 

Weed Ranking Project assesses the potential invasiveness of non-natives that have 

been found in Alaska and non-natives that have been invasive in other locations and 

for which there is appropriate habitat in Alaska. The invasiveness rankings are 

available online through ANHP at: 

http://akweeds.uaa.alaska.edu/akweeds_ranking_page.htm. 

During the past several years, surveys along some roads, trails, trailheads, and 

other sites of recent human activity in Southeast Alaska have been conducted. 

Recently, systematic surveys of all non-native species have been initiated in areas 

of heavier use that are more susceptible to non-native plant invasion. The areas of 

greatest non-native plant diversity and extent of invasion have been found around 

towns and the most heavily traveled areas. The areas with the lowest number of 

species were further from population centers or paved roads (Arhangelsky 2005). 

Schrader and Hennon (2005) cited references that suggest that highest invasive 

plant occurrences are in areas of human activity, such as roads, recreational areas, 

industrial, commercial, and industrial development. 

Survey results of all non-natives found on the Tongass are documented in the 

AKEPIC inventory. The data do not provide the extent of infestation, but do include 

the location of species found. While the database includes some entries for the 

Tongass starting in 2000, the majority of the entries are from 2002 and later. Table 

3.7-2 shows the number of non-native species found on the Tongass during 

Invasive Plant 

Species 
3 Environment and Effects

Plants 3-102 Final EIS

Table 3.7-2 

Number of Non-Native Species Recorded by District

 Ranger District Number of Non-Native Species Recorded1

Admiralty National Monument 17 

Craig Ranger District 56 

Hoonah Ranger District 10 

Juneau Ranger District 17 

Ketchikan-Misty Fiords Ranger 

District 26 

Petersburg Ranger District 21 

Sitka Ranger District 24 

Thorne Bay Ranger District 59 

Wrangell Ranger District 28 

Yakutat Ranger District 14 

Total 88 

1

 Sites may be very close to each other and done on the same day (e.g., the survey of Prince of Wales Is

included recording non-native species every 0.25 mile of road) 

Source: AKEPIC 2006 and Tongass GIS

surveys. The number of species is notably larger on the Craig and Thorne Bay 

Ranger Districts due to the systematic survey of roads completed on Prince of 

Wales Island in 2005. 

The 2005 systematic survey of Prince of Wales Island also provided information that 

many more species exist than had previously been recorded on the island. The 

2005 survey of Prince of Wales Island recorded 33 new species of non-native plants 

on NFS lands (Arhangelsky 2005). 

Table 3.7-3 shows a list of all non-native plant species recorded on the Tongass 

National Forest and invasiveness rankings from the Alaska Weed Ranking Program. 

The rankings are for the South Coastal zone of Alaska and range from 1 to 100 (100 

representing the highest invasiveness rating) for the species that have an 

invasiveness ranking. 

Of the 88 species of non-natives on the Tongass, 46 have an invasiveness ranking. 

The invasiveness ranking is based on analysis of four parameters for each species, 

including: 

• Ecological impact: impact on processes, community structure and 

composition, and other trophic levels. 

• Biological characteristics: mode of reproduction, methods of dispersal, 

competitive abilities, and habitat. 

• Ecological amplitude and distribution: United States and global distribution, 

and level of impact in other locations. 

• Feasibility of control: seed bank viability, other methods of reproduction, 

and effort known to be required for control. 
Environment and Effects 3

Final EIS 3-103 Plants 

Table 3.7-3 

Non-Native Plants on the Tongass: Number of Occurrences and Invasiveness 

Ranking

Common Name Scientific Name 

No. of Locations on 

the Tongass1

Invasiveness 

Ranking 2

alfalfa Medicago sativa 2 

alsike clover Trifolium hybridum 417 57 

annual bluegrass Poa annua 460 51 

annual hawksbeard Crepis tectorum 25 43 

bird's foot trefoil Lotus corniculatus 6 

bitter dock Rumex obtusifolius 2 

black bindweed, wild buckwheat Polygonum convolvulus 7 51 

black medic, hop clover Medicago lupulina 57 48 

bladder campion Silene latifolia 1 45 

bluegrass Poa pratensis 654 57 

brittlestem hempnettle Galeopsis tetrahit 67 

bull thistle Cirsium vulgare 92 61 

burr medic Medicago minima 4 

butter and eggs Linaria vulgaris 21 

Canada bluegrass Poa compressa 83 35 

Canada thistle Cirsium arvense 72 76 

Canary grass Phalaris canariensis 1 

cat's-ears Hypochoeris radicata 161 

chicory Cichorium intybus 1 

colonial bentgrass Agrostis tenuis. 56 

common chickweed Stellaria media. 22 57 

common comfrey Symphytum officinale 6 

common dandelion Taraxacum officinale 1,681 62 

common dogmustard Erucastrum gallicum 6 

common groundsel Senecio vulgaris 31 

common hawkweed Hieracium lachenalii 12 

common plantain Plantago major var. major 2,264 44 

common St. Johnswort Hypericum perforatum 15 52 

common tansy Tanacetum vulgare 39 57 

common velvetgrass Holcus lanatus 238 

common yarrow Achillea millefolium 120 48 

creeping bentgrass, red top Agrostis gigantea 463 

Agrostis stolonifera 126 

creeping buttercup Ranunculus repens 526 54 

crested wheatgrass Agropyron cristatum 1 

curled dock Rumex crispus 24 48 

European mountain ash Sorbus aucuparia 1 

fall dandelion Leontodon autumnalis 2 

field bindweed Convolvulus arvensis 2 

field mustard Brassica rapa 66 

fowl bluegrass Poa palustris 830 

foxtail barley Hordeum jubatum 8 63 

garden dock Rumex longifolius 4 

garlic mustard Alliaria petiolata 12 70 

golden clover Trifolium aureum 1 

hedge false bindweed 

Calystegia sepium ssp. 

sepium 1 

Himalayan blackberry 

Rubus armeniacus (R. 

discolor ) 1 

Italian rye grass Lolium multiflorum 5 41 

Japanese knotweed Polygonum cuspidatum 254 87 

lamb's quarters Chenopodium album 7 

large-leaf lupine Lupinus polyphyllus 77 

larger mouse-eared chickweed 

Cerastium fontanum Baumg. 

ssp. triviale 1,262 39 

maltesecross Lychnis chalcedonica 2 

marsh cudweed Gnaphalium palustre 11 

mayweed, stinking chamomile Anthemis cotula 3 41 
3 Environment and Effects

Plants 3-104 Final EIS

Table 3.7-3 (continued) 

Non-Native Plants on the Tongass: Number of Occurrences and Invasiveness 

Ranking

Common Name Scientific Name 

No. of 

Locations on 

the Tongass1

Invasiveness 

Ranking 2

meadow foxtail Alopecurus pratensis 15 

meadow hawkweed Hieracium caespitosum 8 

mouseear hawkweed Hieracium pilosella 1 

Narrow-leaf Hawkweed Hieracium umbellatum 60 35 

night-flowering catchfly Melandrium noctiflorum 1 

Norwegian cinquefoil Potentilla norvegica 2 

orange hawkweed Hieracium aurantiacum 325 71 

orchard grass Dactylis glomerata 610 

ornamental jewelweed Impatiens glandulifera 2 

ox-eye daisy Leucanthemum vulgare 610 

perennial rye grass Lolium perenne 162 

perennial sowthistle Sonchus arvensis 8 59 

pineappleweed Matricaria discoidea 140 34 

prickly lettuce Lactuca serriola 8 

purple foxglove, foxglove Digitalis purpurea 73 51 

purple-topped turnip Brassica rapa var. rapa 6 

quackgrass Elymus repens 5 

Queen Anne's lace Daucus carota 1 

red clover Trifolium pratense 206 

reed canary grass Phalaris arundinacea 3,120 83 

ribgrass, buckhorn, English plantain Plantago lanceolata 2 

rough bluegrass Poa trivialis 34 

rough hawkbit Leontodon hirtus 3 

scentless mayweed Tripleurospermum inodorum 1 48 

scotch broom Cytisis scoparius 22 69 

sheep sorel Rumex acetosella ssp. acetosella 86 45 

Rumex acetosella ssp. angiocarpus 2 

shepherd's purse Capsella bursa-pastoris 6 40 

Capsella rubella 1 

silverweed Potentilla anserina 3 

slender hairgrass Deschampsia elongata 304 

smooth brome Bromus inermis 9 62 

sneezeweed Achillea ptarmica 1 46 

spearmint Mentha spicata 1 

spiny sowthistle Sonchus asper 35 

splitlip hempnettle Galeopsis bifida. 5 43 

spotted knapweed Centaurea biebersteinii 6 88 

spurry Spergula arvensis 1 

stick chickweed Cerastium glomeratum 1 

tall buttercup Ranunculus acris 1 

tall fescue Festuca arundinacea 20 

tansy ragwort, stinky willie Senecio jacobea 9 63 

thyme-leaf speedwell 

Veronica serpyllifolia subsp. 

serpyllifolia 228 

timothy Phleum pratense 1,373 56 

true forget-me-not Myosotis scorpioides 25 

wall lettuce Mycelis muralis 39 32 

western pearly everlasting Anaphalis margaritacea 46 

wheat Triticum aestivum 2 

white clover Trifolium repens 2,269 59 

white mustard Sinapis alba 1 

white sweet clover Melilotus alba 54 80 

willow weed Polygonum lapathifolium 6 

wormseed mustard 

Erysimum cheiranthoides subsp. 

cheiranthoides 2 

yellow salsify, goatsbeard Tragopogon dubius 1 48 

yellow sweet clover Melilotus officinalis 9 65 1

 AKEPIC 2006 http://akweeds.uaa.alaska.edu/ 

2

 Alaska Weed Ranking Proogram. http://akweeds.uaa.alaska.edu/akweeds_ranking_page.htm
Environment and Effects 3

Final EIS 3-105 Plants 

Environmental Consequences 

This section compares effects of the seven alternatives on sensitive and rare plant 

species and on the introduction or spread of invasive species. There would be no 

effects to Threatened or Endangered plant species because there are none found 

on the Tongass. 

Threatened, Endangered, Sensitive, and Rare Plants 

Direct effects of the proposed alternatives on sensitive or rare plants would include 

physical damage to sensitive plants by cutting, trampling, or crushing them with 

vehicles, other machinery, foot traffic, or felled trees. Severe impacts may cause 

mortality, or inhibit the vigor and reproductive capability of the plants. 

Indirect effects involve alteration of habitat, such as changes in sunlight and 

moisture availability, herbivore or pollinator behavior, soil structure and fertility, 

vegetation structure, and competition from other native species as well as invasive 

and other non-native species. Some indirect effects, such as changes in sunlight or 

moisture, can be beneficial or harmful depending on the effect and the specie’s life 

history. For example, if a plant has habitat requirements of partial sun, then 

increasing the size of a forest opening may benefit that species; however, that same 

opening may be harmful to a plant that requires shade. Activities likely to cause 

indirect effects to sensitive and rare plants include removal or reduction of tree 

canopy, road construction, changes in hydrology associated with road construction, 

increased competition by invasive plants, construction of other facilities, increased 

off-road vehicle use, increased access, and increased use and associated trampling 

by recreationists. 

The alternatives described in Chapter 2 differ primarily by the proposed amount of 

timber that is likely to be harvested and the miles of road construction and 

reconstruction. Alternative 5, the No-Action Alternative, would follow the 1997 

Forest Plan standards and guidelines. The other six alternatives would mostly 

follow the proposed standards and guidelines, which provide additional protection 

for sensitive and rare plants. There are three exceptions that could affect sensitive 

and rare plants: the area of non-development LUDs, beach buffer requirements, 

and Class III stream protection. Table 2-16 in Chapter 2 provides a comparison of 

the components of the alternatives. 

Alternatives 1, 2, 3, and 6 would have more acreage in old-growth reserves and 

other non-development LUDs than Alternative 5 (current Forest Plan) or Alternatives 

4 and 7. This increased area in reserves would provide more area in large blocks of 

intact habitats, which would be beneficial to sensitive and rare plants. Alternative 4 

utilizes a reduced old-growth strategy and Alternative 7 would reduce nondevelopment LUDs even further (including the elimination of the Old-Growth Habitat 

LUD). This could contribute to the risk of direct or indirect effects to sensitive or rare 

plant species that generally occur in old-growth habitats. Both Alternatives 4 and 7 

could result in the loss of local viability for some sensitive species due to the 

creation of large gaps within old-growth habitat. Species listed as sensitive on the 

Tongass that include forest or forest openings as a potential habitat are Norberg 

arnica, Wright filmy fern, and loose-flowered bluegrass. 

In Alternative 7, the beach buffer would be reduced to 500 feet for timber harvest, 

compared to 1,000 feet in the other alternatives. This would increase the risk of 

direct or indirect effects to species that inhabit areas close to shore or in low 

elevations. The species listed as sensitive on the Tongass that may inhabit areas 

close to shore are moonwort fern, Wright filmy fern, loose-flowered bluegrass, 

Direct and 

Indirect Effects 
3 Environment and Effects

Plants 3-106 Final EIS

Kamchatka alkali grass, Unalaska mist-maid, Queen Charlotte butterweed, and 

circumpolar starwort. 

Finally, Alternative 7 is different from the other alternatives in that it would not 

require timber harvest buffers along Class III streams. As a result, plant species 

that occupy riparian areas along steep, rocky and mountainous streams would not 

receive the same degree of protection under Alternative 7. 

Construction of roads would involve removal of vegetation within the path of the 

road. This could affect rare and sensitive plants that inhabit the specific habitat 

found within the location of the new road. Roads can be constructed in many types 

of habitat, depending on the need for access for forestry activities. 

Reconstruction of a road for timber harvest maintains the original investment and 

makes the road suitable and safe for the intended use. Reconstruction for forestry 

activities involves the rehabilitation of the original roadbed. It can include cleaning 

ditches, replacing drainage structures, re-installing bridges, and grading and 

shaping. The roadbed had been created and used (compacted) in the past and, in 

general, no longer supports sensitive or rare plants; however, newly exposed 

bedrock in unique geological areas can create new habitat for rare and sensitive 

plants. Road maintenance can include reconditioning the original road template, 

grading the road surface, cleaning roadside ditches, and removing vegetation that 

may encroach upon the road or block vision. Because the maintenance activities 

remain in the road prism, this would be unlikely to have an effect on sensitive or rare 

plants. 

In general, alternatives with low amounts of timber harvest and road construction 

would have less risk of direct and indirect effects. Alternatives with more acres 

proposed for harvest and road construction would have more risk of effects. Other 

activities related to timber harvest, such as log transfer facility (LTF) construction, 

would increase with elevated timber harvests. Effects to sensitive and rare plants 

would, therefore, also be related to the amount of timber harvest allowed. 

Alternative 5, the No-Action Alternative, proposes harvesting up to approximately 

463,000 acres of old growth and constructing up to 3,874 miles of new roads over 

the next 100+ years (Table 3.7-4). Alternatives 1 and 2 would maintain the most 

acres of undisturbed forest and have less risk of adverse effects due to harvest and 

related activities. Alternatives 1 and 2 propose harvesting approximately 86,000 

and 215,000 old-growth acres, respectively, or 19 to 46 percent of the acreage 

proposed in Alternative 5 (No Action). Alternatives 1 and 2 also propose 

constructing approximately 20 and 54 percent of the road miles proposed by 

Alternative 5. Alternatives 3 and 6 are in the middle of the alternatives in terms of 

acres for harvest and road construction. They include harvesting 335,000 and 

445,000 acres, respectively, or 72 and 96 percent of the maximum acres of old 

growth proposed under Alternative 5. They propose to construct up to 2,799 and 

3,744 miles of new road, respectively. Alternatives 4 and 7 propose the highest 

level of harvest and road construction and would have the highest risk of adverse 

effects due to harvest and related activities. They would harvest a maximum of 

656,000 to 807,000 acres of old growth, respectively, and would build more miles of 

roads to achieve that harvest than any other alternative. Following Table 3.7-4 is a 

discussion of the likely effects to sensitive and rare plants, taking into account the 

Forest management direction for activities proposed by the alternatives. 
Environment and Effects 3

Final EIS 3-107 Plants 

Table 3.7-4 

Maximum Acres of Harvest and Maximum Miles of Road Construction 

by Alternative 

 Alternative 

 1 2 3 4 5 6 7 

Maximum Acres Likely to be Harvested after Full Implementation of the Forest Plan 

(thousands of acres after 100+ years) 

 Productive Old Growth 86.0 214.5 313.4 656.5 462.6 445.1 807.4 

 Young Growth 58.3 179.4 200.2 235.5 224.0 218.4 262.2 

 Total Acres 144.3 393.9 513.7 892.0 686.6 663.5 1,069.6 

Maximum Miles of Road Likely to be Constructed 

 New Road Construction 774 2,079 2,799 4,890 3,874 3,744 5,825 

 Road Reconstruction 925 1,784 1,932 2,182 2,100 2,046 2,371 

Total Road Work 

(includes reconstruction) 1,948 4,344 5,252 7,660 6,541 6,342 8,836 

Source: Tongass National Forest GIS database 

Sensitive Plants 

Within all alternatives, a biological evaluation, including a sensitive plant review, is 

prepared for individual project proposals as part of the site-specific environmental 

analysis. The sensitive plant review is required to include sufficient detail to 

determine how a proposed action may affect each sensitive species. The intensity 

and scope of inventories selected to provide information for effects analysis is 

required to be commensurate with the potential risk of a proposed project to 

sensitive plant species. The review is used to evaluate project-level impacts to 

sensitive plants in order to ensure that proposed project activities do not contribute 

to population or habitat declines that could lead to federal listing or loss of viability. 

In addition, appropriate Forest-wide standards and guidelines (TES species) will be 

applied to sustain those plants and their habitat that are listed as sensitive. 

The proposed standards and guidelines for Alternatives 1, 2, 3, 4, 6, and 7 include 

an additional provision for reviewing the implementation and effectiveness of 

conservation actions for sensitive plants. This review would provide information to 

improve conservation efforts and reduce the likelihood of negative effects due to 

management actions. 

The risk of adverse effects to sensitive plants would increase with increasing land 

disturbance; therefore, over time, Alternatives 4 and 7 would have a higher risk of 

direct and indirect effects due to harvest and road work, when compared to other 

alternatives. Alternatives 5 and 6 would have the next highest risk. The acres of 

harvest and miles of road construction for Alternative 3 is intermediate and its risk to 

affect sensitive plants would likely fall in the mid-range when compared to the other 

alternatives. Alternatives 1 and 2 would have the least risk of effects. It should be 

noted that through project-level evaluation and application of Forest-wide standard 

and guideline protection measures, it is unlikely the alternatives under consideration 

would have substantial adverse effects. 

A species distribution is limited to areas that can meet the species-specific physical 

and biological needs. Due to the limited scope of surveys conducted within the 

Tongass, exact species distributions are unknown; however, by utilizing existing GIS 

data and available habitat information, areas that contain the necessary biological 

and physical requirements of each species on a macro-scale can be approximated. 

Although this analysis can not predict the exact distribution of each species, it can 

aid in assessing the location and total acreage of potentially suitable habitat for each 

sensitive species. For the sake of this discussion, potentially suitable habitat is 
3 Environment and Effects

Plants 3-108 Final EIS

defined as an area where the biological and physical requirements of a sensitive 

species are met, at least on a macro-scale, based on available GIS data. Although 

this technique overestimates the actual available habitat, it is likely that it also 

overestimates the acreage affected and, therefore, it is useful to be able to compare 

the percent of habitat affected by each alternative. Only 3 of the 17 sensitive 

species found on the Tongass would experience an impact on more than 0.1 

percent of their potentially suitable habitat due to road construction and harvest 

activities. These include Norberg arnica, Wright filmy fern, and loose-flowered 

bluegrass. In general, the magnitude of effects for these species declines in order 

from Alternative 7 to 4, 5, 6, 3, 2, and 1. The effects on each of the sensitive 

species and their potentially suitable habitat are addressed below and in Table 3.7-

5. 

Eschscholtz’s little nightmare (Aphragmus eschscholtzianus): 

There is a high estimate of approximately 1,424,000 acres of potentially suitable 

habitat for Eschscholtz’s little nightmare within the Tongass. This species grows 

within moist mossy areas, seeps, heaths, and scree slopes in subalpine and alpine 

areas, where harvest would not occur. Very little access to timber through alpine or 

subalpine areas would be needed. Each of the alternatives considered would 

impact less than 0.1 percent of potentially suitable habitat (Table 3.7-5). Because of 

the protection from the Forest-wide standards and guidelines, and the very low 

chance of impacting this habitat, there is essentially no risk that any alternative 

would result in loss of this specie’s viability, or create significant trends towards 

federal listing. 

Norberg arnica (Arnica lessingii ssp. Norbergii): 

There is a high estimate of approximately 502,000 acres of potentially suitable 

habitat for Norberg arnica within the Tongass. This plant grows in various habitats, 

including open forests where it could be affected by silvicultural practices or 

associated road construction. The largest effect would result from Alternatives 4 

and 7, which could impact approximately 0.3 percent of potentially suitable habitat 

for Norberg arnica (Table 3.7-5). The magnitude of effect declines in order from 

Alternative 7 to 4, 5, 6, 3, 2, and 1. Alternative 1 would result in an impact to less 

than 0.1 percent of potentially suitable habitat. Through project-level evaluation and 

application of Forest-wide standard and guideline protection measures, and based 

on the low proportion of habitat potentially affected, there would be a very low risk 

that effects would result in loss of this specie’s viability, or create significant trends 

towards federal listing. 

Moonwort fern, no common name (Botrychium tunux and Botrychium 

yaaxudakeit): 

There is a high estimate of approximately 16,000 acres of potentially suitable habitat 

for Botrychium tunux and Botrychium yaaxudakeit within the Tongass. These plants 

grow in open areas on maritime beaches or upper beach meadows where 

harvesting activities would not occur. While access to timber through beaches may 

be needed if new LTFs are required, it would be infrequent. Each of the Alternatives 

considered would impact less than 0.1 percent of potentially suitable habitat (Table 

3.7-5). Because of the protection from the Forest-wide standards and guidelines, 

and the very low chance of impacting this habitat, there is essentially no risk that 

any alternative would result in loss of this specie’s viability, or create significant 

trends towards federal listing. 

Goose-grass sedge (Carex lenticularis var. dolia): 

There is a high estimate of approximately 526,000 acres of potentially suitable 

habitat for goose-grass sedge within the Tongass. This plant grows in moist mossy 

areas, seeps, heaths, and scree slopes in the subalpine and alpine where harvest 

would not occur. While access to timber through alpine or subalpine areas may be 
Environment and Effects 3

Final EIS 3-109 Plants 

needed, it is not likely. Each of the alternatives considered would impact less than 

0.1 percent of potentially suitable habitat (Table 3.7-5). Additionally, goose grass 

sedge is more common than originally thought, although still rare. It has been 

proposed to be removed from the sensitive species list. With the very low chance of 

impacting potential habitat and the protection of Forest-wide standards and 

guidelines, there would be essentially no risk that effects would result in loss of this 

specie’s viability or create significant trends towards federal listing. 

Edible thistle (Cirsium edule): 

There is a high estimate of approximately 695,000 acres of potentially suitable 

habitat for edible thistle within the Tongass. The likelihood of adverse effects is low 

because this plant grows in open meadows, scree slopes, and along glacial streams 

and lakeshores where harvest would not occur; however, access to timber through 

this type of habitat may be needed. Each of the alternatives considered would 

impact less than 0.1 percent of potentially suitable habitat (Table 3.7-5). Because of 

the protection from the Forest-wide standards and guidelines, and the very low 

chance of impacting this habitat, there is essentially no risk that any alternative 

would result in loss of this specie’s viability, or create significant trends towards 

federal listing. 

Davy mannagrass (Glyceria leptostachya): 

There is a high estimate of approximately 1,314,000 acres of potentially suitable 

habitat for davy mannagrass within the Tongass. This plant grows in shallow 

freshwater and along stream and lake margins where harvest would not occur. 

While these areas are generally protected by Riparian Standards and Guidelines, it 

is possible that access to timber through this type of habitat may be needed. Under 

Alternative 7, road construction would impact approximately 0.1 percent of 

potentially suitable habitat for davy mannagrass. Road construction and harvest 

activities under all other alternatives considered would impact less than 0.1 percent 

of potentially suitable habitat (Table 3.7-5). The magnitude of effect declines in 

order from Alternative 7 to 4, 5, 6, 3, 2, and 1. With the protection of Forest-wide 

standards and guidelines along with the Riparian Standards and Guidelines, there is 

a very low risk that effects would result in loss of this specie’s viability, or create 

significant trends towards federal listing. 

Wright filmy fern (Hymenophyllum wrightii): 

There is a high estimate of approximately 8,845,000 acres of potentially suitable 

habitat for wright filmy fern within the Tongass. This plant grows in various habitats, 

including near the bases of trees, on decaying wood and rootwads, and in the 

dense, humid coastal forests near saltwater and low elevation areas. These areas 

could be affected by silviculture or associated road construction, indicating that all 

alternatives considered may affect this sensitive plant. Alternative 7 would impact 

up to approximately 9 percent of potentially suitable habitat; 0.2 percent of this 

would be as a result of road construction (Table 3.7-5). The magnitude of effect 

declines in order from Alternative 7 to 4, 5, 6, 3, 2, and 1. Alternative 1 would impact 

up to approximately 1 percent of potentially suitable habitat. Through project-level 

evaluation and application of Forest-wide standard and guideline protection 

measures, there is a low risk that effects would result in loss of this specie’s viability, 

or create significant trends towards federal listing. 

Truncate quillwort (Isoetes x truncata): 

There is a high estimate of approximately 31,000 acres of potentially suitable habitat 

for truncate quillwort within the Tongass. This plant grows immersed in shallow 

fresh water pools or ponds where harvest would not occur. While these areas are 

protected by riparian standards and guidelines, it is possible that access to timber 

through this type of habitat may be needed. Each of the alternatives considered 

would impact less than 0.1 percent of potentially suitable habitat (Table 3.7-5). This 
3 Environment and Effects

Plants 3-110 Final EIS

species is more common than previously thought and it has been proposed to be 

removed from the sensitive species list. With the extremely low chance of impacting 

this habitat and the protection of Forest-wide standards and guidelines, there is 

essentially no low risk that effects would result in loss of specie’s viability, or create 

significant trends towards federal listing. 

Calder lovage (Ligusticum calderi): 

There is a high estimate of approximately 681,000 acres of potentially suitable 

habitat for calder lovage within the Tongass. This plant occurs in alpine and 

subalpine meadows, boggy slopes, and rocky areas where harvest would not occur. 

While access to timber through alpine and subalpine areas may be needed, it is not 

likely. Each of the alternatives considered would impact less than 0.1 percent of 

potentially suitable habitat (Table 3.7-5). Because of the protection from the Forestwide standards and guidelines, and the very low chance of impacting this habitat, 

there is essentially no risk that any alternative would result in loss of this specie’s 

viability, or create significant trends towards federal listing. 

Pale poppy (Papaver alboroseum): 

There is a high estimate of approximately 1,598,000 acres of potentially suitable 

habitat for pale poppy within the Tongass. This plant occurs in open areas, recently 

deglaciated areas, rock outcrops, sand, gravel, and on well-drained soils where 

harvest would not occur. While access to timber through this type of habitat may be 

needed, it is not likely. Each of the alternatives considered would impact less than 

0.1 percent of potentially suitable habitat (Table 3.7-5). Because of the protection 

from the Forest-wide standards and guidelines, and the very low chance of 

impacting this habitat, there is essentially no risk that any alternative would result in 

loss of this specie’s viability, or create significant trends towards federal listing. 

Bog orchid (Platanthera gracilis): 

There is a high estimate of approximately 84,000 acres of potentially suitable habitat 

for bog orchid within the Tongass. This plant grows in wet meadows and peat bogs 

where harvest would not occur. While standards and guidelines provide protection 

to wetlands, it is possible that access to timber through this type of habitat may be 

needed. Each of the alternatives considered would impact less than 0.1 percent of 

potentially suitable habitat (Table 3.7-5). In addition, this plant has been 

synonymized with the common Platanthera stricta and is proposed to be removed 

from the sensitive list. With the extremely low chance of impacting this habitat and 

the protection of Forest-wide standards and guidelines, there is essentially no risk 

that effects would result in loss of this specie’s viability, or create significant trends 

towards federal listing. 

Loose-flowered bluegrass (Poa laxiflora): 

There is a high estimate of approximately 7,287,000 acres of potentially suitable 

habitat for loose-flowered bluegrass within the Tongass. This plant grows in various 

habitats including along riparian areas and in open forests where it could be affected 

by silvicutlure or associated road construction. Alternative 7 would impact up to 

approximately 6 percent of potentially suitable habitat; 0.2 percent of this would be 

as a result of road construction (Table 3.7-5). The magnitude of effect declines in 

order from Alternative 7 to 4, 5, 6, 3, 2, and 1. Alternative 1 would impact 0.6 

percent of potentially suitable habitat. Through project-level evaluation and 

application of Forest-wide standard and guideline protection measures, there is a 

low risk that effects would result in loss of this specie’s viability, or create significant 

trends towards federal listing. 

Kamchatka alkali grass (Puccinellia kamtschatica): 

There is a high estimate of approximately 26,000 acres of potentially suitable habitat 

for Kamchatka alkali grass within the Tongass. This plant occurs in tidal flats, salt 
Environment and Effects 3

Final EIS 3-111 Plants 

marshes, and sea beaches where harvest would not occur. While access to timber 

through beach areas may be needed if new LTFs are required, it would be 

infrequent. Each of the alternatives considered would impact less than 0.1 percent 

of potentially suitable habitat (Table 3.7-5). Because of the protection from the 

Forest-wide standards and guidelines, and the very low chance of impacting this 

habitat, there is essentially no risk that any alternative would result in loss of this 

specie’s viability, or create significant trends towards federal listing. 

Unalaska mist-maid (Romanzoffia unalaschcensis): 

There is a high estimate of approximately 3,158,000 acres of potentially suitable 

habitat for Unalaska mist-maid within the Tongass. The plant grows in cracks within 

rock outcrops, along stream banks, beach terraces, open rocky areas, and on 

grassy/mossy rock cliffs along shores where harvest would not occur; however, 

access to timber through these habitats may be needed. Each of the alternatives 

considered would impact less than 0.1 percent of potentially suitable habitat (Table 

3.7-5). Because of the protection from the Forest-wide standards and guidelines, 

and the very low chance of impacting this habitat, there is essentially no risk that 

any alternative would result in loss of this specie’s viability, or create significant 

trends towards federal listing. 

Queen Charlotte butterweed (Senecio moresbiensis): 

There is a high estimate of approximately 681,000 acres of potentially suitable 

habitat for Queen Charlotte butterweed within the Tongass. This plant grows in 

meadows, boggy or rocky slopes, open rocky heaths, or grassy areas where harvest 

would not occur. While access to timber through these areas may be needed, it is 

not likely. Each of the alternatives considered would impact less than 0.1 percent of 

potentially suitable habitat (Table 3.7-5). With the very low chance of impacting this 

habitat and the protection of Forest-wide standards and guidelines, there is 

essentially no risk that effects would result in loss of this specie’s viability, or create 

significant trends towards federal listing. 

Circumpolar starwort (Stellaria ruscifolia ssp. aleutica): 

There is a high estimate of approximately 176,000 acres of potentially suitable 

habitat for circumpolar starwort within the Tongass. This plant grows in open 

gravely sites and along creeks in the mountains where harvest would not occur; 

however, access to timber through this type of habitat may be needed. Each of the 

alternatives considered would impact less than 0.1 percent of potentially suitable 

habitat (Table 3.7-5). Because of the protection from the Forest-wide standards and 

guidelines, and the very low chance of impacting this habitat, there is essentially no 

risk that any alternative would result in loss of this specie’s viability, or create 

significant trends towards federal listing. 

Rare Plants 

The proposed standards and guidelines for all alternatives, except Alternative 5 (No 

Action), include additional protection for rare plants. Alternatives 1, 2, 3, 4, 6, and 7 

include the proposed standards and guidelines that provide specific direction to 

avoid, minimize, or mitigate adverse effects to rare plants and populations during 

project planning. The additional protection provided by the proposed standards and 

guidelines would reduce the risk of adverse effects on rare plants. 
3 Environment and Effects

Plants 3-112 Final EIS

Table 3.7-5. 

Maximum Effects on Potential Suitable Habitat for Sensitive Plant Species by Alternative 

(contributing effect of roads shown in parentheses) 

Common Name Percent of Total Potential Suitable Habitat Affected by Alternative 

(Scientific Name) 

Total Potential 

Suitable Habitat 

(acres) 1 2 3 4 5 6 7 

Eschscholtz’s little nightmare 

(Aphragmus eschscholtzianus) 1,424,000 < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% 

Norberg arnica 

(Arnica lessingii ssp. Norbergii) 502,000 < 0.1% 0.1% 0.2% 0.3% 0.2% 0.2% 0.3% 

Moonwort fern, 

no common name 

(Botrychium tunux) 

16,000 < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% 

Moonwort fern, 

no common name 

(Botrychium yaaxudakeit) 

16,000 < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% 

Goose-grass sedge 

(Carex lenticularis var. dolia) 526,000 < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% 

Edible thistle 

(Cirsium edule) 695,00 < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% 

Davy mannagrass 

(Glyceria leptostachya) 1,314,000 < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% 0.1% 

(0.1%)

Wright filmy fern 

(Hymenophyllum wrightii) 8,845,000 1.0% 2.5% (0.1%) 

3.7% 

(0.1%)

7.3% 

(0.2%) 

5.5% 

(0.1%) 

5.4% 

(0.1%) 

9.4% 

(0.2%) 

Truncate quillwort 

(Isoetes x truncata) 31,000 < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% 

Calder lovage 

(Ligusticum calderi) 681,000 < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% 

Pale poppy 

(Papaver alboroseum) 1,598,000 < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% 

Bog orchid 

(Platanthera gracilis) 84,000 < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% 

Loose-flowered bluegrass (Poa 

laxiflora) 7,287,000 0.6% 1.5% 2.3% 

(0.1%) 

4.6% 

(0.1%) 

3.4% 

(0.1%) 

3.4% 

(0.1%) 

6.0% 

(0.2%) 

Kamchatka alkali grass 

(Puccinellia kamtschatica) 26,000 < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% 

Unalaska mist-maid 

(Romanzoffia unalaschcensis) 3,158,000 < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% 

Queen Charlotte butterweed 

(Senecio moresbiensis) 681,000 < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% 

Circumpolar starwort (Stellaria 

ruscifolia ssp. aleutica) 176,000 < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% < 0.1% 

Source: Tongass National Forest GIS database 

Percent of total potential suitable habitat affected is calculated by estimating potential suitable macro-habitat using available GIS 

descriptors of habitat and then intersecting these habitat areas with areas to be affected by the alternatives. 

Values in parentheses ( ) represent the contributing effect of roads to the total percent of habitat affected. 
Environment and Effects 3

Final EIS 3-113 Plants 

Alternative 5 is covered by the 1997 Forest Plan standards and guidelines, which 

did not include specific protection for rare plants; however, protection of rare plant 

populations and their habitats in a proposed project area is generally accomplished 

through project analysis and planning. Effects of a proposed action on rare plant 

species and their habitats are generally addressed in plant resource reports. 

The effects of the alternatives on rare plants would be more heavily influenced by 

the area of timber harvest and road construction. Therefore, the likelihood of 

adverse effects to rare plants would be highest for Alternative 7, followed by 

Alternatives 4, 5, 6, 3, 2, and 1. 

Invasive Plant Species 

Invasive plants can adversely affect an area either when invasive plants become 

established or when an existing species spreads to occupy a larger area. Invasive 

plants can negatively affect habitat by competing for resources such as water and 

light, establishing and changing the community composition, eliminating or reducing 

native plants, or by changing the vegetation structure. The changes in community 

composition or vegetation structure can reduce native plant populations as well as 

negatively affect habitat for wildlife. Highly invasive plant species often have 

aggressive reproductive methods and can successfully compete for resources 

(Schrader and Hennon 2005). 

Ground disturbance associated with management activities on the Forest can 

provide an opportunity for invasive plant introduction or expansion. This would be a 

direct effect of timber harvest or road construction because the activities disturb soil 

and/or remove existing vegetation, providing openings for invasive plants to 

establish or spread. Movement of equipment can also provide opportunities for 

seed transport into new areas. Indirect effects can include the establishment or 

spread of invasive plants through the use of roads after harvest for recreation or 

during road maintenance. In general, land disturbance effects to invasive plants can 

be wider than the effects in the specific area of disturbance due to the 

interconnectedness of land. 

The Tongass National Forest Invasive Plant Management Plan (Lerum and Krosse 

2005) provides guidance for prevention, early detection, control, management, and 

rehabilitation or restoration of areas with established invasive plants. It incorporates 

policy and emphasis direction from federal and regional documents, including the 

Alaska Region Invasive Plant Strategy (USDA Forest Service 2005a). 

The proposed standards and guidelines address invasive plants for all alternatives 

except Alternative 5 (No Action). The proposed standards and guidelines for 

invasive plants are new and include direction to review proposed projects to 

determine the risk of introduction or spread of invasive plants and implement 

appropriate mitigation measures. They also include direction to control existing 

invasions and rehabilitate habitats impacted by invasive species. The proposed 

standards and guidelines for Alternatives 1, 2, 3, 4, 6, and 7 would reduce the 

likelihood of negative effects that would result from the introduction or spread of 

invasive plant species. 

Alternative 5 (No Action) includes the use of the 1997 Forest Plan that does not 

include specific standards and guidelines for controlling invasive plants. However, 

when followed, the guidance in the Tongass National Forest Invasive Plant 

Management Plan (Lerum and Krosse 2005) would provide some protection from 

invasive plants. 
3 Environment and Effects

Plants 3-114 Final EIS

All of the alternatives include timber harvest and new road construction that could 

directly and indirectly increase invasive plants. Increased disturbance increases the 

risk of establishment or spread of invasive plants. The effects would vary between 

alternatives depending on the level of disturbance due to timber harvest and new 

roads construction. 

The acres of harvest and miles of road included in each alternative are shown in 

Table 3.7-4. Over time, Alternatives 4 and 7 and, to a lesser extent, Alternatives 5 

and 6 would have a higher risk of direct and indirect effects due to harvest and road 

work. In addition, Alternative 5 does not include the revised standards and 

guidelines; therefore, there is a greater risk of adverse effects for each acre 

disturbed. The acres of harvest and miles of road construction for Alternative 3 is 

intermediate; its risk would likely fall in the mid-range when compared to the other 

alternatives. Alternatives 1 and 2 propose the least amount of disturbance from 

timber harvest, and roads would have the lowest risk of adverse effects. 

Threatened, Endangered, Sensitive, and Rare Plants 

When considering effects to sensitive and rare plants, it is important to look at land 

both inside and outside NFS lands and the cumulative effects of past, present, and 

reasonably foreseeable future activities. Each landscape area has different 

physical, chemical, and biological characteristics, as well as different vegetation 

patterns. The significance of an addition to cumulative effects from management 

activities would depend on factors such as the amount and type of disturbance in an 

analysis area, type of vegetation in the area, habitat availability for each sensitive or 

rare species, known locations of each species, and amount of disturbance in the 

potential habitat area for each species. Assessing cumulative effects to sensitive 

and rare plant species will be done for individual projects as part of the National 

Environmental Policy Act (NEPA) process for the relevant analysis area; however, 

past plus expected harvest and road construction for forestry and other uses on all 

land ownerships can be used to compare the risk that each alternative would add to 

cumulative effects on sensitive and rare plants. 

As discussed above, Table 3.7-5 summarizes the amount of each sensitive species 

potentially suitable habitat on NFS lands affected for each alternative. These values 

create a baseline set of conditions as well as a prediction of future conditions during 

the life of the Forest Plan under all alternatives. These data can be used when 

future project-specific analyses are conducted as part of the NEPA process. 

Timber harvesting on state, municipal, and private land is governed by the Alaska 

Forest Resources and Practices Act (AS 41.17). Alaska Forest Resources and 

Practices Regulations (ADNR 2004) do not address threatened, endangered, or rare 

plants; however, they do limit disturbance in marshes and non-forested muskegs, 

which would provide some protection for those plant species. 

To compare the potential cumulative effects of harvest under the seven alternatives 

on sensitive or rare plants, harvest on lands of all ownerships in Southeast Alaska 

was analyzed. There are approximately 21.6 million acres of land in Southeast 

Alaska. Non-NFS lands comprise about 4.8 million acres or 22 percent of the 21.6 

million acres in Southeast Alaska; Glacier Bay National Park consists of about 2.5 

million acres. Approximately 30 percent of the lands in Southeast Alaska were 

originally productive old growth (POG). Approximately 13 percent of the POG on all 

ownerships had been harvested by 2006. Thus, approximately 87 percent of the 

original POG on all ownerships was remaining in 2006. The percent of POG 

remaining on NFS lands is higher than for non-NFS lands that lie within the Tongass 

National Forest boundary (92 and 70 percent, respectively) due to the concentrated 

timber harvest areas in the non-NFS lands that are within the Tongass boundaries. 

Cumulative 

Effects 
Environment and Effects 3

Final EIS 3-115 Plants 

Looking at all ownerships of land in the Forest, the POG forest remaining in 100 

years under full implementation of the Forest Plan would be greatest for Alternative 

1, followed by Alternatives 2, 3, 6, 5, 4, and 7 (Table 3.7-6). Therefore, the risk of 

cumulative effects to sensitive or rare plants due to harvest would be lowest for 

Alternative 1, followed by 2, 3, 5, 6, 4, and 7. Table 3.9-17 in the Biodiversity

section shows a similar relative risk among the alternatives for cumulative effects by 

Biogeographic Province. 

Table 3.7-6 

Cumulative Percent of the Original (1954) POG Remaining on All 

Ownerships in 2006 and after 100+ Years under Full 

Implementation of the Forest Plan for Each Alternative with 

Estimated Future Harvest on State, Private, and Other Lands 

Remaining POG after 100+ Years as a Percent of 1954 POG

Alternative 

Remaining POG on All 

Ownerships in 2006 as a 

Percent of all Original 

POG 1 2 3 4 5 6 7 

87% 82% 80% 78% 73% 76% 76% 71%

Source: Tongass National Forest GIS database 

Existing road density is greater on the non-NFS lands within the Tongass National 

Forest boundaries than on the NFS lands due to concentrated harvest and more 

populated areas. It averages 0.19 mile per square mile on NFS lands and 2.19 

miles per square mile for the non-NFS lands. The average for lands of all 

ownerships is 0.31 mile per square mile; however, those are averages over a very 

large area and there is great variability. The range of road density by VCU shows 

large variabilityacross the Tongass as seen in Table 3.6-9 in the Fish section 

(percentage of VCUs by road density category for the Tongass and lands of all 

ownerships). All VCUs have road densities of less than 4 miles per square mile 

under existing condition. 

Table 3.7-7 shows the average future road density for each alternative. It includes 

existing roads and forestry as well as other roads proposed for construction on NFS 

lands and reasonably foreseeable on non-NFS lands. Alternatives 7 and 4, and to a 

lesser extent Alternatives 5 and 6, would have the highest average road density. 

Therefore, in those alternatives, there is higher risk that management actions would 

add to cumulative effects to sensitive or rare plants. The average road density for 

Alternative 3 is intermediate and its risk of cumulative effects would fall in the midrange when compared to the other alternatives. Alternatives 1 and 2 would have the 

least risk of cumulative effects. Table 3.6-9 in the Fish section shows a similar 

relative risk among the alternatives of cumulative effects by VCU. 

Table 3.7-7 

Future Average Road Density by Alternative (miles per square mile) 

Alternative 

 Existing 1 2 3 4 5 6 7 

National Forest 

Service Land 0.19 0.22 0.27 0.30 0.38 0.34 0.33 0.41 

All Ownerships 0.31 0.42 0.47 0.49 0.57 0.53 0.52 0.60 

Source: Tongass National Forest GIS database 
3 Environment and Effects

Plants 3-116 Final EIS

There are other activities that have occurred in the past and are reasonably 

foreseeable to occur in the future that have the potential to add to cumulative effects 

to rare and sensitive plants in regional and local areas. They include mineral 

extraction, transmission line projects, hydroelectric projects, transportation 

developments, expansion of cities, and recreational site development. Existing 

mining is at Greens Creek on Admiralty Island, Berner’s Bay north of Juneau, and 

other locations. Given the level of world pricing, an increase in exploration is 

expected. There are also several regional transportation projects and regional 

energy and transmission projects planned for construction. Each of these activities 

can include clearing vegetation and disturbing habitat for construction and 

maintenance; therefore, they have the potential to affect sensitive and rare plants 

and their habitat and would be considered in project analysis. 

Changes in Alaska’s climate (discussed in the Climate and Air section of this 

chapter) could affect the hydrology and other habitat conditions where the sensitive 

and rare plants occur. While the models do not fully agree on the climate change 

predictions for Southeast Alaska, they generally agree on warmer weather with 

more winter rainfall and less snowfall and a decrease in summer rain in some areas. 

That would likely result in lower soil moisture due to increased evaporation during 

warmer, drier summer months. Also, a precipitation shift from snow to rain could 

lead to more water running off the landscape rather than being stored to feed 

streams and wetlands in the late spring and summer; thus, increasing evaporation 

and reducing water storage. These factors could lead to drier streams, meadows, 

and wetlands. 

Changes in temperature and hydrologic conditions would likely favor some plant 

species and stress others. There has been little research into the effects of 

changes in environmental conditions for each of the sensitive and rare species; 

consequently, there is uncertainty as to the effect of changes in the climate on these 

plant species known or suspected to occur on the Tongass. 

Invasive Plant Species 

When considering effects to invasive plants, it is important to look at both NFS and 

non-NFS lands and the cumulative effects of past, present, and reasonably 

foreseeable future activities. Invasive plants on any land ownership in Southeast 

Alaska can affect invasive establishment or spread on NFS lands and vice versa. 

Also, activities on land of any ownership can establish or spread plants that affect 

other lands. As mentioned in the direct and indirect effects, activities can have 

wider affects on invasive plants than the specific area of land disturbance due to the 

interconnectedness of land. 

As discussed for rare plants, each landscape area has different characteristics and 

vegetation patterns. The significance of an addition to cumulative effects of forestry 

activities would depend on factors such as the amount and type of disturbance in 

the analysis area, the existence of invasive plants at the time of project 

implementation, type of vegetation in the area, amount of harvest and road building 

for a specific project, and the project plans to contain invasive plants. Assessing 

cumulative effects needs to be done for individual projects in the context of the 

effects in the relevant analysis area. 

Past, present, and future harvest and road construction for harvest and other 

purposes on lands of all ownerships can be used to compare the risk of Alternative 6 

(Proposed Alternative), to cumulative effects due to invasive plant introduction or 

spread. Table 3.7-7 shows the average existing road density and future road 

density for each alternative for all land ownerships and for NFS lands. Alternatives 

7 and 4 and, to a lesser extent, Alternatives 5 and 6 would have the highest average 
Environment and Effects 3

Final EIS 3-117 Plants 

road density and, therefore, a higher risk of adding to cumulative effects of invasive 

plants. The average road density for Alternative 3 is intermediate; its risk of 

cumulative effects would fall in the mid-range when compared to the other 

alternatives. Alternatives 1 and 2 would have the least risk of cumulative effects due 

to an individual project. 

As discussed under cumulative effects for sensitive and rare plants, there are fewer 

restrictions on timber activities on non-NFS lands than on NFS lands. Timber 

activities on non-NFS lands that can contribute to the introduction or spread of 

invasive plants are not specifically regulated by the State of Alaska. To compare the 

risk of effects of harvest in the seven alternatives on invasive plants, POG remaining 

on land of all ownerships was analyzed. Looking at all ownerships of land in the 

Forest, the POG (unharvested) forest remaining in 100 years under full 

implementation of the Forest Plan would be greatest for Alternative 1, followed by 

Alternatives 2, 3, 6, 5, 4, and 7 (Table 3.7-6). Therefore, the risk of cumulative 

effects to be substantial for invasive plants due to harvest would be highest for 

Alternative 7, followed by 4, 5, 6, 3, 2, and 1. 

There are other activities that have occurred and are reasonably foreseeable to 

occur in the future that have the potential to add to cumulative effects of invasive 

plants. They include mineral extraction, transmission line projects, hydroelectric 

projects, transportation developments, expansion of cities, and recreational site 

development. Each of these activities can include clearing vegetation, construction, 

transportation for construction and ongoing activities, and maintenance. Therefore, 

they have the potential to introduce or spread invasive plants in an area and would 

need to be considered in the project analysis. 

Changes in Southeast Alaska’s climate (discussed in the Climate and Air section of 

this chapter) could also create the conditions that encourage the spread of invasive 

plants by altering opportunities for invasive plants to colonize new areas, where 

could be compounded by climate change. Changing climate may also result in 

range extensions for some species that are native at more southerly latitudes, and 

they may become established or become more widespread on the Tongass, as a 

result. Changes in growing conditions would likely favor some plant species and 

stress others. There is uncertainty in the effect of changes in the climate to the 

invasive plants on the Tongass. 
3 Environment and Effects

Plants 3-118 Final EIS

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Environment and Effects 3

Final EIS 3-119 Forest Health 

Forest Health 

Affected Environment ..............................................................................3-119

Current Situation .....................................................................................3-119

Monitoring and Pest Management ..........................................................3-122

Environmental Consequences................................................................3-122

Direct and Indirect Effects .......................................................................3-122

Cumulative Effects ..................................................................................3-124

Affected Environment 

Insects, diseases, related decay processes and windthrow are an integral and 

natural part of forest ecosystems. Many of these appear to play key roles in gaplevel disturbance (see discussion of old-growth forests in the Biodiversity section of 

this chapter) and in providing wildlife habitat. The majority of the forests on the 

Tongass are old-growth forests. Losses to the timber resource caused by heart rot 

in live trees are considerable in old-growth forests. Approximately one-third of the 

volume of the old-growth hemlock-spruce forests in Southeast Alaska is decayed by 

heart rot fungi (USDA Forest Service and ADNR 2007). 

In addition to heart rot, some of the more common destructive insects, diseases, and 

conditions within Southeast Alaska are listed below. 

Black-Headed Budworm, Acleris gloverana (Walsingham), is one of the more 

destructive forest insects in coastal Southeast Alaska. In 1993, a peak year for 

budworm, approximately 258,000 acres of spruce-hemlock forests were affected. 

This was the largest outbreak in decades. In the 1950s, almost one-third of the net 

timber volume was lost on many hemlock sites due to budworm defoliation (USDA 

Forest Service and ADNR 2000). Black-headed budworm populations are currently 

at endemic levels, with less than 1,000 acres of mapped defoliation in the last 3 

years (USDA Forest Service and ADNR 2007). Larval feeding strips hemlock 

foliage and can cause growth reduction, top-kill, and, at times, tree mortality (USDA 

Forest Service and ADNR 2000). Juday et al. (1998) rated many potential impacts 

on the coastal forests of Southeast Alaska due to climate change. They concluded 

that there was a high risk of increased damage from black-headed budworm 

outbreaks. 

Hemlock Sawfly, Neodiprion tsugae (Middleton), is a serious defoliator of western 

hemlock throughout Southeast Alaska. Outbreaks tend to be of longer duration in 

southern Southeast Alaska where widespread damage is usually confined to the 

area south of Frederick Sound, especially along Clarence Strait. Larvae feed on 

mature (older) needles rather than current year (new) foliage. Most sawfly 

outbreaks do not cause tree mortality, but the tops are killed in some trees and tree 

growth may be reduced. Heavy defoliation by hemlock sawflies is known to reduce 

radial growth and cause top kill. No hemlock sawfly defoliation was mapped in 2006 

(USDA Forest Service and ADNR 2007). 

Spruce Beetle, Dendroctonus rufipennis (Kirby), is the most destructive forest 

insect Alaska-wide, although outbreaks in Southeast Alaska are typically smaller 

and of shorter duration than those in south/central and interior Alaska. Most 

outbreaks originate in blowdown or in cull logs left in harvest units and spread to 

adjacent standing timber. Mortality in unmanaged Sitka spruce stands varies and 

can be as high as 75 percent. Weather conditions appear to play a role in the 

expansion or contraction of beetle populations. Spruce beetle activity has been 

Current 

Situation 
3 Environment and Effects

Forest Health 3-120 Final EIS 

noted across the Tongass National Forest and adjacent lands from Yakutat 

Forelands to Dall Island (USDA Forest Service and ADNR 2000). Spruce beetle 

activity in 2006 centered on a 4,000-acre area between Haines and Skagway 

(USDA Forest Service and ADNR 2007). 

Spruce Needle Aphid, Elatobium abietinum (Walker), is an introduced species that 

feeds on the needles of Sitka spruce, often causing reduced growth and increasing 

susceptibility to other mortality agents such as spruce beetle. As with other insect 

pests, populations have cycles, generally increasing following mild winters. More 

than 25,000 acres of spruce forest were defoliated in the winter of 1991 to 1992 

(USDA Forest Service and ADNR 2000). The current outbreak began in 1998, with 

the worst defoliation occurring in 2003 when more than 30,000 acres were affected. 

Defoliation by spruce aphids affected approximately 9,120 acres in 2006, mostly in 

small pockets within the beach fringe from Lynn Canal in the north to Dall Island in 

the south (USDA Forest Service and ADNR 2007). 

Hemlock Dwarf Mistletoe, Arceuthobium tsugense (Rosendhal, G. N. Jones), is a 

parasitic flowering plant that infects western hemlock throughout Southeast Alaska 

as far north as Haines. Infestation levels vary—dwarf mistletoe is absent in some 

stands, while almost every hemlock is infected in other stands. The upper 

elevational limit for Hemlock dwarf mistletoe in approximately 500 feet (Shaw and 

Hennon 1991). Volume growth in western hemlock trees heavily infected with dwarf 

mistletoe can be reduced by 39 percent or more (Thomson et al. 1985). In addition 

to reduced stem growth, infestations cause increased growth and retention of lower 

branches and distortation and weakening of wood strength at and near swellings. 

The spread of dwarf-mistletoe in young hemlock stands can result from leaving 

standing infected hemlock in harvest units (Laurent 1974). Dwarf mistletoe 

responds to light with increased seed production. Rates of spread to adjacent and 

lower canopy trees may increase in partial cuts where infected hemlocks remain. 

Trummer et al. (1998) developed a model for dwarf mistletoe infections in unevenaged forests of Southeast Alaska that suggests infection rates are significantly 

correlated with levels of dwarf mistletoe infection in the residual trees. Deal (2001) 

reports partial cutting resulted in maintaining mistletoe levels at generally 

undamaging levels, with a trend towards less mistletoe in stands with higher harvest 

levels. A recent study of partial cut stands in British Columbia found that most 

young trees infected with mistletoe were advanced regeneration established before 

logging (Muir 2006). 

Alaska Yellow-Cedar. Decline and mortality of yellow-cedar continues to be one of 

the most widespread and important forest problems in Southeast Alaska. Aerial 

surveys have mapped approximately 500,000 acres of decline in a wide band from 

western Chichagof and Baranof Islands to the Ketchikan area (USDA Forest Service 

and ADNR 2007). This decline is associated with wet, poorly drained sites, and 

recent research has demonstrated that no organism is the primary cause of the 

decline (Hennon and Shaw 1997). Hennon and Shaw suggest that reduced snow 

pack in low-elevation areas associated with a warming trend that started in the 

1800s has exposed fine surface roots to freezing, which in turn kills trees. As the 

climate continues to warm, cedar decline is likely to continue to spread, especially in 

the south and east. Conversely, yellow-cedar appears to be spreading northward as 

climate warms, into areas that retain snow longer into the spring. 

Hemlock Fluting. Hemlocks with fluting have deeply incised grooves and ridges 

extending vertically along their trunks, a condition that reduces the value of hemlock 

logs because they yield less sawlog volume and some of the milled wood contains 

bark. Fluting is a common problem in Southeast Alaska, especially on mid- to highquality sites at low elevations, on gradual slopes, and with western exposure (Julin 

et al. 1993). It is rarely found away from the coast. The cause of fluting is not 
Environment and Effects 3

Final EIS 3-121 Forest Health 

completely understood, but it may be associated with increased wind firmness, 

especially on shallow soils, due to growth increases triggered by silvicultural 

treatments or natural disturbance (USDA Forest Service and ADNR 2007). Julin et 

al (1993) found that the larger buttresses were generally aligned with the direction of 

the tree lean. They also concluded that western hemlock trees in Southeast Alaska 

may be genetically predisposed to form fluted trunks. Silvicultural treatments that 

favor other species and reduce branch size and retention period would greatly 

reduce fluting (Julin et al. 1993). However, because fluting primarily occurs in the 

beach buffer, the effect on timber resources is limited. 

Decays. Stem decays cause substantial loss in all tree species in unmanaged 

stands. Tree death and stem breakage resulting from decay contribute to the 

structural diversity in stands and may be a major factor in small-scale disturbance in 

Southeast Alaska (Hennon and McClellan 2003). Many decay fungi enter through 

tree wounds. The accidental wounding of trees during partial cuts and commercial 

thinnings can increase the impact from decay organisms in managed stands (USDA 

Forest Service 1997a, Appendix G). However, Christensen et al. (2002) found very 

low levels of disease-caused defects in both thinned and unthinned 90-year-old 

hemlock-Sitka spruce stands on the Tongass compared to old-growth forests. 

Juday et al. (1998) rated many potential impacts on the coastal forests of Southeast 

Alaska due to climate change. They concluded that there is a risk that new fungal 

tree diseases will appear in Southeast Alaska as the climate warms. 

Animal Damage. Significant animal damage to trees is apparent at various locations 

across the Tongass National Forest. Porcupine feeding on hemlock and spruce is 

common on Mitkof Island and many mainland areas. Young trees in managed and 

unmanaged stands are often top-killed or killed outright as porcupine feeding girdles 

the main bole. Bark beetles have been found infesting damaged trees. This damage 

becomes significant when groups of trees are killed or deformed. As trees grow 

larger (age 40 to 50 years), porcupine damage shifts from top kill to basal wounds, 

which serve as entry points for decay fungi. Brown bears cause basal wounds on 

Alaska yellow-cedar each spring on Baranof and Chichagof Islands. Bears rip off the 

bark in the spring to lick the sweet cambium. The majority of yellow-cedar in some 

stands have basal wounds from bear feeding (ADNR 2000). 

Fire. Fire has played a minor role in the forests of Southeast Alaska because of the 

abundant year-round precipitation. The average size of fires on the Forest between 

1958 and 1988 was less than 7 acres (USDA Forest Service 2003b). More recently, 

approximately 400 to 500 acres have burned annually on the Tongass. The average 

fire has been approximately 10 acres (pers. com. Dexter Duehn, Fire Management 

Officer, Tongass National Forest). Juday et al. (1998) rated many potential impacts 

on the coastal forests of Southeast Alaska due to climate change. They concluded 

that there would be an increased risk of forest fires, though they anticipated the 

effects on resources would be low. 

Windthrow. Windthrow is the dominant disturbance agent in Southeast Alaska. 

Two forms occur: small-scale events (gap disturbance) and large-scale events 

(catastrophic disturbance). Most of the Forest is subject to small-scale windthrow 

events. Individual trees or small groups of trees blow over during storm events, 

opening gaps in the canopy that allow young trees to grow to fill the openings. This 

results in complex, mixed-aged stands. Disease and decay agents also play a role 

in this process. Nowacki and Kramer (1998) state that diseased trees are more at 

risk to windthrow and stem-snap, while Hennon and McClellan (2003) report that 

many of the uprooted or broken-stemmed trees had died before falling. Small-scale 

events occur on a regular basis and result in openings from 6 to 13 percent on the 

canopy (Nowacki and Kramer 1998). Areas not protected by topographic barriers 

from the severe effects of infrequent, major storms are subject to large-scale 
3 Environment and Effects

Forest Health 3-122 Final EIS 

windthrow events that cause catastrophic damage. Entire stands have been blown 

down in the past, resulting in the regeneration of more even-aged stands with more 

uniform canopies (Nowacki and Kramer 1998). Both forms of windthrow are a part 

of the natural forest generation, growth, and development. Juday et al. (1998) rated 

many potential impacts on the coastal forests of Southeast Alaska due to climate 

change. They concluded that there was a high risk of increased large-scale 

blowdown across Southeast Alaska as well as increased windthrow around harvest 

units. 

Forest pest activity on the Tongass National Forest is typically detected during onthe-ground activities, or during annual aerial surveys conducted by the region’s 

Forest Pest Management group. The timing of surveys coincides with foliage and 

pest development. Pest activity noted during surveys is documented and reported 

to the appropriate land manager. In cooperation with land managers, Forest Pest 

Management people conduct on-site investigations to verify the pest, evaluate the 

pest and its host(s), and formulate future management alternatives. Often, pest and 

host monitoring is required to fully understand potential impacts prior to development 

of management alternatives. 

Populations of historically significant defoliating insects are monitored through a 

sampling system that occurs in conjunction with the annual aerial survey. 

Defoliating larvae are collected, identified, and counted at designated sites. Gypsy 

moth pheromone traps have been placed throughout Southeast Alaska to provide an 

early warning that these insects are present. Data from larvae counts and 

pheromone traps, in conjunction with the collection of host and weather information, 

enhances forest pest managers’ ability to predict defoliator damage. 

The impact of hemlock dwarf-mistletoe and methods of reducing damage from the 

disease in managed stands have been established by several research studies. In 

addition, Forest Pest Management has surveyed numerous even-aged stands from 

10 to 100 years old to determine the incidence and impact of hemlock dwarfmistletoe in managed stands. 

Research studies have yielded information on the pathology and epidemiology of 

decline of yellow-cedar (cited above). In addition, information on the distribution of 

decline and acreage affected has been determined by mapping during aerial 

surveys. Porcupine damage in managed stands is currently being assessed. As 

more young-growth stands reach commercial thinning age, forest pest research is 

beginning to focus on pest activity within these stands. 

The Forest develops site-specific prescriptions, based on monitoring information, 

scientific information, and pest management projections, to prevent or limit insect 

and disease damage. The objective is to limit infestations of natural insects, 

disease-causing organisms, and parasites to normal background levels, and to 

prevent or reduce infestations of non-native organisms to the extent feasible. 

Similarly, the Forest objective is to limit windthrow to levels that would occur 

naturally through silvicultural prescriptions prepared for each timber sale. 

Environmental Consequences 

In general, alternatives that favor low amounts of timber harvest will tend to 

perpetuate current disease levels in old-growth forests. Ecological processes and 

wildlife habitat for old-growth associated species would be maximized, but so would 

the continued loss of timber, primarily due to high levels of heart rot. Higher 

amounts of timber harvest would generally yield young stands with lower levels of 

insect and disease activity. However, two-aged and uneven-aged management, 

primarily used in the Scenic Viewshed LUD, could maintain or even increase levels 

Monitoring 

and Pest 

Management 

Direct and 

Indirect 

Effects 
Environment and Effects 3

Final EIS 3-123 Forest Health 

of hemlock dwarf mistletoe. Two-aged and uneven-aged management may also 

result in higher levels of stem and root disease caused by injuring residual trees 

during harvest operations; however, the degree of increase, if any, is uncertain. 

Two-aged treatments that clump leave trees are less likely to cause damage to 

residual trees. Similarly, thinning young, even-aged stands may also lead to stem 

and root disease due to wounding of leave trees during thinning, although a 

retrospective study did not find that thinning had increased defect levels in thinned 

stands on the Tongass compared to unmanaged stands (Deal et al. 2002), and 

Christensen et al. (2002) did not find higher levels of decay in two 90-year old 

stands that had been commercially thinned 25 years earlier compared to unthinned 

stands. 

Alternative 7 proposes approximately three times the suitable acres as Alternative 1, 

and Alternatives 4, 5, and 6 propose approximately twice the number of suitable 

acres as Alternative 1 and substantially more than Alternatives 2 and 3. Most 

suitable acres would be harvested at some time during the next 100 years (refer to 

the Timber section for a discussion of likely harvest under each alternative). 

Therefore, over time, Alternatives 7 and 4 and, to a lesser extent, Alternatives 5 and 

6, are likely to result in more acres with a lower risk of insect activity and somewhat 

less forest with high levels of heart rot and other disease organisms than the other 

alternatives. Conversely, Alternatives 1 and 2 would retain more acres of old-growth 

forest, which would likely result in somewhat higher levels of insect and disease 

across the Tongass. The acres of suitable land proposed for Alternative 3 is 

intermediate between Alternatives 2 and 5, and its effects on insect and disease 

would likely fall in the mid-range, compared to the other alternatives. 

Alternatives 4, 5, 6, and 7 could result in approximately four to ten times as many 

acres of two-aged and uneven-aged harvest over time as Alternatives 1 and two to 

four times as many acres as Alternative 2 in the first decade (Table 3.8-1). There is 

some concern that two-aged and uneven-aged harvest could lead to higher levels of 

windthrow, dwarf mistletoe, and stem decay compared to even-aged harvest 

methods. Dean et al. (2002) report that the number of uprooted trees was 

somewhat higher in partially harvested stands, but overall tree mortality rates were 

similar. Bole wounds were common on trees in partially harvested stands, but 

“natural tree injuries from falling trees and animal feeding were far more abundant at 

several sites” (USDA Forest Service and ADNR 2002). Alternatives with more twoaged and uneven-aged management may favor shade-tolerant species (western 

hemlock, mountain hemlock, and yellow-cedar), while even-aged may result in 

stands with a higher proportion of Sitka spruce. However, retrospective studies 

indicate that Sitka spruce can be maintained in mixed hemlock-Sitka spruce stands 

over a wide range of cutting intensities if enough Sitka spruce trees are present in 

the stand after harvest (Dean 2002). 

Table 3.8-1 

Approximate Projected Annual Harvest During First Decade (acres) 

Alternative 

1 2 3 4 5 6 7 

Even-aged 1,180 3,674 5,181 7,308 6,872 6,769 10,030 

Two-aged and 

Uneven-aged 

602 1,586 2,193 3,957 3,028 2,859 5,902 

Source: SPECTRUM Model (Forest-wide Activity and Output Results)

In general, endemic levels of insect and disease activity in mature and overmature 

forests would be allowed to run their course under all alternatives. Harvesting 

flexibility would be maintained to take advantage of timber salvage opportunities, 

particularly for dead and dying yellow-cedar stands. Insect and disease suppression 
3 Environment and Effects

Forest Health 3-124 Final EIS 

may be justified in high-quality, mature to overmature stands that cannot be 

salvaged immediately, or that lie near recreation areas and communities where 

scenic values are high. 

Animal damage, such as that from porcupines, is expected to continue and would 

likely be increasingly evident in precommercially thinned stands where porcupines 

are present. Winter feeding by porcupines is known to damage and sometimes kill 

young trees. The Forest has been alternating precommercial thinning prescriptions 

to reduce porcupine damage by favoring cedar and deferring thinning in some 

areas. Bear also damage young trees by removing bark to reach the sweet 

cambium tissue below the bark. Alternatives that result in creating more young 

stands (Alternatives 4, 5, 6, and 7) would lead to more acres of forest that would be 

vulnerable to animal damage. 

Damage from wind would continue to occur; some increase is likely to occur along 

the edges of harvest units and along stream buffers and other legacy trees. 

Riparian buffers would be protected under Alternatives 1 to 6 by leaving sufficient 

additional trees along the outer edge of the stream buffer to provide a reasonable 

assurance of a windfirm (RAW) buffer. Riparian buffers on Class I and II streams 

would be protected by RAW buffers under Alternative 7. Alternatives with more 

harvest and road building (Alternatives 4, 5, 6, and especially 7) would tend to 

increase the risk of harvest- and road-related windthrow compared to those with less 

harvest and road building (Alternatives 1 and 2). If the current climate trend 

continues and more gale-force wind storms occur, blowdown may increase for all 

alternatives in proportion to the amount of harvest (refer to the Timber section of this 

chapter). 

There may be a short-term increase in fire risk during harvest operations if activities 

are conducted during dry periods. Alternatives with higher levels of timber harvest 

(Alternatives 4, 5, 6, and 7) may have a small increase in fire risk compared to 

alternatives with less harvest. If climate change results in warmer, dryer summer 

conditions, fire risk may increase for all alternatives compared to the last several 

decades. Warmer winters are likely to increase insect damage because more 

insects will survive the winter. This, in turn, could lead to larger and more frequent 

fires (refer to the Climate and Air section of this chapter). 

The greatest potential forest insect and disease problems are likely to be in mature 

and overmature stands where disease levels are high. Tree vigor tends to decrease 

with maturity, causing an increase in susceptibility to insects and diseases. Heart 

rot levels are directly proportional to both tree and stand ages. The spruce beetle 

has the potential to significantly alter the desired condition of stands in certain 

locations near the mainland where the insect has periodically become active. The 

spruce aphid was introduced approximately 80 years ago and appears to be causing 

more damage to spruce as the climate warms (Shrader and Hennon 2005). The 

recent assessment of invasive pathogens in Alaska and its national forests states 

that Alaskan forests are particularly vulnerable to invasive pathogens because of the 

relatively small number of native tree species and the narrow genetic base (Shrader 

and Hennon 2005), although damage in 2006 was down 60 percent from the peak in 

2003 (USDA Forest Service and ADNR 2007). The Shrader and Hennon report 

concluded that the European scolytid bark beetle poses the greatest threat to the 

spruce forests throughout Alaska if introduced. 

Stem and root decay, and the incidence of hemlock dwarf-mistletoe, have 

historically increased with intensified land management activities, particularly under 

harvesting systems other than clearcutting (Trummer et al. 1998). If the current 

warming trend continues, cedar decline and damage from insects are likely to 

increase, both from species currently present in Southeast Alaska and from entering 

Cumulative 

Effects 
Environment and Effects 3

Final EIS 3-125 Forest Health 

the area from other parts of North America or elsewhere. Hotter, dryer summers 

could also lead to increased fire frequency, size, and damage, which could have 

fundamental changes in age class and species composition. This, in turn, could 

result in changes in wildlife habitat. Invasive plants may also adversely affect forest 

health. Refer to the Plant section of this chapter for a discussion of invasive plant 

species. 

There have been approximately 767,000 acres of harvest in Southeast Alaska, 

approximately 41 percent of this has been on non-National Forest System (NFS) 

lands. There are over 330,000 acres of old-growth forest on state and Native 

corporation lands. It is likely that most of this would be harvested over the next few 

decades and replaced with young stands that would be managed on relatively short 

rotations. Shorter rotations and even-aged silvicultural prescriptions implemented 

on non-NFS lands are likely to contribute to decreasing mistletoe, insect, and 

disease levels in the forests of Southeast Alaska, especially the loss due to heart 

rot. Alternatives with more even-aged management, especially Alternatives 4 and 7, 

would add to these changes. Conversely, increased use of commercial thinning in 

the outer decades may damage leave trees, increasing decay rates. Also, the 

younger stands established after harvest on all lands are likely to add to the loss of 

growth and tree mortality caused by animal damage in the region. Harvest-related 

windthrow may increase on NFS lands and adjacent areas that are harvested using 

even-aged silvicultural systems whether on NFS or non-NFS lands. 

Maintaining biotic and structural diversity provides an opportunity for limiting some 

insect and disease problems. Some insects and diseases are host-specific, depend 

upon plants that are under stress, or flourish under homogeneous conditions. In 

other cases, and particularly for heart rot, favoring younger-aged stands through 

even-aged management may be the most effective way of limiting insect and 

disease problems. Maintaining healthy young-growth stands through stand density 

control (thinning) may reduce insect damage (Neilson 2007). 

The careful use of alternatives to even-aged harvest methods can be a tool for 

maintaining natural but not excessive levels of diseases, such as heart rot and dwarf 

mistletoe, which have important ecological consequences. Integrated Pest 

Management provides the opportunity to evaluate these and more traditional 

clearcut practices. Through prescription processes, stands with unacceptable insect 

and disease-related losses, as well as those of high risk for future losses, would be 

identified for treatment. Detection methods such as aerial surveys, currently in use, 

would continue to be used for the early identification of epidemics. 

The current warming trend increases the risk of increased insect and disease 

outbreaks, catastrophic blowdown events, and fires. Juday et al. (1998) rated many 

potential impacts on the coastal forests of Southeast Alaska due to climate change. 

They concluded that there was a high risk of increased large-scale blowdown across 

Southeast Alaska and increased windthrow around harvest units; although, they also 

state that as of the date of their report, the increased frequency of storms in the last 

few decades has not corresponded to an increase in large-scale blowdown in 

Southeast Alaska. Also, the 2006 Forest Health report noted very little blowdown in 

aerial and ground surveys (USDA Forest Service and ADNR 2007); however, this 

does not rule out the risk of increased windthrow in the future as additional warming 

occurs. 

Warmer, dryer weather may result in increased levels of insect and disease levels. 

For example, Juday et al. (1998) concluded that there was a high risk of increased 

damage from black-headed budworm outbreaks, and there is a risk that new fungal 

tree diseases will appear in Southeast Alaska as the climate warms. 
3 Environment and Effects

Forest Health 3-126 Final EIS 

As discussed under the Climate and Air section, some climate models for Southeast 

Alaska predict rising temperatures, a 10 percent decrease in summer precipitation in 

portions of the region, and decreased soil moisture due to increased evaporation 

during warmer, dryer summer weather. These factors may lead to an increase in 

fire frequency and severity by 2060, ranging from 10 to 30 percent, depending on 

the model (Dale 2003). Currently, fire is not a factor in the ecology of Southeast 

Alaska, and an increase of 30 percent in acres burned would still result in very little 

fire damage. Given the high rainfall levels in Southeast Alaska (Ketchikan had only 2 

days without rain in July 2007, receiving a total of 10 inches of rain that month), a 10 

percent decrease in summer rainfall would still result in wet conditions in most years. 

However, Southeast Alaska does occasionally experience dryer conditions. For 

example, in July 1971 there were 23 days without rain. If warmer winter weather 

results in higher insect populations and increased tree defoliation, there is a risk that 

increased dead material and warmer, dryer weather may spawn more fires than are 

normal for the area. Berman et al. (1998) state that it is difficult to predict the 

magnitude of area likely to be burned in a region with no historic fire record, but they 

believe that most fires would be small and of low intensity. Berman et al. (1998) 

suggest a scenario in which 5,000 acres might burn over a period of decades. Juday 

et al. (1998) also suggest that the effects of fires on resources are likely to be low. 
 Environment and Effects 3 

Final EIS 3-127 Biodiversity 

Biodiversity 

Affected Environment........................................................................................3-127

Ecosystem Classification.............................................................................3-129

Biogeographic Provinces..........................................................................3-129

Ecological Sections and Subsections.......................................................3-129

Cover Types...................................................................................................3-134

Non-Forested Lands.................................................................................3-135

Unproductive Forest .................................................................................3-135

Productive Forest .....................................................................................3-137

Old Growth Classification .........................................................................3-139

Forest-Wide Distribution of Old-Growth Forest........................................3-142

Past Old-Growth Harvest..........................................................................3-147

Fragmentation ..........................................................................................3-167

Intact Watersheds.....................................................................................3-168

Endemism.................................................................................................3-170

Invasive Species.......................................................................................3-171

Environmental Consequences .........................................................................3-173

Direct and Indirect Effects ...........................................................................3-173

Measurement of Effects............................................................................3-173

Conservation Strategy Overview..............................................................3-174

General Overview of Effects.....................................................................3-175

Effects by Alternative................................................................................3-182

Endemics..................................................................................................3-196

Invasive Species.......................................................................................3-197

Cumulative Effects........................................................................................3-198

Cumulative Effects on Productive Old Growth in General .......................3-199

Cumulative Effects on Specific Productive Old-Growth Types ................3-202

Cumulative Effects and Climate Change..................................................3-203

Cumulative Effects by Biogeographic Province .......................................3-205

Affected Environment 

The conservation of biological diversity, or biodiversity, is of national and global 

concern. Biodiversity may be defined as “The variety of and variability within and 

among living organisms and the ecological complexes of which they are part; this 

includes diversity within species, between species, and of ecosystems.” (United 

Nations Environment Programme 1991). Biological diversity encompasses the 

variety of genetic stocks, plant and animal species and subspecies, ecosystems, 

and the ecological processes through which individual organisms interact with one 

another and their environments. Under the National Forest Management Act 

(NFMA), the Forest must provide for diversity of plant and animal communities 

based on the suitability and capability of specific land areas. 

The conservation of biological diversity commonly requires a dual strategy 

addressing both individual species, as well as entire ecosystems (Marcot et al. 

1994). Many discussions of biodiversity revolve around the maintenance of species; 

however, it must be emphasized that conserving biodiversity is about maintaining 

genetic, species, community or ecosystem, and landscape levels of biological 

organization. The traditional species-by-species approach is important for featured 

or management indicator species, sensitive or rare species, and for the recovery of 

federally designated threatened or endangered species. A more comprehensive 

strategy focused on higher levels of biological organization, and ecosystems may be 
3 Environment and Effects

Biodiversity 3-128 Final EIS

necessary to conserve rare or declining habitats, as well as the entire complement 

of associated biota and ecological processes (Noss 1991, Scott et al. 1991, Franklin 

1993). For a conservation strategy targeting biodiversity to be truly effective, it 

should have the following characteristics or expected outcomes: 

• It should include the conservation of all levels or scales of biodiversity in the 

planning area (Schwartz 1999, Poiani et al. 2000), 

• It should be comprehensive in its inclusion of all elements (Lambeck and Hobbs 

2002, Groves 2003), 

• It should address the concept of adequacy (Lambeck and Hobbs 2000, Tear et 

al. 2005), 

• It should provide a framework for monitoring (Haufler et al. 2002, Tear et al. 

2005), and 

• It should anticipate change (Tear et al. 2005). 

Maintaining and/or enhancing habitats to sustain viable populations of individual 

species are addressed by guidelines for specific species or species groups. This 

"fine filter" approach to biological conservation is discussed in the Wildlife, Fish, and 

Plant sections of this chapter. The most practical way to address conservation of 

these species and other elements of biodiversity is by using a broader “coarse filter,” 

or ecosystem/landscape-based strategy for conserving biological diversity (Noss 

1991, Scott et al. 1991, Wilcove 1993). While many conservation planning efforts 

blend the two strategies, it is important to note that there are fundamental 

differences between these conservation strategies. Fine filter strategies focus on 

providing for the needs of individual or multiple species within a landscape while 

coarse filter strategies focus on providing an appropriate mix of ecosystems or 

ecological communities across a planning landscape (The Nature Conservancy 

1982, Marcot et al. 1994, Haufler 1999, Schwartz 1999). 

Biological diversity on an ecosystem or landscape scale can be described in terms 

of three components: composition, structure, and function (Noss 1990). These three 

components refer to the following: 

• Composition refers to the numbers and types of species, plant communities, 

and smaller ecosystems within an area. 

• Structure refers to the spatial arrangement of these communities or ecosystems 

across a landscape, their vertical stratification into dominant life forms (tree, 

shrub, herbaceous), the horizontal spacing of communities across the 

landscape, and how they are connected to variations in tree heights and 

diameters within a stand or between stands. 

• Function refers to the interactions and influences between plant and animal 

species within an area—how each species uses its environment—and to natural 

processes of change or disturbance (wind, aging, etc.). 

For additional discussion on composition, structure, and function components of 

biological diversity, see the 1997 Forest Plan Final EIS (pages 3-12 to 3-26). 

Assessing biodiversity and the conservation strategy to provide viable, well 

distributed populations across the Tongass National Forest has been conducted at 

several scales from broad biogeographic provinces down to finer scales of 

ecological subsections, watersheds, and Value Comparison Units (VCUs). 

Assessing biodiversity at smaller scales such as at watershed and VCU level is 

done at the project-level scale. The biogeographic province and ecological 
 Environment and Effects 3 

Final EIS 3-129 Biodiversity 

section/subsection are discussed in more detail below, with the focus on maintaining 

biodiversity across the entire Tongass. 

Utilizing both biogeographic provinces and ecological subsection classifications 

allows for some additional insight into how various communities are represented at 

different landscape scales. Both classification systems were developed using 

different processes, but complement each other in terms of addressing biodiversity. 

The development of biogeographic provinces is weighted more heavily toward 

wildlife species distributions, including barriers and linkages, while the ecological 

section/subsection system is more heavily weighted toward surface geology and 

geomorphic processes, both of which affect soils and vegetation patterns. Both of 

these broad-based “coarse filter” classification systems are described in more detail 

below. 

Biogeographic Provinces 

The Tongass can be subdivided on an ecosystem basis. A broad division that has 

been used on the Tongass for a number of years is that of the biogeographic 

province (USDA Forest Service 1997a). These large-scale landscape delineations 

are characterized by 1) similarities in terrestrial wildlife species composition, 2) 

similarities in distributional patterns for many of these species, 3) geologic and water 

barriers stemming from past events, such as glaciation, and 4) generally similar 

climatic conditions and physiographic characteristics. By subdividing on this scale, 

biogeographic provinces can assist land managers in broad-level assessment and 

planning. 

Twenty-one biogeographic provinces were identified within the Tongass National 

Forest boundary. Only one of these provinces (Yakutat Forelands) extends partially 

outside the boundary. Two additional provinces (Chilkat River Complex and Glacier 

Bay/Fairweather Range) are defined completely outside the Forest boundary but 

within Southeast Alaska (Table 3.9-1). Figure 3.9-1 shows the location of the 

biogeographic provinces in Southeast Alaska with their corresponding map 

numbers. 

Ecological Sections and Subsections 

In addition to the biogeographic province approach, another way to address 

conservation of species and other elements of biodiversity with a “coarse filter” or 

ecosystem/landscape-based strategy, is to use the National Hierarchical Framework 

of Ecological Units, which describes and defines the process for delinating 

landscapes at various spatial scales. This process consists of eight nested mapping 

levels that serve a variety of purposes (Cleland et al. 1997). Within the hierarchy, 

ecological sections characterize medium to large ecosystems (on the order of 1,000 

square miles) and ecological subsections characterize mid-sized ecosystems of 10 

to 1,000 squares miles. Nowacki et al. (2001) used this framework to subdivide the 

Alaska Region into 19 ecological sections and 96 ecological subsections; 14 of the 

ecological sections and 73 of the ecological subsections occur on the Tongass. 

Nowacki et al. (2001) provide additional detail on the ecological sections and 

subsections of the Tongass. Physiography, lithology, and surface geology were the 

primary factors for subsection delineation in Southeast Alaska, along with 

geomorphic processes, soil groups, subregional climate, and potential natural 

communities (climax vegetation). They are delineated in Figure 3.9-2 and listed 

later in this section under Table 3.9-6. 

Ecosystem 

Classification 
3 Environment and Effects

Biodiversity 3-130 Final EIS

Table 3.9-1 

Biogeographic Provinces Identified within the Tongass National Forest

No. Province Description 

1. Yakutat 

Forelands 

A very young, nearly flat landscape with extensive flooding and active isostatic rebound (uplifting of 

the ground after glaciers recede). Most surfaces vary from 200 to 1,500 years old. Dune formation 

and succession are ongoing processes due to glacial rebound and wave action. Plant community 

patterns reflect a diverse mosaic of naturally occurring older and young forests, shrublands, bogs, 

and meadows. Sitka spruce, alder, and cottonwood are abundant on well drained, recently 

deglaciated, and active fluvial surfaces. Most of the province is inside the Tongass Forest boundary, 

but the southern lobe that extends into Glacier Bay National Park is not. 

2. 

Yakutat/ 

Glacier Bay 

Upland 

The climate varies from very wet hypermaritime along the coast to very wet maritime inland. 

Mountains abruptly rising more than 10,000 feet from sea level, extensive active glaciers, and fiords 

dominate this landscape. Sitka spruce, alder, and cottonwood are abundant at lower elevations; 

alpine and lichen over rock plant communities dominate the land from 2,000 to over 10,000 feet 

elevation. 

3. East Chichagof 

Island 

This province is drier and colder than the outer coast of Chichagof Island; the winter snow pack is 

generally greater. Chichagof Island is deeply dissected into three peninsulas, which may be 

functioning biologically more like separate islands. Vegetation in this province represents a modal 

condition similar to the Admiralty Island Province. 

4. West Chichagof 

Island 

This province is dominated by a very wet hypermaritime climate and exposure to outer coastal 

storms. Hundreds of small islands dot the coast. Topography is gentle when compared to the 

mountains of Baranof Island and the coastline is highly irregular. The Sitka spruce/Pacific reedgrass 

plant association is abundant along the outermost coastal fringe; otherwise, vegetation is similar to 

the other northern islands. 

5. East Baranof 

Island 

This province is colder than West Baranof or East Chichagof Island. Mountain glaciers occur along 

the divide between east and west Baranof. Topography is rugged and steep to saltwater, with little 

flat land. Plant associations on East Baranof are similar to much of the mainland due to the steep 

topography and cold environment. Spruce, devil's club, salmonberry forest associations are common 

on avalanche and steep erosional slopes; alpine and rock/lichen plant communities are abundant. 

6. West Baranof 

Island 

This province is similar to the West Chichagof Island Province with the exception of southern 

Baranof, where precipitation exceeds 250 inches per year. Topographically, Baranof Island is the 

most rugged of all the islands in Southeast Alaska. The southern half of this province is highly 

dissected by steep-sided fiords; the outer coast is dotted with hundreds of small islands. All forest 

plant associations except those in the Western redcedar series and those found around large 

mainland rivers occur in this province. Kruzof Island has some unique vegetation communities, 

which have not been classified. 

7. Admiralty 

Island 

This province is represented by relatively gentle topography and moderate rainfall. Winter conditions 

are moderated by the surrounding marine environment. Winds from Chatham and Icy Straits, Lynn 

Canal, and off the mainland are often severe. All forest plant associations except those in the 

Western redcedar series, those found around large mainland rivers, and those occurring only on 

outer coastal areas occur in this province. Forest productivity is high. Fresh and saltwater marshes 

in the numerous bays and inlets, and alpine and bog communities, are abundant. 

8. Lynn Canal 

Rain shadows and the dominating influence of the continental climate make this the driest and 

seasonally warmest province in Southeast Alaska. Precipitation is generally less than 60 inches per 

year. The topography is rugged and glaciated. The southern portion of the Chilkat Peninsula is more 

similar to the East Chichagof Island Province. Western and mountain hemlock and Sitka spruce plant 

associations are common. Alpine tundra and extensive rock/lichen communities dominate much of the 

land from 2,000 to over 8,000 feet elevation. 

9. Northern Coast 

Range 

This province has little maritime influence. Topography is rugged and glaciated. The Taku and 

Whiting Rivers extend into Canada. Yellow-cedar plant associations occur in this province. 

10. Kupreanof/ 

Mitkof Islands 

The climate is cooler and the winter snow pack greater than on the islands to the south. The eastern 

edge of this province is strongly influenced by wind-born loess (silt) coming from the Stikine River and 

the mainland. All forest plant associations except those in the Western redcedar series and those 

occurring only on outer coastal areas occur in this province. This province contains the highest 

percentage of muskeg wetlands within the Tongass. 

11. Kuiu Island 

Kuiu Island is deeply dissected, creating several prominent peninsulas. The topography is gentle 

compared to neighboring Baranof Island or the mainland. The climate is cooler and winter snow pack 

greater than on islands to the south, yet milder than the mainland or islands nearer the mainland. The 

western portion of Kuiu Island is subject to severe windstorms from both the ocean and Chatham 

Strait. Most forested plant associations occur here, but those found in outer coastal environments 

dominate. 
Environment and Effects 3 

Final EIS 3-131 Biodiversity 

Table 3.9-1 (continued) 

Biogeographic Provinces Identified within the Tongass National Forest

No. Province Description 

12. Central Coast 

Range 

This province is warmer than the Northern Coast Range Province. The topography is similar, but 

overall less precipitous. The Stikine River system is located in the center of this province and has a 

major continental influence, providing a migration corridor for plant and animal species. Plant 

associations found along saltwater are similar to those occurring elsewhere in northern Southeast 

Alaska except for those near the mouth of the Stikine River. Here, unique plant associations subject to 

high loess-carrying winds can be found. 

13. Etolin Island and 

Vicinity 

Similar to the Kupreanof/Mitkof Islands Province, this province is also subject to continental influence 

from the mainland and the Stikine River. Glacial flour (very finely ground particles of rock, silt, or clay 

created by a glacier when its rock-filled ice scrapes over bedrock and which flow out from beneath a 

glacier in the meltwater) is present in the marine environment in the northern part of this province 

nearly year-round. All forest plant associations except those occurring only on outer coast areas are 

present. 

14. 

North Central 

Prince of Wales 

Island 

Topography is relatively gentle, limestone is common, and precipitation is relatively low due to 

interception by lands to the south and southwest. All forest plant associations except those found 

around the mainland river systems occur in this province. Overall forest productivity is high. Karst 

topography and numerous caves are present. 

15. 

Revilla Island/ 

Cleveland 

Peninsula 

Climate is variable with warm and wet conditions predominating on land nearest the outer coast; much 

colder conditions occur near the mainland. Revilla, Gravina, and Annette Islands are influenced by 

human activities and populations, whereas the Cleveland Peninsula and Duke Island are generally in a 

natural condition. Revilla Island has many exceptional estuaries. Muskeg ponds are common on Duke 

Island, attracting many wintering and migratory birds. 

16. Southern Outer 

Islands 

These islands are isolated and are subject to strong oceanic influences. Temperatures are moderate 

year-round. The topography is low-lying and gentle. These islands are relatively rich in endemic 

vertebrate species, including dusky shrew, long-tailed vole, and ermine. Major coastal seabird 

colonies are present. 

17. Dall Island and 

Vicinity 

These islands are subject to strong oceanic influences. Temperatures are moderate year-around. The 

topography is rugged and dissected, with abundant limestone outcrops. Dall Island appears to be a 

glacial refugia but inventories of plants and animals are limited. Major coastal seabird colonies are 

present on Dall Island. 

18. South Prince of 

Wales Island 

The climate is warm and wet, and deep snow is rare or highly transient. The topography is steep and 

rugged and the coastline is highly dissected. The vegetation in this province is strongly influenced by 

southeasterly storms; mixed conifer and western hemlock-redcedar plant associations dominate. 

19. North Misty 

Fiords 

Compared to South Misty Fiords, this province has considerable topographic relief and characterized 

as having a colder, mainland-type climate with many glaciers. Vegetation occurs in long, narrow strips 

along the valleys and lower slopes of fiords. Much of the vegetation is muskeg, with cottonwoods in 

some of the river bottoms and subalpine fir along the Canadian border. 

20. South Misty 

Fiords 

South Misty Fiords is typical of the other mainland provinces and is the warmest. Topographic relief is 

lower in comparison with North Misty. Forest plant associations are more diverse than the other 

coastal provinces, and the vegetation is less fragmented by rock and ice than in North Misty Fiords. 

The southwestern portion of this province is rolling, nearly continuous muskeg with conifer forests in 

the bottoms and flats. This province is the northern limit of Pacific silver fir, yew, and honeysuckle. 

21. Ice Fields Permanent ice fields, active glaciers (some advancing and some receding), and nunataks (mountain 

peaks between glaciers) dominate this province. 

22. Chilkat River 

Complex 

The Chilkat River Complex lies at the northern end of the Inside Pasage and is outside the Tongass 

Forest boundary. It consists of tall ridge systems, large glacial rivers, and includes glaciers and 

snowfields. Many of the rivers and drainage basins extend across the international boundary into 

Canada. Because of the overlap of coastal and interior floras and faunas, the province contains 

Alaska’s highest vascular plant species richness and the highest mammalian diversity in Southeast 

Alaska (Carstensen et al. 2007). 

23. 

Glacier 

Bay/Fairweather 

Range 

This is the largest province in Southeast Alaska (2.5 million acres) and is located outside the Tongass 

Forest boundary. The vast majority is high mountains and glaciers and the majority is non-vegetated. 

The highest peaks are in the Fairweather Range along the western edge of the province, with Mt. 

Fairweather at over 15,000 feet. A large flat, foreland, the Gustavus Foreland, occurs in the area 

around Gustavus and to the north in the Bartlett River valley. Lowlands are also fairly extensive along 

the Dundee River and other smaller drainages on the southwest side of Glacier Bay. Glacier Bay 

National Park protects virtually the entire province (97 percent), except for about 75,000 acres in the 

vicinity of Gustavus. 
3 Environment and Effects

Biodiversity 3-132 Final EIS

Figure 3.9-1 

Map of Biogeographic Provinces of Southeast Alaska 
Environment and Effects 3 

Final EIS 3-133 Biodiversity 

Figure 3.9-2 

Ecological Sections (numbered areas) and Subsections (dashed lines) of Southeast 

Alaska 
3 Environment and Effects

Biodiversity 3-134 Final EIS

The vegetation of Southeast Alaska and the Tongass National Forest is dominated 

by temperate coastal rain forests at lower elevations (less than about 2,000 feet.). 

Interspersed within the forest are muskegs, other wetlands, and other nonforest 

types. At higher elevations, alpine vegetation, rock, glaciers, and snowfields 

dominate. Figure 3.9.3 displays a general breakdown of the broad cover types on 

the Tongass. Table 3.9-2 provides a summary of this breakdown by biogeographic 

province. 

The Tongass contains approximately 9.9 million acres of forest lands (approximately 

59 percent of the total land area of the Tongass National Forest). These forest 

lands are divided into productive and unproductive forest lands. Productive and 

unproductive forest lands are distinguished in terms of their ability to produce wood. 

The distinction is primarily used in timber management; however, it is useful for 

describing forest cover types for biodiversity and wildlife habitats as well. Productive 

forest land (5.64 million acres of the Tongass) is defined as land capable of 

producing at least 20 cubic feet of wood fiber per acre per year or having greater 

than 8,000 board feet per acre of standing volume. Unproductive forest land (4.22 

million acres of the Tongass) is forest land that does not meet these thresholds. 

Timber harvest occurs only within the productive forest land base. 

Of the 5.64 million acres of productive forest land on the Tongass, 4.95 million acres 

or 88 percent are old growth and are referred to as productive old growth (POG). 

The remaining 0.69 million acres are young-growth forest; about 0.45 million acres 

of the young growth is a result of timber harvest. The remainder of the young 

growth is a result of natural processes (e.g., wind, fire, glacial retreat). 

The remaining 6.91 million acres of the Tongass National Forest (41 percent) is 

classified as non-forest and includes shrub and herbaceous habitats (e.g., muskeg, 

alpine, estuaries), sparsely vegetated and non-vegetated areas (e.g., snow, rock, 

ice), and aquatic habitats (e.g., streams, ponds, and lakes). These general cover 

types are further broken down and discussed in more detail below beginning with 

non-forested habitats and followed by unproductive old-growth and POG cover 

types. 

Figure 3.9-3 

General Cover Types on the Tongass National Forest 

Non-Forest Land 

6,667,142 40%

Productive OldGrowth Forest 

4,951,148 30%

Water 251,059 

1% Unproductive OldGrowth Forest 

4,215,887 25%

Young-Growth 

Forest 688,568 

4%

Cover Types 
 Environment and Effects 3 

Final EIS 3-135 Biodiversity 

Table 3.9-2 

General Cover Types on the Tongass by Biogeographic Province (in thousands of acres)

Forest Lands 

Productive Forest Land Unproductive Forest Land Non-Forest 

Biogeo. 

Province POG 

Young 

Growth1

Total 

Productive 

Forest Land

Forested 

Muskeg 

Other 

Unprod. 

Forest 

Total 

Unprod. 

Forest Land Water 

Total NonForest 

1 47,770 88,844 136,615 30,068 26,297 56,365 99,335 19,632 118,968 

2 23,399 34,554 57,953 3,856 14,875 18,732 822,741 17,423 840,164 

3 395,100 52,788 447,888 64,529 205,804 270,333 319,361 5,877 325,238 

4 72,038 889 72,927 32,300 83,249 115,549 85,698 8,785 94,482 

5 88,311 16,334 104,645 10,670 90,499 101,169 179,273 5,859 185,132 

6 215,021 19,429 234,450 48,782 194,892 243,674 265,738 22,688 288,426 

7 589,823 22,585 612,408 79,852 191,457 271,308 154,516 12,700 167,216 

8 153,160 12,993 166,153 19,707 100,438 120,145 339,303 7,774 347,077 

9 317,677 10,328 328,005 15,718 160,472 176,190 476,234 11,892 488,126 

10 305,846 41,714 347,560 137,220 212,855 350,075 55,250 3,708 58,958 

11 294,075 35,684 329,758 42,158 90,856 133,014 22,204 4,759 26,963 

12 245,701 10,755 256,456 23,464 153,153 176,617 269,774 9,038 278,812 

13 218,715 43,854 262,569 70,258 131,592 201,850 25,302 4,861 30,162 

14 514,269 193,916 708,185 132,501 275,162 407,663 65,171 25,633 90,804 

15 503,091 51,216 554,306 167,122 310,485 477,607 101,272 29,409 130,681 

16 113,451 18,096 131,547 25,607 44,653 70,260 6,564 1,677 8,241 

17 67,987 1,740 69,727 4,979 26,817 31,796 10,996 3,582 14,578 

18 162,097 5,673 167,770 46,126 109,495 155,621 27,991 11,138 39,129 

19 198,559 7,921 206,480 20,210 265,362 285,572 458,110 18,244 476,354 

20 309,900 2,445 312,345 79,770 293,279 373,049 204,634 15,301 219,936 

21 115,160 16,810 131,970 7,277 172,021 179,298 2,677,676 11,079 2,688,754 

Totals 4,951,148 688,568 5,639,716 1,062,173 3,153,714 4,215,887 6,667,142 251,059 6,918,202 1

 Includes 454,724 acres of harvested young growth and 233,843 acres of natural young growth. 

(Source: Tongass National Forest GIS databases) 

Note: Totals may not appear to sum correctly due to rounding. 

Non-Forest Lands 

Non-forest ecosystems provide unique and valuable habitat types that include 

wetland and other areas of shrub and herbaceous types (e.g., muskegs, alpine, 

estuaries), non-vegetated areas (e.g., snow, rock, ice), and aquatic sites (e.g., 

streams, ponds, and lakes). These habitats contribute greatly to the species 

diversity on the Tongass National Forest by providing unique microsites and 

openings that contain shrub and herbaceous vegetation that is often uncommon 

elsewhere. 

Approximately 41 percent of the Tongass is non-forested. Of the non-forest land 

area, over half (55 percent) comprises rock and ice/snow, followed by brush and 

alder brush (20 percent), alpine (8 percent), recurrent slide areas (6 percent), and 

wetland-meadow (4 percent) (Table 3.9-3). Approximately 0.5 million of the 

remaining non-forest acres (7 percent) include small amounts of mass wasting 

areas, uplifted beach, river fill, willow, sand dunes, urban/agriculture, and other 

types. 

Unproductive Forest 

Approximately 25 percent or 4.2 million acres of the Tongass are classified as 

unproductive forest. Approximately 25 percent of this habitat type is forested 
3 Environment and Effects

Biodiversity 3-136 

Table 3.9-3 Non-Forest Cover Types on the Tongass by Biogeographic Province (thousands of acres)

Non-Forest Lands 

No. Biogeographic Unit 

Alder 

Brush Brush Alpine 

Ice & 

Snow 

Field 

MuskegMeadow Rock Recurrent Slide Fresh Water 

1 Yakutat Forelands 4 8 <0.5 <0.5 72 <0.5 <0.5 19 2 Yakutat Uplands 46 419 3 190 2 143 12 17 3 East Chichagof Island 42 <0.5 82 1 43 85 59 6 4 West Chichagof Island 6 <0.5 18 <0.5 13 36 12 7 5 East Baranof Island 5 15 25 16 2 89 25 6 6 West Baranof Island 3 51 54 5 22 103 24 22 

7 Admiralty Island 3 14 37 2 6 28 60 13 

8 Lynn Canal 9 65 45 46 1 140 24 8 

9 North Coast Range 20 124 20 60 4 199 40 11 

10 Kupreanof/Mitkof Island <0.5 3 4 0 40 1 5 3 11 Kuiu Island 1 2 4 <0.5 1 6 4 5 12 Central Coast Range 15 38 23 23 4 125 25 9 

13 Etolin Island 1 2 8 0 2 7 2 3 

14 North Central Prince of Wales <0.5 4 14 <0.5 22 16 6 26 

15 Revilla Isl./Cleveland Pen. 6 12 37 <0.5 10 26 4 29 

16 Southern Outer Islands <0.5 <0.5 3 0 2 1 <0.5 2 17 Dall Island and Vicinity 0 3 3 0 2 3 <0.5 4 18 South Prince of Wales 0 5 2 0 1 15 5 11 

19 North Misty Fiords 23 90 67 41 1 205 23 19 

20 South Misty Fiords 14 57 49 11 1 50 15 15 21 Ice Fields 40 159 42 1,284 1 738 33 11 

Totals 238 1,070 540 1,680 252 2,020 379 245 

1 Other includes small amounts of (in descending order of available acres) Natural Grassland, Mass Wasting areas, Uplifted Beach, Uncensused Freshw

Urban/Agriculture, and Sand Dunes. Source: Tongass National Forest GIS databases
 Environment and Effects 3 

Final EIS 3-137 Biodiversity 

muskeg (Table 3.9-2). Although some of these lands are relatively sparsely 

forested, they have at least 10 percent tree cover. Many unproductive forest stands 

are consistent with old-growth definitions, but the trees are typically small and 

stunted (under 40 feet in height) and the canopy is open (10 to 40 percent canopy 

closure). Hemlock, cedar, and lodgepole pine are the most common trees; 

blueberry and rusty menzesia are the most common shrubs. Near wet bogs or 

muskegs, heath family plants and grasses assume increasing dominance. Timber 

harvest has had little direct effect on unproductive forest. Past disturbance to this 

habitat type has occurred in the primarily as a result of road construction, which has 

resulted in some permanent reduction in total wetland acres. This disturbance is 

discussed further in the Wetlands section. Unproductive forests are also addressed 

in the Old-Growth Forest subsection below. 

Productive Forest 

As noted above, the 5.64 million acres of productive forest land on the Tongass 

consists of both old growth and young growth. Approximately 88 percent of the 

productive forest land consists of old growth and approximately 12 percent is young 

growth, which includes both natural young growth and harvested areas. 

Old-Growth Forest 

POG forests are ecosystems distinguished by old and typically larger diameter 

trees, with most old-growth stands greater than 150 years old. At the landscape 

scale, old-growth forests on the Tongass include heterogeneous stands of 

productive forests within a mosaic of unproductive forests and non-forested areas 

comprised of shrub and herbaceous plant communities. These areas have been 

affected by various levels of natural and human-caused disturbances. 

The biological diversity associated with old-growth forests has long been recognized 

as important within the Tongass National Forest, and the old-growth forest is the 

ecosystem most affected by timber management activities on the Tongass. Franklin 

(1993) estimated that invertebrate biota, creatures essential to ecosystem function 

through such processes as nitrogen fixation and decomposition, may represent 

more than 90 percent of the species diversity of old-growth forests in the Pacific 

Northwest. Because other habitat types (e.g., non-forested habitats) are fully 

represented across the Tongass and have not likely changed appreciably from 

original conditions, the old-growth ecosystem is the primary focus for the analysis of 

biological diversity in this document. 

As described above, old-growth forests are divided into two major categories: POG 

and unproductive old growth. These are further divided on the basis of their 

productivity, defined in terms of their ability to produce a minimum volume of wood. 

The relative productivity of a stand is based on site quality. Site quality is defined as 

the ability of a forest site to grow trees (Carmean 1975), and is based on the 

physiography, climate, soil, and other factors of the environment that are not easily 

altered. Site productivity is the capacity of a tree species to thrive and successfully 

compete on a particular site and is influenced by the physiological makeup of the 

tree species and environmental factors (Pritchett 1979). Productivity measurements 

are most commonly based on site index values. Site index is expressed as the 

height of dominant and co-dominant trees at a given age, normally 50 or 100 years. 

Site index values for Southeast Alaska were determined by Farr (1984) by 

measuring the height and age of sample trees in a stand from standard site index 

curves projecting the height at the index age. 

A higher site quality generally translates into taller trees and higher volume per acre. 

Higher site quality results in faster changes in tree characteristics and stand 
3 Environment and Effects

Biodiversity 3-138 Final EIS

structure. Height to diameter ratios increase faster on high sites and live crown 

ratios will tend to decrease faster due to the affects of heavier stocking. Species 

composition is influenced by site quality. For example, Sitka spruce and western 

hemlock tend to have a greater competitive advantage on the high site quality areas 

while cedars are generally better represented on mid to lower site quality areas. 

Site productivity, a function of site quality, is highly correlated with soil drainage, 

effective soil depth, soil development (parent material), and landscape position 

(landform and slope position) (Cullen 1987). Site variation within stands can be 

significant. Typically, site productivity is highest in the valley bottoms decreasing 

with increased elevation. 

The oldest harvests on the Tongass tended to be on the higher productivity sites at 

lower elevations, adjacent to the beach and within floodplain riparian areas where 

large Sitka spruce were available and abundant. These oldest young-growth stands 

are generally dominated by Sitka spruce and western hemlock regeneration. Road 

construction, started during the pulp mill era, allowed for harvest to be located 

farther away from the beach and riparian areas, although harvest during the early 

years was still concentrated at lower elevations. Old growth on limestone soils 

(which includes karst terrain) was also more heavily targeted. As a result of 

targeting highly productive and economical sites in the early years of timber harvest, 

larger-tree stands were often disproportionately harvested. Due to more extensive 

road development and restrictions brought about by development of a Forest Plan in 

1979, stands harvested in the 1980s and especially in the late 1990s to the present 

tend to be located across a much more diverse range of sites. 

Maintaining a full representation of ecosystem types is an accepted strategy for 

conserving biodiversity in landscapes managed for forestry (Franklin 1993), and is 

part of the overall conservation strategy implemented under the 1997 Forest Plan 

which includes small, medium, and large old-growth reserves and forest-wide 

Standard and Guideline protection measures. Most species, especially those for 

which knowledge is sparse or absent, are best sustained by ensuring that an 

adequate portion of each ecosystem type is represented in a relatively unmanaged 

state (Wells et al. 2003). Some specific types of old-growth forest ecosystems are 

at greater risk than others, such as forests associated with alluvial/colluvial surfaces 

or karst geology (USDA Forest Service 1999a, Baichtal and Swanston 1996). POG 

forest stands, particularly low elevation stands, have been affected the most by 

human modification through timber harvest. 

Young-Growth Forest 

As shown in Figure 3.9-3, there are approximately 689,000 acres of young-growth 

forest on the Tongass. Approximately 455,000 acres of POG have been harvested 

on the Tongass, nearly half of this amount is on land that is currently suitable for 

timber harvest. (See the Timber section for additional discussion on young-growth 

and suitability.) There are opportunities to manage these stands to increase 

biodiversity. Young-growth stands can be treated through release, pre-commercial 

thinning, and commercial thinning to concentrate growth in fewer, larger trees. 

Since 1979, over 100,000 acres have been pre-commercially thinned on the 

Tongass. These treatment methods have averaged about 5,600 acres per year in 

recent years and can be used to extend the period that understory forage is 

available for species such as deer, increase habitat for certain prey species, or 

promote conditions that mimic old-growth stand characteristics at a faster rate than 

would occur without treatment (USDA Forest Service 2000a, Carey 2003). 

Approximately 45 percent of the areas harvested on the Tongass are no longer 

suitable for commercial timber harvest because of their current land use 

designations, which include Wilderness, LUD II, 1,000-foot wide beach fringe, 

riparian areas, and old-growth habitat reserves. While these stands are not 
 Environment and Effects 3 

Final EIS 3-139 Biodiversity 

managed for timber production, they can still be thinned to improve wildlife habitat 

using the same treatments described above. 

Old Growth Classification 

For the 1997 Forest Plan, the Tongass classified POG on the basis of three volume 

strata (low, medium, and high volume). These were refined based on using the 

existing TIMTYP inventory, soils, and slopes. Since the issuance of the 1997 Forest 

Plan, several landscape and timber-sale analyses have effectively used the three 

broad timber-type categories delineating non-forest, unproductive old-growth forest, 

and POG forest lands, which were divided further into high-, medium-, and lowvolume strata forest stands (see the Timber section in this chapter for additional 

discussion on timber volume class and volume strata). 

Size-Density Model 

While the three-volume strata approach for POG is useful for estimating timber 

volume for forest planning purposes, it is not as useful for describing other important 

forest elements, including forest structure, ecosystem diversity, and wildlife habitat. 

Forest structure is defined as the spatial arrangement of the components of 

vegetation, and is a function of tree size and height, vertical stratification into layers, 

and horizontal spacing of trees. It is important because it reflects the complex 

spatial and temporal interactions between plant growth (e.g., dispersal and 

competition), physiographic factors (e.g., geology, soils, slope, aspect, elevation), 

climate, and disturbance (e.g., wind, landslides, and human activities). Areas of 

high-structure habitat are typically located in areas of well-drained soils on 

unconsolidated sediments associated with alluvial fans, floodplains, or toe slopes. 

Differences in forest structure are more useful because timber volume may be 

misleading when describing wildlife habitat or other attributes of the stand. For 

example, two stands may have the same volume but one may be a dense stand of 

medium-sized trees with a single canopy layer while the other stand may be a 

combination of widely-spaced large overstory trees and two or three lower canopy 

layers containing small and medium sized trees (Caouette et al. 2000, Caouette and 

DeGayner 2001). 

To move beyond the limitations of timber volume, Forest Service managers and 

planners have begun to revise and refine forest mapping on the Tongass by creating 

a tree size and density mapping model for POG forests. Such information is more 

applicable for assessing conservation of biodiversity, estimating timber values, and 

developing wildlife habitat models. 

One alternative to using volume estimates is using a combination of two common 

forest measurements: tree sizes and tree densities (Caouette et al. 2000). These 

two measures provide a more comprehensive forest measuring system than timber 

volume (Spies and Franklin 1991, Franklin 1995). The Forest Service recently 

published National Guidance on vegetation classification and mapping that 

specifically requires tree sizes (expressed as quadratic mean diameter of all live 

dominant/co-dominant trees) and tree densities (expressed as canopy closure) for 

the mapping of forest structure (USDA Forest Service 2004d). The Tongass 

National Forest recently developed an approach that uses these two measurements 

to model structural diversity in order to better define and describe forest structural 

attributes (Caouette and DeGayner 2005). The size-density model (SDM) uses a 

combination of two common forest measurements: tree sizes and tree densities 

(Caouette et al. 2000). This model has proven to be the best tool for representing 

these other forest elements. 
3 Environment and Effects

Biodiversity 3-140 Final EIS

SDM uses timber volume class, hydric soil class, and aspect to characterize forest 

structure. These attributes were correlated with the stand density index and mean 

quadratic diameter to derive the various SDM categories. The following seven stand 

types have been defined and delineated using the Tongass Timber Inventory as the 

source for the analysis: 

• SD4H: Volume class 4 on hydric soils 

• SD4N: Volume class 4 on non-hydric soils, north aspect or flat 

• SD4S: Volume class 4 on non-hydric soils, not north aspect or flat 

• SD5H: Volume class 5 on hydric soils 

• SD5N: Volume class 5 on non-hydric soils, north aspect or flat 

• SD5S: Volume class 5 on non-hydric soils, not north aspect or flat 

• SD67: Volume classes 6 and 7 

These categories were used to develop a hierarchical mapping model for predicting 

tree sizes and densities on the Tongass National Forest. Figure 3.9-4 presents a 

description of each of the categories and illustrates the most probable forest type 

based on land form and forest condition. Figure 3.9-5 shows how the above SDM 

categories compare to the low-, medium-, and high-volume strata approach used for 

the 1997 Forest Plan. Based on their analysis, the authors suggest that the model 

is appropriate for use in forest or landscape planning on the Tongass (Caouette and 

DeGayner 2005). For example, the SDM is more useful in its ability to better define 

forest structure, both forest-wide and within stand, than the three-volume strata 

approach. Some components of the SDM have helped identify frequently used 

wildlife habitats in parts of the Tongass National Forest (Doerr et al. 2005, 

DeGayner et al. 2005). Other potential applications may include 1) broad-scale 

forest inventories; 2) stratification for reducing the amount or intensity of projectlevel field inventories; 3) developing forest structure value ranking systems for 

project-level analyses; 4) modeling diversity across landscapes or watersheds; and 

5) setting and implementing conservation targets (DeGayner et al. 2005). 

The disproportionate harvest of the larger POG types is an issue of concern relative 

to forest management on the Tongass. In the analysis that follows, we define the 

larger POG types in two ways. First, large-tree POG is defined as the SD67 POG 

type (Figure 3.9-4). This type represents the most productive of the POG types and 

typically contains the highest density of large trees. The second category is referred 

to as high-volume POG and is defined as the grouping of the three types that 

represent the highest volume stratum -- SD67, SD5N, and SD5s (Figures 3.9-4 and 

3.9-5). This grouping represents the types with the largest trees on the Tongass. 
Environment and Effects 3 

Final EIS 3-141 Biodiversity 

Figure 3.9-4 

Tree Size and Density Model used to Describe Forested Conditions across the Tongass National Forest 

SD Land and Forest Condition 

Most Probable Forest Type 

Tree Sizes and Densities

Most Probable Forest Type 1 Illustration 

Most Probable Forest Type

4H 

Low productive older forests associated 

with wet, poorly drained land types 

(e.g., muskegs, fens, rolling hills, 

broken mountain slopes, plateaus, 

glacial outwash zones). Canopy 

closure is variable. Trees are small, 

old, and defective. Stand volume is 

low. 

Low densities (SDI < 280) of smalldiameter trees (QMD < 17 inches). 

Tree size distribution and spacing is 

variable and patchy. Tree diameters 

greater than 40 inches are generally 

not present. 

4N 

Low to moderately productive older 

upland forests. Canopy characteristics 

are variable and patchy, with moderate 

canopy closure and relatively coarse 

canopy texture. Stand volume is low to 

moderate. 

Low densities (SDI < 280) of medium 

diameter trees (17 < QMD < 21 

inches). Tree size distribution and 

spacing is variable and patchy. Tree 

diameters greater than 40 inches are 

rare.

4S 

Highly productive younger upland 

forests. Stand volume is moderate, but 

increasing rapidly. Crown competition is 

high. Canopy characteristics tend to be 

uniform, with high canopy closure and 

fine canopy texture. 

High densities (SDI > 280) of 

medium-diameter trees (17 < QMD < 

21 inches). Tree size distribution and 

spacing tends to be more uniform. 

Tree diameters greater than 40 

inches are rare. 

5H 

Moderately productive older forests 

associated with wet, poorly drained 

land types (see 4H above). Canopy 

closure, texture, and structure tend to 

be variable and patchy. Stand volume 

and annual growth is also variable and 

patchy. 

Low densities (SDI < 280) of mediumdiameter trees (17 < QMD < 21 

inches). Tree diameters greater than 

40 inches are somewhat common, but 

not uniformly distributed throughout 

the stand. 

5N 

Moderately productive older upland 

forests. Stand volume is moderate to 

high. Canopy characteristics tend to be 

variable, with moderate canopy closure 

and coarse canopy texture. 

Low densities (SDI < 280) of mediumto-large diameter trees (17< QMD < 

21 inches). Tree size distribution and 

spacing is variable and patchy. Tree 

diameters greater than 40 inches are 

common, but not uniformly distributed 

throughout the stand. 

5S 

Highly productive upland forests. 

Stand volume is high. Canopy 

characteristics tend to be uniform, with 

moderate to high canopy closures. 

High densities (SDI > 280) of 

medium-diameter trees (17 < QMD < 

21 inches). Tree size distribution 

and spacing tends to be uniform. 

Tree diameters greater than 40 

inches are somewhat common, but 

not uniformly distributed throughout 

the stand. 

67 

Highly productive forests associated 

with riparian areas, alluvial fans, 

colluvial toe slopes, karst geology, and 

wind-protected uplands. Stand volume 

is high. Stand age can vary. Canopy 

closure is low to moderate and canopy 

texture is coarse. 

Low densities (SDI < 280) of largediameter trees (QMD > 21 inches). 

Tree diameters greater than 40 

inches are common and uniformly 

distributed throughout the stand. 

1

 SDI=Stand Density Index; QMD=Quadratic Mean Diameter; >=greater than; <=less than 

Source: Caouette 2006 
3 Environment and Effects

Biodiversity 3-142 Final EIS

Figure 3.9-5 

Comparison of SDM Categories, the Four Volume Classes from the 1979 

Forest Plan, and the Three Volume Strata Approach Used for the 1997 Forest 

Plan 

Source: Caouette 2006 

Forest-Wide Distribution of Old-Growth Forest 

The distribution and condition of the old-growth ecosystem across the Tongass can 

be examined by comparing the representation of various types of old growth by 

elevation and across the biogeographic provinces and ecological subsections, with 

regard to the original representation. As stated earlier, because other habitat types 

(e.g., non-forested and unproductive forest habitats) are fully represented across the 

Tongass and have not changed appreciably from original levels, the old-growth 

ecosystem is the primary focus for the analysis of biological diversity in this 

document. 

Old Growth Distribution by Elevation 

Elevation is considered one of the most significant landscape variables influencing 

old-growth forest habitat values. Three elevation zones are described in Table 3.9-4 

and the acreages for these components are divided between the productive and 

unproductive old growth. The different elevation zones displayed (less than 800 

feet, 800 to 1,500 feet, and greater than 1,500 feet) are important for many wildlife 

species during certain times of the year. For example, old-growth forest, particularly 

SD5S, SD5N, and SD67, provide suitable winter habitat for Sitka black-tailed deer 

through increased snow-intercept capabilities (see the Wildlife section in this 

chapter for species-specific discussion). 
 Environment and Effects 3 

Final EIS 3-143 Biodiversity 

Table 3.9-4 

Conifer Old-Growth Acres of the Tongass within Three Elevation Zones

Elevation 

Zone Description 

Productive 

Old Growth 

Unproductive 

Old Growth 

Total Old 

Growth 

Less than 800 

feet 

All upland old growth below 800 

feet in elevation 2,961,192 1,812,165 4,773,357 

800 to 1,500 

feet 

All upland old growth between 800 

and 1,500 feet in elevation 1,409,322 1,022,014 2,431,335 

Greater than 

1,500 feet 

All upland old growth more than 

1,500 feet in elevation 580,635 1,381,708 1,962,343 

Total 4,951,148 4,215,887 9,167,035 

POG forest (all SDM categories described in Figure 3.9-4 and outlined in Figure 3.9-

5) found at lower elevations accounts for approximately 60 percent of the old-growth 

forest on the Forest. It should be noted that POG at lower elevations (at or below 

800 feet in elevation) has been harvested disproportionately in some biogeographic 

provinces. Forest-wide, 60 percent of all POG is found at or below 800 feet in 

elevation (Table 3.9-4); however, approximately 80 percent of all old-growth forest 

harvested since 1954 occurred below this elevation zone. 

Old Growth Distribution by Biogeographic Province and SDM Category 

Sixteen of the 21 biogeographic provinces covering the Tongass currently have 

more than 100,000 acres of POG and 11 provinces have more than 200,000 acres. 

Three provinces – Admiralty, North Central Prince of Wales, and Revilla/Cleveland – 

include more than 500,000 acres of POG each. The current POG acreage in each 

SDM category is displayed by biogeographic province in Table 3.9-5. These acres 

by SDM category can serve as a baseline for the amounts of existing structural 

classes at the landscape level. 

The same three provinces that contain more than 500,000 acres of POG, contain 

more than 200,000 acres of high-volume POG, with Admiralty containing over 

300,000 acres. Seven provinces contain more than 100,000 acres of high-volume 

POG and 14 provinces contain more than 50,000 acres. Large-tree POG (SD67), 

however, is not as uniformly distributed. Forty percent of the large-tree POG on the 

Tongass is within two provinces: North Central Prince of Wales and Admiralty. 

Other provinces, in which large-tree POG comprises over 10 percent of the POG 

include Yakutat Forelands, Kuiu Island, Southern Outer Islands, and South Prince of 

Wales. 

Forest-wide, the Tongass consists of 20 percent low-volume, 39 percent mediumvolume, and 41 percent high-volume POG types. The province with the highest 

percentage of low-volume POG (SD4H) is the Kupreanof/Mitkof province, which has 

a high percentage of low-lying wetland areas. Portions of adjacent North Central 

Prince of Wales and Etolin Island and Vicinity provinces also contain large areas of 

the low-volume type. 

Old Growth Distribution by Ecological Subsection and SDM Category 

Examining the distribution of old growth by ecological subsection allows comparison 

at a smaller scale than the biogeographic province scale. The ecological 

subsections better define and describe habitats with similar overall vegetative 

patterns. Table 3.9-6 displays the POG forest acres within each of the 73 ecological 

subsections on the Tongass by SDM category. Ecological subsections vary 

dramatically in their ability to support POG, even within similar landforms, elevation, 
3 Environment and Effects

Biodiversity 3-144 Final EIS

Table 3.9-5 

Distribution of Existing POG Acres by SDM Category across the 21 Biogeographic 

Provinces on the Tongass National Forest

Low 

Biogeographic Volume Medium Volume High Volume 

Province SD4H SD4N SD4S SD5H SD5N SD5S SD67 TOTAL 

1 6,948 2,759 2,610 6,759 2,063 1,501 25,130 47,770 

2 1,829 1,657 8,148 1,054 2,005 6,707 1,999 23,399 

3 83,913 44,368 85,560 31,428 42,357 72,959 34,515 395,100 

4 16,714 11,994 22,963 3,144 5,333 9,878 2,012 72,038 

5 15,270 13,291 25,180 6,157 11,590 14,852 1,970 88,311 

6 45,715 34,958 71,142 10,072 18,262 30,760 4,113 215,021 

7 87,253 55,535 101,188 43,735 67,356 136,494 98,262 589,823 

8 20,710 19,585 43,837 9,102 12,384 35,748 11,796 153,160 

9 43,024 35,686 79,235 27,219 41,582 68,458 22,472 317,677 

10 102,873 25,362 49,867 29,484 27,240 51,465 19,554 305,846 

11 54,018 16,443 32,329 34,529 43,449 76,626 36,682 294,075 

12 44,458 23,603 55,247 18,750 25,559 58,108 19,975 245,701 

13 63,121 20,091 43,580 15,813 23,807 39,915 12,387 218,714 

14 132,698 18,722 47,170 89,807 37,119 70,773 117,979 514,269 

15 109,381 32,378 73,788 74,881 62,216 118,593 31,854 503,090 

16 27,750 6,911 20,161 15,643 13,408 16,767 12,810 113,451 

17 9,324 5,513 15,509 4,616 10,851 14,262 7,911 67,987 

18 31,743 10,788 29,621 13,682 10,819 22,115 43,328 162,097 

19 16,008 34,433 77,411 4,454 18,889 34,597 12,767 198,559 

20 56,978 39,468 102,131 13,814 28,691 54,676 14,142 309,900 

21 8,873 19,348 47,494 2,995 9,720 20,938 5,793 115,160 

Total 978,603 472,889 1,034,172 457,139 514,702 956,193 537,451 4,951,148 

Percent of 

Total POG by 

SDM Category 20% 10% 21% 9% 10% 19% 11% 100% 

 

and soil conditions. For example, the Gulf of Esquibel Till Lowlands and the Rowan 

Sediments vary from 32 percent to 72 percent covered by POG, respectively. 

Sixty of the 73 ecological subsections currently have more than 20,000 acres of 

POG on National Forest System (NFS) land and 65 of the ecological subsections 

have more than 10,000 acres. The 13 subsections that currently have less than 

20,000 acres, also had less than 20,000 acres of POG originally. Similarly, the 8 

subsections with less than 10,000 acres had less than 10,000 acres originally. 

Fifteen ecological subsections currently have more than 100,000 acres of POG and 

only 2 subsections have less than 1,000 acres. The ecological sections containing 

the largest amounts of POG include the Inside Passage Fiordlands (1,208,000 

acres), Kootznoowoo Fiordlands (653,000 acres), Baranof-Chichagof Fiordlands 

(573,000 acres), Kuiu-Prince of Wales Fiordlands (481,000 acres), Kupreanof 

Lowlands (388,000 acres), and the Coast Mountain Batholith Fiordlands (387,000 

acres). 
 Environment and Effects 3 

Final EIS 3-145 Biodiversity 

Table 3.9-6 

Distribution of POG Acres by SDM Category across the 73 Ecological Subsections on the 

Tongass National Forest

Low 

Ecological Section (Bold) and Volume Medium Volume High Volume 

Subsection Names SD4H SD4N SD4S SD5H SD5N SD5S SD67 TOTAL 

St. Elias-Fairweather Mountains 

St. Elias-Fairweather Icefields 299 849 3,453 106 409 1,880 1,530 8,526 

Puget Peninsula Metasediments 359 431 2,894 129 255 2,260 961 7,290 

Northern Gulf Forelands 

Yakutat-Lituya Forelands 8,196 3,305 5,271 7,657 3,755 5,212 25,512 58,908 

Chilkat River Complex 

Chilkat Complex 41 711 574 111 127 197 1,759 

Boundary Ranges 

Boundary Ranges Icefields 18,532 40,237 104,352 5,833 17,555 45,982 11,503 243,994 

Stikine-Taku River Valleys 8,795 4,329 5,562 4,031 4,915 4,085 1,894 33,612 

Glacier Bay Fiordlands 

Wachusett-Adams Hills 183 2 35 9 229 

Berg Bay Complex 1,706 1,882 1,636 5,223 

Chilkat Peninsula Carbonates 12,458 9,562 16,726 5,137 6,884 19,379 7,074 77,221 

Baranof-Chichagof Fiordlands 

North Chichagof Granitics 18,954 12,584 20,940 10,251 11,161 16,339 6,213 96,442 

Outer Coast Wave-cut Terraces 16,503 5,245 7,776 2,537 1,898 3,157 520 37,636 

West Chichagof Complex 3,951 5,839 12,510 605 1,869 3,816 1,297 29,885 

Ushk-Patterson Bay Granitics 8,588 6,115 11,611 1,846 5,139 5,575 3,017 41,891 

Peril Strait Granitics 24,267 12,521 27,806 6,708 6,761 17,857 5,128 101,048 

North Baranof Complex 7,658 8,027 13,811 3,403 8,987 10,237 1,470 53,593 

Sitka Sound Complex 13,253 13,369 24,712 3,409 8,008 10,602 1,153 74,506 

Mount Edgecumbe Volcanics 9,104 2,775 4,777 1,749 1,361 3,464 358 23,587 

Central Baranof Metasediments 5,393 7,007 15,056 1,604 2,553 5,512 638 37,764 

Necker Bay Granitics 4,772 7,287 17,705 808 3,249 5,625 1,121 40,568 

South Baranof Sediments 6,990 5,285 12,303 1,557 3,157 6,326 702 36,320 

Northeast Chichagof Fiordlands 

Point Adolphus Carbonates 5,795 2,371 4,291 5,009 5,878 10,189 8,256 41,789 

Freshwater Bay Carbonates 24,930 10,465 21,713 6,361 9,758 18,152 6,636 98,016 

Kook Lake Carbonates 7,339 5,647 9,308 2,927 7,708 11,250 4,465 48,644 

Kootznoowoo Fiordlands 

Stephens Passage Glaciomarine 

Terraces 29,237 14,792 27,359 11,854 11,620 22,812 11,482 129,157 

North Admiralty Complex 8,185 12,478 25,696 6,213 17,144 35,680 21,370 126,767 

Stephens Passage Volcanics 5,438 4,544 10,810 2,951 4,551 12,531 7,110 47,934 

Thayer Lake Granitics 7,257 3,231 7,099 3,518 4,505 12,624 7,337 45,571 

Mitchell-Hasselborg Till Lowlands 15,796 6,337 9,383 7,803 7,037 10,228 6,028 62,613 

Hood-Gambier Bay Carbonates 17,558 12,920 23,352 7,494 16,977 34,493 30,787 143,582 

South Admiratly Volcanics 14,815 6,746 15,113 7,962 10,769 23,072 19,067 97,544 

Inside Passage Fiordlands 

Holkham Bay Complex 38,205 23,686 56,501 25,641 35,865 60,405 18,060 258,363 

Cape Fanshaw Complex 12,630 1,805 4,206 6,477 3,730 7,298 7,089 43,235 

Thomas Bay Outwash Plains 3,584 796 1,522 621 787 1,089 1,718 10,117 

Wrangell Narrows Metasediments 23,849 14,914 29,699 7,897 17,142 29,659 11,455 134,615 

Eastern Passage Complex 14,925 11,611 23,600 6,583 15,496 31,932 7,555 111,702 

Stikine River Delta 2,047 2,372 4,398 1,558 3,012 4,875 2,554 20,816 
3 Environment and Effects

Biodiversity 3-146 Final EIS

Table 3.9-6 (continued) 

Distribution of POG Acres by SDM Category across the 73 Ecological Subsections on the 

Tongass National Forest

Low 

Ecological Section (Bold) and Volume Medium Volume High Volume 

Subsection Names SD4H SD4N SD4S SD5H SD5N SD5S SD67 TOTAL 

Bell Island Granitics 27,649 14,696 30,882 9,943 14,785 32,133 4,639 134,728 

Stikine Strait Complex 8,059 2,769 6,194 2,055 3,520 5,015 1,180 28,793 

Etolin Granitics 5,354 3,364 7,527 1,411 3,813 7,769 1,229 30,467 

Zimovia Strait Complex 26,709 9,998 17,501 8,214 10,164 15,439 4,831 92,857 

Clarence Strait Volcanics 25,544 5,380 16,072 9,671 7,748 15,987 4,720 85,122 

Ketchikan Mafics/Ultramafics 4,918 1,351 2,966 2,794 2,926 4,060 2,253 21,268 

Vixen Inlet Till Lowlands 5,448 398 510 1,718 466 727 788 10,055 

Traitors Cove Metasediments 25,264 6,307 17,610 21,641 19,070 36,149 13,364 139,405 

Behm Canal Complex 10,428 5,368 8,679 12,918 13,848 29,211 6,328 86,781 

Kuiu-Prince of Wales Fiordlands 

Kuiu-POW Granitics 11,577 7,314 13,410 7,190 10,666 19,532 10,683 80,372 

Rowan Sediments 11,803 2,780 5,736 11,593 14,262 27,328 20,013 93,515 

North POW-Kuiu Carbonates 14,398 2,847 8,219 14,703 9,314 18,754 41,545 109,779 

Alvin Bay Sediments 10,604 2,418 5,212 8,513 10,055 15,997 3,558 56,357 

Affleck Canal Till Lowlands 11,880 1,179 2,311 4,018 2,814 4,062 1,033 27,296 

North POW Complex 11,885 593 1,577 10,837 2,660 5,434 9,704 42,689 

Elevenmile Till Lowlands 5,412 269 872 3,676 525 2,702 1,112 14,567 

Gulf of Esquibel Till Lowlands 5,789 1,115 2,844 2,002 993 1,457 627 14,828 

Klawock Inlet Till Lowlands 144 99 129 151 84 58 665 

Soda Bay Till Lowlands 13,048 2,721 7,560 5,551 3,528 4,912 3,131 40,451 

Kupreanof Lowlands 

Kake Volcanics 16,523 1,316 2,485 6,075 1,775 2,690 2,365 33,229 

Duncan Canal Till Lowlands 32,046 6,065 10,841 7,279 5,722 10,184 3,766 75,903 

Sumner Strait Volcanics 59,191 9,633 21,131 17,840 12,904 25,254 8,863 154,815 

Central POW Till Lowlands 39,785 1,263 2,946 26,001 3,982 6,432 19,322 99,730 

Kasaan Peninsula Volcanics 1,316 358 601 474 544 388 515 4,197 

Skowl Arm Till Lowlands 6,159 2,202 3,392 2,034 1,240 2,022 3,167 20,215 

Outer Islands Fiordlands 

Outer Islands Complex 7,382 384 1,028 6,415 959 1,462 1,383 19,013 

Dall-Outside Complex 19,494 10,250 29,453 8,030 20,460 23,329 13,223 124,239 

Prince of Wales Mountains 

Central POW Volcanics 38,491 7,238 19,645 26,452 15,377 30,390 38,341 175,934 

Hetta Inlet Metasediments 10,731 3,157 10,982 5,710 4,538 9,603 27,293 72,015 

Moira Sound Complex 11,087 3,818 11,548 4,683 4,212 9,652 12,684 57,684 

Dixon Entrance Lowlands 

South POW Granitics 12,121 5,151 10,997 3,837 3,365 5,427 8,211 49,109 

Duke Island Till Lowlands 3,684 389 352 1,740 450 576 114 7,306 

Thorne Arm Granitics 7,810 1,713 4,971 4,334 3,105 3,832 1,271 27,035 

Princess Bay Volcanics 6,658 471 1,982 10,176 1,546 4,520 361 25,715 

Foggy Bay Till Lowlands 10,848 1,259 3,410 2,035 963 1,734 391 20,641 

Boca De Quadra Complex 12,468 8,408 19,394 2,813 5,482 7,277 912 56,754 

Coast Mountain Batholith Fiordlands 

Misty Fiords Granitics 45,483 58,470 141,313 12,490 36,799 70,963 21,632 387,149 

Total 978,603 472,889 1,034,172 457,139 514,702 956,193 537,451 4,951,148 

Percent of Total POG by SDM 

Category 20% 10% 21% 9% 10% 19% 11% 100%
 Environment and Effects 3 

Final EIS 3-147 Biodiversity 

High-volume and large-tree POG occur throughout Southeast Alaska; however, their 

relative abundance varies across ecological subsections. High-volume POG 

represents more than 50 percent of all POG in 12 subsections. It occurs at the 

highest relative abundance in subsections within the Northern Gulf Forelands, KuiuPrince of Wales Fiordlands, and the Prince of Wales Mountains ecological sections. 

Similarly, large-tree POG makes up more than 20 percent of all POG in 9 

subsections. It occurs in the highest relative abundance in the Northern Gulf 

Forelands, Kuiu-Prince of Wales Fiordlands, and the Prince of Wales Mountains 

ecological sections. 

Past Old-Growth Harvest 

Overview of Past Harvest on National Forest System Lands 

Originally, 5.4 million acres of POG occupied the Tongass and 8 percent of this 

POG has been harvested. At least 10 percent harvest has occurred in six 

provinces—East Chichagof Island, East Baranof Island, Kupreanof/Mitkof Islands, 

Etolin Island, North Central Prince of Wales Island, and Southern Outer Islands 

(Table 3.9-7). With 26 percent POG harvest, North Central Prince of Wales has had 

Table 3.9-7 

Total POG, High-Volume POG (SD5S, SD5N, SD67), Large-Tree POG (SD67), and LowElevation High-Volume and Large-Tree POG: Original Acres and Percent Remaining by 

Biogeographic Province on National Forest System Lands

Acres of Original POG1 Percent of Original POG Remaining 

No. Geographic Unit Total POG 

HighVolume 

POG2

HighVolume2

POG 

<800 ft 

SD67 

POG 

SD67 

POG 

<800 ft 

Total 

POG 

HighVol. 

POG2

HighVol.2

POG 

<800 ft 

SD67 

POG 

SD67 

POG 

<800 ft

1 Yakutat Forelands 51,398 31,015 30,799 26,181 26,095 93% 93% 93% 96% 96%

2 Yakutat Uplands 24,811 11,614 11,103 2,408 2,192 94% 92% 92% 83% 81%

3 East Chichagof Island 439,307 178,124 114,262 47,335 36,883 90% 84% 80% 73% 71%

4 West Chichagof Isld 72,038 17,223 13,795 2,012 1,918 100% 100% 100% 100% 100%

5 East Baranof Island 101,840 37,072 29,024 5,894 5,397 87% 77% 74% 33% 34%

6 West Baranof Island 231,999 64,001 49,692 9,036 8,488 93% 83% 80% 46% 44%

 7 Admiralty Island 598,419 307,613 184,803 100,755 68,011 99% 98% 97% 98% 96%

8 Lynn Canal 158,538 63,368 37,892 13,355 9,417 97% 95% 93% 88% 86%

9 North Coast Range 317,898 132,654 65,270 22,536 13,773 100% 100% 100% 100% 100%

10 Kupreanof/Mitkof Isld 341,588 121,135 73,158 29,920 22,505 90% 81% 76% 65% 64%

11 Kuiu Island 322,569 174,993 121,702 44,945 28,952 91% 90% 87% 82% 75%

12 Central Coast Range 252,179 107,789 66,361 21,854 16,777 97% 96% 94% 91% 89%

13 Etolin Island 254,781 99,193 61,367 22,847 15,739 86% 77% 72% 54% 48%

14 North Central POW 698,394 343,711 231,880 171,375 128,734 74% 66% 62% 69% 68%

15 Revilla Isl/Cleveld Pen 548,748 241,884 123,115 45,095 26,869 92% 88% 84% 71% 65%

16 Southern Outer Islds 128,589 52,674 38,826 17,200 12,957 88% 82% 79% 74% 71%

17 Dall Island and Vicin. 68,355 33,260 23,189 8,018 5,937 99% 99% 99% 99% 98%

18 South POW 165,389 78,369 55,383 44,283 34,589 98% 97% 97% 98% 98%

19 North Misty Fiords 199,929 67,130 38,864 13,164 9,693 99% 99% 98% 97% 96%

20 South Misty Fiords 309,900 97,509 61,530 14,142 11,210 100% 100% 100% 100% 100%

21 Ice Fields 119,204 39,039 18,296 6,965 4,764 97% 93% 89% 83% 80%

Forest-wide 5,405,872 2,299,369 1,450,310 669,321 490,903 92% 87% 84% 80% 78% 1 Original POG is defined in this EIS as the POG that existed, outside of towns, prior to all mapped timber harvest. About 300 acres 

were mapped as harvested in the 1700s and 1800s and about 16,000 acres are from the first half of the 1900s. The vast majority

(about 438,000 acres) has occurred since 1950. To estimate original high volume and SD67 POG, an estimate was made of the 

percentage of past harvest in these categories using timber type mapping from the mid-1980s. Based on this analysis, prior harvest on 

NFS lands was estimated to have been 29% SD67 and 64% high volume (see Appendix B). 2 High-volume POG contains the largest tree types (SD5S, SD5N, SD67). 
3 Environment and Effects

Biodiversity 3-148 Final EIS

the highest rate of past harvest. Ten provinces have had less than 5 percent 

harvest and six provinces have had 1 percent or less. Significant among these is 

Admiralty, which had nearly 600,000 acres of original POG and only about 1 percent 

harvest on NFS lands. 

Approximately 454,724 acres of old growth have been harvested on the Tongass 

National Forest, with 96 percent (435,039 acres) having been harvested since 1954, 

when industrial-scale logging began. The two decades with the greatest amount of 

harvest were the 1960s and the 1970s; these two decades account for 50 percent of 

all Tongass old-growth harvest (Table 3.9-8). 

Harvest practices and regulations on the Tongass have varied substantially over the 

years. The amount of harvest is categorized in Table 3.9-9 according to specific 

periods of relatively consistent land management. 

Table 3.9-8 

Past Harvest by Decade on the Tongass National Forest

Decade Harvest Acres Percent of All Harvest 

2000-2006 15,507 3% 

1990-1999 80,846 18% 

1980-1989 87,946 19% 

1970-1979 117,645 26% 

1960-1969 109,544 24% 

1950-1959 26,994 6% 

1940-1949 6,456 1% 

1930-1939 1,502 0% 

1920-1929 5,064 1% 

1910-1919 2,669 1% 

<1910 550 0% 

Total 454,724 100% 

Table 3.9-9 

Past Harvest Relative to Management Practices on the Tongass 

National Forest 

Period 

Harvest 

Acres Period Description 

1997-2006 29,218 Represents the current period under the 1997 Forest 

Plan (as amended); high level of resource protection 

1991-1996 52,266 

TTRA had passed and Forest Plan was under revision; 

proportional harvest for long-term contracts and stream 

buffers required 

1979-1990 115,401 1979 Forest Plan was in effect, but prior to TTRA 

amendment 

1954-1978 237,154 Prior to the first Forest Plan – initial period of industrialscale logging; relatively few restrictions 

1750-1953 20,685 Prior to the first Forest Plan and before industrial-scale 

logging began 

Total 454,724 

In general, the more recent the harvest the more protections were in place. 

Approximately 57 percent of the harvest on the Tongass occurred prior to the 

protections adopted by the first Forest Plan in 1979. Another 25 percent was 

harvested after the first Forest Plan, but before the additional riparian protections 
 Environment and Effects 3 

Final EIS 3-149 Biodiversity 

and proportionality requirements of TTRA (see below). An additional 12 percent of 

the harvest took place after TTRA, but before the current Forest Plan was adopted, 

which implemented extensive harvest restrictions. Thus, only 6 percent of the oldgrowth harvest on the Tongass has taken place under the current Forest Plan, 

which offers the greatest protections. 

Past harvest on the Tongass has disproportionately targeted the larger POG types. 

Early logging in particular, especially prior to the 1990s, extensively harvested the 

larger tree types. These types were not only the highest timber volume types, but 

they also often grew at lower elevations in the easiest areas to access (e.g., valley 

bottoms and lower slopes). When TTRA was passed, the harvest of the largest tree 

categories was limited as a proportion of total harvest. This applied only to the longterm contracts, which were in effect at the time and extended into the late 1990s. 

In this discussion, larger POG types are defined by two categories: 1) large tree 

POG, also referred to as SD67, is the type with the largest average diameter tree 

diameter sizes and 2) high-volume POG, which includes the three largest types 

(SD67, SD5N, and SD5S), and represents the types with the highest average timber 

volume. Both of these categories are of high value for wildlife and aesthetics, but 

the large-tree POG is considered of highest value. 

The proportion of harvest in these larger POG types was estimated based on timber 

type mapping conducted in the mid-1980s. As a result, we estimate that 31 percent 

of all harvest on NFS lands conducted prior to 1992 (when the proportionality 

requirement of TTRA began to be implemented) consisted of large-tree POG and 66 

percent consisted of high-volume POG. From 1992 to the present, these 

percentages dropped to approximately 17 percent for large-tree POG and 52 

percent for high-volume POG. The original composition of POG on the Tongass 

National Forest is estimated to have included 12 percent large-tree POG and 43 

percent high-volume POG. Averaging all past harvest together, the weighted 

average harvest of large-tree and high-volume POG was 29 and 64 percent of the 

harvest. As a result of the cumulative disproportionate harvest on NFS lands over 

the years, the overall proportion of larger tree types on the Tongass have been 

reduced to 11 percent for large-tree POG and 41 percent for high-volume POG. 

The composition of recent past harvest (under the current Forest Plan) by SDM 

category is summarized in the Tongass 2006 Annual Monitoring Report (USDA 

Forest Service 2007h). Of the 17,202 acres harvested during the period, 1998 

through 2003, approximately 14 percent was from the large tree type (SD67) and 48 

percent occurred in high-volume POG (SD5S, SD5N, and SD67), indicating that 

harvest has been slightly disproportionate during this period as well. However, this 

has been a period of relatively poor economics and only a small percentage of the 

total harvest allowed under the Forest Plan has been implemented. 

Table 3.9-7 displays the original amount of POG and the percent remaining in 

different categories by biogeographic province. This table also provides an 

indication of the rate of past harvest for different types. For example, 87 percent of 

the original high-volume POG and 80 percent of the original large-tree POG are 

remaining Forest-wide. As noted above, the larger tree types were targeted for 

logging, especially at lower elevations. As a result, 84 percent of the original highvolume POG and 78 percent of the large-tree POG below 800 feet are remaining 

today. 

Three provinces – East Baranof, Etolin, and North Central Prince of Wales – have 

had more than 20 percent of their high-volume POG harvested. Conversely, 13 

provinces have had 10 percent or less of their high-volume POG harvested. Five 

provinces – East Baranof, West Baranof, Kupreanof/Mitkor, Etolin, North Central 
3 Environment and Effects

Biodiversity 3-150 Final EIS

Prince of Wales have had more than 30 percent of their large-tree POG harvested 

and 9 provinces have had 10 percent or less removed. 

At low to intermediate elevations, the same limestone soils that produce karst 

topography and caves are very productive and produce some of the largest tree 

forests on the Tongass. As a result, POG forests on karst terrain have been 

harvested at a very high rate. Overall, 31 percent of all POG growing on karst soils 

of the Tongass has been harvested (95,000 acres harvested out of 303,000 original 

acres). Approximately 38 percent of the low elevation (less than 800 feet) POG 

growing on karst soils of the Tongass has been harvested (81,000 out of 216,000 

acres). Over half of this harvest has occurred in the North Central Prince of Wales 

province where karst terrain is most well developed. 

Overview of Past Harvest on Non-National Forest System Lands 

Many of the non-NFS lands in Southeast Alaska are also available for timber 

harvest and much harvest has occurred on these lands, which cumulatively affects 

old-growth forest resources (see the Timber section in this chapter). The non-NFS 

landowners include the Alaska native corporations, the State of Alaska, and other 

private landowners and local governments within the Tongass boundary. Areas 

within Southeast Alaska, but outside the Forest boundary are managed by the 

National Park Service (Glacier Bay National Park), the Bureau of Land 

Management, the State of Alaska, and private landowners and local governments. 

The major landowners that harvest timber on non-NFS lands within the Tongass 

boundary are the Alaska native corporations, including Sealaska, the regional 

corporation, and 12 village corporations. Together, the native corporations own and 

manage approximately 579,000 acres within the Tongass boundary (see Table 

3.11-1 in the Lands section). In addition, the State of Alaska owns and manages 

454,000 acres of lands within the Tongass boundary, and an additional 513,000 

acres of lands north and west of Haines in and adjacent to the Haines State Forest. 

A portion of these state lands are managed for timber harvest. Other private 

landowners and local governments own and manage another 227,000 acres of 

lands within the Tongass boundary and a limited acreage outside the boundary; 

some of these acres are managed for timber. 

Past old-growth harvest on non-NFS lands within the Tongass boundary consists of 

approximately 301,000 acres on native corporation lands (some of which is partial 

harvest), 35,000 acres on state lands, and 14,000 acres on other lands. Outside the 

Forest boundary, primarily in the Haines area, an additional 21,000 acres have been 

harvested. Thus, the total non-NFS harvest of old growth within the Tongass Forest 

boundary is approximately 351,000 acres and an estimated total of 371,000 acres 

have been harvested on non-NFS lands throughout Southeast Alaska. 

Intensive harvest on non-NFS lands started later than on NFS lands, beginning in 

earnest in the late 1970s. High rates of harvest began in the early 1980s, peaking in 

the early 1990s, and decreasing to a lower level at present. The decades with the 

highest harvest were the 1980s and 1990s. 

As a result of the timing of past harvest, a large majority (about 94 percent) of the 

second growth on non-NFS lands is less than 25 years old and is currently in the 

stand initiation stage. Only about 6 percent is currently in the early stages of the 

stem exclusion stage. 

The Alaska Forest Resources and Practices Act (FRPA) (Alaska Statute 41.17) 

governs how timber harvesting, reforestation, and timber access can occur on state, 

private, and municipal land. The FRPA was originally adopted in 1978. Major 

revisions were adopted in 1990 to address riparian management on private land and 
 Environment and Effects 3 

Final EIS 3-151 Biodiversity 

other issues. Additional changes to the stream classification system and riparian 

management standards for coastal forests were adopted in 1999. Approximately 48 

percent of the harvest on non-NFS lands in Southeast Alaska occurred prior to the 

major protective revisions to the FRPA in 1990. However, the majority of the 

harvest (52 percent) occurred after the FRPA revisions were adopted. 

Disproportionate past harvest has occurred at a higher rate for large-tree POG and 

at approximately the same rate for high-volume POG on non-NFS lands compared 

with NFS lands. Overall, 37 percent of the non-NFS harvest acres consisted of 

large-tree POG and 62 percent consisted of high-volume POG. As a result of past 

harvest on non-NFS lands within the Forest boundary, the proportion of larger tree 

types has been reduced to 6 percent for large-tree POG and 37 percent for highvolume POG. Counting all non-NFS lands within Southeast Alaska, the 

percentages are 7 percent for large-tree POG and 56 percent for high-volume POG. 

The higher percentages for high-volume POG are because of the prevalence of 

these types and the low rate of harvest in the Glacier Bay and Chilkat River complex 

biogeographic provinces. 

Cumulative Past Harvest 

Overview

Cumulatively, of the 6.13 million acres of POG that originally existed on all lands 

within the Tongass Forest boundary (outside of that occupied by towns), 

approximately 805,000 acres or 13 percent has been harvested. When considering 

all of Southeast Alaska, including Glacier Bay National Park and the lands around 

Haines and Skagway, approximately 826,000 acres, or 13 percent, have been 

harvested out of 6.5 million acres of original POG. Approximately 92 percent of the 

original POG is present on the Tongass and 66 percent is estimated to remain on 

non-NFS lands. The percent of total POG remaining for all of Southeast Alaska is 

estimated to be 87 percent. 

Timber harvest has occurred in a spatially clumped fashion within Southeast Alaska, 

with activity concentrated on islands, such as Prince of Wales, northeast Chichagof, 

northern Kuiu, and Zarembo. Very little activity has occurred on some other islands 

and much of the mainland (e.g., within the 19 designated Wilderness Areas and 

National Monuments and 12 legislated LUD II areas). Table 3.9-10 displays the 

land area, acreage of remaining POG and POG harvested, and percentage of POG 

remaining by land category for all lands in Southeast Alaska by biogeographic 

province. The percentage of the original POG forest no longer in an old-growth 

condition can serve as a general indicator of the potential effect on several 

biodiversity aspects, including structural (within-stand) diversity, connectivity 

(unfragmented, continuous old-growth blocks), and age and species composition 

(including understory species). 

Some harvest has occurred in 20 of the 23 biogeographic provinces in Southeast 

Alaska; however, 13 provinces have over 90 percent of their original POG remaining 

(Table 3.9-10). Over 30,000 acres have been harvested in 6 biogeographic 

provinces (Table 3.9-10); the harvest in these 6 provinces accounts for about 75 

percent of all harvest in Southeast Alaska. Only 2 provinces, North Central Prince 

of Wales and Dall Island and Vicinity, have had 20 percent or more of their original 

POG harvested. 

Disproportionate Past Harvest

Across the Tongass and Southeast Alaska in general, timber harvest has been 

concentrated in the larger tree types and the higher timber volume classes. While 

approximately 87 percent of all POG remains across Southeast Alaska, about 82 
3 Environment and Effects

Biodiversity 3-152 Final EIS

percent of high-volume POG remains unharvested, and about 68 percent of largetree POG remains. To a lesser extent, timber harvest has also been concentrated 

at the lower elevations (e.g., approximately 84 percent of the high-volume, lowelevation old growth remains unharvested on NFS lands compared with 87 percent 

of high-volume POG on NFS lands in general) (Table 3.9-7). 

Large-tree stands found in alluvial river bottoms and karst areas were the target of 

early clearcut logging throughout Southeast Alaska (especially in the 1950s through 

the 1970s); some clearcuts were extensive and in many cases trees were harvested 

to the stream banks. With growing concerns over fisheries protection and 

proportionality, buffer restrictions were instituted in the 1990s. 

As timber harvest moved away from streams and further inland, large-tree karst 

forests began to receive more logging pressure than did the riparian and alluvial fan 

forests due to their excellent drainage and the ease of road-building on these low, 

rolling landscapes (Albert and Schoen 2007, Chapter 2). 

Most harvested POG was high-volume POG and a high proportion of this harvest 

was the largest tree category (SD67). Approximately 10 percent of the remaining 

POG in Southeast Alaska is mapped as the largest tree category (SD67); 42 percent 

of the remaining POG is mapped as high volume. The greatest concentrations of 

POG in the largest tree categories are in the North Central Prince of Wales and the 

Admiralty Island Biogeographic Provinces. These two biogeographic provinces 

account for 40 percent of the remaining large-tree POG inside the Forest boundary 

and 38 percent of the remaining large-tree POG in Southeast Alaska (Tables 3.9-7 

and 3.9-10). These values serve as baselines for comparison with potential 

changes under the alternatives considered in this analysis. 

Albert and Schoen (2007) estimate that, although approximately 10 percent of all 

POG is represented by large-tree forests, it has been harvested at a rate of nearly 

three times its availability on the landscape. Furthermore, harvest of these largetree stands has primarily occurred at low elevations, particularly within valley floor 

(flood plain) areas and on karst lands. Albert and Schoen (2007) estimate that low 

elevation karstland forests make up only 2.7 percent of the region’s POG, but these 

types have also been the focus of timber harvest in Southeast Alaska, accounting 

for approximately 15 percent of all timber harvest in Southeast Alaska (Chapter 2, 

Table 4). 

Harvest of POG growing on karst terrain may be the most disproportionate example 

of the types of past harvest. Karst mapping covers 458,000 acres of the Tongass, 

303,000 acres (66 percent) of which was originally covered by POG. Although 

limited amounts of karst POG occur in almost all provinces of Southeast Alaska, the 

majority is found in five provinces: North Central Prince of Wales, Southern Outer 

Islands, Dall Island and Vicinity, East Chichagof, and Admiralty Island. 

Today, 208,000 acres (69 percent) of the original POG on karst terrain remains. 

Therefore, 31 percent of the original POG on NFS karst terrain has been harvested, 

compared with 8 percent of POG in general. Karst POG at low elevations were 

targeted by early harvest activity at an even higher rate. Of the 216,000 acres of 

karst POG originally found at low elevations (less than 800 feet) on NFS lands, 

81,000 acres or 38 percent have been harvested. 
Environmen

Final EIS 3-153 

1 Includes Annette Island and all of the Ice Fields province, although they are not entirely within the Forest boundary. 

Table 3.9-10 Existing POG, Past Harvest, and Percent of Original POG Remaining for NFS, Non-NFS and All Lands bProvince for Southeast Alaska

Existing POG Part Harvest of POG 

% of Original POG 

Remaining 

% of Original Hig

Volume POG 

Remaining 

No. Biogeographic Unit NFS 

NonNFS All Lands NFS Non- NFS All Lands NFS Non- NFS 

All 

Land

s NFS 

NonNFS 

A

Lan

s 

1 Yakutat Forelands 47,770 41,456 89,226 3,627 13,991 17,618 93% 75% 84% 93% 66% 82 Yakutat Uplands 23,399 0 23,400 1,411 0 1,411 94% -- 94% 92% -- 93 East Chichagof Island 395,100 34,935 430,035 44,208 37,503 81,711 90% 48% 84% 84% 34% 74 West Chichagof Island 72,038 331 72,369 0 0 0 100% 100% 100% 100% 100% 105 East Baranof Island 88,311 1,027 89,338 13,530 2 13,531 87% 100% 87% 77% 99% 76 West Baranof Island 215,021 12,731 227,753 16,978 2,354 19,332 93% 84% 92% 83% 69% 87 Admiralty Island 589,823 7,800 597,623 8,595 20,135 28,730 99% 28% 95% 98% 21% 98 Lynn Canal 153,160 16,254 169,414 5,378 549 5,927 97% 97% 97% 95% 95% 99 North Coast Range 317,677 38,786 356,463 221 20,561 20,782 100% 65% 94% 100% 57% 9

10 Kupreanof/Mitkof Island 305,846 29,258 335,104 35,742 35,026 70,768 90% 46% 83% 81% 28% 711 Kuiu Island 294,075 1,855 295,929 28,494 144 28,639 91% 93% 91% 90% 84% 912 Central Coast Range 245,701 5,258 250,959 6,479 1,433 7,912 97% 79% 97% 96% 69% 913 Etolin Island 218,714 13,390 232,104 36,066 4,476 40,543 86% 75% 85% 77% 61% 714 North Central Prince of Wales 514,268 84,377 598,645 184,125 135,406 319,532 74% 38% 65% 66% 24% 515 Revilla Isl./Cleveland Pen. 503,091 70,123 573,213 45,658 24,906 70,563 92% 74% 89% 88% 62% 816 Southern Outer Islands 113,451 4,887 118,338 15,138 5,827 20,964 88% 46% 85% 82% 33% 717 Dall Island and Vicinity 67,986 31,635 99,621 369 32,916 33,285 99% 49% 75% 99% 33% 618 South Prince of Wales 162,097 11,077 173,174 3,292 14,536 17,828 98% 43% 91% 97% 43% 819 North Misty Fiords 198,559 2,261 200,820 1,370 841 2,211 99% 73% 99% 99% 58% 920 South Misty Fiords 309,900 276 310,176 0 0 0 100% 100% 100% 100% 100% 1021 Ice Fields 115,160 113 115,273 4,044 0 4,044 97% 100% 97% 93% 100% 9

Total within Forest Boundary1 4,951,148 407,829 5,358,976 454,724 350,606 805,331 92% 54% 87% 87% 40% 8

 Chilkat River Complex 0 145,104 145,104 0 20,637 20,637 -- 88% 88% -- 89% 8

Glacier Bay/Fairweather Range 0 170,840 170,840 0 200 200 -- 100% 100% -- 100% 10

Total Southeast Alaska 4,951,148 723,773 5,674,921 454,724 371,443 826,168 92% 66% 87% 87% 64% 8
3 Environment and Effects

Biodiversity 3-154 Final EIS

Although only 26,000 acres of mapped karst POG originally occurred on non-NFS 

lands, harvest rates are higher if non-NFS lands are considered as well. Assuming 

that 50 percent of all non-NFS karst POG and 75 percent of all non-NFS low 

elevation karst POG have been harvested, the overall harvest rate for karst POG in 

Southeast Alaska was estimated at 33 percent overall, and 41 percent for low 

elevation karst. 

Current Conditions by Biogeographic Province 

This section summarizes the affected environment in each biogeographic province, 

with respect to past harvest and other past developments on NFS and non-NFS 

lands. The primary sources for this information include the Tongass GIS layers, GIS 

layers provided by the State of Alaska, GIS layers provided by Sealaska 

Corporation, interpretation of aerial photographs and orthophotography to create 

new GIS layers, GIS layers developed by The Nature Conservancy based on 

satellite imagery (Albert and Schoen 2007), and the State’s FRPA detailed plan of 

operation database of harvest activities on non-NFS lands. A tabular summary of 

past harvest information is presented as a catalogue of past harvest in Appendix E. 

A description of the climate, topography, vegetation, and other factors related to 

biodiversity is provided for the 23 biogeographic provinces in Southeast Alaska in 

Table 3.9-1. In addition, a description of the natural history for 22 biogeographic 

provinces (some of these provinces follow different boundaries) in Southeast Alaska 

is presented by Carstensen et al. (2007). Some of the key relevant information from 

both of these sources is also summarized here. 

In addition, these sections summarize the effects of past harvest on the biodiversity 

and old-growth habitats of Southeast Alaska. The effects of past harvest are 

differentially discussed for NFS and non-NFS lands, as well as cumulatively. A 

similar analysis of the current condition of old-growth integrity and biodiversity within 

the biogeographic provinces of Southeast Alaska is presented by Carstensen et al. 

(2007). 

Yakutat Forelands

The Yakutat Forelands biogeographic province is a very young and nearly flat 

landscape at the northern end of Southeast Alaska that supports a complex mosaic 

of forest and wetlands. Approximately 65 percent of the province is in 

congressionally protected land designations (mostly in the Yakutat Forelands LUD II 

and Glacier Bay National Park). Private and State of Alaska lands comprise about 5 

percent of the province and consist primarily of Yak-Tat Kwaan Village Corporation 

lands (4 percent of the province). State of Alaska lands also comprise a significant 

percentage (1 percent of the province). 

A relatively low percentage of NFS POG has been harvested (about 4,000 acres). 

As a result, approximately 93 percent of the original POG on NFS land remains 

today. The native corporation and state lands in the province (mostly near Yakutat), 

have experienced relatively high harvest (about 14,000 acres); however, essentially 

no harvest has occurred in Glacier Bay National Park within the province. As a 

result, about 75 percent of the original POG remains on non-NFS lands. Most of the 

harvest took place in the mid-1980s or earlier, so the young growth that resulted is 

primarily at the end of the stand initiation stage or the beginning of the stem 

exclusion stage (Appendix E). Overall, 84 percent of the original POG on all lands 

within the province remains today. Harvest of larger tree types has occurred at a 

rate slightly higher than the overall rate and it is estimated that the percentage of 

high-volume and large-tree POG remaining today is 81 percent for both categories. 
 Environment and Effects 3 

Final EIS 3-155 Biodiversity 

One very large block of large-tree POG exists in the upper Situk River and adjacent 

small watersheds, near the northeastern edge of the province. As a result of this 

large block and other patches, 51 percent of the existing POG in the province is 

mapped as high volume and 29 percent is mapped as large-tree POG. These 

percentages are among the highest of the provinces in Southeast Alaska, although 

the province includes only 89,000 acres of existing POG. However, this province is 

prone to extensive windthrow events, and the extensive large-tree POG in this area 

is susceptible to blowdown as well as future harvesting. 

Past harvest has not significantly affected the biodiversity of the province or the 

integrity of the old-growth ecosystem, except on native corporation lands in a 

relatively confined area east of Yakutat where extensive harvest has taken place. 

Although POG has been locally harvested intensively, the overharvest of large-tree 

or high-volume POG has not been a significant factor in this province. Past 

blowdown events have also reduced the extent of old growth within the province. 

However, because the landscape of the Yakutat Forelands is so geologically young, 

this natural reduction of old growth by wind is compensated somewhat, by the 

natural succession of large acreages of younger forest that have colonized fresh 

substrates. 

Yakutat Uplands

This rugged and mountainous province includes extensive active glaciers, fiords, 

and mountains rising from sea level to more than 10,000 feet. Approximately 38 

percent of the province is in congressionally protected land designations (primarily 

the Russell Fiord Wilderness). Aside from a few acres of private lands (less than 

0.1 percent), the province is virtually 100 percent within the Tongass National 

Forest. 

Slightly over 1,000 of the 25,000 original acres of POG in the province have been 

harvested; therefore, 94 percent of the original POG remains today. Harvest of 

larger tree types has occurred at a higher rate so it is estimated that the percentage 

of high-volume and large-tree POG remaining today is 92 and 83 percent, 

respectively. 

High-volume POG makes up almost half of the POG in the province (46 percent). 

However, large-tree POG comprises only 9 percent because of the lack of highly 

productive sites. The province contains only about 23,000 acres of existing POG. 

Portions of the province are prone to extensive windthrow events, as is the case for 

the Yakutat Forelands province. 

Because past harvest has been so low in this province, little effect on the 

biodiversity or old-growth ecosystem integrity of the province has occurred. As is 

the case for the Yakutat Forelands province, wind may play the role of diminishing 

existing old growth, while primary succession of natural young-growth forests will 

contribute to the extent of POG over time. 

East Chichagof Island

This rugged province is characterized by steep, U-shaped valleys and rounded 

mountains and is deeply dissected into three peninsulas. Karst terrain occupies 

high elevations and steep sideslopes, mostly above the POG, but the U-shaped 

valleys contain a substantial amount of valley floor POG, including large-tree types. 

Approximately 31 percent of the province is in congressionally protected land 

designations (25 percent in four LUD II areas and 6 percent in the West ChichagofYakobi Wilderness). Non-NFS lands comprise about 8 percent of the province, and 

consist primarily of Sealaska lands (5 percent of the province) and Huna Totem 
3 Environment and Effects

Biodiversity 3-156 Final EIS

Village Corporation lands (2 percent of the province). It includes the town of 

Hoonah and several smaller settlements including Tenakee Springs and Pelican. 

Approximately 10 percent of the original POG on NFS lands has been harvested 

(about 44,000 acres). Most of this harvest took place in the 1970s, 1980s, and 

1990s (Appendix E). On native corporation lands and other non-NFS lands in the 

province, approximately 38,000 additional acres or 52 percent have been harvested, 

primarily in the past 25 years. As a result, about 90 percent of the original POG on 

NFS lands, about 48 percent of the original POG on non-NFS lands, and about 84 

percent of the original POG on all lands remains today. The vast majority of all 

harvest has taken place within the last 25 years and, therefore, the resulting young 

growth is in the stand initiation stage of succession. Harvest of the larger tree types 

(especially large-tree POG) occurred at a high rate relative to other POG types in 

this province, and it is estimated that 76 percent of the high-volume types and 58 

percent of the large-tree types remain today. 

Most high-volume and large-tree POG occurred along the shoreline and within 

valley bottoms in the province, and this POG was targeted by past harvest. 

Although only about 16 percent of all POG has been harvested in the province, 

approximately 42 percent of all large-tree POG and 24 percent of all high-volume 

POG has been harvested. This province also originally contained about 46,000 

acres of POG on karst terrain. About 17 percent of this karst POG has been 

harvested. 

Past harvest has had a substantial effect on old-growth ecosystems in some 

watersheds of this province. This has occurred in many of the watersheds on NFS 

lands of northeast and southeast Chichagof, and on native corporation lands to the 

south, southeast, and west of Hoonah. As noted above, overharvest of high-volume 

POG, and especially large-tree POG, has occurred and floodplain/valley bottom 

large-tree POG was targeted in the past in many of these watersheds. Because of 

the rugged topography of this province, the largest tree forests and the easiest 

access for logging were concentrated in these valley bottom areas. The rate of 

disproportionate harvest on NFS lands was substantially reduced with the passage 

of the Tongass Timber Reform Act in 1990 (which had a proportionality requirement 

for high vs. low volume Forest-wide) and with the adoption of the 1997 Forest Plan, 

which incorporates large portions of the floodplain areas on Chichagof Island within 

riparian buffers; however, most past harvest was conducted prior to the 1990s 

(Appendix E). 

One area of particular concern is the narrow neck of land that connects northeast 

Chichagof to the main body of the island. This “pinch-point” or “bottleneck” may 

constrain wildlife movements and genetic interchange for other plants and animals 

because of the relatively narrow corridors of habitat between saltwater areas. This 

area has experienced some past harvest and could be significantly affected if 

substantial future harvest in this area were to occur. A second area of concern is 

the pinch-point connecting Lisianski Inlet with the North Arm of Peril Strait in the 

western portion of the province. However, this area lies completely within 

congressionally protected land designations. See the Wildlife section for a 

description of pinch-points and an analysis of the effects of additional development 

in these areas on wildlife movements. 

West Chichagof Island

This province has a very wet climate and is exposed to outer coastal storms. It has 

a highly irregular shoreline with hundreds of small islands. Topography is gentler 

than the mountains of Baranof Island. Approximately 87 percent of the province is 

within congressionally protected land designations, mostly within the West 
 Environment and Effects 3 

Final EIS 3-157 Biodiversity 

Chichagof – Yakobi Wilderness. Non-NFS lands comprise less than 0.5 percent of 

the province. 

As a result of the high proportion of congressionally protected areas and the 

relatively low productivity of the province, no known harvest has taken place, either 

on NFS lands or on non-NFS lands. Therefore, the original percentage of highvolume and large-tree POG remain today. Approximately 24 percent of the POG in 

the province is high volume and 3 percent is large-tree POG. The province includes 

about 72,000 total acres of POG. 

East Baranof Island

The East Baranof Island province is rugged and steep to saltwater, with relatively 

few flat lands. It includes among the highest and most rugged topography found on 

the islands of Southeast Alaska. Approximately 23 percent of its land area lies 

within the South Baranof Wilderness. Less than 1 percent of the province is 

comprised of non-NFS lands (the majority of which is state-owned). 

Approximately 13 percent of the original POG on all lands has been harvested 

(about 14,000 acres), resulting in 87 percent of the original POG remaining. The 

majority of the harvest in this province was conducted in the 1960s (Appendix E), 

when relatively few restrictions on harvesting were in place. About 77 percent of the 

original high-volume POG and about 33 percent of the original large-tree POG 

remains today, indicating a high disproportionate harvest, particularly of large-tree 

POG. 

The remaining large-tree POG is relatively scattered in small patches, often 

occurring in valley bottoms. However, high-volume POG occurs in many areas and 

along shorelines and within river valleys. 

As is the case for East Chichagof, past harvest in the East Baranof Island province 

has had a substantial effect on old-growth ecosystems of several watersheds in the 

northern portion of the province. As noted for East Chichagof, overharvest of highvolume POG, and especially large-tree POG, occurred in floodplain/valley bottom 

areas, which were targeted because of the presence of large trees and the rugged 

topography elsewhere. Also as noted for East Chichagof, the rate of 

disproportionate harvest on NFS lands was substantially reduced with the passage 

of the Tongass Timber Reform Act in 1990, and with the adoption of the 1997 Forest 

Plan; however, most past harvest was conducted prior to the 1990s (Appendix E). 

West Baranof Island

This province is similar to the West Chichagof Island Province with the exception of 

southern Baranof, which has exceptionally high precipitation. Baranof Island is the 

most rugged of all the islands in Southeast Alaska. Approximately 31 percent of the 

province is protected within the South Baranof Wilderness or the Enacted Municipal 

Watershed of Sitka. Non-NFS lands comprise about 4 percent of the province and 

consist of lands owned by the city and borough of Sitka, the State of Alaska, Shee 

Atika Village Corporation, and a variety of other private owners. 

Approximately 7 percent of the original POG on NFS lands has been harvested 

(about 17,000 acres). On the State of Alaska and other non-NFS lands, 16 percent 

(2,000 acres) has been harvested. Overall, this results in 92 percent of the original 

POG on all lands remaining today. The vast majority of these acres were harvested 

30 to 40 years ago and they are now in the stem exclusion stage of succession 

(Appendix E). High-volume POG was harvested at a rate higher than the overall 

harvest rate; 82 percent of all high-volume POG remains. Large-tree POG has been 

harvested at a much higher rate; an estimated 44 percent of all large-tree POG 

remains today. 
3 Environment and Effects

Biodiversity 3-158 Final EIS

Most remaining high-volume and large-tree POG is distributed along the shoreline 

and in river valleys. On all land ownerships combined, 25 percent of all POG is high 

volume, but only 2 percent is large-tree POG. 

Although the overall rate of past harvest within the province is relatively low, the rate 

for the northern portion of the province is relatively high and the effects of past 

harvest on some watersheds in this area has also been relatively high. As noted for 

East Chichagof and East Baranof, overharvest of large-tree POG has occurred in 

floodplain/valley bottom areas, which were targeted because of the presence of 

large trees and the rugged topography elsewhere. As a result, less than half of the 

original large-tree POG in the province remains today. 

Admiralty Island

The Admiralty Island Province has relatively gentle topography and moderate 

rainfall. Forest productivity is high. Approximately 90 percent of the province is 

protected within the Admiralty National Monument (Kootznoowoo Wilderness). NonNFS lands in the province represent 4 percent of the land area and primarily consist 

of Shee Atika Village Corporation lands near Cube Cove, as well as lesser amounts 

of Sealaska Regional Corporation and State of Alaska lands and other ownerships. 

The village of Angoon occurs on the west side of the island and the Greens Creek 

mine at the north end of the island. The Greens Creek mine is the largest operating 

mine on the Tongass; however, it only occupies about 320 acres for facility 

development (see Minerals section). 

Admiralty Island province ranks second in POG acreage relative to all other 

provinces in Southeast Alaska (598,000 acres). Before commercial timber harvest 

was initiated, it ranked third in POG acreage. Although 99 percent of the original 

POG on NFS lands remains today, about 72 percent (20,000 acres) of the POG on 

non-NFS lands has been harvested and only 28 percent is remaining. Because of 

the dominance of NFS lands in the province, 95 percent of the original POG remains 

on all lands combined. High-volume and large-tree POG have been harvested at a 

rate slightly higher than the overall POG harvest rate; 94 percent of all high-volume 

POG and 91 percent of all large-tree POG remain today. 

High-volume and large-tree POG are abundant throughout the province. On all 

lands combined, approximately 51 percent of POG is high volume and 17 percent 

consists of large-tree POG. This province also originally contained about 38,000 

acres of POG on karst terrain. Only about 3 percent of this karst POG has been 

harvested. 

Although most of the province has experienced little to no past harvest, the area on 

native corporation lands near Cube Cove in the northwest portion of the province 

has been extensively harvested. Because the majority of all POG in three major 

adjacent drainages and adjacent areas near Cube Cove has been harvested, 

effects on the biodiversity and old-growth integrity in this local area have been 

substantial. However, the vast majority of Admiralty Island remains intact and, as a 

result of the abundance of POG in this province, including high-volume and largetree POG, it represents a massive reserve and reservoir for biological diversity in 

Southeast Alaska. 

Lynn Canal

The Lynn Canal province is characterized by rugged and glaciated topography and 

relatively low precipitation. The southern portion of the Chilkat Peninsula is more 

similar to the East Chichagof Island Province than to the rest of the province. 

Approximately 22 percent of the province is included within congressionally 

protected land designations (15 percent wilderness and 6 percent LUD II). Non-
 Environment and Effects 3 

Final EIS 3-159 Biodiversity 

NFS lands comprise about 4 percent of the province; the State of Alaska manages 

the majority of this land. The cities of Juneau and Douglas occur on the east side of 

Lynn Canal within the province. 

Approximately 169,000 acres of POG currently exists in the province and 6,000 

acres have been harvested. As a result, approximately 97 percent of the original 

POG remains today. High-volume POG and large-tree POG have both been 

harvested at a higher rate than other POG; 95 percent of high-volume POG 

remains, but only 88 percent of large-tree POG remains today. 

The overall effects of past harvest on the biodiversity and old-growth ecosystem 

integrity within the province have been relatively low, because of the relatively low 

harvest rates. However, localized pockets of high harvest have occurred on the 

west side of Lynn Canal. 

Northern Coast Range

The Northern Coast Range covers the rugged and glaciated coastal mountains of 

the northern mainland. It is characterized by deep fiords, tidewater glaciers, and 

active glacial rivers, including the Taku and Whiting Rivers, which extend into 

Canada. It also includes some less rugged topography on Douglas Island, Cape 

Fanshaw, and other locations. Approximately 23 percent of the province is in a 

congressionally protected land designation (wilderness) and an additional 1 percent 

is in a research natural area. Approximately 10 percent of the province (103,000 

acres) is non-NFS lands, with the largest landowners being Goldbelt Village 

Corporation (35,000 acres), the State of Alaska (19,000 acres), and the city and 

borough of Juneau (19,000 acres) 

Approximately 356,000 acres of POG currently exists in the province and about 

21,000 acres have been harvested. Overall, 94 percent of the POG, 77 percent of 

the large-tree POG, and 92 percent of the high-volume POG remains today. 

However, almost all of the past harvest in the province is from non-NFS lands 

owned by Goldbelt in the vicinity of Hobart Bay. As a result, 65 percent of all POG 

on non-NFS lands remains and only 33 percent and 57 percent of the large-tree and 

high-volume POG types remains today on these lands, respectively. 

On all lands combined, 7 percent of all POG is large-tree POG and 42 percent is 

high volume. Remaining larger tree types are well distributed at lower elevations 

throughout the province, except in the vicinity of Hobart Bay. 

Although only about 6 percent of the original POG in the province has been 

harvested, as noted above, it is concentrated in the vicinity of Hobart Bay. 

Approximately two-thirds of the POG and a higher percentage of the larger tree 

types have been removed in this area on non-NFS lands. Thus, the effects of past 

harvest in the watersheds of this area have been relatively high. 

Kupreanof/Mitkof Island

This province covers Kupreanof and Mitkof Islands in the center of Southeast Alaska 

and represents the province with the greatest extent of low-lying, muskeg wetlands. 

Because of the less rugged relief in the province, it is not as topographically 

fragmented as most other provinces; however, natural fragmentation of old growth 

does occur, due to the extensive wetlands. Approximately 6 percent of the lands of 

the Kupreanof/Mitkof Island province are in congressionally protected land 

designations; this is one of the lowest percentages in Southeast Alaska. Another 1 

percent is protected in municipal watershed status. Non-NFS lands cover 90,000 

acres, or 11 percent of the province. The State of Alaska is the largest individual 

landowner (31,000 acres), followed by Sealaska Regional Corporation (27,000 
3 Environment and Effects

Biodiversity 3-160 Final EIS

acres) and Kake Village Corporation (24,000 acres). Petersburg, Kake, and a few 

smaller settlements occur within this province. 

POG currently exists on 335,000 acres and there has been about 71,000 acres of 

harvest in the province. Overall, 83 percent of the original POG remains today; 

however, 90 percent of NFS POG and 46 percent of non-NFS POG remains. 

Disproportionate harvest of larger tree types has occurred on NFS lands; about 65 

percent of the original large-tree POG and 81 percent of the original high-volume 

POG remains. Disproportionate harvest has occurred even more intensively on 

non-NFS lands; only 8 percent of the original large-tree POG and 28 percent of the 

original high-volume POG remains. As a result of past disproportionate harvest and 

the relatively low original proportion of larger tree types in this province, large-tree 

POG and high-volume POG make up only about 6 percent and 32 percent of 

existing POG, respectively. 

Harvest has occurred in many areas throughout the province and the remaining 

POG is also distributed throughout. However, the northwest corner of Kupreanof 

Island, near Kake, has been the most extensively harvested. The heavy POG 

harvest, especially of the larger tree types, has likely negatively affected biodiversity 

in this area. 

One area of particular concern in this province is the narrow area between 

Lindenburg Peninsula and the remainder of Kupreanof Island. This pinch-point may 

constrain wildlife movements and genetic interchange for other plants and animals 

because of the relatively narrow corridors of habitat between saltwater areas. 

These areas have experienced some past harvest and could be significantly 

affected if substantial future harvest were to occur in this area. However, this area 

is largely protected by the Petersburg Creek-Duncan Salt Chuck Wilderness. See 

the Wildlife section for a description of pinch-points and an analysis of the effects of 

additional development in these areas on wildlife movements. 

Kuiu Island

The Kuiu Island province has gentle topography relative to adjacent Baranof Island 

or the mainland. Kuiu Island is deeply dissected, creating several prominent 

peninsulas and obstacles to wildlife movements. Approximately 27 percent of the 

province is in congressionally protected land designations (mostly wilderness). The 

province is 99 percent NFS lands; only a few thousand acres are owned by others. 

Approximately 296,000 acres of POG, containing about 12 percent large-tree POG 

and 53 percent high-volume POG, remains in the province. This compares with an 

estimated 325,000 original acres of POG, containing about 14 percent large-tree 

POG and 54 percent high-volume POG, indicating a slightly higher rate of past 

harvest of the larger tree types for all lands combined. Overall, 91 percent of all 

POG, 90 percent of high-volume POG, and 82 percent of large-tree POG remains 

today. 

Most past harvest occurred in this province during the 1970s and 1980s 

(Appendix E). Although logging has occurred in many portions of the province, the 

southern two-thirds of the province has experienced relatively low rates of harvest. 

In contrast, the northern one-third of the island has undergone fairly extensive 

harvest, which began relatively intensively in the late 1960s. Because much of this 

logging occurred in the early years, prior to the implementation of many Forest Plan 

protections, some fairly extensive tracts are now in the stem exclusion stage of 

succession. Some of these watersheds with extensive early harvest have 

experienced relatively high old-growth fragmentation and effects on biodiversity. 

One area of particular concern in this province is the narrow neck of land between 

the Bay of Pillars and Port Camden and the portage between Port Camden and 
 Environment and Effects 3 

Final EIS 3-161 Biodiversity 

Threemile Arm, which connect the northern and eastern parts of the island to the 

rest of Kuiu Island. These pinch-points may constrain wildlife movements and 

genetic interchange for other plants and animals because of the relatively narrow 

corridors of habitat between saltwater areas. These areas have experienced some 

past harvest and could be significantly affected by substantial future harvest, if it 

were to occur. See the Wildlife section for a description of pinch-points and an 

analysis of the effects of additional development in these areas on wildlife 

movements. 

Central Coast Range

The Central Coast Range covers the rugged and glaciated coastal mountains of the 

central mainland. It is similar to the Northern Coast Range, although it is less 

precipitous and warmer. The Stikine River system traverses the center of this 

province and has a major continental influence on it. Approximately 37 percent of 

the province is protected within the large Stikine-LeConte Wilderness. NFS lands 

comprise 97 percent of the province, State of Alaska lands cover 2 percent, and 

there are no other landowners with more than a few hundred acres. 

POG currently exists on 251,000 acres and there has been about 8,000 acres of 

past harvest. Overall, 97 percent of the original POG remains today. 

Disproportionate harvest of larger tree types has occurred to some degree; about 95 

percent of high-volume POG and 89 percent of large-tree POG remains today. 

High-volume and large-tree POG represent about 42 percent and 8 percent of the 

remaining POG, respectively. 

The majority of the watersheds in the province have experienced no past harvest to 

very minor effects from past timber harvest. Exceptions are watersheds in the 

Thomas Bay area and the Bradfield River drainage. Relatively high rates of past 

harvest, including large-tree harvest, have had some negative effects on old-growth 

integrity and biodiversity in these watersheds. 

Etolin Island and Vicinity

The Etolin Island and Vicinity province includes Etolin, Wrangell, Zarembo, and 

smaller islands. It is similar to the Kupreanof/Mitkof province and is subject to 

continental influence from the mainland and the Stikine River. Congressionally 

protected land designations (South Etolin Wilderness) cover 16 percent of the 

province and 95 percent of the province is under national forest management. The 

State of Alaska manages almost 5 percent of the province and the city of Wrangell 

owns almost 1 percent. 

Approximately 232,000 acres of POG, containing about 35 percent high-volume 

POG and 6 percent large-tree POG, remains in the province. This compares with 

an estimated 273,000 original acres of POG, containing 39 percent high-volume 

POG and 9 percent large-tree POG, indicating a higher rate of past harvest of the 

larger tree types. Overall, 85 percent of all POG, 76 percent of high-volume POG, 

and 51 percent of large-tree POG remains today. Although disproportionate harvest 

has occurred on all ownerships, non-NFS lands have had the highest rate of 

disproportionate harvest; the 4,000 acres of past harvest on non-NFS lands included 

39 percent of the high-volume and 80 percent of the large-tee POG. 

Most harvest in this province occurred in the 1970s and 1980s (Appendix E). 

Harvest has occurred throughout the province, but especially on northern Etolin and 

Zarembo Islands, central Wrangell Island, and many of the smaller islands in the 

province. Watersheds containing the highest rates of past harvest include those on 

northwest Zarembo Island and the majority of Vank and Sokolof Islands. Past 
3 Environment and Effects

Biodiversity 3-162 Final EIS

harvest in these areas and on some state lands has had negative effects on local 

biodiversity. 

North Central Prince of Wales Island

The North Central Prince of Wales Island province covers the northern and central 

portions of Prince of Wales Island and some adjacent islands. It has relatively 

gentle topography and extensive areas of karst and limestone soils. Approximately 

8 percent of the province is protected in congressional land designations 

(wilderness and LUD II) and approximately 79 percent of the province is under 

national forest management. Other major landowners include: Sealaska Regional 

Corporation (11 percent), State of Alaska (5 percent), Kavilco Village Corporation (2 

percent), Klawock-Heenya Village Corporation (2 percent); Shan-Seet Village 

Corporation (1 percent); and Haida Village Corporation (1 percent). A number of 

small towns and settlements occur within the province including Craig, Klawock, 

Thorne Bay, Hydaburg, Coffman Cove, Hollis, and others. 

The North Central Prince of Wales Island province originally contained more POG 

than any other province in Southeast Alaska and, after half a century of commercial 

timber harvest, it still does. The province currently contains 599,000 acres of POG; 

about 320,000 acres or 35 percent of the original POG have been harvested. 

Approximately 74 percent of the original POG remains on NFS lands and 38 percent 

remains on non-NFS lands. For high-volume POG, an estimated 66 percent 

remains on NFS lands and 24 percent remains on non-NFS lands. Similarly, for 

large-tree POG, an estimated 69 percent remains on NFS lands and only 12 percent 

remains on non-NFS lands. 

Almost all of the past harvest on NFS lands took place in the 1960s through the 

1990s, with the majority occurring in the 1960s and 1970s. On non-NFS lands, 

most of the harvest took place in the 1980s and 1990s, with substantial acreage 

harvested in the current decade as well (Appendix E). Therefore, a mixture of age 

groups occurs and the young growth in this province is split between the stand 

initiation and stem exclusion stages of plant succession. 

This province originally contained about 152,000 acres of karst POG, or almost half 

of the karst POG within the Forest boundary in Southeast Alaska. About 72,000 

acres, or 47 percent, has been harvested. This percentage climbs to about 52 

percent if only karst POG at low elevations (less than 800 feet) is considered. 

On NFS lands, 44 percent of the existing POG is high volume and 23 percent is 

large tree POG. On non-NFS lands, 31 percent of existing POG is high volume and 

8 percent is large tree POG. Overall, 42 percent of the remaining POG on all lands 

is high volume and 20 percent is large tree POG. Because of its abundance, POG 

is still well distributed within the province; however, there are many areas of past 

intensive harvest where negative effects on biodiversity have likely occurred. These 

areas include parts of northern Prince of Wales Island; the Staney Creek, Thorne 

Bay, Big Salt, Craig/Klawock, and Hollis areas of central Prince of Wales Island; and 

much of Kosciusko and Tuxekan Islands. 

One area of particular concern in this province is the Neck Lake area, which is a 

relatively narrow piece of land between Whale Passage and El Capitan Passage 

connecting the extreme northern Prince of Wales to the remainder of the island. 

This pinch-point could constrain wildlife movements and genetic interchange for 

other plants and animals because of the relatively narrow corridors of habitat 

between saltwater areas. In addition, this area has experienced relatively high past 

harvest and could be significantly affected by substantial future harvest, if it were to 

occur. See the Wildlife section for a description of pinch-points and an analysis of 

the effects of additional development in these areas on wildlife movements. 
 Environment and Effects 3 

Final EIS 3-163 Biodiversity 

In addition, Sulzer Portage, a relatively narrow neck of land on Prince of Wales 

Island connecting West Arm Cholmondeley Sound and Portage Bay at the head of 

Hetta Inlet. It joins the North Central Prince of Wales and the South Prince of Wales 

Island provinces and has had considerable past timber harvest. Due to recent land 

selections, the immediate portage is entirely on non-NFS lands. Substantial future 

harvest, if it were to occur, could substantially affect ecological connectivity. See the 

Wildlife section for a description of pinch-points and an analysis of the effects of 

additional development in these areas on wildlife movements. 

Revilla Island/Cleveland Peninsula

This province includes Revillagedo (Revilla), Gravina, Annette, Duke, and smaller 

islands, as well as the Cleveland Peninsula portion of the mainland. Approximately 

23 percent of the province is in congressionally protected land designations 

(wilderness national monument and LUD II) and an additional 1 percent is in a 

municipal watershed status. About 85 percent of the province is under national 

forest management. The Annette Island Indian Reservation is the second largest 

ownership with 7 percent of the province, the State of Alaska is the third largest 

landowner with 5 percent, followed by Cape Fox Village Corporation at 2 percent, 

and Sealaska Regional Corporation at 1 percent. The cities of Ketchikan, Saxman, 

and Metlakatla occur within the province. 

This province has the third largest number of acres of POG among all Southeast 

Alaska provinces. Approximately 573,000 acres of POG currently exist in the 

province, and 70,000 acres have been harvested. The remaining POG consists of 

41 percent high-volume POG and 6 percent large-tree POG. Originally, 44 percent 

of the POG was high volume and 9 percent was large-tree POG, indicating a higher 

rate of past harvest of larger tree types. Overall, 89 percent of all POG, 84 percent 

of high-volume POG, and 59 percent of large-tree POG remains today. Although 

disproportionate harvest occurred on all ownerships, non-NFS lands had the highest 

rate of disproportionate harvest: the 25,000 acres of past harvest on non-NFS lands 

included 38 percent of the high-volume and 91 percent of the large-tree POG. 

Harvest on NFS lands in this province has been relatively evenly distributed over 

time beginning in the 1950s, with the highest decadal harvest in the 1990s 

(Appendix E). Harvest on non-NFS lands has generally occurred in the more recent 

decades. Relatively high concentrations of past harvest have occurred at a number 

of areas along Behm Canal, George Inlet, Carroll Inlet, and near Ketchikan on 

Revilla Island and on northern Annette Island. In many of these areas, biodiversity 

has been affected due to the intensity of past harvest and the higher reductions in 

larger tree POG types. 

Southern Outer Islands

The Southern Outer Islands is a small, isolated province subject to strong oceanic 

influences. Topography is low-lying and gentle and the islands are relatively rich in 

endemic vertebrate species. Almost half (49 percent) of the province is in 

congressionally protected land designations (wilderness and LUD II) and 94 percent 

of the province consists of NFS lands. Other major landowners include: ShaanSeet Village Corporation (3 percent); State of Alaska (2 percent); and Sealaska 

Regional Corporation (1 percent). 

The province contains a high proportion of POG relative to its size. It contains about 

118,000 acres of existing POG and 21,000 acres of harvest have occurred; thus, the 

remaining POG represents 85 percent of the original POG acreage. The majority of 

the islands in the province have had little or no past harvest; harvest has been 

concentrated on Heceta Island, and to a lesser extent on San Juan Batista and 

Suemez Islands. Most NFS harvest was conducted in the 1960s through the 1980s 
3 Environment and Effects

Biodiversity 3-164 Final EIS

(Appendix C). Heceta Island is mostly covered with karst terrain and limestone soils 

and originally contained fairly extensive stands of large-tree karst POG; most of 

these stands have been cut. Today, about 38 percent of the existing POG within the 

province is high-volume and 11 percent is large-tree POG. On NFS lands, 88 

percent of the original POG remains, while on non-NFS lands only 46 percent 

remains. About 82 percent of the original NFS high-volume POG remains compared 

with only 33 percent of the original high-volume POG on non-NFS lands. Similarly, 

74 percent of the original large-tree POG exists today on NFS lands, while only 16 

percent of original large-tree POG remains on non-NFS lands. This province 

originally contained about 39,000 acres of POG on karst terrain. To date, about 36 

percent of this karst POG has been harvested. 

Effects of past harvest have been slight to non-existent on most portions of most of 

the islands in the province. However, extensive past harvesting on Heceta Island, 

on both NFS and non-NFS lands, have affected the biodiversity in a number of the 

watersheds. 

Dall Island and Vicinity

This province is located at the extreme southwestern corner of Southeast Alaska 

and, like the Southern Outer Islands province, is subject to strong oceanic 

influences. Unlike the Southern Outer Islands province, the topography of the Dall 

Island and Vicinity province is rugged and dissected with abundant limestone 

outcrops. The province includes Dall Island and Long Island along with numerous 

small islands. Approximately 3 percent of the province is in congressionally 

protected land designations and only 56 percent of the province consists of Tongass 

National Forest lands. This province has the lowest proportion of NFS lands of any 

province within the Tongass Forest boundary. Other major landowners include: 

Sealaska Regional Corporation (29 percent); Klukwan Village Corporation (11 

percent); Haida Village Corporation (1 percent); and the State of Alaska (1 percent). 

The Dall Island and Vicinity province contains approximately 100,000 acres of POG 

and has experienced 33,000 acres of harvest, almost all of which is on non-NFS 

lands. Almost all of this harvest was conducted either in the 1980s or in the last 10 

years (Appendix E), so the majority of the young growth is still in the stand initiation 

successional stage. Approximately 99 percent of the original POG remains on NFS 

lands, along with 99 percent of the original high-volume POG and 99 percent of the 

original large-tree POG. On non-NFS lands, 49 percent of the original POG is 

remaining, while 33 percent of the original high-volume POG and 8 percent of the 

original large-tree POG remains today, indicating substantial disproportionate 

harvest of large-tree POG. This province originally contained about 12,000 acres of 

POG on karst terrain. To date, at least 10 percent of this karst POG has been 

harvested. 

Much of the past harvest took place on private lands on Long Island, where 

extensive stands of large-tree POG originally existed. The province is believed to 

have originally contained the best representation of large-tree karst forest in 

Southeast Alaska (Carstensen et al. 2007). The biodiversity of watersheds on much 

of northern Long Island has been substantially modified due to expansive harvesting 

in this area. This level of modification has also occurred in some watersheds on 

eastern Dall Island. 

South Prince of Wales Island

The South Prince of Wales Island biogeographic province covers the southern 

quarter of Prince of Wales Island and is characterized by steep and rugged 

topography and a highly dissected coastline. It is relatively warm and wet and 

provides habitat for plant species that do not grow further north. Approximately 28 
 Environment and Effects 3 

Final EIS 3-165 Biodiversity 

percent of the province is in congressionally protected land designations (South 

Prince of Wales Wilderness and Nutkwa LUD II) and the majority of the province is 

roadless. Non-NFS lands comprise about 8 percent of the land area, about twothirds of which is owned and managed by Kootznoowoo Village Corporation. Haida 

Village Corporation, the State of Alaska, and other parties comprise the remaining 

owners. 

The province currently contains about 173,000 acres of POG and has had about 

18,000 acres of past harvest. With the exception of the Chasina Peninsula in the 

northeast, relatively little past harvest has occurred on NFS lands in the province 

(about 3,000 acres). As a result, approximately 98 percent of the original POG on 

NFS land remains. Non-NFS lands have been relatively heavily harvested 

(approximately 14,000 acres) with approximately 43 percent of the original POG 

remaining. Counting all ownerships, 91 percent of the original POG remains. 

Harvest is concentrated in the northern portion of the province on the Chasina 

Peninsula and along Cholmondeley Sound. Although high-volume and large-tree 

POG have been harvested at higher rates than smaller tree types, it is estimated 

that 88 percent of both high-volume and large-tree POG remains in the province on 

all lands combined. However, the percent of these types remaining is much lower in 

local areas with the highest rates of harvest (e.g., Chasina Peninsula and 

Cholmondeley Sound). 

Extensive tracts of high-volume POG, including large-tree forests, occur within the 

northwestern portion of the province and are mostly protected within the Nutkwa 

LUD II area. Because of these tracts and other areas of high-volume and large-tree 

POG, these types make up high percentages of the existing POG relative to other 

Southeast Alaska provinces (51 and 29 percent, respectively). 

One area of particular concern on the edge of this province is the Sulzer Portage, a 

relatively narrow neck of land on Prince of Wales Island connecting West Arm 

Cholmondeley Sound and Portage Bay at the head of Hetta Inlet. It joins the North 

Central Prince of Wales and the South Prince of Wales Island provinces and has 

had considerable past timber harvest. Due to recent land selections, the immediate 

portage is entirely on non-NFS lands. Substantial future harvest, if it were to occur, 

could substantially affect ecological connectivity. See the Wildlife section for a 

description of pinch-points and an analysis of the effects of additional development 

in these areas on wildlife movements. 

North Misty Fiords

The North Misty Fiords province has considerable topographic relief and a cold, 

mainland-type climate with many glaciers. Vegetation occurs in long, narrow strips 

along river valleys and lower slopes of fiords. The province is 99 percent NFS lands 

and 82 percent of the province is protected within the Misty Fiords National 

Monument, which is in wilderness status. The State of Alaska is the only other 

major landowner with 1 percent of the province. 

The province contains 201,000 acres of existing POG and only 2,000 acres of past 

harvest. Thus, 99 percent of the original POG, 98 percent of the original highvolume POG, and 95 percent of the original large-tree POG remains today. Highvolume and large-tree POG represent 33 percent and 6 percent of the existing POG, 

respectively. Because of the low degree of past harvest, their effects are relatively 

minor throughout the province. 

South Misty Fiords

The South Misty Fiords province has lower topographic relief and is warmer than the 

North Misty Fiords province, but otherwise it is typical of the other mainland 
3 Environment and Effects

Biodiversity 3-166 Final EIS

provinces. Forest vegetation is more diverse than the other coastal provinces, and 

vegetation is less fragmented by rock and ice than the North Misty Fiords province. 

The southwestern portion of the province is rolling, nearly continuous muskeg with 

conifer forests in the bottoms and flats. Approximately 99 percent of the province is 

in congressionally protected land designations (Misty Fiords National Monument) 

and nearly 100 percent is on NFS lands. The State of Alaska is the only other major 

landowner with less than 1 percent of the province. 

The province contains 310,000 acres of existing POG and no measurable past 

harvest. Thus, 100 percent of the original POG, 100 percent of the original highvolume POG, and 100 percent of the original large-tree POG remains today. Highvolume and large-tree POG represent 31 percent and 5 percent of the existing POG, 

respectively. Because of the lack of past harvest, no effects from past timber 

harvest have occurred within the province. 

Ice Fields

The Ice Fields province covers the highest mountains along the eastern boundary of 

Southeast Alaska with Canada. It is dominated by permanent ice fields, active 

glaciers, and nunataks (mountain peaks between glaciers). Approximately 33 

percent of the province is in congressionally protected land designations (wilderness 

or national monument) and nearly 100 percent is on NFS lands. The State of 

Alaska is the only other major landowner with less than 1 percent of the province. 

The province contains 115,000 acres of existing POG in narrow bands along 

mountain valleys, and 4,000 acres of past harvest. Thus, 97 percent of the original 

POG, 93 percent of the original high-volume POG, and 83 percent of the original 

large-tree POG remains today. High-volume and large-tree POG represent 32 

percent and 5 percent of the existing POG, respectively. Because of the low level of 

past harvest in this province, the effects of past harvest are localized and relatively 

minor throughout the province. 

Chilkat River Complex

The Chilkat River Complex lies at the northern end of the Inside Pasage and is 

outside the Tongass Forest boundary. It consists of tall ridge systems, large glacial 

rivers, and includes glaciers and snowfields. Many of the rivers and drainage basins 

extend across the international boundary into Canada. Because of the overlap of 

coastal and interior floras and faunas, the province contains Alaska’s highest 

vascular plant species richness and the highest mammalian diversity in Southeast 

Alaska (Carstensen et al. 2007). The province is located outside the Tongass 

Forest boundary and has 2 percent of its lands in a congressionally protected status. 

Although an additional 10 percent is administratively protected, the province has the 

lowest overall percentage of lands in a status that restricts development of all 

Southeast Alaska provinces. Approximately 59 percent of the province consists of 

state lands, including the 286,000-acre Haines State Forest, the 45,000-acre Chilkat 

Bald Eagle Preserve, and 242,000 acres of other state lands. The Bureau of Land 

Management manages about 39 percent of the province, small edges of Glacier Bay 

National Park represent about 1 percent, and other landowners, including the cities 

and boroughs of Haines and Skagway, comprise the remaining 1 percent. 

The province contains about 145,000 acres of POG and about 21,000 acres have 

been harvested. The result is that approximately 88 percent of the original POG in 

the province remains today. Large-tree POG has been harvested at a higher rate; 

about 73 percent remains. However, about 89 percent of the original high-volume 

POG is estimated to remain, indicating a non-disproportionate harvest for the highvolume POG types as a group. 
 Environment and Effects 3 

Final EIS 3-167 Biodiversity 

Although only about 13 percent of the original POG in the province has been 

harvested, about 27 percent of the large-tree POG has been logged and harvest has 

been concentrated within the Haines State Forest near the confluences of the 

Chilkat River with the Klehini and Kelsall Rivers. Thus, the effects of past harvest in 

these local areas have been relatively high. 

Glacier Bay/Fairweather Range

The Glacier Bay/Fairweather Range province is the largest province in Southeast 

Alaska (2.5 million acres), but the vast majority of it is high mountains and glaciers 

and the majority is non-vegetated. The highest peaks are in the Fairweather Range 

along the western edge of the province, with Mt. Fairweather at over 15,000 feet. A 

large flat, foreland, the Gustavus Foreland, occurs in the area around Gustavus and 

to the north in the Bartlett River valley. Lowlands are also fairly extensive along the 

Dundee River and other smaller drainages on the southwest side of Glacier Bay. 

Glacier Bay National Park protects virtually the entire province (97 percent), except 

for about 75,000 acres in the vicinity of Gustavus. There are no NFS lands in the 

province. 

Although approximately 171,000 acres of POG exist in the lowlands of the province, 

only a small fraction (< 0.5 percent) has been harvested. High-volume POG makes 

up the vast majority of the POG in the province (an estimated 92 percent), but largetree POG is relatively rare (< 1 percent). 

The effects of past harvest on the biodiversity and old-growth ecosystem integrity of 

the province has been insignificant because of the insignificant amount of past 

harvest. Primary succession of natural young-growth forests will contribute to the 

extent of POG over time. 

Fragmentation 

The Tongass National Forest is characterized by fragmentation on many scales and 

this fragmentation is the result of different processes. Fragmentation occurs when 

large blocks of habitat are broken into smaller parcels by natural (e.g., wind throw, 

landslides, soil slumping, erosion, insects and diseases, and avalanches) or human 

induced (e.g., roads or timber harvest operations) forces. From a regional 

perspective, the Tongass National Forest is highly fragmented due to numerous 

islands and dramatic topographic relief. At a landscape level across the project 

area, the natural distribution of POG forest is quite patchy and is linear in many 

areas, with fragmentation created by muskeg, forested wetlands, and alpine areas. 

On a small scale, single-tree gaps within a 400-year-old Sitka spruce stand provide 

habitat for forest interior birds such as the hairy woodpecker. On a broader scale, 

large patches of wind disturbance of 10 acres or more may create nesting habitat for 

migratory songbirds, or increase the growth of understory forage for some species 

such as deer. 

Timber harvest operations, including road-building, add to the level of fragmentation 

or edge that occurs naturally. The effect of timber-harvest varies with the placement 

of units and their proximity to large existing forest blocks. Simulation studies have 

indicated that when 50 percent of a watershed is harvested with a staggered setting 

design, little if any interior forest remains. As habitat becomes fragmented, residual 

habitat patches become smaller and more isolated from each other. Whether a 

particular patch pattern and degree of fragmentation is beneficial or deleterious 

depends largely on the characteristics of the species using the landscape (Morrison 

et al. 1992). Some species, particularly those with limited mobility such as small 

mammals may view open spaces (natural or human-induced) as travel barriers. 

Fragmentation may increase the risk of predation by avian, and mammalian 
3 Environment and Effects

Biodiversity 3-168 Final EIS

carnivores, or increase isolation between other subpopulations which in turn may 

increase the risk of local extirpation. 

Timber harvest tends to increase forest fragmentation and the amount of forest 

edge. The edges between different forest types, and between forested and 

non-forested areas, can affect the environment close to the edge. For example, 

forest edges tend to be warmer in the summer and cooler in the winter than interior 

forests (Franklin 1993). Some species increase in abundance close to an edge 

while others decrease in abundance. Species associated with interior forests but 

not with forest edges are of concern since timber harvest tends to decrease the 

amount of interior forest. Concannon (1995) noted that the edge effect or depth-ofedge influence distance varied by such factors as forest type, tree density, site 

aspect, slope, solar insolation, aspect, slope, latitude, season, and edge type (e.g., 

peatland, shoreline). Edge effects ranged from 30 to over 200 meters (from 

approximately 100 feet to over 660 feet) from an edge. Edge effects change as 

forest grows; however, there is little information on how that may reduce overall 

effects over time. 

Patches of old-growth forest sometimes serve as the only habitat in a landscape for 

many lichens, fungi, bryophytes, plants, and small-bodied animals, all of which 

contribute to the biodiversity and productivity of the forest ecosystem. These 

patches may be critical for species that are locally endemic, occur only in very 

specific conditions of forest structure or soil, or have limited dispersal capabilities. 

These issues are typically assessed in detail during project-level analysis. 

The framework of the old-growth forest conservation strategy in the current Forest 

Plan consists of a network of small, medium, and large old-growth reserves (OGRs), 

specifically designed to conserve habitats of the species that have the most viability 

concerns. It was designed, in part, to recognize and account for current conditions 

within each biogeographic province, and to better maintain future old-growth forest 

in provinces where past harvest has been high. A second component of the oldgrowth forest conservation strategy in the 1997 Forest Plan is the set of standards 

and guidelines that protect specific areas (e.g., 1,000-foot-wide beach fringe) and 

provide habitat connectivity in those areas with LUD allocations that permit 

commercial timber harvest. 

To preserve the integrity of the old-growth ecosystem on the Tongass National 

Forest, project-level analyses are conducted at the landscape scale to identify 

blocks of contiguous old-growth forest within already identified large and medium 

reserves and other natural setting LUDs. Landscape connectivity among these 

blocks is evaluated during this analysis (see Chapter 4 of the Forest Plan, 

Landscape Connectivity Standard and Guideline). 

Intact Watersheds 

Another way of evaluating fragmentation and biodiversity in general is through 

considering the degree to which areas have been modified or developed by humans 

on a large watershed scale and then assessing effects on the watersheds that have 

undergone little if any previous modification. For this analysis, the VCU is used to 

define large watersheds. VCUs are Tongass land divisions with boundaries that 

typically follow watershed divides and encompass one or more stream systems. 

There are about 945 VCUs on the Tongass and they average about 18,000 acres in 

size. 

Intact watersheds are defined here as those having less than 5 percent of their POG 

harvested, which is consistent with a similar analysis conducted by Audubon Alaska 

and The Nature Conservancy (Albert and Schoen 2007). This measure provides 

land managers with a means to assess the extent to which the Tongass consists of 
Environment and Effects 3 

Final EIS 3-169 Biodiversity 

intact, undeveloped, and fully functional landscapes (a measure of conservation 

representation), and provides a means of assessing future changes expected under 

various management alternatives. Fully functional landscapes are defined as areas 

that maintain focal species, communities, and/or systems, and their supporting 

ecological processes within their natural ranges of variability (Poiani et al. 2000). 

Thus, functional landscapes are an important element in the conservation of 

biodiversity and can be used as a means to identify areas of biological importance. 

The use of a 5 percent POG harvest criterion for this classification is not meant to 

imply that a watershed must exceed this threshold to be fully functional. It is highly 

likely that many watersheds remain fully functional at harvest levels significantly 

above this level. It is used simply to provide an index or a measure of the proportion 

of watersheds that are intact and in relatively pristine condition. 

Table 3.9-11 summarizes the number and acreage of intact large watersheds within 

each biogeographic province inside the Tongass Forest boundary. Overall, 

approximately 67 percent of the large watersheds and 72 percent of the acreage are 

estimated to be intact. Biogeographic provinces with the highest acreages of intact 

watersheds include the six biogeographic provinces along the mainland south of 

Skagway and the Admiralty Island province. Others that contain at least 0.5 million 

acres in intact watersheds include the East Chichagof, West Baranof, and Lynn 

Canal provinces. Those provinces with less than 50 percent of their large 

watersheds considered to be intact include Kupreanof/Mitkof, Etolin Island and 

Vicinity, and North Central Prince of Wales. Audubon Alaska and The Nature 

Conservancy (Albert and Schoen 2007) conducted a similar comparison of 

watersheds with greater than 95 percent of POG intact for all of Southeast Alaska. 

They found that approximately 71 percent of the landbase in Southeast Alaska still 

exists within these intact landscapes, and that much of this area was concentrated 

along the rugged mainland coast and Glacier Bay. 
3 Environment and Effects

Biodiversity 3-170 Final EIS

Table 3.9-11 

Number and Acreage of Existing Intact* Large Watersheds (VCUs) by 

Biogeographic Province within the Tongass Forest Boundary

Biogeographic Province 

Total Number 

of Large 

Watersheds 

(VCUs) 1/

Percent of 

Intact Large 

Watersheds 

(VCUs) 1/

Approximate 

Total Acreage 

in Large 

Watersheds 

Percent of 

Acreage in 

Intact Large 

Watersheds 

1 Yakutat Forelands 24 83% 344,231 80% 

2 Yakutat Uplands 26 96% 916,929 99% 

3 East Chichagof Island 87 53% 1,129,840 49% 

4 West Chichagof Island 31 100% 287,518 100% 

5 East Baranof Island 22 55% 394,381 60% 

6 West Baranof Island 43 65% 797,901 69% 

7 Admiralty Island 60 88% 1,085,689 85% 

8 Lynn Canal 50 76% 671,845 80% 

9 North Coast Range 49 90% 1,111,396 94% 

10 Kupreanof/Mitkof Island 35 37% 842,334 39% 

11 Kuiu Island 30 73% 493,252 60% 

12 Central Coast Range 29 79% 729,163 85% 

13 Etolin Island 27 33% 518,932 30% 

14 North Central Prince of Wales 116 24% 1,488,826 17% 

15 Revilla Island/Cleveland 

Peninsula 84 68% 1,347,381 71% 

16 Southern Outer Islands 20 50% 223,986 64% 

17 Dall Island and Vicinity 35 71% 200,222 53%

18 South Prince of Wales 36 78% 395,076 75%

19 North Misty Fiords 32 94% 975,904 96%

20 South Misty Fiords 54 100% 906,047 100%

21 Ice Fields 57 93% 3,006,309 94%

Total 947 69% 17,867,163 74% 1 Intact is defined here as those watersheds having less than 5 percent of their POG harvested and not containing 

other major disturbances (e.g., large mines, communities, major roads).

Endemism 

Endemic species are species that are isolated to islands or specific geography that 

potentially have an increased risk of adverse effects associated with management or 

natural disturbance. For example, these species may not be able to travel between 

islands or may be adapted to living in a very specific habitat that has a limited 

distribution. Species tied to island archipelagos are more sensitive to the effects of 

introduced non-natives, including pathogens and disease, and natural events, such 

as climate change, than other managed landscapes due to their limited mobility and 

isolation from other subpopulations (Cook et al. 2006). Therefore, there is a higher 

probability of extinction on islands. Risk assessment panels, convened prior to the 

1997 Forest Plan, determined that endemic mammals were the most sensitive of all 

wildlife species to future landscape disturbances, such as that resulting from timber 

harvesting (Swanston et al. 1996). Such disturbances affect the likelihood of 

maintaining viable, well-distributed populations of endemic mammals across the 

Forest. 

Southeast Alaska has been found to be a region with an especially high degree of 

endemism in its small mammal fauna, principally because of its archipelago 

geography combined with highly dynamic glacial history and resulting natural “pinch 

points” or "bottle-necks" where natural features (e.g., mountains or water bodies) or 

human caused features (e.g., roads and harvest units) constrain potential movement 

by wildlife to narrow bands of habitat. For example, some islands do not support 

particular species even though suitable habitat exists (e.g., there are no brown 

bears on Prince of Wales Island or wolves on Admiralty, Baranof, or Chichagof 
 Environment and Effects 3 

Final EIS 3-171 Biodiversity 

islands). Other species have restricted habitat requirements. Small mammals 

appear to be most diverse in scrub and herbaceous habitat associations and were 

least abundant and diverse in closed-canopy, even-aged (young growth) coniferous 

forest types and pine muskegs (MacDonald and Cook 2000). Between 1990 and 

2005, 111 islands on the Tongass were surveyed for mammals, though much of this 

effort occurred prior to 2000 (Tongass Conservation Strategy Review Workshop 

2006). This has resulted in the documentation of new distributions, new species, 

and distinct populations that also suggest a high level of endemism on the Tongass 

(see the Wildlife section for additional discussion). There continue to be gaps in 

knowledge about the natural history, ecology, and distribution of wildlife subspecies 

indigenous to Southeast Alaska (Hanley et al. 2005), and continued research will 

help to fill current gaps for some species. Additional species-specific discussion can 

be found in this chapter under the Wildlife, Plant, and Fish sections. 

Invasive Species 

Alaska has, until recently, been relatively isolated from invasive species, due to 

climatic conditions, large undeveloped areas, limited transportation routes, and 

sparse human population centers (Fay 2002). Schrader and Hennon (2005) 

assessed the current status of invasive species in Alaska’s ecosystems, which 

include non-native plants, fish, wildlife, and other species, emphasizing the Chugach 

and Tongass National Forests. More than 130 non-native plant species have been 

recorded in Alaska through 2005 (AKEPIC 2006). Eighty-eight species of nonnatives have been recorded on the Tongass, 46 have an invasiveness ranking 

according to their invasive characteristics and threat to Alaska, with 29 of those 

species identified as having a greater potential threat to Alaska. Fifteen of the 

species found on the Tongass are among the species that pose a greater potential 

threat (see the Plant section in this chapter for additional discussion on non-native 

plants). 

Although many non-native wildlife species have been introduced or transplanted in 

Alaska, with the exception of rats in coastal ecosystems and possibly slugs in 

estuaries, none is considered invasive at the present. Additional discussion on 

terrestrial wildlife invasives are discussed in the Wildlife section of this chapter. 

Schrader and Hennon (2005) identified 11 aquatic species in their assessment. Six 

species have already established breeding populations in National Forest lands and 

other areas in Alaska and include northern pike (Esox lucius Linnaeus), yellow 

perch (Perca flavescens), redlegged frog (Rana aurora), Pacific chorus frog 

(Pseudacris regilla), rainbow trout (Oncorhynchus mykiss Walbaum), and brook 

trout (Salvelinus fontinalis). The other five species are not established in Alaska yet, 

but cause widespread problems in the lower 48 states and could become 

problematic in Alaska. These species of concern are the Atlantic salmon (Salmo 

salar), Chinese mitten crab (Eriocheir sinesis), New Zealand mudsnail 

(Potamopyrgus antipodarum Gray), goldfish (Carassius auratus), and the signal 

crayfish (Pacifacstacus leniusculus). In Alaska, established populations of northern 

pike (with the exception of Pike Lakes on the Yakutat Ranger District) pose the 

greatest immediate concern, while the Atlantic salmon, Chinese mitten crab, and 

New Zealand mudsnail species are likely to invade Alaska in coming years (Fay 

2002). Invasive tree pathogens are not currently damaging Alaskan ecosystems, 

but there are numerous species that could cause widespread tree mortality if 

introduced. 

Four introduced insects are currently established in Alaska: the larch sawfly, alder 

woolly aphid, spruce aphid, and amber-marked birch leafminer. These insects can 

cause widespread tree defoliation and mortality. A number of exotic insects pose a 
3 Environment and Effects

Biodiversity 3-172 Final EIS

potential threat and are related primarily to transport of infested plant and wood 

products. 

Managing invasive species on the Tongass National Forest will likely be challenging 

in the future. Increased public awareness at all levels coupled with interagency 

cooperation and development of cooperative management partnerships is needed to 

limit invasive species populations at current levels in Alaska. 

The Forest Service is addressing invasive plant management through the Alaska 

Region Invasive Plant Strategy (USDA Forest Service 2005a) and the Tongass 

National Forest Invasive Plant Management Guides (Lerum and Krosse 2005). 

Within the Forest Service, various approaches are in place to address four action 

elements (prevention, early detection and rapid response, control, and restoration) 

in the National Strategy and Implementation Plan for Invasive Species Management 

(USDA Forest Service 2004f). See the Plants section in this chapter for more 

information on management of non-native plant species. 
 Environment and Effects 3 

Final EIS 3-173 Biodiversity 

Environmental Consequences 

Old-growth forests, which cover more than half of the 16.8 million acres of the 

Tongass, provide the primary habitat for the majority of terrestrial plant and animal 

species. They also represent ecosystems with uniquely defined characteristics and 

are the habitat types most affected by timber management activities; therefore, they 

are the most affected ecosystems on the Tongass, and the following discussion 

focuses on general effects on old-growth forest ecosystems. 

This analysis of effects on biodiversity is subdivided into a number of sections. The 

first section focuses on effects associated with anticipated changes to old-growth 

forest representation over time, related to timber harvest. Associated with the 

evaluation of the effects on representation, are the effects on the elements of the 

old-growth forest conservation strategy for each alternative, including the coarsefilter (forest-wide system of old growth reserves) and fine-filter (standards and 

guidelines) components. Smaller sections address the effects on fragmentation and 

intact watersheds, endemics, and invasive species. The final section of this analysis 

evaluates the cumulative effects on biodiversity of the proposed Forest Plan 

adjustment in conjunction with past, present, and reasonably foreseeable activities 

on both NFS) and non-NFS lands (including private, state, and other ownerships). 

Measurement of Effects 

To quantify potential effects on biodiversity, the alternatives can be compared in 

terms of their ability to maintain a functional and interconnected old-growth 

ecosystem. Functional refers to the ability of an ecosystem to maintain or contribute 

to the maintenance of populations that use it, and to contribute to the diversity and 

productivity of other ecosystems. Examples of ecosystem functions include 

providing habitat for organisms, climatic buffering, soil development, and the 

maintenance of soil productivity through inputs of coarse woody debris, nitrogen 

fixation, spread of biotic and abiotic disturbance through landscapes, and nutrient 

cycles. 

The interconnectedness of an ecosystem is a measure of the extent to which the 

landscape pattern of the old-growth ecosystem provides for biological and 

ecological flows to sustain old-growth associated animal and plant species across 

the Tongass and Southeast Alaska. Connectivity does not necessarily mean that 

old-growth areas need to be physically joined in space, because most associated 

species can disperse across areas that are not in old-growth ecosystem conditions. 

Landscape features affecting connectivity of old-growth ecosystems include the 

distances between old-growth reserve areas and forest conditions in the areas 

between the reserve areas (matrix lands). 

Given that Southeast Alaska consists of many islands, connectivity issues should 

include landscape level connections between individual islands as well as between 

islands and the mainland portion of Southeast Alaska; however, current and future 

forest management activities are expected to have a greater influence on 

within-island conditions than between islands. Forest management areas require 

measures that ensure wildlife movement patterns and habitat diversity are protected 

over time. This is an important consideration when analyzing functional landscape 

connectivity and the maintenance of well-distributed, viable populations. Several 

“pinch-points“ or "bottle-necks" where natural features or human-caused features 

(e.g., roads and clearcuts) constrain potential movement by wildlife to narrow bands 

of habitat have been identified on the Tongass and are discussed in greater detail in 

other places within this section and under the Wildlife section of this chapter. 

Direct and 

Indirect Effects 
3 Environment and Effects

Biodiversity 3-174 Final EIS

Fragmentation associated with habitat loss results in smaller sizes of habitat 

patches available to a species, increased distances among habitat patches, 

increased amounts of matrix conditions in which habitat patches are embedded, and 

altered spatial distribution of habitat types (Haufler 2006). These factors are 

strongly tied to the structural and functional connectivity of the landscape, and thus 

the ability of the landscape to support well-distributed and viable wildlife populations. 

By maintaining a functional and interconnected old-growth ecosystem, it can be 

assumed that various components of biodiversity, including structural diversity 

(within-stand and landscape level), connectivity (unfragmented, contiguous blocks of 

old growth), stand age and species composition (including understory species), and 

ecological processes (e.g., tree establishment, disturbance, and nitrogen fixation) 

will also be maintained. The amount and distribution of POG after 100 years of 

Forest Plan implementation can serve as a relative indicator of the functioning and 

interconnectedness of the old-growth ecosystem and the potential effects on 

biodiversity under each alternative. 

In addition, effects on biodiversity can be measured by the degree of change 

expected to occur in the composition and distribution of the old-growth ecosystem 

relative to its historic composition and distribution. It can be assumed that the more 

an alternatives change the natural distribution and composition of old-growth 

ecosystems, the greater are its effects on biodiversity. Therefore, the effects of the 

alternatives on the distribution and composition of old-growth forests can be 

evaluated by examining the representation of POG and specific types of POG 

across the Tongass, with reference to historical representation. At the same time 

the analysis examines the old-growth conservation strategy of each alternative and 

the degree to which it maintains old-growth function, interconnectedness, and 

representation. 

Another measure of the effects of the alternatives on landscape fragmentation can 

be obtained by evaluating the degree to which the alternatives would result in 

converting large, relatively pristine watersheds to a modified state (see Intact 

Watersheds in the Affected Environment part of this section). For this analysis, 

VCUs are used to define large watersheds and intact large watersheds are defined 

as those having less than 5 percent of their POG harvested and not containing other 

major disturbances. The use of VCUs and a 5-percent threshold are not based on 

specific criteria for defining intact large watersheds. Therefore, this measure should 

be viewed as one measure or an index of ecosystem fragmentation. 

Finally, one additional tool is used in the comparison of the alternatives. The 1997 

Forest Plan Revision Final EIS biodiversity analysis (U.S. Forest Service 1997a) 

relied in part upon expert panel evaluations of alternatives in terms of the estimated 

relative risks to the old-growth ecosystem (DeGayner 1996). This old-growth panel 

assessment is referred to below, where appropriate. Although the alternatives 

evaluated by the panel evaluations do not exactly correspond to the alternatives 

evaluated here (the old-growth reserve system and many new standards and 

guidelines were being developed and evaluated during the 1997 Forest Plan 

Revision), useful inference about the relative risks of the current alternatives can be 

made. Panel assessments were also conducted for wildlife and fish species and 

these are discussed in the Wildlife and Fish environmental effects sections. 

Conservation Strategy Overview 

An integrated old-growth conservation strategy was developed and incorporated into 

the 1997 Forest Plan (Appendix D). This strategy has two basic components. The 

first is a forest-wide reserve network that protects the integrity of the old-growth 

forest by retaining blocks of intact, largely undisturbed habitat. The old-growth 

reserves include a system of large, medium, and small Habitat Conservation Areas 
 Environment and Effects 3 

Final EIS 3-175 Biodiversity 

allocated to the Old-growth Habitat Land Use Designation (LUD), and full protection 

of all islands less than 1,000 acres in size. The reserve network also includes all 

other non-development LUDs. These include Wilderness, National Monument, 

Legislated LUD II, Wild River, Remote and Semi-remote Recreation, Research 

Natural Area, Municipal Watershed, and all other LUDs that essentially maintain the 

integrity of the old-growth ecosystem. The old-growth reserves were specifically 

designed to conserve habitats of the species that have the greatest viability 

concerns. They were designed, in part, to recognize and account for current 

conditions within each biogeographic province, and to better maintain future oldgrowth forest in provinces where past harvest has been high. The second 

component of the old-growth habitat conservation strategy is management of the 

matrix, e.g., the lands with LUD allocations where commercial timber harvest may 

occur. Within the matrix, components of the old-growth ecosystem are maintained 

by standards and guidelines to protect important areas and provide old-growth forest 

habitat connectivity. This component includes the beach and estuary fringe, riparian 

buffers, and a variety of other categories where timber harvest is not permitted. 

Matrix lands play a vital role in providing functional connectivity across fragmented 

landscapes (Szacki 1999). A detailed description of the rationale and components 

of the strategy is provided in Appendix D. 

Research since 1997 has provided much new information on plant and wildlife 

populations and habitat relationships in Southeast Alaska; however, there continue 

to be gaps in knowledge about the ecology and distribution of many species making 

direct correlations between land management activities and their habitats and/or 

population impacts difficult. The conservation strategy itself is a step toward 

addressing this uncertainty by maintaining an extensive network of reserves and 

landscape connectivity on the Tongass; however, the effectiveness of the reserves 

and buffers in relation to their size, landscape pattern, and geographic distribution 

has yet to be scientifically tested (Powell et al. 1997). Smith (2005) noted that for 

many species, it is unknown whether the current reserve design is capable of 

supporting well-distributed, viable populations or providing sufficient connectivity to 

enable the flow of individuals between reserves. In addition to the unknowns related 

to the reserve network, there is also a need to explicitly define future desired 

conditions of matrix lands which provide life requisites for many species and to 

determine the optimal way to manage young-growth to benefit wildlife (Workshop 

Integration Session, Tongass Conservation Strategy Review Workshop 2006); new 

approaches to stand management that offer alternatives to clearcutting are also 

being evaluated. 

The conservation strategy developed for the 1997 Forest Plan Revision is 

incorporated directly in Alternative 5, which represents the current Forest Plan. 

Each alternative incorporates a variation of the current old-growth conservation 

strategy by maintaining some level of old-growth reserves and providing additional 

old-growth protection within the matrix. These variations in the strategy are 

evaluated below. 

General Overview of Effects 

An overview of the degree to which old-growth forest protection is afforded by the 

old-growth strategy of each alternative is provided by examining the amount and 

percent of POG that occurs in reserves (areas where old-growth harvest is generally 

not permitted) versus the amount and percent in the matrix (areas where forests are 

actively managed). Table 3.9-12 presents a detailed summary of this information for 

each alternative. This table also identifies the composition of POG in various 

categories by summarizing all POG, high-volume POG, and large-tree POG. 
3 Environment and Effects

Biodiversity 3-176 Final EIS

Table 3.9-12 

Estimated Acreage and Percentage of All Existing POG, High-Volume POG, and SD67 POG in 

Reserves1

 and Matrix2 Lands (minimum protected vs. maximum harvested) by Alternative3

Amount in Matrix2

Amount in Reserves1

Minimum Protected Maximum Harvested4 Total Existing POG 

Alt. POG Category Acres Percent Acres Percent Acres Percent Acres Percent

All POG 4,615,995 93% 249,182 5% 85,972 2% 4,951,148 100% 

1 High-Volume POG 1,862,441 93% 104,444 5% 41,460 2% 2,008,345 100% 

SD67 POG 477,813 89% 43,253 8% 16,385 3% 537,451 100% 

All POG 4,167,367 84% 569,270 11% 214,511 4% 4,951,149 100% 

2 High-Volume POG 1,674,500 83% 232,318 12% 101,529 5% 2,008,346 100% 

SD67 POG 425,744 79% 77,417 14% 34,291 6% 537,451 100% 

All POG 3,866,467 78% 771,255 16% 313,426 6% 4,951,148 100% 

3 High-Volume POG 1,572,277 78% 294,628 15% 141,440 7% 2,008,345 100% 

SD67 POG 401,011 75% 90,844 17% 45,596 8% 537,451 100% 

All POG 2,965,670 60% 1,329,005 27% 656,473 13% 4,951,148 100% 

4 High-Volume POG 1,203,702 60% 511,928 25% 292,714 15% 2,008,345 100% 

SD67 POG 307,863 57% 145,418 27% 84,169 16% 537,451 100% 

All POG 3,518,425 71% 970,176 20% 462,556 9% 4,951,156 100% 

5 High-Volume POG 1,431,634 71% 378,068 19% 198,647 10% 2,008,349 100% 

SD67 POG 364,183 68% 113,501 21% 59,767 11% 537,451 100% 

All POG 3,563,600 72% 942,445 19% 445,103 9% 4,951,148 100% 

6 High-Volume POG 1,458,202 73% 352,379 18% 197,760 10% 2,008,342 100% 

SD67 POG 375,671 70% 103,085 19% 58,696 11% 537,451 100% 

All POG 2,807,478 57% 1,336,275 27% 807,396 16% 4,951,148 100% 

7 High-Volume POG 1,143,122 57% 502,283 25% 362,940 18% 2,008,345 100% 

SD67 POG 287,295 53% 144,188 27% 105,968 20% 537,451 100% 

1 Reserves include all Non-Development LUDs (e.g., Old-Growth Habitat, Semi-Remote Recreation, Remote Recreation, Wilderness, 

National Monument, etc.). 2

 Matrix includes all Development LUDs (Timber Production, Modified Landscape, Scenic Viewshed, and Experimental Forest). 3 Numbers may not appear to sum correctly due to rounding. 4 Maximum harvested assumes the maximum allowed by the Allowable Sale Quantity is harvested each decade. The estimate assumes 

all scheduled suitable POG is harvested [calculated by subtracting alternative-specific reduction factors for the Model Implementation 

Reduction Factor (MIRF) and scheduling from the mapped suitable acreage under each alternative (see the Timber section)].

The alternatives cover a wide range of old-growth effects from minimal effects 

associated with Alternative 1, which has a maximum old-growth harvest of 86,000 

acres, to substantially greater effects associated with Alternative 7, which has a 

maximum old-growth harvest of 807,000 acres. This broad range results in from 57 

to 93 percent of the existing POG on the Tongass being maintained within reserves, 

with an additional amount of POG being protected from harvest by standards and 

guidelines in the matrix. Maximum POG harvest would range from 2 percent to 16 

percent of existing POG. Harvest of high-volume and large-tree POG would range 

from 2 to 18 percent and from 3 to 20 percent, respectively. Placing the alternatives 

in order from lowest to highest maximum POG harvest results in the following 

ranking: Alternatives 1, 2, 3, 6, 5, 4, and 7. 
 Environment and Effects 3 

Final EIS 3-177 Biodiversity 

Table 3.9-13 

Estimated Acreage and Percentage of Young Growth1

 in Reserves2 and in Matrix3 Lands 

(minimum protected vs. maximum harvested) by Alternative4

Amount in Matrix3

Amount in Reserves2

Minimum Protected Maximum Harvested5

Total Existing Young 

Growth 

Alternative Acres Percent Acres Percent Acres Percent Acres Percent 

1 189,528 42% 208,624 46% 56,573 12% 454,724 100%

2 96,452 21% 189,840 42% 168,432 37% 454,724 100%

3 88,097 19% 182,289 40% 184,339 41% 454,724 100%

4 55,024 12% 187,627 41% 212,073 47% 454,724 100%

5 72,930 16% 176,753 39% 205,037 35% 454,724 100%

6 83,045 18% 171,601 38% 200,075 44% 454,724 100%

7 35,426 8% 183,700 40% 235,599 52% 454,724 100%

1 Young growth in this table includes only young growth originating from past timber harvest. It does not include natural young growth 

(e.g., from blowdown), which is assumed to either be harvested or converted back to young growth naturally. 2 Reserves include all non-development LUDs (e.g., Old-Growth Habitat, Semi-Remote Recreation, Remote Recreation, Wilderness, 

National Monument, etc.). 3

 Matrix includes all development LUDs (Timber Production, Modified Landscape, Scenic Viewshed, and Experimental Forest). 4 Numbers may not appear to sum correctly due to rounding. 5 Maximum harvested assumes the maximum allowed by the Allowable Sale Quantity is harvested each decade. The estimate 

assumes all scheduled suitable young growth is harvested [calculated by subtracting alternative-specific reduction factors for the 

Model Implementation Reduction Factor (MIRF) and scheduling from the mapped suitable acreage under each alternative (see the 

Timber section)].

In addition, to the harvest of POG, each alternative designates a portion of the 

existing young growth to be set aside and not harvested. Table 3.9-13 summarizes 

these areas and the amounts to be included in reserves, in the matrix, and the 

amount potentially harvested. There would be a range of approximately 219,000 to 

398,000 acres of existing productive young growth that would not be harvested and 

that would eventually develop into mature forest and then POG. Based on the fact 

that most of this young growth is currently 20 to 40 years old (see Table 3.9-8), after 

about 70 years when the majority of the POG harvest has taken place, this young 

growth will be maturing and potentially beginning to take on some older forest 

characteristics, particularly if subjected to thinning or other types of stand 

management. Based on the historical overharvest of high-volume and large-tree 

POG (see Affected Environment part of this section), a high proportion of this young 

growth will be on high-site index lands, indicating faster than average growth rates. 

The future and historical distribution of POG harvest by biogeographic province is 

represented in Table 3.9-14, which shows the percent of existing POG relative to the 

original POG, and the percent of original POG remaining after 100+ years of 

implementation for each alternative. In addition, Table 3.9-14 shows the percent of 

original POG that would be remaining, after 100+ years, inside reserves designated 

by the Forest Plan for each alternative. POG harvest would occur in 18 of the 21 

provinces in at least one alternative. The range of the alternatives is 9 provinces 

containing some harvest under Alternative 1 to 18 provinces containing harvest 

under Alternative 7. Most of harvest in all alternatives would come from four 

biogeographic provinces in the south-central portion of the Tongass (North Central 

Prince of Wales Island, Kupreanof/Mitkof Island, Revilla Island/Cleveland Peninsula, 

and Etolin Island). 
3 Environment and Effects

Biodiversity 3-178 Final EIS

Table 3.9-14 

Estimated Percent of Original POG Remaining Forest-wide (1st number) and in Reserves 

(2nd number) in 100+ Years Assuming Maximum POG Harvest1

 under Each Alternative by 

Biogeographic Province

POG 

% of Original POG Remaining After 100+ Years 

(Forest-wide/In Reserves) by Alternative 

No. 

Biogeographic 

Province 

Original 

Acres 

% Remaining 

in 2006 1 2 3 4 5 6 7 

1 Yakutat Forelands 51,398 93 93/93 89/82 84/70 81/59 83/70 83/70 81/59

2 Yakutat Uplands 24,811 94 94/94 94/93 94/92 93/91 94/92 94/92 93/91

3 East Chichagof 

Island 439,307 90 88/81 85/66 83/60 76/34 80/49 81/52 72/27

4 West Chichagof 

Island 72,038 100 100/100 100/100 100/100 100/100 100/100 100/100 100/100

5 East Baranof 

Island 101,840 87 87/87 81/60 80/57 72/31 77/50 78/53 71/31

6 West Baranof 

Island 231,999 93 93/93 91/83 89/79 83/57 89/78 89/79 82/56

7 Admiralty Island 598,419 99 99/99 99/99 99/99 99/99 99/98 99/99 99/99

8 Lynn Canal 158,538 97 96/93 94/82 92/77 83/50 88/67 89/68 82/50

9 North Coast 

Range 317,898 100 100/100 100/100 99/95 87/51 91/65 91/67 85/51

10 Kupreanof/Mitkof 

Island 341,588 90 85/74 80/61 75/48 64/25 69/35 70/36 60/19

11 Kuiu Island 322,569 91 91/91 85/76 84/77 72/42 79/62 79/63 69/42

12 Central Coast 

Range 252,179 97 97/97 97/94 91/76 83/49 86/67 87/68 81/60

13 Etolin Island & 

Vicinity 254,781 86 81/70 74/45 71/40 60/18 69/40 69/40 56/17

14 North Central 

Prince of Wales 698,394 74 69/53 67/47 65/41 60/33 63/38 63/39 53/21

15 Revilla Island/ 

Cleveland Pen. 548,748 92 90/84 86/73 85/68 75/47 81/62 81/62 71/43

16 Southern Outer 

Islands 128,589 88 85/78 83/73 82/71 80/64 81/70 81/70 76/62

17 Dall Island and 

Vicinity 68,355 99 99/99 99/99 98/96 93/82 95/85 95/86 90/80

18 South Prince of 

Wales 165,389 98 98/97 96/87 91/73 80/48 87/63 87/65 77/48

19 North Misty Fiords 199,929 99 99/99 98/97 98/93 97/88 98/93 98/93 96/88

20 South Misty Fiords 309,900 100 100/100 100/100 100/100 100/100 100/100 100/100 100/100

21 Ice Fields 119,204 97 97/94 96/89 95/81 93/76 93/82 94/81 93/76

Forest-wide 5,405,872 92 90/85 88/77 86/72 79/55 83/65 83/66 77/52

Additional Mature or Older Second 

Growth (110-160 yrs), Protected 

Forest-wide3 

0 7/4 5/2 5/2 4/1 5/1 5/2 4/1

1 The estimated suitable POG incorporates a reduction factor for the Model Implementation Reduction Factor (MIRF) and scheduling,

which reduces mapped suitable acres to the estimated scheduled acres for each biogeographic province (see the Timber section). 2

 Percentage of original POG. Harvest of suitable old growth is estimated to occur until approximately until the year 2105 3

 Expressed as a percent of original POG
 Environment and Effects 3 

Final EIS 3-179 Biodiversity 

Effects on the largest tree categories of old growth and on old-growth growing on 

karstlands are of particular concern because past timber harvest has concentrated 

in these stands. In the following discussion the largest tree categories are 

represented in two ways: high-volume and large-tree POG. High-volume POG 

includes the three (out of seven) SDM classes that generally represent the most 

productive sites, produce the highest timber volumes, and contain the largest trees 

(SD5N, SD5S, and SD67). Large-tree POG is defined as the SD67 class (typically 

the type with the highest density of large trees) by itself. Tables 3.9-15 and 3.9-16 

present information similar to Table 3.9-14, but for high-volume POG and large-tree 

POG relative to the original amounts of each of these POG categories by 

biogeographic province. Harvest of karstlands is summarized in Table 3.9-17, 

which shows the percent of existing karst POG relative to the original karst POG 

acres, and the percent of original karst POG remaining after 100+ years of 

implementation for each alternative. Impacts on biodiversity could be expected to 

be greatest in those areas that have the highest cumulative harvest percentages of 

the various POG categories, because they are more susceptible to greater losses of 

biodiversity components associated with POG forests. 

Under all alternatives, long-term POG representation by ecological subsection would 

be maintained by protecting at least 41 percent of original POG in all 73 subsections 

(Table 3.9-18). At least 90 percent of original POG would be maintained in 25 

(Alternative 7) to 51 (Alternative 1) of the 73 subsections and at least 75 percent 

would be maintained in 45 (Alternative 7) to 69 (Alternative 1) out of the 73 

subsections. 

The effects of the alternatives on the number, acreage, and percentage of intact 

large watersheds are summarized in Table 3.9-19. An intact watershed is defined, 

for the purpose of this ananlysis as one in which less than 5 percent of the original 

POG has been harvested. Currently, 69 percent of the large watersheds on the 

Tongass, which converts to 74 percent of the acreage, are considered intact. After 

100+ years of implementation of the alternatives, giving consideration to additional 

harvest on non-NFS lands, these percentages would range from 60 percent of the 

watersheds (68 percent of the acreage) under Alternative 1 to 47 percent of the 

watersheds (57 percent of the acreage) under Alternative 7. Approximately 8 

percent of the drop in percentage of intact watersheds and 5 percent of the drop in 

acreage would be due to additional development on non-NFS lands. 
3 Environment and Effects

Biodiversity 3-180 Final EIS

Table 3.9-15 

Estimated Percent of Original High-Volume POG Remaining Forest-wide (1st number) and in 

Reserves (2nd number) in 100+ Years Assuming Maximum POG Harvest1

 under Each 

Alternative by Biogeographic Province

POG 

% of Original POG Remaining After 100+ Years 

(Forest-wide/In Reserves)

by Alternative 

No. 

Biogeographic 

Province 

Original 

Acres 

% Remaining 

in 2006 1 2 3 4 5 6 7 

1 Yakutat 

Forelands 31,015 93 93/93 87/78 79/61 75/56 78/61 78/61 74/56

2 Yakutat Uplands 11,614 92 92/92 92/90 91/89 90/87 91/89 91/89 90/87

3 East Chichagof 

Island 178,124 84 83/75 79/61 78/56 70/31 75/47 76/50 67/25

4 West Chichagof 

Island 17,223 100 100/100 100/100 100/100 100/100 100/100 100/100 100/100

5 East Baranof 

Island 37,072 77 77/77 70/49 69/46 63/24 66/39 67/42 60/24

6 West Baranof 

Island 64,001 83 83/83 81/75 80/71 74/49 79/71 79/71 72/49

7 Admiralty Island 307,613 98 98/98 98/98 98/98 98/98 98/97 98/98 98/98

8 Lynn Canal 63,368 95 94/92 91/78 89/74 78/42 85/64 86/66 77/42

9 North Coast 

Range 132,654 100 100/100 100/100 99/95 85/49 90/66 91/68 84/48

10 Kupreanof/Mitkof 

Island 121,135 81 76/66 71/53 67/45 56/25 61/35 61/36 51/19

11 Kuiu Island 174,993 90 90/90 82/72 80/68 69/43 75/59 75/59 66/43

12 Central Coast 

Range 107,789 96 96/96 95/92 89/74 82/58 86/66 86/68 81/59

13 Etolin Island & 

Vicinity 99,193 77 72/62 65/40 63/36 53/17 61/36 61/36 48/16

14 North Central 

Prince of Wales 343,711 66 60/46 58/40 56/37 51/29 55/34 54/35 44/20

15 Revilla Island/ 

Cleveland Pen. 241,884 88 86/80 83/70 81/67 71/45 79/61 79/62 67/42

16 Southern Outer 

Islands 52,674 82 78/69 75/62 74/61 71/52 73/59 73/60 67/50

17 Dall Island and 

Vicinity 33,260 99 99/99 99/99 99/97 95/86 96/89 96/89 92/83

18 South Prince of 

Wales 78,369 97 97/96 95/85 91/73 78/44 86/62 86/63 74/44

19 North Misty 

Fiords 67,130 99 99/99 97/95 97/91 95/85 97/91 97/91 94/85

20 South Misty 

Fiords 97,509 100 100/100 100/100 100/100 100/100 100/100 100/100 100/100

21 Ice Fields 39,039 93 93/91 93/87 92/81 90/76 90/80 91/81 90/76

Forest-wide 2,299,369 87 86/81 83/73 81/68 75/52 79/62 79/63 72/50

Additional Mature or Older Second 

Growth (110-160 yrs) on HighVolume Sites, Protected Forestwide3

 

0 11/5 8/3 8/2 7/2 7/2 7/2 6/1

1 The estimated suitable POG incorporates a reduction factor for the Model Implementation Reduction Factor (MIRF) and scheduling, which 

reduces mapped suitable acres to the estimated scheduled acres for each biogeographic province (see the Timber section). 2

 Percentage of original POG. Harvest of suitable old growth is estimated to occur until approximately until the year 2105 3

 Expressed as a percent of original High-Volume POG
 Environment and Effects 3 

Final EIS 3-181 Biodiversity 

Table 3.9-16 

Estimated Percent of Original Large-Tree POG (SD67) Remaining Forest-wide (1st number) and 

in Reserves (2nd number) in 100+ Years Assuming Maximum POG Harvest1 under Each 

Alternative by Biogeographic Province

POG 

% of Original POG Remaining After 100+ Years 

(Forest-wide/In Reserves)

by Alternative 

No. 

Biogeographic 

Province 

Original 

Acres 

% Remaining 

in 2006 1 2 3 4 5 6 7 

1 Yakutat Forelands 26,181 96 96/96 90/80 82/61 78/59 80/61 80/61 78/59

2 Yakutat Uplands 2,408 83 83/83 80/74 80/73 75/65 79/73 79/73 74/65

3 East Chichagof 

Island 47,335 73 72/65 71/55 70/52 64/31 69/47 70/49 62/26

4 West Chichagof 

Island 2,012 100 100/100 100/100 100/100 100/100 100/100 100/100 100/100

5 East Baranof 

Island 5,894 33 33/33 32/24 32/21 31/15 31/18 31/20 31/15

6 West Baranof 

Island 9,036 46 46/46 45/42 44/40 43/29 44/40 44/40 43/29

7 Admiralty Island 100,755 98 98/98 98/98 98/98 98/98 98/96 98/98 98/98

8 Lynn Canal 13,355 88 88/86 86/75 84/71 74/33 80/58 81/61 72/33

9 North Coast 

Range 22,536 100 100/100 100/100 99/96 81/33 88/61 91/65 78/33

10 Kupreanof/Mitkof 

Island 29,920 65 62/54 58/45 55/39 47/21 51/28 51/30 43/15

11 Kuiu Island 44,945 82 82/82 67/49 65/47 56/26 61/40 62/41 52/26

12 Central Coast 

Range 21,854 91 91/91 90/85 84/71 76/50 81/62 80/60 75/52

13 Etolin Island & 

Vicinity 22,847 54 50/41 46/29 44/27 36/12 42/26 43/27 33/11

14 North Central 

Prince of Wales 171,375 69 62/45 60/40 59/38 54/30 57/34 57/37 47/21

15 Revilla Island/ 

Cleveland Pen. 45,095 71 68/62 65/52 64/51 57/34 61/45 62/47 54/32

16 Southern Outer 

Islands 17,200 74 69/57 67/52 65/51 61/40 64/48 64/51 57/39

17 Dall Island and 

Vicinity 8,018 99 99/99 99/99 97/95 96/93 97/94 97/94 95/91

18 South Prince of 

Wales 44,283 98 98/96 94/83 91/74 78/41 87/62 87/64 73/41

19 North Misty Fiords 13,164 97 97/97 95/89 95/89 93/84 94/88 94/88 93/84

20 South Misty Fiords 14,142 100 100/100 100/100 100/100 100/100 100/100 100/100 100/100

21 Ice Fields 6,965 83 83/81 83/80 83/78 82/73 81/74 83/78 81/73

Forest-wide 669,321 80 78/71 75/64 73/60 68/46 71/54 72/56 64/43

Additional Mature or Older Second 

Growth (110-160 yrs) on SD67 

Sites, Protected Forest-wide3 

0 17/8 12/4 12/4 11/2 11/3 11/4 9/2

1 The estimated suitable POG incorporates a reduction factor for the Model Implementation Reduction Factor (MIRF) and scheduling, which 

reduces mapped suitable acres to the estimated scheduled acres for each biogeographic province (see the Timber section). 2

 Percentage of original POG. Harvest of suitable old growth is estimated to occur until approximately until the year 2105 3

 Expressed as a percent of original SD67 POG
3 Environment and Effects

Biodiversity 3-182 Final EIS

Table 3.9-17 

Estimated Percent of Original Karst POG Remaining Currently and in 100+ Years 

Assuming Maximum POG Harvest1 under Each Alternative

Karst POG 

% of Original Karst POG Remaining After 100+ Years 

by Alternative 

Original 

Acres 

% Remaining 

in 2006 1 2 3 4 5 6 7 

Low Elevation 

(<800 feet) 215,708 62% 58% 56% 55% 52% 54% 55% 47%

Moderate-High 

Elevation (>800 feet) 87,791 84% 82% 79% 78% 73% 76% 77% 70%

Total 303,499 69% 65% 63% 62% 58% 60% 61% 54%

Additional Mature or Older Second 

Growth (110-160 yrs) on Karst, 

Protected from Future Harvest3

0% 26% 17% 16% 14% 14% 15% 12%

1 The estimated suitable POG incorporates a reduction factor for the Model Implementation Reduction Factor (MIRF) and 

scheduling, which reduces mapped suitable acres to the estimated scheduled acres (see the Timber section). 2

 Percentage of original POG. Harvest of suitable old growth is estimated to occur until approximately until the year 2105 3

 Expressed as a percent of original SD67 POG

Effects by Alternative 

The following subsections summarize the biodiversity effects associated with each 

alternative with reference to the data presented in Tables 3.9-12, 3.9-13, 3.9-14, 

3.9-15, 3.9-16, 3.9-17, 3.9-18, and 3.9-19. 

Alternative 1 

Alternative 1 would have the lowest effect on biodiversity among the alternatives, 

primarily because it would result in the lowest harvest and the highest POG acreage 

in reserves. Although this alternative was not specifically evaluated in the 1996 

panel assessment, based on its level of harvest and other factors considered in the 

assessment, it is clear that the assessment would have confirmed this ranking. 

Alternative 1 would maintain 93 percent of the existing POG within reserves and an 

additional 5 percent would be protected in the matrix by standards and guidelines or 

not scheduled for harvest. As a result, only 2 percent or 86,000 acres would be 

subject to harvest (Table 3.9-12). Long-term maximum harvest of high-volume and 

large-tree POG are also projected to be in the 2 to 3 percent range. In addition, 

there would be about 398,000 acres of existing productive young growth that would 

not be harvested and that would eventually develop into mature forest and then 

POG (Table 3.9-13). This represents about four times as much as the maximum 

POG harvest. 

Assuming maximum harvest over 100+ years, approximately 90 percent of the 

original POG would remain Forest-wide; 85 percent of the original POG would be in 

reserves (Table 3.9-14). Harvest would be conducted in 9 out of 21 provinces 

occupied by the Tongass, but only 5 provinces would have potential harvest 

exceeding 5,000 acres. At least 15 of the 21 provinces would have more than 90 

percent of their original POG remaining after 100+ years, and only 1 province, North 

Central Prince of Wales, would have less than 75 percent remaining (Table 3.9-14). 
 Environment and Effects 3 

Final EIS 3-183 Biodiversity 

Table 3.9-18 

Estimated Percentage of Original POG Remaining Forest-wide in 100+ Years Assuming 

Maximum POG Harvest1

 under Each Alternative by Ecological Subsection 

Alternative 

Ecological Section (Bold) 

and Subsection Names 

Original 

POG Acres 

Remaining 

POG in 2006 

as a Percent 

of Original 

POG 1 2 3 4 5 6 7 

St. Elias-Fairweather Icefields 

St. Elias-Fairweather 

Icefields 9,147 93% 93% 93% 93% 83% 85% 87% 80% 

Puget Peninsula 

Metasediments 7,290 100% 100% 100% 100% 100% 100% 100% 100% 

Northern Gulf Forelands 

Yakutat-Lituya Forelands 63,945 92% 92% 89% 85% 82% 83% 83% 81% 

Chilkat River Complex 

Chilkat Complex 1,759 100% 100% 100% 100% 100% 100% 100% 100% 

Boundary Ranges 

Boundary Ranges Icefields 247,947 98% 98% 97% 97% 94% 96% 96% 93% 

Stikine-Taku River Valleys 33,612 100% 100% 100% 100% 100% 100% 100% 100% 

Glacier Bay Fiordlands 

Wachusett-Adams Hills 229 100% 100% 100% 100% 100% 100% 100% 100% 

Berg Bay Complex 5,223 100% 100% 100% 100% 100% 100% 100% 100% 

Chilkat Peninsula 

Carbonates 81,944 94% 94% 89% 89% 75% 83% 83% 73% 

Baranof-Chichagof Fiordlands 

North Chichagof Granitics 99,381 97% 97% 96% 95% 91% 94% 94% 90% 

Outer Coast Wave-cut 

Terraces 37,756 100% 100% 100% 100% 99% 100% 100% 99% 

West Chichagof Complex 29,885 100% 100% 100% 100% 100% 100% 100% 100% 

Ushk-Patterson Bay 

Granitics 44,015 96% 95% 95% 95% 87% 88% 89% 86% 

Peril Strait Granitics 112,526 90% 90% 86% 83% 72% 77% 78% 70% 

North Baranof Complex 65,323 82% 82% 75% 74% 63% 69% 70% 61% 

Sitka Sound Complex 82,921 91% 90% 87% 85% 70% 84% 84% 67% 

Mount Edgecumbe 

Volcanics 27,352 86% 86% 82% 79% 76% 78% 78% 74% 

Central Baranof 

Metasediments 42,324 89% 89% 88% 86% 82% 85% 85% 82% 

Necker Bay Granitics 40,686 100% 100% 100% 100% 100% 100% 100% 100% 

South Baranof Sediments 36,320 100% 100% 100% 100% 100% 100% 100% 100% 

Northeast Chichagof Fiordlands 

Point Adolphus Carbonates 43,858 95% 95% 90% 89% 76% 88% 88% 75% 

Freshwater Bay 

Carbonates 114,959 86% 81% 75% 75% 69% 72% 73% 60% 

Kook Lake Carbonates 59,098 82% 80% 76% 73% 65% 70% 71% 64% 

Kootznoowoo Fiordlands

Stephens Passage 

Glaciomarine Terraces 129,536 100% 100% 99% 98% 96% 95% 97% 95% 

North Admiralty Complex 126,913 100% 100% 100% 100% 100% 100% 100% 100% 

Stephens Passage 

Volcanics 49,914 97% 96% 96% 96% 93% 96% 96% 96% 

Thayer Lake Granitics 45,630 100% 100% 100% 100% 100% 100% 100% 100% 

Mitchell-Hasselborg Till 

Lowlands 62,653 100% 100% 100% 100% 100% 100% 100% 100% 

Hood-Gambier Bay 

Carbonates 144,261 100% 100% 100% 100% 100% 100% 100% 100% 

South Admiralty Volcanics 102,890 97% 95% 95% 95% 95% 95% 95% 95% 
3 Environment and Effects

Biodiversity 3-184 Final EIS

Table 3.9-18 (continued) 

Estimated Percentage of Original POG Remaining Forest-wide in 100+ Years Assuming 

Maximum POG Harvest1

 under Each Alternative by Ecological Subsection 

Alternative 

Ecological Section (Bold) 

and Subsection Names 

Original 

POG Acres 

Remaining 

POG in 2006 

as a Percent 

of Original 

POG 1 2 3 4 5 6 7 

Inside Passage Fiordlands

Holkham Bay Complex 258,587 100% 100% 100% 98% 86% 90% 90% 84% 

Cape Fanshaw Complex 43,579 100% 99% 99% 97% 61% 71% 75% 57% 

Thomas Bay Outwash 

Plains 14,538 70% 70% 62% 56% 47% 54% 55% 44% 

Wrangell Narrows 

Metasediments 160,511 85% 76% 67% 64% 56% 62% 62% 51% 

Eastern Passage Complex 114,036 98% 98% 96% 85% 78% 83% 83% 76% 

Stikine River Delta 25,010 89% 83% 82% 82% 82% 82% 82% 81% 

Bell Island Granitics 139,862 97% 96% 94% 91% 89% 91% 91% 87% 

Stikine Strait Complex 32,029 90% 86% 75% 73% 56% 72% 72% 49% 

Etolin Granitics 32,088 95% 92% 84% 81% 72% 78% 80% 68% 

Zimovia Strait Complex 103,961 90% 85% 79% 71% 58% 68% 69% 53% 

Clarence Strait Volcanics 86,738 99% 98% 95% 94% 79% 94% 94% 75% 

Ketchikan 

Mafics/Ultramafics 21,499 99% 98% 96% 96% 95% 84% 84% 72% 

Vixen Inlet Till Lowlands 10,068 100% 100% 100% 100% 82% 84% 83% 66% 

Traitors Cove 

Metasediments 162,948 86% 81% 77% 76% 62% 70% 70% 58% 

Behm Canal Complex 92,329 94% 92% 90% 90% 85% 89% 89% 84% 

Kuiu-Prince of Wales Fiordlands

Kuiu-POW Granitics 85,962 95% 93% 92% 90% 83% 89% 89% 80% 

Rowan Sediments 109,770 85% 85% 72% 71% 66% 69% 69% 64% 

North POW-Kuiu 

Carbonates 190,444 58% 52% 50% 49% 45% 48% 48% 41% 

Alvin Bay Sediments 57,548 99% 98% 98% 98% 79% 88% 88% 74% 

Affleck Canal Till Lowlands 27,386 100% 100% 100% 100% 82% 100% 100% 77% 

North POW Complex 50,227 85% 82% 81% 80% 78% 77% 77% 72% 

Elevenmile Till Lowlands 14,899 98% 97% 88% 88% 75% 87% 86% 69% 

Gulf of Esquibel Till 

Lowlands 14,828 100% 100% 100% 100% 100% 100% 100% 100% 

Klawock Inlet Till Lowlands 755 88% 88% 88% 88% 88% 88% 88% 88% 

Soda Bay Till Lowlands 40,933 99% 99% 99% 94% 90% 88% 89% 80% 

Kupreanof Lowlands

Kake Volcanics 40,175 83% 77% 71% 69% 62% 65% 67% 59% 

Duncan Canal Till 

Lowlands 83,581 91% 86% 80% 76% 65% 69% 70% 58% 

Sumner Strait Volcanics 167,966 93% 90% 88% 81% 64% 71% 71% 60% 

Central POW Till Lowlands 133,163 75% 69% 69% 68% 66% 67% 67% 59% 

Kasaan Peninsula 

Volcanics 4,197 100% 93% 93% 92% 91% 92% 91% 59% 

Skowl Arm Till Lowlands 21,442 94% 92% 87% 79% 73% 79% 77% 67% 

Outer Islands Fiordlands

Outer Islands Complex 19,013 100% 100% 100% 100% 100% 100% 100% 100% 

Dall-Outside Complex 125,992 99% 97% 97% 95% 91% 93% 92% 89% 

Prince of Wales Mountains

Central POW Volcanics 244,092 72% 66% 64% 61% 56% 60% 60% 48% 

Hetta Inlet Metasediments 85,030 85% 82% 77% 76% 64% 71% 71% 59% 

Moira Sound Complex 57,828 100% 100% 99% 91% 81% 88% 87% 77% 
 Environment and Effects 3 

Final EIS 3-185 Biodiversity 

Table 3.9-18 (continued) 

Estimated Percentage of Original POG Remaining Forest-wide in 100+ Years Assuming 

Maximum POG Harvest1

 under Each Alternative by Ecological Subsection 

Alternative 

Ecological Section (Bold) 

and Subsection Names 

Original 

POG Acres 

Remaining 

POG in 2006 

as a Percent 

of Original 

POG 1 2 3 4 5 6 7 

Dixon Entrance Lowlands

South POW Granitics 244,092 100% 100% 100% 97% 92% 96% 97% 91% 

Duke Island Till Lowlands 85,030 100% 97% 97% 97% 97% 97% 97% 97% 

Thorne Arm Granitics 57,828 91% 88% 81% 81% 80% 80% 80% 78% 

Princess Bay Volcanics 244,092 83% 79% 76% 75% 73% 76% 75% 71% 

Foggy Bay Till Lowlands 85,030 100% 100% 100% 100% 100% 100% 100% 100% 

Boca De Quadra Complex 57,828 100% 100% 100% 100% 100% 100% 100% 100% 

Coast Mountain Batholith Fiordlands

Misty Fiords Granitics 388,315 100% 100% 100% 100% 100% 100% 100% 100% 

Totals 5,405,873 92% 90% 88% 86% 79% 83% 83% 77% 1

 The estimated suitable POG incorporates a reduction factor for the Model Implementation Reduction Factor (MIRF) and scheduling, 

which reduces mapped suitable acres to the estimated scheduled acres for each ecological subsection (see the Timber section). 

Relative to the largest tree categories, after 100+ years of maximum implementation 

of Alternative 1, 86 percent of the original high-volume POG and 78 percent of the 

original large-tree POG would remain, with the vast majority of these acres in 

reserves (Tables 3.9-15 and 3.9-16). At least 13 of the provinces would maintain 90 

percent or more of their original high-volume POG and 2 provinces would maintain 

less than 75 percent (minimum = 60 percent for North Central Prince of Wales) 

(Table 3.9-15). Relative to large-tree POG, at least 9 provinces would maintain 90 

percent or more of their original acres and 8 provinces would have less than 75 

percent (minimum = 33 percent for East Baranof) (Table 3.9-16). 

Implementation of Alternative 1 would result in a maximum reduction of the karst 

POG on the Tongass from 69 percent of the original karst POG at present, to 65 

percent after 100+ years. Low elevation karst POG would be reduced from 62 

percent currently, to 58 percent (Table 3.9-17). 

Long-term POG representation by ecological subsection would be maintained under 

Alternative 1 by protecting at least 52 percent of the original POG on NFS lands in 

all 73 subsections (Table 3.9-18). At least 90 percent of original POG would be 

maintained in 51 of the 73 subsections and at least 75 percent would be maintained 

in 69 out of the 73 subsections. 

If one considers the regrowth of current young growth that would be protected under 

this alternative (Table 3.9-13), after 100+ years the equivalent of an additional 7 

percent of the original POG acres would be in mature forest stands and some 

stands would be at the beginning stages of exhibiting older forest characteristics 

(Table 3.9-14). Similarly, an additional 11 percent of the original high-volume POG, 

17 percent of the original large-tree POG, and 26 percent of the original karst POG 

would be in mature forest stages (Tables 3.9-15, 3.9-16, and 3.9-17, respectively). 

In summary, after 100+ years of implementation under Alternative 1, 97 percent of 

the original POG would be remaining as POG or in mature forest stages. Likewise, 

97 percent of the original high-volume POG would still be in high-volume POG or in 

mature forest stages, 95 percent of the original large-tree POG would be remaining 

as large-tree POG or in mature forest stages, and 91 percent of the original karst 

POG would be remaining as POG or in mature forest stages. 
3 Environment and Effects

Biodiversity 3-186 Final EIS

Alternative 1 would result in the additional conversion of intact large watersheds to a 

modified condition. After 100+ years of implementation under maximum harvest, the 

percentage of intact watersheds would be reduced from 69 percent to 60 percent of 

the Tongass. Similarly, the percentage of the land area of the Tongass in intact 

watersheds would be reduced from 74 percent to 68 percent (Table 3.9-19). 

However, the majority of this reduction would occur as a result of additional 

development on non-NFS lands, even if no additional Tongass harvest occurred. 

Approximately 8 percentage points of the drop in percentage of intact watersheds 

and 5 percentage points of the drop in acreage are due to additional development 

on non-NFS lands. 

Table 3.9-19 

Estimated Percent of All Large Watersheds1

 in each Biogeographic Province Defined as Intact2

After 100+ Years3

 of Forest Plan Implementation under Each Alternative

Number and 

Acreage of All 

Large Watersheds 

% of All Large Watersheds Defined as Intact 

Under Existing Conditions and After 100+ Years by Alternative 

 (% of number of watersheds/% of acreage)

No. 

Biogeographic 

Province No. Acres Existing 1 2 3 4 5 6 7 

1 Yakutat Forelands 24 344,231 83/80 67/73 63/72 58/71 58/71 58/71 58/71 58/71 

2 Yakutat Uplands 26 916,929 96/99 96/99 96/99 96/99 96/99 96/99 96/99 96/99 

3 East Chichagof 

Island 87 1,129,840 53/49 52/47 51/45 48/43 33/27 37/29 41/34 31/26 

4 West Chichagof 

Island 31 287,518 100/100 97/99 97/99 97/99 97/99 97/99 97/99 97/99 

5 East Baranof 

Island 22 394,381 55/60 45/49 45/49 45/49 45/49 45/49 45/49 45/49 

6 West Baranof 

Island 43 797,901 65/69 58/65 58/65 56/64 47/54 53/57 53/57 47/54 

7 Admiralty Island 60 1,085,689 88/85 82/80 82/80 82/80 82/80 82/80 82/80 82/80 

8 Lynn Canal 50 671,845 76/80 56/64 56/64 50/59 32/45 42/51 44/53 32/45 

9 North Coast 

Range 49 1,111,396 90/94 67/80 67/80 67/80 31/54 39/59 39/59 31/54 

10 Kupreanof/Mitkof 

Island 35 842,334 37/39 31/30 29/29 20/20 9/8 11/11 11/11 9/8 

11 Kuiu Island 30 493,252 73/60 73/60 73/60 73/60 47/34 67/55 67/55 47/34 

12 Central Coast 

Range 29 729,163 79/85 72/77 66/73 52/57 38/53 38/51 38/51 38/51 

13 Etolin Island & 

Vicinity 27 518,932 33/30 26/23 22/19 19/17 11/12 19/17 19/17 11/12 

14 North Central 

Prince of Wales 116 1,488,826 24/17 20/13 19/13 16/10 12/8 12/9 12/10 10/6 

15 Revilla Island/ 

Cleveland Pen. 84 1,347,381 68/71 55/60 51/58 49/57 37/44 39/47 39/47 33/43 

16 Southern Outer 

Islands 20 223,986 50/64 50/64 45/60 45/60 45/59 45/60 45/60 45/59 

17 Dall Island and 

Vicinity 35 200,222 71/53 34/19 34/19 31/16 29/15 29/15 29/15 29/15 

18 South Prince of 

Wales 36 395,076 78/75 72/69 69/65 56/51 47/45 50/46 50/46 47/45 

19 North Misty Fiords 32 975,904 94/96 94/96 91/93 88/91 88/91 88/91 88/91 88/91 

20 South Misty Fiords 54 906,047 100/100 100/100 100/10

0 100/100 100/100 100/100 100/100 100/100 

21 Ice Fields 57 3,006,309 93/94 88/92 86/91 84/90 84/89 82/89 84/90 82/88 

Forest-wide 947 17,867,163 69/74 60/68 59/67 56/65 48/58 50/60 51/60 47/57 1 Large watersheds are defined here as VCUs. 

2

 Intact is defined here as having less than 5 percent of original POG harvested and not containing other major disturbances. 3 Considers past and future harvest on private and other non-NFS lands.
 Environment and Effects 3 

Final EIS 3-187 Biodiversity 

Alternative 2 

Alternative 2 would rank second lowest in terms of effects on biodiversity primarily 

because it would result in the second lowest POG harvest and the second highest 

POG acreage in reserves. Although this alternative was not specifically evaluated in 

the 1996 panel assessment, based on its level of harvest and other factors 

considered in the assessment, it is clear that the assessment would have confirmed 

this ranking. 

Under Alternative 2, approximately 84 percent of all existing POG would be 

maintained within reserves. Standards and guidelines would protect an additional 

11 percent of the existing POG from harvest and the maximum POG potentially 

harvested would be approximately 215,000 acres or 4 percent (Table 3.9-12). Longterm maximum harvest of high-volume and large-tree POG are projected to be in the 

4 to 5 percent range. In addition, there would be about 286,000 acres of existing 

productive young growth that would not be harvested and that would eventually 

develop into mature forest and then POG (Table 3.9-13). This represents a longterm replacement for over 100 percent of the future maximum POG harvest. 

Assuming maximum harvest over 100+ years, approximately 88 percent of the 

original POG would remain Forest-wide; 77 percent of the original POG would be in 

reserves (Table 3.9-14). Harvest would be spread over 18 out of 21 provinces 

occupied by the Tongass, but only 8 provinces would have potential harvest 

exceeding 5,000 acres. At least 12 of the 21 provinces would have 90 percent or 

more of their original POG remaining after 100+ years, and only 2 provinces (North 

Central Prince of Wales and Etolin & Vicinity) would have less than 75 percent 

remaining (Table 3.9-14). 

Relative to the largest tree categories, after 100+ years of maximum implementation 

of Alternative 2, 83 percent of the original high-volume POG and 75 percent of the 

original large-tree POG would remain, with the vast majority of these acres in 

reserves (Tables 3.9-15 and 3.9-16). At least 11 of the provinces would maintain 90 

percent or more of their original high-volume POG and 4 provinces would maintain 

less than 75 percent (minimum = 58 percent for North Central Prince of Wales) 

(Table 3.9-15). Relative to large-tree POG, at least 9 provinces would maintain 90 

percent or more of their original acres and 9 provinces would have less than 75 

percent (minimum = 32 percent for East Baranof) (Table 3.9-16). 

Implementation of Alternative 2 would result in a maximum reduction of the karst 

POG on the Tongass from 69 percent of the original karst POG at present, to 63 

percent after 100+ years. Low elevation karst POG would be reduced from 62 

percent currently, to 56 percent (Table 3.9-17). 

Long-term POG representation by ecological subsection would be maintained under 

Alternative 2 by protecting at least 50 percent of original POG in all 73 subsections 

(Table 3.9-18). At least 90 percent of original POG would be maintained in 43 of the 

73 subsections and at least 75 percent would be maintained in 66 out of the 73 

subsections. 

If one considers the regrowth of current young growth that would be protected under 

this alternative (Table 3.9-13), after 100+ years the equivalent of an additional 5 

percent of the original POG acres would be in mature forest stands and some 

stands would be at the beginning stages of exhibiting older forest characteristics 

(Table 3.9-14). Similarly, an additional 8 percent of the original high-volume POG, 

12 percent of the original large-tree POG, and 17 percent of the original karst POG 

would be in mature forest stages (Tables 3.9-15, 3.9-16, and 3.9-17, respectively). 

In summary, after 100+ years of implementation under Alternative 2, 93 percent of 

the original POG would be remaining as POG or in mature forest stages. Likewise, 

91 percent of the original high-volume POG would still be in high-volume POG or in 
3 Environment and Effects

Biodiversity 3-188 Final EIS

mature forest stages, 87 percent of the original large-tree POG would be remaining 

as large-tree POG or in mature forest stages, and 80 percent of the original karst 

POG would be remaining as POG or in mature forest stages. 

Alternative 2 would result in the additional conversion of intact large watersheds to a 

modified condition. After 100+ years of implementation under maximum harvest, the 

percentage of intact watersheds would be reduced from 69 percent to 59 percent of 

the Tongass. Similarly, the percentage of the land area of the Tongass in intact 

watersheds would be reduced from 74 percent to 67 percent (Table 3.9-19). 

However, the majority of this reduction would occur as a result of additional 

development on non-NFS lands, even if no additional Tongass harvest occurred. 

Approximately 8 percentage points of the drop in percentage of intact watersheds 

and 5 percentage points of the drop in acreage are due to additional development 

on non-NFS lands. 

Alternative 3 

Alternative 3 would rank third lowest in terms of effects on biodiversity primarily 

because it would result in the third lowest POG harvest and the third highest POG 

acreage in reserves. Although this alternative was not specifically evaluated in the 

1996 panel assessment, based on its level of harvest and other factors considered 

in the assessment, it is clear that the assessment would have confirmed this 

ranking. 

Alternative 3 would maintain approximately 78 percent of all existing POG would be 

maintained within reserves. Standards and guidelines would protect an additional 

16 percent of the existing POG from harvest and the maximum POG potentially 

harvested would be approximately 313,000 acres or 6 percent (Table 3.9-12). Longterm maximum harvest of high-volume and large-tree POG are projected to be in the 

7 to 8 percent range. In addition, there would be about 270,000 acres of existing 

productive young growth that would not be harvested and that would eventually 

develop into mature forest and then POG (Table 3.9-13). This represents a longterm replacement for over 86 percent of the future maximum POG harvest. 

Assuming maximum harvest over 100+ years, approximately 86 percent of the 

original POG would remain Forest-wide; 72 percent of the original POG would be in 

reserves (Table 3.9-14). Harvest would be spread over 18 out of 21 provinces 

occupied by the Tongass, but only 12 provinces would have potential harvest 

exceeding 5,000 acres. At least 11 of the 21 provinces would have 90 percent or 

more of their original POG remaining after 100+ years, and only 2 provinces (North 

Central Prince of Wales and Etolin & Vicinity) would have less than 75 percent 

remaining (Table 3.9-14). 

Relative to the largest tree categories, after 100+ years of maximum implementation 

of Alternative 3, 81 percent of the original high-volume POG and 73 percent of the 

original large-tree POG would remain, with the vast majority of these acres in 

reserves (Tables 3.9-15 and 3.9-16). At least 9 of the provinces would maintain 90 

percent or more of their original high-volume POG and 5 provinces would maintain 

less than 75 percent (minimum = 56 percent for North Central Prince of Wales) 

(Table 3.9-15). Relative to large-tree POG, at least 7 provinces would maintain 90 

percent or more of their original acres and 9 provinces would have less than 75 

percent (minimum = 32 percent for East Baranof) (Table 3.9-16). 

Implementation of Alternative 3 would result in a maximum reduction of the karst 

POG on the Tongass from 69 percent of the original karst POG at present, to 62 

percent after 100+ years. Low elevation karst POG would be reduced from 62 

percent currently, to 55 percent (Table 3.9-17). 
 Environment and Effects 3 

Final EIS 3-189 Biodiversity 

Long-term POG representation by ecological subsection would be maintained under 

Alternative 3 by protecting at least 49 percent of original POG in all 73 subsections 

(Table 3.9-18). At least 90 percent of original POG would be maintained in 41 of the 

73 subsections and at least 75 percent would be maintained in 62 out of the 73 

subsections. The one subsection with less than 50 percent of its original POG, 

North POW-Kuiu Carbonates, would still maintain about 94,000 acres of POG. 

If one considers the regrowth of current young growth that would be protected under 

this alternative (Table 3.9-13), after 100+ years the equivalent of an additional 5 

percent of the original POG acres would be in mature forest stands and some 

stands would be at the beginning stages of exhibiting older forest characteristics 

(Table 3.9-14). Similarly, an additional 8 percent of the original high-volume POG, 

12 percent of the original large-tree POG, and 16 percent of the original karst POG 

would be in mature forest stages (Tables 3.9-15, 3.9-16, and 3.9-17, respectively). 

In summary, after 100+ years of implementation under Alternative 2, 91 percent of 

the original POG would be remaining as POG or in mature forest stages. Likewise, 

89 percent of the original high-volume POG would still be in high-volume POG or in 

mature forest stages, 85 percent of the original large-tree POG would be remaining 

as large-tree POG or in mature forest stages, and 78 percent of the original karst 

POG would be remaining as POG or in mature forest stages. 

Alternative 3 would result in the additional conversion of intact large watersheds to a 

modified condition. After 100+ years of implementation under maximum harvest, the 

percentage of intact watersheds would be reduced from 69 percent to 56 percent of 

the Tongass. Similarly, the percentage of the land area of the Tongass in intact 

watersheds would be reduced from 74 percent to 65 percent (Table 3.9-19). 

However, the majority of this reduction would occur as a result of additional 

development on non-NFS lands, even if no additional Tongass harvest occurred. 

Approximately 8 percentage points of the drop in percentage of intact watersheds 

and 5 percentage points of the drop in acreage are due to additional development 

on non-NFS lands. 

Alternative 4 

With several important exceptions, Alternative 4 is similar to most aspects of the 

current Forest Plan (Alternative 5). Most importantly, however, it would have fewer 

old-growth reserves. The Old-Growth Habitat LUD is used in only four provinces 

(plus a few individual reserves), but other non-development LUDs provide some 

reserves in all provinces. It also includes additional requirements of maintaining 33 

percent of the old growth in each VCU and not harvesting more than 50 percent of 

the POG within a 50-year period. However, there is no requirement to consider 

spacing, location, size, shape, or composition in the design of the retained acres; as 

a result, Alternative 4 would not provide as much protection to the conservation of 

biodiversity if the retained acres are widely distributed, in small parcels, linear in 

shape, or do not protect important habitat features (e.g., important deer winter 

range, under-represented forest plant associations, or suspected goshawk nesting 

habitat). Alternative 4 would have the same beach and estuary fringe and riparian 

buffers as Alternative 5 that would enhance connectivity within the matrix, but would 

not include the goshawk and marten or the legacy forest structure standards and 

guidelines that require retention trees in harvest units within specific VCUs. 

Alternative 4 is based on, and is similar to, the 1997 Alternative 6, which was 

evaluated in the 1997 Forest Plan Revision FEIS (see Chapter 2); therefore, the 

conclusions of the 1997 old-growth panel assessment can be extended to the 

current Alternative 4. The panel assessment concluded that this alternative was 

ranked in the middle group of the alternatives evaluated by the panel. As such, it 

ranked better than our 2007 Alternative 7 but, through comparisons with acreage 
3 Environment and Effects

Biodiversity 3-190 Final EIS

harvested and other alternative components, it would have ranked worse than all of 

the other 2007 alternatives in terms of effects on biodiversity. In addition to the 

acres of harvest, the primary factor associated with this ranking is the absence of 

reserves over relatively large areas of the Tongass. The old-growth network was 

specifically designed to ensure the maintenance of well-distributed viable 

populations of all old-growth associated wildlife species across the Tongass. The 

1996 panel assessment concluded that alternatives that did not emphasize the oldgrowth reserve network had the highest potentials to create biodiversity concerns 

within biogeographic provinces over the long term. 

Moreover, the old-growth network was specifically designed to ensure the 

maintenance of well-distributed viable populations of all old-growth associated 

wildlife species across the Tongass. The 1997 FEIS panel assessment concluded 

that alternatives that did not include the OGR system have the highest potentials to 

create biodiversity concerns within biogeographic provinces over the long term. 

Therefore, by default, the reduction of this component of the conservation strategy 

under Alternative 4 would be expected to result in a greater loss of biodiversity 

relative to the current Forest Plan. This is particularly relevant in the Etolin and 

Revilla Island/Cleveland Peninsula biogeographic provinces where a substantial 

amount of timber harvest is proposed but where no reserve system or a very limited 

reserve system would be in place, respectively. 

Alternative 4 would include 60 percent of the existing POG within reserves and an 

additional 27 percent would be protected within the matrix by standards and 

guidelines or not scheduled for harvest. As a result, about 13 percent, or 656,000 

acres, would be subject to harvest (Table 3.9-12). Long-term maximum harvest of 

existing high-volume and large-tree POG are projected to be in the 15 to 16 percent 

range. In addition, there would be about 243,000 acres of existing productive young 

growth that would not be harvested and that would eventually develop into mature 

forest and then POG (Table 3.9-13). This represents a long-term replacement for 

about 37 percent of the future maximum POG harvest. 

Assuming maximum harvest over 100+ years, approximately 79 percent of the 

original POG would remain Forest-wide; 55 percent of the original POG would be in 

reserves (Table 3.9-14). Harvest would be spread over 20 out of the 21 provinces, 

and 15 provinces would have potential harvest exceeding 5,000 acres. At least 7 of 

the 21 provinces would have more than 90 percent of their original POG remaining 

after 100+ years, and 5 provinces (North Central Prince of Wales, Kupreanof/Mitkof, 

Etolin & Vicinity, Kuiu, and East Baranof) would have less than 75 percent remaining 

(Table 3.9-14). 

Relative to the largest tree categories, after 100+ years of maximum implementation 

of Alternative 4, 75 percent of the original high-volume POG and 68 percent of the 

original large-tree POG would remain, with the majority of these acres in reserves 

(Tables 3.9-15 and 3.9-16). At least 7 provinces would maintain 90 percent or more 

of their original high-volume POG and 9 provinces would maintain less than 75 

percent (minimum = 51 percent for North Central Prince of Wales) (Table 3.9-15). 

Relative to large-tree POG, at least 5 provinces would maintain 90 percent or more 

of their original acres and 10 provinces would have less than 75 percent (minimum = 

31 percent for East Baranof) (Table 3.9-16). 

Implementation of Alternative 4 would result in a maximum reduction of the karst 

POG on the Tongass from 69 percent of the original karst POG at present, to 58 

percent after 100+ years. Low elevation karst POG would be reduced from 62 

percent currently, to 52 percent (Table 3.9-17). 

Long-term POG representation by ecological subsection would be maintained under 

Alternative 4 by protecting at least 45 percent of original POG in all 73 subsections 
 Environment and Effects 3 

Final EIS 3-191 Biodiversity 

(Table 3.9-18). At least 90 percent of original POG would be maintained in 29 of the 

73 subsections and at least 75 percent would be maintained in 51 out of the 73 

subsections. Two subsections, North POW-Kuiu Carbonates and Thomas Bay 

Outwash Plains, would have with less than 50 percent of their original POG 

remaining after 100+ years. North POW-Kuiu Carbonates would maintain about 

86,000 acres of POG and Thomas Bay Outwash Plains would maintain about 7,000 

acres of POG. 

If one considers the regrowth of current young growth that would be protected under 

this alternative (Table 3.9-13), after 100+ years the equivalent of an additional 4 

percent of the original POG acres would be in mature forest stands and some 

stands would be at the beginning stages of exhibiting older forest characteristics 

(Table 3.9-14). Similarly, an additional 7 percent of the original high-volume POG, 

11 percent of the original large-tree POG, and 14 percent of the original karst POG 

would be in mature forest stages (Tables 3.9-15, 3.9-16, and 3.9-17, respectively). 

In summary, after 100+ years of implementation under Alternative 4, 83 percent of 

the original POG would be remaining as POG or in mature forest stages. Likewise, 

82 percent of the original high-volume POG would still be in high-volume POG or in 

mature forest stages, 79 percent of the original large-tree POG would be remaining 

as large-tree POG or in mature forest stages, and 72 percent of the original karst 

POG would be remaining as POG or in mature forest stages. 

Alternative 4 would result in the additional conversion of intact large watersheds to a 

modified condition. After 100+ years of implementation under maximum harvest, the 

percentage of intact watersheds would be reduced from 69 percent to 48 percent of 

the Tongass. Similarly, the percentage of the land area of the Tongass in intact 

watersheds would be reduced from 74 percent to 58 percent (Table 3.9-19). 

However, a portion of this reduction would occur as a result of additional 

development on non-NFS lands, even if no additional Tongass harvest occurred. 

Approximately 8 percentage points of the drop in percentage of intact watersheds 

and 5 percentage points of the drop in acreage are due to additional development 

on non-NFS lands. 

Alternative 5 

Alternative 5 represents the current Forest Plan. Although this alternative was not 

specifically evaluated in the 1996 panel assessment, based on its level of harvest 

and other factors considered in the assessment, it is clear that it would rate as 

having a lower effect on biodiversity than Alternatives 4 and 7 and a higher effect 

than Alternatives 1, 2, 3, or 6. 

Alternative 5 would maintain 71 percent of the existing POG within reserves and an 

additional 20 percent would be protected within the matrix by standards and 

guidelines or not scheduled for harvest. As a result, about 9 percent, or 463,000 

acres, would be subject to harvest (Table 3.9-12). Long-term maximum harvest of 

high-volume and large-tree POG are projected to be in the 10 to 11 percent range. 

In addition, there would be about 250,000 acres of existing productive young growth 

that would not be harvested and that would eventually develop into mature forest 

and then POG (Table 3.9-13). This represents a long-term replacement for about 

54 percent of the future maximum POG harvest. 

Assuming maximum harvest over 100+ years, approximately 83 percent of the 

original POG would remain Forest-wide; 65 percent of the original POG would be in 

reserves (Table 3.9-14). Harvest would be spread over 19 out of the 21 provinces, 

but only 14 provinces would have potential harvest exceeding 5,000 acres. At least 

8 of the 21 provinces would have more than 90 percent of their original POG 

remaining after 100+ years, and 3 provinces (North Central Prince of Wales, 
3 Environment and Effects

Biodiversity 3-192 Final EIS

Kupreanof/Mitkof, and Etolin & Vicinity) would have less than 75 percent remaining 

(Table 3.9-14). 

Relative to the largest tree categories, after 100+ years of maximum implementation 

of Alternative 5, 79 percent of the original high-volume POG and 71 percent of the 

original large-tree POG would remain, with the majority of these acres in reserves 

(Tables 3.9-15 and 3.9-16). At least 8 provinces would maintain 90 percent or more 

of their original high-volume POG and 5 provinces would maintain less than 75 

percent (minimum = 55 percent for North Central Prince of Wales) (Table 3.9-15). 

Relative to large-tree POG, at least 5 provinces would maintain 90 percent or more 

of their original acres and 9 provinces would have less than 75 percent (minimum = 

31 percent for East Baranof) (Table 3.9-16). 

Implementation of Alternative 5 would result in a maximum reduction of the karst 

POG on the Tongass from 69 percent of the original karst POG at present, to 60 

percent after 100+ years. Low elevation karst POG would be reduced from 62 

percent currently, to 54 percent (Table 3.9-17). 

Long-term POG representation by ecological subsection would be maintained under 

Alternative 5 by protecting at least 48 percent of original POG in all 73 subsections 

(Table 3.9-18). At least 90 percent of original POG would be maintained in 31 of the 

73 subsections and at least 75 percent would be maintained in 56 out of the 73 

subsections. One subsection, North POW-Kuiu Carbonates, would have with less 

than 50 percent of its original POG remaining after 100+ years, but would still 

maintain about 91,000 acres. 

If one considers the regrowth of current young growth that would be protected under 

this alternative (Table 3.9-13), after 100+ years the equivalent of an additional 5 

percent of the original POG acres would be in mature forest stands and some 

stands would be at the beginning stages of exhibiting older forest characteristics 

(Table 3.9-14). Similarly, an additional 7 percent of the original high-volume POG, 

11 percent of the original large-tree POG, and 14 percent of the original karst POG 

would be in mature forest stages (Tables 3.9-15, 3.9-16, and 3.9-17, respectively). 

In summary, after 100+ years of implementation under Alternative 5, 88 percent of 

the original POG would be remaining as POG or in mature forest stages. Likewise, 

86 percent of the original high-volume POG would still be in high-volume POG or in 

mature forest stages, 82 percent of the original large-tree POG would be remaining 

as large-tree POG or in mature forest stages, and 74 percent of the original karst 

POG would be remaining as POG or in mature forest stages. 

Alternative 5 would result in the additional conversion of intact large watersheds to a 

modified condition. After 100+ years of implementation under maximum harvest, the 

percentage of intact watersheds would be reduced from 69 percent to 50 percent of 

the Tongass. Similarly, the percentage of the land area of the Tongass in intact 

watersheds would be reduced from 74 percent to 60 percent (Table 3.9-19). 

However, over on-third of this reduction would occur as a result of additional 

development on non-NFS lands, even if no additional Tongass harvest occurred. 

Approximately 8 percent of the drop in percentage of intact watersheds and 5 

percent of the drop in acreage is due to additional development on non-NFS lands. 

Approximately 8 percentage points of the drop in percentage of intact watersheds 

and 5 percentage points of the drop in acreage are due to additional development 

on non-NFS lands. 

Alternative 6 

Alternative 6 represents the proposed action and represents a modification of the 

current Forest Plan. It would result in slightly less POG retained within the matrix, 

but would expand the reserve system relative to the current Forest Plan 
 Environment and Effects 3 

Final EIS 3-193 Biodiversity 

(Alternative 5). On balance, it would protect more POG than Alternative 5, 

particularly the POG in reserves and large-tree POG. Therefore, it would have a 

lower overall effect on biodiversity than Alternative 5. Although this alternative was 

not specifically evaluated in the 1996 panel assessment, based on its level of 

harvest and other factors considered in the assessment, it is clear that it would have 

a lower effect on biodiversity than Alternatives 4, 5, and 7 and a higher effect than 

Alternatives 1, 2, or 3. 

Under Alternative 6, 72 percent of the existing POG would be included within 

reserves and an additional 19 percent would be protected within the matrix by 

standards and guidelines or not scheduled for harvest. As a result, about 9 percent, 

or 445,000 acres, would be subject to harvest (Table 3.9-12). Although Alternative 6 

would protect 28,000 fewer acres of POG in the matrix than Alternative 5 (partly 

because the matrix land area would be smaller under Alternative 6), it would have 

45,000 more acres of POG in reserves. Long-term maximum harvest of highvolume and large-tree POG are projected to be in the 10 to 11 percent range. Again 

in comparison with Alternative 5, although Alternative 6 would protect 1,000 fewer 

acres of large-tree POG in the matrix, it would maintain about 11,000 more acres 

within reserves. Alternative 6 includes a refinement of small old-growth reserve 

boundaries relative to Alternative 5; one of the factors this refinement emphasized 

was the incorporation of more large-tree POG. 

In addition to the POG that would not be harvested, there would be about 255,000 

acres of existing productive young growth that would not be harvested under 

Alternative 6 and that would eventually develop into mature forest and then POG 

(Table 3.9-13). This represents a long-term replacement for about 57 percent of the 

future maximum POG harvest. 

Assuming maximum harvest over 100+ years, approximately 83 percent of the 

original POG would remain Forest-wide; 66 percent of the original POG would be in 

reserves (Table 3.9-14). Harvest would be spread over 19 out of the 21 provinces, 

but only 13 provinces would have potential harvest exceeding 5,000 acres. At least 

8 of the 21 provinces would have more than 90 percent of their original POG 

remaining after 100+ years, and 3 provinces (North Central Prince of Wales, 

Kupreanof/Mitkof, and Etolin & Vicinity) would have less than 75 percent remaining 

(Table 3.9-14). 

Relative to the largest tree categories, after 100+ years of maximum implementation 

of Alternative 6, 79 percent of the original high-volume POG and 72 percent of the 

original large-tree POG would remain, with the majority of these acres in reserves 

(Tables 3.9-15 and 3.9-16). At least 8 provinces would maintain 90 percent or more 

of their original high-volume POG and 5 provinces would maintain less than 75 

percent (minimum = 54 percent for North Central Prince of Wales) (Table 3.9-15). 

Relative to large-tree POG, at least 6 provinces would maintain 90 percent or more 

of their original acres and 9 provinces would have less than 75 percent (minimum = 

31 percent for East Baranof) (Table 3.9-16). 

Implementation of Alternative 6 would result in a maximum reduction of the karst 

POG on the Tongass from 69 percent of the original karst POG at present, to 61 

percent after 100+ years. Low elevation karst POG would be reduced from 62 

percent currently, to 55 percent (Table 3.9-17). 

Long-term POG representation by ecological subsection would be maintained under 

Alternative 6 by protecting at least 48 percent of original POG in all 73 subsections 

(Table 3.9-18). At least 90 percent of original POG would be maintained in 31 of the 

73 subsections and at least 75 percent would be maintained in 57 out of the 73 

subsections. One subsection, North POW-Kuiu Carbonates, would have with less 
3 Environment and Effects

Biodiversity 3-194 Final EIS

than 50 percent of its original POG remaining after 100+ years, but would still 

maintain about 92,000 acres. 

If one considers the regrowth of current young growth that would be protected under 

this alternative (Table 3.9-13), after 100+ years the equivalent of an additional 5 

percent of the original POG acres would be in mature forest stands and some 

stands would be at the beginning stages of exhibiting older forest characteristics 

(Table 3.9-14). Similarly, an additional 7 percent of the original high-volume POG, 

11 percent of the original large-tree POG, and 15 percent of the original karst POG 

would be in mature forest stages (Tables 3.9-15, 3.9-16, and 3.9-17, respectively). 

In summary, after 100+ years of implementation under Alternative 6, 88 percent of 

the original POG would be remaining as POG or in mature forest stages. Likewise, 

86 percent of the original high-volume POG would still be in high-volume POG or in 

mature forest stages, 83 percent of the original large-tree POG would be remaining 

as large-tree POG or in mature forest stages, and 76 percent of the original karst 

POG would be remaining as POG or in mature forest stages. 

Alternative 6 would result in the additional conversion of intact large watersheds to a 

modified condition. After 100+ years of implementation under maximum harvest, the 

percentage of intact watersheds would be reduced from 69 percent to 51 percent of 

the Tongass. Similarly, the percentage of the land area of the Tongass in intact 

watersheds would be reduced from 74 percent to 60 percent (Table 3.9-19). 

However, over on-third of this reduction would occur as a result of additional 

development on non-NFS lands, even if no additional Tongass harvest occurred. 

Approximately 8 percentage points of the drop in percentage of intact watersheds 

and 5 percentage points of the drop in acreage are due to additional development 

on non-NFS lands. 

Alternative 7 

Alternative 7 represents the alternative with the highest POG harvest level. It also 

differs from the other alternatives in that it does not designate Old-Growth Habitat 

LUDs, although it does include reserves associated with other non-development 

LUDs. In addition to the elimination of Old-Growth Habitat LUDs, Alternative 7 also 

proposes to reduce the beach buffer from 1,000 feet to 500 feet. This would likely 

reduce the effectiveness of these shoreline corridors in providing landscape 

linkages between habitat reserves and thus, potentially reduce the 

interconnectedness of the old-growth forest ecosystem. Further, it differs from all 

other alternatives by not requiring riparian buffers along Class III streams, which 

would also have some negative effect on old-growth connectivity (although Class I 

and II riparian buffers are most important in this regard). Finally, as in the case for 

Alternative 4, it would not include the goshawk and marten or the legacy forest 

structure standards and guidelines that require retention trees in harvest units within 

specific VCUs. 

Alternative 7 is based on and is similar to the 1997 Alternative 2, which was 

evaluated in the 1997 Forest Plan Revision FEIS (see Chapter 2); therefore, the 

conclusions of the 1997 old-growth panel assessment can be extended to the 

current Alternative 7. The panel assessment concluded that this alternative was 

ranked in the highest risk group in terms of effects on biodiversity among the 

alternatives evaluated by the panel. As such, it ranked worse than our 2007 

Alternative 4 and, through comparisons with acreage harvested and other 

alternative components, it would have ranked worse than all of the other 2007 

alternatives as well. In addition to the acres of harvest, the primary factor 

associated with this ranking is the absence of reserves over many relatively large 

areas of the Tongass. Of particular concern are the North Central Prince of Wales 

Island, Etolin Island & Vicinity, Kupreanof/Mitkof Island, and Revilla Island/Cleveland 
 Environment and Effects 3 

Final EIS 3-195 Biodiversity 

Peninsula biogeographic provinces, which have already been heavily affected by 

timber harvest. The old-growth network was specifically designed to ensure the 

maintenance of well-distributed viable populations of all old-growth associated 

wildlife species across the Tongass. The 1996 panel assessment concluded that 

alternatives that did not emphasize the old-growth reserve network had the highest 

potentials to create biodiversity concerns within biogeographic provinces over the 

long term. 

Alternative 7 would include 57 percent of the existing POG within reserves and an 

additional 27 percent would be protected within the matrix by standards and 

guidelines or not scheduled for harvest. As a result, about 16 percent, or 807,000 

acres, would be subject to harvest (Table 3.9-12). Long-term maximum harvest of 

existing high-volume and large-tree POG are projected to be in the 18 to 20 percent 

range. In addition, there would be about 219,000 acres of existing productive young 

growth that would not be harvested and that would eventually develop into mature 

forest and then POG (Table 3.9-13). This represents a long-term replacement for 

about 27 percent of the future maximum POG harvest. 

Assuming maximum harvest over 100+ years, approximately 77 percent of the 

original POG would remain Forest-wide; 52 percent of the original POG would be in 

reserves (Table 3.9-14). Harvest would be spread over 20 out of the 21 provinces, 

and 16 provinces would have potential harvest exceeding 5,000 acres. At least 7 of 

the 21 provinces would have at least 90 percent of their original POG remaining 

after 100+ years, and 7 provinces (North Central Prince of Wales, Kupreanof/Mitkof, 

Etolin & Vicinity, Revilla/Cleveland, Kuiu, East Chichagof, and East Baranof) would 

have less than 75 percent remaining (Table 3.9-14). 

Relative to the largest tree categories, after 100+ years of maximum implementation 

of Alternative 7, 72 percent of the original high-volume POG and 64 percent of the 

original large-tree POG would remain, with the majority of these acres in reserves 

(Tables 3.9-15 and 3.9-16). At least 7 provinces would maintain 90 percent or more 

of their original high-volume POG and 11 provinces would maintain less than 75 

percent (minimum = 44 percent for North Central Prince of Wales) (Table 3.9-15). 

Relative to large-tree POG, at least 5 provinces would maintain 90 percent or more 

of their original acres and 12 provinces would have less than 75 percent (minimum = 

31 percent for East Baranof) (Table 3.9-16). 

Implementation of Alternative 7 would result in a maximum reduction of the karst 

POG on the Tongass from 69 percent of the original karst POG at present, to 54 

percent after 100+ years. Low elevation karst POG would be reduced from 62 

percent currently, to 47 percent (Table 3.9-17). 

Long-term POG representation by ecological subsection would be maintained under 

Alternative 7 by protecting at least 41 percent of original POG in all 73 subsections 

(Table 3.9-18). At least 90 percent of original POG would be maintained in 25 of the 

73 subsections and at least 75 percent would be maintained in 45 out of the 73 

subsections. Four subsections, North POW-Kuiu Carbonates, Central POW 

Volcanics, Stikine Strait Complex, and Thomas Bay Outwash Plains, would have 

with less than 50 percent of their original POG remaining after 100+ years. These 

subsections would have 78,000, 79,000, 16,000, and 6,000 acres of POG, 

respectively. 

If one considers the regrowth of current young growth that would be protected under 

this alternative (Table 3.9-13), after 100+ years the equivalent of an additional 4 

percent of the original POG acres would be in mature forest stands and some 

stands would be at the beginning stages of exhibiting older forest characteristics 

(Table 3.9-14). Similarly, an additional 6 percent of the original high-volume POG, 9 

percent of the original large-tree POG, and 12 percent of the original karst POG 
3 Environment and Effects

Biodiversity 3-196 Final EIS

would be in mature forest stages (Tables 3.9-15, 3.9-16, and 3.9-17, respectively). 

In summary, after 100+ years of implementation under Alternative 7, 81 percent of 

the original POG would be remaining as POG or in mature forest stages. Likewise, 

78 percent of the original high-volume POG would still be in high-volume POG or in 

mature forest stages, 71 percent of the original large-tree POG would be remaining 

as large-tree POG or in mature forest stages, and 66 percent of the original karst 

POG would be remaining as POG or in mature forest stages. 

Alternative 7 would result in the additional conversion of intact large watersheds to a 

modified condition. After 100+ years of implementation under maximum harvest, the 

percentage of intact watersheds would be reduced from 69 percent to 47 percent of 

the Tongass. Similarly, the percentage of the land area of the Tongass in intact 

watersheds would be reduced from 74 percent to 57 percent (Table 3.9-19). 

However, a portion of this reduction would occur as a result of additional 

development on non-NFS lands, even if no additional Tongass harvest occurred. 

Approximately 8 percentage points of the drop in percentage of intact watersheds 

and 5 percentage points of the drop in acreage are due to additional development 

on non-NFS lands. 

Endemics 

As noted in the Endemism subsection of the Affected Environment part of this 

section, Southeast Alaska is rich in endemics, and endemic mammals and other 

groups are sensitive to future landscape disturbances. Because unproductive forest 

and non-forested ecosystems have not changed appreciably since original levels, 

nor are they anticipated to change under the full implementation of the Forest Plan 

under any of the alternatives, concerns focus on the loss of POG habitat, which is 

most influenced by management activities. Those species most closely associated 

with old growth are assumed to be at greatest risk. 

The 1997 Forest Plan FEIS panel assessment for endemics evaluated 14 species or 

subspecies endemic to Southeast Alaska (see the Wildlife section of the 1997 

Forest Plan Revision FEIS and the Wildlife section in this chapter for additional 

information). Each of the above species occupies restricted ranges (i.e., currently 

known to be limited to one or a few isolated islands). Under all alternatives, the 

Prince of Wales flying squirrel is currently assumed to have the greatest viability 

concern over time. 

The panel concluded that the 1997 Alternative 11 (equivalent to the current Forest 

Plan or the 2007 Alternative 5) ranked among the alternatives with the highest 

likelihood of sustaining habitat to support viable populations of endemic mammals. 

Under the current Forest Plan, all islands less than 1,000 acres were removed from 

the timber base to eliminate risk to these species associated with habitat loss or 

alteration from timber harvest. The 1,000-foot beach buffer, riparian corridors, and 

the old-growth reserve system are also features of the current Forest Plan that 

provide functional habitat for species with relatively small home ranges. These 

protective provisions would be maintained under all the action alternatives, with the 

exception of Alternative 7 under which the beach fringe buffer would be reduced to 

500 feet, the system of old-growth reserves would be significantly contracted, and 

Class III stream buffers would be eliminated. Alternative 4 would also significantly 

reduce the old-growth reserve system in some provinces. Alternatives 1, 2, 3, and 

6, which propose to harvest less timber than under the current Forest Plan, would 

likely continue to maintain habitat and connectivity to support viable populations of 

endemic mammals. 

Based on the number of acres converted from the matrix to reserves, as described 

above, the ability to maintain viable populations of endemic mammals would be 
 Environment and Effects 3 

Final EIS 3-197 Biodiversity 

greatest under Alternative 1, followed by Alternatives 2, 3, 6, 5, 4, and 7. See the 

Wildlife section in this chapter for additional species-specific discussion. 

Invasive Species

As discussed in the Affected Environment section, numerous non-native species 

have been introduced or transplanted in Alaska, including plants, wildlife, fish, other 

aquatic organisms, and insects. Managing invasive species on the Tongass 

National Forest must include increased public awareness at all levels coupled with 

interagency cooperation and development of cooperative management partnerships 

to monitor and limit invasive species populations at current levels in Alaska. 

Currently, non-native or invasive plant species make up the vast majority of species 

listed as threats in Alaska. Fifteen of the species found on the Tongass are among 

the species that pose a greater potential threat. The areas of greatest non-native 

plant diversity and extent of invasion have been found around towns and the most 

heavily traveled areas. The areas with the lowest number of species were further 

from population centers or paved roads (Arhangelsky 2005). Schrader and Hennon 

(2005) cited several references that suggest that the highest invasive plant 

occurrences are in areas of disturbance such as roads, recreational areas, 

commercial, and industrial development. As more surveys are conducted, it is 

anticipated that more invasive plant species will be documented (see the Plant 

section in this chapter for additional discussion of effects from non-native plants). 

Non-native wildlife species have been transplanted for sport hunting or other 

consumption opportunities such as trapping or, in some cases, accidentally 

introduced in Southeast Alaska; however, only the Norway rat is considered invasive 

at this time. Concern regarding potential range expansion of this species exists; 

however, measures to reduce the potential of introducing this species elsewhere on 

the Tongass is limited because the Forest does not have jurisdiction regarding 

shipping throughout Southeast Alaska waters. Because of the growing number of 

elk in Southeast Alaska, this species may be considered as a possible invasive 

species outside of Etolin and Zarembo islands, due to their effects on Sitka blacktailed deer, which have similar habitat needs (see the Wildlife section in this 

chapter). 

Invasive fish and other aquatic organisms identified as threats for Alaska are 

discussed in more detail under the Fish section in this chapter. Established 

populations (throughout the Susitna River drainage, parts of the Kenai system) of 

northern pike (with the exception of Pike Lakes on the Yakutat Ranger District) pose 

the greatest immediate concern, while the Atlantic salmon, Chinese mitten crab, and 

New Zealand mudsnail are species likely to invade Alaska in coming years 

(Schrader and Hennon 2005). Effects of these species on native populations are 

currently unknown; however, based on documented impacts in other areas, species 

such as the Chinese mitten crab and New Zealand mudsnail quickly colonize 

environments and dominate the invertebrate community in aquatic ecosystems by 

consuming large portions of the food resources, outcompeting and physically 

crowding native species. This could lead to local extirpation in some areas over 

time. 

Schrader and Hennon (2005) noted that invasive tree pathogens are not currently 

damaging Alaskan ecosystems, but there are numerous species that could cause 

widespread tree mortality if introduced. Introduced insects currently established in 

Alaska include the larch sawfly, alder woolly aphid, spruce aphid, and ambermarked birch leafminer, and could cause widespread tree defoliation and mortality 

(see the Forest Health section in this chapter for additional discussion of effects). 
3 Environment and Effects

Biodiversity 3-198 Final EIS

With the exception of certain fish and aquatic organisms that would not be expected 

to increase independent of any of the alternatives, most of the other invasive or 

potentially invasive species listed above would be influenced by management 

activities that would increase harvest and other associated management activities, 

such as the building of new roads. Alternatives 1, 2, and 3 designate more reserve 

areas than the other alternatives. Under Alternatives 4 and 7, there would be an 

increase in the amount of harvest and roading, relative to the current Forest Plan; 

more lands would be available for timber harvest activities under Alternatives 4 and 

7. Although any management activity has the potential to increase the risk of 

introducing invasive species to a system, it is reasonable to assume that increases 

in harvest and roading from current levels would contribute additional source areas 

for invasive establishment and persistence. 

None of the alternatives proposes changes to the management framework of the 

Tongass in relation to invasives. Most of the species identified above are not 

specifically addressed under the Forest Plan Monitoring section or standards and 

guidelines; however, the Alaska Region of the Forest Service is currently developing 

an invasive species strategy that will apply the principles of prevention, early 

detection, control, and rehabilitation in cooperation with various agencies and 

partners to reduce or eliminate invasive species establishment. 

When considering biodiversity and the distribution of old growth across the Tongass, 

it is important to consider non-NFS lands (which include private, city, state, and 

other federal lands. As noted in the subsections titled Cumulative Past Harvest and 

Current Conditions by Biogeographic Province in the Affected Environment portion 

of this section, past harvest has been more extensive on non-NFS lands than on 

NFS lands. The area used to assess cumulative effects on biodiversity 

encompasses all lands in Southeast Alaska, including all lands within the Tongass 

National Forest boundary, from the Yakutat area southeast to the south of 

Ketchikan. In addition, it includes the area of Glacier Bay National Park, and the 

areas around Haines and Skagway. Some resource areas may require larger or 

smaller areas to address cumulative effects. For example, for some resources, the 

extent of analysis needs only include the area within the Tongass boundary (i.e., 

without the Glacier Bay National Park and Haines/Skagway areas). In particular, 

cumulative effects are sometimes addressed within a VCU (e.g., water, fish, 

wetlands), or a WAA (e.g., wolves, deer), or a Biogeographic Province or an 

Ecological Subsection (e.g., species viability). 

Under the current Forest Plan, with few exceptions (e.g., minerals production and 

utility corridors), only lands classified as suitable for timber production are scheduled 

for harvest in the future. However, other reasonably foreseeable activities that have 

the potential to cumulatively affect biodiversity locally and regionally include: 

• Minerals extraction (e.g., Green’s Creek on Admiralty Island and Kensington 

Gold Mine near Berners Bay north of Juneau), 

• Transmission line intertie projects (e.g., Swan Lake-Lake Tyee Intertie northeast 

of Ketchikan), 

• Hydroelectric projects (e.g., Four Dam Pool projects, other limited small 

hydroelectric projects such as Angoon), 

• Regional transportation developments (e.g., Juneau Access Road), 

• Growth in the cruise ship, guiding services, fishing/destination type lodging, and 

• Human settlements (e.g., expansion of cities like Juneau and Ketchikan, 

recreational cabin development, and land auctions by the State of Alaska). 

Cumulative 

Effects 
 Environment and Effects 3 

Final EIS 3-199 Biodiversity 

Because plant and wildlife populations exist across all land ownerships, addressing 

potential adverse effects of management activities on overall biodiversity requires 

agencies and other landowners to work together. A species population viability and 

its distribution within Southeast Alaska is influenced in part by geologic processes 

(e.g., island archipelago), habitat and connectivity between patches (e.g., 

fragmentation), and by state and federal regulatory mechanisms such as harvest 

limits, season length, subsistence needs, and timber harvest practices on all lands. 

Overall, biodiversity on the Tongass remains in good condition and are mostly 

dominated by old-growth forest. As development continues through timber harvest, 

associated activities such as road building, and community expansion, particularly in 

areas where extensive development has already occurred (i.e., Prince of Wales 

Island), maintaining connectivity and roadless refugia will become increasingly 

important, particularly for wide-ranging species whose distribution depends on some 

level of connectivity across the landscape. In addition, the management of human 

resources will continue to play a role in the viability and distribution of biodiversity 

across the Forest. 

Cumulative Effects on Productive Old Growth in General 

The focus of the analysis remains on changes to the old-growth ecosystem as this 

habitat is most affected under each of the alternatives. This section displays future 

projected harvest on both NFS lands and non-NFS lands by biogeographic province 

and ecological subsection. For assessing overall effects to biodiversity across all 

ownerships for Southeast Alaska, both biogeographic province and ecological 

subsection are appropriate scales. As stated in the Affected Environment section, 

using both biogeographic provinces and ecological subsection classifications allows 

additional insight into how various communities are represented at different 

landscape scales. Both classification systems were developed using different 

processes, but complement each other in terms of addressing biodiversity. 

To estimate the future harvest of POG on non-NFS lands, it was assumed that 75 

percent of the remaining old-growth would be harvested on Native corporation lands 

and 50 percent of the remaining old growth would be harvested on state lands, other 

private lands, and lands owned by municipalities, over the life of the Forest Plan 

(100+ years). The total percent harvest of POG on all lands within Southeast 

Alaska by biogeographic province and each ecological subsection could then be 

calculated. 

On NFS lands, approximately 455,000 acres have been harvested. As a result, 92 

percent of the original POG remains today. Additional POG harvest on NFS lands 

under the alternatives would range from an estimated maximum of 86,000 acres 

under Alternative 1 to 807,000 acres under Alternative 7, over the next 100+ years. 

The result would be that an estimated 90 to 77 percent of the original POG on these 

lands would remain indefinitely. 

Approximately 371,000 acres of POG (including a small portion of helicopter partial 

harvest acres) have been harvested on non-NFS lands, with the majority of the 

harvest occurring in the last 25 years. With this harvest, 51 percent of the original 

POG is estimated to remain on these lands. Future harvest on non-NFS lands over 

the next 100+ years is estimated to be as high as 295,000 additional acres. 

Therefore, after the total cumulative harvest on non-NFS lands an estimated 19 

percent is expected to remain (considered to be a conservatively high estimate). 

Considering NFS and non-NFS lands combined, 87 percent of the area originally 

occupied by POG remains unharvested today. The percent of original POG that 

would remain after full implementation of the Forest Plan and future non-NFS 

harvest (after 100+ years) would range from 82 percent under Alternative 1 to 71 

percent under Alternative 7 (Table 3.9-20). This does not include approximately 3 to 
3 Environment and Effects

Biodiversity 3-200 Final EIS

6 percent additional that would be represented by mature second growth that is 

protected from harvest, some of which would be beginning to take on older forest 

characteristics. 

Past harvest activities have concentrated, and future harvest will continue to 

concentrate under most alternatives, primarily in three biogeographic provinces: the 

North Central Prince of Wales, Kupreanof/Mitkof, and Revilla/Cleveland provinces. 

These three provinces account for about 56 percent of the past harvest and will 

account for 44 to 74 percent of future harvest, depending on the alternative. 

North Central Prince of Wales is the province with the most extensive past and 

future harvest and development. Currently, 65 percent of the original POG remains 

in the province (Table 3.9-20). After 100+ years, the minimum amount remaining 

would range from 44 to 55 percent, depending on the alternative. 

In addition to the three provinces mentioned above, relatively high rates of POG 

removal have occurred, or are planned to occur, within the Etolin Island & Vicinity, 

East Chichagof, Southern Outer Island, Dall Island & Vicinity, and Yakutat Forelands 

biogeographic provinces (however, POG removal in the Yakutat Forelands province 

is partially due to windthrow rather than timber harvest). Under all alternatives, 

harvest will continue to be concentrated in matrix NFS lands and on private and 

state lands, and reserves will continue to exist on NFS, other federal, and some 

state lands. More specific descriptions of effects are presented under the 

Cumulative Effects by Biogeographic Province subsection below. 

Theoretical and empirical studies suggest that the likelihood of a population 

persisting over time is related to some threshold level of habitat loss across the 

landscape (Fahrig 1997, 1999, 2003; Flather et al. 2002; Andren 1994). Reported 

threshold levels for the percentage of habitat maintained at which the rate of 

landscape extinction increases range from 20 percent (Fahrig 1997) to 50 percent 

(Soule and Sanjayan 1998), depending in part on the dispersal capability of the 

species under consideration (see the Cumulative Effects subsection of the Wildlife 

section for further information on this topic). It is important to note that, although 

many plant and animal species make higher use of the larger forest types defined by 

high-volume and large-tree POG, few are totally restricted to these habitats. In fact, 

almost all species make at least some use of types other than mapped POG (e.g., 

unproductive old growth and older young growth forests). The thresholds of 

importance to an individual species depend on specific habitat requirements as well 

as dispersal capabilities. Existing natural fragmentation of habitats can also affect 

the level of additional fragmentation that can be supported. Therefore, the 

percentages of POG and larger tree types presented in these cumulative effects 

discussions represent indices of risk, which can be generally compared with 

theoretical and empirical thresholds, recognizing the high degree of variability 

among species habitat requirements, dispersal capabilities, and the natural level of 

fragmentation within the landscape. 

Within the Tongass National Forest boundary, the Conservation Strategy was 

designed to address the more extensive harvest on non-NFS lands through the oldgrowth reserve system network and Forest-wide standards and guidelines, both of 

which were intended to maintain habitat components important to a variety of 

species and maintain connectivity across the landscape, with or without much 

contribution from non-NFS lands. In other words, benefits from non-NFS lands were 

assumed to be minimal in the design of the strategy. Therefore, the cumulative 

effects associated with the combination of NFS and non-NFS harvest, for those 

alternatives that incorporate the complete conservation strategy (i.e., Alternatives 1, 

2, 3, 5, and 6), are not expected to be appreciably different than the direct and 

indirect effects. 
 Environment and Effects 3 

Final EIS 3-201 Biodiversity 

Table 3.9-20 

Cumulative Percent of Original POG Remaining on All Ownerships after 100+ Years of 

Maximum1

 Forest Plan Implementation under Each Alternative, incorporating Future Harvest 

on Non-NFS Lands2

 by Biogeographic Province 

Percent Remaining POG after 100+ Years

as a Percent of Original POG 

Alternative 

Biogeographic Province 

Estimated 

Original 

POG on All 

Ownerships 

(Acres) 

Percent 

Remaining 

POG on All 

Ownerships 1 2 3 4 5 6 7 

1 Yakutat Forelands 89,226 84% 77% 75% 73% 72% 72% 73% 71%

2 Yakutat Uplands 23,400 94% 94% 94% 94% 93% 94% 94% 93%

3 East Chichagof Island 430,035 84% 78% 75% 74% 67% 71% 72% 64%

4 West Chichagof Island 72,369 100% 100% 100% 100% 100% 100% 100% 100%

5 East Baranof Island 89,338 87% 86% 81% 80% 72% 76% 78% 70%

6 West Baranof Island 227,753 92% 90% 88% 86% 81% 86% 86% 80%

7 Admiralty Island 597,623 95% 95% 95% 95% 95% 95% 95% 95%

8 Lynn Canal 169,414 97% 92% 89% 88% 80% 84% 85% 79%

9 North Coast Range 356,463 94% 89% 89% 88% 77% 81% 81% 76%

10 Kupreanof/Mitkof Island 335,104 83% 74% 70% 66% 57% 61% 61% 53%

11 Kuiu Island 295,929 91% 91% 85% 83% 72% 79% 79% 69%

12 Central Coast Range 250,959 97% 96% 95% 89% 82% 85% 86% 80%

13 Etolin Island 232,104 85% 78% 71% 69% 59% 67% 67% 55%

14 North Central Prince of 

Wales 598,645 65% 55% 54% 52% 49% 51% 51% 44%

15 Revilla Island/ 

Cleveland Peninsula 573,213 89% 81% 79% 77% 69% 74% 74% 66%

16 Southern Outer Islands 118,338 85% 80% 78% 77% 75% 76% 76% 72%

17 Dall Island and Vicinity 99,621 75% 58% 58% 57% 55% 55% 55% 53% 

18 South Prince of Wales 173,174 91% 87% 85% 81% 71% 77% 77% 68% 

19 North Misty Fiords 200,820 99% 98% 98% 97% 96% 97% 97% 95% 

20 South Misty Fiords 310,176 100% 100% 100% 100% 100% 100% 100% 100%

21 Ice Fields 115,273 97% 97% 96% 95% 93% 93% 94% 93% 

22 Chilkat River Complex 145,104 88% 56% 56% 56% 56% 56% 56% 56% 

23 Glacier Bay/ 

Fairweather Range 170,840 100% 100% 100% 100% 100% 100% 100% 100%

Total for 

Southeast Alaska 5,674,921 87% 82% 80% 78% 73% 76% 76% 71%

1 Maximum Forest Plan implementation is defined as the maximum harvest allowed by the Allowable Sale Quantity each decade. The 

estimate assumes all scheduled suitable POG is harvested [calculated by subtracting alternative-specific reduction factors for the Model 

Implementation Reduction Factor (MIRF) and scheduling from the mapped suitable acreage under each alternative (see the Timber 

section)]. 2 Based on an inventory of existing harvest on non-NFS lands and the estimation of future harvest by major landowner category.
3 Environment and Effects

Biodiversity 3-202 Final EIS

Table 3.9-21 

Cumulative Percent of Original High-Volume POG Remaining on All Ownerships after 100+ 

Years of Maximum1

 Forest Plan Implementation under Each Alternative, incorporating 

Future Harvest on Non-NFS Lands2

 by Biogeographic Province

Remaining High-Volume POG after 100+ Years

as a Percent of Original POG 

Alternative 

Biogeographic Province 

Estimated 

Original 

High-Volume 

POG on All 

Ownerships 

(Acres) 

Percent 

Remaining 

High-Volume 

POG on All 

Ownerships 1 2 3 4 5 6 7 

1 Yakutat Forelands 56,525 81% 73% 70% 66% 64% 65% 65% 63%

2 Yakutat Uplands 11,614 92% 92% 92% 91% 90% 91% 91% 90%

3 East Chichagof 

Island 213,321 76% 69% 66% 65% 59% 63% 63% 56%

4 West Chichagof 

Island 17,275 100% 100% 100% 100% 100% 100% 100% 100%

5 East Baranof Island 37,246 77% 76% 70% 69% 62% 66% 67% 60%

6 West Baranof Island 68,682 82% 77% 76% 74% 69% 74% 74% 68%

7 Admiralty Island 323,390 94% 93% 93% 93% 93% 93% 93% 93%

8 Lynn Canal 69,994 95% 87% 84% 83% 73% 78% 79% 71%

9 North Coast Range 162,093 92% 83% 83% 82% 71% 76% 76% 70%

10 Kupreanof/Mitkof 

Island 151,400 71% 61% 57% 53% 44% 49% 49% 41%

11 Kuiu Island 175,546 90% 89% 82% 80% 69% 75% 75% 66%

12 Central Coast Range 110,637 95% 94% 93% 87% 80% 84% 84% 79%

13 Etolin Island 106,381 76% 67% 61% 59% 50% 57% 57% 45%

14 North Central Prince 

of Wales 453,890 56% 45% 44% 42% 39% 41% 41% 33%

15 Revilla Island/ 

Cleveland Peninsula 282,301 84% 74% 71% 70% 62% 68% 68% 58%

16 Southern Outer 

Islands 58,072 77% 70% 68% 67% 64% 66% 66% 61%

17 Dall Island and 

Vicinity 63,691 68% 52% 52% 51% 50% 50% 50% 48% 

18 South Prince of 

Wales 94,158 88% 83% 81% 77% 67% 74% 73% 64% 

19 North Misty Fiords 68,370 98% 97% 96% 95% 93% 95% 95% 93% 

20 South Misty Fiords 97,581 100% 100% 100% 100% 100% 100% 100% 100%

21 Ice Fields 39,093 93% 93% 93% 92% 90% 90% 91% 90% 

22 Chilkat River 

Complex 112,625 89% 60% 60% 60% 60% 60% 60% 60% 

23 Glacier Bay/ 

Fairweather Range 157,413 100% 100% 100% 100% 100% 100% 100% 100%

Total for Southeast 

Alaska 2,931,297 82% 75% 73% 72% 67% 70% 70% 65% 

1 Maximum Forest Plan implementation is defined as the maximum harvest allowed by the Allowable Sale Quantity each decade. The 

estimate assumes all scheduled suitable POG is harvested [calculated by subtracting alternative-specific reduction factors for the 

Model Implementation Reduction Factor (MIRF) and scheduling from the mapped suitable acreage under each alternative (see the 

Timber section)]. 2 Based on an inventory of existing harvest on non-NFS lands and the estimation of future harvest by major landowner category. 
 Environment and Effects 3 

Final EIS 3-203 Biodiversity 

Cumulative Effects on Specific Productive Old-Growth Types

Historically, as discussed in the Past Old-Growth Harvest subsection, some of the 

more productive forest types have been harvested at a higher rate than POG in 

general. These forest types have included both high-volume and large-tree POG 

(SD67), POG on karstlands, and low elevation POG (Albert and Schoen 2007). 

Tables 3.9-21 and 3.9-22 present the acreage of original high-volume and large-tree 

POG along with the percent currently remaining and the percent remaining after 

100+ years by biogeographic province for all of Southeast Alaska. 

For all ownerships across Southeast Alaska, an estimated 82 percent of highvolume POG remains today, although the percentage found in individual provinces 

ranges from a low of 56 percent to a high of 100 percent. After 100+ years, it is 

estimated that the overall amount remaining would range from a high of 75 percent 

under Alternative 1 to a low of 65 percent under Alternative 7 (Table 3.9-21). This 

does not include approximately 5 to 9 percent additional that would be represented 

by mature second growth growing on high-volume sites and is protected from 

harvest. The percent of POG remaining would range from 45 to 100 percent in 

individual provinces under Alternative 1 and from 33 to 100 percent under 

Alternative 7. 

Approximately 68 percent of large-tree POG remains on all ownerships combined in 

Southeast Alaska. The percent remaining in individual provinces ranges from a low 

of 33 percent to a high of 100 percent. After 100+ years, the amount remaining 

would range from a high of 62 percent under Alternative 1 to a low of 52 percent 

under Alternative 7 (Table 3.9-22). This does not include approximately 7 to 14 

percent additional that would be represented by mature second growth growing on 

large-tree POG sites and is protected from harvest. The percent of POG remaining 

would range from 32 to 100 percent in individual provinces under Alternative 1 and 

from 30 to 100 percent under Alternative 7. 

Cumulative harvest on karst lands has affected about 34 percent of all karst POG 

and resulted in approximately 66 percent of all karst POG remaining unharvested. 

This represents about 84 percent of all karst POG at moderate to higher elevations 

(> 800 ft.), but only about 60 percent of all karst POG at low elevations (< 800 ft.). 

After 100+ years and assuming that all karst POG on non-NFS lands is harvested, 

the overall percent remaining would range from a high of 60 percent under 

Alternative 1 to a low of 50 percent under Alternative 7. In addition, from 11 to 24 

percent of the original karst POG would be in mature second growth, some of which 

would be beginning to take on older forest characteristics. 

Cumulative Effects and Climate Change 

In addition to the approach and direction of management on the Tongass, there is 

uncertainty with regards to the cumulative effects on biodiversity associated with 

climate change. Warmer temperatures and decreased precipitation are anticipated 

to result in changes to vegetation and thus the suitability of wildlife habitat, among 

other impacts (see Climate and Air section). Although some species may benefit 

(e.g., greater overwinter survival of deer, and thus a greater prey base for wolves, 

resulting from warmer winter temperatures during normal years), habitat losses 

could also result from wind, increased risk of fires, insect infestations, disease, and 

from changes to microclimate conditions for many plant and animal species, 

especially those species already found in unique habitat conditions. 
3 Environment and Effects

Biodiversity 3-204 Final EIS

Table 3.9-22 

Cumulative Percent of Original SD67 POG Remaining on All Ownerships after 100+ Years 

of Maximum1

 Forest Plan Implementation under Each Alternative, incorporating Future 

Harvest on Non-NFS Lands2

 by Biogeographic Province

Remaining SD67 POG after 100+ Years

as a Percent of Original POG 

Alternative 

Biogeographic Province 

Estimated 

Original 

SD67 POG 

on All 

Ownerships 

(Acres) 

Percent 

Remaining 

SD67 POG 

on All 

Ownerships 1 2 3 4 5 6 7 

1 Yakutat Forelands 32,356 81% 78% 73% 66% 63% 65% 65% 63%

2 Yakutat Uplands 2,408 83% 83% 80% 80% 75% 79% 79% 74%

3 East Chichagof 

Island 63,769 58% 54% 53% 52% 47% 51% 52% 46%

4 West Chichagof 

Island 2,012 100% 100% 100% 100% 100% 100% 100% 100%

5 East Baranof Island 5,894 33% 33% 32% 32% 31% 31% 31% 31%

6 West Baranof Island 10,434 44% 39% 39% 39% 37% 38% 38% 37%

7 Admiralty Island 109,477 91% 90% 90% 90% 90% 90% 90% 90%

8 Lynn Canal 15,109 88% 78% 76% 75% 65% 70% 71% 64%

9 North Coast Range 33,870 77% 66% 66% 66% 54% 59% 60% 52%

10 Kupreanof/Mitkof 

Island 43,968 47% 42% 40% 38% 32% 34% 35% 29%

11 Kuiu Island 45,073 82% 81% 67% 65% 56% 61% 61% 52%

12 Central Coast Range 22,550 89% 89% 87% 82% 73% 79% 78% 72%

13 Etolin Island 24,912 51% 46% 42% 40% 33% 39% 39% 30%

14 North Central Prince 

of Wales 228,477 55% 47% 45% 44% 40% 43% 43% 35%

15 Revilla Island/ 

Cleveland Peninsula 55,209 59% 55% 53% 52% 46% 50% 50% 44%

16 Southern Outer 

Islands 19,760 67% 60% 58% 57% 53% 56% 56% 49%

17 Dall Island and 

Vicinity 21,202 42% 37% 37% 37% 36% 37% 37% 36% 

18 South Prince of 

Wales 54,556 88% 85% 82% 80% 69% 76% 76% 65% 

19 North Misty Fiords 13,545 95% 94% 92% 92% 90% 92% 92% 90% 

20 South Misty Fiords 14,147 100% 100% 100% 100% 100% 100% 100% 100%

21 Ice Fields 6,978 83% 83% 83% 83% 81% 81% 83% 81% 

22 Chilkat River 

Complex 28,676 73% 32% 32% 32% 32% 32% 32% 32% 

23 Glacier Bay/ 

Fairweather Range 0 -- -- -- -- -- -- -- -- 

Total for Southeast 

Alaska 854,457 68% 62% 60% 59% 54% 57% 57% 52% 

1 Maximum Forest Plan implementation is defined as the maximum harvest allowed by the Allowable Sale Quantity each decade. The 

estimate assumes all scheduled suitable POG is harvested [calculated by subtracting alternative-specific reduction factors for the 

Model Implementation Reduction Factor (MIRF) and scheduling from the mapped suitable acreage under each alternative (see the 

Timber section)]. 2 Based on an inventory of existing harvest on non-NFS lands and the estimation of future harvest by major landowner category.

The greatest concerns for plant and wildlife populations in relation to climate 

change, however, are the weather extremes that can be expected to occur 

periodically (CGC-ASR 1998). Periodic severe winter snowfalls are anticipated 
 Environment and Effects 3 

Final EIS 3-205 Biodiversity 

(Juday et al. 1998). These events would be of greatest concern for populations that 

are limited in number or distribution. The predator-prey dynamic of wolves and deer 

provide an example of one system where these effects may be realized. Additional 

discussion on predator-prey dynamics can be found under the Wildlife section. 

However, despite these uncertainties, the risks associated with implementation of 

the Forest Plan are very low. The life of this amendment is expected to be 10 to 15 

years at most, by which time, much more research and monitoring information will 

be available and another comprehensive evaluation will be undertaken. The current 

levels of harvest activity are at a 5-decade low and even if timber sales are made 

available and the timber industry responds rapidly, there will be a period of 

preparation prior to the implementation of any sale. Therefore, it is estimated that a 

maximum of 30,000 to 150,000 acres of old-growth could be harvested over the life 

of this amended plan (e.g., the next 10 to 15 years). This harvest level would 

represent from less than 1 percent to 3 percent of the existing POG. Even when 

added to past harvest, cumulative harvest on NFS lands would be only 9 to 11 

percent of the original POG. 

Many of the gaps in information will be addressed through monitoring (See Chapter 

6 in the Forest Plan). Additional studies stemming from adaptive management and 

known informational needs are discussed in Appendix B of the Forest Plan should 

assist land managers in the decision-making process to limit the degree of 

uncertainty and measure risk inherent in any decision into the future. 

Cumulative Effects by Biogeographic Province

In the Current Conditions by Biogeographic Province subsection of Affected 

Environment, each biogeographic province is described with regard to past harvest 

and developments on both NFS and non-NFS lands of Southeast Alaska, and their 

effects on biodiversity. The following subsection builds on the previous subsection 

and discusses the cumulative effects associated with the past harvest and 

developments, when combined with the present and reasonably foreseeable harvest 

and developments on both NFS and non-NFS lands. 

Yakutat Forelands 

Past cumulative harvest in this biogeographic province removed 16 percent of the 

POG on all lands combined, resulting in 84 percent of the original POG remaining. 

Future harvest is expected to remove an additional 7 to 13 percent, resulting in 

approximately 71 to 77 percent of the original POG remaining after 100+ years 

(Table 3.9-20). High-volume POG is currently estimated to represent 81 percent of 

its original acreage. Future representation of high-volume POG is expected to be a 

minimum of 63 to 73 percent (Table 3.9-21). Similarly, large-tree POG is expected 

to decline from about 81 percent of original acreage at present, to a minimum of 63 

to 78 percent after 100+ years (Table 3.9-22). 

Currently, 83 percent of the large watersheds (representing 80 percent of the 

acreage) in the portion of the province within the Tongass Forest boundary are 

considered to be in an intact condition. After 100+ years, this percentage is 

expected to be reduced to a minimum of 58 to 67 percent (representing 71 to 73 

percent of the acreage), depending on the alternative (Table 3.9-19). If the portion 

of the province that extends south into Glacier Bay National Park is included, the 

percentage of intact watersheds existing and remaining in the province after 100+ 

years would be substantially greater. 

Cumulative effects on biodiversity associated with Alternatives 1 and 2 are expected 

to be slightly higher than existing conditions and concentrated in the area around 

Yakutat. Under these alternatives, future harvest would be mostly associated with 
3 Environment and Effects

Biodiversity 3-206 Final EIS

non-NFS lands (there would be no NFS harvest under Alternative 1). Harvest on 

non-NFS lands would also be higher than harvest on NFS lands under all other 

alternatives. However, future NFS harvest associated with the other alternatives 

would approach the non-NFS harvest level. The extensive area of reserves in this 

province, under all alternatives, would limit effects on biodiversity. This is 

particularly true for Alternatives 1, 2, 3, 5, and 6, which include some acreage in the 

Old-Growth Habitat LUD designations, in addition to the large areas in Semi-Remote 

Recreation and LUD II and in Glacier Bay National Park that are associated with all 

the alternatives (65 percent of the province is in congressionally protected land 

designations). Further, Alternatives 1, 2, 3, and 6 would provide additional matrix 

retention as a result of the application of the legacy forest structure standard and 

guideline in two VCUs within the province. 

Yakutat Uplands 

The Yakutat Uplands province has experienced only limited past harvest equivalent 

to 6 percent of the original POG. Future cumulative harvest under all alternatives 

would also be limited to no more than several hundred additional acres. Therefore, 

approximately 93 to 94 percent of the original POG would be remaining after 100+ 

years (Table 3.9-20). In addition, future development would not change the 

percentage of large watersheds in an intact condition; they would remain at 96 

percent of the watersheds or 99 percent of the acreage (Table 3.9-19). As a result 

of the limited extent of future development, cumulative effects on biodiversity are 

expected to be insignificant under any of the alternatives. 

East Chichagof Island 

Approximately 16 percent of the original POG in this province has been harvested, 

resulting in 84 percent of the original POG remaining. Following maximum future 

harvest after 100+ years, the percentage of original POG remaining would range 

from 64 percent (Alternative 7) to 78 percent (Alternative 1) (Table 3.9-20). Highvolume POG is currently estimated to represent 76 percent of its original acreage. 

Future representation of high-volume POG is expected to be a minimum of 56 to 69 

percent (Table 3.9-21). Similarly, large-tree POG is expected to decline from about 

58 percent of original acreage at present, to a minimum of 46 to 54 percent after 

100+ years (Table 3.9-22). 

Currently, 53 percent of the large watersheds (representing 49 percent of the 

acreage) of the province are considered to be in an intact condition. After 100+ 

years, this percentage is expected to be reduced to a minimum of 31 to 52 percent 

(representing 26 to 47 percent of the acreage), depending on the alternative (Table 

3.9-19). In addition to timber harvest, additional development associated with 

Hoonah and other communities in the province would contribute to cumulative 

effects. 

Although specific watersheds would undergo a high cumulative percent harvest, 

Alternatives 1, 2, 3, 5, and 6 would result in the long-term retention of at least 71 

percent of the original POG, 63 percent of the original high-volume POG, and 51 

percent of the original large-tree POG. In addition, the conservation strategy in each 

of these alternatives would result in the spatial distribution of POG within reserves 

across the province. Further, Alternatives 1, 2, 3, and 6 would fully protect both 

pinch-points within the province by including them within reserves; Alternative 5 

would fully protect one pinch-point and provide substantial protection to the second. 

Alternative 5 would not provide as much POG in reserves, but would provide more 

POG within the matrix because of the marten standards and guidelines. 

Alternatives 4 and 7, on the other hand, would not protect the pinch-point between 

northeast Chichagof and the main island. Further, because of a relatively low 
 Environment and Effects 3 

Final EIS 3-207 Biodiversity 

abundance and non-uniform distribution of reserves within the province, Alternative 

7 and, to a lesser extent, Alternative 4, would likely result in gaps in the distribution 

of some organisms within the province and lower biodiversity. 

West Chichagof Island 

No past harvest has been mapped within the West Chichagof Island province and 

less than 200 acres (mostly on non-NFS lands) are projected to be harvested in the 

future. Therefore, the percentage of original POG remaining in the province after 

100+ years would be almost 100 percent (Table 3.9-20). Future development is not 

expected to change the percentage of large watersheds in an intact condition either; 

currently this percentage is 100 percent. As a result, because of the very limited 

extent of future development, cumulative effects on biodiversity are expected to be 

virtually non-existent under any of the alternatives. 

East Baranof Island 

Past cumulative harvest in this biogeographic province has removed 13 percent of 

the POG on all lands combined, resulting in 87 percent of the original POG 

remaining. Future harvest is expected to remove an additional 1 to 17 percent, 

resulting in approximately 70 to 86 percent of the original POG remaining after 100+ 

years (Table 3.9-20). High-volume POG is currently estimated to represent 77 

percent of its original acreage. Future representation of high-volume POG is 

expected to be a minimum of 60 to 76 percent (Table 3.9-21). Similarly, large-tree 

POG is expected to decline from about 33 percent of original acreage at present, to 

a minimum of 31 to 33 percent after 100+ years (Table 3.9-22). Therefore, although 

past large-tree POG harvest has been disproportionately high, the vast majority of 

remaining large-tree POG is in reserves and less than 10 percent of this remaining 

large-tree POG would be harvested under any of the alternatives. 

Currently, 55 percent of the large watersheds (representing 60 percent of the 

acreage) are considered to be in an intact condition. After 100+ years, this percent 

age is expected to be reduced to a minimum of 45 percent (representing 49 percent 

of the acreage), depending on the alternative (Table 3.9-19). 

Cumulative effects on biodiversity associated with Alternative 1 would be similar to 

those associated with existing conditions, because less than 1,000 additional acres 

of harvest would occur (on non-NFS lands). Alternatives 2, 3, 5, and 6 would result 

in a maximum of 6,000 to 11,000 additional acres of POG harvest. As is the case 

for East Chichagof Island province, specific watersheds would undergo high 

cumulative harvest under these alternatives; however, the conservation strategy 

would provide for extensive areas in reserves, distributed across the province, 

resulting in the retention of a minimum of 76 percent of original POG. Alternatives 4 

and 7 would result in 15,000 to 17,000 additional acres of harvest and, although the 

southern half of the province would substantially be in reserves, the northern half 

would have large areas with no reserves, resulting in higher cumulative effects on 

biodiversity. 

West Baranof Island 

Approximately 8 percent of the original POG in this province has been harvested, 

resulting in 92 percent of the original POG remaining. Following maximum future 

harvest after 100+ years, the percentage of original POG remaining would range 

from 80 percent (Alternative 7) to 88 percent (Alternative 1) (Table 3.9-20). Highvolume POG is currently estimated to represent 82 percent of its original acreage. 

Future representation of high-volume POG is expected to be a minimum of 68 to 77 

percent (Table 3.9-21). Similarly, large-tree POG is expected to decline from about 

44 percent of original acreage at present, to a minimum of 37 to 39 percent after 
3 Environment and Effects

Biodiversity 3-208 Final EIS

100+ years (Table 3.9-22). Therefore, as is the case for East Baranof Island 

province, although past large-tree POG harvest has been disproportionately high, 

the vast majority of remaining large-tree POG is in reserves and less than 10 

percent of this remaining large-tree POG would be harvested under any of the 

alternatives. 

Currently, 65 percent of the large watersheds (representing 69 percent of the 

acreage) of the province are considered to be in an intact condition. After 100+ 

years, this percentage is expected to be reduced to a minimum of 47 to 58 percent 

(representing 54 to 65 percent of the acreage), depending on the alternative (Table 

3.9-19). In addition to timber harvest, additional development associated with Sitka 

and possible road and transmission line extensions within the province would 

contribute to cumulative effects. 

Cumulative effects on biodiversity associated with Alternative 1 would only be 

associated with past harvest and non-NFS harvest because no NFS harvest would 

occur. Alternatives 2, 3, 5, and 6 would result in a maximum of 11,000 to 16,000 

additional acres of POG harvest. As is the case for East Baranof Island province, 

specific watersheds would undergo high cumulative harvest under these 

alternatives; however, the conservation strategy would provide for extensive areas 

in reserves, distributed across the province, resulting in the retention of a minimum 

of 86 percent of original POG under these alternatives. In addition, Alternatives 1, 2, 

3, and 6 would provide additional matrix retention as a result of the application of the 

legacy forest structure standard and guideline in four VCUs within the province. 

Under Alternatives 4 and 7, 28,000 to 31,000 additional acres of harvest (including 

non-NFS harvest) would occur and, although the southern half of the province would 

substantially be in reserves, the northern half would have large areas with no 

reserves, resulting in higher cumulative effects on biodiversity. 

Admiralty Island 

The Admiralty Island province has experienced 29,000 acres of past harvest; this 

represents only 5 percent of the original POG because of the size of the province 

and its extensive amount of POG. No NFS harvest would occur in the future and, 

although several thousand additional acres of harvest on non-NFS lands is expected 

to occur, the remaining POG would still be close to 95 percent of the original POG 

after 100+ years (Table 3.9-20). Similarly, high-volume POG is expected to change 

from about 94 to 93 percent and large-tree POG is expected to decrease from about 

91 to 90 percent, purely as a result of non-NFS harvest. 

Currently, 88 percent of the large watersheds (representing 85 percent of the 

acreage) of the portion of the province within the Tongass Forest boundary are 

considered to be in an intact condition. After 100+ years, this percentage is 

expected to be reduced to a minimum of 82 percent (representing 80 percent of the 

acreage) (Table 3.9-19). In addition to timber harvest, a proposed hydroelectric 

project and transmission line north of Angoon and continued operation and potential 

expansion of mining activity at Greens Creek would contribute to cumulative effects. 

Although past and future harvest and development are concentrated in a few 

watersheds, which would experience relatively high effects on biodiversity, the 

cumulative effect on the overall biodiversity of the province is not expected to be 

high because of the expansive size and dominantly undeveloped nature of the 

province. Further, none of the future effects would be associated with NFS harvest. 

The vast majority of Admiralty Island would continue to remain intact under all 

alternatives and, as a result of the abundance of POG in this province, including 

high-volume and large-tree POG, it would continue to represent a massive reserve 

and reservoir for biological diversity in Southeast Alaska. 
 Environment and Effects 3 

Final EIS 3-209 Biodiversity 

Lynn Canal 

Past cumulative harvest in this biogeographic province has removed only 3 percent 

of the POG on all lands combined, resulting in 97 percent of the original POG 

remaining. Future harvest is expected to remove an additional 5 to 18 percent, 

resulting in approximately 79 to 92 percent of the original POG remaining after 100+ 

years (Table 3.9-20). High-volume POG is currently estimated to represent 95 

percent of its original acreage. Future representation of high-volume POG is 

expected to be a minimum of 71 to 87 percent (Table 3.9-21). Similarly, large-tree 

POG is expected to decline from about 88 percent of original acreage at present, to 

a minimum of 64 to 78 percent after 100+ years (Table 3.9-22). 

Currently, 76 percent of the large watersheds (representing 80 percent of the 

acreage) are considered to be in an intact condition. After 100+ years, this percent 

age is expected to be reduced to a minimum of 32 to 56 percent (representing 45 to 

64 percent of the acreage), depending on the alternative (Table 3.9-19). In addition 

to timber harvest, continued development of areas around Juneau, Skagway, and 

Haines, the potential development of the Kensington Mine near Berners Bay, and 

the proposed development of the Juneau Access Road, would contribute to 

cumulative effects in this province. 

Alternatives 1, 2, and 3 would result in a maximum of 5,000 to 12,000 acres of 

additional harvest resulting in the retention of at least 88 percent of original POG. 

Alternatives 5 and 6 would result in a maximum of 20,000 to 23,000 additional acres 

of POG harvest, resulting in the retention of a minimum of 84 percent of original 

POG. In addition, these five alternatives would incorporate a conservation strategy 

that would result in the spatial distribution of reserves, which would limit effects on 

biodiversity. Alternatives 4 and 7 would result in a maximum of 29,000 to 31,000 

additional cumulative acres of harvest, which would produce a retention of at least 

79 percent of the original POG. Even though there would be large areas with no 

reserves, the province would have extensive reserves even under Alternatives 4 and 

7, which would limit effects on biodiversity. 

Northern Coast Range 

Approximately 6 percent of the original POG in this province has been harvested, 

resulting in 94 percent of the original POG remaining. Following maximum future 

harvest after 100+ years, the percentage of original POG remaining would range 

from 76 percent (Alternative 7) to 89 percent (Alternative 1) (Table 3.9-20). Highvolume POG is currently estimated to represent 92 percent of its original acreage. 

Future representation of high-volume POG is expected to be a minimum of 70 to 83 

percent (Table 3.9-21). Similarly, large-tree POG is expected to decline from about 

77 percent of original acreage at present, to a minimum of 52 to 66 percent after 

100+ years (Table 3.9-22). 

Currently, 90 percent of the large watersheds (representing 94 percent of the 

acreage) of the province are considered to be in an intact condition. After 100+ 

years, this percentage is expected to be reduced to a minimum of 31 to 67 percent 

(representing 54 to 80 percent of the acreage), depending on the alternative (Table 

3.9-19). 

Harvest on NFS lands would not contribute to cumulative effects under Alternatives 

1 and 2, and would contribute only in a minor way under Alternative 3. Almost all 

future harvest would be on non-NFS lands under these alternatives; long-term 

retention of POG would be about 88 to 89 percent. Under Alternatives 5 and 6, 

cumulative harvest would be a maximum of 48,000 to 52,000 acres; however, the 

conservation strategy under these two alternatives would provide for extensive 

areas in reserves, distributed across the province, resulting in the retention of a 

minimum of 81 percent of original POG. Under Alternatives 4 and 7, 65,000 to 
3 Environment and Effects

Biodiversity 3-210 Final EIS

68,000 additional acres of harvest (including non-NFS harvest) would occur and 

there would be large areas with no reserves, resulting in higher cumulative effects 

on biodiversity. 

Kupreanof/Mitkof Islands 

The Kupreanof/Mitkof Islands province has experienced 71,000 acres of past 

harvest, which represents 17 percent of the original POG; as a result, 83 percent of 

the original POG remains today. Following maximum future harvest after 100+ 

years, the percentage of original POG remaining would range from 53 percent 

(Alternative 7) to 74 percent (Alternative 1) (Table 3.9-20). High-volume POG is 

currently estimated to represent 71 percent of its original acreage. Future 

representation of high-volume POG is expected to be a minimum of 41 to 61 percent 

(Table 3.9-21). Similarly, large-tree POG is expected to decline from about 47 

percent of original acreage at present, to a minimum of 29 to 42 percent after 100+ 

years (Table 3.9-22). 

Currently, 37 percent of the large watersheds (representing 39 percent of the 

acreage) of the portion of the province within the Tongass Forest boundary are 

considered to be in an intact condition. After 100+ years, this percentage is 

expected to be reduced to a minimum of 8 to 31 percent (representing 9 to 30 

percent of the acreage) (Table 3.9-19). In addition to timber harvest, additional 

development in the Petersburg and Kake areas and proposed additional road and 

transmission line development (especially between Petersburg and Kake) would 

contribute to cumulative effects. 

Projected future cumulative harvest could be as high as 35,000 (Alternative 1) to 

87,000 acres (Alternative 5) under Alternatives 1, 2, 3, 5, or 6. These harvest levels 

would result in the retention of 61 to 74 percent of the original POG, 49 to 61 

percent of the original high-volume POG, and 34 to 42 percent of the original largetree POG. These cumulative harvest levels would result in a reduction in habitat for 

species that prefer older forest stages (particularly larger tree types) and increases 

in habitat for species that prefer younger forest stages. However, the conservation 

strategy employed in each of these alternatives would result in POG being 

distributed in reserves and within the matrix across the province so that, although 

local reductions in biodiversity would be expected, habitat representation across the 

province would be maintained. Alternative 5 would not provide as much POG in 

reserves as Alternatives 1, 2, 3, and 6; however, it would provide more POG within 

the matrix because of the marten standards and guidelines. Under Alternatives 4 

and 7, harvest could be as high as 104,000 to 119,000 additional acres, resulting in 

the retention of 53 to 57 percent of original POG, 41 to 44 percent of original highvolume POG, and 29 to 32 percent of large-tree POG. These cumulative harvest 

levels would result in greater reductions in habitat for species that prefer older forest 

stages, but more importantly, these alternatives would result in large expanses of 

habitat areas without POG in reserves, particularly under Alternative 7. 

Kuiu Island 

Past cumulative harvest in this biogeographic province has removed 9 percent of 

the POG on all lands combined, resulting in 91 percent of the original POG 

remaining. Future cumulative harvest is expected to remove from less than 1 

percent (Alternative 1) to 22 percent of additional POG acreage, resulting in 

approximately 69 to 91 percent of the original POG remaining after 100+ years 

(Table 3.9-20). High-volume POG is currently estimated to represent 90 percent of 

its original acreage. Future representation of high-volume POG is expected to be a 

minimum of 66 to 89 percent (Table 3.9-21). Similarly, large-tree POG is expected 
 Environment and Effects 3 

Final EIS 3-211 Biodiversity 

to decline from about 82 percent of original acreage at present, to a maximum of 52 

to 81 percent after 100+ years (Table 3.9-22). 

Currently, 73 percent of the large watersheds (representing 60 percent of the 

acreage) are considered to be in an intact condition. After 100+ years, this 

percentage is expected to be reduced to a minimum of 47 to 73 percent 

(representing 34 to 60 percent of the acreage), depending on the alternative (Table 

3.9-19). 

Cumulative effects on biodiversity associated with Alternative 1 would only be 

associated with past harvest and non-NFS harvest because no NFS harvest would 

occur. Alternatives 2, 3, 5, and 6 would result in a cumulative maximum of 20,000 to 

41,000 acres of additional harvest, resulting in the long-term retention of at least 79 

to 85 percent of original POG, 75 to 82 percent of original high-volume POG, and 61 

to 67 percent of original large-tree POG. In addition, these four alternatives would 

incorporate a conservation strategy that would result in the spatial distribution of 

reserves, which would limit effects on biodiversity. Alternatives 4 and 7 would result 

in a maximum of 62,000 to 72,000 additional cumulative acres of harvest, which 

would result in the retention of at least 69 to 72 percent of the original POG, 66 to 69 

percent of high-volume POG, and 52 to 56 percent of large-tree POG. These two 

alternatives would result in large expanses of habitat areas without POG in 

reserves, which would increase their effects on biodiversity. 

Central Coast Range 

Approximately 3 percent of the original POG in this province has been harvested, 

resulting in 97 percent of the original POG remaining. Following maximum future 

harvest after 100+ years, the percentage of original POG remaining would range 

from 80 percent (Alternative 7) to 96 percent (Alternative 1) (Table 3.9-20). Highvolume POG is currently estimated to represent 95 percent of its original acreage. 

Future representation of high-volume POG is expected to be a minimum of 79 to 94 

percent (Table 3.9-21). Similarly, large-tree POG is expected to decline from about 

89 percent of original acreage at present, to a minimum of 72 to 89 percent after 

100+ years (Table 3.9-22). 

Currently, 79 percent of the large watersheds (representing 85 percent of the 

acreage) of the province are considered to be in an intact condition. After 100+ 

years, this percentage is expected to be reduced to a minimum of 38 to 72 percent 

(representing 51 to 77 percent of the acreage), depending on the alternative (Table 

3.9-19). 

Additional harvest on NFS lands would not contribute to cumulative effects under 

Alternative 1 and only in a limited way under Alternative 2. Under Alternatives 3, 5, 

and 6, additional cumulative harvest would range from 20,000 acres to 31,000 

acres, resulting in long-term POG retention of 85 to 89 percent, long-term highvolume POG retention of 84 to 87 percent, and long-term large-tree POG retention 

of 78 to 82 percent. The conservation strategy under these alternatives would 

provide for extensive areas in reserves, distributed across the province. Under 

Alternatives 4 and 7, 39,000 to 43,000 additional acres of harvest (including nonNFS harvest) would occur, resulting in long-term POG retention of 80 to 82 percent, 

long-term high-volume POG retention of 79 to 80 percent, and long-term large-tree 

POG retention of 72 to 73 percent. There would be some large areas with no 

reserves, under these two alternatives, resulting in higher cumulative effects on 

biodiversity. 
3 Environment and Effects

Biodiversity 3-212 Final EIS

Etolin Island and Vicinity 

The Etolin Island and Vicinity province has experienced 41,000 cumulative acres of 

past harvest representing 15 percent of the original POG; as a result, 85 percent of 

the original POG remains today. Following maximum future harvest after 100+ 

years, the percentage of original POG remaining would range from 55 percent 

(Alternative 7) to 78 percent (Alternative 1) (Table 3.9-20). High-volume POG is 

currently estimated to represent 76 percent of its original acreage. Future 

representation of high-volume POG is expected to be a minimum of 45 to 67 percent 

(Table 3.9-21). Similarly, large-tree POG is expected to decline from about 51 

percent of original acreage at present, to a minimum of 30 to 46 percent after 100+ 

years (Table 3.9-22). 

Currently, 33 percent of the large watersheds (representing 30 percent of the 

acreage) of the portion of the province within the Tongass Forest boundary are 

considered to be in an intact condition. After 100+ years, this percentage is 

expected to be reduced to a minimum of 11 to 26 percent (representing 12 to 23 

percent of the acreage) (Table 3.9-19). In addition to timber harvest, additional 

development in the Wrangell area would contribute to cumulative effects. 

Projected future cumulative maximum harvest would be 19,000 acres under 

Alternative 1, resulting in 78 percent long-term POG retention. Under Alternatives 2, 

3, 5, and 6 the cumulative maximum harvest would be 38,000 (Alternative 2) to 

50,000 acres (Alternative 5). These harvest levels would result in the retention of 67 

to 71 percent of the original POG, 57 to 61 percent of the original high-volume POG, 

and 39 to 42 percent of the original large-tree POG. These cumulative harvest 

levels would result in a reduction in habitat for species that prefer older forest stages 

(particularly larger tree types) and increases in habitat for species that prefer 

younger forest stages. However, the conservation strategy employed in each of 

these alternatives would result in POG being distributed in reserves and within the 

matrix across the province so that, although local reductions in biodiversity would be 

expected, habitat representation across the province would be maintained. The 

legacy forest structure standard and guideline would provide for additional POG in 

the matrix under Alternatives 1, 2, 3, and 6, and the marten standard and guideline 

would provide this for Alternative 5. Under Alternatives 4 and 7, harvest could be as 

high as 72,000 to 83,000 additional acres, resulting in the retention of 55 to 59 

percent of original POG, 45 to 50 percent of original high-volume POG, and 30 to 33 

percent of large-tree POG. These cumulative harvest levels would result in greater 

reductions in habitat for species that prefer older forest stages, but more importantly, 

these two alternatives would result in large expanses of habitat areas without POG 

in reserves. In addition, POG in the matrix would not be supplemented by either the 

legacy or the marten standard and guideline. As a result, these two alternatives 

would have a relatively high effect on province biodiversity. 

North Central Prince of Wales Island 

Approximately 35 percent of the original POG in this province has been harvested, 

resulting in 65 percent of the original POG remaining. Following maximum future 

harvest after 100+ years, the percentage of original POG remaining would range 

from 44 percent (Alternative 7) to 59 percent (Alternative 1) (Table 3.9-20). Highvolume POG is currently estimated to represent 56 percent of its original acreage. 

Future representation of high-volume POG is expected to be a minimum of 33 to 45 

percent (Table 3.9-21). Similarly, large-tree POG is expected to decline from about 

55 percent of original acreage at present, to a minimum of 35 to 47 percent after 

100+ years (Table 3.9-22). 

Currently, 24 percent of the large watersheds (representing 17 percent of the 

acreage) of the province are considered to be in an intact condition. After 100+ 
 Environment and Effects 3 

Final EIS 3-213 Biodiversity 

years, this percentage is expected to be reduced to a minimum of 10 to 20 percent 

(representing 6 to 13 percent of the acreage), depending on the alternative (Table 

3.9-19). In addition to timber harvest, additional development associated with 

Klawock, Craig, Thorne Bay, and the many other small communities in the province 

would contribute to cumulative effects. 

Under Alternatives 1 and 2, additional cumulative harvest would range from 89,000 

acres to 104,000 acres, resulting in long-term POG retention of 54 to 55 percent, 

long-term high-volume POG retention of 44 to 45 percent, and long-term large-tree 

POG retention of 45 to 47 percent. Projected future cumulative maximum harvest 

would be 118,000 to 131,000 acres under Alternatives 3, 5, and 6, resulting in 51 to 

52 percent long-term POG retention, 41 to 42 percent long-term high-volume POG 

retention, and 43 to 44 percent long-term large-tree POG retention. The 

conservation strategy under Alternatives 1, 2, 3, 5, and 6 would provide for 

extensive areas in reserves, distributed across the province. In addition, the legacy 

forest structure standard and guideline would provide for additional POG in the 

matrix under Alternatives 1, 2, 3, and 6, and the goshawk and marten standards and 

guidelines would provide this for Alternative 5. Alternatives 1, 2, 3, and 6 would 

provide reserves to maintain connectivity for the Neck Lake pinch-point, while 

Alternative 5 would provide for some connectivity. These alternatives also would 

provide a number of reserves in the Sulzer Portage pinch-point area to enhance 

connectivity. Under Alternatives 4 and 7, 150,000 to 198,000 additional acres of 

harvest (including non-NFS harvest) would occur, resulting in long-term POG 

retention of 44 to 49 percent, long-term high-volume POG retention of 33 to 39 

percent, and long-term large-tree POG retention of 35 to 40 percent. Alternative 4 

would supplement the pool of non-development LUDs in this province with an array 

of Old-Growth Habitat LUD areas, although the extent of reserves would be less 

than under Alternatives 1, 2, 3, 5, or 6. Alternative 7, on the other hand, would not 

include Old-Growth Habitat LUDs and would have large areas with no reserves. In 

addition, POG in the matrix would not be supplemented by either the legacy or the 

marten standard and guideline. Alternative 4 would provide for some connectivity at 

the Neck Lake pinch-point, but would not provide much in the way of reserves near 

the Sulzer Portage pinch-point. Alternative 7 would provide not provide very few 

acres of reserves in the vicinity of either pinch-point. As a result, Alternative 4 would 

have a relatively high effect on province biodiversity and Alternative 7 would have a 

very high effect. Alternative 7 and, to a lesser extent, Alternative 4, would likely 

result in gaps in the distribution of some organisms within the province and lower 

biodiversity. 

Revilla Island/Cleveland Peninsula 

The Revilla Island/Cleveland Peninsula province has had 71,000 cumulative acres 

of past harvest representing 11 percent of the original POG; as a result, 89 percent 

of the original POG remains today. Following maximum future harvest after 100+ 

years, the percentage of original POG remaining would range from 66 percent 

(Alternative 7) to 81 percent (Alternative 1) (Table 3.9-20). High-volume POG is 

currently estimated to represent 84 percent of its original acreage. Future 

representation of high-volume POG is expected to be a minimum of 58 to 74 percent 

(Table 3.9-21). Similarly, large-tree POG is expected to decline from about 59 

percent of original acreage at present, to 44 to 55 percent after 100+ years (Table 

3.9-22). 

Currently, 68 percent of the large watersheds (representing 71 percent of the 

acreage) of the portion of the province within the Tongass Forest boundary are 

considered to be in an intact condition. After 100+ years, this percentage is 

expected to be reduced to a minimum of 33 to 55 percent (representing 43 to 60 

percent of the acreage) (Table 3.9-19). In addition to timber harvest, additional 
3 Environment and Effects

Biodiversity 3-214 Final EIS

development in the Ketchikan, Saxman, and Metlakatla areas, including the SwanTyee transmission line (under construction), would contribute to cumulative effects. 

Projected future cumulative maximum harvest would be 49,000 acres to 77,000 

acres under Alternatives 1, 2, and 3, resulting in 77 to 81 percent long-term POG 

retention, 70 to 74 percent of the original high-volume POG retention, and 52 to 55 

percent of the original large-tree POG retention. Under Alternatives 5 and 6 the 

cumulative maximum harvest would be 94,000 acres. These harvest levels for 

Alternatives 5 and 6 would result in the retention of 74 percent of the original POG, 

68 percent of the original high-volume POG, and 50 percent of the original large-tree 

POG. These cumulative harvest levels would result in a reduction in habitat for 

species that prefer older forest stages (particularly larger tree types) and increases 

in habitat for species that prefer younger forest stages. However, the conservation 

strategy employed in each of these alternatives would result in POG being 

distributed in reserves and within the matrix across the province so that, although 

local reductions in biodiversity would be expected, habitat representation across the 

province would be maintained. The legacy forest structure standard and guideline 

would provide for additional POG in the matrix under Alternatives 1, 2, 3, and 6, and 

the marten standard and guideline would provide this for Alternative 5. Under 

Alternatives 4 and 7, harvest could be as high as 128,000 to 151,000 additional 

acres, resulting in the retention of 66 to 69 percent of original POG, 58 to 62 percent 

of original high-volume POG, and 44 to 46 percent of large-tree POG. These 

cumulative harvest levels would result in greater reductions in habitat for species 

that prefer older forest stages, but more importantly, these two alternatives 

(especially Alternative 7) would result in large expanses of habitat areas without 

POG in reserves. In addition, POG in the matrix would not be supplemented by 

either the legacy or the marten standard and guideline. As a result, these two 

alternatives would have a relatively high effect on province biodiversity. 

Southern Outer Islands 

Approximately 15 percent of the original POG in this province has been harvested, 

resulting in 85 percent of the original POG remaining. Following maximum future 

harvest after 100+ years, the percentage of original POG remaining would range 

from 72 percent (Alternative 7) to 80 percent (Alternative 1) (Table 3.9-20). Highvolume POG is currently estimated to represent 77 percent of its original acreage. 

Future representation of high-volume POG is expected to be a minimum of 61 to 70 

percent (Table 3.9-21). Similarly, large-tree POG is expected to decline from about 

67 percent of original acreage at present, to a minimum of 49 to 60 percent after 

100+ years (Table 3.9-22). 

Currently, 50 percent of the large watersheds (representing 64 percent of the 

acreage) of the province are considered to be in an intact condition. After 100+ 

years, this percentage is expected to be reduced to a minimum of 45 to 50 percent 

(representing 59 to 64 percent of the acreage), depending on the alternative (Table 

3.9-19). 

Most of the islands that make up this province are entirely in reserves under all 

alternatives. Harvest would be limited to Heceta and Suemez in all alternatives, as 

well as San Juan Bautista Islands in Alternatives 3, 5, and 6. Alternatives 1, 2, 3, 5, 

and 6 would result in the maximum future cumulative harvest of 7,000 to 12,000 

acres, producing a long-term retention of 76 to 80 percent of the original POG, 66 to 

70 percent of the original high-volume POG, and 56 to 60 percent of the original 

large-tree POG. The conservation strategy in each of these alternatives would 

result in the spatial distribution of POG within reserves across the province. Under 

Alternatives 4 and 7, harvest could be as high as 14,000 to 19,000 additional acres, 

resulting in the retention of 72 to 75 percent of original POG, 61 to 64 percent of 
 Environment and Effects 3 

Final EIS 3-215 Biodiversity 

original high-volume POG, and 49 to 53 percent of large-tree POG. These latter two 

alternatives would result larger habitat areas without POG in reserves. 

Dall Island and Vicinity 

Past cumulative harvest in this biogeographic province has removed 25 percent of 

the POG on all lands combined, resulting in 75 percent of the original POG 

remaining. Future cumulative harvest is expected to remove from less than 17 

percent (Alternative 1) to 22 percent of additional POG acreage, resulting in 

approximately 53 to 58 percent of the original POG remaining after 100+ years 

(Table 3.9-20). The vast majority of this future harvest is on non-NFS lands under 

all alternatives. High-volume POG is currently estimated to represent 77 percent of 

its original acreage. Future representation of high-volume POG is expected to be a 

minimum of 61 to 70 percent (Table 3.9-21). Similarly, large-tree POG is expected 

to decline from about 42 percent of original acreage at present, to a minimum of 36 

to 37 percent after 100+ years (Table 3.9-22). The great majority of this retention 

would be in reserves. 

Currently, 71 percent of the large watersheds (representing 53 percent of the 

acreage) are considered to be in an intact condition. After 100+ years, this 

percentage is expected to be reduced to a minimum of 29 to 34 percent 

(representing 15 to 19 percent of the acreage), depending on the alternative (Table 

3.9-19). 

The maximum cumulative future harvest would be 23,000 to 29,000 acres under all 

of the alternatives, with 23,000 acres of harvest on non-NFS lands and from 0 to 

6,000 acres on NFS lands. At least 80 percent of the original POG on NFS lands 

would be in reserves under all alternatives. The only area on NFS harvest would be 

at the extreme northwestern corner of Dall Island with no harvest planned on Long 

Island. The reserves on Dall Island stretch the entire length of the island on the 

west side. Therefore, although a substantial portion of the non-NFS POG is 

expected to be harvested, the contribution by NFS harvest would be relatively small. 

South Prince of Wales 

The South Prince of Wales Island province has had 18,000 cumulative acres of past 

harvest representing 9 percent of the original POG; as a result, 91 percent of the 

original POG remains today. Following maximum future harvest after 100+ years, 

the percentage of original POG remaining would range from 68 percent (Alternative 

7) to 87 percent (Alternative 1) (Table 3.9-20). High-volume POG is currently 

estimated to represent 88 percent of its original acreage. Future representation of 

high-volume POG is expected to be a minimum of 64 to 83 percent (Table 3.9-21). 

Similarly, large-tree POG is expected to decline from about 88 percent of original 

acreage at present, to a minimum of 65 to 85 percent after 100+ years (Table 3.9-

22). 

Currently, 78 percent of the large watersheds (representing 75 percent of the 

acreage) of the portion of the province within the Tongass Forest boundary are 

considered to be in an intact condition. After 100+ years, this percentage is 

expected to be reduced to a minimum of 47 to 72 percent (representing 45 to 69 

percent of the acreage) (Table 3.9-19). 

Projected future cumulative maximum harvest would be 8,000 acres to 26,000 acres 

under Alternatives 1, 2, 3, 5, and 6, resulting in 77 to 87 percent long-term POG 

retention, 73 to 83 percent of the original high-volume POG retention, and 76 to 85 

percent of the original large-tree POG retention. The conservation strategy 

employed in each of these alternatives would result in POG being distributed in 

reserves and within the matrix across the province so that, although local reductions 
3 Environment and Effects

Biodiversity 3-216 Final EIS

in biodiversity would be expected, habitat representation across the province would 

be maintained. The goshawk and marten standards and guidelines would provide 

additional POG in the matrix in this province under Alternative 5. Under Alternatives 

4 and 7, harvest could be as high as 37,000 to 43,000 additional acres, resulting in 

the retention of 68 to 71 percent of original POG, 64 to 67 percent of original highvolume POG, and 65 to 69 percent of large-tree POG. In all alternatives, large 

reserves exist in the southern and western portions of the province. However, 

Alternatives 4 and 7 do not include reserves over large areas in the north and east 

parts of the province, as well as portions of the west. As a result, these two 

alternatives would have a higher effect on province biodiversity. 

North Misty Fiords 

Only 2,000 acres of past harvest has occurred in the North Misty Fiords province, 

and up to 7,000 acres is projected for the future. As a result, a minimum of 95 

percent of the POG originally found in the province is expected to be retained long 

term, relative to the 99 percent at present (Table 3.9-20). Similarly, neither highvolume nor large-tree POG are expected to drop below 90 percent of their original 

acreages. Also, future development is not expected to reduce the percentage of 

large watersheds in intact condition to less than 88 percent by number or 91 percent 

by acreage, under any of the alternatives (Table 3.9-19). Therefore, because of the 

very limited extent of future development, cumulative effects on biodiversity are 

expected to be very low under any of the alternatives. 

South Misty Fiords 

No past harvest has been mapped within the South Misty Fiords province and less 

than 200 acres (on non-NFS lands) are projected to be harvested in the future. 

Therefore, the percentage of original POG remaining in the province after 100+ 

years would be almost 100 percent (Table 3.9-20). Future development is not 

expected to change the percentage of large watersheds in an intact condition either; 

currently this percentage is 100 percent. As a result, because of the very limited 

extent of future development, cumulative effects on biodiversity are expected to be 

virtually non-existent under any of the alternatives. 

Ice Fields 

Approximately 3 percent of the original POG in this province has been harvested, 

resulting in 97 percent of the original POG remaining. Following maximum future 

harvest after 100+ years, the percentage of original POG remaining would range 

from 93 percent (Alternative 7) to 97 percent (Alternative 1) (Table 3.9-20). Highvolume POG is currently estimated to represent 93 percent of its original acreage. 

Future representation of high-volume POG is expected to be a minimum of 90 to 93 

percent (Table 3.9-21). Similarly, large-tree POG is expected to decline from about 

83 percent of original acreage at present, to a minimum of 81 to 83 percent after 

100+ years (Table 3.9-22). 

Currently, 93 percent of the large watersheds (representing 94 percent of the 

acreage) of the province are considered to be in an intact condition. After 100+ 

years, this percentage is expected to be reduced to a minimum of 82 to 88 percent 

(representing 88 to 94 percent of the acreage), depending on the alternative (Table 

3.9-19). 

Cumulative effects on biodiversity associated with Alternative 1 would only be 

associated with past harvest because no NFS harvest and only a few acres of nonNFS harvest would occur. Alternatives 2, 3, 4, 5, 6 and 7 would result in a 

cumulative maximum of 1,000 to 4,000 acres of additional harvest, resulting in the 

long-term retention of at least 93 percent of original POG, 90 percent of high-volume 
 Environment and Effects 3 

Final EIS 3-217 Biodiversity 

POG, and 81 percent of large-tree POG. The vast majority of this POG is in 

reserves (Table 3.9-14). Therefore, although local watershed effects are expected, 

cumulative effects on biodiversity at the province level are expected to be minor. 

Chilkat River Complex 

The Chilkat River Complex province has had about 21,000 acres of past harvest, 

representing 12 percent of the original POG; therefore, 88 percent of the original 

POG remains today. The province lies entirely outside the Forest boundary, so 

there would be no future harvest on NFS lands associated with any of the 

alternatives. Approximately 32 percent of the existing POG, 26 percent of existing 

high-volume POG, and 11 percent of existing large-tree POG stands are located in 

reserves. 

Future cumulative harvest associated with state and private lands in the province, 

could result in up to 52,000 additional acres of POG harvest after 100+ years (Table 

3.9-20). With this additional harvest, the POG retention would amount to a minimum 

of 56 percent, with a minimum of 60 percent retention for high-volume POG and 32 

percent retention for large-tree POG. In addition, future development associated 

with Haines and Skagway could contribute to cumulative effects within the province. 

Tongass management would not contribute to cumulative effects within the province 

and would only contribute to a regional effect, relative to multiple adjacent provinces. 

The three provinces that are adjacent to the Chilkat River Complex are the Glacier 

Bay/Fairweather Range, the Ice Fields, and the Lynn Canal provinces. Among 

these three, the Lynn Canal province would be managed with the highest intensity. 

However, even in the Lynn Canal province, the long-term retention of POG would be 

79 to 92 percent, depending on the alternative. The Ice Fields and Glacier 

Bay/Fairweather Range provinces would retain 93 to 100 percent of their POG 

under any alternative (Table 3.9-20). 

Glacier Bay/Fairweather Range 

Past harvest within the Glacier Bay/Fairweather Range province has been limited to 

a few hundred acres. Similarly, negligible future cumulative harvest is projected 

under all alternatives. As a result, the percentage of original POG remaining in the 

province after 100+ years would be almost 100 percent (Table 3.9-20). Future 

development is not expected to change the percentage of large watersheds in an 

intact condition either; currently this percentage is also close to 100 percent 

because of Glacier National Park. Therefore, because of the very limited extent of 

future development, cumulative effects on biodiversity are expected to be negligible 

under any of the alternatives. 
3 Environment and Effects

Biodiversity 3-218 Final EIS

This page is intentionally left blank. 
 Environment and Effects 3 

Final EIS 3-219 Wildlife 

Wildlife 

Affected Environment ...............................................................................3-219 

Landscape Connectivity and Fragmentation ........................................3-221 

Species Accounts..................................................................................3-223 

Threatened and Endangered Species ..................................................3-223 

Candidate Species ................................................................................3-225 

Forest Service Sensitive Listed Species...............................................3-226 

Management Indicator Species ............................................................3-230 

Other Species of Concern.....................................................................3-241 

Endemism .............................................................................................3-248 

Invasive Species ...................................................................................3-250 

Environmental Consequences .................................................................3-252 

Introduction............................................................................................3-252 

Effects Analysis.....................................................................................3-255 

Candidate Species ................................................................................3-262 

Forest Service Sensitive Species .........................................................3-262 

Management Indicator Species ............................................................3-265 

Other Species of Concern.....................................................................3-286 

Cumulative Effects ................................................................................3-292

Affected Environment 

The Tongass National Forest supports a rich array of wildlife species, providing 

habitat for approximately 54 species of mammals, 231 species of birds, and 5 

species of amphibians and reptiles. There are an additional 18 species of marine 

mammals found in Southeast Alaska that depend entirely on the ocean 

environment, as well as 45 bird and 3 amphibian or reptile species considered 

casual or accidental visitors to Southeast Alaska. Some species that are relatively 

abundant on the Forest (e.g., bald eagles and brown bears) are listed as threatened 

or endangered in other parts of their range, and others are endemic to the Tongass 

(essentially found nowhere else in the world) and may occupy ranges limited to 

single islands. Other species have wide geographic ranges and are found 

elsewhere in Alaska, Canada, and the lower 48 states. The diversity of wildlife on 

the Forest provides many opportunities for consumptive and non-consumptive uses 

including commercial, general, and subsistence hunting; and photographic and 

viewing activities. 

This section provides an overview of wildlife habitats on the Tongass, describes 

current management regimes related to wildlife habitat and relevant policies, and 

provides information on key species and their habitats. The consumptive uses of 

wildlife are also briefly discussed. This section also addresses issues related to 

invasive species and endemism. Updated information presented at an interagency 

review of the Forest Plan Conservation Strategy, held in Ketchikan, Alaska, in April 

2006, is incorporated and referenced where appropriate. This workshop took into 

account new literature published since 1997 as well as ongoing research and 

included the presentation of preliminary results. 

Approximately 55 percent of the 16.8 million acres of the Tongass National Forest 

consists of temperate rainforest (see Figure 3.9-3 of the Biodiversity section). This 

includes both productive and non-productive old growth (POG), a classification that 

relates to the ability of a stand to grow trees of a certain size or volume per acre. 

Ninety-eight percent of the POG on the Tongass is dominated by Sitka spruce and 

western hemlock, both of which occur throughout Southeast Alaska. Approximately 
3 Environment and Effects

Wildlife 3-220 Final EIS

4 percent of the Tongass is young-growth forest (both natural and harvested), 

primarily distributed among four biogeographic provinces (North Central Prince of 

Wales, Etolin Island, Kupreanof/Mitkof, andRevillagigedo Island/Cleveland 

Peninsula). The remaining 41 percent of the Tongass consists non-forested habitat 

that includes sparsely vegetated areas of shrub and herbaceous (e.g., muskegs, 

alpine, estuaries), non-vegetated areas (e.g., snow, rock, ice), and aquatic sites 

(e.g., streams, ponds, and lakes). Tables 3.9-2 and 3.9-3 in the Biodiversity section 

show the distribution of forested and non-forested cover types on the Tongass. 

Although many wildlife species on the Tongass are associated with more than one 

habitat type, most inhabit old-growth forests or prey on species that inhabit oldgrowth forests. Old growth is characterized by a patchy, multi-layered canopy; trees 

that represent many age classes; large trees that dominate the overstory, standing 

dead (snags) or decadent trees; and higher accumulations of down woody material. 

The structure and function of an old-growth ecosystem will be influenced by stand 

size, landscape position, and juxtaposition with other elements of the landscape. 

POG can be broken down further in terms of seven categories based on tree size 

and density. See the Old-Growth Forest subsection in the Affected Environment 

portion of the Biodiversity section of this document, including Figures 3.9-4 and 3.9-

5, for a detailed discussion of old growth on the Tongass and the size-density model 

(SDM). 

The 1997 Forest Plan established a comprehensive, science-based old-growth 

conservation strategy to address wildlife sustainability and viability. This strategy 

was based on careful analysis and integration of the best scientific information 

available at that time and is comprised of two key components. 

The first is a Forest-wide reserve network that is designed to protect the integrity of 

the existing old-growth ecosystem. It incorporates a network of small, medium, and 

large old-growth reserves (OGRs) and other non-development Land Use 

Designations (LUDs), which protect 71 percent of the existing POG on the Tongass 

National Forest (Appendix D). 

The second component of the conservation strategy is a set of standards and 

guidelines that apply in the development LUDs where commercial timber harvesting 

is permitted (referred to as the matrix). In these areas, the standards and guidelines 

sustain key components of the landscape that the available scientific information 

indicates is important for wildlife. These include a 1,000-foot buffer along the entire 

marine shoreline and riparian buffer corridors. Standards and guidelines 

established for other reasons, also contribute protected old growth. Finally, 

assuming the maximum level of timber harvest permitted by the Forest Plan, there 

are additional areas that are not scheduled for harvest due to economic 

considerations. Collectively, these standards and guidelines and unscheduled 

areas would maintain at least 66 percent of the POG within the matrix or over 19 

percent of all POG on the Tongass (Appendix D). 

Overall, the conservation strategy in the 1997 Forest Plan protects slightly more 

than 90 percent of all existing POG forests on the Tongass. It is important to note 

that this percentage assumes that old-growth forest is harvested at the maximum 

allowable rate in each future decade before sufficient second-growth forest has 

reached harvestable size and can replace old growth in the harvest. If this 

maximum rate does not occur, then the percentage of POG retained will be higher. 

A more detailed description of the Tongass conservation strategy, and the basis for 

its development, is provided below under effects, in the Biodiversity section, and in 

Appendix D. 

Old-Growth 

Habitat and the 

Conservation 

Strategy 
 Environment and Effects 3 

Final EIS 3-221 Wildlife 

Landscape connectivity is defined as the degree to which the structure of a 

landscape helps or hinders the movement of wildlife species (Taylor et al. 1993). A 

“well-connected” landscape enables organisms to readily move among habitat 

patches over the long term. Fragmentation is the loss of connectivity across the 

landscape and is a substantial threat to many species, especially those that are 

smaller or less mobile. Fragmentation occurs when large blocks of habitat are 

broken into smaller parcels by natural (e.g., wind throw) or human induced (e.g., 

roads or timber operations) forces. As habitat is lost or fragmented, residual habitat 

patches become smaller and more isolated from each other. This limits the 

movement of species and, through their increased isolation, puts them at greater 

risk of extirpation. Open spaces left by fragmentation can act as travel barriers for 

some species, or increase the risk of predation for other species that venture across 

them (see the Biodiversity section for additional discussion on fragmentation). 

There are two types of landscape connectivity that can be considered: structural and 

functional connectivity (Brooks et al. 2003). Structural connectivity describes the 

physical relationships among habitat patches, generally ignoring the behavioral 

response of organisms to landscape structure. Landscape corridors, or areas of 

continuous habitat that link similar habitat patches in a landscape and thus facilitate 

the movement of species among isolated habitat patches, are representative of 

structural connectivity. On the Tongass, intact riparian buffers and the beach fringe 

function as corridors that facilitate dispersal and allow movement between small, 

isolated subpopulations of species. Advances in the fields of landscape ecology, 

habitat fragmentation, and population genetics have led to a broader view of 

connectivity, with less of a structured focus on corridors, and more of a perspective 

on the functional connectivity provided by landscape linkages or “linkage zones” 

(Bennett 1999 as cited in Haufler 2007). Functional connectivity relates to the 

degree of movement or flow of organisms through the landscape. Linkage zones 

are not necessarily discrete features of the landscape, but may occur where the 

juxtaposition of particular habitats or land uses act to funnel dispersers between 

habitat patches. The concept of functional connectivity addresses movement 

capabilities of individual species, habitat patches, landscape configurations, matrix 

conditions, barriers, and their relationships in maintaining continuous populations 

(Haufler 2007). On the Tongass, matrix lands play a vital role as landscape linkages 

because they provide functional connectivity between OGRs and other nondevelopment land use areas. 

The National Forest Management Act (NFMA) regulations provide that habitat must 

be “well distributed” so that "individuals can interact with others in the planning 

area." The continued existence of a population within which interaction between 

individuals becomes difficult (significantly less frequent) or impossible may no longer 

be well distributed, as segments of the population become isolated. The 

fragmentation of habitats, which isolates and creates small insular populations, 

contributes to decreased population distribution and increased likelihood of local 

extirpation (Wilcove et al. 1986). Because the Tongass is an island archipelago, 

relatively isolated populations may already exist with naturally higher risks to local 

extirpation (see discussion of endemism below). 

The idea of maintaining well-distributed habitats brings up the issue of scale, which 

is a fundamental difficulty underlying the assessment of functional landscape 

connectivity. For example, because species differ in their dispersal abilities and, 

therefore, the way they perceive patches as functionally connected, the scale of the 

interaction between the species and the landscape should be taken into account 

when assessing the connectedness of the landscape. That is, there are likely 

features within the matrix that are not conducive to crossing by some species that 

are most appropriately identified at the project level, rather than on a Forest-wide 

basis. As such, the following discussion takes a broader view of connectivity by 

focusing on areas where natural or human-caused features (e.g., roads and 

Landscape 

Connectivity and 

Fragmentation 
3 Environment and Effects

Wildlife 3-222 Final EIS

clearcuts) constrain potential movement by wildlife to narrow bands of habitat, often 

referred to as “pinch-points” or “bottlenecks.” 

These points often function as movement corridors and need special planning and 

design to ensure that wildlife migration patterns and habitat diversity are protected 

over the long term and are thus an important aspect in considering functional 

landscape connectivity. Additionally, determining if management activities are likely 

to create barriers that could affect species distribution on a landscape scale (e.g., 

within biogeographic provinces) is a useful means of identifying potential adverse 

short-term effects on maintaining well distributed, viable populations. 

“Pinch-points” can be geographic or ecologically based. For example, areas have 

been identified on the Tongass where geographic “pinch-points” connect major 

landscapes within islands. These are all relatively narrow areas between larger land 

units where future alterations in habitat could significantly reduce natural 

connectivity and limit the ability of land-based species to disperse or migrate. The 

following is a description of six key areas, identified by the Interdisciplinary Team 

(IDT) during the development of the 1997 Forest Plan, where a high amount of 

development has occurred; there are a number of additional pinch-points (e.g., the 

Cleveland peninsula between Santa Ana and Yes Bay and between Neets and 

Shrimp Bay) where concentrated harvest is less likely to occur during the life of the 

Forest Plan, which should be analyzed at the project level: 

1. The portage between Tenakee Inlet and West Port Frederick on Chichagof 

Island, a narrow neck of land connecting northeast Chichagof Island to the 

main body of the rest of the island. This is in the East Chichagof 

biogeographic province. 

2. The area connecting Lisianski Inlet with the North Arm of Peril Strait is a 

narrow region that connects two major portions of Chichagof Island. 

3. The area between Port Camden, Bay of Pillars, and 3-Mile Arm on Kuiu 

Island (Kuiu Island biogeographic province), a narrow neck of land 

connecting the northern and eastern part of the island to the rest of Kuiu 

Island. 

4. The narrow area between Lindenburg Peninsula and the remainder of 

Kupreanof Island. 

5. The Neck Lake area between Whale Passage and El Capitan Passage on 

Prince of Wales Island (North Central Prince of Wales biogeographic 

province) has experienced high levels of past and ongoing forest 

management activities. It also is a relatively narrow piece of land 

connecting the extreme northern end of Prince of Wales Island to the 

remainder of the island. 

6. Sulzer Portage, between the West Arm Cholmondeley Sound and Portage 

Bay at the head of Hetta Inlet, on Prince of Wales Island. This area has had 

considerable timber harvesting on both National Forest and adjacent private 

lands, and due to a recent transfer of land ownership the pinch-point itself is 

now all private land. This relatively narrow neck of land joins the southeast 

part of Prince of Wales Island to the remainder of the island, connecting 

North Central and South Prince of Wales biogeographic provinces. 

Ecological “pinch-points” are areas where habitat conditions within a landscape 

facilitate movement between habitat patches. These areas may be peninsulas of 

forested habitat surrounded by nonforested habitat that receive concentrated wildlife 

use and can best be identified by conducting a landscape connectivity analysis. 

Some species are very mobile through a variety of habitat conditions and some 

need relatively intact mature forest to successfully travel. Some conditions, such as 

large water crossings, present a barrier to movement to some species and not to 
 Environment and Effects 3 

Final EIS 3-223 Wildlife 

others. For most species, however, connectivity is not an either/or function. Pyare 

and Smith (2005, 2006) conducted a preliminary evaluation of functional connectivity 

on the Tongass by experimentally evaluating the movement potential of flying 

squirrels through various landscape elements in an intensively managed area on 

Prince of Wales Island to derive a spatial model to evaluate movement potential at a 

larger scale. Experiments revealed that flying squirrels moved with the least 

resistence across large expanses of old-growth and old-growth fragments, followed 

by second-growth up to 100 meters wide, with the most resistence in regenerating 

clearcuts and young second growth greater than 100 meters wide. Noteably, while 

males appeared to have a high movement potential in fragmented landscapes, 

females and juveniles did not. This detailed level of pinch-point analysis is 

necessarily done at a finer scale during project planning or landscape analyses 

(Smith and Pyare 2005, 2006). 

The following species accounts are divided into five sections: Threatened and 

Endangered Species, Candidate Species, Forest Service Sensitive Species, 

Management Indicator Species, and Other Species of Concern. Species on 

“sensitive lists” compiled by other entities (e.g., Boreal Partners in Flight, Alaska 

Natural Heritage Program, and Alaska Department of Fish and Game (ADF&G) 

Nongame) are addressed through the Regional Forester’s sensitive species list. 

This list is in the process of being updated. Table 3.10-1 lists all species considered 

for this section. 

Federally listed threatened and endangered species are those plant and animal 

species formally listed by the U.S. Fish and Wildlife Service (USFWS) or National 

Marine Fisheries Service (NMFS) under authority of the Endangered Species Act 

(ESA) of 1973, as amended. An endangered species is defined as one that is in 

danger of extinction throughout all or a significant portion of its range. A threatened 

species is defined as one that is likely to become an endangered species within the 

foreseeable future throughout all or a significant portion of its range. 

The federally listed wildlife species within the boundary of the Tongass National 

Forest include humpback whale (Megaptera novaeangliae) and Steller sea lion 

(Eumetopias jubata). Recovery plans have been prepared for the humpback whale 

and Steller sea lion. The ESA for the State of Alaska authorizes the Commissioner 

of the ADF&G to list Alaska endangered species. Species listed as endangered by 

the State of Alaska include the short-tailed albatross (Diomedea albatrus), 

humpback whale, right whale (Eubalaena glacialis), and blue whale (Balaenoptera 

musculus). With the exception of the humpback whale, none of these species occur 

in Southeast Alaska and therefore are not considered further here. 

Pursuant to Section 7 of the ESA, a Biological Assessment was prepared to assess 

the effects of the 1997 Forest Plan revision on endangered or threatened species 

and ensure that proposed actions would not jeopardize the continue existence of 

listed species (specifically, humpback whale and the eastern population of the 

Steller sea lion) and was submitted to NMFS for review and concurrence. The 

Biological Assessments and agency concurrences for the Forest Plan revision can 

be found in Appendix J of the 1997 Forest Plan Revision Final EIS. Humpback 

whales and Steller sea lions will not be addressed further in this document, but are 

evaluated in an updated Biological Assessment prepared for the current Forest Plan 

amendment (Appendix F). 

The Queen Charlotte goshawk and the Alexander Archipelago wolf were both the 

subject of listing petitions under the ESA in the 1990s; the petitions were reviewed 

and formally accepted by USFWS in 1994. USFWS concluded in 1995 that listing 

was not warranted for either subspecies, but concerns remained for their long-term 

viability. The goshawk finding was challenged in U.S. District Court, which 

remanded the finding to USFWS with instructions to base the finding on the existing 

management plan for the Tongass (the 1997 Forest Plan), rather than the one in 

Species 

Accounts 

Threatened and 

Endangered 

Species 
3 Environment and Effects

Wildlife 3-224 Final EIS

Table 3.10-1 

Wildlife Species in Southeast Alaska that are Federally Listed Species or Candidate for 

Listing under the ESA (NMFS or USFWS), Management Indicator Species (USDA Forest 

Service), or Sensitive Listed Species (USDA Forest Service) 

Species Common Name 

(Scientific Names)

2/ 

Federal 

T&E Listed 

Species 

Federal 

Candidate 

Species 

Management 

Indicator 

Species1

Forest 

Service 

Sensitive 

Listed 

Species 2

Other 

Species 

of 

Concern 

MAMMALS 

Alexander Archipelago Wolf (Canis 

lupus ligoni) X 

American Marten (Martes americana X 

Black Bear (Ursus americanus) X 

Brown Bear (Ursus arctos) X 

Northern Flying Squirrel (Glaucomys 

sabrinus) 

X 

Humpback Whale (Megaptera 

novaeangliae) 

X 

Mountain Goat (Oreamnus 

americana) X 

Red Squirrel (Tamiasciurus 

hudsonicus) X 

River Otter (Lutra canadensis) X 

Sitka Black-tailed Deer (Odocoileus 

hemionus sitkensis) X 

Steller sea lion (Eumetopias jubata) X 

BIRDS 

Bald Eagle (Haliaeetus 

leucocephalus) X 

Brown Creeper (Certhia americana) X 

Hairy Woodpecker (Picoides villosus) X 

Kittlitz’s Murrelet (Brachyramphus 

brevirostris) X 

Marbled Murrelet (Brachyramphus 

marmoratus) X 

Queen Charlotte Goshawk (Accipiter 

gentilis laingi) X 

Osprey (Pandion haliaetus) X 

Peale’s Peregrine Falcon (Falco 

peregrinus anatum) X 

Red-breasted Sapsucker 

(Sphyrapicus ruber) X 

Spruce Grouse (Falcipennis 

Canadensis) 

 

Trumpeter Swan (Cygnus 

buccinator) X 

Vancouver Canada Goose (Branta 

canadensis fulva) X 

1

 This document addresses all Management Indicator Species listed in the 1997 Forest Plan. 

2

 Listed plant and fish species are addressed in their respective sections. 
 Environment and Effects 3 

Final EIS 3-225 Wildlife 

development at the time. USFWS released a new finding in August 1997, which 

also concluded that listing was not warranted. Several more legal challenges 

occurred in the intervening years and, most recently, the court instructed the 

USFWS to evaluate whether Vancouver Island is a “significant portion of the 

subspecies’ range and, if so, to determine whether the bird should be listed. A new 

Finding, released in November 2007 concluded that that Vancouver Island is a 

significant portion of the Queen Charlotte goshawk’s range and that listing the 

subspecies on Vancouver Island is warranted. The review also indicated that the 

subspecies’ populations in British Columbia and Alaska are distinct population 

segments (DPS) and that the best available information on biological vulnerability 

and threats to the goshawk does not support listing the Alaska DPS as threatened 

or endangered at this time. 

The Kittlitz’s murrelet is a candidate species for listing. Species accounts for the 

Kittlitz’s murrelet, Queen Charlotte goshawk, and Alexander Archipelago wolf are 

provided below under the Candidate Species subsection, Forest Service Sensitive 

Species subsection, and Management Indicator Species subsection, respectively. 

Kittlitz’s Murrelet 

On May 9, 2001, the Secretary of the Interior was petitioned to list the Kittlitz’s 

murrelet (Brachyramphus brevirostris) as endangered with concurrent designation of 

critical habitat under the ESA. Petitioners cited dramatic reductions in population 

size over the past decade and declining habitat quality as reasons for the requested 

listing. The species was officially designated a candidate species (warranted, but 

precluded) on May 4, 2004. 

The Kittlitz’s murrelet is closely associated with glacial habitats along the Alaska 

mainland coast. Breeding sites are usually chosen in the vicinity of glaciers and 

cirques in high-elevation alpine areas with little or no vegetative cover (van Vliet 

1993). When present, vegetation is primarily composed of lichens and mosses (Day 

et al. 1983). The species nests a short distance below the peak or ridge on coastal 

cliffs, barren ground, rock ledges, and talus above timberline in coastal mountains, 

generally near glaciers 0.2 to 47 miles inland (Day et al. 1983). The remote and 

solitary nesting habits lead to extreme difficulty in finding nests. Non-breeding or 

off-duty breeders spend the summer in inshore areas, especially along glaciated 

coasts. 

The Kittlitz’s murrelet is one of the rarest seabirds in North America. The only 

American population occurs in Alaskan waters from Point Lay south to northern 

Southeast Alaska (Endicott and Tracey Arm). The largest breeding populations are 

believed to be in Glacier Bay National Park and Preserve, Prince William Sound, 

Kenai Fjords, and Icy Bay (Kendall and Agler 1998 as cited in Day et al. 2000). 

According to the petition, the southern boundary of the breeding range is LeConte 

Bay on the Tongass National Forest. Latest worldwide population estimates range 

from 9,500 to 26,500 birds. The best information available from USFWS indicates 

that Prince William Sound populations have declined by 84 percent since 1984, 

Kenai Fjords area by 83 percent since 1976, Malaspina Forelands by 38 percent 

and perhaps as much as 75 percent between 1992 and 2002, and Glacier Bay by 60 

percent between 1990 and 1999. Speculated causes for decline include oil 

pollution, glacial recession, gillnet mortality, and availability of preferred forage fish 

(Kuletz et al. 2003, Piatt and Anderson 1996, van Vliet and McAllister 1994). Effects 

of these factors include increased adult and juvenile mortality and low recruitment. 

Human-caused mortality includes gillnet fisheries and oil spills like that from the 

Exxon Valdez or smaller tourism and fishing boats. Increased disturbance from 

helicopter tours and cruise ships may also be a factor. 

Candidate 

Species 
3 Environment and Effects

Wildlife 3-226 Final EIS

Sensitive species are those plant and animal species identified by the Regional 

Forester for which population viability is a concern on National Forest System (NFS) 

lands within the region. Either a significant current or predicted downward trend in 

population numbers or density, or a significant current or predicted downward trend 

in habitat capability that would reduce a species’ existing distribution indicates a 

viability concern. The goal of the Forest Service Sensitive Species Program (Forest 

Service Manual 2670) is to ensure that species numbers and population distribution 

are adequate so that no federal listing will be required and no extirpation will occur 

on NFS land. The Alaska Region Sensitive Species List was last updated in June 

2002 and an update is currently in progress. 

Plants and fish species identified as Sensitive are discussed in their respective 

sections. The Queen Charlotte goshawk is described in greater detail because this 

species has additional management concerns. The Regional Sensitive Species List 

continues to be revised as new information dictates. 

Queen Charlotte Goshawk 

The northern goshawk inhabits forested lands throughout North America, favoring 

dense stands of conifer or deciduous mature and/or old growth for nesting habitat. 

The Queen Charlotte goshawk is recognized as a distinct subspecies, and is 

endemic to coastal rainforests from Vancouver Island to northern Southeast Alaska 

(Taverner 1940, Iverson et al. 1996, Squires and Reynolds 1997). Recent genetic 

analysis indicates that this population may be genetically distinct from goshawks 

found elsewhere (Talbot et al. 2005 as cited in USFWS 2007). During the last 

decade, conservation designations of the goshawk in Southeast Alaska have varied; 

however, its status in Southeast Alaska remains a concern (Cotter 2007b). In 

addition to being considered a species of special management concern on the 

Tongass, the Queen Charlotte goshawk is of special concern to the State of Alaska 

and has been included by Stenhouse and Senner (2005) on Audubon’s Alaska 

WatchList because of its limited distribution and the potential threats posed by 

commercial timber harvesting in breeding and nonbreeding seasons. In 2000, the 

Canadian government listed the Queen Charlotte subspecies as threatened 

because of continued logging of low-elevation, old-growth coniferous forests within 

its range and likely population declines (Environment Canada 2006). 

Within Southeast Alaska and on the Tongass, the goshawk is a year-round resident 

and may occupy different, or overlapping, winter and breeding territories. Prior to 

studies during the past decade, very little was known about goshawks on the 

Tongass. Goshawks occur in low densities across the Forest and are difficult to 

study in the dense temperate rainforests of Southeast Alaska (Schempf et al. 1996 

as cited in USFWS 2007). A recent interagency study of goshawks in the Tongass 

found 61 nesting areas within approximately 30,000 mi2

 (77,000 km2); though this 

number is not reflective of a density estimate per se (Flatten et al. 2001). Goshawk 

nests can be found in all LUDs, and the number of known nest sites has not 

significantly increased in recent years; however, this is probably related to reduced 

survey efforts and the fact that goshawks are frequenty missed during surveys due 

to their secretive nature, low density, and use of old-growth habitats where they are 

difficult to detect (Flatten et al. 2001, Boyce et al. 2005, Northern Goshawks on the 

Tongass National Forest presented at the Tongass Conservation Strategy Review 

Workshop 2006). The interagency research project has also ceased, and follow-up 

of leads apart from timber sale activities now seldom occurs. 

A nesting area, which in Southeast Alaska can be 2,000 acres (800 hectares) in size 

(Iverson et al.1996, Flatten et al. 2001), is defined as the area containing all nests 

used by a pair of goshawks; it is the portion of a pair's home range that contains all 

active and inactive nests. Female goshawks tend to move greater distances 

between nests in sequential years than males; however, a majority of nests 

Forest Service 

Sensitive Listed 

Species 
 Environment and Effects 3 

Final EIS 3-227 Wildlife 

remained within a 0.8-mile (1.3-kilometer) radius of the previous year’s nest and all 

movements were within 3.2 kilometers of the “year one” nest site (Lewis and Flatten 

2004 as cited in USFWS 2007). Adult home ranges on the Tongass are some of the 

largest recorded for the species, averaging 9,640 acres for females and 10,625 

acres for males during the nesting season, and 29,160 acres for females and 

29,400 acres for males outside of the nesting season (Lewis and Flatten 2004 as 

cited in USFWS 2007). The large size of Tongass goshawk home ranges compared 

to other areas may be related to methological differences; aircraft were used in 

Southeast Alaska for radiotelemetry and birds were located even if they were “over 

the ridge” where ground-based radiotelemetry would not have located the bird 

(Squires and Reynolds 1997, Kenward 2006). 

Based on a recent study of 37 nest trees, 54 percent were Sitka spruce, 41 percent 

were western hemlock, and 4 percent were yellow cedar (Flatten et al. 2002). Lewis 

et al. (2003) found nest trees in Southeast Alaska to be larger than those around 

them at the nest site. In a separate analysis of 63 nest sites (habitat immediately 

surrounding the nest) from 50 nesting areas (a 20- to 30-acre area surrounding a 

nest, including roosts and prey plucking sites), 89 percent were located in highvolume stands with relatively dense, multi-storied canopies (SD5N, SD5S, and 

SD67 categories) compared to the surrounding forest (Lewis et al. 2003, McClaren 

2004, Doyle 2006); nest areas had significantly more forest, productive forest, 

hemlock, and canopy cover and less non-forested area than random 12-hectare 

plots, and less non-forested habitat and forest/non-forest edge than random 65-

hectare plots (Lewis 2005). Goshawk nesting density appears to be closely 

associated with dense overstories and open understories and goshawk habitat may 

therefore be improved by silvicultural activities which reduce the densities of shrubs, 

saplings, and small poles, while maintaining or enhancing the canopy of large trees 

(Crocker-Bedford 1990). Some nests have been found in maturing second-growth 

(previously harvested) stands (Bosakowski et al. 1999, McClaren 2004). On 

Vancouver Island, most second-growth stands supporting nests were 60 to 80 years 

old, and suitable structure was apparently achieved in as little as 50 years 

(McClaren 2004). 

The diet of goshawks in Southeast Alaska is dominated by a few key prey (grouse 

spp., medium-sized birds such as Steller’s jay and varied thrush, and red squirrels, 

where present). In prey rich areas, blue grouse and red squirrel are the dominant 

prey items taken (Lewis 2001). On Prince of Wales Island and other islands where 

blue grouse and red squirrels are not present, spruce grouse, Steller’s jays, and 

ptarmigan are the dominant prey items taken (Lewis 2001). Small mammals make 

up a small portion of the overall diet in this area. Thrushes, grouse, and squirrels 

(common forest inhabitants that may be affected by timber harvesting) contribute up 

to 60 percent of prey deliveries to goshawk nests during the breeding season (Lewis 

et al. 2004). Recent research from neighboring populations on Haida Gwaii/Queen 

Charlotte Islands suggests blue grouse populations have probably declined since 

intensive harvesting was initiated, despite the limited benefit gained from some 

recent harvesting (e.g., new openings [more than 15 years] are used by breeding 

birds), and that this decrease in grouse may have substantially impacted the viability 

of the threatened goshawk population (Doyle 2004a, 2006). 

POG forest is an important component of goshawk habitat use patterns in Southeast 

Alaska and at all scales (nest tree, nest site, post-fledging areas) goshawks select 

POG forest types. Habitat use of the 1,000-foot beach and estuary buffer was 

higher for females than males during the nesting and non-nesting season, with 

peaks in use occuring at 3,000 and 4,000 feet from the beach fringe (Northern 

Goshawks on the Tongass National Forest presented at the Tongass Conservation 

Strategy Review Workshop 2006). Radio telemetry points within adult home ranges 

suggest very high use of POG forests. Non-productive forest types and secondgrowth stands are also used to a lesser extent, and in some areas these matrix 
3 Environment and Effects

Wildlife 3-228 Final EIS

lands may be important for long-term goshawk management (Reynolds 2004, 

Reynolds et al. 1992). Most other habitat types (such as alpine, subalpine, muskeg, 

and clearcuts) were used infrequently or avoided by goshawks. This is corroborated 

by recent research conducted in the Southwest and Pacific Northwest, which 

indicates that although goshawks prefer to place their nests in mature to old-growth 

forest types, they are much more adaptable than once thought, and when these 

habitats are not available they will nest in maturing second growth with sufficient 

structure or in smaller patches of trees, and forage in young forest as well as along 

edges and in openings (Bosakowski et al. 1999, McClaren 2004, Boyce et al. 2006, 

Reynolds et al. 2006). Although there is some documented use of second growth in 

Southeast Alaska, the majority of Southeast Alaska second growth is younger than 

50 years and most goshawks are associated with older forests. Use of older second 

growth (e.g., approximately 90- to 100-year-old stands) by goshawks for nesting in a 

few instances in Southeast Alaska was used by the assessment panels to suggest 

that goshawks would benefit from a long timber rotation of 150 or 200 years, 

providing 50 or 100 years of use. 

Timber harvesting on the Tongass and on private lands in Southeast Alaska, has 

resulted in the conversion of old-growth forest to young growth, and likely has 

contributed to a decline in goshawk habitat capability due to their association with 

this habitat and the association of their prey with this habitat (e.g., blue grouse and 

red squirrels). Although goshawks are considered generalist predators and possess 

some adaptability to fluctuations in their prey base, large-scale habitat disturbance 

may diminish breeding success of goshawks in Southeast Alaska through changes 

in prey availability (Lewis et al. 2004). In the contiguous U.S., such habitat change is 

believed to reduce the number of breeding goshawks by degrading the structural 

character of forests used for nesting and foraging, though it is still unclear how 

goshawk populations respond to habitat modifications because study of effects 

across a gradient of harvest intensity is lacking (Boyce et al. 2006). However, forest 

harvest may be compatible with goshawk management provided that habitat needs 

are provided at multiple spatial scales (Reynolds et al. 1992). For example, Doyle 

(2004b) concluded that grouse selection of stands with more open canopy with a 

variety of heights and a patchy shrub layer on the Haida Gwaii/Queen Charlotte 

Islands, provides for the possibility that there may be a pattern for single tree 

selection, or a patch retention harvest threshold, that will allow harvesting without 

impacting grouse populations and thus, goshawks. 

In 1996, a conservation assessment was conducted to synthesize literature and 

original data from Southeast Alaska to describe the habitat relationships and 

conservation status of the Queen Charlotte goshawk (Iverson et al. 1996). Iverson 

et al. (1996) concluded that goshawk habitat theoretically could be maintained 

across the landscape under a 300-year ecological rotation. A risk assessment using 

a conceptual 300-year rotation revealed that several landscapes (including the 

North Prince of Wales Biogeographic Province) within the Tongass may be at 

increased risk of not sustaining goshawks. The assessment suggested that a 

combination of reserve-based and dynamic-landscape management approaches 

could sustain well distributed viable populations of goshawks across the Tongass. 

In 1997, a panel of goshawk experts concluded that, even though they had viability 

concerns, under the 1997 Tongass Forest Plan, there would be a high likelihood that 

after full implementation for 100 years, goshawks would still persist across the 

Forest in some distributional status considerably more dense than in refugia 

(Iverson 1997). 

As noted above under the Threatened and Endangered Species section, a recent 

court decision has required USFWS to determine whether Vancouver Island is a 

“significant portion of the subspecies range” and, if so, to determine whether the bird 

should be listed. USFWS (2007) finalized an update to the 1997 Status Assessment 

in April 2007. A new Finding, released in November 2007 concluded that that 
 Environment and Effects 3 

Final EIS 3-229 Wildlife 

Vancouver Island is a significant portion of the Queen Charlotte goshawk’s range 

and that listing the subspecies on Vancouver Island is warranted. The review also 

indicated that the subspecies’ populations in British Columbia and Alaska are DPS 

and that the best available information on biological vulnerability and threats to the 

goshawk does not support listing the Alaska DPS as threatened or endangered at 

this time. 

Osprey 

The best available information indicates that the osprey is naturally rare in 

Southeast Alaska and this area may represent the northern periphery of the species’ 

range. A total of 16 osprey nest sites have been documented in Southeast Alaska 

(USDA Forest Service 1997a). Of this total, no more than three have ever been 

known to be active in any year. Nests can be found along the coasts of Wrangell 

Island and Kupreanof Island, typically 0.25 to 1.4 miles from the nearest saltwater; 

ospreys do nest along inland freshwater lakes, but none has been documented in 

Southeast Alaska. They require large trees and snags or power poles for nesting 

and, in Southeast Alaska, osprey nests typically occur in broken-top spruce trees or 

western hemlock snags. Ospreys nest from late April through August and probably 

overwinter in Mexico and Central America. Historically, there is no evidence that 

there were additional ospreys in Southeast Alaska, and population numbers have 

remained stable but low. Limiting factors are unknown, but available nest sites and 

foraging areas (i.e., larger lakes, rivers, beaver ponds, coastal beaches or large 

estuaries with abundant fish) do not appear to be limiting. Interaction and 

competition with the abundant bald eagle population may be a limiting factor. 

Peale’s Peregrine Falcon 

As of 1997, 36 nests of Peale’s peregrine falcon have been located in Southeast 

Alaska; 32 of which are on the Tongass National Forest. Nest surveys are very 

difficult to conduct, and biologists believe more nests may be present. Peregrine 

nest distribution is closely associated with large seabird colonies located on the 

outer coasts or nearby islands. The nest sites are on cliffs ranging from 65 to 900 

feet in height; all but one nest faces the open ocean. Seabirds are thought to be 

major prey of the falcon. Information on falcon breeding biology or reproductive 

success is limited, but based on USFWS surveys, their population appears to be 

stable. 

Trumpeter Swan 

The largest nesting population of trumpeter swans on the Tongass National Forest 

occurs on the Yakutat Forelands. A smaller breeding population occurs in the 

Chilkat Valley on non-NFS land. Young cygnets have been located as far south as 

Traitors Cove on Revillagigedo Island and pairs of swans have been consistently 

observed during the summer months on Smuggler’s Lake on the Cleveland 

Peninsula. Surveys by USFWS and other cooperating agencies indicate that the 

Yakutat population continues to be stable. A complete aerial survey was completed 

in September 2005. Mean brood size was estimated at 3.1 with approximately 27 

percent of the total swans counted (n=23,692) reported as juveniles. The mean 

brood size was 3 percent higher than in 2004, but lower than the 29-year mean. 

The proportion of juveniles was 30 percent higher than in 2004 and 7 percent above 

the 29-year average. Trumpeter swans winter in ice-free areas throughout 

Southeast Alaska. Winter surveys on the Yakutat Forelands documented 646 adults 

and 98 juveniles in March 2006. Information on wintering habitats and populations 

elsewhere on the Tongass is very limited, but a traditional winter concentration area 

has been documented on Mitkof Island near Petersburg. Numerous swans from 
3 Environment and Effects

Wildlife 3-230 Final EIS

other parts of Alaska migrate through Southeast Alaska, and many winter in suitable 

habitats in Southeast Alaska. 

Management Indicator Species (MIS) are vertebrate or invertebrate species whose 

response to land management activities can be used to predict the likely response 

of other species with similar habitat requirements. NFMA regulations of 1982 

require both the selection of MIS during development of forest plans (36 CFR 

219.19(a), 1982), and that reasons for species selection be clearly stated. Criteria 

are to include those species whose population changes are believed to indicate the 

effects of management activities (36 CFR 219.19(a)(1), 1982). 

Though required under the NFMA, the MIS concept is not universally accepted and 

is difficult to use, especially on the Tongass. First, our fundamental knowledge of 

many Tongass MIS is limited, as is our understanding of the viability requirements of 

most Tongass wildlife species. Moreover, although Tongass MIS represent varying 

needs related to old-growth forest, there is no assurance that all or even most other 

old growth associated species are adequately represented. Additionally, many 

current MIS are difficult to monitor or no clear linkage has been established between 

observed population changes and habitat modification. Some species may be 

better monitored through surrogate measures such as important habitat features or 

prey populations. Consequently, an effort is underway to re-evaluate, and possibly 

reduce, the current list of MIS. 

For the 1997 Forest Plan, 13 wildlife MIS were identified and are discussed in this 

section. Four MIS species with special management concerns (brown bear, marten, 

Sitka black-tailed deer, and Alexander Archipelago wolf) are discussed in more 

detail. POG habitat provides essentially all of the highly important habitats and the 

preponderance of the moderately important habitats for most of the MIS. However, 

some species (e.g., wolves) use a variety of different habitats but rely on prey 

species associated with old growth (e.g., black-tailed deer). Table 3.10-2 indicates 

the relative importance of conifer successional stages as habitat for the MIS. Table 

3.9-4 in the Biodiversity section displays the elevational distribution of productive 

and unproductive old growth on the Tongass, based on different elevation 

constraints thought important for many of the species discussed in this section. 

Sitka Black-Tailed Deer 

Sitka black-tailed deer (Odocoileus hemionus sitkensis) are indigenous to the 

coastal regions of Southeast Alaska and northwest British Columbia. This 

subspecies of mule deer occupies the northernmost extreme of black-tailed deer 

habitat. Deer are strong swimmers, and have occupied almost all islands of the 

Alexander Archipelago capable of supporting them. On the mainland, deep snow 

and harsh winters limit populations more than on the islands. 

The Sitka black-tailed deer is the wildlife species receiving the highest hunting and 

subsistence use of all terrestrial species in Southeast Alaska. Table 3.10-7 in the 

effects section below presents the average deer harvest per year over the last 10 

years by Wildlife Analysis Area (WAA). This species represents those that use 

lower elevation (below 800 feet elevation) POG forest habitats during the winter 

period. The quantity, quality, distribution and arrangement of winter habitat are 

considered the most important limiting factors for Sitka black-tailed deer in 

Southeast Alaska. There are about 4.8 million acres of old-growth forest (3.0 million 

acres of POG and 1.8 million acres of unproductive old growth below 800 feet 

elevation within occupied deer habitat on the Tongass National Forest (Table 3.9-4 

in the Biodiversity section). Currently, approximately 92 percent of the original old 

growth remains Forest-wide (see Table 3.10-7 for relative deer habitat capability by 

WAA). 

Management 

Indicator Species 
 Environment and Effects 3 

Final EIS 3-231 Wildlife 

Table 3.10-2 

Relative Importance of Conifer Successional Stages as Habitats for Management 

Indicator Species 

Successional Stages1 

Late (>200 years) 

Early 

(years) Mid (years) 

Productive Old 

Growth 

Species Season2 0-25 26-150 150-200 

Unproductive 

Old Growth 

Low-Med 

(SD4S, 

SD4N, 

SD5H) 

High 

(SD5S, 

SD5N, 

SD67) 

Mountain Goat 1 L L L L M-H H 

Sitka B-tail Deer 1 L-M L L-M L-M M H 

River Otter 2,3 L L M L H H 

American Marten 1 L L L L M H 

Brown Bear 3 L L L M-H M-H M-H 

Black Bear 2,3,4 M L L M M-H M-H 

Wolf3 5 - - - - - - 

Red Squirrel 5 L L-H H L M-H M-H 

Bald Eagle 2,3 L L L L H H 

Red-br. Sapsucker 2,3 L L L L H M 

Hairy Woodpecker 1 L L L L L M-H 

Brown Creeper 1 L L L L L L-H 

Van. Can. Goose 2,3 L L L H H H 1

 H = Highest importance, high population densities, M = Moderate importance, moderate population densities, L = Least 

importance, low population densities 2

 Season codes: 1 = winter, 2 = spring, 3 = summer, 4 = fall, 5 = all year 

3

 Wolves use habitats according to the abundance and availability of prey species (primarily Sitka black-tailed deer). 

A deer winter habitat suitability index (HSI) model, which takes into account snow 

depth (indicative of typical, moderate winter severity), elevation, aspect, and conifer 

forest successional stage, is currently used in Tongass Forest planning to provide 

an index of habitat capability (referred to as the TLMP deer model, DeGayner 1997). 

It is a stand-alone model, based on expert opinion, which does not require the 

collection of new data. Old-growth forests are assigned the highest value because 

they intercept snow and provide understory forage plants. Generated HSI values 

are an index of how features are correlated with deer winter habitat. High model 

scores represent features that are correlated with deer abundance. These features 

include closed canopy (based on volume class rather than canopy cover), maritime 

influence, south facing slopes, and low average snow depth. 

One shortcoming of the model is the high rating it gives to some large-tree oldgrowth stands (some of the stands mapped as SD67). These stands consist of 

widely spaced, very large Sitka spruce trees, most commonly located in riparian 

floodplains. Riparian floodplains tend to be some of the coldest locations on the 

landscape due to cold air drainage, shade, and flat terrain, and tend to have greater 

snow accumulations than neighboring stands, making them less hospitable to deer 

(T. Hanley, personal communication, 2007). Additionally, despite their high volume, 

these stands have open overstories that intercept less snow than other stands and, 

while they typically have a high understory biomass, dominant species include devils 

club, salmonberry, elderberry, and ferns, all of which provide suitable forage during 

summer but not during winter (Hanley and Hoel 1996). Thus, these stands constitue 

poor winter range, but by default, their high volume results in high assigned model 

values. The effect of this error is to overestimate the value of some large tree 

stands and to overestimate the impact of their harvest; however, the overall effect is 

relatively small because these stands comprise a very small fraction of the 

landscape (T. Hanley, personal communication, 2007). 
3 Environment and Effects

Wildlife 3-232 Final EIS

Recent research indicates the greater importance of summer range for reproduction 

and population recovery following severe winters, and for building up pre-winter 

body reserves. This suggests that changes to the 1997 HSI model may be 

warranted such that higher suitability values are assigned to habitats that provide 

important summer forage, such as recent clearcuts, unproductive forest, and low 

volume old growth (Parker et al. 1999). Due to changes in vegetation mapping on 

the Tongass, model coefficients are currently being refined; however, these 

modifications will occur outside of the timeframe for the Forest Plan amendment. 

Therefore, the existing, approved deer HSI model used in the 1997 Forest Plan 

Revision Final EIS will be used here for alternative comparisons, with the caveat 

that it likely overestimates the effect of timber harvest on deer habitat quality. 

The deer model provides a tool to evaluate the relative differences among 

alternatives. The winter HSI model is most appropriate for analysis over large 

planning areas such as the entire Tongass National Forest or at the scale of a WAA 

or number of WAAs, where the greatest differences in habitat value occur between 

main habitat types (e.g., old growth versus young clearcuts versus closed-canopy 

young-growth) and their topographic settings, rather than differences within such 

classes. Thus, the model has limitations when applied at the watershed or project 

planning level. A new tool for evaluating deer habitat appropriate for analysis at 

finer scales, called the Forest Resource Evaluation System for Habitat (FRESHDeer) model, is currently being developed by the Forest Service in cooperation with 

the University of Alaska (Deer Habitat Management, presented at the Tongass 

Conservation Strategy Review Workshop 2006). FRESH-Deer is a food-based 

system that provides a “snap shot” analysis of habitat conditions at one point in time 

by taking into account the biomass of available forages (by species and by plant 

part), the nutritional quality of each forage (e.g., digestible energy and digestible 

protein), and user-specified metabolic requirements (e.g., metabolic energy, 

digestible protein) that are dependent on the age, sex, season, and reproductive 

status of the animal. The model identifies limiting factors within the habitat and the 

most important forages. In contrast to the winter HSI model, FRESH-Deer is a datadriven model that requires the collection of new data. In the future, this model may 

be available for use in project planning. 

In addition to winter habitat conditions, predation can act as a major controlling 

factor of deer populations. Primary predators include humans, wolves, and blackbears; however, the predominance of each in terms of impacting the deer population 

varies geographically. For example, studies of deer mortality indicate that on Mitkof 

and Heceta Islands human harvest and wolf predation were the main causes of deer 

mortality, but on Prince of Wales Island deer mortality (primarily fawns) was 

predominantly due to bear predation (Wolves and Predator-Prey Interactions, 

presented at the Tongass Conservation Strategy Review Workshop 2006). Deer 

are the primary prey of wolves in Southeast Alaska, and the significance of 

predator/prey interactions on wolf populations led to the conclusion that wolf 

persistence was directly linked to deer habitat capability. However, even in highquality habitats increased deer mortality can occur during severe winters. In 

fragmented landscapes, where small, remnant patches of old growth exist, deep 

snow may isolate deer by precluding movement between patches (McNay 1995). 

Concentrated use of these areas can result in overbrowsing of forage and ultimately 

malnutrition and death (Farmer et al. 2006) 

Mountain Goat 

Mountain goats (Oreamnos americanus) represent species using cliffs, alpine and 

subalpine, and old-growth forest habitats. The quantity and quality of winter habitat 

is the most limiting factor for mountain goats in Southeast Alaska. Lack of snow 

interception in early successional stages and lack of forage in middle successional 

stages reduces the value of winter habitat. Historically, mountain goats in Southeast 
 Environment and Effects 3 

Final EIS 3-233 Wildlife 

Alaska were present only on the mainland, but they have more recently been 

transplanted to many of the islands. 

Mountain goat populations in Southeast Alaska are currently monitored via ADF&G 

aerial surveys and harvest records, which are used to estimate population trends. 

This species is considered one of the easier species in Southeast Alaska to monitor 

by virtue of their predictable use of open terrain during summer and fall. However, 

they spend much of their time outside of areas where habitat manipulations (e.g., 

logging) have occurred or are likely to take place in the future. Additionally, a clear 

link between timber harvest and mountain goat population trends has not been 

established. Existing Forest Plan standards and guidelines were developed to 

reduce the impacts of other activities (e.g., helicopter over-flights) and impacts 

associated with facilities (e.g., crew camps). 

Black Bear 

Black bears (Ursus americanus) are present throughout the mainland and on the 

islands south of Frederick Sound. They use habitats from sea level to the alpine. 

There are about 9.4 million acres (excluding rock, permanent ice fields, and acres of 

lakes) within occupied black bear range on the Tongass National Forest. Estuarine, 

riparian, and forested coastal habitats receive the highest use by black bears and 

appear to have the highest habitat values. Within forested areas, both early and late 

(old growth) successional stages provide the best forage and/or cover for black 

bears. A recent interagency study estimated black bear population size on the 

northern portion of Kuiu Island (Peacock 2005) and conservation genetics more 

broadly across the Alexander Archipelago (e.g., Peacock et al. 2007). 

Black bears were chosen as an MIS because of their importance for hunting and for 

recreation and tourism. However, this species is difficult to monitor and existing 

monitoring data, derived from ADF&G sealing records, are not sensitive enough to 

detect population changes over large expanses, or determine the cause of 

population change in a given area. 

River Otter 

The river otter (Lutra canadensis) was selected as an MIS because of its 

association with coastal and freshwater aquatic environments and the immediately 

adjacent (within 100 to 500 feet) upland habitats. River otters are distributed 

throughout Southeast Alaska along coastal and inland waters (MacDonald and 

Cook 1999). Their distribution is Forest-wide in suitable habitats. Beach 

characteristics affect the availability of food and cover, and adjacent upland 

vegetation is also important in providing cover for otters. Old-growth forests have 

the highest habitat value, providing canopy cover, large-diameter trees and snags, 

and burrow and den sites. They tend to use POG (SDM SD5N, SD5S, SD67 

categories) with fairly open understory and greater than 50 percent canopy closure 

where they commonly rest in cavities or beneath the roots of large conifers or snags 

(Larsen 1984, Ben-David et al. 1996, Bowyer et al. 2003). Younger successional 

stages provide lower quality habitat. 

The best data currently available on river otter populations typically consist of 

infrequent, localized density estimates and thus may not be sufficient to monitor 

population changes at a level of resolution appropriate for the Tongass National 

Forest (i.e., commensurate with very small changes in habitat). Further, there is no 

monitoring protocol in place to detect changes in the population due to humancaused habitat change. Beach, Estuary, and Riparian standards and guidelines 

under the current Forest Plan protect most, if not all, of the key otter habitat 

components, thus greatly reducing risk to this species and others that rely on such 
3 Environment and Effects

Wildlife 3-234 Final EIS

habitats. It is important to note, however, that most streams receive a standard 100-

foot buffer which does not protect habitat used by otters beyond this distance. 

American Marten 

Marten naturally inhabit the mainland of Southeast Alaska and many of the islands 

in the Alexander Archipelago. Known endemic populations exist on Admiralty, 

Etolin, Gravina, Kupreanof, Mitkof, Revillagigedo, Woewodski, Wrangell, and Kuiu 

Islands (MacDonald and Cook 2000). However, many islands remain unsampled 

but could also support populations. Marten were transplanted to Prince of Wales, 

Chichagof, and Baranof Islands between 1930 and 1950; whether these transplants 

were new introductions or just supplemented existing populations is unknown. 

Although only one species of marten is formally recognized in Southeast Alaska two 

distinct lineages exist, including the coastal form caurina, which in the Alexander 

Archipelago occurs only on Kuiu and Admiralty Islands, and the continental form 

americana (Cook et al. 2006). Originally, these lineages were described as 

separate species but were reclassified as separate subspecies in the 1950s. It is 

unknown whether these lineages have different life history traits or habitat 

preferences, and thus, may require different management strategies. However, 

recent molecular analyses clearly distinguish the two forms and suggest that they 

have very different evolutionary histories (Stone and Cook 2002, Small et al. 2003, 

Cook et al. 2006). Hybridization of caurina and americana individuals has been 

documented in the two contact zones where both forms coincide, one in Southeast 

Alaska (Kuiu Island) and one in Montana (Cook et al. 2006). 

Marten numbers fluctuate greatly over time in response to food availability habitat 

conditions and trapping pressure. Results of a multi-scaled study on Chichagof 

Island conducted between 1990 and 1999 evaluated marten habitat selection, 

demographics, diet, and prey availability, and indicate that marten abundance is 

best predicted by the abundance of long-tailed voles (Flynn and Schumacher 2001, 

Flynn et al. 2004). Habitat requirements reflect a strong interaction between food, 

cover, climate, and predation, with forest cover being particularly important for 

travel, dens and resting sites, hunting, and avoiding predation and inclement 

weather (Flynn and Schumacher 1999, 2001). Consequently, the quantity and 

quality of winter habitat is a limiting factor for marten in Southeast Alaska. There are 

about 7.2 million acres of forested land (all age classes and types of conifer forests) 

below 1,500 feet elevation within occupied marten habitat on the Tongass. Due to 

lower snow accumulation, habitats at lower elevations have higher value for 

wintering marten. Coastal habitats (beach fringe) and riparian areas have the 

highest value, followed by upland habitats below 1,500 feet in elevation. Of the 

successional stages, larger-sized old-growth forests have the highest value because 

they intercept snow, provide cover and denning sites, and provide habitat for prey 

species used by marten. Early successional stages do not provide these habitat 

components and have lower habitat value. However, studies of eight marten 

populations in Southeast Alaska conducted between 2001 and 2003 show that 

marten selected POG but used some second growth 26 to 40 years of age; on 

Mitkof Island these second growth stands were characterized by abundant 

understory forage and small mammals (Flynn et al. 2004). In addition, home ranges 

of marten were well distributed across the landscape and included areas with timber 

harvest and roads. These findings indicate that although OGRs are still an 

appropriate model for marten conservation in terms of providing optimal habitat 

requirements, the management of matrix lands to provide productive habitat and 

linkages between reserves is also important. Noteably, marten densities are higher 

in intact forests with less fragmentation (Hargis et al. 1999, Flynn et al. 2004), 

indicating that large, continguous block of old growth are important for this species. 
 Environment and Effects 3 

Final EIS 3-235 Wildlife 

Dispersal between islands is limited, but marten are fairly mobile on land. Marten 

are easily trapped and can be overharvested. Forest management activities 

resulting in increasing access may result in the potential for overtrapping. Currently 

the ADF&G permits unlimited trapping of marten in the Game Management Units 

(GMUs) that cover the Tongass (GMUs 1, 2, 3, 4, and 5) from December 1 to 

February 15. In GMU 3, which includes the endemic population on Kuiu Island, a 9-

year average of 188 marten were trapped per year (Lowell 2004). For perspective, 

across Southeast Alaska the annual average harvest ranged from 224 martens per 

year on north central Prince of Wales Island to three martens per year on northern 

Kuiu Island between 1991 and 2002 (Flynn et al. 2004). 

Marten were initially selected as an MIS because forest management activities were 

expected to affect population abundance, and marten pelts represented significant 

economic value to local residents. In Southeast Alaska, the best available 

information that can be related to marten populations comes from the ADF&G 

sealing records; however, this monitoring method was not designed to determine 

causes of observed population trends. Further, although marten populations appear 

to be sensitive to habitat alteration, no clear correlation between population trends 

and habitat change has been defined due to the lack of research on this dynamic 

and the absence of long-term population datasets. An assumption of the 

conservation strategy was that large OGRs would support a minimum of 25 female 

martens; however, in a study of marten densities conducted between 2001 and 

2003, Flynn et al. (2004) determined that this minumim number was not met in five 

of eight study areas, the exception being the Chichagof Island site and possibly the 

sites near Point Couverden and Thomas Bay. These results illustrate the 

importance of the matrix lands between reserves for marten survival and the 

importance of the POG retention requirement under the conservation strategy. 

Brown Bear 

Southeast Alaska is home to one of the highest concentrations of brown bears 

(Ursus arctos) in the world (ADF&G 2000). Brown bears are important both for 

hunting (including both outfitter guided and non-guided hunting) and to the 

recreation and tourism industry of Southeast Alaska. As tourism grows in Southeast 

Alaska, there is increasing demand for more bear viewing opportunities such as 

those provided by Pack Creek and Anan Creek. Brown bears are present on the 

mainland and on most the islands north of Frederick Sound. They are occasionally 

reported on Mitkof, Etolin, and Wrangell Islands south of Frederick Sound, but are 

not found on any of the other islands in Southeast Alaska. Brown bears use areas 

from sea level to the alpine and are habitat generalists. There are about 7.9 million 

acres (excluding rock, permanent ice fields, and acres of lakes) within occupied 

brown bear habitat on the Tongass; 7.5 million acres of which are considered to be 

roadless. Home ranges of brown bears in Southeast Alaska are much smaller than 

those found in interior portions of North America. Average annual home range sizes 

for radio-collared bears on Admiralty Island was 39 square mile (100 square 

kilometers) and 14 square miles (37 square kilometers) for males and females, 

respectively (Schoen and Beier 1990); these are comparable to home range sizes of 

radio-collared bears on Chichagof Island (Titus et al. 1999). 

The late-summer season has been identified as the most critical or limiting period for 

brown bears when they must build up energy reserves that are adequate to survive 

the winter and successfully reproduce (Hildebrand et al. 1999). During this season, 

many brown bears concentrate along low elevation valley bottoms and salmon 

streams, with most use occurring within 500 feet of streams (Schoen and Beier 

1990, Titus and Beier 1999), where their efforts focus on consuming large quantities 

of fish in order rebuild their body condition and lay on essential fat reserves. Brown 

bears have been known to maximize their energy intake by preferentially attacking 
3 Environment and Effects

Wildlife 3-236 Final EIS

salmon with the highest energy content (i.e., those that have just entered the stream 

with protein and fat stores that have not yet been depleted) and by consuming the 

most energy dense body parts (Gende et al. 2004a, b, Gende and Quinn 2004). 

These are often the same areas of highest human use and most intense resource 

development activities. To better understand these relationships, a study on 

Chichagof Island conducted between 2001 and the present is evaluating brown bear 

spatial relationships, resource selection, and levels of use during the salmon 

spawning season in relation to riparian management along two drainages that differ 

in timber harvest intensity and road building (Flynn et al. 2007). Results showed 

that in both drainages male brown bears tended to concentrate their use along the 

stream, whereas females made greater daily movements and used both riparian and 

adjacent upland areas. In the drainage with more timber harvest and roading, with a 

smaller riparian buffer, daily movements of female bears tended to be greater and 

more variable (75 percent of radiotelemetry locations occurring within 2,482 feet of 

the stream), including more use of adjacent upland areas, than in the less disturbed 

drainage (75 percent of radiotelemetry locations occurring within 937 feet of the 

stream). DNA-based population estimates indicated that the number of male bears 

along both streams was approximately equal and remained constant over time, with 

an increase in use in September; the number of female bears present declined over 

the same period. Additionally, diet analyses were conducted with an interest in 

evaluating the proportion of the diet consisting of salmon, based on the premise that 

a greater amount of salmon in the diet should support a larger and more productive 

population. Salmon obtained from mid-summer to early fall represent an important 

food source for accumulation of energy reserves to sustain bears over-wintering in 

dens. Results showed that females along heavily managed streams ate less 

salmon than females along steams with larger riparian buffers, though both 

drainages still supported high densities of brown bears (22 bears per square 

kilometer in the less altered watershed and 13 bears per square kilometer in the 

highly altered watershed, as measured within a 500 meter riparian buffer). A similar 

study on the Kenai Peninsula reported that female brown bears with cubs tended to 

avoid areas used by other bears and by humans, apparently in an effort to increase 

offspring survival, and used less productive salmon spawning areas despite having 

high nutritional requirements (Suring et al. 2006). These results indicate that small 

streams are important for female and young bears and forested buffers are 

important to maintaining high density brown bear populations by providing adequate 

vegetative cover for secure foraging areas and to support anadromous fish 

production (Flynn et al. 2007). 

Cover for visual obscurity, provided by riparian buffers, is important for minimizing 

interactions among bears and between humans and bears. Increases in human 

activity due to an expanding road system in an area may result in increased direct 

human-induced deaths of bears. This may include legal hunting, illegal kills, 

wounding losses, and deaths due to the defense of life or property (DLP mortality). 

Open roads are of greatest concern because they receive the highest, most 

consistent use; however, closed roads are also important to consider because they 

provide off-highway vehicle and pedestrian access. ADF&G permits harvest of 

brown bears in GMU 4, which encompasses Admiralty, Baranof, and Chichagof 

islands. An annual average of 165 brown bears per year was taken from this area 

over the last 5 years (ADF&G 2005b). Hunting is also permitted elsewhere in 

Southeast Alaska. 

Alexander Archipelago Wolf 

Two Alaskan subspecies of the gray wolf are currently recognized (Weckworth et al. 

2005). The wolf found in Southeast Alaska is known as the Alexander Archipelago 

wolf (Canis lupus ligoni). It inhabits the mainland and the larger islands south of 

Frederick Sound (MacDonald and Cook 2000). However only the largest islands, 
 Environment and Effects 3 

Final EIS 3-237 Wildlife 

including Prince of Wales, Kuiu, Kupreanof, Mitkof, Etolin, Revillagigedo, Kosciusko, 

Zarembo, and Dall islands, are thought to support persistent wolf populations 

(Person et al. 1996). Recent genetic analyses have shown that wolves on Prince of 

Wales Island (GMU 2) are a population segment isolated from all other wolves in 

Southeast Alaska and coastal British Columbia (Weckworth et al. 2005). Wolves 

require an adequate prey base of ungulates, beaver, and salmon; in most areas of 

Southeast Alaska the Alexander Archipelago wolf depends heavily on deer. 

Suitable habitats for wolves equate to areas capable of supporting this prey base. 

Wolves use a wide variety of habitats when prey are present, and can affect prey 

populations in those areas. 

Wolf densities are closely tied to the population levels of their prey though 

populations may not exceed certain levels even when prey abundance is high due to 

other regulatory mechanisms including environmental conditions and social 

interatcions (Messier 1994, 1995). However, deciphering the influence of each of 

these factors can be obscured by varying rates of harvest, time lags in carnivore 

response to changes in prey, or changes in prey vulnerability (Peterson 1977, Fuller 

and Sievert 2001). Throughout their range, a density of one adult wolf per 10 

square miles appears to be high, based on densities reported for wolf populations 

elsewhere in North America, and this density is often considered as a saturation 

point beyond which wolf populations would not expand (Person et al. 1996). Wolves 

have large home ranges (about 100 square miles per pack), use a wide variety of 

habitats, and are very mobile (Person et al. 1996). 

A petition to list the Alexander Archipelago wolf as threatened under the ESA in 

1993 illustrated a concern for the viability of this subspecies. USFWS accepted the 

petition, confirming the concern, but concluded in 1995 that listing was not 

warranted at this time. However, an interagency wolf conservation assessment was 

conducted to synthesize available information on wolf ecology and identify 

management considerations for sustaining viable wolf populations on the Tongass 

(Person et al. 1996). The assessment concluded that wolf densities are generally 

lower on the mainland and higher on islands in the southern half of the Tongass. 

The large islands south of Frederick Sound (GMUs 2 and 3) support approximately 

60 to 70 percent of the total wolf population in Southeast Alaska (Person et al. 1996, 

Person 2001). Principal concerns exist on Prince of Wales and Kosciusko Islands, 

where past timber harvest has reduced deer habitat capability and increased road 

density. Although the wolf population is capable of sustaining harvest, Person 

(2001) expressed concern that expanding road access, particularly on Prince of 

Wales Island, may increase mortality of wolves there beyond sustainable levels. 

Therefore, assessing potential impacts to the wolf population is critical given the 

complex relationship they have with deer populations and human livelihoods. 

Recent analyses presented at the Tongass Conservation Strategy Review 

Workshop (2006) have modeled the probability of an overkill (average harvest of 

greater than 30 percent of the population) or destructive harvest (harvest greater 

than 90 percent of the population occurring once between 1985 and 1999) of the 

wolf population on Prince of Wales Island taking into account road density and 

whether the road system was connected to a main road system with access to a 

ferry. Results indicated that 32 percent of WAAs on Prince of Wales Island have 

road densities indicatative of a high probability of overkill and 52 percent have road 

densities indicating a high proability of having had at least one destructive harvest 

between 1985 and 1999. These results indicated that roads exert a strong influence 

on wolf mortality, particularly when connected to main road systems. However, it is 

important to note that roads themselves do not decrease habitat capability for 

wolves, but increased density of roads may lead to higher hunting and trapping 

mortality through improved human access. There are other methods available to 
3 Environment and Effects

Wildlife 3-238 Final EIS

address unsustainable hunting and trapping mortality including changes to both 

state and federal hunting and trapping regulations and increased enforcement. 

GMUs 2 and 3 support some of the highest wolf densities in the state and 

populations are thought to be stable in GMU 2 and increasing in GMU 3 (ADF&G 

2003). The State permits wolf harvest with a bag limit of five wolves taken by 

hunting and no limit for trapping; their objective is to maintain an average annual 

harvest of 39 wolves in GMU 2 based on the average harvest from 1984 to 1990 

(ADF&G 2003). However, there is a harvest cap in GMU 2 that does not allow the 

harvest of more than 30 percent of the estimated fall population to ensure that a 

sustainable wolf population is maintained. Wolf hunting and trapping regulations for 

federally qualified users under the auspices of the Federal Subsistence Board are 

generally the same as that under State of Alaska regulation. 

Important components of a wolf conservation strategy include providing core 

habitats with low road density, maintaining wolf harvest within sustainable limits 

through regulations, and providing adequate deer habitat to support an abundant 

and stable deer population. Under the current Forest Plan, this is accomplished 

through standards and guidelines for road density, deer density, and den site buffers 

with associated timing restrictions. Current wolf standards and guidelines direct that 

effective road closures should be implemented when road access has been 

determined through analysis to be a significant factor in wolf mortality contributing to 

unusustainable wolf mortality. Preliminary results presented at the Tongass 

Conservation Strategy Review Workshop (2006) indicate that closed roads also may 

contribute to wolf mortality and that open and closed roads should be considered in 

road density calculations. In addition, consideration should be given to excluding 

high elevations when calculating road densities. Current standards and guidelines 

related to den site buffers and timing restrictions include buffers of 1,200 feet 

surrounding active dens from April 15 to July 1, no road construction within 600 feet 

during this time period, and protection for active dens from disturbance. 

The wolf was selected as an MIS because of population viability concerns in some 

areas of the Tongass. However, the datasets available for monitoring wolves are 

insufficient for detecting all but very large changes in the wolf population and are not 

designed to track trends in the population resulting from changes in their habitat. 

Additionally, although recent efforts have been made to improve information on 

wolves in the form of multi-year research projects undertaken by ADF&G and the 

Forest Service, it is difficult to determine the link, if any, between habitat change on 

the Tongass and changes in the wolf population, especially given confounding 

factors such as weather-dependent fluctuations in prey abundance or spatially 

differential hunting pressure (USDA Forest Service 2004i). Further existing 

observation and monitoring measures do not address the distinct population in 

GMU 2. 

Bald Eagle 

North America’s bald eagle (Haliaeetus leucocephalus) population reaches its 

highest density in Southeast Alaska. In 1992 the population was estimated at over 

13,000 adult birds; more than 8,000 nest sites were identified through 1996. Their 

nesting habitat is primarily old-growth trees along the coast and within riparian 

areas. The USFWS and Forest Service maintain an interagency agreement for bald 

eagle habitat management in the Alaska Region, which includes standards and 

guidelines for regulating human disturbance within identified bald eagle use areas. 

Gende et al. (1998) reported a decrease in active bald eagle nest density with 

increasing proximity to clearcuts, with reduced nesting activity for locations within 

948 feet (300 meters) of clearcuts. Gende et al. (1998) suggested that a buffer of 

328 feet would be inadequate to mitigate effects of harvest, and recommended a 
 Environment and Effects 3 

Final EIS 3-239 Wildlife 

984-foot buffer around active nests (Gende et al. 1998). Furthermore, most bald 

eagles nest within 328 feet (100 meters) of saltwater shorelines in Southeast Alaska 

and it has been suggested that to prevent loss of this segment of the eagle 

population, a 1,300-foot buffer be maintained to protect all nesting bald eagles. 

Currently, a 330-foot radius protective habitat management zone surrounds all 

identified bald eagle nest trees and a 1,000 foot beach buffer is maintained along 

the shoreline. 

The bald eagle was selected as an MIS because of its use of coastal areas for 

foraging and nesting. Unlike many current MIS, a reasonably precise estimate of 

bald eagle population trends in Southeast Alaska can be derived from surveys 

conducted by USFWS, which could serve as a logical measure of the efficacy of the 

1,000-foot beach buffer prescription under the current Forest Plan. USFWS has 

completed an evaluation of the effectiveness of the 1,000-foot beach buffer 

prescription for conserving forest-dwelling birds through two separate research 

projects, which indicated that a minimum of 1,000-foot buffer was beneficial for 

several species (red breasted sapsucker and some others) and then buffers less 

than this may not be effective at maintaining nesting habitat for some species (see 

Kissling 2003 and Sperry 2006 for additional information). 

Red Squirrel 

The red squirrel is one of only two arboreal rodents in Southeast Alaska. Red 

squirrels are abundant on many of the islands in the Alexander Archipelago and the 

mainland. Red squirrels require forests with cone-producing trees and cavities in 

trees and snags for nesting and denning. The root systems of large spruce trees 

are also important for den sites. They represent a species that can do fairly well in 

seed-producing young-growth timber stands. There are about 8.4 million acres of 

forested land (including all age classes and types of conifer forests) within occupied 

red squirrel habitat on the Tongass National Forest. Optimum habitat use is 

believed to occur when patches of preferred habitat are greater than 30 acres. 

The red squirrel was selected as an MIS because it is an important prey species for 

marten and requires forests with cone-producing trees and cavities in trees and 

snags. However, few data are available describing red squirrel populations over 

time and changes in local populations do not necessarily imply negative impacts to 

the overall population. Thus, this presents an impasse in the ability to correlate 

human-induced habitat change with population trends. Additionally, although habitat 

capability for red squirrels is reduced through the conversion of POG to second 

growth, recovery of habitat capability after timber harvest is much faster for red 

squirrels than other species. That is, although post-harvest formation of structures 

favored for nesting and food storage (cavities) takes longer, the majority of habitat 

capability (food availability) is restored quickly as cone production typically begins 

40 years after harvest. 

Red-breasted Sapsucker 

The red-breasted sapsucker (Sphyrapicus ruber) is well distributed throughout 

Southeast Alaska during the spring, summer, and early fall seasons, and occurs in 

lower elevations during the late fall and winter seasons. They use a wide variety of 

forested habitats but require the presence of snags during the breeding season and 

are indicative of low volume POG (SD4H category). They are weak excavators and 

therefore require rotted or soft substrates in order to create cavities for nesting and 

roosting. There are about 9.9 million acres of forested land (includes all age classes 

and types of conifer forests) within occupied red-breasted sapsucker habitat on the 

Tongass National Forest of which approximately 980,000 acres are in the SD4H 

category (see Table 3.9-5 in the Biodiversity section). Old-growth forests provide 
3 Environment and Effects

Wildlife 3-240 Final EIS

the best snag habitat over the long-term; stands with higher densities of snags 

receive more use. Red-breasted sapsuckers on northern Vancouver Island, British 

Columbia, preferentially selected large diameter trees (mean diameter at breast 

height [dbh] 93.3 cm), which Joy (2000) surmised provided an optimal balance of 

nest space (could accommodate larger clutch sizes), insulation, and protection from 

predation. In managed landscapes, forest buffers are important for this species. 

Kissling (2003) found that in Southeast Alaska red-breasted sapsucker densities 

were positively correlated with forest buffer width, and appeared to be maximized 

when bufferes were at least 300 meters wide. 

The red-breasted sapsucker was selected as an MIS as a representative primary 

cavity excavator. In Southeast Alaska, currently the best available information that 

can be related to red-breasted sapsucker populations comes from the US 

Geological Survey (USGS) Breeding Bird Survey (BBS) and the Audubon Society 

Christmas Bird Counts (CBC). Additional information has been derived from the 

Monitoring Avian Productivity and Survivorship (MAPS) program, under which three 

to seven stations are surveyed by the Tongass National Forest to capture forest 

birds during the breeding season, and the Alaska Landbird Monitoring Survey 

(ALMS). However, these are large-scale monitoring programs and may not detect 

changes in avian populations at a scale and resolution appropriate for the Tongass 

National Forest. Further, existing monitoring does not relate changes in redbreasted sapsucker habitat directly to changes in their populations under the 

present limitations of data provided and assumptions used. 

Hairy Woodpecker 

The hairy woodpecker (Picoides villosus) is considered an uncommon, permanent 

resident throughout Southeast Alaska. Hairy woodpeckers use old-growth forest 

habitats with snags and dying trees for foraging and nesting. Like the red-breasted 

sapsucker, hairy woodpeckers are primary cavity excavators for other cavity-using 

wildlife species. Their winter habitat may be their most limiting. There are about 9.9 

million acres of forested land (including all age classes and types of conifer forests) 

within occupied hairy woodpecker habitat on the Forest. High-volume old-growth 

forests provide the best long-term snag habitat, with large diameter old-growth trees 

(particularly SD5S, SD5N, and SD67 categories) receiving more use than stands 

with smaller diameter trees. There are approximately 2 million acres of old growth in 

the SD5S, SD5N, and SD67 categories; optimum habitat use is believed to occur 

when patches of preferred habitat are greater than 500 acres. 

The hairy woodpecker was also selected as an MIS as a representative primary 

cavity excavator. As with the red-breasted sapsucker, the best available information 

that can be related to hairy woodpecker populations in Southeast Alaska comes 

from the BBS, CBC, the MAPS program, and the ALMS. However, these are large 

scale monitoring programs and may not detect changes in avian populations at a 

scale and resolution appropriate for the Tongass National Forest. Further, existing 

monitoring does not relate changes in hairy woodpecker habitat directly to changes 

in their populations under the present limitations of data provided and assumptions 

used. 

Brown Creeper 

The brown creeper (Certhia americana) is considered an uncommon, permanent 

resident throughout Southeast Alaska. Brown creepers are likely more common 

than usually acknowledged, but detectability of this species is relatively low, 

resulting in abundance estimates that are biased low. This species was selected as 

an MIS because of its close association with large diameter old-growth trees 

(particularly SD5S, SD5N, and SD67 categories). As noted above, there are 
 Environment and Effects 3 

Final EIS 3-241 Wildlife 

approximately 2 million acres of the SD5S, SD5N, and SD67 category old growth on 

the Forest. The factor most cited as limiting brown creeper populations is the 

availability of old-growth and mature woodlands as nesting and foraging sites and 

research has shown that creepers abandon sites that have been subjected to even 

light (e.g., partial-cut) logging activity because such activity is typically focused on 

large, mature trees (Wiggins 2005). In a study of the effects of buffer width on 

breeding bird communities in the Tongass, a majority (83 percent) of all brown 

creeper observations occurred in undisturbed control plots (Kissling 2003). Optimum 

habitat use is believed to occur when patches of preferred habitat are greater than 

15 acres (USDA Forest Service 2003). 

In Southeast Alaska, the best available information that can be related to brown 

creeper populations comes from the BBS and the CBC. Additional information has 

been derived from the MAPS program and the ALMS. However, these are large 

scale monitoring programs and may not detect changes in avian populations at a 

scale and resolution appropriate for the Tongass National Forest. Further, existing 

monitoring does not relate changes in brown creeper habitat directly to changes in 

their populations under the present limitations of data provided and assumptions 

used. 

Vancouver Canada Goose 

Vancouver Canada geese (Branta canadensis) are distributed throughout the 

Alexander Archipelago of Southeast Alaska, with an estimated resident population 

of 10,000 birds. This population is relatively non-migratory, with the majority of birds 

moving only locally between nesting, brood rearing, molting, and winter 

concentration areas. Vancouver Canada geese were selected as an MIS because 

of their association with wetlands (both forested and non-forested) in the estuary, 

riparian, and upland areas of the Forest. Vancouver Canada geese are highly 

mobile and are found throughout the islands of Southeast Alaska. 

Nesting and brood-rearing habitats are potentially affected by various forest 

management activities, though timber harvest in these areas has generally been 

minimal because these sites are fairly unproductive. Additionally, Riparian and 

Wetland standards and guidelines in place under the current Forest Plan, which 

include the use of various Best Management Practices (BMPs), are designed to 

minimize impacts to and maintain the function of these habitats. Effects of timber 

harvest and recreation on winter habitats have not been assessed but may result in 

increased human disturbance to wintering flocks or their habitats. Waterfowl census 

surveys conducted by the USFWS are the best source of demographic information 

for Vancouver Canada geese; however, population data are too insufficient to 

indicate a Forest-wide trend in the population, and thus no clear relationship has 

been established between population numbers and trends in habitat change. 

Marbled Murrelet 

The marbled murrelet (Brachyramphus marmoratus) is a robin-sized seabird. It 

feeds below the water's surface on small fish and invertebrates, and in Southeast 

Alaska, is usually found within 5 miles of shore. The marbled murrelet typically 

nests on mossy-limbed branches of large, mature coniferous trees within stands of 

structurally complex, coastal old-growth forest (SD5N, SD5S, SD67 categories). 

There are roughly two million acres of this habitat on the Tongass. However, on 

some treeless islands in Southeast Alaska marbled murrelets will lay eggs on bare 

talus slopes in mountainous areas (Piatt et al. 2007). 

The majority of the world population of marbled murrelet breeds in Alaska, with most 

found in Southcentral and Southeast Alaska. In March 2006, a status review for the 

Other Species of 

Concern 
3 Environment and Effects

Wildlife 3-242 Final EIS

marbled murret was initiated by the USFWS for the northern part of the species 

range to support ESA deliberations over the listing of the species as threatened in 

the sourthern part of its range (California, Oregon, and Washington). This review 

compiled published information on the conservation status, population biology, 

foraging ecology, population genetics, population status and trends, demography, 

marine and nesting habitat characteristics, threats, and ongoing conservation efforts 

for marbled murrelets in Alaska and British Columbia (Piatt et al. 2007). Genetic 

analysis conducted as part of the review identified three distinct population 

segments: one in the central and western Aleutian Islands, one ranging from the 

eastern Aleutians to Northern California, and one in central California. Based on 

historical abundance information, the Alaska population numbered approximately 1 

million birds in the recent past and is now estimated to be approximatey 270,000 

birds (Piatt et al. 2007). Three areas of greatest abundance include Lower Cook 

Inlet (35,670 birds), Prince William Sound (33,745 birds), and Southeast Alaska 

(144,190 birds). 

Using trend information from at-sea surveys conducted at eight sites in Alaska, 

numbers have declined annually at five sites at rates of -5.4 to -12.7 percent per 

year since the 1990s, representing an overall decline in the Alaska population of 70 

percent during the past 25 years (Piatt et al. 2007). Populations at three sites in 

Southeast Alaska have exhibited overall declines of 46 to 70 percent between the 

early 1990s and 2001. Likewise, the Prince William Sound population declined by 

69 percent between 1989 and 2005 and the population on the outer coast has 

declined by 43 percent between 1992 and 2002. Possible causes of estimated 

overall Alaska declines are oil spills, mortality from gill netting, cyclic changes in 

marine food productivity, and the harvesting of POG forests, though it is likely that it 

is a combination of these forces, as has been implicated in similar declines 

observed in other seabird populations in Alaska (Piatt et al. 2007). The 2007 status 

review concluded that, over the last half century, marbled murrelets have lost about 

15 percent of their suitable forested nesting habitat in Southeast Alaska due to 

large-scale logging, though nesting habitat losses cannot explain the declines 

observed in areas such as Prince William Sound or Glacier Bay where industrial 

logging has not occurred on a large scale or at all (Piatt et al. 2007). 

Recent research indicates that key microhabitat characteristics of marbled murrelets 

nest sites include: (1) sufficient height to allow stall landings and jump-off 

departures, (2) openings in the canopy for unobstructed flight access, (3) sufficient 

platform diameter to provide a nest sight and landing pad, (4) soft substrate to 

provide a nest cup, and (5) overhead cover to provide shelter and reduce detection 

by predators (Hamer and Nelson 1995, Nelson 1997, and Burger 2002). 

Conceptually, uneven-aged silvicultural practices or extended harvest rotations may 

maintain sufficient forest structure to support nesting murrelets, depending on gap 

size and the interspersion of trees and patches in the cutting unit. However, due to 

their association with old-growth forests it is apparent that nesting habitat for this 

species is not easily created and is likely that in young stands, suitable nesting 

habitat will not develop for 150 or more years (Albert and Schoen 2006). 

An interagency conservation assessment of marbled murrelets in Southeast Alaska 

conducted in 1996 concluded that a murrelet conservation strategy should consider 

a reserve-based approach, especially in those biogeographic provinces where 

substantial timber harvest has been concentrated and is projected to continue 

(DeGange 1996). The current Forest Plan satisfies many of the measures identified 

in the assessment, including a Forest-wide system of OGRs and uneven-aged 

management in many areas that allow timber harvest. Standards and guidelines 

pertaining to marbled murrelets include maintaining a 600-foot (200-meter) radius no 

cut buffer zone around identified murrelet nests. However, marbled murrelet nests 

are extremely difficult to find, so in the Pacific Northwest where old growth is 

relatively rare, some resarchers have suggested that a more effective conservation 
 Environment and Effects 3 

Final EIS 3-243 Wildlife 

strategy would be to maintain a 5-mile (0.8-km) radius buffer around any stand that 

is occupied by marbled murrelets (Raphael 2006). 

Spruce Grouse 

Spruce grouse (Falcipennis canadensis) are resident across much of northern North 

America, occurring from Alaska to Labrador southward into New England and into 

the northern states of the western U.S. The Prince of Wales spruce grouse is a 

subspecies that is endemic to Prince of Wales and nearby islands in southern 

Southeast Alaska. 

Spruce grouse are closely associated with taiga and northern montane coniferous 

forests, with a lush understory of mountain cranberry, blueberry, crowberry, and 

spiraea growing on a thick carpet of mosses, where they rely heavily on pine and 

spruce needles as their main food source. Spruce grouse select relatively young 

successional stands that are dense with a well developed middle story. Microhabitat 

selection varies between seasons, with habitat selection being driven by snow 

during winter (they move from open stands to dense stands possibly in relation to 

the availability of snow of sufficient depth for snow roosting) and by food availability 

during summer (density of breeding females increases with the abundance of the 

shrub and herb layer). During dispersal and migration, birds traverse stands of 

deciduous growth, though they generally avoid non-forested habitat. 

Spruce grouse in Southeast Alaska appear to be living in isolated and scattered lowdensity populations, which fluctuate overtime apparently in response to the degree 

of maturation of post-disturbance re-growth and predation pressure (Boag and 

Schroeder 1992). These small and isolated populations are particularly vulnerable 

to overexploitation associated with advancing roads and settlements. In addition, 

travel barriers created by development may reduce the exchange between 

neighboring populations, making it difficult for isolated populations to recruit new 

breeders. Though they are closely associated with conifer forests, the highest 

densities of spruce grouse are supported by areas with a mosaic of older coniferous 

habitats interspersed with regenerating patches of dense trees. Changes in forest 

structure, (e.g., timber harvest or windthrow) associated with fragmentation may 

lead to population declines if open areas are too large or forested patches are 

spread too far apart to enable spruce grouse to move between them. In the GMUs 

that encompass the Tongass (GMUs 1, 2, 3, 4, and 5), the ADF&G permits taking of 

spruce grouse between August 1 and May 15, with a bag limit of five per day. 

Flying Squirrel 

The northern flying squirrel (Glaucomys sabrinus) inhabits the boreal forests of 

Alaska, Canada, and the far northern U.S. and occurs on the mainland and southern 

islands in Southeast Alaska. The Prince of Wales flying squirrel subspecies (G. s. 

griseifrons) is endemic to Southeast Alaska and has been documented on Dall, El 

Capitan, Heceta, Kosciusko, Orr, Suemez, Tuxecan, Prince of Wales, and Barrier 

islands (Demboski et al. 1998, Smith 2005). The subspecies G. s. zaphaeus is 

more widespread in Southeast Alaska and occurs on the mainland. 

The flying squirrel is a keystone species in the Pacific Northwest associated with 

late-seral habitat and is a diet specialist (mycophagous). Their density often 

increases with forest complexity. However, recent research has suggested that 

flying squirrels in Southeast Alaska differ ecologically from those in the Pacific 

Northwest, in that they are more closely associated with important, individual habitat 

attributes (large standing live and dead trees) that may be present in both old and 

complex young forests, and have been shown to use peatland-scrub-mixed conifer 

forests, rather than just old-growth forest (Smith and Nichols 2003, Smith et al. 

2004b, Smith et al. 2005a). Surveys on Prince of Wales and Mitkof Islands 
3 Environment and Effects

Wildlife 3-244 Final EIS

indicated that the primary habitat of this species is high-volume POG, with some of 

the highest flying squirrel densities recorded in North America; however, breeding 

females were found in peatland and mixed-conifer stands, although demographic 

analyses showed that these were sink habitats (Smith and Nichols 2003). 

Additionally, a study on Prince of Wales Island found the density of large-diameter 

trees (greater than 74 cm dbh), abundance of Vaccinium shrubs, and density of 

large-diameter (50 to 74 cm dbh) snags was positively correlated with habitat use 

(Smith et al. 2004b). Although this study only looked at unmanaged landscapes, the 

authors suspected that had younger, less complex forest been included in their 

comparison, more attributes typical of old forest would have emerged as correlates 

of population density. Flying squirrels use large tree and snags for denning and 

nesting and require an adequate spacing of trees to travel through the forest. Thus, 

although flying squirrels may not be good indicators of “old” forest condition, they 

may be good indicators of landscape permeability in managed landscapes because 

successful dispersal of the species depends on the functional connectivity of the 

landscape (Smith et al. 2005a). The Prince of Wales subspecies was identified by 

the 1997 Forest Plan risk assessment panel as being at risk of extirpation in 

managed landscapes; however, the recent research described above indicates that 

this risk is likely less than presumed because abundant noncommercial forests 

appear to contribute to breeding populations (Smith 2005). 

Flying squirrels are an important prey for various predators including great horned 

owls, Queen Charlotte goshawks, and marten, although few, if any, predators in 

Southeast Alaska specialize on flying squirrels (AKNHP 2006, Smith and Nichols 

2003). Consequently, direct impacts to flying squirrels associated with habitat 

change may result in indirect impacts to predator populations. Timber harvest can 

adversely affect flying squirrel populations by creating restricted, isolated 

populations if clearcut size is too large or if some scattered tall conifers in large cuts 

are not retained as cover and for travel across the open spaces. 

Migratory Birds 

Executive Order 13186 (Responsibilities of Federal Agencies to Protect Migratory 

Birds) provides for the conservation of migratory birds and their habitats and 

requires the evaluation of the effects of federal actions on migratory birds, with an 

emphasis on species of concern. Federal agencies are required to support the 

intent of the migratory bird conventions by integrating bird conservation principles, 

measures, and practices into agency activities and by avoiding or minimizing, to the 

extent practicable, adverse impacts on migratory birds when conducting agency 

actions. 

Neotropical migratory birds are far ranging species that require a diversity of habitat 

for foraging, breeding, and wintering. Therefore, patterns of population declines are 

generally detected at larger observational scales than those traditionally used to 

manage lands and by assessing habitat at a larger geographic scale, effects to 

overall biodiversity can be better incorporated into the planning process (Finch and 

Stangel 1992). 

Over 100 species of birds migrate from the lower 48 states, Central and South 

America, to nesting, breeding, and rearing grounds in Alaska. Most of the birds fly 

to the interior or northern Alaska and only pass through southeast Alaska on their 

way to the breeding grounds. There are 114 “Important Bird Areas” identified by the 

Audubon Society, and a Partner for BirdLife International is working to identify a 

network of sites that provide critical habitat for birds. Of those areas identified, 49 

sites have been recognized to date as important habitat for migratory birds in 

Alaska. Though there are no recognized Important Bird Areas within Southeast 

Alaska, a statewide Important Bird Area program is well underway (Stenhouse 

2007). There are 40 protected bird species that may occur on the Tongass National 
 Environment and Effects 3 

Final EIS 3-245 Wildlife 

Forest; however, 20 bird species are identified as species of concern in Southeast 

Alaska (Boreal Partners in Flight 1999) and listed in Table 3.10-3. 

Of the protected bird species, 35 are associated with old-growth and mature forest 

habitats, and thus are sensitive to timber management activities. Based on nesting 

behavior, these species fall into four categories including ground-nesting birds (blue 

and spruce grouse), cavity- and bark-nesting birds (12 species including 

woodpeckers, the brown creeper, swallows, forest owls, and wrens), tree- and 

shrub-nesting birds (20 species including flycatchers, warblers, forest raptors, 

crossbills, thrushes, kinglets, and corvids), and specialized nesters (dippers). 

Spruce grouse are discussed above in detail. Of the cavity- and bark-nesting birds, 

only the red-breasted sapsucker and northern saw-whet owl are migratory, the rest 

being year-round residents in Southeast Alaska. Cavity nesters require suitable 

nest cavities and adequate foraging habitats such as snags and dead wood material 

on live trees (e.g., broken tree tops) that are not recruited into harvested stands for 

more than 100 years (Sallabanks et al. 2001). For example, in a study of the effect 

of buffer width on breeding bird communities in the Tongass (Kissling 2003), 83 

percent of brown creeper observations occurred in undisturbed control plots. Thus, 

the conversion of old-growth stands to clearcuts and younger successional stages 

reduces the amount of habitat available to these species. In addition, fragmentation 

increases forest edge area which can improve predator access and affect ecological 

dynamics of the forest through microclimatic effects (DellaSala et al. 1996). 

Of the forest- and shrub-nesting species in Southeast Alaska, most are migratory. 

Large proportions of the global population of several species breed in Southeast 

Alaska (e.g., 21 precent of varied thrushes and 20 percent of Pacific-slope 

flycatchers). Though there is a general lack of information regarding habitat 

requirements for most of these species, many occur more commonly in highvolume, lower elevation old-growth forests compared with second-growth stands 

(DellaSala et al. 1996, Russel 1999, Kissling 2003, Zwickel and Bendell 2005). The 

Pacific-slope flycatcher, varied thrush, golden-crowned kinglet, and Townsend’s 

warbler have the strongest association with old-growth and mature forest and 

require interior forest conditions (Stotts et al. 1999 as cited in Cotter 2007c). For 

Townsend’s warblers, large trees have been found to be important as nest sites in 

Southcentral Alaska, with predation rates higher among nests in small trees than in 

large trees (Matsuoka et al. 1997a, 1997b). Kissling (2003) measured breeding 

densities of Townsend’s warblers to be more than two times higher in forested 

beach buffers than in adjacent clearcuts. Like cavity- and bark-nesting species, 

open cup-nesting birds are also sensitive to fragmentation and tend to avoid nesting 

near forest edges where they are particularly vulnerable to predation (DellaSala et 

al. 1996). It is important to note that while studies of bird community response to 

timber harvest alternatives to clearcutting in Southeast Alaska do indicated that 

creation of forest edge may increase nest predation rates, the actual response 

depends on a broad array of factors and is highly variable. 

A specialized-breeder, the American dipper is a dependent stream-dweller and a 

year-round resident of Southeastern Alaska (Gabrielson and Lincoln 1959 as cited 

in Cotter 2007a). Within Southeast Alaska, American dippers appear to migrate 

seasonally along an altitudinal gradient as they do elsewhere in their range 

(Johnson 2003 as cited in Cotter 2007a, Morrissey 2004). American dippers benefit 

from adequate riparian buffers and thus may serve as an indicator of watershed 

health throughout the forest (Cotter 2007a). Estuaries and the intertidal zone are 

also important seasonal habitats for this species (M. Willson, ecologist, Juneau, AK, 

personal communication 2004 as cited in Cotter 2007a). As with the other nesting 

guilds, American dippers are known to be sensitive to human activities that 

negatively affect the riparian zone (Kingery 1996). 
3 Environment and Effects

Wildlife 3-246 Final EIS

Bird community composition and abundance has been shown to be correlated with 

forest buffer width, with widths in excess of 984 feet (300 meters) appearing optimal 

for many species (Forest Birds presented at the Tongass Conservation Strategy 

Review 2006). For example, Kissling (2003) found that densities of Pacific-slope 

flycatchers and Townsend’s warblers were similar in buffers greater than 300 

meters wide and in control sites, but lower in buffers less than 300 meters wide. 

Likewise, red-breasted sapsucker densities were positively associated with buffer 

width at the stand and landscape scales with densities greatest in buffers in excess 

of 300 meters. The largest effects were detected at the landscape scale, suggesting 

that a fragmentation threshold may exist for some species (Kissling 2003). Thus, as 

landsapes become more fragmented, forest buffers become increasingly important 

for migratory birds. Recent and ongoing studies that have evalatuated the effects of 

silviculture on bird communities include Deal et al. (2002), DellaSala et al. (1996), 

De Santo et al. (2003), De Santo and Willson (2001), Hennon et al. (2002), Holimon 

et al. (1998), Kissling (2003), Kissling and Lewis (ongoing), Matsuoka et al. 

(ongoing), Sieving and Willson (1998), and Sperry (2006). 
 Environment and Effects 3 

Final EIS 3-247 Wildlife 

Table 3.10-3 

Migratory and Resident Birds Identified as Species of Concern in Southeast Alaska1

Common Name 

Scientific 

Name General Habitat 

Preferred 

Habitat2 Abundance 

Blue Grouse Dendragopus 

obscurus

Habitat affinities vary by season and region. 

Coastal birds tend to remain in old-growth or 

recently logged forests all year. Inland birds 

prefer forest edges in summer, coniferous 

forests in winter (Kaufman 1996). Found in 

coniferous and mixed forests in Southeastern 

Alaska; also in dwarf conifer forests at treeline.

2, 3 Rare 

Western ScreechOwl Otis kennicottii 

open coniferous and deciduous forests and 

along rivers, creeks, ponds and bogs. Also 

forest edges and in suburban areas in parks, 

orchards and gardens. Often nest near water 

(Campbell et al. 1990). In southern part of 

range in mesquite groves and saguaros 

(Kaufman 1996). Probably non-migratory in 

Alaska due to sufficient habitat to meet yearround requirements (P. Schempf, pers. 

commun.). In Yakutat, appears to favor riparian 

spruce (B. Andres, pers. commun.). 

2 Uncommon 

Black Swift Cypseloides 

niger (borealis) 

appear to be restricted to river valleys with 

steep unvegetated cliffs. Although nesting has 

not been confirmed in Southeastern Alaska, 

summer sightings in adequate habitat suggest 

Black Swifts are a probable breeder. 

5 Rare 

Vaux's Swift Chaetura vauxi

Nests in coniferous and mixed forests, 

especially old growth. Often observed foraging 

over lakes, rivers, open country and clearcuts. 

Many records from Southeastern Alaska are 

along rivers and estuaries. 

2 Uncommon 

Rufous 

Hummingbird 

Selasphorus 

rufus

Found in a variety of habitats throughout 

breeding range including old growth, second 

growth, thickets, and shrubby hillsides 

2 Common 

Red-Breasted 

Sapsucker 

Sphyrapicus 

ruber

Often associated with mature stands, especially 

hemlock and/or spruce in Pacific Northwest and 

Southeastern Alaska, but may not be an 

obligate old-growth species.

2 Abundant 

Olive-sided 

Flycatcher 

Contopus 

cooperi

In Central Alaska, most often found in open 

conifer forest. Usually associated with openings 

(muskegs, meadows, burns, and logged areas) 

and water (streams, beaver ponds, bogs, and 

lakes). Apparently requires an uneven canopy 

or openings for aerial hawking, and wet areas 

productive of insect prey.

3 Uncommon 

Western WoodPewee Contopus 

sordidulus

In Southeastern Alaska, occurs along large 

mainland rivers, much less common on islands. 3 Uncommon 

Hammond’s 

Flycatcher 

Empidonax 

hammondii 

In southeastern Alaska, found in riparian 

deciduous forests. 2, 3 Uncommon 

Pacific-slope 

Flycatcher 

Empidonax 

difficilis

Prefers old-growth coniferous forests, especially 

near streams. 2, 3 Common 

Steller’s Jay Cyanocitta 

stelleri

In Alaska, found predominately in coniferous 

forests 2 Abundant 

Northwestern 

Crow Corvus caurinus Coastal beaches, rocky shores, estuaries, coastal ponds and inshore islands. 2, 6, 7, 8 Abundant 
3 Environment and Effects

Wildlife 3-248 Final EIS

Table 3.10-3 (continued) 

Migratory and Resident Birds Identified as Species of Concern in Southeast Alaska1

Common Name 

Scientific 

Name General Habitat 

Preferred 

Habitat2 Abundance 

Chestnut-backed 

Chickadee 

Poecile 

rufescens 

In Southeastern Alaska, common in mature 

hemlock/spruce forests and also in pole and 

sawtimber stages of successional forests 

2 Abundant 

American Dipper Cinclus 

mexicanus 

Dippers are a riparian-obligate species and are 

totally dependent on the productivity of streams 

and rivers. 

4, 5 Fairly 

Common 

Varied Thrush Ixoreus naevius Found mostly in thick, wet, coniferous forests of 

the coast. 1, 2, 3 Abundant 

Townsend's 

Warbler 

Dendroica 

townsendi

Largely restricted to mature forests with tall 

coniferous trees throughout its breeding range. 

Most abundant in large undisturbed tracts of 

contiguous forest, but will also use forests in 

late successional stages.

2, 3 Common 

Blackpoll Warbler Dendroica 

striata

Habitat preference variable, but usually found in 

tall shrubs (riparian woodland) or in coniferous 

or deciduous forest or woodland

2 Rare 

MacGillivray’s 

Warbler 

Oporornis 

tolmiei

In southeastern Alaska, it is found in shrubs 

along hemlock/spruce edges, deciduous 

woodlands with shrubs, clearcuts, and riparian 

shrubs.

1 Uncommon 

Golden-crowned 

Sparrow Regulus satrapa

Prefers low to tall alder and willow scrub on 

hillsides and near tundra. Commonly found in 

proximity to lakes, streams, and bogs. In winter 

prefers uninterrupted brushland, streamside 

thickets, and chaparral.

1 Fairly 

Common 

Golden-crowned 

kinglet 

Zonotrichia 

atricapilla 

Found in coniferous forests (spruce, fir, and 

hemlock) all times of year; also in mixed forests 

in southcoastal and central Alaska. In winter 

and migration, can be found in other trees and 

shrubs. 

1, 3 Common 

1/Source: Boreal Partners in Flight Landbird Conservation Plan for Alaska Biogeographic Regions (1999) 2/ 1=shrub thicket; 2=hemlock/Sitka spruce/cedar forest; 3=mixed deciduous/spruce woodland; 4=fluvial waters; 5=cliffs, 

bluffs, and screes; 6=moraines, alluvia, and barrier islands; 7=beaches and tidal flats; 8=rocky shores and reefs. 

The Federal ESA defines endemic as “a species native and confined to a certain 

region; having comparatively restricted distribution.” Forest Plan standards and 

guidelines for endemic mammals direct the Forest to “maintain habitat to support 

viable populations and improve knowledge of habitat relationships of rare or 

endemic terrestrial mammals that may represent unique populations with restricted 

ranges.” Likewise, the NFMA directs that management prescriptions “shall preserve 

and enhance the diversity of plant and animal communities, including endemic(s).” 

Due to its historic isolation, ecological complexity, and narrow distribution between 

the Pacific Ocean and coastal mountain ranges the North Pacific Coast is 

considered a hot spot for endemism (Demboski et al. 1999, Cook and MacDonald 

2001, Cook et al. 2006). Southeast Alaska has been found to be a region with an 

especially high degree of endemism in its small mammal fauna, principally because 

of the combination of its archipelago geography and its highly dynamic glacial 

history (Demboski et al. 1998). Roughly 23 percent of the 107 mammalian taxa in 

Southeast Alaska (species and subspecies) are endemic to the region (MacDonald 

and Cook 1996 as cited in Cook et al. 2006, Cook et al. 2001). Recent molecular 

genetic analysis has enabled a more accurate look at the level of genetic divergence 

among island and mainland populations than previously possible; this analysis has 

refuted the classification of some taxa previously believed to be endemic and 

identified other taxa as endemic (see Dawson et al. [2007] for a current list of 

species and associated ranges). Two of these, the Prince of Wales flying squirrel 

Endemism 
 Environment and Effects 3 

Final EIS 3-249 Wildlife 

and the Alexander Archipelago wolf, are incipient species, or subspecies that are 

beginning to diverge due to lack of interaction with other varieties of the same 

species (Bidlack and Cook 2001, Other Mammals Including Endemic presented at 

the Tongass Conservation Strategy Review Workshop 2006). 

Current understanding of endemism in Southeast Alaska is based on the sampling 

of only a minority of the islands (just over 100 of the more than 2,000 named 

islands). The documentation of new distributions, new species, and distinct 

populations from this effort, much of which occurred between 1991 and 1999, 

suggests a high level of endemism on the Tongass (Cook et al. 2006). Thus, there 

continue to be gaps in knowledge about the natural history and ecology of wildlife 

subspecies indigenous to Southeast Alaska and conclusive geographic ranges of 

many endemics cannot yet be produced (Hanley et al. 2005, Dawson et al. 2007). 

Although mammals have been the primary focus of current research on endemics 

there are potentially other endemic animals (e.g., nonvolant taxa) that exist on the 

Tongass.(e.g, endemic spruce grouse on Prince of Wales Island and Zarembo 

Island). These include organisms such as plants, birds, amphibians, or 

invertebrates that may foreseeably have levels of endemism (Dawson et al. 2007). 

Within the Alexander Archipelago, the Prince of Wales Island complex appears to be 

an endemic hotspot based on evidence that it was an area of refugia during the last 

glacial event (Cook et al. 2001). This has implications for management because 

there is notable overlap between this area, past timber harvest, and the potential for 

future timber harvest (Cook et al. 2006). 

The island archipelago setting of the Tongass and naturally fragmented landscapes 

of Southeast Alaska, create challenges for management as natural interaction 

between subpopulations and individuals is often problematic, especially for species 

that cannot move between islands. The insular distribution patterns of many 

terrestrial mammal species among individual islands illustrates these dispersal 

limitations. For example, in study of population structure and genetic diversity in 

eight northern flying squirrel populations in the Alexander Archipelago (six island 

and two mainland populations), Bidlack and Cook (2001, 2002) found that island 

populations were less genetically diverse and that, on a genetic level, populations 

appeared to be isolated by distance, indicating that there is little long-distance 

geneflow across the archipelago. The authors found that six populations from the 

Prince of Wales complex are genetically very similar, suggesting current or recent 

geneflow among these islands, yet no apparent gene flow between the Prince of 

Wales complex and other populations in Southeast Alaska. Similar recent research 

on the demography, systematics, phylogeography, and post-glacial expansion of 

Southeast Alaska endemics has focused on the red-backed vole (Runck 2001, Cook 

et al. 2004, Smith and Nichols 2004, Runck and Cook 2005, Smith et al. 2005b), 

long-tailed vole (Conroy and Cook 2000), Keen’s mouse ( Lucid and Cook 2004, 

Smith et al. 2005b), dusky shrew (Demboski and Cook 2001), long-tailed shrew 

(Demboski and Cook 2003), ermine (Fleming and Cook 2002), marten (Stone and 

Cook 2002, Stone et al. 2002), wolverine (not endemic, but isolated populations with 

limited dispersal capability occur in Southeast Alaska; Tomasik and Cook 2005), 

and black bear (Stone and Cook 2000, Peacock et al. 2007). Major factors 

identified by these studies include reduced genetic diversity, limited dispersal 

capabilities, and the existence of highly divergent or relatively restricted western, or 

Pacific coastal, lineages of some species. This last factor was due to the existence 

of eastern and western forest refugia in North America during past glacial advances, 

all resulting in populations that are especially vulnerable to environmental 

stochastisity and anthropogenic disturbances. 

Island archipelagos themselves are more sensitive to the effects of introduced 

exotics, emerging pathogens and disease (e.g., canine distemper), and natural 

events, such as climate change, than other managed landscapes, due to their 
3 Environment and Effects

Wildlife 3-250 Final EIS

insularity. Therefore, there is a higher probability of extinction on islands due to the 

restricted ranges of species, patterns of extinction are dynamic (i.e., in higher 

latitude archipelagos geographic ranges of mammals and recolonization abilitites 

fluctuate with glacial advances and retreats), and the effects of management 

activities are magnified. In fact, more than 81 percent of mammalian extincions in 

the last 500 years have been insular, endemic mammals (Ceballos and Brown 1995 

as cited in Dawson et al. 2007). Noteably, while the distribution of mammalian 

species in Southeast Alaska is a function of the size of the island on which they 

occur and distance to the mainland, the distirubtion of endemic mammals is not 

(Conroy et al. 1999, Dawson et al. 2007). Thus, designing conservation measures 

based on island size or location will not effectively maintain the endemic diversity 

found in this region. Because of the uniqueness of this type of geographic setting 

and the vulnerability of species within it, some researchers have proposed 

structuring conservation efforts and land management planning along the North 

Pacific Coast around the issue of endemism (Cook and MacDonald 2001, Cook et 

al. 2001). 

Species are considered invasive if they are not native to an ecosystem, and are 

likely to cause harm to human health, the economy, or the environment (Executive 

Order 13112). Due to its remote landscape and climate, Alaska has relatively few 

invasive species compared to the rest of the United States. However, factors such 

as altered disturbance patterns, climate change, and the expansion of the 

transportation network in Alaska are expected to increase the prevalence of 

invasives. Global climate change also creates conditions suitable for new invasives 

by altering geographic range limits and by making habitats no longer suitable for 

native species. 

Invasive species can affect native species by preying on them, competing with them, 

hybridizing with them, disrupting or destroying their habitat, or introducing pathogens 

or parasites that sicken or kill them. At least eight terrestrial species have been 

introduced into coastal Alaska habitats: Norway rat (Rattus norvegicus), European 

black slug (Arion atter), garden slug (Arion spp.), leopard slug (Limax maximus), elk 

(Cervus elaphus), house mouse (Mus musculus), starling (Sturnus vulgaris), and 

rock dove (Columba livia). Raccoons and snowshoe hares have also been 

introduced; however, due to their small population size and limited distribution, these 

species are not currently considered a threat to coastal Alaska ecosystems 

(Schrader and Hennon 2005). At this time, only rats are considered to be causing 

substantial ecological harm in coastal ecosystems and thus invasive, though there is 

concern about the expanding elk population (Schrader and Hennon 2005). With the 

exception of elk, which were introduced intentionally as part of a collaborative effort 

between ADF&G and the USDA Forest Service and are a desired non-native in 

some areas, all other species were unintentionally introduced. 

Norway rats likely became established along the Alaska coast following shipwrecks 

of early European explorers and now occur in areas of human habitation and along 

coastal islands where food supplies are abundant (Schrader and Hennon 2005). 

The primary concern with this species is the adverse effects it may have on groundnesting birds, as evidenced by rat populations on the Aleutian and Queen Charlotte 

Islands that prey on bird nests and have substantially impacted breeding bird 

colonies. 

Elk were introduced to Alaska to develop additional hunting opportunities. As 

recently as 1987, ADF&G introduced elk on Etolin Island. Elk have spread to other 

islands and areas in the Southeast. A population occurs on Zarembo Island, and 

there have been reports of elk on other nearby islands including Onslow, Wrangel, 

Mitkof, Kupreanoff, Kashevaroff, Prince of Wales, Brush, Shrubby, and Farm 

Invasive Species 
 Environment and Effects 3 

Final EIS 3-251 Wildlife 

islands. They have also been spotted on the mainland as far north as Cape 

Fanshaw, and one of the original transplanted and radio-collared elk was located at 

the mouth of the Stikine River (J. Brainard, USDA Forest Service biologist, 

Petersburg District, personal communication). Elk are a desired non-native species 

on Etolin and Zarembo islands, but there are still many unknowns about their 

presence and potential ecological effects elsewhere. The ADF&G Division of 

Wildlife Conservation has prepared a draft elk management plan for Southeast 

Alaska to manage and better understand the elk population and its potential effect 

on native plants and animals (ADFG 1999). The main concern is competition with 

native Sitka black-tailed deer due to the high degree of dietary overlap of the two 

species (ADFG 1999). This is primarily an issue on deer winter range, where deer 

are most limited by resource availability. Elk may reduce the available winter forage 

for deer through browsing, physically displace deer, alter predator-prey dynamics, 

and directly compete for food. The degree of dietary overlap between the species is 

the highest reported in the literature, indicating a high potential for direct competition 

(Kirchhoff and Larsen 1998). Pellet-count surveys on Etolin Island between 1991 

and 1998 documented a doubling of the elk population while deer population 

declined by 56 percent (ADFG 1999). An associated issue is that a decline in deer 

numbers could lead to fewer deer hunting opportunities. One recommendation for 

managing the elk population outside Etolin and Zarembo islands is to increase 

harvest pressure. 

There are also two invasive aquatic amphibian species that are present in coastal 

Alaska. The red-legged frog (Rana aurora), which is native to the Pacific Northwest, 

has established populations in several drainages on Chichagof Island and the 

Juneau area and recent surveys suggest that its range is expanding (MacDonald 

2003). Effects of this species are currently unknown but potentially include the 

displacement of the endemic boreal toad (Bufo borealis) and wood frogs (Rana 

sylvatica) (MacDonald 2003). The Pacific chorus frog (Pseudacris regilla) has an 

established breeding population on Revillagigedo Island in a single pond complex 

(MacDonald 2003). Currently, this population is thought to be having little effect on 

native amphibian species, because in recent years boreal toads and rough-skinned 

newts (Taricha granulose) have successfully reproduced in the same pond complex 

(Schrader and Hennon 2005). 

Consumptive Uses of Wildlife on the Tongass 

A number of the wildlife species on the Tongass are important for subsistence, 

general hunting, or trapping. Sitka black-tailed deer, mountain goat, brown bear, 

black bear, moose, wolf, marten, river otter, and waterfowl (collectively) are all 

species with hunting and/or trapping seasons managed by the ADF&G. These 

species are also important for a variety of native and traditional uses that vary 

across the geographic area and cultural framework of Alaska. This factor must be 

considered in management actions because of the need to be in compliance with 

Title VIII of ANILCA requiring that the needs of rural residents be given priority when 

managing wildlife and fisheries resources in Alaska. This priority adds considerable 

importance to the job of monitoring management effects. The Federal Subsistence 

Board has management responsibility for subsistence taking of fish and wildlife on 

federal lands in Alaska and the State of Alaska has management responbility for 

subsistence and general taking of fish and wildlife on all lands in Alaska. The 

primary source of information on annual hunting and trapping is the ADF&G. Except 

for a summary for Sitka black-tailed deer, consumptive use information is not 

repeated here (see the Subsistence section for more information on subsistence 

uses of wildlife). The Sitka black-tailed deer is by far the most important, and most 

"harvested," terrestrial wildlife species for subsistence purposes, and for general 

hunting. 
3 Environment and Effects

Wildlife 3-252 Final EIS

Based on ADF&G annual harvest summary reports, an average of 10,670 deer per 

year were harvested in Southeast Alaska from 1996 to 2004. This is approximately 

2,400 deer per year lower than the average annual harvest over the previous 15 

years (ADF&G 1996). Annual harvest fluctuated from year to year between 1996 

and 2004 ranging from 8,574 deer harvested in 2002 to 12,289 in 1998 (ADF&G, 

various years). Deer harvest has not been evenly distributed throughout Southeast 

Alaska. Of total deer harvested during this period, approximately 70 percent were 

harvested from Admiralty, Baranof, and Chichagof islands, and adjacent small 

islands (GMU 4), where the deer hunting season is longer and bag limits are larger 

than other parts of Southeast Alaska. Another 23 percent came from Prince of 

Wales and adjacent Islands (GMU 2). Eight percent of the harvest came from both 

the group of islands that comprise GMU 3 (Kuiu, Kupreanof, Mitkof, Zarembo, Etolin, 

and Wrangell islands) and the mainland (GMU 1). Less than 1 percent came from 

Yakutat (GMU 5). This trend is similar to that reported over the previous 16 years 

(see 1997 Forest Plan Revision Final EIS for trends in deer harvest between 1981 

and 1996), though the proportion of harvest in GMU 3 has increased since that 

period, likely because much of that area was closed to deer hunting in the 1980s. 

Total annual harvest has remained stable over the same period in GMUs 1, 2, and 

4; ADF&G began conducting surveys in GMU 5 in 1997 and harvest in this area 

remains low, but appears to be gradually increasing. 

The number of deer hunters decreased between 1996 and 2003 from 8,270 to 

7,028, for an average of 7,632 deer hunters per year (ADF&G various years). This 

is approximately 8 percent lower than the long-term average reported for the 15 

years prior to 1996 (ADF&G 1996). The average success rate for deer hunting from 

1996 to 2003 was 1.4 deer per hunter, which is slightly lower than the long-term 

average (1.6 deer per hunter). Likewise, the average annual success rate during 

this period (60 percent success) was lower than the long-term average (63 percent 

success). 

In 1987-1988, ADF&G conducted a survey within Southeast Alaska, asking deer 

hunters how many deer they desired to harvest (annually). The average from this 

survey was 4.2 deer, but respondents indicated they would be satisfied with an 

average of 2.7 deer. It has 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 population remaining stable and hunter satisfaction 

(success/effort) remaining fairly high (Flynn and Suring 1993). When harvest 

approaches 20 percent of carrying capacity, hunter satisfaction may diminish, and 

the harvest may be unsustainable over time, particularly in areas with high predator 

populations. If deer populations are above long-term carrying capacity, such as 

after several mild winters, hunter success may remain temporarily high. 

Environmental Consequences 

This section builds on the effects analysis conducted for the 1997 Tongass Forest 

Plan Revision Final EIS (USDA Forest Service 1997a). It is based on the known (or 

estimated) requirements of selected wildlife species with varying needs related to 

old-growth forest; there is no assurance that all, or even most, other old-growth 

associated species have similar needs or are adequately represented. Our 

knowledge of the specific viability requirements of most Tongass wildlife species is 

limited. We do know that the old-growth forest ecosystem is the dominant forest 

system in Southeast Alaska and provides habitat for most of these species, and is 

the primary habitat type potentially affected by the programmatic changes discussed 

here. Therefore, an analysis that focuses primarily on the old-growth ecosystem will 

best address or capture the requirements of all the old-growth associated species. 

Introduction 
 Environment and Effects 3 

Final EIS 3-253 Wildlife 

NFMA requires that the Forest Service provide for the diversity of plants and 

animals, based upon the suitability and capability of each National Forest, as a part 

of meeting overall multiple-use objectives (16 USC 1604(g)(3)(B)). The NFMA 

implementing regulations define diversity as "the distribution and abundance of 

different plant and animal communities and species within the area covered by a 

[forest plan]" (36 CFR 219.3). In addition to providing diversity direction (at 219.26), 

the NFMA regulations include the following provisions for managing habitat to 

maintain viable populations of wildlife species: 

Fish and wildlife habitat shall be managed to maintain viable populations 

of existing native and desired non-native vertebrate species in the 

planning area. For planning purposes, a viable population shall be 

regarded as one which has the estimated numbers and distribution of 

reproductive individuals to insure its continued existence is well distributed 

in the planning area. In order to insure that viable populations will be 

maintained, habitat must be provided to support, at least, a minimum 

number of reproductive individuals and that habitat must be well 

distributed so that those individuals can interact with others in the planning 

area. (36 CFR 219.3) 

The Multiple Use-Sustained Yield Act of 1960 states that “the national forests are 

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

watershed, and wildlife and fish purposes” (16 U.S.C. 528). The Act further directs 

the Forest to maintain renewable surface resources for multiple use and sustained 

yield. Likewise, under NFMA, forest plans are required to incorporate multiple use 

and sustained yield principles. Accordingly, another important purpose of the 

Tongass Forest Plan is to manage wildlife resources in such a way that, in addition 

to ensuring that viable wildlife populations are sustained, consumptive (hunting) and 

non-consumptive (wildlife viewing) opportunities are maintained. 

In order to accomplish these requirements, an Old-Growth Conservation Strategy 

(Conservation Strategy) was developed within the framework of the 1997 Forest 

Plan to maintain viable and well distributed populations of old-growth associated 

species on the Tongass. The Conservation Strategy is the product of the integration 

of several science-based efforts that were informed by the latest concepts in 

conservation biology and landscape ecology. These efforts include the Interagency 

Viable Population Committee’s (VPOP) proposed strategy for conserving old-growth 

associated vertebrates on the Tongass, which ranked species according to the 

concern for their viability and well distributed status and developed conservation 

strategies for the highest concern species (Suring et al. 1993). This proposal, its 

peer review (Keister and Eckhardt 1994), and ensuing response (Suring et al. 1994) 

formed the basis for two components of the Conservation Strategy: a coarse filter 

and a fine filter approach to conserving biodiversity on the Tongass. 

The coarse filter component to the Conservation Strategy is the old-growth strategy 

which divides the Forest into reserves consisting of protected lands which include 

non-development LUDs, and a system of small, medium, and large OGRs located 

strategically across the landscape. The reserves, based on the system of large and 

medium Habitat Conservation Areas (HCAs) originally mapped by VPOP, were 

designed to protect the “biological heart” of the forest and maintain a functionally 

interconnected old-growth ecosystem. In general, the size, spacing, and number of 

reserves were based on the home range and dispersal capabilities of old-growth 

associated species of concern. In addition, many other non-development LUDs 

(e.g., wilderness) were identified as functioning as large and medium OGRs. To 

address the need for larger habitat reserves and minimize fragmentation, the Forest 

Plan also contains at least one “very large” reserve within each of the 21 

biogeographic provinces across the Tongass. However, there was insufficient 

information to finalize the location of all small OGRs prior to the 1997 Forest Plan. 
3 Environment and Effects

Wildlife 3-254 Final EIS

VPOP recommended placing a small HCA in each 10,000-acre watershed with the 

objective of “providing temporary functional habitat for animals dispersing between 

large and medium HCAs and to ensure that species of concern have a relatively 

high likelihood of occurring in each 10,000+

-acre watershed.” The task of refining 

the location of small reserves has been conducted since then on a project-by-project 

basis per VPOP recommendations. During the current Forest Plan amendment 

process, an interagency team developed biological recommendations for the 

majority of the small OGRs on the Tongass. These recommendations were 

reviewed and refined at the District and Forest Supervisor levels to account for 

multiple uses and the resulting refined small OGR proposal is incorporated into 

Alternatives 1, 2, 3, and 6 in this assessment (see Appendix D).. 

Between 1997 and 2008, lands within the non-development LUDs have increased 

by 2,000 acres through reallocation, even though the total lands within the Tongass 

have decreased (primarily due to land adjustments). The Old-Growth Habitat LUD 

area has increased based on 24 project analyses conducted during this period, and 

the percentage of Tongass POG in reserves has increased from 70 to 71 percent 

(see Appendix D). Matrix lands, which include timber management lands, constitute 

areas where timber harvest can occur. Primarily since the 1950s, approximately 

450,000 acres of POG has been converted to young-growth stands under the 

Tongass timber management program (Table 3.9-2 in the Biodiversity section 

provides a breakdown of cover types on the Tongass by biogeographic province 

and Table 3.9-8 provides a breakdown of POG harvest by decade). 

The second component of the Conservation Strategy is a fine-filter approach, which 

includes species and habitat specific standards and guidelines that provide for 

connectivity between reserves and address old-growth structural needs within the 

matrix lands. Some of the primary management prescriptions, designed to ensure 

protection of a significant proportion of high-quality habitat within the matrix, are the 

1,000-foot beach and estuary fringe and the riparian buffers. Other standards and 

guidelines preclude or significantly limit timber harvest in areas of high hazard soils, 

steep slopes (greater than 72 percent), high vulnerability karst terrain, visually 

sensitive travel routes and use areas, and timber stands technically not feasible to 

harvest. In addition to providing additional old-growth protection, many of these 

prescriptions provide important connectivity functions within and between matrix 

lands and the larger OGR system lands outlined in the Conservation Strategy. 

There are also specific standards and guidelines designed to protect key wildlife 

habitat structure (e.g., reserve trees and cavity nesting habitat). 

Matrix lands are receiving growing attention for the importance they potentially play 

in maintaining well distributed and viable wildlife populations. Some species, 

particularly those that are wide ranging, require large blocks of continuous habitat to 

meet their life requirements. They also require surrounding habitat within the matrix 

for movement. Wolves and nesting pairs of goshawks, for example, require land 

bases that are larger than most OGRs on the Tongass and use resources within 

matrix lands to meet their life requisites and facilitate movement. Matrix lands are 

also important for supporting prey populations of many old-growth associated 

species. 

Previously, little emphasis was given to the young second-growth component of the 

matrix in terms of its ability to contribute structure, function, or value to wildlife. 

However, there appears to be a growing perception that, with active management, 

young stands can contribute at least some of the values commonly associated with 

old growth (Barbour et al. 2005). Key features of old-growth forest include large, old 

decadent trees, multiple canopy layers, standing snags, down woody debris, and a 

diverse and abundant herb layer. These features can be maintained or created by 

retaining structures and organisms at the time of regeneration harvest of old-growth 

forest and through active management of young, even-aged stands. Some potential 
 Environment and Effects 3 

Final EIS 3-255 Wildlife 

approaches to even-aged management involve thinning of older, “commercial”-aged 

young-growth stands (Deal 2001, Deal and Tappeiner 2002, Deal et al. 2002), 

including red alder (Alnus rubra) in the reforestation of harvested areas to expedite 

the production of large-diameter conifers (Deal 1997, Deal et al. 2004, Hanley et al. 

2006), and the initial use of alternatives to clearcutting (McClellan et al. 2000). It 

should be emphasized that additional research on the implementation of these 

techniques is needed. 

For example, both pre-commercial and commercial thinning of young-growth stands 

have beneficial impacts to black-tailed deer by opening up the forest and promoting 

the growth of understory vegetation. Likewise, active young-growth management 

has the potential to benefit both marten and goshawk through an increase in small 

mammal populations (red squirrels and red-backed voles, major prey items of these 

species, benefit from more open forests with abundant understory vegetation) and 

by speeding the succession of older young-growth stands toward old-growth 

condition (Hanley 1996, 2005). Although the time frame in which young-growth 

stands become suitable habitat for many species is beyond the lifespan of the 

Forest Plan, it is something to be considered as part of a long-term vision for 

management of the Tongass. It must be noted, however, that there research on the 

effectiveness of young-growth management is on going and peer-reviewed results 

are not yet available. The evidence in support of the potential benefits of younggrowth management for multiple values is derived from a series of demonstration 

projects that have tested various second-growth management methods (e.g., 

Zaborske et al. 2002; Deal et al. 2004; McClellan 2004, 2005; Wipfli et al. 2003), 

retrospective assessments (Hanley and Barnard 1998), and other observations. 

Thus, there remains much uncertainty about the true benefits of second-growth 

management to wildlife. Although active management will likely improve habitat 

conditions in young conifer stands, significant questions remain regarding the types 

of treatments, treatment timing, and cost/benefit tradeoffs. 

Framework for Analysis 

Alternatives 1, 2, 3, 5, and 6 do not propose to change the framework of the existing 

Forest Plan Old-Growth Conservation Strategy. That is, these alternatives maintain 

a strategy divided into coarse filter (system of protected lands) and fine filter 

(species- and habitat-specific standards and guidelines) management regimes, 

which appears to be an appropriate framework for maintaining well distributed and 

viable wildlife populations on the Tongass. Alternative 4 modifies the coarse filter 

component by requiring OGRs in only four of the most heavily modified 

biogeographic provinces (North Central Prince of Wales, Kupreanof/Mitkof Islands, 

Dall Island and Vicinity, and East Chichagof Island) in addition to maintaining two 

individual reserves including the Wright Lake (mainland southeast of Wrangell), and 

Myers Chuck (Cleveland Peninsula northwest of Ketchikan) reserves and creating 

one near Eva Lake (northeast Baranoff Island) in an area currently designated as 

semi-remote recreation. In addition, all VCUs outside of these biogeographic 

provinces would be required to retain 33 percent of their old growth with no 

requirement to consider spacing, location, size, shape, or composition in the design 

of the retained acres, as are provided by Appendix K of the current Forest Plan (OldGrowth Habitat Reserve Criteria). Alternative 7 maintains substantial area in nondevelopment LUDs, but eliminates the system of OGRs and would not have a 

specific retention requirement.. 

Alternative 5 would maintain the current standards and guidelines described in the 

1997 Forest Plan. Consistent under Alternatives 1, 2, 3, and 6 are proposed 

changes that modify the existing standards and guidelines or create new standards 

and guidelines that are similar to those under Alternative 5. These alternatives 

would replace the Goshawk Foraging and Marten Habitat standards and guidelines 

Effects Analysis 
3 Environment and Effects

Wildlife 3-256 Final EIS

with a Forest-wide Legacy Structure standard and guideline, revise the Goshawk 

Nest standard and guideline, and modify a number of other standards and 

guidelines (see Appendix D and the accompanying Forest Plan volume). 

Alternatives 1, 2, 3, and 6 also propose boundary modifications to the existing 

system of small OGRs (see the interagency effort described above in the 

Introduction). Rationale and background for these changes are provided in 

Appendix D. 

Alternatives 4 and 7 eliminate the Goshawk Foraging and Marten Habitat standards 

and guidelines, but do not apply the Legacy Structure standard and guideline. 

Alternative 4 maintains the existing Goshawk Nest standard and guideline, whereas 

Alternative 7 eliminates it and relies on the general Raptor Nest standard and 

guideline to provide protection. 

The following wildlife analysis is subdivided into three major sections. The first 

section focuses on the Conservation Strategy where changes to LUD designations, 

impacts to the OGR system and landscape connectivity, and matrix land 

management are discussed. The old-growth ecosystem is discussed in the 

Biodiversity section, but is briefly addressed here relative to the Conservation 

Strategy’s ability to maintain viable populations of old-growth associated species. 

The second section focuses on species-specific direct and indirect impacts related 

to habitat capability for ESA Candidate species, MIS, Forest Service Sensitive 

species, and other selected terrestrial wildlife species; impacts to ESA-listed species 

(which only include marine mammals and fish) are discussed in an updated 

Biological Assessment (Appendix F). Where appropriate, changes to standards and 

guidelines are discussed. Consideration of endemic and invasive species under the 

Forest Plan is also briefly addressed. The third section of this analysis evaluates 

cumulative effects of the proposed Forest Plan amendment on wildlife. Potential 

effects of the proposed action are discussed inlight of, the risks associated with 

uncertainties related to existing knowleged of species distributions and habitat 

relationshiops, the efficacy of the of protective measures under the conservation 

strategy, the future direction of forest management on the Tongass, and overall 

unpredictable enrivonmental factors such as climate change. 

Old-Growth Forest Conservation Strategy 

When considering the viability of old-growth associated species, the possible effects 

of alternatives, and the likelihood of maintaining viable well distributed populations, 

the assumption is made that if a functional interconnected old-growth ecosystem is 

maintained, then its component parts (composition and structure) and processes 

(function) are maintained. The likelihood of these outcomes is discussed in detail in 

the Biodiversity section. The framework of the old-growth conservation strategy 

relative to wildlife viability is now further described as two basic components: 1) the 

reserve system in terms of its ability to effectively maintain the integrity of the oldgrowth forest ecosystem through non-development LUDs such as Wilderness 

Areas, Research Natural Areas, Remote and Semi-Remote Recreation, and OldGrowth Habitat, among others, and 2) matrix lands where development, such as 

timber harvest and road building, is permitted that will alter the old-growth forest 

ecosystem on a portion of the lands. These development LUDs are restricted by a 

suitability determination process (see Timber section), which precludes the harvest 

of forest stands that would result in impacts to long-term site productivity or cause 

irreparable damage (e.g., mass wasting), and other Forest-wide standards and 

guidelines. 

The amount of matrix lands (development LUDs) versus reserve system lands (nondevelopment LUDs) is one measure of the ability of the alternatives to protect the 

integrity of the old-growth forest ecosystem. There are approximately 3.6 million 

acres of matrix lands under Alternative 5 (No Action), which would slightly decrease 
Environment and Effects 3 

Final EIS 3-257 Wildlife 

under the Alternative 6. Alternatives 3, 2, and 1 would provide increasingly greater 

protection by reallocating existing matrix lands to various non-development LUD 

designations, resulting in approximately 3.0 million, 2.0 million, and 938,000 acres of 

matrix, respectively. In contrast, Alternatives 4 and 7 would create an additional 1.1 

million and 1.5 million acres of matrix lands relative to Alternative 5, respectively 

(see Table 3.10-4). 

Table 3.10-4 

Summary of Acres in Matrix and Reserve Lands by Alternative 

Matrix1 Reserve2 

Alternative Acres 

% of 

Landbase Acres 

% of 

Landbase

Alternative 1 840,359 5.0% 15,933,443 95.0% 

Alternative 2 1,929,485 11.5% 14,844,321 88.5% 

Alternative 3 2,803,945 16.7% 13,969,858 83.3% 

Alternative 4 4,727,686 28.2% 12,046,116 71.8% 

Alternative 5 3,605,974 21.5% 13,167,834 78.5% 

Alternative 6 3,457,420 20.6% 13,316,385 79.4% 

Alternative 7 5,049,695 30.1% 11,724,107 69.9% 1

 Includes Modified Landscape, Timber Production, Scenic Viewshed, and Experimental Forest LUDs 2

 Includes all other LUDs where timber harvest is prohibited or restricted 

Table 3.9-12 in the Biodiversity section shows the acreage and percentage of POG, 

high-volume POG, and large-tree POG that would be contained within reserves and 

matrix lands, and the acres that would be protected from harvest in the matrix, under 

each alternative. Table 3.10-5 (below) provides a summary of the percentage of 

POG in each category, under each alternative. There are approximately 4.95 million

acres of POG remaining on the Tongass. Alternative 5 (No Action) provides a 

combination of land allocations that protects at least 91 percent of this acreage over 

the long-term, and is believed to reduce the overall risk and increase the likelihood 

of maintaining viable and well distributed populations of old-growth associated 

species. Alternatives 1, 2, 3, and 6 would also protect at least 91 percent of the 

existing POG. However, Alternatives 4 and 7 would protect 87 and 84 percent, 

respectively. Within reserves (non-development LUDs), which represent long-term 

habitat patches or blocks of POG, the greatest percentage of existing POG would be 

maintained by Alternative 1 (93 percent), followed by Alternatives 2 and 3 (84 and 

78 percent, respectively), Alternatives 5 and 6 (71 and 72 percent, respectively), and 

Alternative 7 (57 percent). Tables 3.9-14 and 3.9-18 in the Biodiversity section 

present additional detail on the percentages of POG protected in reserves and 

throughout the landscape by biogeographic province and ecological subsection, 

respectively. Harvest under all of the alternatives would be concentrated in four 

biogeographic provinces (North Central Prince of Wales Island, Etolin Island and 

Vicinity, Kupreanof/Mitkof Islands, and Revillagigedo Island/Cleveland Peninsula), 

where substantial amounts of timber harvest have already occurred. That is, a 

majority of harvest under all alternatives occurs in or near the roaded base (areas 

where roads are already constructed) which is concentrated in the four aformetioned 

biogeographic provinces. As the alternatives increase in harvest intensity, the area 

harvested progressivly extends beyond that roaded base. 
3 Environment and Effects

Wildlife 3-258 Final EIS

Table 3.10-5. 

Percentage of Existing Productive Old-Growth Acreage in Reserves, 

Protected/Unscheduled in the Matrix, and Suitable for Timber Harvest in 2008 

POG Area in Matrix – Protected 

or Unscheduled 

Alternative 

POG Area 

in 

Reserves 

Protected in 

Beach Fringe, 

Riparian, & 

Other 

Suitable, But 

Not Scheduled 

for Harvest 

Total 

Protected 

POG 

Total POG 

Suitable for 

Harvest1

1 93% 4% 1% 98% 2% 

2 84% 10% 2% 96% 4% 

3 78% 14% 2% 94% 6% 

4 60% 25% 1% 87% 13% 

5 71% 18% 1% 91% 9% 

6 72% 17% 2% 91% 9% 

7 57% 26% 1% 84% 16% 1 Represents the maximum POG that could be harvested assuming POG harvest takes place at the maximum rate. 

The 1997 Forest Plan Revision Final EIS expert panel assessment concluded that 

due to the Forest-wide system of OGRs and standards and guidelines that provide 

additional protection to old-growth habitat, Alternative 11 (the basis for Alternative 5 

in this EIS) would provide an amount and distribution of habitat adequate to maintain 

viable populations of vertebrate species across the Tongass and to maintain the 

diversity of plant and animal communities. Wildlife dependent on old-growth and/or 

unroaded habitats would have a moderately high likelihood of being maintained as 

viable and well distributed across the Tongass. Alternative 5 in this EIS was based 

on the 1997 Alternative 11, but incorporates the amendments that have occurred 

since 1997. These amendments have slightly increased the proporation of nondevelopment LUDs so Alternative 5 would be slightly more protective than the 1997 

Alternative 11. 

The same conservation measures are generally maintained under Alternatives 1, 2, 

3, and 6. The largest change is the replacement of the goshawk and marten 

standards and guidelines with the legacy standards and guidelines. As a result of 

this change, legacy would still be provided in the highest risk areas, but there would 

be slightly less POG protected within the matrix overall. However, the fact that 

these alternatives would allocate larger acreages to non-development LUDs 

produces more POG in reserves and a greater overall percentage of protected 

POG. In addition, these alternatives would protect a higher overall percentage of 

the larger tree POG types (both high-volume POG and big-tree POG), and would 

generally protect more POG and more larger tree POG in the most heavily 

harvested biogeographic provinces compared with Alternative 5 (see the 

Biodiversity section). Therefore, their likelihood of maintaining viable, well 

distributed populations of old-growth associated species across the Tongass would 

be higher. Because of the reduction or elimination of the OGR system under 

Alternatives 4 and 7, respectively, and the increase in area of development LUDs, 

these alternatives would have a reduced ikelihood of maintaining viable, well 

distributed populations relative to Alternative 5. 

As discussed above, matrix lands, including both old growth and some older young 

growth (e.g., stands of 25 to 150 years of age), are important in facilitating 

movement of wildlife across the landscape and providing life requisites to many 

species. However, young-growth stands vary in their value to wildlife but can 

potentially contribute more, in terms of structure and function, through active stand 

management. There are approximately 687,000 acres of young-growth stands 
 Environment and Effects 3 

Final EIS 3-259 Wildlife 

(including both harvested and natural young growth) on the Tongass. Under all the 

action alternatives, several Forest-wide standards and guidelines have been 

modified to specifically address young-growth management. The Timber 

Management standards and guidelines direct the Forest to “implement commercial 

thinning treatments in young conifer stands to obtain chargeable timber, improve 

wildlife habitat...” Likewise, wording has been added to the Transportation Road 

Management standards and guidelines to “consider future needs for commercial 

thinning.” The term “young-growth management” has been incorporated into 

existing standards and guidelines for Wildlife Habitat Improvement. Finally, the 

Forest is also planning for thinning in non-development LUDs to improve wildlife 

habitat. Management of young growth will increase over time and will produce 

positive benefits to wildlife by shortening the stem-exclusion phase of stand 

development when tree crowns are crowded and forage availability is at its lowest. 

Landscape Connectivity 

Fragmentation associated with habitat loss results in smaller sizes of habitat 

patches available to a species, increased distances among habitat patches, 

increasing amounts of matrix conditions in which habitat patches are embedded, 

and altered spatial distribution of habitat types (Haufler 2007). These factors are 

strongly tied to the structural and functional connectivity of the landscape, and thus 

the ability of the landscape to support well distributed and viable wildlife populations. 

When a landscape becomes fragmented (i.e., when habitat patches become small 

and farther apart), a continuously distributed population may become a series of 

small, isolated subpopulations that rely on the ability of dispersing individuals to 

facilitate genetic interchange between populations and to recolonize area following 

local extirpation. Consequently, smaller, less mobile species that have limited 

dispersal capabilities and species that occupy limited ranges (e.g., endemics) are 

likely to experience the largest population level effects of fragmentation. 

Consequently, matrix lands play a vital role in providing functional connectivity 

across fragmented landscapes (Szacki 1999). 

Timber harvest under all alternatives would increase fragmentation and reduce 

landscape connectivity. Alternative 7 proposes the greatest amount of timber 

harvest and therefore would result in the greatest increase in habitat fragmentation, 

followed by Alternatives 4, 5, 6, 3, 2, and 1, in decreasing order (Table 3.10-5 and 

Table 3.9-11 in the Biodiversity section). Most of this harvest would occur in the 

North Central Prince of Wales Island, Etolin Island, Kupreanof/Mitkof Island, and 

Revillagigedo Island/Cleveland Peninsula biogeographic provinces, which have 

already been heavily impacted by timber harvest. 

The OGR system, as noted above, is an important component of the Conservation 

Strategy aimed at maintaining the amount and distribution of old growth on the 

Tongass. A reserve system would be maintained under Alternatives 1, 2, 3, 5, and 

6. By limiting the OGR system to four highly developed biogeographic provinces 

and instating a retention requirement elsewhere, Alternative 4 would not be as 

effective in maintaining landscape connectivity over the long-term if retained acres 

are widely distributed, in small parcels, are linear in shape, and are not located to 

specifically protect important habitat features (e.g., suspected goshawk nesting 

habitat or deer winter range). This is particularly relevant in the Etolin and 

Revillagigedo Island/Cleveland Peninsula biogeographic provinces where a 

substantial amount of timber harvest is proposed but where no reserve system 

would be in place. Alternative 7 would have effects similar to Alternative 4, but to a 

greater extent because it eliminates old-growth habitat reserves all together. 

The following discussion addresses the areas identified as being critical links 

connecting portions of the landscape in areas where a high amount of timber 

harvest has occurred, or is likely occur in the future: 
3 Environment and Effects

Wildlife 3-260 Final EIS

Pinch-point No.1: This pinch-point is located in the middle of the East Chichagof 

biogeographic province, one of the more heavily developed provinces. This area is 

completely protected by a large OGR under Alternative 5, which provides 

connectivity between northeast Chichagof Island and the rest of the island. 

Alternatives 1, 2, 3, and 6 maintain this protection and add to it to varying degrees 

through the reallocation of the adjacent Timber Production lands to Remote and 

Semi-remote Recreation where minimal timber harvest is allowed. These 

alternatives ensure that habitat protection is in place to facilitate wildlife movement 

through the pinch-point as well as provide connectivity to a large area of LUD II and 

the West Chichagof-Yakobi wilderness area to the west. 

This pinch-point would receive little protection beyond what is provided by the beach 

fringe in Alternatives 4 and 7, which designate the area as development LUDs. 

Alternative 4 proposes to shift the large OGR to the southeast, and Alternative 7 

removes it completely, eliminating any actual old-growth connectivity across the 

pinch-point, except that which is provided by the beach buffer, which is only 500 feet 

wide in Alternative 7. Not only would Alternatives 4 and 7 isolate old-growth habitat 

in the vicinity of the pinch-point, but they could potentially isolate a portion of 

Chichagof Island if timber harvest limits wildlife movements through this corridor. 

Pinch-point No. 2: The area connecting Lisianski Inlet with the North Arm of Peril 

Strait on Chichagof Island is pinch-point No. 2. This area is fully protected as a 

Legislated LUD II area in all alternatives. 

Pinch-point No. 3: This area includes the Port Camden-Bay of Pillars connection 

and the portage between Port Camden and 3-Mile Arm and serves as a major 

linkage connecting north Kuiu with east Kuiu Island and Rocky Pass on its eastern 

edge; and North and South Kuiu Island. This area is protected by Old-Growth 

Habitat, Semi-Remote Recreation, and Remote Recreation LUDs under Alternatives 

1, 2, 3, 5, and 6. In contrast, under Alternatives 4 and 7, all of the Old-Growth 

Habitat LUDs in northern and eastern Kuiu would be reallocated to development 

LUDs; some non-development LUD would remain around the Bay of Pillars. Thus, 

Alternatives 4 and 7 could negatively affect wildlife movements between major 

portions of the island. 

Pinch-point No. 4: Pinch-point No. 4 is the narrow area between Lindenburg 

Peninsula and the remainder of Kupreanof Island and it is largely protected by the 

Petersburg Creek-Duncan Salt Chuck Wilderness. The remaining small area not 

included in the Wilderness between Portage Bay and Duncan Salt Chuck is primarily 

forested peatland. Under all alternatives the beach fringe buffer provides some 

additional connectivity but to a lesser extent under Alternative 7 because it reduces 

the buffer from 1,000 to 500 feet. 

Pinch-point No. 5: This area connects the extreme north end of Prince of Wales 

Island to the remainder of the island, where there has been substantial past and ongoing forest management activities. Under Alternatives 1, 2, 3, 4, 5, and 6 a crossisland connection is nearly protected by a small OGR around Neck Lake, and fully 

protected farther south by a very large reserve (including Remote Recreation LUD) 

around Sarkar Lakes. Because much of the pinch-point is highly developed, 

additional habitat alterations could create barriers to movement. Furthermore, the 

critical connecting habitat of this area is primarily inland (both shorelines are private 

land), and thus existing standards and guidelines for beach fringe and estuary 

buffers under all alternatives are not likely to maintain much additional connectivity. 

All action alternatives add a small Special Interest Area south of Neck Lake, which 

would be withdrawn from timber management. No OGRs exist under Alternative 7, 

thus reducing the likelihood of functional cross-island connectivity. 

Pinch-point No. 6: This area is now all private land, dividing the north-central and 

south portions of Prince of Wales Island with a non-NFS strip of land one to two 
 Environment and Effects 3 

Final EIS 3-261 Wildlife 

miles wide. Continued timber harvesting is anticipated on these private lands, with 

the potential to create migration and dispersal barriers. All action alternatives 

provide some additional protection to this pinch-point, relative to Alternative 5 (No 

Action), by designating a Special Interest Area adjacent to the non-NFS land. 

However, Alternative 7 eliminates all the Old-Growth Habitat LUDs in the vicinity of 

the pinch-point, thus reducing the functional connectivity of the old-growth 

ecosystem in the surrounding area. 

Species Assessments 

As noted above, the NFMA directs the Forest to manage wildlife habitat to maintain 

viable and well distributed populations to ensure continued existence in the planning 

area. Quantitative criteria for viability are not specified by the NFMA or associated 

regulations. For this analysis, the evaluation of viability includes considerations of 

its unique island archipelago environment as well as current scientific thinking on 

population viability and conservation biology, as found in the general literature and 

that compiled during the recent Tongass Conservation Strategy meeting (2006). 

This section briefly discusses potential effects to all Candidate, Forest Service 

Sensitive listed species, MIS, and selected other species of concern. There are 

several species that have been identified as species of special management 

concern, and for which a more in-depth fine filter analysis is necessary. As 

discussed under the Affected Environment portion of this section, these include two 

species evaluated for possible listing under the Endangered Species Act (Alexander 

Archipelago wolf and goshawk), the most important wildlife species for consumptive 

use (Sitka black-tailed deer, also important as the principal prey for the wolf), and 

two other species important as old-growth habitat indicator species and long-term 

viability concerns (brown bear and marten). 

The 1997 Forest Plan Revision Final EIS wildlife analysis relied in part upon expert 

panel evaluations of alternatives in terms of the estimated relative risks to a species 

or habitat of concern. Seven "panel assessments" were conducted: one for wolf, 

marten, goshawk, brown bear, marbled murrelet, "other terrestrial mammals" 

including endemics, and one for the old-growth ecosystem. Each of these oldgrowth associated species was selected ostensible because collectively their 

ecologies incorporated the breadth of forest habitat features and other attributes of 

environmental variation represented across the Forest, and because they were 

thought to be representative of a subset of species that are sensitive to disturbance 

and potentially at risk of either becoming locally extirpated or jeaopardizing cultural 

or subsistence uses. This approach has been effectively used in the Pacific 

Northwest and was chosen for the Tongass because a substantial amount of 

uncertainty existed in the understanding of various wildlife habitat and community 

relations and there was generally inadequate information on which to base 

predictive models (i.e., population viability anaysis). 

The panel assessments resulted in the generation of a set of estimates of the 

likelihood of various outcomes related to the persistence of each species under 

each plan alternative, which were then examined to determine the influence of the 

alternatives on viability across the Tongass (Shaw 1999).The panel assessments 

evaluated alternatives in terms of their ability to maintain the continued existence of 

well distributed, viable wildlife populations across the Tongass. A 100-year time 

period, or planning horizon, was used for the viability analysis, which was assumed 

to be the minimum period over which viability could be evaluated based on current 

scientific literature. This time period is the average rotation age under even-aged 

management and thus the time period over which old-growth characteristics would 

be affected (see the Wildlife section of the 1997 Forest Plan Revision Final EIS for 

further justification for this planning horizon and additional description of the panel 
3 Environment and Effects

Wildlife 3-262 Final EIS

assessments). It should be noted that within its first decade, the current Forest Plan 

has harvested much less timber than originally estimated in the 1997 Final EIS. 

Kittlitz’s Murrelet 

Due to the Kittlitz’s murrelet’s association with glacial habitat, this species occupies 

areas outside of where timber harvest and associated activities have occurred or 

are likely to occur. Major threats to this species are global climate change, which is 

correlated with a loss of suitable habitat (glacial melt) and reduction in prey 

availability due to warming sea temperatures. Human activity in the marine 

environment, particularly vessel traffic and fishing operations, are additional threats 

to this species. There is no indication that any Forest Service management activity 

is affecting the Kittlitz's murrelet (USDA Forest Service 2004h). Consequently, 

implementing any of the alternatives will not directly or indirectly affect the Kittlitz’s 

murrelet. 

Queen Charlotte (Northern) Goshawk 

Iverson et al. (1996) concluded that landscapes that maintained a forest age 

structure consistent with a 300-year ecological rotation would provide a high 

likelihood of sustaining goshawks. This composition would generally consist of onethird each of 0- to 100-year old stands, 100- to 200-year old stands, and 200-year 

old or older stands, categories with increasing value to goshawks. Additionally, 

harvest under a 300-year ecological rotation permits a maximum of 3.3 percent of 

the 1954 old growth to be harvested per decade in order to maintain a forest age 

structure favorable to goshawks. The 1997 Forest Plan Revision Final EIS 

compared alternatives in terms of their ability to support viable populations of 

goshawks over the long-term, by evaluating the number of VCUs where harvest 

levels met these criteria. This was based on the notion that the average size of a 

VCU approximates the size of a goshawk territory and that they are old-growth 

obligates, though recent research has shown that goshawks range wider and use a 

greater variety of habitats than once thought (Boyce et al. 2006, Reynolds et al. 

2006). As a measure of the ability of each alternative to support well distributed 

viable goshawk populations, this discussion takes a more conservative approach by 

focusing on impacts to high value goshawk nesting and foraging habitat (SD5N, 

SD5S, and SD67 stands located below 800 feet in elevation) but on a forest-wide 

basis, and discusses trends in areas with the greatest risk of not supporting 

goshawks due to the high levels of past disturbance. 

Protection of high value goshawk habitat would be greatest under Alternative 1 

(24,000 acres proposed for harvest), followed by Alternatives 2 (48,000 acres), 3 

(68,000 acres), 6 (97,000 acres), 5 (102,000 acres), 4 (145,000 acres), and 7 

(191,000 acres). Table 3.10-6 summarizes the percentage of high-volume POG and 

large-tree POG that is suitable for harvest under each alternative. These 

percentages represent the maximum potentially harvested over 100+ years of Plan 

implementation. The extent to which harvest impacts the ability of an area to 

support goshawks is dependent on the amount of suitable habitat remaining in the 

resulting landscape. That is, areas that originally had a substantial amount highvolume POG before timber harvest began and where much of that amount remains 

(e.g., Admiralty Island and Central Coastal Range biogeographic provinces) have a 

higher likelihood of supporting healthy goshawk populations even with additional 

harvest. Table 3.9-15 in the Biodiversity section displays the original acres of highvolume POG and the minimum percentage remaining after 100+ years of Plan 

implementation by biogeographic province. 

Candidate 

Species 

Forest Service 

Sensitive Species 
 Environment and Effects 3 

Final EIS 3-263 Wildlife 

Table 3.10-6 

Maximum Percentage of Existing High-Volume (SD5N, SD5S, and SD67) and 

Large-Tree (SD67) Productive Old-Growth Proposed for Harvest by Elevation 

Category and Alternative after 100+ years 

Alternative Elevation Category 1 2 3 4 5 6 7 

High-Volume POG 

< 800 feet 2.0% 4.0% 5.6% 11.9% 8.3% 7.9% 15.6% 

> 800 feet 2.0% 6.1% 8.5% 16.8% 12.0% 11.6% 19.3% 

Total 2.0% 4.8% 6.7% 13.8% 9.8% 9.3% 17.1% 

 

Large-Tree POG 

< 800 feet 2.9% 5.1% 7.0% 12.8% 9.5% 9.0% 17.0% 

> 800 feet 3.0% 8.5% 10.8% 19.8% 14.6% 13.9% 22.6% 

Total 2.9% 6.1% 8.1% 14.8% 11.0% 10.4% 18.6% 

Biogeographic provinces with greatest potential reduction in high value goshawk 

habitat include North Central Prince of Wales, Kupreanof/Mitkof, Etolin and Vicinity, 

and Revilla Island/Cleveland Peninsula. Highest harvest in these provinces would 

occur under Alternative 7. However, it is important to note that under Alternatives 1, 

2, 3, 4, 5, and 6 this loss is limited to old growth within the matrix and that the large 

and “very large” OGRs established under the Forest Plan were intended to 

compensate for timber management activities in the most developed areas. In the 

Prince of Wales Island area, for example, these include the Sarkar/Honker 

Divide/Karta Wilderness reserve that totals over 200,000 acres, the 200,000-acre 

reserve on South Prince of Wales, and a 56,000-acre reserve at Mt. Calder/Mt. 

Holbrook on Kosciusko Island. 

Alternative 5 (No Action) also incorporates a set of standards and guidelines that 

were intended to address aspects of goshawk habitat such as connectivity and 

stand structure in highly developed areas. These include the goshawk foraging 

habitat standards and guidelines, which require that timber harvest units must meet 

certain minimum criteria designed to maintain forest stand structure characteristics 

thought to be beneficial to goshawks in VCUs on Prince of Wales Island where more 

than 33 percent of the POG has been converted to young-growth, and the goshawk 

nest standard and guideline. Additional protection of habitat elements important to 

goshawks is provided by marten habitat standards and guidelines (see description 

under marten). Both sets of guidelines only apply to provinces where harvest has 

been relatively extensive. The retention of additional forest structure in harvest units 

was thought to result in improved foraging habitat for goshawks and facilitate 

dispersal among OGRs. However, recent science supports retaining clumps of 

legacy trees rather than a uniform distribution of legacy trees (see Appendix D and 

Northern Goshawks on the Tongass National Forest, presented at the Tongass 

Conservation Strategy Review Workshop 2006). That is, even spacing of reserve 

trees may, in effect, create a thinned stand that over time grows into a forest with 

understory shrubs and trees filling in spaces under the forest canopy, inhibiting 

goshawk maneuverability for foraging within the stand. 

Based on the 1997 panel assessment ratings (Iverson 1997), Alternative 5 (rated as 

its precursor, Alternative 11 in the 1997 Forest Plan EIS) was rated as having a high 

likelihood of sustaining viable, well-distributed goshawk populations during the 100-

year planning horizon and unlikely to result in a loss of viability or a declining trend 

that would require additional protection (see Appendix D). In addition, the panel 

concluded that there was no possibility of extirpation from the Tongass and virtually 
3 Environment and Effects

Wildlife 3-264 Final EIS

no possibility the goshawk would exist only within isolated refugia populations under 

Alternative 5. It is important to recognize that the panel assessments were 

conducted prior to the development of the Goshawk and Marten standards and 

guidelines (discussed above). In addition, recent research suggests that goshawks 

may be more adaptable to managed forest conditions than once thought, though 

they rely on prey that are closely associated with old growth. Thus, the 1997 panel 

ratings, which considered the goshawk an old-growth obligate, may provide a 

conservative assessment of impacts to goshawks. 

Alternatives 1, 2, 3, and 6 maintain the reserve system (slightly to substantially 

expanded over Alternative 5) and the various buffer standards and guidelines, but 

propose a new Forest-wide Legacy Forest Structure standard and guideline, in 

place of the existing Goshawk Foraging Habitat and Marten Habitat standards and 

guidelines. The Legacy Forest Structure standard and guideline is designed to 

protect forest legacy components in areas that are already highly developed, as well 

as areas that will experience increased harvest levels over the life of the Forest 

Plan. Thus, the Legacy Forest Structure standard and guideline is not limited to 

certain biogeographic provinces and, therefore, covers more provinces than the 

Goshawk standard and guideline (see Appendix D for a detailed analysis and 

comparison of the Legacy and Goshawk standards and guidelines). Because 

Alternative 6 would protect slightly more POG and a higher percentage of larger tree 

POG types within reserves, than Alternative 5 (Tables 3.10-5 and 3.10-6) and 

incorporates the Legacy standard and guideline, it is expected that long-term effects 

on goshawks would be similar to or slightly less than under Alternative 5. Because 

Alternatives 1, 2, and 3 would all result in lower harvests than Alternatives 5 and 6, it 

is expected that they would result in a very high likelihood of sustaining viable, welldistributed populations over the long term (based on their old-growth harvest levels, 

including larger POG types – see Table 3.10-6). 

The reduction of the OGR system, in combination with the absence of speciesspecific or Forest-wide forest legacy retention, under Alternatives 4 and 7, 

respectively, would increase risk to goshawk populations. However, Alternative 4 

maintains a relatively extensive reserve system in four of the most heavily 

developed biogeographic provinces, including the above mentioned “very large” 

reserves in the Prince of Wales Island complex. The distribution of these reserves 

is such that nearly all matrix habitats outside of these reserves and other protected 

areas are within the dispersal distance of goshawks, thus increasing the likelihood 

of re-colonization of landscapes that may be at risk of not supporting goshawks 

(USDA Forest Service 1997a). However, by significantly reducing reserves 

elsewhere and not providing legacy tree requirements, Alternative 4 could reduce 

the dispersal and re-colonization capability of goshawks in areas where timber 

would be harvested in the future. Even so, Alternative 4 would still only result in a 

harvest level of less than 12 percent of the existing low elevation, high-volume POG 

(considered to be the highest value goshawk habitat) after 100 years (Table 3.10-6). 

Based on the 1997 expert panel assessments (Iverson 1996a), Alternative 4 

(equivalent to Alternative 6 in the 1997 FEIS) would be rated as having a moderately 

high likelihood of maintaining viable, well-distributed goshawk populations; the 

assessments also noted no possibility of extirpation from the Tongass, but a low 

likelihood that the alternative would result in the goshawk existing only in isolated 

refugia (Appendix D). 

The likelihood of effects on goshawk distribution would be greater under Alternative 

7, which eliminates much of the coarse-filter component of the Conservation 

Strategy (the Old-Growth Habitat LUD), as well as the species-specific Goshawk 

Foraging and Marten Habitat standards and guidelines. Full implementation of 

Alternative 7, would result in harvesting approximately 16 percent of the existing low 

elevation, high-volume POG after 100 years (Table 3.10-6). Based on the 1997 

expert panel assessments (Iverson 1997a) Alternative 7 (equivalent to Alternative 2 
 Environment and Effects 3 

Final EIS 3-265 Wildlife 

in the 1997 FEIS) would be rated as having a moderate likelihood of maintaining 

viable, well-distributed goshawk populations; the assessments also noted there 

would be a very low possibility of extirpation from the Tongass and a low likelihood 

that the alternative would result in the goshawk existing only in isolated refugia. 

Osprey 

Limiting factors for osprey populations are unknown, but availability of nest sites and 

foraging areas do not appear to be limiting on the Tongass and Forest-wide 

standards and guidelines were developed to provide for protection of nest sites as 

they are identified. In addition to protection around known nest sites, standards and 

guidelines also include a 1,000-foot beach and estuary buffer that provides suitable 

dominant or co-dominant trees along shorelines, essentially protecting all suitable or 

potentially suitable nesting, perching, and foraging habitat for ospreys. Although in 

other parts of their range ospreys do nest on freshwater lakes, where no such buffer 

applies, none have been documented in Southeast Alaska. Consequently, no 

impacts to osprey or osprey habitats are anticipated from Alternatives 1, 2, 3, 4, 5, 

and 6, which uphold the current Forest Plan standards and guidelines. Ospreys 

would be at increased risk of effects associated with timber management activities 

under Alternative 7, which proposes to reduce the beach fringe buffer to 500 feet; 

however, this distance is likely to protect most nesting habitat. 

Peale’s Peregrine Falcon 

Forest-wide standards and guidelines were developed to provide for protection of 

Peale’s peregrine falcon habitat. Any project level planning requires the evaluation 

of potential impacts to known falcon nests within 2 miles of a proposed project in an 

effort to plan project activities to avoid adverse impacts to the falcons and their 

habitats. These standards and guidelines would be maintained under all the action 

alternatives, therefore no effects are anticipated for peregrine falcons. 

Trumpeter Swan 

The largest concentration of nesting trumpeter swans on the Forest is at Yakutat, in 

the Yakutat Forelands Biogeographic Province (primarily Roadless Area 339). 

Approximately 96 percent of this province is already within legislated LUD II areas or 

other natural setting LUDs; none of the alternatives propose changes to these 

designations. The entire nesting habitat is classified as wetlands and/or riparian 

habitat. Forest-wide standards and guidelines for wetlands and riparian 

management apply to these areas, which were specifically developed for trumpeter 

swan habitats on the Forest. 

None of the alternatives would increase the likelihood of any adverse effects on 

trumpeter swan populations, nesting habitat, or wintering habitat, or would result in a 

loss of species viability. Therefore, no effects are anticipated for trumpeter swans. 

Sitka Black-tailed Deer 

This analysis of effects to black-tailed deer uses the deer winter HSI model 

described in the Affected Environment section to evaluate impacts to winter range 

habitat capability potentially resulting from each of the alternatives. The Forest Plan 

model uses four discrete variables (four levels of snow depth, three elevation zones, 

four aspects, and seven vegetation/successional stages) to predict a habitat 

suitability index. For this application, a cross-walk was developed to reclassify the 

new Forest-wide vegetation model (the SDM) into the model vegetation categories 

(See Appendix B for additional details about the deer model analysis). This results 

Management 

Indicator Species 
3 Environment and Effects

Wildlife 3-266 Final EIS

in an overall reduction in average HSI values because fewer stands would be 

classified as high and medium volume strata and more stands would be classified 

as low volume strata compared to the old volume strata mapping used in the 1997 

Forest Plan Revision Final EIS. However, this makes no difference to the analysis 

because relative values were used to compare alternatives. For reference, high 

volume stands include SDM vegetation categories SD5N, SD5S, and SD67; 

medium volume stands include SD4N, SD4S, and SD5H; and low volume stands 

include SD4H (see the Biodiversity section for further discussion of the SDM 

categories). 

The deer model is used here to compare the alternatives in a relative sense. 

However, it should be noted that, for several reasons, the model is believed to 

overestimate the effects of harvest. Please refer to the discussion of these factors 

under the Sitka Black-tailed Deer subsection of the Affected Environment. 

For the purpose of this analysis, the following assumptions were made: 

• HSI values were standardized to range from 0 to 1.0, by dividing all values by 

1.3, because outputs from such models represent a range from 0 to 100 percent 

habitat suitability, with higher values indicating higher habitat capability. 

• After full implementation of the Forest Plan (100+ years), all suitable acres are 

harvested; calculations take the model implementation reduction factor (MIRF) 

into account which is the reduction between planned and actual timber 

volume/acres due to the presence of karst, unstable soils, and other issues that 

preclude harvest during timber sale layout. These numbers are based on 

known differences between the acres of forest land mapped as suitable for 

timber management and the number actually harvested on the Tongass (see 

the Timber section and the project record for additional discussion). 

• To estimate 1954 habitat capability, previously harvested stands were assumed 

to be medium (SD4N, SD4S, SD5H categories) and high (SD5N, SD5S, and 

SD67 categories) volume forest; stand with a date of origin prior to 1954 were 

not changed. 

• To project future habitat capability, 25 percent of the current young-growth 

stands would be in the stand initiation phase (25 years old or younger) and 75 

percent would be in the stem exclusion phase (26 to 150 years old) by 2105; 

previously harvested stands that are unsuitable for harvest would be in the stem 

exclusion phase. 

• This analysis evaluated relative changes in habitat capability; actual habitat 

capability may be more or less than model predictions. 

• Lands under non-federal ownership have an assumed habitat capability of zero 

(see discussion below). 

After the initial years following logging, there is a rapid increase in deer forage 

production due to the large amount of light penetration created by open stand 

conditions. However, this nutrition is of lower quality than the same forage types 

found in old growth. After the initial 20 to 30 years, there is a 100- to150-year period 

in which the vigorously growing hemlock and spruce shade out the understory 

forage. Person et al. (2001) described this situation as “succession debt” because 

the full impacts to deer may not immediately be expressed but will be sustained for 

many decades after timber harvesting. Under even-aged and two-aged harvest 

systems, the amount of habitat capability reduction over the 100-year analysis 

period is substantial and is directly related to the amount of timber harvest. While 

the short-term (20- to 30-year) effect is also related to the amount of timber harvest, 

the effect of timber harvest will vary with the average seasonal snow accumulation 
 Environment and Effects 3 

Final EIS 3-267 Wildlife 

(since higher accumulations reduce forage availability). Under uneven-aged 

systems (such as group selection), available forage within any given area would be 

maintained for a longer time, as would adjacent thermal cover. Assumptions related 

to future forest condition are intended to model future deer habitat capabilties after 

harvest. For this analysis, the effects of harvest are modeled over the long term and 

all harvest is assumed to consist of regeneration methods (e.g., clearcut harvest). 

Regeneration methods and rotation length depend on site-specific analysis done at 

the project level. 

Effects on winter range habitat capability by WAA, as indicated by changes in HSI 

scores, are displayed in Table 3.10-7. This does not include any State, City, or 

private land. Many of these lands have been, or will be, developed for intensive 

forestry and are expected to have lower habitat capability over time. WAAs are land 

divisions used by the ADF&G for deer inventories and planning. Table 3.10-7 

illustrates the cumulative effect of timber harvest on estimated deer habitat 

capability, from the beginning of large-scale timber harvest on NFS lands in 1954 to 

the present and to year 2105 and includes the 10-year (1996 to 2005) average 

harvest intensity, measured in hunter-days, by WAA. 

In addition, the percentage of high value habitats available for timber harvest was 

also calculated by WAA to quantify impacts to high quality deer winter range (Table 

3.10-8). To take into account impacts to deer across the Tongass inhabiting areas 

that vary naturally in their habitat quality, high quality habitat was defined as the 

quartile of the land base with the highest HSI scores within in each WAA. Lands not 

available for timber harvest include areas within LUDs that do not permit timber 

harvest and areas that are protected by Forest-wide standards and guidelines, such 

as Riparian or Beach and Estuary Fringe. 

Forest-wide, the alternatives are estimated to retain from 77 to 86 percent of the 

original winter range habitat capability in 100+ years (Table 3.10-7). At the WAA 

level, Alternatives 4 and 7 show the greatest reductions in deer habitat capability 

because they propose the greatest amounts of harvest. Most of the largest 

reductions in habitat quality occur in WAAs that have already experienced a high 

amount of past timber harvest (e.g., Prince of Wales and Kuiu Islands); however, 

there are several WAAs (e.g., 2008, 2305, 2927, 3524) where currently over 95 

percent of the 1954 deer habitat capability remains, that would receive substantial 

reductions under some of the alternatives. 

On average, the highest percentage of high quality winter range habitat subject to 

timber harvest is proposed under Alternative 7 (16 percent per WAA), followed by 

Alternatives 4 (13 percent), 5 (9 percent), and 6 (8 percent), 3 (6 percent), 2 (4 

percent), and 1 (1 percent; Table 3.10-8). Forest-wide, however, the alternatives 

would harvest 1 to 5 percent of the existing high quality winter range (Table 3.10-8). 

Table 3.10-8 also displays the range of HSI scores in each WAA. At the WAA level, 

there are some areas where 40 to 55 percent of the high value deer winter range 

could be harvested under Alternatives 4, 5, 6, and 7. This magnitude of effect would 

be primarily concentrated on Prince of Wales Island, the Cleveland Peninsula and 

nearly islands, Baranof Island, and Mitkof Island. 

Over the long-term, reductions in habitat capability and harvest of high value deer 

winter range could reduce carrying capacity, or the numbers of deer in areas 

capable of supporting them given the available resources, such that deer 

populations would decrease in areas that could no longer support the current 

population. This would primarily be a concern during severe winters, when 

resources are already limited. Ultimately reductions in the deer population resulting 

from decreased habitat capability could reduce the number of deer available to 

wolves and hunters. At some low level, wolf predation could actually limit deer 

population recovery (the “predotor pit” hypothesis (Boutin 1992), though there is no 
3 Environment and Effects

Wildlife 3-268 Final EIS

threshold population level or threshold loss of winter range that has been defined for 

Southeast Alaska with which to predict these potential population responses. 

However, it is also important to note that forest management on the Tongass has 

produced more forage than assumed by the model, through the management of 

second-growth stands. The purpose of young-growth management is to accelerate 

the stem exclusion phase of forest development, which occurs roughly 15 to 25 

years following a major disturbance when the growing space is fully occupied and 

tree crowns are crowded. Deer forage availability is at its lowest during this time 

due to the lack of light penetrating the understory, which causes lower tree limbs 

and understory plants to die and less vigorous trees to be shaded out. Activities 

such as thinning, girdling, or pruning, which open the forest canopy, result in 

increased understory biomass thus increasing the amount of forage available to 

deer. Since 1970, the Tongass has treated approximately 168,000 acres of secondgrowth, mostly by precommercial thinning; roughly 16.000 acres were treated 

specifically for wildlife and riparian objectives (Young-growth Management, 

presented at the Tongass Conservation Strategy Review Workshop 2006). 

However, it is important to note that there are still many uncertainties related to 

appropriate young-growth treatment designs, specific beneficial effects of such 

treatments, and implications for deer. In addition, some studies have shown the 

opposite results. Farmer (2006) found that the risk of death to fawns was positively 

correlated with pre-commercial thinning. The Tongass, in collaboration with the 

Pacific Northwest Research Station, is conducting the Tongass-Wide Young Growth 

Study (TWYGS) to address many of these uncertainties. TWYGS is the most 

extensive and intensive study of young-growth ever conducted in Southeast Alaska 

and is designed to evaluate the potential benefits of treating pre-commercial stands 

to increase wildlife habitat and wood production. Initial results indicate that the 

potential for restoring diverse and abundant understory plant communities through 

the active management of young stands is promising (Young-growth Management, 

presented at the Tongass Conservation Strategy Review Workshop 2006). 

Mountain Goat and Black Bear 

These species occupy different niches but both are associated with old-growth 

forest and are susceptible to over-hunting if road access is increased or improved, 

though most roads are located a long distance (both vertically and horizontally) from 

goat habitat. The amount of road access, quantified in terms of the amount of road 

construction and reconstruction proposed under each alternative, is assumed to be 

inversely related to the amount of POG conserved after full implementation of the 

Forest Plan (100+ years) and to be representative of the potential for over-hunting. 

This provides a rough index for assessing risk to these species, since roads can be 

designed (or closed) at the project level to avoid key habitats. Risk of over-harvest 

due to human access along roads is mitigated to some extent by Transportation 

Forest-wide standards and guidelines that require travel access road objectives to 

be developed for all roads, and Mountain Goat and Black Bear Forest-wide 

standards and guidelines directed toward assessing and minimizing disturbance and 

access to meet management objectives. A maximum of 3,874 miles of road 

construction and 2,100 miles of road reconstruction would be implemented after 

100+ years of Forest Plan implementation under Alternative 5 (No Action). 

Alternative 6 (3,744 miles), Alternative 3 (2,799 miles), Alternative 2 (2,079 miles), 

and Alternative 1(774 miles) provide decreasing risk to these species associated 

with new road construction; all of these alternatives maintain or decrease the 

currently estimated level of road reconstruction (ranging from 2,046 miles under 

Alternative 6 to 925 miles under Alternative 1). Only Alternatives 4 and 7 would 

increase the proposed amount of road construction (4,890 miles and 5,825 miles, 

respectively) and reconstruction (2,182 miles and 2,371 miles, respectively). Thus 
 Environment and Effects 3 

Final EIS 3-269 Wildlife 

Table 3.10-7 

Relative Changes in Deer Habitat Capability by Wildlife Analysis Area (WAA) by Alternative

Percent Deer Habitat Capability in 100+ Years3/

Alternative 

WAA1/ 

Average 

Deer 

Harvest 

(Hunting)-/ 

Percent of 

1954 

Habitat 

Capability 

in 2006 1 2 3 4 5 6 7 

Average 

Hunting 

Pressure 

(Hunter 

Days)2/ Vicinity 

101 112 94 94 89 87 86 86 86 85 715 Gravina Is. 

202 11 0 0 0 0 0 0 0 0 60 Annette Is. 

303 3 98 98 98 98 98 98 98 98 22 Duke Is. 

404 12 100 100 100 100 100 100 100 100 70 Eastern Revilla Is. 

405 27 83 80 74 73 73 74 73 71 131 Thorne Arm (Revilla Is.) 

406 88 77 71 66 65 60 65 64 57 600 Carrol Inlet (Revilla Is.) 

407 27 89 83 75 74 69 73 73 67 296 George Inlet (Revilla Is.) 

408 21 96 96 95 95 94 94 94 94 317 Ketchikan 

509 23 93 92 88 87 81 86 87 80 214 Naha Area (Revilla Is.) 

510 48 68 63 59 58 53 57 58 50 277 

Neets Bay Area (Revilla 

Is.) 

511 0 100 100 100 100 100 100 100 100 0 Northern Revilla Is. 

612 8 99 99 99 96 73 83 83 70 88 Eastern Cleveland Pen. 

613 22 95 95 95 95 72 95 95 66 189 

Helm Bay (Cleveland 

Pen.) 

614 6 98 98 98 98 72 98 98 70 38 

Meyers Chuck 

(Cleveland Pen.) 

715 3 99 99 99 99 99 99 99 99 40 Redoubt Lake, Neckar Is. 

716 0 100 99 100 100 100 100 100 100 6 

Unuk Drainage 

(Cleveland Pen.) 

717 0 100 100 100 100 100 100 100 100 0 

Lower Chickamin (Misty 

Fiords) 

718 0 100 99 100 100 100 100 100 100 0 

Upper Chickamin (Misty 

Fiords) 

719 0 100 100 100 100 100 100 100 100 33 

Rudyerd Bay (Misty 

Fiords) 

820 5 100 100 100 100 100 100 100 100 16 

Wilson/Blossom 

Drainages (Misty Fiords) 

821 0 100 100 100 100 100 100 100 100 0 

Smeaton Bay ( Misty 

Fiords) 

822 1 100 100 100 100 100 100 100 100 19 

Boca De Quadra 

Drainages (Misty Fiords) 

823 6 100 100 100 100 100 100 100 100 15 

Pearse Canal (Misty 

Fiords) 

824 0 100 100 100 100 100 100 100 100 8 

Peabody Mtns (Misty 

Fiords) 

825 4 100 100 100 100 100 100 100 100 4 

Upper Portland Canal 

(Misty Fiords) 

826 0 100 100 88 87 73 86 86 70 0 Hyder (Misty Fiords) 

901 37 97 89 82 79 75 80 78 71 85 Suemez Is. 

902 27 100 100 100 99 100 99 99 99 62 Outside Is. 

1003 60 66 54 53 53 49 51 52 47 175 Heceta Is. 

1105 11 99 99 99 99 96 97 97 94 71 Dall Is. 

1106 28 99 99 99 99 99 99 99 99 52 Long Is. 

1107 47 98 97 97 97 88 90 90 86 192 

Hydaburg, Hetta Inlet, 

Sukkwan Is. 

1108 5 99 99 99 99 99 99 99 99 34 

Southwestern Prince Of 

Wales Is. 

1209 4 100 100 100 98 94 98 98 93 9 

Southeastern Prince Of 

Wales Is. 

1210 9 100 100 99 89 82 88 88 79 42 Moira Sound (POW) 

1211 16 91 85 76 76 67 74 75 62 77 

Kitkun, South Arm 

Cholmondeley (POW) 

1212 19 100 100 100 92 91 92 92 90 40 Clover Mtn. (POW) 

1213 7 98 98 89 89 80 87 88 74 40 

West Arm Cholmondeley 

(POW) 

1214 95 79 70 66 65 62 64 64 53 488 

Skowl Arm, Polk Inlet 

(POW) 
3 Environment and Effects

Wildlife 3-270 Final EIS

Table 3.10-7 (continued) 

Relative Changes in Deer Habitat Capability by Wildlife Analysis Area (WAA) by Alternative

Percent Deer Habitat Capability in 100+ Years3/

Alternative 

WAA1/ 

Average 

Deer 

Harvest 

(Hunting)-/ 

Percent of 

1954 

Habitat 

Capability 

in 2006 1 2 3 4 5 6 7 

Average 

Hunting 

Pressure 

(Hunter 

Days)2/ Vicinity 

1315 241 55 50 49 47 44 47 47 41 1289 

Kasaan Peninsula, 

Thorne Bay (POW) 

1316 22 100 100 100 100 100 100 100 100 100 Karta Bay (POW) 

1317 88 54 51 49 47 45 47 47 38 411 

Twelve Mile Arm, Harris 

River (POW) 

1318 223 92 85 78 76 66 72 75 64 917 

Craig, Klawock Areas 

(POW) 

1319 227 74 69 67 66 59 64 64 54 973 

Thorne River Drainage 

(POW) 

1323 42 97 94 91 91 88 90 90 84 124 

Western Prince Of Wales 

Is. 

1332 43 85 83 82 78 75 77 78 70 119 

Trocadero Bay, Waterfall 

Area (POW) 

1420 186 52 43 42 40 39 40 40 36 857 

Coffman Cove, Luck 

Lake, Ratz Harbor 

(POW) 

1421 92 74 66 64 64 64 63 63 55 377 

Sweetwater Lake, 

Logjam Creek (POW) 

1422 289 60 50 48 47 46 47 47 43 1494 

Staney Creek, Naukati, 

Sarkar (POW) 

1524 0 100 100 100 100 100 100 100 100 1 Warren Is. 

1525 14 51 48 47 46 46 46 46 43 64 Southern Kosciusko Is. 

1526 13 91 91 91 91 88 89 89 87 58 

Holbrook Mt., Northern 

Kosciusko Is. 

1527 46 73 65 61 60 60 59 59 55 128 

Prince Of Wales El 

Capitan Area 

1528 52 77 75 74 73 72 72 71 63 171 Salmon Bay (POW) 

1529 215 73 63 61 60 56 59 59 50 797 

Mt. Calder, Red Bay, 

Port Protection (POW) 

1530 140 62 58 57 55 54 55 55 50 798 

Exchange Cove, Whale 

Passage (POW) 

1531 22 61 54 52 52 49 50 52 46 98 

Tuxekan, Marble, Sea 

Otter Sound (POW) 

1601 0 100 100 100 100 75 80 82 71 0 Fanshaw-Farragut Area 

1602 3 99 99 99 99 98 99 99 98 25 Farragut River Drainage 

1603 0 91 91 91 84 80 82 83 78 4 Thomas Bay 

1604 0 100 100 100 100 100 100 100 100 0 Baird Glacier 

1605 39 76 76 71 64 57 63 63 56 291 

Muddy River, Patterson 

Glacier 

1706 6 100 100 100 100 100 100 100 100 32 Horn Cliffs, Le Conte Bay 

1707 6 100 100 100 100 100 100 100 100 15 North Arm Of The Stikine 

1708 0 100 100 100 100 100 100 100 100 28 Stikine River Drainage 

1809 0 100 100 100 100 100 100 100 100 0 Cone Mtn. 

1810 2 100 100 100 77 62 75 75 62 8 

Virginia Lake, Garnet 

Mtn. 

1811 0 99 99 99 93 87 92 92 84 9 Aaron Creek Drainage 

1812 0 97 96 96 93 93 93 93 91 0 

Marten Lake, Harding 

River Drainage 

1813 0 68 68 65 63 60 62 63 59 0 

Bradfield River 

Drainages 

1814 0 98 98 98 92 88 92 92 85 3 

Eagle River, S. Shore 

Bradfield Canal 

1815 5 92 92 92 89 87 88 89 85 12 Anan Creek 

1816 2 89 88 85 78 75 77 77 72 15 Seward Passage 

1817 9 100 100 100 99 89 89 88 68 59 Vixen Inlet, Union Bay 

1901 36 91 87 80 78 70 77 77 64 131 Northern Etolin Is. 

1902 7 79 72 72 68 64 68 68 58 16 Deer Is. 

1903 62 86 80 73 72 63 71 71 60 821 Wrangell Is. 

1904 18 59 58 57 52 48 50 51 43 37 

Woronkofski And Stikine 

Mouth Is. 

1905 350 77 72 67 67 59 66 65 57 1249 Zarembo Is. 
 Environment and Effects 3 

Final EIS 3-271 Wildlife 

Table 3.10-7 (continued) 

Relative Changes in Deer Habitat Capability by Wildlife Analysis Area (WAA) by Alternative

Percent Deer Habitat Capability in 100+ Years3/

Alternative 

WAA1/ 

Average 

Deer 

Harvest 

(Hunting)-/ 

Percent of 

1954 

Habitat 

Capability 

in 2006 1 2 3 4 5 6 7 

Average 

Hunting 

Pressure 

(Hunter 

Days)2/ Vicinity 

1906 15 59 55 55 55 55 55 55 53 30 Kashevarof Islands 

1910 18 96 96 96 94 93 94 94 92 125 Southern Etolin Is. 

2007 117 79 74 68 67 62 66 65 58 1155 Mitkof Is. 

2008 5 99 99 99 80 77 78 78 72 14 Woewodski Is. 

2202 1 90 90 90 90 82 86 86 80 53 Sullivan River And Island 

2203 0 92 92 92 92 90 91 91 90 0 Endicott River Drainage 

2304 2 94 94 94 94 75 77 79 73 22 St. James Bay 

2305 0 97 97 93 92 80 92 91 78 17 Southern Chilkat Range 

2306 0 84 84 74 74 66 73 73 63 25 Excursion Inlet 

2408 0 100 100 99 91 86 90 90 85 0 Eldred Rock-Pt. St. Mary 

2409 0 99 98 97 91 85 91 91 83 5 Berners Bay 

2410 0 100 100 100 100 100 100 100 100 18 Berners River Drainage 

2411 0 100 100 100 100 100 100 100 100 0 Lace River Drainage 

2412 0 100 100 100 100 100 100 100 100 0 Antler River Drainage 

2413 0 100 100 100 100 100 100 100 100 0 Gilkey River Drainage 

2514 4 100 100 99 94 86 83 94 84 29 Cowee, Davies Creeks 

2515 8 100 100 100 100 100 100 100 100 87 

Eagle River-Mendenhall 

River Area 

2516 0 100 100 100 100 100 100 100 100 0 Juneau Ice Field 

2517 6 100 100 100 100 92 94 95 88 47 Juneau And Lower Taku 

2518 0 100 100 100 100 100 100 100 100 0 Taku River 

2519 0 100 100 100 100 93 96 95 92 0 

Turner Lake, Southern 

Shore Taku Inlet 

2620 17 100 100 100 100 100 100 100 100 93 Lincoln Is. 

2621 42 100 100 100 100 100 100 100 100 272 Shelter Is. 

2722 275 100 100 100 100 88 100 100 100 2378 Douglas Is. 

2823 4 100 100 100 100 92 95 95 89 7 

Snettisham Inlet, Speel, 

Whiting Rivers 

2824 0 100 100 100 100 100 100 100 100 5 Holkham Bay-Tracy Arm 

2825 0 100 100 100 100 100 100 100 100 9 Endicott Arm 

2926 2 100 100 100 98 87 88 89 85 22 

Windham Bay, Chuck 

River, Hobart Bay 

2927 2 100 100 100 99 79 87 88 76 14 

Port Houghton-Cape 

Fanshaw 

3001 410 81 81 79 79 72 78 79 71 937 

Nakwasina, Neva Strait 

Area (NW Baranof) 

3002 328 69 69 68 68 67 68 68 67 1111 Sitka Road System 

3003 143 85 84 83 80 73 79 80 72 459 Silver Bay, Deep Inlet 

3104 182 73 73 69 68 65 68 68 64 388 Northern Kruzof Is. 

3105 130 99 99 99 98 97 97 97 97 207 Southern Kruzof Is. 

3206 80 99 99 99 99 99 99 99 99 177 

Redoubt Lake, Neckar 

Islands 

3207 147 100 100 100 100 100 100 100 100 239 

Crawfish Inlets, Neckar 

Bay (Baranof Is.) 

3308 163 66 64 59 57 53 56 57 51 391 

Kook Lake, Sitkoh Bay, 

False Is. 

3309 72 99 99 99 99 93 94 94 92 114 

Northern Shore Hoonah 

Sound 

3310 158 93 93 93 93 93 93 93 93 327 

South Arm Hoonah 

Sound 

3311 124 97 97 97 97 88 89 91 86 202 Ushk Bay-Kakul Narrows 

3312 90 91 91 87 87 80 86 86 79 137 Duffield Penin., Bear Bay 

3313 134 65 64 57 56 50 52 53 48 226 

Rodman And Saook Bay 

Drainages 

3314 135 88 88 87 87 73 87 87 73 283 Fish Bay Drainages 

3315 112 83 82 75 75 71 74 74 69 173 

Catherine Island, Lake 

Eva, Hanus Bay 

3416 75 100 100 100 100 100 100 100 100 109 

Khaz Penin., Slocum 

Arm (Chichagof Is.) 

3417 157 100 100 100 100 100 100 100 100 361 West Coast Chichagof 

3418 65 100 100 100 100 100 100 100 100 116 Yakobi Is. 
3 Environment and Effects

Wildlife 3-272 Final EIS

Table 3.10-7 (continued) 

Relative Changes in Deer Habitat Capability by Wildlife Analysis Area (WAA) by Alternative

Percent Deer Habitat Capability in 100+ Years3/

Alternative 

WAA1/ 

Average 

Deer 

Harvest 

(Hunting)-/ 

Percent of 

1954 

Habitat 

Capability 

in 2006 1 2 3 4 5 6 7 

Average 

Hunting 

Pressure 

(Hunter 

Days)2/ Vicinity 

3419 54 100 100 100 100 100 100 100 100 130 

Upper Lisianski Inlet, 

Lisianski River 

(Chichagof Is.) 

3420 43 100 100 100 100 100 100 100 100 139 Idaho Inlet Drainages 

3421 51 100 100 100 100 100 100 100 100 132 

Port Althorp, Lower 

Lisianski, Inian Is. 

3523 153 81 76 74 74 72 73 73 63 440 

East Side Port Frederick, 

Game Creek (NE 

Chichagof) 

3524 94 100 100 86 85 79 83 84 78 354 Hoonah Area 

3525 171 78 71 67 67 62 65 66 58 443 

Freshwater Bay 

Drainages (NE 

Chichagof) 

3526 120 81 77 73 72 69 72 72 60 418 

North Shore Tenakee 

Inlet (NE Chichagof) 

3551 200 83 77 73 72 68 71 72 62 519 

Whitestone Harbor, 

False Bay Drainages (NE 

Chichagof) 

3627 71 76 70 67 65 62 64 65 61 187 

Corner Bay, Trap Bay 

(Chichagof Is.) 

3628 12 98 98 98 98 98 98 98 98 34 Kadashan (Chichagof Is.) 

3629 62 91 91 89 85 75 79 80 73 143 

Southern Shore Tenakee 

Inlet (Chichagof Is.) 

3630 17 99 99 99 99 87 91 94 86 47 

Upper Tenakee Inlet 

(Chichagof Is.) 

3731 84 92 92 91 91 86 90 91 83 178 

Kelp Bay-Takatz Bay 

(Baranof Is.) 

3732 20 100 100 100 100 100 100 100 100 39 

Warm Springs Coast 

(Baranof Is.) 

3733 143 100 100 100 100 100 100 100 100 188 

Whale Bay Drainages, 

Wilderness Coast 

(Baranof Is.) 

3734 75 100 100 100 100 100 100 100 100 117 Southern Baranof Is. 

3835 210 100 100 100 100 100 100 100 100 810 

Northern Mansfield 

Penin. 

3836 206 100 100 100 100 100 100 100 100 754 

Hawk Inlet, Young Bay 

Drainages (Admiralty Is.) 

3837 27 100 100 100 100 100 100 100 100 86 

Wheeler, Greens Creeks 

Drainages (Admiralty Is.) 

3938 112 100 100 100 100 100 100 100 100 287 

Gambier Bay Drainages 

(Admiralty Is.) 

3939 125 100 100 100 100 100 100 100 100 261 

Pybus Bay Drainages 

(Admiralty Is.) 

3940 79 92 92 92 92 92 92 92 92 160 

Pt. Gardner, Eliza Harbor 

(Admiralty Is.) 

4041 34 90 90 90 90 90 90 90 90 47 

Whitewater Bay, Wilson 

Cove (Admiralty Is.) 

4042 43 100 100 100 100 100 100 100 100 105 

Angoon Area (Admiralty 

Is.) 

4043 64 100 100 100 100 100 100 100 100 317 Central Admiralty Lakes 

4044 215 100 99 99 99 99 99 99 99 433 

Shee-Atika Drainages 

(Admiralty Is.) 

4054 40 100 100 100 100 100 100 100 100 75 Fishery, Thayer Creeks 

4055 67 96 96 96 96 96 96 96 96 162 

Hood Bay, Chaik Bay 

Drainages (Admiralty Is.) 

4145 82 100 100 100 100 100 100 100 100 243 

Tiedeman Is.-Mole 

Harbor Area (Admiralty 

Is.) 

4146 37 100 100 100 100 100 100 100 100 144 

Windfall Harbor, Swan 

Cove Drainages 

(Admiralty Is.) 

4147 61 100 100 100 100 100 100 100 100 273 

Upper Seymour Canal 

(Admiralty Is.) 
 Environment and Effects 3 

Final EIS 3-273 Wildlife 

Table 3.10-7 (continued) 

Relative Changes in Deer Habitat Capability by Wildlife Analysis Area (WAA) by Alternative

Percent Deer Habitat Capability in 100+ Years3/

Alternative 

WAA1/ 

Average 

Deer 

Harvest 

(Hunting)-/ 

Percent of 

1954 

Habitat 

Capability 

in 2006 1 2 3 4 5 6 7 

Average 

Hunting 

Pressure 

(Hunter 

Days)2/ Vicinity 

4148 53 89 89 89 89 89 89 89 89 156 

West Side Glass Penin. 

(Admiralty Is.) 

4149 59 100 100 100 100 100 100 100 100 155 

East Side Glass Penin. 

(Admiralty Is.) 

4150 112 100 100 100 100 100 100 100 100 453 

Grand Is., Oliver Inlet, 

Stink Creek (Admiralty 

Is.) 

4222 62 97 96 95 94 86 94 94 86 142 

Pt. Adolphus, Mud Bay 

Area (Baranof Is.) 

4252 101 92 92 78 78 70 77 76 69 221 

Humpback, Gallagher 

Creeks (Baranof Is.) 

4253 74 85 82 78 77 71 76 76 69 139 

Neka Bay Drainages 

(Baranof Is.) 

4256 54 100 100 100 100 100 100 100 100 184 

Lemesurier, Pleasant 

Islands 

4302 0 80 80 80 80 66 66 73 63 0 

Lower Chilkat, Kelsall 

River Valleys 

4304 0 100 100 100 100 100 100 100 100 0 Chilkat Penin. 

4407 0 100 100 100 100 100 100 100 100 0 West Side Taiya Inlet 

4408 0 100 100 100 100 100 100 100 100 0 

Katzehin River-Eldred 

Rock 

4503 0 100 95 96 96 97 97 97 97 0 

Yakutat Forelands E. Of 

Dangerous River 

4504 9 100 100 100 100 100 100 100 100 86 Yakutat Bay Islands 

4505 0 100 93 94 94 95 95 95 95 0 Russell Fjord Drainages 

4506 0 100 100 100 100 100 100 100 100 14 

Eastern Shore 

Disenchantment Bay 

4508 2 92 91 87 82 80 81 81 79 63 

Yakutat Forelands W. Of 

Dangerous River 

4607 0 100 98 98 98 98 98 98 99 0 Nunatak Bench 

5012 10 76 73 61 60 55 58 59 52 62 Northern Kuiu Is. 

5013 2 94 93 92 90 82 84 84 80 17 

Port Camden, Bay Of 

Pillars 

5014 5 96 96 96 96 70 75 75 64 20 

Eastern Kuiu Is., 

Conclusion Is. 

5015 1 100 100 100 100 100 100 100 100 1 Coronation Is. 

5016 2 98 98 98 98 98 98 98 98 2 Tebenkof Bay 

5017 2 98 98 98 98 89 98 98 86 10 Southern Kuiu Is. 

5018 3 93 92 90 84 79 81 81 78 26 Rocky Pass/Kuiu 

5130 6 98 96 96 90 83 86 87 81 51 Rocky Pass/Kupreanof 

5131 15 90 86 83 83 80 81 82 79 164 

Hamilton Creek, Big 

John Bay 

5132 18 73 71 68 67 64 65 67 62 265 Kake Area 

5133 27 98 97 97 96 82 84 85 80 153 West Duncan Canal 

5134 40 92 92 92 89 83 87 87 83 157 South Shore Kupreanof 

5135 5 98 94 90 90 89 89 89 85 31 North Shore Kupreanof 

5136 16 86 76 71 67 60 64 66 58 79 

Portage Bay, Nw 

Kupreanof 

5137 4 98 98 97 97 97 97 97 97 20 

Petersburg Creek 

(Kupreanof Is.) 

5138 74 88 79 70 69 64 68 68 59 327 

Southern Lindenberg 

Penin. (Kupreanof Is.) 

Total 88 86 84 83 79 81 82 77 1

 Includes only National Forest System lands 

2 Based on 1995 to 2005 ADF&G harvest summary reports 

3

 This analysis assumes: 1) maximum timber harvest levels over the 100+-year period, 2) timber harvest from 1954 to 1995 occurred in the 

high volume stratum (SD 5N, 5S, 67), 3) in 2105 25 percent of the second-growth would be in stand initiation (<25 years) and 75 percent 

would be in stem exclusion (26-100 years), 

4/ Estimates incorporate the model implementation reduction factor (MIRF), which is the reduction in the number of suitable acres actually 

harvested during plan implementation (see Timber section for further description). 
3 Environment and Effects

Wildlife 3-274 Final EIS

Table 3.10-8 

High Quality Deer Winter Range Suitable for Harvest by Alternative 

Percent of High Value Deer Winter 

Range Suitable for Harvest2/, 3/ 

Range of HSI 

Scores1/ Alternative 

WAA Vicinity Low High 1 2 3 4 5 6 7 

101 Gravina Is. 0.0 1.0 0 12 16 18 17 17 20 

303 Duke Is. 0.0 1.0 0 0 0 0 0 0 0 

404 Eastern Revilla Is. 0.0 1.0 0 0 0 0 0 0 0 

405 Thorne Arm (Revilla Is.) 0.0 1.0 2 16 17 17 16 19 20 

406 Carrol Inlet (Revilla Is.) 0.0 1.0 7 16 17 28 19 19 32 

407 George Inlet (Revilla Is.) 0.0 1.0 6 19 20 29 22 22 31 

408 Ketchikan 0.0 1.0 0 3 3 3 3 3 3 

509 Naha Area (Revilla Is.) 0.0 0.8 1 7 7 15 9 8 16 

510 Neets Bay Area (Revilla Is.) 0.0 0.8 6 13 14 24 18 15 30 

511 Northern Revilla Is. 0.0 0.5 0 0 0 0 0 0 0 

612 Eastern Cleveland Pen. 0.0 0.8 0 0 5 43 27 26 49 

613 Helm Bay (Cleveland Pen.) 0.0 1.0 0 0 0 41 0 0 52 

614 Meyers Chuck (Cleveland Pen.) 0.0 1.0 0 0 0 47 0 0 49 

715 Redoubt Lake, Neckar Is. 0.0 0.8 0 0 0 0 0 0 0 

716 Unuk Drainage (Cleveland Pen.) 0.0 0.5 0 0 0 0 0 0 0 

717 Lower Chickamin (Misty Fiords) 0.0 0.5 0 0 0 0 0 0 0 

718 Upper Chickamin (Misty Fiords) 0.0 0.5 0 0 0 0 0 0 0 

719 Rudyerd Bay (Misty Fiords) 0.0 0.5 0 0 0 0 0 0 0 

820 Wilson/Blossom Drainages (Misty Fiords) 0.0 0.5 0 0 0 0 0 0 0 

821 Smeaton Bay ( Misty Fiords) 0.0 0.8 0 0 0 0 0 0 0 

822 Boca De Quadra Drainages (Misty Fiords) 0.0 1.0 0 0 0 0 0 0 0 

823 Pearse Canal (Misty Fiords) 0.0 1.0 0 0 0 0 0 0 0 

824 Peabody Mtns (Misty Fiords) 0.0 0.5 0 0 0 0 0 0 0 

825 Upper Portland Canal (Misty Fiords) 0.0 0.5 0 0 0 0 0 0 0 

826 Hyder (Misty Fiords) 0.0 0.5 0 12 13 30 15 15 33 

901 Suemez Is. 0.0 1.0 7 21 24 33 25 26 40 

902 Outside Is. 0.0 1.0 0 0 1 0 1 1 2 

1003 Heceta Is. 0.0 1.0 12 19 20 31 25 22 38 

1105 Dall Is. 0.0 1.0 0 0 0 4 4 3 8 

1106 Long Is. 0.0 1.0 0 0 0 1 0 0 1 

1107 Hydaburg, Hetta Inlet, Sukkwan Is. 0.0 1.0 0 1 1 18 15 15 23 

1108 Southwestern Prince Of Wales Is. 0.0 1.0 0 0 0 0 0 0 0 

1209 Southeastern Prince Of Wales Is. 0.0 1.0 0 0 4 12 4 4 15 

1210 Moira Sound (POW) 0.0 1.0 0 1 15 27 18 16 31 

1211 Kitkun, South Arm Cholmondeley (POW) 0.0 1.0 0 17 18 33 20 19 44 

1212 Clover Mtn. (POW) 0.0 1.0 0 0 15 18 15 17 20 

1213 West Arm Cholmondeley (POW) 0.0 1.0 1 11 12 25 15 13 35 

1214 Skowl Arm, Polk Inlet (POW) 0.0 0.8 9 16 18 24 20 19 42 

1315 Kasaan Peninsula, Thorne Bay (POW) 0.0 1.0 11 17 21 30 23 23 42 

1316 Karta Bay (POW) 0.0 0.8 0 0 0 0 0 0 0 

1317 Twelve Mile Arm, Harris River (POW) 0.0 0.8 7 14 20 29 22 22 47 

1318 Craig, Klawock Areas (POW) 0.0 1.0 5 17 23 39 28 25 43 

1319 Thorne River Drainage (POW) 0.0 0.8 6 11 13 28 17 17 40 

1323 Western Prince Of Wales Is. 0.0 1.0 3 11 12 21 13 13 29 

1332 Trocadero Bay, Waterfall Area (POW) 0.0 1.0 2 3 12 20 14 13 31 

1420 Coffman Cove, Luck Lake, Ratz Harbor (POW) 0.0 1.0 13 20 24 29 26 26 39 

1421 Sweetwater Lake, Logjam Creek (POW) 0.0 0.8 8 13 14 12 16 16 33 

1422 Staney Creek, Naukati, Sarkar (POW) 0.0 1.0 14 23 25 31 28 28 38 

1524 Warren Is. 0.0 1.0 0 0 0 0 0 0 0 

1525 Southern Kosciusko Is. 0.0 1.0 11 18 21 21 22 24 34 

1526 Holbrook Mt., Northern Kosciusko Is. 0.0 1.0 0 0 0 4 3 3 6 

1527 Prince Of Wales El Capitan Area 0.0 1.0 10 21 23 25 26 26 34 

1528 Salmon Bay (POW) 0.0 0.8 4 6 7 11 11 11 28 

1529 Mt. Calder, Red Bay, Port Protection (POW) 0.0 1.0 7 12 13 28 17 14 37 

1530 Exchange Cove, Whale Passage (POW) 0.0 0.8 6 9 13 17 15 14 27 

1531 Tuxekan, Marble, Sea Otter Sound (POW) 0.0 1.0 11 18 19 28 26 21 38 

1601 Fanshaw-Farragut Area 0.0 0.8 0 0 0 36 29 26 41 

1602 Farragut River Drainage 0.0 0.8 0 0 0 0 0 0 0 
 Environment and Effects 3 

Final EIS 3-275 Wildlife 

Table 3.10-8 (continued) 

High Quality Deer Winter Range Suitable for Harvest by Alternative

Percent of High Value Deer Winter 

Range Suitable for Harvest Range of HSI 2/, 3/ 

Scores1/ Alternative 

WAA Vicinity Low High 1 2 3 4 5 6 7 

1603 Thomas Bay 0.0 0.8 0 0 12 18 15 13 23 

1604 Baird Glacier 0.0 0.2 0 0 0 0 0 0 0 

1605 Muddy River, Patterson Glacier 0.0 0.8 0 10 23 36 25 25 39 

1706 Horn Cliffs, Le Conte Bay 0.0 0.8 0 0 0 0 0 0 0 

1707 North Arm Of The Stikine 0.0 0.8 0 0 0 0 0 0 0 

1708 Stikine River Drainage 0.0 0.6 0 0 0 0 0 0 0 

1809 Cone Mtn. 0.0 0.5 0 0 0 0 0 0 0 

1810 Virginia Lake, Garnet Mtn. 0.0 0.8 0 0 27 48 30 30 48 

1811 Aaron Creek Drainage 0.0 0.8 0 0 8 16 10 9 21 

1812 Marten Lake, Harding River Drainage 0.0 0.8 0 0 4 4 4 4 6 

1813 Bradfield River Drainages 0.0 0.5 0 6 10 16 13 11 17 

1814 Eagle River, S. Shore Bradfield Canal 0.0 0.8 0 0 7 13 7 8 17 

1815 Anan Creek 0.0 0.8 0 0 4 6 5 4 10 

1816 Seward Passage 0.0 0.8 0 5 18 23 20 20 27 

1817 Vixen Inlet, Union Bay 0.0 0.8 0 0 2 17 15 15 47 

1901 Northern Etolin Is. 0.0 1.0 3 15 17 33 20 19 42 

1902 Deer Is. 0.0 0.8 0 0 6 11 6 6 20 

1903 Wrangell Is. 0.0 0.8 6 20 21 38 23 23 44 

1904 Woronkofski And Stikine Mouth Is. 0.0 0.8 0 4 14 21 17 16 32 

1905 Zarembo Is. 0.0 1.0 8 20 21 37 23 23 42 

1906 Kashevarof Islands 0.0 1.0 0 15 16 18 18 18 29 

1910 Southern Etolin Is. 0.0 1.0 0 0 2 3 2 2 4 

2007 Mitkof Is. 0.0 1.0 9 21 22 32 24 26 40 

2008 Woewodski Is. 0.0 1.0 0 0 39 45 43 43 56 

2202 Sullivan River And Island 0.0 0.8 0 0 0 10 5 5 13 

2203 Endicott River Drainage 0.0 0.5 0 0 0 3 1 1 3 

2304 St. James Bay 0.0 0.5 0 0 0 28 27 24 32 

2305 Southern Chilkat Range 0.0 0.5 0 7 8 28 8 9 30 

2306 Excursion Inlet 0.0 0.5 0 13 14 25 15 15 28 

2408 Eldred Rock-Pt. St. Mary 0.0 0.5 1 2 12 23 13 13 25 

2409 Berners Bay 0.0 0.5 2 4 9 13 8 9 15 

2410 Berners River Drainage 0.0 0.5 0 0 0 0 0 0 0 

2411 Lace River Drainage 0.0 0.5 0 0 0 0 0 0 0 

2412 Antler River Drainage 0.0 0.5 0 0 0 0 0 0 0 

2413 Gilkey River Drainage 0.0 0.5 0 0 0 0 0 0 0 

2514 Cowee, Davies Creeks 0.0 0.5 0 1 7 16 16 7 19 

2515 Eagle River-Mendenhall River Area 0.0 0.8 0 0 0 0 0 0 0 

2516 Juneau Ice Field 0.0 0.1 0 0 0 0 0 0 0 

2517 Juneau And Lower Taku 0.0 0.8 0 0 0 15 11 10 21 

2518 Taku River 0.0 0.5 0 0 0 0 0 0 0 

2519 Turner Lake, Southern Shore Taku Inlet 0.0 0.5 0 0 0 11 7 8 15 

2620 Lincoln Is. 0.1 0.1 0 0 0 0 0 0 0 

2621 Shelter Is. 0.0 0.8 0 0 0 0 0 0 0 

2722 Douglas Is. 0.0 0.8 0 0 0 19 0 0 0 

2823 Snettisham Inlet, Speel,Whiting Rivers 0.0 0.5 0 0 0 12 7 6 15 

2824 Holkham Bay-Tracy Arm 0.0 0.5 0 0 0 0 0 0 0 

2825 Endicott Arm 0.0 0.5 0 0 0 0 0 0 0 

2926 Windham Bay, Chuck River, Hobart Bay 0.0 0.5 0 0 1 11 9 9 12 

2927 Port Houghton-Cape Fanshaw 0.0 0.8 0 0 1 22 13 12 25 

3001 Nakwasina, Neva Strait Area (NW Baranof) 0.0 1.0 0 3 5 20 5 5 23 

3002 Sitka Road System 0.0 1.0 0 1 1 4 1 1 4 

3003 Silver Bay, Deep Inlet 0.0 1.0 0 2 8 19 8 8 21 

3104 Northern Kruzof Is. 0.0 1.0 0 13 15 25 17 16 29 

3105 Southern Kruzof Is. 0.0 1.0 0 0 4 4 4 4 5 

3206 Redoubt Lake, Neckar Islands 0.0 1.0 0 0 0 0 0 0 0 

3207 Crawfish Inlets, Neckar Bay (Baranof Is.) 0.0 1.0 0 0 0 0 0 0 0 

3308 Kook Lake, Sitkoh Bay, False Is. 0.0 0.8 1 12 16 25 18 17 29 

3309 Northern Shore Hoonah Sound 0.0 0.8 0 0 0 9 7 7 10 

3310 South Arm Hoonah Sound 0.0 0.8 0 0 0 0 0 0 0 

3311 Ushk Bay-Kakul Narrows 0.0 0.8 0 0 0 16 14 11 19 

3312 Duffield Penin., Bear Bay 0.0 0.8 0 9 9 22 10 10 24 

3313 Rodman And Saook Bay Drainages 0.0 0.8 0 15 17 32 28 24 35 

3314 Fish Bay Drainages 0.0 0.8 0 1 1 25 1 1 27 
3 Environment and Effects

Wildlife 3-276 Final EIS

Table 3.10-8 (continued) 

High Quality Deer Winter Range Suitable for Harvest by Alternative

Percent of High Value Deer Winter 

Range Suitable for Harvest Range of HSI 2/, 3/ 

Scores1/ Alternative 

WAA Vicinity Low High 1 2 3 4 5 6 7 

3315 Catherine Island, Lake Eva, Hanus Bay 0.0 0.8 0 11 11 18 12 12 20 

3416 Khaz Penin., Slocum Arm (Chichagof Is.) 0.0 1.0 0 0 0 0 0 0 0 

3417 West Coast Chichagof 0.0 1.0 0 0 0 0 0 0 0 

3418 Yakobi Is. 0.0 1.0 0 0 0 0 0 0 0 

3419 Upper Lisianski Inlet, Lisianski River (Chichagof 

Is.) 0.0 0.6 0 0 0 0 0 0 0 

3420 Idaho Inlet Drainages 0.0 0.6 0 0 0 0 0 0 0 

3421 Port Althorp, Lower Lisianski, Inian Is. 0.0 0.8 0 0 0 0 0 0 0 

3523 East Side Port Frederick, Game Creek 

(NE Chichagof) 0.0 0.8 2 6 6 12 7 6 27 

3524 Hoonah Area 0.0 0.8 0 21 22 30 25 24 31 

3525 Freshwater Bay Drainages (NE Chichagof) 0.0 0.8 6 12 13 22 15 14 29 

3526 North Shore Tenakee Inlet (NE Chichagof) 0.0 0.8 3 9 9 15 10 10 29 

3551 Whitestone Harbor, False Bay Drainages 

(NE Chichagof) 0.0 0.8 4 11 12 19 13 13 31 

3627 Corner Bay, Trap Bay (Chichagof Is.) 0.0 0.8 5 10 13 18 15 14 20 

3628 Kadashan (Chichagof Is.) 0.0 0.8 0 0 0 0 0 0 0 

3629 Southern Shore Tenakee Inlet (Chichagof Is.) 0.0 0.8 0 4 10 25 19 18 28 

3630 Upper Tenakee Inlet (Chichagof Is.) 0.0 0.5 0 0 0 19 13 7 20 

3731 Kelp Bay-Takatz Bay (Baranof Is.) 0.0 0.8 0 2 3 10 3 3 14 

3732 Warm Springs Coast (Baranof Is.) 0.0 0.5 0 0 0 0 0 0 0 

3733 Whale Bay Drainages, Wilderness Coast 

(Baranof Is.) 0.0 1.0 0 0 0 0 0 0 0 

3734 Southern Baranof Is. 0.0 0.8 0 0 0 0 0 0 0 

3835 Northern Mansfield Penin. 0.0 0.8 0 0 0 0 0 0 0 

3836 Hawk Inlet, Young Bay Drainages (Admiralty Is.) 0.0 0.8 0 0 0 0 0 0 0 

3837 Wheeler, Greens Creeks Drainages 

(Admiralty Is.) 0.0 0.8 0 0 0 0 0 0 0 

3938 Gambier Bay Drainages (Admiralty Is.) 0.0 0.8 0 0 0 0 0 0 0 

3939 Pybus Bay Drainages (Admiralty Is.) 0.0 1.0 0 0 0 0 0 0 0 

3940 Pt. Gardner, Eliza Harbor (Admiralty Is.) 0.0 0.8 0 0 0 0 0 0 0 

4041 Whitewater Bay, Wilson Cove (Admiralty Is.) 0.0 0.8 0 0 0 0 0 0 0 

4042 Angoon Area (Admiralty Is.) 0.0 0.8 0 0 0 0 0 0 0 

4043 Central Admiralty Lakes 0.0 0.8 0 0 0 0 0 0 0 

4044 Shee-Atika Drainages (Admiralty Is.) 0.0 0.8 0 0 0 0 0 0 0 

4054 Fishery, Thayer Creeks (Admiralty Is.) 0.0 0.8 0 0 0 0 0 0 0 

4055 Hood Bay, Chaik Bay Drainages (Admiralty Is.) 0.0 0.8 0 0 0 0 0 0 0 

4145 Tiedeman Is.-Mole Harbor Area (Admiralty Is.) 0.0 0.8 0 0 0 0 0 0 0 

4146 

Windfall Harbor, Swan Cove Drainages 

(Admiralty Is.) 0.0 0.8 0 0 0 0 0 0 0 

4147 Upper Seymour Canal (Admiralty Is.) 0.0 0.8 0 0 0 0 0 0 0 

4148 West Side Glass Penin. (Admiralty Is.) 0.0 0.8 0 0 0 0 0 0 0 

4149 East Side Glass Penin. (Admiralty Is.) 0.0 0.8 0 0 0 0 0 0 0 

4150 Grand Is., Oliver Inlet, Stink Creek 

(Admiralty Is.) 0.0 0.8 0 0 0 0 0 0 0 

4222 Pt. Adolphus, Mud Bay Area (Baranof Is.) 0.0 0.8 0 2 4 14 4 4 14 

4252 Humpback, Gallagher Creeks (Baranof Is.) 0.0 0.8 0 22 23 35 23 25 36 

4253 Neka Bay Drainages (Baranof Is.) 0.0 0.8 0 8 10 20 11 11 22 

4256 Lemesurier, Pleasant Islands 0.0 0.8 0 0 0 0 0 0 0 

4302 Lower Chilkat, Kelsall River Valleys 0.0 0.5 0 0 0 22 21 10 28 

4304 Chilkat Penin. 0.0 0.4 0 0 0 0 0 0 0 

4407 West Side Taiya Inlet 0.0 0.5 0 0 0 0 0 0 0 

4408 Katzehin River-Eldred Rock 0.0 0.5 0 0 0 0 0 0 0 

4503 Yakutat Forelands E. Of Dangerous River 0.0 0.8 0 0 0 0 0 0 0 

4504 Yakutat Bay Islands 0.0 0.5 0 0 0 0 0 0 0 

4505 Russell Fjord Drainages 0.0 0.5 0 0 0 1 0 0 1 

4506 Eastern Shore Disenchantment Bay 0.0 0.5 0 0 0 0 0 0 0 

4508 Yakutat Forelands W. Of Dangerous River 0.0 0.8 0 4 10 13 11 11 13 

4607 Nunatak Bench 0.0 0.1 0 0 0 0 0 0 0 

5012 Northern Kuiu Is. 0.0 0.8 0 20 23 31 26 25 36 

5013 Port Camden, Bay Of Pillars 0.0 0.8 0 3 6 15 12 12 18 

5014 Eastern Kuiu Is., Conclusion Is. 0.0 1.0 0 0 0 31 24 24 39 

5015 Coronation Is. 0.0 1.0 0 0 0 0 0 0 0 

5016 Tebenkof Bay 0.0 1.0 0 0 0 0 0 0 0 
 Environment and Effects 3 

Final EIS 3-277 Wildlife 

Table 3.10-8 (continued) 

High Quality Deer Winter Range Suitable for Harvest by Alternative

Percent of High Value Deer Winter 

Range Suitable for Harvest Range of HSI 2/, 3/ 

Scores1/ Alternative 

WAA Vicinity Low High 1 2 3 4 5 6 7 

5017 Southern Kuiu Is. 0.0 1.0 0 0 0 15 0 0 20 

5018 Rocky Pass/Kuiu 0.0 0.8 0 4 14 23 19 20 25 

5130 Rocky Pass/Kupreanof 0.0 1.0 2 3 14 26 21 19 31 

5131 Hamilton Creek, Big John Bay 0.0 0.8 5 11 12 17 14 13 18 

5132 Kake Area 0.0 1.0 4 13 13 21 18 15 23 

5133 West Duncan Canal 0.0 1.0 1 2 4 27 23 22 32 

5134 South Shore Kupreanof 0.0 1.0 0 0 5 16 10 10 18 

5135 North Shore Kupreanof 0.0 1.0 5 12 13 14 14 14 22 

5136 Portage Bay, Nw Kupreanof 0.0 1.0 10 22 27 40 32 30 48 

5137 Petersburg Creek (Kupreanof Is.) 0.0 1.0 0 1 1 1 1 1 1 

5138 Southern Lindenberg Penin. (Kupreanof Is.) 0.0 1.0 10 27 28 38 31 31 50 

Average 1 4 6 13 9 8 16 

Forestwide 1 2 2 5 3 3 5 1 Scores range from 0 to 1.0, with higher numbers indicating higher habitat quality. 2 High quality habitat was defined as the top 25 percent of acres within each WAA with the highest HSI scores. The analysis 

excluded all lands with HSI scores of 0 before identifying high quality habitat; WAA 202 contains only two polygons, both 

with HSI scores of 0, and therefore was not included in this table 

3 This analysis assumes maximum timber harvest levels and takes the Model Implementation Reduction Factor (MIRF) into 

account (see the Timber section for additional discussion). 

Alternatives 4 and 7, in increasing order, would have the greatest potential to lead to 

over-hunting of mountain goats and black bears because of increased access. 

Both mountain goats and black bears are also susceptible to disturbance associated 

with helicopter overflights and landings. In a study of mountain goat responses to 

helicopter disturbance, Cote (1996) documented temporary displacement from the 

area of disturbance, the disintegration of social groups, and injury while fleeing. 

Cardiac responses (i.e., elevated heart rate) have been documented in bighorn 

sheep which occupy similar habitats. Distance between animals and helicopters 

appears to be the most important factor affecting mountain goat responses and 

disturbance can occur as far away as 2 kilometer from a helicopter flight (Cote 

1996). Though no studies have been completed to date that examine the long-term 

consequences of this disturbance on mountain goats (Wilson and Shacklston 2001), 

it has been suggested that behavioural disruptions in response to disturbing stimuli 

result in demographic consequences (e.g., Côté 1996). For example, disturbance 

increases energy expenditure due to the flight response, and has the potential to 

affect foraging, socialization, and other life-history strategies which could ultimately 

affect mortality and natality. This would be most likely when mountain goats are 

already under seasonal nutritional or energetic stress such as when they are on 

winter range or kidding areas,. 

Recent trends indicate that use of helicopters by the tourism industry to reach 

remote areas has increased since 1997 and is anticipated to continue increasing 

(see Recreation section for further discussion). However, Forest Plan standards 

and guidelines in place address helicopter use at the project scale, though there is 

still some uncertainly related to their adequacy due to the lack of long-term studies 

on disturbance effects. 

River Otter 

River otters prefer habitats immediately adjacent to coastal and fresh water aquatic 

environments, with most use occurring within 500 feet. Old-growth forests in these 
3 Environment and Effects

Wildlife 3-278 Final EIS

areas provide the highest value habitat, providing cover and burrow and den sites 

(Suring et al. 1988). The majority of otter habitat is secure under the existing Forest 

Plan because of beach, estuary, and riparian Forest-wide standards and guidelines; 

therefore, there is no increased risk associated with Alternatives 1, 2, 3, 4, 5, and 6, 

which maintain existing 1,000-foot Beach and Estuary Buffer standards and 

guidelines. Alternative 7 proposes to reduce the beach fringe buffer to 500 feet. 

Although most use by river otters occurs within this distance, the additional 500 feet 

are important for providing connectivity. Consequently, the reduced buffer under 

Alternative 7 may result in more road construction and timber harvest closer to 

areas inhabited by otters thereby providing less protection of otter habitat. 

American Marten 

The most important factors related to viability of the marten populations on the 

Tongass are the large amount of habitat in OGRs and non-development LUDs, 

followed by habitat characteristics of the matrix. Within the matrix, forest structure at 

the stand level (e.g., forest cover and components that contribute to structural 

diversity such as large trees, snags, and downed logs) and landscape connectivity 

are important factors. Marten are strongly associated with late-seral and old-growth 

forests below 1,500 feet in elevation. They are also wide ranging and require large 

tracts of contiguous habitat to move across the landscape, as well as habitats 

capable of supporting an adequate prey-base of small mammals. 

The elevation preferences for marten presents the potential for a viability concern in 

that high quality habitats generally contain a greater, relative proportion of mature 

forest and thus have also historically received a disproportionately high level of 

harvest and associated road effects of harvest. That is, new roads may lead to 

increased human access and thus the potential for increased trapping pressure. 

Consequently, beach and riparian zones are particularly important for this species in 

terms of landscape connectivity and prey habitat diversity. As noted under the 

Affected Environment section, recent research has shown that prey availability and 

harvest play significant roles in the population dynamics of this species. 

There are currently approximately 1.83 million acres of high volume (SD5N, SD5S, 

and SD67 categories) old growth below 1,500 feet in elevation on the Tongass. 

Under Alternative 5 (No Action), a maximum of 9.7 percent of these acres could be 

harvested over the next 100+ years. Alternatives 1, 2, 3, and 6 would each protect 

more acres of high-volume old growth below 1,500 feet elevation than Alternative 5, 

with potential harvest ranging from 2.0 percent of the acres under Alternative 1 to 

9.3 percent of the acres under Alternative 6. Alternatives 4 and 7 would protect 

fewer acres of high-value marten habitat, with the potential harvest ranging from 

13.8 percent to 17.2 percent, respectively. 

Based on the 1997 expert panel assessments for marten (DeGayner 1997), it can 

be concluded that Alternative 5 (which is the equivalent of Alternative 11 in the 1997 

Forest Plan Revision Final EIS) would have a moderate likelihood of sustaining 

viable, well-distributed marten populations because it incorporates three key 

features thought important for marten use: wider riparian management buffers; 

1,000-foot beach and estuary buffers; and a system of small, medium, and large 

reserves (Appendix D). Subsequent to the panel assessment, Alternative 5 was 

strengthened by incorporating additional measures, including the requirement for 

special prescriptions for managing high-value marten habitat in timber harvest areas 

to retain important components of forest stand structure in higher risk biogeographic 

provinces where timber harvest has reduced the abundance of habitat components 

important to marten. The overall objective was to avoid the creation of additional 

significant gaps in marten habitat that could inhibit interaction between 

subpopulations by limiting harvest units to 2 acres in size and applying even-aged 

harvest at a 200-year rotation in highly fragmented VCUs and, in less fragmented 
 Environment and Effects 3 

Final EIS 3-279 Wildlife 

VCUs, retaining structures that will allow harvested units to regain value as marten 

habitat in a relative short amount of time by retaining coarse woody debris and 

green trees to act as a source of woody debris during the next rotation (Appendix N, 

1997 Final EIS). These Marten Habitat standards and guidelines only apply to 

areas identified as high value habitat by the marten habitat capability model. 

Alternatives 1, 2, 3, and 6 maintain key features and management prescriptions 

under Alternative 5, propose the less cumulative harvest of POG (acres after full 

implementation of the Forest Plan), and protect more POG and a higher percentage 

of larger tree POG types in reserves. These alternatives also replace the existing 

Marten Habitat and Goshawk Foraging standards and guidelines with a Forest-wide 

Legacy Structure standard and guideline. The Legacy Forest Structure standard 

and guideline continues to meet the objectives of maintaining sources of coarse 

woody debris important for marten and of reducing fragmentation to facilitate 

movements of marten between OGRs and is to be applied in the high risk VCUs 

Forest-wide, including the biogeographic provinces that have not had concentrated 

past timber harvest activity but where concentrated harvest could take place in the 

future. Additionally, it specifies a clumped distribution of reserve trees and therefore 

would implement a larger number of acres of even-aged management, whereas the 

existing standards and guidelines specify that reserve trees be uniformly distributed 

across a unit (see Section 2.5 of Appendix D for a detailed analysis and 

comparison). In addition, the potential road densities are lower under Alternatives 1, 

2, 3, and 6, thereby reducing the chances of increasing trapping pressure on marten 

through increased human access. Therefore, Alternatives 1, 2, and 3 provide better 

protection of key marten habitat components and connectivity across the landscape 

than Alternatives 5 (No Action), and are more likely to continue to support well 

distributed, viable marten populations on the Tongass. Alternative 6, which harvests 

slightly less timber than Alternative 5, would also be expected to have a moderate 

likelihood of sustaining well-distributed viable populations of marten (Appendix D). 

Similar to Alternative 5, Alternative 6 was strengthened by incorporating additional 

measures that would increase the likelihood of maintaining habitat to sustain viable 

marten populations. Measures include increased protections of old growth in both 

the reserve system and within non-development LUDs, standards and guidelines 

regarding trapping mortality and road density and the Legacy Forest Structure 

standards and guidelines. Given the smaller suitable land bases and 

implementation of the Legacy Structure standards and guidelines under Alternatives 

1, 2, and 3, these alternatives are expected to have a very high (Alternative 1) to 

high (Alternatives 2 and 3) likelihood of sustaining viable, well-distributed 

populations of marten over the long-term (Appendix D). 

Alternatives 4 and 7 propose to harvest amounts of POG similar to Alternatives 6 

and 2 of the 1997 Forest Plan Revision Final EIS, respectively (greater than under 

Alternative 5), reduce or eliminate the OGRs system, and eliminate the Goshawk 

Foraging and Marten Habitat standards and guidelines. In addition, there is no 

Forest-wide Legacy Forest Structure requirement. Alternative 7 would also reduce 

the beach fringe from 1,000 to 500 feet. Based on the 1997 expert panel 

assessments (Iverson 1996a, DeGayner 1997) both Alternatives 4 and 7 would be 

rated as having a moderate chance of maintaining habitat sufficient to support welldistributed viable marten populations across the Tongass (Iverson 1996a, 

DeGayner 1997). As a result,it is likely that under these alternatives more isolated 

populations could result. The extensive planned roading, potentially leading to 

increased trapping pressure, continued fragmentation of habitat, and the higher 

harvest rate for the important high-volume old-growth forest component were factors 

cited by panelists that contributed to these conclusions. 
3 Environment and Effects

Wildlife 3-280 Final EIS

Brown Bear 

The quality and quantity of riparian habitats play an essential role in sustaining 

brown bear populations, both in terms of the maintaining adequate vegetative cover 

to support anadromous fish production (i.e., regulate stream temperature) and 

providing visual obscurity of bears from humans and other bears. The existing 

Brown Bear standard and guideline requires a minimum no-harvest buffer of 500 

feet around important brown bear foraging sites. Additionally, the reserve system 

serves as an important source of roadless refugia for bears, reducing the possibility 

of human-bear interactions. The 1997 Forest Plan panel members viewed factors 

that increased road construction and repeated human entry into a watershed as 

adverse to brown bears. Of particularly concern are activities that are dispersed or 

occur over an extended time period because once an area is roaded for one 

development activity, it often results in additional developments that increase 

human-bear interactions, and ultimately reduce the area's capability for supporting 

high bear populations. Wilderness and LUD II areas were determined to essentially 

ensure brown bear persistence somewhere in Southeast Alaska over the 100-year 

planning horizon. 

Alternative 5 (No Action) emphasizes protection of known high value brown bear 

areas, protection of riparian habitats, control of human access, sanitation 

management, and the system of OGRs to maintain viable and well distributed brown 

bear populations on the Tongass. Based on the 1997 Final EIS expert panel 

assessments, Alternatives 5 and 6 (equivalent to Alternative 11 of the 1997 Final 

EIS) would be ranked as having a high likelihood of maintaining viable brown bear 

populations over the long-term due to the reserve system (related to road effects) 

and the riparian buffer requirements (Meade 1997). Alternatives 1, 2, and 3, which 

maintain the conservation measures in place under Alternative 5 related to brown 

bears but propose less timber harvest and road construction, would have a very 

high (Alternatives 1) or high (Alternatives 2 and 3) likelihood of maintaining welldistributed, viable brown bear populations over the long term (Appendix D). 

As noted in the description of the Affected Environment in this section, brown bears 

are primarily found north of Frederick Sound. Alternative 4 maintains some 

protection of known high value brown bear areas by requiring OGRs in the 

Northeast Chichagoff Island biogeographic province within ADF&G GMU 4 

(Admiralty, Baranof, Chichagof, and surrounding islands), which supports the 

highest concentration of brown bears in the world. It is important to note though that 

Northeast Chichagof Island continues to support this population despite already 

having experienced a high level of timber harvest with roads having been built in 

nearly every watershed, many of which are closely associated with major fish 

streams (ADF&G 2000). In addition, Alternative 4 would also locate an individual 

reserve, the Eva Lake reserve, which is currently designated as Semi-remote 

Recreation LUD, in an ADF&G brown bear special use zone on Baranoff Island. 

Alternative 7 would completely eliminate the OGR system. Based on the 1997 

panel assessment (Meade 1997, Iverson 1996b) Alternatives 4 and 7(equivalent to 

Alternatives 6 and 2 of the 1997 Final EIS, respectively) would be ranked as having 

a moderately high relative likelihood of maintaining well-distributed, viable brown 

bear populations with some potential for the development of temporary gaps in 

distribution, due to the reduction in the reserve system (Appendix D). Although, risk 

would be greatest under Alternative 7 due to the more extensive timber harvest, 

associated road construction, and absence of an OGR system. OGRs serve as 

important roadless refugia for bears where human-bear interactions can be 

minimized, and that provide connectivity between upland areas and habitats used by 

bears for foraging (riparian areas, beach fringe, and estuaries). Therefore, 

Alternatives 4 and 7 are the most likely to adversely affect brown bears by reducing 

the amount of roadless refugia secured from timber harvest, which could prevent 
 Environment and Effects 3 

Final EIS 3-281 Wildlife 

access to important habitats, impede movement through corridors, and increase the 

risk of over-harvest and DLP mortality. 

Road densities are another measure of the potential impact of the alternatives on 

brown bears. Primary concerns include increased hunting or poaching, and 

disturbance during critical life stages (e.g., late-summer feeding periods for bear). 

Habitat fragmentation, as well as habitat loss secondary to activities that are 

facilitated by vehicular access (e.g., timber harvest, mining, residential development) 

are other potential impacts. Open roads, which receive the highest and most 

consistent use, are likely to have the greatest effect on brown bears, although 

closed roads still facilitate access (e.g., off-highway vehicle, pedestrian) to roadless 

areas. There is no road density threshold for brown bears, per se, however it can 

be assumed that increased road density elevates the potential for human-bear 

interactions. 

Road density was evaluated by WAA in ADF&G GMU 4, which includes Admiralty, 

Baranof, Chichagof, Kruzof, Yakobi, and neighboring islands, and is the only island 

group in Southeast Alaska with a persistent, high density population of brown bears. 

Current road densities (all roads included) are highest on Chichagof Island, 

Northeast Chichagof Island, and North Kruzof Island. These WAAs are likely to 

experience the greatest cumulative effects of road access (increased potential of 

human-bear interactions) associated with increased road density. They are also 

where the greatest increases in road density are proposed under the alternatives. 

Within these higher risk WAAs, road density increases would be greatest under 

Alternative 7, followed by 4, 5, 6, 3, 2, and 1; one exception is WAA 3311 where 

road density would only increase under Alternatives 4, 5, 6, and 7. There are also 

two WAAs on Baranof Island (3314 and 3315) that could become areas of higher 

risk under all alternatives;no road density increases would occur under any of the 

alternatives on Admiralty Island. 

Alexander Archipelago Wolf 

Two principal management concerns associated with maintaining well-distributed 

and viable wolf populations in Southeast Alaska are that 1) current mortality rates in 

localized areas such as north Prince of Wales Island (POW), may result in local 

declines in the wolf population, and 2) long-term reductions in deer habitat capability 

resulting from timber harvest may negatively affect wolf populations (Interagency 

Wolf Conservation Assessment; Person et al. 1996). Though wolves exploit a 

variety of food resources across the Tongass, deer are their primary prey and 

predator/prey interactions between wolves and deer have been demonstrated to be 

implicitly linked to wolf persistence. That is, if deer habitat capability in a territory is 

reduced to such an extent that it can no longer support a reproductively successful 

pack, it could create a gap in wolf distribution, particularly on islands that experience 

a substantial decline in deer numbers, or result in a lower density wolf population 

with larger pack home range sizes (Mech et al. 1998, Person et al. 2001, Fuller et al. 

2003). This concept was identified as the most important factor limiting wolf viability 

by the 1997 Forest Plan panel assessment. Recent research (Alexander 

Archipelago Wolf, presented at the Tongass Conservation Strategy Review 

Workshop 2006) has shown that the population on POW Island is genetically 

isolated from other Tongass populations, which presents profound implications for 

maintaining well-distributed wolf populations in light of local declines, given that 

these populations are are more sensitive to human activity and habitat disturbance 

than wolf populations elsewhere in the state (Schoen and Person 2007). Local 

declines on POW Island have been linked to the influence of road densities that 

provide greater trapping and hunting access to significant proportions of the wolf 

range, which increases wolf vulnerability to both legal and illegal mortality. The 
3 Environment and Effects

Wildlife 3-282 Final EIS

following analysis focuses on GMUs 2 and 3, which support 60 to 70 percent of the 

wolf population in Southeast Alaska. 

To address impacts to wolves, the potential effects of the alternatives on the 

availability of deer to wolves were evaluated. Though prediction of the response of 

the wolf population to changes in the deer population is speculative at best, a 

decline in the deer population would likely result in a decline in the wolf population 

and a reduction in wolf density. Resonating effects could include reductions in 

opportunities to harvest wolves. The Wolf standards and guidelines state that 

habitat to support a density of 18 deer per square mile is necessary to provide 

wolves and hunters with adequate foraging/hunting opportunities (see TPIT 

clarification letter regarding correct interpretation of deer density stated in Wolf 

standards and guidelines and additional discussion below regarding subsequent 

modification). This density does not represent actual population density and is not 

related to wolf viability, but represents the functioning of the predator-prey system 

dynamic. Although the Tongass and the ADF&G conduct limited deer pellet surveys 

to estimate deer population trends, robust deer density estimates are not available 

for the Tongass because surveys are conducted in a very limited number of areas 

(they focus on areas with heavy hunting pressure) and are inconsistently conducted 

from year to year. Given these limitations, impacts to actual deer density cannot be 

quantified per se; however, some generalizations can be made about the effects of 

changes in habitat capability on deer numbers if information about current 

population trends is known. 

It can be assumed that the carrying capacity for deer, or the maximum population 

size that a given area can support, influences how a deer population might react to 

changes in habitat capability. That is, if habitat capability were substantially reduced 

in an area, a deer population may simply slow in growth or stabilize if the population 

is below carrying capacity, or it may dramatically decline if it is at, or exceeding, 

carrying capacity because resources would no longer be adequate. This in turn 

relates to the influence of wolf predation on the deer population in that predation can 

be compensatory if the population exceeds carrying capacity (i.e., wolves kill deer 

that normally would have died of starvation), or additive if the population is below 

carrying capacity (i.e., wolves kill healthy deer that normally would have survived the 

winter). In the latter case wolf predation may contribute to a locally declining deer 

population and may actually suppress recovery of deer populations following severe 

declines (Person et al. 1996, Person 2001, Bowyer et al. 2005). This effect is 

sometimes referred to as a predator pit. For example, the slow rebound in the deer 

population on some of the south central islands in the Alexander Archipelago 

following severe winters in the late 1960s and early 1970s have been attributed to a 

combination of factors, including several severe winters, low-quality winter deer 

habitat in some locales (such as Kupreanof Island), and predator suppression 

(Kirchhoff 2003). Clearly, deer populations and the ability of a habitat to support 

deer are influenced by a myriad of factors not accounted for in this comparison. 

Weather, hunter effort, current deer population trends, allowed hunting pressure, 

and the presence of other predators are some of the factors that influence deer 

numbers and the magnitude of impacts related to changes in habitat capability. 

Moreover, there are time-lag effects associated with changes in habitat capability. 

The 2005 ADF&G deer management report provides general information on deer 

population trends by GMU (Porter 2005, Lowell 2005). Both GMU 2 and 3 

populations have historically fluctuated with the most severe declines having been 

associated with winter weather; however predation and illegal harvest have 

extended these declines. Current ADF&G management goals, which are to 

increase population levels in these units, indicate that deer populations are below 

carrying capacity. Deer populations in GMU 2 are reported to be at moderate levels 

but expected to decline; deer populations in GMU 3 are reported to be stable with 

some localized variation. Continued logging is anticipated to result in a decrease in 
 Environment and Effects 3 

Final EIS 3-283 Wildlife 

carrying capacity over the long-term due to reductions the amount of available 

winter range. In GMU 2 a reduction in carrying capacity of up to 60 percent has 

been projected (Porter 2005). This means that over the long-term reductions in 

habitat capability could cause deer numbers to decline, reducing the number of deer 

available to wolves. 

Timber harvest of important deer winter range reduces modeled deer habitat 

capability over the long term. Immediate concerns with all action alternatives focus 

on the cumulative effects of past timber harvest on the reduction in deer habitat 

capability on Prince of Wales and Kosciusko Islands (GMU 2), where a substantial 

amount of harvest has already occurred. In the 25 WAAs on Prince of Wales and 

Kosciusko islands, reductions in deer habitat capability would be greatest under 

Alternatives 4 and 7. Alternatives 1, 2, 3, and 6 would result in an equal or smaller 

reduction in deer habitat capability on these islands than Alternative 5 (No Action) 

(Table 3.10-7). The risk of not sustaining a well distributed, viable wolf population 

increases under Alternatives that have multiple WAAs within a single biogeographic 

province where large reductions in deer habitat capability would occur and where 

deer habitat capability is already low, but would be further reduced (e.g., WAAs on 

North Central Prince of Wales and South Prince of Wales biogeographic provinces). 

In several cases, deer habitat capability under Alternative 7 would be reduced to 

below 40 percent of that existing in 1954 prior to large-scale timber harvest. Of the 

16 WAAs on Kuiu, Kupreanof, and Mitkof islands (GMU 3) maximum estimated 

reductions in habitat capability range from 2 to 47 percent. Risks to wolves would 

be slightly lower on these islands due to the lower level of planned timber harvest. 

An index of the ability of the alternatives to support deer populations capable of 

maintaining sustainable wolf populations and meeting human harvest demands can 

also be approximated by using the deer habitat capability model to project habitat 

capability in terms of deer density (i.e., the number of deer per square mile an area 

may be capable of supporting) for comparison with the Wolf standard and guideline 

described above. In the wolf conservation assessment (Person et al. 1996), a 

population density of 13 deer per square mile, was recommended to maintain 

sustainable wolf populations, assuming an annual deer reproductive rate of 30 

percent. This equates to approximately 17 deer per square mile at carrying capacity 

(Person et al. 1996). That is, to provide for a population of 13 deer per square mile 

there needs to be an average long-term habitat capability of 17 deer per square mile 

over broader areas. This number was later revised to the current value of 18 deer 

per square mile as stated in the standard and guideline. It must be emphasized that 

these model outputs do not represent actual deer densities and cannot be used to 

predict changes in the prey base available to wolves and hunters, rather they are 

intended as one method of making relative comparisons among the alternatives. At 

the project level, other factors such as local knowledge of habitat conditions, spatial 

location of habitat, and other site-specific information need to be considered 

Based on ADF&G recommendations, habitat capability in terms of deer density was 

calculated by assuming a density of 100 deer per square mile for an HSI of 1.0. 

Only WAAs where wolves potentially occur (GMUs 1, 2, 3, and 5) were included. 

Table 3.10-9 shows long-term wolf habitat capability in terms of deer per square 

mile. 

The Wolf guideline is intended to apply to biogeographic provinces where deer are 

the primary prey of wolves. Thus, the number of WAAs that appear to fall below 18 

deer per square mile in terms of habitat capability is inflated because many either do 

not naturally contain much suitable deer habitat or are areas where wolves also prey 

heavily on species other than deer such as moose, beaver, or mountain goats. All 

of the alternatives increase the number of WAAs that do not maintain habitat 

capable of supporting 18 deer per square mile, the greatest number being added 

under Alternative 7, followed by Alternatives 4, 5/6, 3, 2, and 1, respectively. Most 
3 Environment and Effects

Wildlife 3-284 Final EIS

of the WAAs that currently meet the Wolf guideline, but may not meet it in the future 

after 100+ years of implementation, are located in the North Central Prince of Wales 

and Revilla Island/Cleveland Peninsula biogeographic provinces. 

Table 3.10-9. 

Comparison of Alternatives in terms of their Long-term Ability to Meet the 

Wolf Guideline of Providing Sufficient Habitat to Support 18 Deer per 

Square Mile after 100+ Years of Forest Plan Implementation 1

Increase in Percent of WAAs, 

Relative to 1954 Conditions, with 

Model-generated Habitat Capability 

<18 Deer/Sq. Mi. 2 

Biogeographic Provinces of 

WAAs Affected by 

Implemention of the 

Alternatives 3 

1954 Conditions4 -- - 

Current Conditions +12% - 

Alternative 1 +16% 14, 15 

Alternative 2 +17% 11,14, 15, 18 

Alternative 3 +25% 11, 14, 15, 18 

Alternative 4 +22% 9, 10, 11, 12, 14, 15, 18, 20 

Alternative 5 +22% 9, 10, 11, 12, 14, 15, 18, 20 

Alternative 6 +22% 9, 10, 11, 12, 14, 15, 18, 20 

Alternative 7 +25% 9, 10, 11, 12, 14, 15, 18, 20 1 Assumes full implementation of Forest Plan at ASQ levels. 2

 Excludes WAAs where wolves do not occur (Admiralty, Baranof, and Chichagof islands and associated small 

islands) and WAAs with naturally very low deer densities (WAAs 4302-4607). Habitat capability in terms of 

deer density calculated using a multiplier of 100 deer per square mile equating to a habitat suitability index 

score of 1.0. 3 Biogeographic Provinces: 9 = Northern Coast Range; 10 = Kupreanof/Mitkof Island; 11 = Kuiu Island; 12 = 

Central Coast Range; 14 = North Central Prince of Wales; 15 = Revilla Island/Cleveland Peninsula; 18 = 

South Prince of Wales; 20 = South Misty Fiords (some WAAs may overlap more than one biogeographic 

province) 4 Approximately 69 out of 122 WAAs (57%) were estimated to have had deer habitat capabilities <18 deer per 

square mile in 1954. 

As noted above, human access on roads may result in wolf mortality by both legal 

and non-legal harvest. Therefore, road densities are a factor to consider in 

sustaining wolf populations. Person et al. (1996) suggested that roadless and 

unfragmented reserves should be established in biogeographic provinces where 

extensive timber harvesting is planned to reduce long-term risks to wolf viability. 

Reserves of approximately 50,000 acres for each 192,000 acres of landscape area 

were considered necessary to support relatively secure core wolf populations. 

Spacing among reserves was not a critical criterion due to the extensive movement 

capability of wolves. The 1997 Forest Plan established habitat reserves in excess of 

this amount in Prince of Wales/Kosciusko islands and Kuiu/Kupreanof/Mitkof 

islands, including one reserve greater than 200,000 acres in size in the North 

Central Prince of Wales biogeographic province. Based on reductions in deer 

habitat capability and the existence of roadless refugia, Alternative 11 in the 1997 

Final EIS (Alternative 5 here) was determined to meet the reserve criteria identified 

by Person et al. (1996) and was ranked as having a high likelihood of sustaining 

persistent core wolf populations and reducing risks to long-term viability in the two 

principal areas of concern in Southeast Alaska (GMU 2 and 3) as well as the 

remainder of the historic wolf range on the Tongass (Iverson 1997c, 1996c) 

(Appendix D). Alternatives 3, 4, and 6 would also be rated high (Appendix D). 

Given the higher level of timber harvest and reduction of the Old-Growth Habitat 
 Environment and Effects 3 

Final EIS 3-285 Wildlife 

LUD under Alternative 7 would have a moderately high likelihood of maintaining 

well-distributed, viable wolf populations. 

The current Wolf standards and guidelines state that “where road access has been 

determined through analysis to significantly contribute to wolf mortality...open road 

densities of 0.7 to 1.0 mile per square mile or less may be necessary to reduce 

mortality to sustainable levels.” This metric is appropriately applied at the project 

level to areas that are the approximate size of an average wolf pack territory (about 

74,000 acres; Person et al. 1996). For this analysis, total road densities were 

calculated by WAA, the average size of which is 90,000 acres. Thus, road densities 

reported here are likely slightly lower than what could actually be experienced within 

a wolf pack territory. Currently, out of the 54 WAAs in GMUs 2 and 3, there are 19 

WAAs with total road densities greater than 1.0 mile per square mile (including both 

NFS and non-NFS lands). After full implementation of the Forest Plan (100+ years), 

the total number of WAAs where this is exceeded would be greatest under 

Alternative 7 (30 WAAs), followed by Alternatives 4 (29 WAAs), 5 and 6 (28 WAAs), 

3 (27 WAAs), 2 (25 WAAs), and 1 (23 WAAs) Although additional research is 

needed to determine whether or not a direct correlation exists between local wolf 

population dynamics and road density, research indicates that the likelihood of 

maintaining viable wolf populations would be lowest in areas that have the highest 

road densities, due to higher trapping and hunting harvest rates (Alexander 

Archipelago Wolf, presented at the Tongass Conservation Strategy Review 

Workshop 2006), though this is situation-specific in that it depends on how 

accessible roads are (i.e., whether they are near main road systems or human 

settlements). In addition, harvest levels can be controlled through regulations. 

However, Alternatives 4 and 7, in increasing order, would be most likely to result in 

increased harvest pressure and illegal mortality associated with higher road 

densities. However, if a viability concern emerged, there are other Forest-wide 

standards and guidelines in place that would mitigate road-related effects including 

road closures that effectively prohibit motorized vehicle traffic (e.g., bridge and 

culvert removal) and off-highway vehicle restrictions. 

Bald Eagle 

Bald eagles primarily nest in old-growth trees along the coast and within riparian 

areas. Over 90 percent of the known nests on the Tongass are within 50 feet of the 

saltwater beach. The Bald Eagle and Riparian Forest-wide standards and 

guidelines are specifically designed to protect nesting habitat and the current Forest 

Plan includes 1,000-foot beach and estuary buffer requirements. The amount of 

nesting habitat in OGRs, non-development LUDs, and the 1,000-foot beach and 

estuary buffer protects virtually all bald eagle nesting habitat on the Tongass. All of 

the action alternatives considered here would maintain these standards and 

guidelines and provide the same level of protection as the current Forest Plan, with 

the exception of Alternative 7, which proposes to reduce the beach fringe buffer to 

500 feet. Therefore, only slight effects to bald eagles are expected under 

Alternatives 1, 2, 3, 4, 5, or 6. Under Alternative 7, protection of bald eagle nests 

occurring beyond 500 feet from saltwater would be reduced to the required 330-foot 

nest buffer, which would limit protection of nesting habitat to the area around known 

nests. This would reduce the overall amount of habitat potentially available for 

nesting in areas where road construction and harvest occur. 

Red-breasted Sapsucker, Hairy Woodpecker, Brown Creeper, and Red 

Squirrel 

These species rely on legacy components (e.g., large diameter trees, snags) of the 

old-growth forest ecosystem for nesting and foraging. A simple index of the level of 

habitat protection provided by each alternative is the amount of suitable old growth 
3 Environment and Effects

Wildlife 3-286 Final EIS

schedule to be harvested. After full implementation of the Forest Plan, the greatest 

percentage of existing POG could be harvested under Alternative 7 (16 percent), 

followed by Alternative 4 (13 percent), Alternatives 5 and 6 (9 percent), Alternative 3 

(6 percent), Alternative 2 (4 percent), and Alternative 1 (2 percent) (see Table 

3.10-5). Thus, Alternatives 7, 4, 5, 6, 3, 2, and 1 would have an increasingly greater 

chance of maintaining habitat capable of supporting well distributed, viable 

populations of these species. 

Under Alternative 5 (No Action), non-development LUDs provide broader protection 

for old-growth forest, where as Reserve Tree/Cavity-nesting Habitat, Goshawk 

Foraging, and Marten Habitat standards and guidelines provide protection to oldgrowth habitat components within matrix lands. The application of two-aged and 

uneven-aged management under Alternative 5 provides further habitat protection for 

these species. The current Goshawk and Marten standards and guidelines are 

applied to areas of the Forest with the greatest amount of disturbance. Although the 

new Legacy standard and guideline proposed under Alternatives 1, 2, 3, and 6 

would affect less overall area, it would be applied on a Forest-wide basis and 

require that retained trees and snags be representative of the existing stand age, 

species composition, and structural components (Appendix D). In contrast, neither 

the Goshawk Foraging, the Marten Habitat, nor the new Legacy Forest Structure 

standards and guidelines would be implemented under Alternatives 4 and 7. 

Therefore under these alternatives there would be no quantitative direction for the 

retention of structure, and consequently, together with the higher rate of harvest, 

Alternatives 4 and 7 would have greater effects on these species. 

Vancouver Canada Goose 

Vancouver Canada geese use wetlands (forested and non-forested) in the estuary, 

riparian, and uplands areas of the forest. Habitat needs for these species are 

specifically provided for under the waterfowl standards and guidelines, which apply 

to specific sites, and a 100-foot buffer around lakes or streams. The beach, estuary, 

and riparian Forest-wide standards and guidelines provide additional protection to 

habitats used by Canada geese. Consequently, there is no increased risk of habitat 

loss associated with any alternatives considered under this Forest Plan amendment, 

with the exception of Alternative 7, which proposes to reduce the beach fringe buffer 

to 500 feet and could result in the loss of suitable habitat in areas outside of this 

buffer if timber harvest and associated activities occur. 

Marbled Murrelet 

Distributional and ecological information about marbled murrelets in Southeast 

Alaska is largely lacking but high value habitats appear to be those found within 

large, contiguous blocks of high volume, low-elevation old-growth forest. 

Fragmentation and loss of overstory cover are two threats associated with 

development activities, such as timber harvest, that are correlated with increased 

predation. Alternative 11 of the 1997 Forest Plan Final EIS (Alternative 5 here) was 

determined to provide a very high likelihood of sustaining well distributed murrelet 

populations throughout Southeast Alaska due to the reserve system, which includes 

at-risk landscapes with high levels of past timber harvest, as well as beach and 

riparian protection. 

Alternative 7 proposes to harvest the greatest amount of existing POG (16 percent), 

and thus provides the least protection to marbled murrelets due to direct habitat loss 

and fragmentation and the limited reserve system. This is followed, in decreasing 

order of potential impacts, by Alternative 4 (13 percent), Alternatives 5 and 6 (9 

percent), Alternative 3 (6 percent), Alternative 2 (4 percent), and Alternative 1 (2 

percent) (Table 3.9-5). Alternatives 1, 2, 3, 5, and 6 would be judged as having a 

Other Species of 

Concern 
 Environment and Effects 3 

Final EIS 3-287 Wildlife 

very high likelihood of maintaining viable and well distributed marbled murrelet 

populations, Alternative 4 was judged high, and Alternative 7 was judged moderately 

high (Appendix D). 

Spruce Grouse 

Spruce grouse have historically inhabited forests showing a disturbance-related 

patchwork of various stages of regeneration. Timber harvest can produce similar 

patterns, but only if clearcut areas are small and if sufficient quantities of forested 

habitat are preserved. Spruce grouse inhabit some of the most highly modified 

landscapes on the Tongass (e.g., Prince of Wales Island) where additional timber 

harvest could threaten the long-term survival of these highly isolated and scattered 

low-density populations. This has particularly important conservation implications 

since the subspecies that occurs in Southeast Alaska is endemic. Conservation 

measures including a system of non-development LUDs and standards and 

guidelines that maintain connectivity within matrix lands (e.g., various buffer 

requirements) are essential to facilitating dispersal and interchange between 

isolated populations. Spruce grouse are also vulnerable to hunting and exploitation, 

correlated with road access, because they are not wary of humans, though viability 

is not an immediate concern given the level of harvest permitted in this area. 

Spruce grouse are an important prey species for goshawks and marten. In a study 

of goshawk diet during the breeding season in Southeast Alaska, birds (including 

spruce grouse) comprised a larger proportion of goshawk diet on Prince of Wales 

Island than elsewhere due to the limited number of prey species, many of which are 

sensitive to timber harvest activities (Lewis et al. 2006). This study concluded that 

the ability of goshawks to successfully reproduce in Southeast Alaska and on Prince 

of Wales Island in particular, appears to be affected by the extensive landscape 

alteration in this region in combination with the restricted prey base. Thus, alteration 

of spruce grouse habitat could have a resonating effect on predator populations. 

Given the current level of habitat modification in areas of the Tongass occupied by 

spruce grouse, the greatest protection would be provided by alternatives that 

propose the least amount of POG harvest and those with provisions for maintaining 

landscape connectivity. As described above under the marbled murrelet analysis, 

the greatest amount of habitat protection would be provided by Alternative 1, 

followed by Alternatives 2, 3, 6, 5, 4, and 7. Alternative 1, 2, 3, and 5, also include 

the most measures for maintaining landscape connectivity through the existing 

system of OGRs, where as Alternatives 4 and 7 reduce or eliminate the OGR 

system, respectively. Thus the alternatives in this order would have a decreasing 

likelihood of sustaining spruce grouse populations capable of providing an adequate 

prey base for goshawks and other predatory species and sustaining current levels of 

harvest. 

Prince of Wales Flying Squirrel 

Given that flying squirrel density in Southeast Alaska is highest in POG and closely 

tied to the abundance of large trees and snags, and that timber harvest occurs in 

forests where these habitat components are most abundant, the number of acres 

suitable for timber harvest is an appropriate measure of the relative effects of the 

alternatives on this species. The recent research described in the Affected 

Environment indicates that this risk is likely less than presumed because abundant 

noncommercial forests appear to contribute to breeding populations. Alternative 7 

proposes the most acres of harvest, followed by Alternatives 4, 5, 6, 3, 2, and 1 (see 

Table 3.10-5 and the Marbled Murrelet discussion above). In addition to decreasing 

the abundance of these habitat components, timber harvest can also create 

openings that may be too large for flying squirrels to travel through, resulting in 
3 Environment and Effects

Wildlife 3-288 Final EIS

smaller, isolated populations that may be at risk of local extirpation. Consequently, 

a system of OGRs and retention requirements for forest legacy components are 

important for sustaining well distributed populations of flying squirrels. 

Alternative 5 maintains the existing system of OGRs and Goshawk Foraging and 

Marten Habitat standards and guidelines that apply reserve tree requirements to 

matrix lands in the highest risk biogeographic provinces that have experience the 

highest cumulative effects of timber harvest (e.g., North Central Prince of Wales). 

Alternatives 1, 2, 3, and 6 also maintain the Forest-wide reserve system and replace 

the Goshawk Foraging and Marten standards and guidelines with the Forest-wide 

Legacy Structure standard and guideline; Alternatives 4 and 7 provide less 

protection because they include more area in development LUDs and do not include 

any of these standards and guidelines (see discussion under Red-breasted 

Sapsucker, Hairy Woodpecker, Brown Creeper, and Red Squirrel). In addition, 

Alternative 4 limits the OGR system to four of the most heavily logged biogeographic 

provinces, one of which is North Central Prince of Wales, and thus is not anticipated 

to affect Prince of Wales flying squirrels in that respect. Alternative 7 eliminates the 

Old-Growth Habitat LUD entirely. Consequently, Alternative 7 would have the 

greatest risk of creating isolated populations of flying squirrels susceptible to local 

extirpation both directly through habitat removal and through increased 

fragmentation by not incorporating provisions intended to maintain landscape 

connectivity. 

Migratory Birds 

Direct habitat and disturbance related effects to migratory birds would occur under 

all of the alternatives. The primary effect to birds would be nest destruction or 

abandonment if management activities occur in suitable nesting habitat during the 

breeding/nesting period, which generally begins in May and ends in September 

when young birds have fledged. The magnitude of the effects will vary depending 

on the alternative that is selected and the season in which disturbance would occur. 

It can be assumed that species most likely to be affected are those that nest in 

hemlock/Sitka spruce forests (e.g., blue grouse, rufous humming bird, and Pacificslope flycatcher) where timber harvest occurs, and thus the amount of harvest 

proposed under the alternatives is a measure of the extent of potential effects. 

Alternative 7 would remove the most POG after full implementation of the Forest 

Plan (roughly 100+ years) followed in descending order by Alternatives 4, 6, 5, 3, 2, 

and 1, respectively. Total percentage of POG harvest would range from 16.7 

percent of existing POG under Alternative 7 to 1.7 percent of existing POG under 

Alternative 1. In addition, Alternatives 1, 2, 3, 5, and 6 include some provisions for 

retaining additional legacy forest structure either through the existing Goshawk 

Foraging, Marten Habitat, and Cavity-nester standards and guidelines (Alternative 

5), or through a Forest-wide Legacy Structure standard and guideline. Therefore, 

these alternatives would provide more available legacy structure to migratory birds 

for nesting, roosting, and foraging than Alternatives 4 and 7, which do not include 

any legacy retention requirements. 

Other effects of timber harvest and associated activities include the fragmentation 

and patch size reduction of suitable habitat. For species such as the varied thrush 

and Townsend’s warbler, habitat removal would potentially reduce the effectiveness 

of interior habitat and increase the potential for nest-site predation from avian 

predators that are associated with forest edges and fragmented landscapes. The 

Conservation Strategy was designed to retain large blocks of old-growth distributed 

across the Forest, such that interior nesting habitat would be retained across the 

landscape. In addition, other retention in the matix, including the 1000’ beach and 

estuary buffer, benefits migratory birds and mitigate negative effects of 

fragmentation in the matrix. Therefore, effects to species associated with interior 
 Environment and Effects 3 

Final EIS 3-289 Wildlife 

forest conditions would be greatest under Alternatives 4 and 7, in increasing order, 

because they reduce or eliminated the OGR system, respectively. Effects to other 

species that are more closely associated with forest edge, riparian, or more open 

habitats would likely be negligible under Alternatives 1, 2, 3, 4, 5, and 6, which 

maintain species-specific and/or Forest-wide standards and guidelines that provide 

protection measures for key habitats (e.g., beach, estuary, and riparian buffers). 

However, the beach fringe buffer would be reduced to 500 feet under Alternative 7, 

thus decreasing the amount of protected nesting habitat in these areas and reducing 

the amount of interior habitat available. Some species, particularly those associated 

with edge habitats, may benefit from timber harvest proposed under any of the 

alternatives due to the creation of new habitat. Greatest adverse impacts to 

migratory birds would occur in the four most heavily disturbed biogeographic 

provinces where a majority of future timber harvest is concentrated (e.g., North 

Central Prince of Wales Island, Kupreanof/Mitkof islands, Revillagigedo 

Island/Cleveland Peninsula, and Etolin Island provinces). 

Endemic Mammals 

The 1997 Forest Plan Final EIS panel assessments evaluated 14 species or 

subspecies endemic to Southeast Alaska (Shaw and Smith 1995, Iverson 1997b). 

All of these species occupy restricted ranges, limited to a subset of islands in 

Southeast Alaska. Under the current Forest Plan all islands less than 1,000 acres 

were removed from the timber base to eliminate risk to these species associated 

with habitat loss or alteration from timber harvest. The 1,000-foot beach buffer, 

riparian corridors, and OGR system are also features of the current Forest Plan that 

provide functional habitat for species with relatively small home ranges. In addition, 

implementation of various standards and guidelines that apply within matrix lands 

will result in significant old-growth retention, which also benefits many endemic 

mammals. These protective provisions would be maintained under all the 

alternatives, with the exception of Alternative 7 under which the beach fringe buffer 

would be reduced to 500 feet and the system of OGRs eliminated. 

The panel assessments emphasized that just being an endemic represented a 

naturally elevated viability risk and that all alternatives had some likelihood of 

causing extirpation of endemic species based on historical and proposed timber 

harvest activity and that this likelihood increased with higher levels of proposed 

harvest. This is consistent with recent science suggesting that the areas of greatest 

conservation concern in the Alexander Archipelago are biodiversity hotspots (i.e., 

areas where multiple endemic mammal lineages occur), many of which coincide 

with the most heavily impacted areas (Cook et al. 2006). Based on the 1997 expert 

panel assessments for endemics (Iverson 1997b), it can be concluded that 

Alternative 5 (which is the equivalent of Alternative 11 in the 1997 Forest Plan 

Revision Final EIS) and Alternative 6, which proposes to harvest slightly less timber, 

would have a moderate likelihood of sustaining viable, well-distributed populations of 

endemic mammals (Appendix D). Alternatives 1, 2, and 3, which propose to harvest 

less timber than Alternatives 5 and 6, would only build on the above scenario, but 

also would be ranked as having moderate likelihoods of sustaining viable, welldistributed populations of endemic mammals over the long-term. Because of the 

level of past harvest, the panel also rated a no-harvest alternative as having a 

moderate likelihood 

Based on the expert panel assessments (Shaw and Smith 1995, Iverson 1997b) 

Alternative 4 (equivalent to Alternative 6 in the 1997 FEIS) would be rated as having 

a moderately low likelihood of maintaining viable, well-distributed populations of 

endemic mammals given proposed harvest levels. Alternative 7 (equivalent to 

Alternative 2 in the 1997 FEIS) would have a very low likelihood of sustaining welldistributed, viable endemic populations, and would have the highest likelihood 
3 Environment and Effects

Wildlife 3-290 Final EIS

among the alternatives to result in endemic populations that exist only in refugia 

(e.g., northern flying squirrel) or become extirpated (e.g., Keen’s myotis). 

Invasive Species 

Although a number of non-native wildlife species have been accidentally introduced 

or transplanted in Southeast Alaska, the only species considered invasive (i.e., 

based on the definition that they cause harm to the economy, environment, or 

humans) at the present time is the Norway rat; elk in Southeast Alaska may be 

considered invasive in certain geographic areas due to their effects on habitat in 

areas to which they were not intentionally introduced. Although the current Forest 

Plan does not specifically address invasive species, its intent is to manage for native 

species, as evidenced by the Goals of the Forest Plan, and in the Biodiversity and 

Forest Health sections, albeit these sections emphasize invasive plants. 

At the time of this writing, none of the alternatives propose changes to the 

management framework of the Tongass in relation to invasives and neither the 

Norway rat nor elk are addressed under the Forest Plan Monitoring section or 

standards and guidelines. However, the Alaska Region of the Forest Service is 

currently developing an invasive species strategy that will apply the principles of 

prevention, early detection, control, and rehabilitation in cooperation with various 

agencies and partners. 

Activities that create or enhance the habitats preferred by invasive species may 

facilitate range expansion. This premise can be used as a measure of how the 

alternatives potentially contribute to, or reduce, the invasive species problem. 

Norway rats inhabit coastal habitats where the main cause of range expansion, or 

source of new introductions, is shipping activity. Management activities on the 

Tongass have no effect on shipping activity and therefore will not influence the 

occurrence of Norway rats. 

In contrast, elk in Southeast Alaska have similar habitat requirements to black-tailed 

deer and therefore may benefit from habitat enhancement resulting from timber 

harvest. Timber harvest has been a precursor to both deer and elk population 

expansions in many parts of the western United States, due to the resulting increase 

in forage. Although, forest management activities on the Tongass will have no 

influence on the ability of elk to move between islands, they may affect the success 

of elk in colonizing new islands, particularly those in the vicinity of Zarembo and 

Etolin Islands where elk sightings are becoming more frequent, or the likelihood of 

expanding their distribution on larger islands where smaller populations exist. 

Elk, like deer, require a mosaic of habitat types for foraging, finding shelter, and 

obtaining security from predators and humans. Timber management activities that 

create gaps in the forest canopy create a favorable environment for the 

establishment and growth of early seral vegetation, thus increasing the abundance 

and variety of forage available to elk (Skovlln et al. 1989). However, because of 

their wariness, elk generally forage in proximity to hiding cover and are not likely to 

use the interior areas of large gaps due to the lack of accessible cover (Thomas 

1979). Elk have also been shown to avoid ongoing road construction and timber 

harvest, using adjacent areas of cover (e.g., late seral stands) until the conclusion of 

these activities. Therefore, over the short-term, elk will likely avoid areas of 

proposed timber harvest activities while activities are ongoing. However, over the 

long-term all of the alternatives have the potential to promote elk establishment in 

areas where they propose timber harvest. However, the extent to which this affects 

the expansion of the elk population is dependent upon the timing and location of 

timber harvest and associated activities. It is important to note however, that elk are 

a desired non-native species on Zarembo and Etolin islands where they were 

introduced. The Forest Service and ADF&G are working collaboratively to identify 
 Environment and Effects 3 

Final EIS 3-291 Wildlife 

research needs including determining existing population levels and documenting 

the distribution of elk on these islands and elsewhere. 

Alternate Risk Assessment Method 

To determine whether the alternatives provided sufficient habitat to sustain all 

indigenous wildlife across the planning area the Forest Plan FEIS relied in part on 

the findings of structured panel assessments. As described above these panel 

assessments provided estimates of the relative risk, in the form of a probability, that 

implementating the range of management alternatives would pose to the continued 

persistence across the landscape of an array of species. Scores from individual 

panel members were averaged to assign probabilities to 5 possible outcomes 

related to population distributions: occupancy of historic range (Outcome I), 

temporary gaps in distribution (Outcome II), permanent gaps in distribution 

(Outcome III), existence in refugia (Outcome IV), and local extirpation (Outcome V). 

Recently, Smith and Zollner (2005) argued that using the most vulnerable species to 

assess impacts of land management likely underestimates the probability of 

extinction of wildlife species across the planning area because the risk of local 

extirpation increases with the number of extinction prone species considered. 

Additionally, the management alternative that poses the greatest risk to the most 

vulnerable wildlife species may not pose the greatest risk to the wildlife community 

as a whole (Smith and Zollner 2005). The authors present an alternative method for 

assessing risk to wildife viability that considers the risk of “any” extinction among 

species at risk in the planning area. To accomplish this, an equation is used which 

calculates the joint probablitity of at least one extinction among the set of selected 

species to compare the relative, rather than absolute, risk of extinction among land 

management alternatives (see Appendix D and Smith and Zollner (2005) for the 

equation and for statistical details). 

This method was used to rank the current alternatives in terms of relative level of 

viability risk, in order to consider an alternate method for risk assessment. The 

likelihood scores assigned by the 1995/96 and 1997 expert panels were used to 

develop the index. Section 3.6 in Appendix D presents the results of this alternate 

risk assessment for Alternatives 4, 5, 6, and 7, which are the alternatives most 

easily related to the alternatives assessed by the risk assessment panels. 

Applying this risk assessment method indicates that, when all evaluated species are 

considered jointly, Alternatives 4 and 7 would have the greatest risks. This 

difference is driven primarily by potential risks to the endemic and widely distributed 

mammals groups, which have the highest risks of any species or group evaluated 

(Appendix D). The risk index was substantially lower for Alternatives 5 and 6. 

Because Alternatives 1, 2, and 3 would harvest less timber than Alternative 5 or 6, 

but maintain equivalent or more protective conservation measures, their risk indices 

would likely be lower than the corresponding indices for Alternatives 5 and 6. As 

expected based on harvest acres, the lowest risk indices would be associated with 

Alternative 1. 

Monitoring and Evaluation Program 

One facet of the Forest Plan amendment is a rigorous review of the Monitoring and 

Evaluation Program, including the MIS approach. As noted above, the MIS concept 

allows a manageable subset of species, whose response to land management 

activities can be used to predict the likely response of other species with similar 

habitat requirements, to be used in planning. Consistent with planning regulations 

under the NFMA, the Tongass has selected the list of 13 MIS described above and 

has developed monitoring strategies for each species to track population trends. 
3 Environment and Effects

Wildlife 3-292 Final EIS

Forest Plan Standards and Guidelines narrow the selection of suitable indicator 

species to emphasize management for indigenous wildlife species and natural 

habitat (WLD112 I(B)), and to provide the abundance and distribution of habitat 

necessary to maintain viable populations of existing native and desirable introduced 

species well distributed in the planning area (WILD112 II(B)). To achieve this, the 

MIS monitoring effort has been designed to determine if population trends for MIS 

and their relationship to habitat changes are consistent with expectations. 

An assessment of monitoring data collected since 1997 indicates several 

shortcomings. First, monitoring data are not collected at a scale, or with sufficient 

statistical rigor, to determine population status or trends for an area as expansive as 

the Tongass. Moreover, due to the inherent difficulty of monitoring many species, 

which is a fundamental problem underlying the MIS approach on the Tongass, data 

are derived from the best available sources, yet they are generally not appropriate 

for answering specific forest management monitoring questions. That is, they are 

not useful in identifying a link between habitat modification and population trends. 

Thus, there are few species actually able to provide insight into whether or not the 

Conservation Strategy is meeting wildlife objectives, as established by the Forest 

Plan. One challenge related to this is that limited funding may preclude the 

development of new monitoring strategies, or may be insufficient to support an 

increase in monitoring efforts to improve statistical rigor. It is important to note 

however, that these problems are not unique to the Tongass, as many national 

forests are evaluating their MIS lists, as well as the value of the MIS approach in 

general. 

One potential option for revising the Monitoring and Evaluation program under 

consideration is to shift the focus to a select number of ‘focal’ species that could be 

more intensively monitored. These species would likely be those that are most 

easily monitored, have the greatest economic and/or cultural value, or whose 

viability is of greatest concern. Another approach would be to use surrogate 

measures for monitoring impacts to species of concern, such as habitat 

characteristics (e.g., snag abundance) or prey species, which may be more 

conducive to monitoring. For example, focusing monitoring efforts on red squirrels, 

and establishing a relationship between their population trends and habitat 

modifications, may provide a better insight as to how management activities are 

affecting marten and goshawks than actually surveying for these species. The 

redesignation of MIS for the Tongass is continuing to be evaluated and new MIS are 

not being proposed at this time. Broader adjustments to the proposed Monitoring 

and Evaluation Program have been incorporated into the accompanying Forest 

Plan. 

Activities that occur on other land ownerships within and adjacent to the Tongass 

have the potential to affect the overall context within which effects of Forest 

management on wildlife population distribution and viability are considered. Such 

reasonably foreseeable activities include, but are not limited to, timber harvest, 

residential development, mining, recreation and tourism, and road construction. 

Typically these activities have the potential to negatively impact wildlife populations 

through habitat conversion, fragmentation, and disturbance associated with road 

building, though some activities can have short-term or long-term beneficial impacts, 

depending on the species (i.e., improved forage quality and quantity for deer 

following timber harvest). Prediction of the future extent and intensity of such 

activities has a high degree of uncertainty associated with it on a Forest-wide basis 

over a broad time scale. As such, cumulative effects associated with specific 

projects are most appropriately assessed at the project level. Therefore, this 

analysis will examine effects associated with general trends in activities on non-NFS 

lands. 

Cumulative 

Effects 
 Environment and Effects 3 

Final EIS 3-293 Wildlife 

Many private lands in Southeast Alaska are already highly developed in terms of 

roading and timber harvest and are likely to experience a continuing decline in oldgrowth forest in the future. Therefore, the cumulative long-term trend within the 

Forest boundary under all alternatives is likely to be a decline in optimum habitat for 

most old-growth associated species, with non-NFS land contributing to this trend. 

When combined with other management activities occurring on non-NFS lands, all 

alternatives would produce additional impacts to some species, but to varying 

degrees. Cumulative effects are anticipated to be the greatest under Alternative 7, 

which proposes the highest amount of timber harvest, followed by Alternatives 4, 5, 

6, 3, 2, and 1 in decreasing order, and would be most evident in areas where timber 

harvest is concentrated. Table 3.9-20 in the Biodiversity section summarizes the 

maximum long-term cumulative percent of the original POG that would be harvested 

in Southeast Alaska on all ownerships by biogeographic province. This table shows 

that the current cumulative past harvest on public and private lands equals 13 

percent of all POG in Southeast Alaska (87 percent POG retention). Looking 100+ 

years into the future, cumulative POG harvest levels on all lands of Southeast 

Alaska would vary by alternative, ranging from 18 percent (80 percent POG 

retention) under Alternative 1 to 29 percent under Alternative 7 (71 percent POG 

retention). Under Alternatives 5 (no action) and 6 (proposed action), projected 

cumulative harvest levels would be 24 percent (76 percent POG retention). The 

highest rates of cumulative harvest would be in the North Central Prince of Wales 

biogeographic province (49 percent under Alternatives 5 and 6), Dall Island and 

Vicinity (45 percent under Alternatives 5 and 6), the Chilkat River Complex (44 

percent under Alternatives 5 and 6), and Kupreano/Mitkof Island province (39 

percent under Alternatives 5 and 6). 

Cumulative harvest of high-volume and large-tree POG are summarized in Tables 

3.9-21 and 3.9-22 of the Biodiversity section. These results show that because of 

historic disproportionate harvest, especially on private lands, the current cumulative 

past harvest of high-volume and large-tree POG in Southeast Alaska is estimated at 

18 and 32 percent, respectively. Looking 100+ years into the future, cumulative 

high-volume POG harvest levels would again, vary by alternative, ranging from 25 

percent (75 percent high-volume POG retention) under Alternative 1 to 35 percent 

under Alternative 7 (65 percent high-volume POG retention). Under Alternaties 5 

(no action) and 6 (proposed action), projected cumulative harvest levels would be 30 

percent (70 percent high-volume POG retention). Similarly, for large-tree POG, 

cumulative harvest levels would range from 38 percent under Alternative 1 to 48 

percent under Altenative 7. Under Alternatives 5 and 6, projected cumulative 

harvest levels for large-tree POG would be 43 percent. 

Evidence from theoretical and empirical studies suggests that the likelihood of a 

population persisting over time is related to some threshold level of habitat loss 

across the landscape (Fahrig 1997, 1999, 2003; Flather et al. 2002; Andren 1994). 

Haufler (2006) reviewed the literature and found that, based on modeling, habitat 

loss and reduction of population size are linearly related, up to some threshold. 

Below this threshold, the additional effects of habitat fragmentation increase the rate 

of population reduction, and in turn, the risk of extinction. Haufler (2006) also 

concluded that empirical studies provided support for this relationship. 

Reported threshold levels for the percentage of habitat maintained at which the rate 

of landscape extinction increases range from 20 percent (Fahrig 1997) to 50 percent 

(Soule and Sanjayan 1998), depending in part on the dispersal capability of the 

species under consideration. In a modeling analysis, With (1999) demonstrated that 

landscape connectivity became a concern for species with some dispersal capability 

(e.g., wolves) when habitat was reduced to below 20 percent of the landscape, 

whereas when the landscape consisted of less than 40 percent habitat it became a 

concern for species with limited dispersal capabilities (e.g., flying squirrels). Natural 
3 Environment and Effects

Wildlife 3-294 Final EIS

fragmentation of habitats can also affect the level of additional fragmentation that 

can be supported. 

None of the alternatives would result in less than 71 percent of the original POG 

remaining on the Southeast Alaska landscape after 100+ years. In addition, at least 

51 percent of the original POG would be retained within each of the 23 individual 

biogeographic provinces under Alternatives 1, 2, 3, 5, and 6. Only under 

Alternatives 4 and 7, would this percentage fall below 50 percent, and then only in 

one province – North Central Prince of Wales (Table 3.9-20). Likewise, on a 

Southeast Alaska basis, none of the alternatives would result in less than 65 

percent of the original high-volume POG remaining after 100+ years. At least 41 

percent of the original high-volume POG would be retained in all 23 individual 

provinces under Alternatives 1, 2, 3, 5, and 6. In Alternatives 4 and 7, this 

percentage would decline to 39 and 33 percent in the North Central Prince of Wales 

province (Table 3.9-21). Finally, under each of the alternatives at least 52 percent 

of the large-tree POG would be retained over the entire landscape in Southeast 

Alaska after 100+ years. Under Alternatives 1, 2, 3, 5, and 6, this minimum 

percentage would range from 57 to 62 percent. For individual provinces, this 

percentage could drop as low as 31 to 33 percent in the East Baranof Island and 

Chilkat River Complex provinces under each of the alternatives, except Alternative 7 

(Table 3.9-22). Under the latter alternative, the minimum percentage in the 

Kupreanof/Mitkog province could decline to 29 percent. 

Although some wildlife species make higher use of the larger forest types defined by 

high-volume and large-tree POG, none of the wildlife species of concern are 

restricted to these habitats. In fact, all wildlife species make at least some use of 

types other than mapped POG (e.g., unproductive old-growth and older younggrowth forests). Therefore, based on the reported habitat loss thresholds, it is 

unlikely that cumulative timber harvest would result in significant viability concerns 

for any species of wildlife in any of the provinces, except under Alternatives 4 and 7. 

The reduction of POG to below 50 percent in North Central Prince of Wales 

province, coupled with the greater reduction of larger forest types, would result in 

greater long-term viability concerns in this province under Alternatives 4 and 7. 

Under these alternatives, species with low dispersal capabilities, in particular, would 

have landscape connectivity concerns over the long term. 

Additional effects, associated with the cumulative timber harvest described above, 

include road construction, which has the potential to impact wildlife species through 

habitat fragmentation, and access-related disturbance. Species that may be 

especially sensitive to this include forest interior species and large predators. Table 

3.10-10 summarizes existing and proposed total (open and closed roads) road 

density by the number of WAAs within road density categories on NFS and 

combined (NFS and non-NFS) land ownerships. Generally road densities on private 

and state lands are greater than those found on adjacent NFS lands. In addition, 

there are no road closure/access management guidelines in place on these lands to 

reduce effects to sensitive species. The greatest cumulative road densities (NFS 

and non-NFS lands) would occur under Alternative 7, followed by Alternatives 4, 5 , 

6, 3, 2, and 1. Maximum (i.e., proposed under Alternative 7) cumulative road 

densities would be greatest on Prince of Wales, Kupreanof, and Chichagof islands 

where a number of WAAs would exceed total road densities of 2 miles per square. 

Therefore the potential for habitat fragmentation, increased human access, and 

overharvesting of some species would be greatest under Alternative 7 followed by 

Alternative 4, followed by Alternatives 5, 6, 3, 2, and 1. 

Cumulative habitat disturbance is especially problematic for archipelagos such as 

the Tongass, where habitat is already naturally fragmented among oceanic islands, 

average population size is smaller than in mainland habitats, source populations are 

isolated, and demographic stochasticity and inbreeding depression increase risk of 
 Environment and Effects 3 

Final EIS 3-295 Wildlife 

extinction (Cook et al. 2006). This is particularly pertinent for endemic taxa (e.g., 

POW flying squirrel) that already exist in isolated populations by default, and for 

species that are less mobile (e.g., spruce grouse). The Conservation Strategy was 

designed to address this through the network of non-development LUDs, including 

the OGR system, and Forest-wide standards and guidelines both of which were 

intended to maintain habitat components important to a variety of species and 

maintain connectivity across the landscape. Alternative 5 would continue to do so 

by maintaining all elements of the current Forest Plan. By proposing less harvest 

and strengthening some of the existing standards and guidelines, Alternatives 6, 3, 

2, and 1 in increasing order would have a greater chance of maintaining wildlife 

habitats and connectivity. However, because the Conservation Strategy is 

weakened under Alternatives 4 and 7, and these alternatives proposed the greatest 

amount of harvest and road construction, these alternatives would result in greater 

habitat loss, fragmentation and population isolation, and therefore have the greatest 

relative risk of not sustaining well distributed, viable wildlife populations across the 

Tongass over the long-term. 

While this analysis is informative and updates the analysis of cumulative effects, it is 

important to note that the conclusions drawn by the wildlife viability panels done for 

the 1997 Forest Plan and brought forward for this Amendment fully considered the 

level of past and likely future harvest and associated development on non-NFS 

lands. Likelihood scores recognized the combined effects of harvest and road 

development on these land ownerships. Therefore, the viability ratings represent a 

cumulative effects prediction for each alternative. The goshawk, deer, marten, and 

marbled murrelet panels identified habitat loss as a key impact of the alternatives on 

these species. The old-growth reserve system was specifically identified as being 

important to the likelihood of maintainging viable, well-distributed populations of 

marbled murrelets, marten, and goshawks. Population isolation resulting from 

habitat fragmentation and barriers to migrating individuals in some biogeographic 

provinces was also identified as a key impact of the alternatives on endemic 

mammals. Effects associated with human access associated with road 

development were identified as key impacts to brown bears (in relation to DLP 

mortality and hunting pressure) and wolves (in relation to legal and illegal hunting 

and trapping). 

Because wildlife populations exist across all land ownerships, managing adverse 

effects of management activities on wildlife often must be dealt with collaboratively. 

In addition, the population viability and distribution of wildlife on the Tongass is 

influenced in part by state and federal regulatory mechanisms such as harvest 

limits, season length, and population management objectives. Overall, the wildlife 

resources and associated habitat on the Tongass remain in good condition and are 

mostly dominated by old growth. As development continues through timber harvest, 

associated activities, and community expansion, particularly in areas where 

extensive development has already occurred (i.e., Prince of Wales Island) 

maintaining connectivity and roadless refugia will become increasingly important, 

particularly for wide-ranging species whose distribution depends on the availability 

of travel corridors and known “pinch-points” to access important habitats and move 

across the landscape. In addition, the management of human resources will 

continue to play a role in the viability and distribution of wildlife across the Forest.

While research since 1997 has provided a wealth of information on wildlife 

populations and habitat relationships in Southeast Alaska, there continue to be gaps 

in knowledge about the ecology and distribution of many species and direct 

correlations between land management activities and population impacts. The 

conservation strategy itself is a major step toward maintaining landscape 

connectivity on the Tongass, however, the effectiveness of its reserves and buffers 

in relation to their size, landscape pattern, and geographic distribution has yet to be 

scientifically tested (Powell et al. 1997). The future importance of individual 
3 Environment and Effects

Wildlife 3-296 Final EIS

elements of the conservation strategy in terms of their ability to support welldistributed and viable wildlife populations given potential cumulative effects of 

activities on forest system and non-forest system lands will depend on the direction 

of future managment activities (i.e., whether road construction will be prohibited in 

currently roadless areas, whether timber harvest will occur in pristine watersheds, 

etc.; Hanley 2005). However, despite these uncertainties, the risks associated with 

implementation of the Forest Plan are very low. The life of this amendment is 

expected to be 10 to 15 years at most, at which time another review will be 

undertaken. The current levels of harvest and road construction are at a 5-decade 

low and even if timber sales are made available and the timber industry responds 

very rapidly, there will be a period of preparation and transition prior to reaching the 

maximum harvest level allowed by the ASQ, particularly if one of the higher ASQ 

alternatives is selected.. Therefore, it is estimated that old-growth harvest levels are 

likely to be well below the maximum values evaluated in this EIS. 

The effects of climate change may also contribute to cumulative effects. Warmer 

temperatures and decreased precipitation are anticipated to result in changes to 

vegetation and thus, the suitability of wildlife habitat, among other impacts (see 

Climate and Air section). Although many species may benefit (e.g., greater 

overwinter survival of deer, and thus a greater prey base for wolves, resulting from 

warmer winter termperatures during normal years), habitat changes resulting from a 

longer growing season, wind, fires, insect infestations, and disease may have 

variable effects on others. For example, Juday et al. (1998) concluded that the 

dramatic increase in gale force winds in coastal Alaska since the 1970s suggests 

that the risk of windthrow will be much greater in the future. 

The greatest concerns for wildlife populations in relation to climate change, 

however, are the weather extremes that can be expected to occur periodically 

(Bermann et al. 1998). Periodic severe winter snowfalls, which may seem 

counterintuitive given the general warming trend, are anticipated (Juday et al. 1998). 

These stochastic events would be of greatest concern for populations that are 

limited in number or distribution. The predator-prey dynamic of wolves and deer 

provide an example of one system where these effects may be realized. Preliminary 

modeling has shown that during periodic severe winters reduced deer habitat 

capability due to snowfall would result in a disproportionately greater decline in the 

deer population (Person 2001). This could have repercussions on the wolf 

population, whose trends in size and volatility are sensitive to the available habitat 

capability for deer. At this time, no models exist that can be used in Forest Planning 

to accurately predict these effects. Some authors have noted though that the most 

effective means for managing for climate change impacts is through the 

development of ecosystem resistence which can be accomplished by maintaining a 

reserve system where active management is minimized (WWF 2003, Noss 2001). 

Thus the Forest Plan, with the reserve system through the conservation strategy 

represents a valid method to maintain a resilent ecosystem in the face of uncertain, 

future change. 

.
Environmen

Final EIS 3-297 

Table 3.10-10. Estimated Maximum Average Road Density and Percent of WAAs in Road Density Categories on NFS L

Lands Combined2 for All Roads and for Open Roads Only within the Tongass National Forest Boundary 

100+ Years 

Percentage of WAAs 

Existing Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 A

Road Density 

Category 

(miles per sq. 

mi.)

NFS 

Lands 

Only 

All 

Lands 

NFS 

Lands 

Only 

All 

Lands 

NFS 

Lands 

Only 

All 

Lands 

NFS 

Lands 

Only 

All 

Lands 

NFS 

Lands 

Only 

All 

Lands 

NFS 

Lands 

Only 

All 

Lands 

NFS 

Lands 

Only 

All Roads 

0 38.8% 34.6% 38.3% 15.7% 37.8% 15.7% 33.0% 15.2% 27.1% 13.1% 31.4% 14.7% 30.9% 

0 to 0.7 47.3% 46.1% 44.7% 58.1% 41.5% 55.5% 43.6% 54.5% 44.1% 49.7% 41.0% 50.8% 41.5% 

0.7 to 1.0 5.9% 5.2% 5.9% 6.3% 4.3% 5.8% 5.9% 6.3% 5.9% 8.9% 8.5% 8.4% 9.6% 1.0 to 2.0 7.4% 11.0% 8.5% 13.1% 13.8% 15.2% 13.8% 15.2% 18.1% 18.3% 14.9% 17.3% 13.8% 2.0 to 3.0 0.5% 3.1% 2.7% 5.2% 2.7% 6.3% 3.7% 7.3% 4.8% 8.4% 4.3% 7.3% 4.3% 

>3.0 0.0% 0.0% 0.0% 1.6% 0.0% 1.6% 0.0% 1.6% 0.0% 1.6% 0.0% 1.6% 0.0% 

Average Total Road Density – All WAAs 0.19 0.31 0.26 0.43 0.29 0.46 0.32 0.49 0.40 0.56 0.35 0.52 0.35 Open Roads 

0 54.3% 45.5% 53.2% 18.3% 52.1% 18.3% 46.3% 17.3% 36.2% 14.7% 41.5% 16.2% 41.0% 

0 to 0.7 40.4% 40.8% 41.5% 63.9% 42.6% 63.4% 48.4% 63.9% 58.5% 66.5% 53.2% 64.9% 53.2% 

0.7 to 1.0 4.3% 5.8% 4.3% 4.7% 3.7% 5.2% 3.2% 5.8% 3.2% 5.8% 3.2% 5.8% 3.7% 1.0 to 2.0 1.1% 6.8% 1.1% 8.9% 1.6% 8.9% 2.1% 8.9% 2.1% 8.9% 2.1% 8.9% 2.1% 2.0 to 3.0 0.0% 1.0% 0.0% 3.1% 0.0% 3.1% 0.0% 3.1% 0.0% 3.1% 0.0% 3.1% 0.0% 

>3.0 0.0% 0.0% 0.0% 1.0% 0.0% 1.0% 0.0% 1.0% 0.0% 1.0% 0.0% 1.0% 0.0% 

Average Open Road Density – All WAAs 0.10 0.23 0.10 0.23 0.10 0.23 0.11 0.23 0.11 0.23 0.11 0.23 0.11 1 For NFS Lands, percentages are based on 188 WAAs that contain at least 100 acres of NFS lands. 2 For All Lands combined, percentages are based on all 191 WAAs inside the Forest boundary, including Annette Island.
3 Environment and Effects

Wildlife 3-298 Final EIS

This page is intentionally blank. 
 Environment and Effects 3 

Final EIS 3-299 Lands 

Human Uses and Land Management 

Lands 

Affected Environment............................................................................. 3-299

Land Ownership Administration and Adjustment................................... 3-300

Land Acquisition..................................................................................... 3-304

Withdrawals/Encumbered Areas............................................................ 3-305

Special Use Authorizations .................................................................... 3-305

Environmental Consequences............................................................... 3-307

Direct and Indirect Effects...................................................................... 3-307

Cumulative Effects ................................................................................. 3-308

Affected Environment 

This section addresses land ownership administration and adjustments and special 

uses of Tongass National Forest System (NFS) lands. Transportation and utility 

systems and land uses related to minerals are discussed in separate sections. 

Adjustment of land ownership within the Tongass boundaries can occur through 

Congressionally mandated conveyances, exchanges, and acquisitions, or through 

Forest Service administrative activities. Authorized special uses on the Tongass 

include industrial or commercial uses, such as commercial fishing camps, 

transportation facilities, electronic and other communications sites, and a variety of 

recreational uses. The Recreation section of the EIS discusses the recreation special 

uses; non-recreation special uses are discussed below. (Appendix E to the Forest 

Plan lists the approved communications sites on the Tongass.) 

The exterior boundary of the Tongass National Forest established by Congress 

includes lands that had been conveyed to other ownership both prior and 

subsequent to creation of the Forest. Table 3.11-1 indicates the distribution of 

acreage by ownership type within the exterior boundary. Of the approximately 

17,867,000 total acres (based on GIS analysis), nearly 16,774,000 acres (nearly 94 

percent of the total) are federal lands administered by the Forest Service (this total 

includes lakes surrounded by NFS lands). The State of Alaska accounts for the 

largest non-federal ownership, with about 286,000 acres or almost 2 percent of the 

total (this figure does not include lakes surrounded by NFS lands). The Alaska 

Native regional corporation (Sealaska) accounts for approximately 293,000 acres, 

and 12 village corporations collectively own another 287,000 acres. The remaining 

acreage consists of lands owned by units of local government (cities and boroughs), 

private lands, and miscellaneous ownerships. 
3 Environment and Effects

Lands 3-300 Final EIS

Table 3.11-1 

Land Ownership Distribution, Tongass National Forest1

Ownership Type Acres Percent of Total 

Federal/Forest Service administered2 16,774,000 93.9 

State of Alaska3 286,000 1.6 

Local Governments 44,000 0.2 

Native Regional Corporation 

(Sealaska) 

293,000 1.6 

Native Village Corporations 287,000 1.6 

Private Owners and Unknown 183,000 1.0 

Total 17,867,000 100 

1 Table indicates calculated ownership of total acreage within the exterior boundary of the Tongass 

National Forest. 2 Figure includes 296 acres administered by other federal agencies. Figure includes lakes surrounded 

by NFS lands. 3 Figure does not include lakes surrounded by NFS lands. 

Source: USDA Forest Service 2007 

A number of land adjustments have occurred on the Tongass since the adoption of 

the 1997 Forest Plan. Some lands have been conveyed from federal to other 

ownership, and these adjustments need to be documented on the Forest Plan 

maps. New lands that have become NFS lands during this period have not been 

formally given LUD designations. Specific designations need to be updated in a 

Forest Plan amendment. 

From 1998 through August 2006, 50,277 acres of Tongass National Forest lands 

were conveyed to other entities. Most of these land adjustments were conveyances 

to the State of Alaska and Native corporations as authorized by the Statehood Act 

and the Alaska Native Claims Settlement Act of 1971 (ANCSA), and conveyances of 

Alaska Native Allotments as authorized by the 1906 Alaska Native Allotment Act. 

This acreage figure also includes parcels conveyed through land exchanges, a 

Small Tracts Act sale, and the disposal of two lighthouse reserves. Through land 

exchanges, purchases, and donations, the United States acquired 5,864 acres of 

new lands for inclusion within the Tongass during the same period. The balance of 

conveyances and acquisitions represents a net decrease of 44,413 acres of federal 

ownership. 

Legislated Alaska Conveyances 

Land ownership status within the Tongass is complicated by several ongoing Alaska 

land conveyances created under various federal legislation (USDA Forest Service 

2003b). The Alaska Native Allotment Act of 1906 provided for Native individuals who 

had occupied lands prior to their designation as national forest to apply for 

conveyance of up to 160 acres, under conditions prescribed by the Act and federal 

regulations. As of August 2006, approximately 4,500 acres in 44 Native allotments 

had been conveyed, with an additional 3,500 acres pending adjudication by the 

Bureau of Land Management (BLM). 

The 1958 Alaska Statehood Act authorized the State of Alaska to select 400,000 

acres of vacant and unappropriated land from within the Tongass and Chugach 

National Forests in Alaska, to further the development and expansion of Alaskan 

communities. To date, under this provision of the Statehood Act, the state has 

received title to approximately 258,600 acres located in the Tongass National 

Forest. Approximately 37,400 acres remain to be conveyed to the state from the 

Chugach and Tongass National Forests. 

Land Ownership 

Administration 

and Adjustment 
 Environment and Effects 3 

Final EIS 3-301 Lands 

ANCSA established processes for transfer of federal land to Alaska Native village 

corporations and regional corporations, and to Native individuals. ANCSA provided 

for the conveyance of 23,040 acres of surface estate lands (a full township, 36 

square miles) to each of the 10 Native village corporations and 2 urban corporations 

located in Southeast Alaska. ANCSA provided that the subsurface estate under the 

village and urban corporation land would be conveyed to the Native regional 

corporation. ANCSA also included other provisions addressing land conveyances to 

Native regional corporations. Under Section 12c of ANCSA, 11 regional 

corporations were to share in the selection of 16 million acres. Section 14(h)(8) set 

aside a pool of 2 million acres to be transferred to the Native regional corporations in 

the state after certain other conveyances are completed. After the specified 

conveyances have been implemented, the remaining land in the pool will be divided 

among the regional corporations based on population, with approximately 22 

percent of the balance going to Sealaska Corporation, the regional corporation for 

Southeast Alaska. Finally, ANCSA provided for selection and transfer of up to 160 

acres to Native individuals who had occupied that land as a primary place of 

residence on August 31, 1971. 

To date, approximately 571,000 acres within the Tongass have been conveyed 

under ANCSA. Each of the 10 Native village corporations and 2 urban corporations 

in Southeast Alaska has selected its authorized acreage; virtually all of that land has 

been conveyed, amounting to a total of approximately 279,000 acres. 

Approximately 292,000 acres have been conveyed to date to Sealaska Corporation, 

in addition to the subsurface estate under the lands owned by the village and urban 

corporations. Sealaska has selected about 171,000 additional acres. It is expected 

that approximately 64,000 acres of these lands will be conveyed to Sealaska. 

Potential Future Conveyances 

The major land conveyances described above have been authorized by Acts of 

Congress and implemented through additional legislation and regulations. In recent 

years there have been a number of other formal and informal proposals that, if 

authorized, might result in the transfer of Tongass NFS lands out of federal 

ownership. Several of these conveyance proposals are summarized below (see 

Appendix C for more detailed information): 

• Southeast Alaska Native Land Entitlement Finalization Act. This bill was 

introduced in Congress in late 2007 as H.R. 3560, and is to provide for the 

completion of certain land selections by Sealaska under ANCSA and for other 

reasons. This legislative proposal represents the evolution of a Sealaska 

proposed land exchange (discussed below under Land Exchanges); however, 

the bill, as introduced, more closely resembles a conveyance rather than a land 

exchange. The bill allows Sealaska to select its remaining entitlement from 

areas outside the ten Southeast Alaska village withdrawal areas. It authorizes 

Sealaska to select and receive conveyance of its remaining land entitlement 

from three categories including economic development lands; sites with sacred, 

cultural, traditional, or historic significance; and Native enterprise sites. 

• University of Alaska Lands Bill. Under the terms of Senate Bill 293, 

introduced in Congress on February 3, 2005, the University of Alaska would be 

allowed to select up to an additional 250,000 acres of federal land that would be 

managed to provide income for the university system. If enacted, the university 

would not be allowed to select lands within a federal conservation system area 

(e.g., a national park or a wilderness area) or Tongass NFS lands other than 

those within development Land Use Designations (LUDs), and the selections 

would be limited to areas of second-growth timber where timber harvest 

occurred after January 1, 1952. 
3 Environment and Effects

Lands 3-302 Final EIS

• Unrecognized Southeast Alaska Native Communities Recognition and 

Compensation Act. Senate Bill 1746, introduced on June 29, 2007, proposes 

to allow Alaska Native residents of Haines, Ketchikan, Petersburg, Tenakee 

Springs, and Wrangell to organize as five Urban Corporations and to each 

receive 23,040 acres of surface estate lands and other compensation. 

(Sealaska Corporation would receive the subsurface estate to these lands.) 

These five communities were not included among the villages authorized to form 

corporations and receive land entitlements in 1971 under ANCSA, presumably 

because they did not meet the eligibility requirements. The language in Senate 

Bill 1746 does not identify the specific areas that would be available for selection 

and/or conveyance. 

• Alaska Natives Veterans Land Allotment Equity Act. Introduced on August 

2, 2007, as House Bill 3350, this proposes to redress certain obstacles created 

by the 1998 Alaska Native Veterans Allotment Act (Public Law 105-276). That 

Act amended ANCSA to provide Alaska Native veterans another opportunity to 

apply for a Native allotment of up to 160 acres of land under the repealed Native 

Allotment Act of 1906 (discussed above). This Act intended to compensate for 

the fact that Natives serving in Vietnam may not have been able to apply for 

their allotments prior to closure of the allotment program. The 1998 legislation 

contained several provisions regarding federal land status, prior use of the 

claimed land, and eligible military service dates that may be viewed by some as 

barriers to Native veterans obtaining their allotments. 

• Alaska State Forest Proposal. State officials or interests have at times 

advocated the establishment of an additional Alaska State Forest to be 

managed to provide income for state government programs. One concept for 

such a management unit was for a 2-million-acre area on or near Prince of 

Wales Island, which would require transfer of extensive areas of current 

Tongass NFS lands to the State. To date, no federal legislation to implement 

such a proposal has been introduced in Congress. 

Land Disposal 

Federal agencies responsible for administering public lands sometimes dispose of 

lands to other governments or private parties. Such disposals typically involve 

relatively small land parcels that have been determined to be “surplus” or “excess” 

property under federal property regulations. 

With respect to the Tongass, one example of land disposal involves the conveyance 

of historic lighthouse or light station properties in Southeast Alaska that have been 

managed jointly by the U.S. Coast Guard and the Forest Service. The National 

Historic Lighthouse Preservation Act of 2000 authorizes the General Services 

Administration (GSA) to dispose of historic light stations to “eligible entities” that are 

required to make the light stations available to the general public for education, park, 

recreation, cultural, or historic preservation purposes (USDA Forest Service 2005c). 

The Forest Service has been working with GSA to dispose of light stations while 

granting Forest Service easements to the recipients for occupancy of the underlying 

NFS lands. Two light stations have been disposed of under this program; four other 

stations have been identified as candidates for disposal. Most of these stations 

have small land reserves associated with them, although the Forest Service is 

working with the Coast Guard and BLM to reduce the acreage of larger reserves 

associated with some stations. 
 Environment and Effects 3 

Final EIS 3-303 Lands 

Land Exchanges 

Administrative land exchanges, in which NFS lands can be conveyed to another 

entity in exchange for lands of equal value, are another form of land ownership 

adjustment. Complex land exchanges are sometimes authorized by Congress 

through special legislation. In addition to the Alaska conveyances discussed above, 

the Forest Service has completed several land exchanges involving Tongass NFS 

lands. These adjustments are summarized below: 

• Under the Kake Tribal Corporation Land Transfer Act (Public Law 106-283), 

approved by Congress on October 6, 2000, the Forest Service was directed to 

convey 1,389 acres of Tongass NFS lands (which had previously been selected 

by the State of Alaska) in the Jenny Creek area near Kake to the Kake Tribal 

Corporation. This Act also provided for transfer of 1,430 acres of land owned by 

the Kake Tribal Corporation and Sealaska to the City of Kake an exchange of 

the subsurface estate (mineral rights) for two areas (each of over 1,100 acres) 

between the Forest Service and Sealaska. The Act, technically an amendment 

to ANCSA, was enacted to provide protection and management of the Kake 

municipal watershed. 

• Under the Hood Bay Land Exchange, the Forest Service received a 54-acre 

parcel that had formerly been a private inholding within Admiralty Island National 

Monument and the Kootznoowoo Wilderness (USDA Forest Service 2006c). 

The United States conveyed and relinquished all reversionary interests on 144 

acres of land at Sitka to the Alaska Pulp Corporation. 

• Through an exchange with the Kennecott Greens Creek Mining Company, Inc., 

the Forest Service received one 50-acre parcel within the Misty Fiords National 

Monument Wilderness and two parcels totaling approximately 139 acres within 

Admiralty Island National Monument Kootznoowoo Wilderness (USDA Forest 

Service 2006c). The United States conveyed the subsurface mineral estate on 

7,301 acres at Hawk Inlet/Young Bay on Admiralty Island. 

There have also been discussions regarding potential future land exchanges 

between the Forest Service, a number of Native corporations, and other entities that 

could adjust land ownership on the Tongass. 

In late 2007, Shee Atika, Incorporated (an Alaska Native Village Corporation) 

approached the Forest Service about a possible exchange of NFS lands on West 

and North Yakobi Island and on western Chichagof Island, for Shee Atika surface 

estate located at Cube Cove. Both parties are discussing the concept and neither 

party has made any binding commitments on proceeding further. 

Also in late 2007, the Trust Land Office (State of Alaska, Department of Natural 

Resources) representing the Mental Health Trust Authority, presented a conceptual 

proposal to the Forest Service to exchange approximately 20,000 acres of lands 

managed by the Trust Land Office in Southeast Alaska for an equal value of 

Tongass National Forest lands on Prince of Wales Island. The parcels the Trust has 

offered for exchange are mostly adjacent to NFS lands and are also adjacent to, or 

in the immediate vicinities of, Skagway, Juneau, Petersburg, Wrangell, Sitka, and 

Ketchikan. At this point, the Forest Service is considering the concepts of the 

proposal and has made no agreements on whether or not it will pursue this 

exchange further. 

The potential exchange that has received the most attention and discussion is 

known as the Sealaska Proposed Comprehensive Tongass-wide Land Exchange 

(USDA Forest Service 2005d). In August 2002, Sealaska Corporation submitted a 

proposal to the Forest Service to exchange approximately 100,000 acres of NFS 
3 Environment and Effects

Lands 3-304 Final EIS

lands for Sealaska Corporation lands and selection rights under ANCSA. The 

Tongass-wide exchange proposed by Sealaska involves lands throughout 

Southeast Alaska. The goals of the exchange are to consolidate NFS lands and 

Sealaska lands, and to finalize Sealaska’s remaining land selections under ANCSA. 

This proposal has recently evolved into the Southeast Alaska Native Land 

Entitlement Finalization Act which has been introduced in Congress (see above 

under Potential Future Conveyances). 

At present, about 171,000 acres in the ANCSA withdrawal areas are encumbered by 

Sealaska selections. Other lands within these areas have not been selected by a 

Native corporation but will remain withdrawn until the ANCSA conveyances are 

completed. 

Based on current information from BLM, Sealaska has approximately 64,000 acres 

of lands yet to be conveyed. This includes approximately 20,000 acres of 

unconveyed ANCSA entitlement under Section 14(h)(8), in addition to approximately 

44,000 acres of 14(h)(8) lands resulting from the 2004 Alaska Land Transfer 

Acceleration Act, P.L. 108-452. 

The proposed land exchange would enable Sealaska to acquire other lands outside 

of the ANCSA withdrawal areas, in addition to the Native heritage 14(h)(1) parcels. 

This is not authorized under ANCSA except by exchange. Land exchanges are 

discretionary, voluntary real estate transactions between federal and non-federal 

parties. At present, there is no binding land exchange agreement in place signed by 

the Forest Service and Sealaska that would enable Sealaska to receive lands 

outside of the withdrawal areas. 

The Forest Service completed a draft feasibility report on the exchange proposal in 

2003. After lengthy discussions and several modifications to the proposal, in 2005 

the Forest Supervisor informed Sealaska that the Forest Service was not willing to 

move forward with the exchange because of a lack of substantial agreement on the 

parcels to be exchanged, concerns over a variety of resource issues, and the need 

for a revision to the Forest Plan to accommodate the exchange due to the 

magnitude of the resulting changes in LUDs. 

Land Acquisition 

Land ownership adjustments can also occur through the outright purchase of lands 

or the acceptance of land donations for inclusion in the Forest. Purchases typically 

involve small inholdings, always involve a willing seller, and usually involve parcels 

surrounded by designated wilderness or other sensitive resource lands. Since 

1997, the Forest Service has acquired 17 parcels totaling approximately 5,864 acres 

of land in various locations within the Forest (USDA Forest Service 2006c). These 

figures include the parcels obtained through the Hood Bay and Greens Creek 

exchanges discussed above; apart from these exchanges, the acquisitions total 12 

parcels and 5,621 acres. The largest acquisition involved two parcels and 2,939 

acres near Petersburg Creek and 1,045 acres at Mt. Verstovia near Sitka. Other 

purchases included an Unuk River parcel in the Misty Fiords National Monument 

Wilderness and parcels at Favorite Bay and Hood Bay in the Admiralty Island 

National Monument/Kootznoowoo Wilderness. Donations included a parcel at Cape 

Bingham and two at Bohemia Basin, including portions in the West ChichagofYakobi Wilderness in both locations, and a parcel at Windham Bay in the Chuck 

River Wilderness. 

The Forest Service obtained the Petersburg Creek and Verstovia parcels through a 

legislated program with the State of Alaska Mental Health Land Trust, which has as 

its mission to generate revenue to support mental health services in Alaska. 
 Environment and Effects 3 

Final EIS 3-305 Lands 

Congress directed the Forest Service to purchase lands from the Trust and 

allocated funds for the purchases. The Forest Service is currently working on an 

acquisition in the Deer Mountain area near Ketchikan, which will be the last 

component of this program. 

Congress has directed the Forest Service to make a similar purchase under the 

Craig Recreation Land Purchase Act (PL 108-325), passed in October 2004. The 

Act provides for the Forest Service to acquire the surface rights to approximately 

350 acres surrounding and near the Sunnahae Trail from the City of Craig (USDA 

Forest Service 2005e). The city would use the funds received under this acquisition 

to purchase 10 acres of property within Craig for harbor expansion, development, 

and other purposes. Congress has not yet appropriated funds for the purchase of 

the Sunnahae Trail lands. 

Withdrawals/Encumbered Areas 

Withdrawals and encumbrances are other key aspects of land ownership 

administration. Withdrawal is the withholding of an area of federal land from 

settlement, sale, mineral location, or entry under some or all of the general land laws 

for the purpose of limiting activities under those laws in order to maintain public 

values in the area. In general, an encumbrance is a claim, lien, charge, or liability 

attached to and binding real property (Black 1979, as cited in USDA Forest Service 

2003b). In the context of the Tongass, an encumbrance is a land claim of some 

type that removes NFS lands from the full range of Forest Service administrative 

functions. 

By acreage, the largest withdrawal action applies to the more than 5.7 million acres 

in designated wilderness areas, which are withdrawn from entry under the mining 

laws. Many of the administrative withdrawals date back several decades and 

include withdrawals around lighthouse and light station sites, and a large number of 

power site withdrawals intended to preserve options for hydroelectric development 

at promising sites. 

The land conveyance processes established by ANCSA delineated areas of federal 

lands within which Native village corporation land selections were to be located. 

These areas, totaling an estimated 1.8 million acres (including large areas of 

saltwater) on the Tongass, were withdrawn and will likely remain encumbered in the 

land status records until all lands to which the Native corporations are entitled have 

been conveyed. Other areas of the Forest have not been formally withdrawn, but 

are similarly encumbered as a result of land selections. For example, while the 

Alaska Statehood Act did not withdraw specific federal land areas identified for land 

selection by the state, those lands that have been selected by the state but not yet 

conveyed are nevertheless encumbered. Likewise, Native allotments that have 

been claimed but not conveyed and a number of small-scale Sealaska selections 

under ANCSA Section 14 (h)(1) are outside of the ANCSA withdrawal areas and are 

encumbered. Altogether, approximately 395,000 acres of Tongass NFS lands are 

encumbered by such transitional ownership situations (USDA Forest Service 

2006e). 

Uses of NFS lands by entities other than the Forest Service can be authorized under 

a special use permit, subject to applicable regulations found in 36 CFR 251. 

Generally, most permits are issued for periods of 5 years or less. Complex permits 

for long-term uses such as hydroelectric facilities may be issued for periods of up to 

50 years. As of August 2006, there were 715 special use permits currently issued 

on the Tongass. The number of permits on the Tongass at any given time may 

fluctuate between 700 and 750. Nearly half of the permits issued on the Tongass 

Special Use 

Authorizations 
3 Environment and Effects

Lands 3-306 Final EIS

are related to outfitter and guiding and other recreational uses of NFS lands. The 

remainder involve a wide variety of uses including, but not limited to, 

communications sites, roads, cabins, organization sites, hydroelectric projects, 

temporary facilities, aquatic farming activities, military training, sanitary landfills, and 

fish camps. 

Communication and Other Electronic Sites 

A communication or other electronic site is a dedicated land use allocation of NFS 

land. These sites are used for electronic communication systems, including 

electronic transmitters, receivers, and passive microwave reflectors. These uses of 

federal land are authorized by the Federal Land Policy and Management Act of 

1976 and the Telecommunications Act of 1996. As of August 2006, there were 69 

designated electronic sites throughout the Tongass (see Appendix E to both the 

1997 Tongass Land and Resources Management Plan and the proposed Forest 

Plan Amendment). Fifty-two (52) of these sites were occupied under special use 

permits by non-Forest Service parties, while the remaining sites are for Forest 

Service facilities. A few of the sites have several special uses authorized. The 

majority of sites are limited to one user. All sites are currently open to more than 

one user if the need arises. Some of the sites are operated by the Coast Guard, the 

Federal Aviation Administration, the National Weather Service, and a variety of other 

private and public entities. Applicants for new communications uses will be 

encouraged to co-locate their facilities at existing, approved sites. 

Recreation-Related Permits 

As of August 2006, the Forest Service administers 390 special use permits for 

purposes related to recreation. These included 275 outfitter/guide permits, 65 

isolated cabins, and 15 recreation residences. Isolated cabins and recreation 

residences, although similar in many ways, are managed differently because of the 

different authorities used to grant use and occupancy. Construction of new cabins is 

regulated by Alaska National Interest Lands Conservation Act of 1980 (ANILCA) and 

generally prohibited, except under limited circumstances. Existing cabins are 

expected to decrease in number over time as a result of ANILCA direction limiting 

the transfer of permits.

Camps and Cabins 

Two organization camps operated on the Tongass under special use permit in 2005. 

Based on prior authorizations, the Forest Service also administered 15 permits for 

summer homes or recreational cabins. Construction of new cabins is prohibited 

except under quite limited circumstances, and the existing cabins are expected to 

decrease in number over time as a result of restrictions on transfer of the permits. 

Roads and Rights-of-Way 

Inholders and other landowners are allowed reasonable access across NFS lands to 

use their own lands under provisions of ANILCA and other federal laws. Easements 

are also issued to the Alaska State Department of Transportation for state-managed 

highways. The Forest Service administered 39 easements or right-of-way permits in 

2006. The types of authorizations include 1 railroad right of way, 1 Department of 

Transportation easement, 13 Forest Road and Trail Act easements, 4 Federal Land 

Policy and Management Act easements, and 20 Federal Land Policy and 

Management Act rights-of-way. 
 Environment and Effects 3 

Final EIS 3-307 Lands 

Other Special Uses 

Non-recreation special use authorizations accounted for 325 permits in August 

2006. Types of uses in this group included hydroelectric projects, mariculture- and 

agriculture-related activities, uses for schools and municipalities, weather 

monitoring, filming and photography, and power lines. 

Hydroelectric Projects. There are 11 existing hydropower projects on the Tongass 

that are operated under license from the Federal Energy Regulatory Commission 

(FERC). Of the 11, 8 are also under special use permit from the Forest Service and 

authorized under the Federal Land Policy and Management Act. As of August 2006, 

there were an additional 11 proposed projects that are in various stages of the 

FERC licensing process. 

The Forest Service is currently conducting environmental review under the National 

Environmental Policy Act (NEPA) for the proposed Angoon hydroelectric project, 

located approximately 6 miles north of the City of Angoon on Admiralty Island. 

Kootznoowoo, Incorporated, the Native village corporation for Angoon, proposes to 

develop a 1 megawatt hydro project on Thayer Creek to supply electricity for 

Angoon. The project is authorized under ANILCA Section 506(a)3(B), subject to 

conditions imposed by the Forest Service, and is not subject to the Wilderness Act 

of 1964. FERC has determined that it does not have jurisdiction over the project 

because Admiralty Island is a Congressionally designated National Monument on 

NFS lands. Therefore, FERC is not involved in project review. As directed by 

ANILCA, the Forest Service will issue special use permits, with specified conditions, 

to allow construction and operation of the project when the environmental analysis is 

complete and all NEPA requirements are met. 

Other Energy Resources. The Tongass has recently received some interest from 

energy companies exploring for oil and gas and geothermal resources (see related 

discussion in the Minerals section of this chapter). These exploration activities 

require a special use permit when they occur on NFS lands. 

Environmental Consequences 

No significant environmental consequences within the Lands category are 

anticipated for any of the alternatives. The NFS land base is the same for all seven 

alternatives, at just under 16.8 million acres. An adjustment to the suitable timber 

land base has been made for each alternative for lands anticipated to be conveyed 

in the future (“encumbered”). Minor changes to the land base may continue to occur 

as a result of the ongoing conveyance processes, or from future land exchange, 

disposal, and acquisition actions. Any such changes that would occur are 

irrespective of the goals associated with any alternative, as none of the alternatives 

incorporate any specific land adjustment that is unique to the alternative. 

The Forest Service would continue land administration activities under the 

respective Forest-wide standards and guidelines presented in Chapter 4 of the 

Forest Plan. Those standards and guidelines reflect minimal changes from the 

current Forest Plan direction. The only substantive change in the standards and 

guidelines is the additional statement that motorized access may be authorized as 

part of a special use authorization, subject to the provisions of 36 CFR 212, 251 and 

261. In other respects, administration of special use permits would continue as at 

present under all alternatives. The number of communication and other electronic 

sites on NFS lands under special use permit has increased somewhat in recent 

years, and additional sites may be permitted in the future. Permits for camps and 

cabins may decrease somewhat over time because of restrictions on new uses of 

Direct and 

Indirect Effects 
3 Environment and Effects

Lands 3-308 Final EIS

this type. Based on recent trends, minor future increases in special use permits for 

other recreation purposes, rights-of-way, and other special uses are possible. 

Additional special use permits may be granted in the future; the environmental 

impacts of those actions would be evaluated through the permit approval process. 

The Forest Service would issue permit conditions to address the impacts of new 

permits and renewed permits. Special use permits generally apply to small, specific 

areas and activities that have limited impacts. Impacts from permitted activities can 

not be predicted at this time, would not vary among the alternatives, and are not 

likely to be significant. The future addition of electronic sites by private industry 

could help improve electronic signal coverage Forest-wide. 

Forest Service land administration activities under the updated Forest Plan are not 

considered to have the potential to create or contribute to significant cumulative 

effects. To the extent that special use permits increase in number and affected 

acreage, environmental effects from future permits would add to those of permits 

already in effect. As noted above, however, those effects are not likely to be 

significant. In general, land ownership adjustments executed by the Forest Service 

are made in response to direction from others, primarily Congress through legislated 

land conveyances or exchanges. No land ownership adjustments are proposed 

under any of the Forest Plan alternatives, and none of the potential adjustments 

discussed above and in Appendix C is considered reasonably foreseeable. To the 

extent that any of the potential conveyance or exchange proposals were adopted in 

the future, they would have a cumulative effect on the NFS land base within the 

Tongass. There has been a substantial transfer of federal lands in Southeast 

Alaska to other ownership since statehood.

Cumulative 

Effects 
 Environment and Effects 3 

Final EIS 3-309 Transportation and Utilities 

Transportation and Utilities 

Affected Environment............................................................................. 3-309

National Forest Transportation System Roads...................................... 3-311

Power Transmission Lines..................................................................... 3-313

Transportation and Utility Systems in the Forest Plan........................... 3-314

Environmental Consequences............................................................... 3-314

Direct and Indirect Effects...................................................................... 3-314

Cumulative Effects ................................................................................. 3-316

Affected Environment 

There are three principal types of travel in Southeast Alaska: air, water, and ground. 

Historically, marine transportation has been the major method of moving freight and 

passengers; however, during the last five decades, air services have developed to 

serve the growing demand for rapid transportation between communities within 

Alaska and to the contiguous United States. Residents of the region are dependent 

on air and water transportation for travel between most communities, rather than 

roads or rail. A roaded transportation system has developed on National Forest 

System (NFS) lands, largely in support of timber harvesting. 

Only three cities in Southeast Alaska are connected to the continental road system: 

Haines, Skagway, and Hyder. Several cities in Southeast Alaska are linked to 

Bellingham, Washington via the Alaska Marine Highway. Ketchikan is also linked by 

ferry to the Canadian community of Prince Rupert, British Columbia. In addition, 

several ferries connect communities on a weekly or twice-weekly basis. Prince of 

Wales Island has the only road system in Southeast Alaska that interconnects island 

communities. Several possibilities exist for state highways that could connect some 

communities of Southeast Alaska to the continental road system. Several new 

internal corridors are also possible. 

The Alaska Department of Transportation and Public Facilities (DOT&PF) issued the 

Southeast Alaska Transportation Plan (SATP) in August 2004 (Alaska DOT&PF 

2004). The SATP requested 34 essential transportation and utility corridors be 

reserved and incorporated into the Tongass Land and Resource Management Plan. 

Most corridors are planned for infrastructure construction by Alaska DOT&PF. For 

other corridors, Alaska DOT&PF has requested the Forest Service improve and 

connect forest roads. The SATP proposes doubling the forest highway system, 

which would result in a 1,032-mile system. 

Historically, Southeast Alaska has relied on a “marine highway system” to augment 

its limited roads and highways. The Marine Highway System primarily consisted of 

long line ferries, which are becoming obsolete with current Coast Guard regulations, 

and are increasingly costly to operate. The SATP calls for transitioning away from 

the long line ferries to a system of expanded roads and shuttle ferries. Strategically, 

the plan calls for centering transportation and access around three major highway 

linkages: the Juneau Access Road (which would link Juneau to the continental road 

system via Skagway), a Sitka highway (which would link Sitka with the east side of 

Baranof Island), and a mid-region connector to the Cassier Highway in British 

Columbia, Canada (the Bradfield Canal Corridor is one alternative under 

consideration). 

Public Law 109-59, the Safe Accountable Flexible Efficient Transportation Equity 

Act: A Legacy for Users, was passed in August 2005. It refers to Map 92337, which 

shows marine access points, log transfer facilities (LTFs), and proposed 

transportation corridors in Southeast Alaska. This map shows 22 corridors, all but 
3 Environment and Effects

Transportation and Utilities 3-310 Final EIS

one of which is also in the SATP (the Whale Pass to Exchange Cove corridor on 

Prince of Wales Island is not included in the SATP). 

Because the Southeast Region of Alaska DOT&PF lies largely within the Tongass 

National Forest’s boundaries, many of the proposed road projects would cross NFS 

lands and require Forest Service coordination and U.S. Department of 

Transportation easements. The proposed major linkages for the Juneau Access, a 

Sitka Highway System, and the Cassier Highway connection would each cross 

Tongass National Forest land. The completion of the SATP has initiated more sitespecific planning, and has focused on a request for a change in land use 

designation (LUD) in the Forest Plan. 

The Forest Service signed a Memorandum of Understanding with the State of 

Alaska in 2006 to provide rights-of-way for the road corridors covered by Public Law 

109-59. These corridors are displayed on the alternative maps. The Memorandum 

of Understanding also grants easements to the Forest Service for marine access 

points and LTFs listed on Map 92337. To date, eight rights-of-way have been 

granted to the State, and work is proceeding on the remaining right-of-way grants. 

The Federal Highway Administration issued a Record of Decision (ROD) in 2006 

approving a road on the east side of Lynn Canal from the current terminus of State 

Highway 7 to the Katzehin River. From there, shuttle ferries would continue to 

Haines and Skagway. Site-specific planning is also underway for the Sitka Access 

and the Northern Panhandle Transportation Study. The Forest Service continues to 

be involved as a cooperating agency with Alaska DOT&PF for all highway National 

Environmental Protection Agency (NEPA) efforts, identifying the impacts to the 

Tongass National Forest, and creating opportunities for appropriate mitigation and 

recreational enhancements. This analysis considers the request for reserving these 

transportation corridors (refer to the alternative descriptions in Chapter 2). 

In addition to the corridor reservation request, the SATP identifies the Forest Service 

as a “transportation partner” highlighting that there are 3,600 miles of Forest Service 

roads on the Tongass National Forest that many communities rely on. The SATP 

also calls out the merits of the Forest Service’s role as a public roading agency, 

recognizing the need for lower standard public road links to Southeast Alaska’s 

smaller communities. 

The SATP is based on two fundamental concepts: 1) an integrated multi-modal 

transportation system (a combination of road segments linked to shuttle and 

mainline ferry services within key corridors), and 2) a combination of sub-area or 

zone and regional transportation services and facilities. The four identified major 

travel corridors or zones are: 1) Juneau-Haines-Skagway, 2) Juneau-SitkaPetersburg, 3) Petersburg-Ketchikan, and 4) Ketchikan-Prince Rupert, British 

Columbia. New ferry terminals have been completed at Mitkof Island and Coffman 

Cove. The Inter-Island Ferry Authority, which operates a route between Hollis and 

Ketchikan, also operates the new route serving Wrangell, Coffman Cove, and Mitkof 

Island. 

A number of different groups have identified several corridors for consideration as 

major transportation routes. The SATP identifies several potential extensions of the 

Inside Passage Highway among its long-term actions. Several possibilities are 

under consideration, including extensions or new highway construction on 

Kupreanof Island (to connect Kake and Petersburg), Cleveland Peninsula, and 

Revillagigedo Island (including an extension of the Revilla road to Shelter Cove, and 

a road from Carroll Inlet to Shrimp Bay). The SATP recommends reserving these 

possible future alignments as highway corridors. The SATP also proposes a study 

to consider the viability of constructing a road to connect Sitka with the east side of 

Baranof Island, either at Rodman Bay or Warm Springs Bay. 

Other potential routes that have been discussed in recent years include a route 

along the west shore of Lynn Canal, two Juneau-to-Canada routes along Taku Inlet, 
 Environment and Effects 3 

Final EIS 3-311 Transportation and Utilities 

the East Bradfield River corridor connection to the Cassiar Highway, several other 

road corridors near Wrangell, a coastal alignment connecting Thorne Bay and 

Coffman Cove, a road connecting North Whale Pass and the East Prince of Wales 

road, and a road to the southeastern tip of the Kasaan Peninsula. In addition to the 

routes listed above, draft Transportation System Concept maps prepared for the 

Southeast Conference identify a potential route connecting Hoonah and Tenakee 

Springs, and a short connector route between the Chatham and Corner Bay road 

systems. The Southeast Conference maps also identify an alternative corridor 

between Kake and Petersburg via a ferry across Duncan Canal. 

When a National Forest Transportation System road (discussed in the next 

subsection) provides a connection between communities, serves local needs such 

as mail delivery, or connects public roads within the Tongass National Forest, it can 

be designated as a forest highway (see 23 U.S.C. 101 for technical definition). 

Forest highways are usually upgraded to state highway standards, during which 

jurisdiction passes to the State. To date, the Alaska DOT&PF, Federal Highway 

Administration, and Forest Service have agreed to designate a potential 362 miles 

as forest highways; the State would assume jurisdiction and maintenance 

responsibility for 181 miles of these highways. 

Other transportation facilities within Southeast Alaska include more than 300 marine 

facilities (docks, small boat harbors, refuge floats, and boat launch ramps), 12 major 

airports, approximately 35 seaplane bases or floats, and numerous heliports and 

airstrips (Alaska DOT&PF 2004). 

National Forest Transportation System roads are constructed to provide access to 

NFS lands and are included in the Forest Development Transportation Plan (see 

Transportation Standards and Guidelines in Chapter 4 of the Forest Plan [USDA 

Forest Service 1997b]). They are considered NFS roads, as are other roads that 

are wholly or partially on NFS lands and are intended to be maintained for the long 

term (see text box on Road Types). They are functionally classified as arterial 

(serving large land areas and usually connecting to public highways), collector 

(serving smaller areas, usually connecting to arterials or public highways), and local 

(terminal roads, may connect to any other type). 

NFS roads are also managed by a system of maintenance levels, depending on 

their intended use and suitability for various types of vehicles. These levels range 

between level 1 (closed), level 2 (suitable for high-clearance vehicles), level 3 

(suitable for passenger vehicles, rough surface), level 4 (suitable for passenger 

vehicles, smooth surface), and level 5 (suitable for passenger cars, dust free, 

possibly paved). Maintenance can include reconditioning the original road template, 

grading the road surface, cleaning roadside ditches, and removing vegetation that 

may encroach upon the road or block vision. Grading and other maintenance would 

generally take place more often on a maintenance level 4 road than on a level 3 

road, and would be expected to occur less often on a level 2 road. Level 1 roads 

are left to a self-maintaining condition that requires little or no maintenance. 

With the exception of a few administrative sites and campgrounds, most forest roads 

are single lane, constructed with blasted quarry rock, and designed for off-highway 

loads. Typical collector and local roads are 14 feet wide with a rough gravel 

surface. Higher standard arterial roads are normally 16 feet wide, may have a 

smooth gravel surface, and are designed for speeds of up to 30 miles per hour. 

Travel speed on lower standard roads is often controlled more by surface roughness 

than by horizontal alignment or road gradient. 

For the Tongass, the demand for roads has primarily been a function of the demand 

for access to timber resources. The maintenance and reconstruction requirements 

of the existing system depend mainly on the volume of timber hauled and, to a 

lesser extent, on recreational use. The amount of future construction is anticipated 

to continue to be largely determined by the need to access timber resources. 

National Forest 

Transportation 

System Roads 
3 Environment and Effects

Transportation and Utilities 3-312 Final EIS

Currently, there are approximately 3,532 miles of authorized roads on NFS lands, 

approximately 2,485 miles of which are not maintained for highway vehicles 

(maintenance level 1 and 2). There are another 607 miles of roads that are on nonNFS lands. In addition, there are about 1,409 miles of unauthorized roads—roads 

that are not maintained by the Forest Service. These roads provide access to about 

8 percent of the Tongass National Forest. Over half of the roads suitable for 

highway vehicles are connected to communities. Between 1984 and 1993, an 

average of 168 miles of road was constructed annually. The 1997 Forest Plan 

estimated that 106 miles of road would be constructed annually in the first decade of 

the Plan. However, actual construction was well below that level, averaging less 

than 25 miles annually between 1997 and 2005. During that same time period, 

approximately 94 miles of road were decommissioned. The result was a net 

addition of 126 miles of road, compared to the 954 miles predicted for the first 9 

years. 

The steep, densely vegetated terrain of Southeast Alaska limits the use of typical 

off-highway vehicles (OHVs) such as three-wheelers and all-terrain vehicles to 

beaches, communities, road systems, braided river channels, and frozen or snowcovered areas. Most trails in Southeast Alaska do not lend themselves well to the 

use of such vehicles because of wet ground conditions that often necessitate the 

use of boardwalks. With the exception of a few specific areas, the Tongass has not 

experienced the kinds of resource damage typically associated with OHVs 

elsewhere. The Tongass contains many unauthorized roads, some utilize old 

roadbeds and some are user-created. Many of these unauthorized roads and trails 

are used by OHVs for recreation. It is anticipated that travel management plans 

scheduled for completion by December 2009 will decide which of these 

unauthorized roads are incorporated into the Forest transportation system and 

which will be closed as funding becomes available. 

Prior to 2005, the Forest was designated open to OHVs except for Wilderness, 

National Monuments, and Research Natural Areas. Site-specific closures were 

considered in specific locations where conflicts with other uses, public safety 

problems, or damage to resources could occur. The goal of OHV management is to 

ensure resource protection and public safety, minimize user conflicts, and provide 

diverse opportunities for Forest users. A specific set of closures was consolidated 

in the Juneau area in November 1985 as the “Off-Road Vehicle Travel Plan” for the 

Juneau Ranger District. This travel plan was incorporated in the Forest Plan by 

reference. In November 2005, the Forest Service adopted a final rule for managing 

motor vehicle use, including OHV use, on national forests throughout the United 

States. Under this rule, the travel management plans will designate a system of 

roads and trails for OHV use, and identify if any areas for cross country travel are 

appropriate and do not cause resource damage. Use maps are scheduled to be 

completed by 2010. 

In early 2001, the Forest Service adopted a new road management policy that 

requires the agency to maintain a safe, environmentally sound road network that is 

responsive to public needs and affordable to manage. The policy includes a 

science-based roads analysis process designed to help managers make better 

decisions on roads. The Forest completed a Forest-wide roads analysis for 

maintenance level 3, 4, and 5 roads in 2003. Ranger Districts are in the process of 

completing roads analysis on maintenance level 1 and 2 roads as well as 

unauthorized roads. 

The transport of harvested timber from isolated islands in Southeast Alaska requires 

both land and water routes to reach processing facilities. LTFs are used to transfer 

logs to barges or rafts for towing. About 116 LTFs currently exist on the Tongass 

and there are 59 marine access points suitable for transferring logs to barges that 

have current permits on NFS lands. Another 10 marine access points no longer 

have permits. The Memorandum of Understanding discussed above grants the 

Road Types 

National Forest 

System roads: 

Roads wholly or 

partially within 

National Forest 

System (NFS) 

land that the 

Forest Service 

determines are 

needed for the 

protection, 

administration, 

and utilization for 

the NFS and the 

use and 

development of its 

resources. 

Unauthorized 

roads: Roads that 

are not forest 

roads or are 

temporary roads 

not included in the 

forest 

transportation 

atlas. 

Temporary roads: 

Roads that are not 

forest roads and 

are not listed on 

the forest road 

atlas, but are 

necessary for 

emergency 

operations or 

authorized by 

contract, permit, 

lease, or other 

written 

authorization. 
 Environment and Effects 3 

Final EIS 3-313 Transportation and Utilities 

Forest Service easements to use the 126 LTFs on state lands listed on Map 92337. 

In addition, 59 proposed LTF sites have been identified on NFS lands. 

A number of power transmission lines link existing hydroelectric projects with the 

nearest larger community in Southeast Alaska. The State of Alaska has proposed 

corridors for transmission lines and/or undersea cables to link many Southeast 

Alaska communities to each other and to British Columbia. Several projects are 

either in the NEPA stage or under construction. The Swan Lake–Lake Tyee Intertie 

corridor runs from the Swan Lake Hydro project near the head of Carroll Inlet, north 

to the Tyee Hydro project at the head of Bradfield Canal. The route is shown as a 

potential power transmission corridor on the alternative maps. NEPA was 

completed in 1997 and construction began in 2002; most of the corridor has been 

cleared and approximately three-quarters of the power pole foundations have been 

built. The State Legislature approved $46.2 million for the project. As a result of the 

Swan Lake-Lake Tyee Intertie, another potential corridor, which runs down the 

Cleveland Peninsula connecting the Tyee power line with Ketchikan and Meyers 

Chuck, is not likely to be needed. 

Construction of a transmission line connecting Ketchikan with Metlakatla via 

Saxman is expected to begin soon. The route is shown as a potential power 

transmission corridor on the alternative maps. This corridor is primarily on private 

land. It would run from Ketchikan to Saxman, then across the channel to Annette 

Island, and then southwest and south along the northern portion of the island to 

Metlakatla. 

Kootznoowoo Inc., a Native village cooperative, has proposed developing a 

hydroelectric facility on Thayer Creek and a transmission line between the Thayer 

Creek facility and Angoon. The route is shown as a potential power transmission 

corridor on the alternative maps. This project is authorized by Congress and is 

currently being analyzed by the Forest Service in an EIS. The 1-megawatt, run-ofthe-river hydroelectric project on Thayer Creek (north of Angoon) includes a 10-foothigh diversion dam, a diversion pond, 1.3 miles of pipeline and penstock, a 

powerhouse, and 6 miles of overhead transmission line (plus a marine segment) to 

carry the power south to Angoon. The DEIS was released in May 2007. 

The Juneau to Hoonah Transmission Line route runs from Juneau across northern 

Douglas Island and underwater to the north end of Admiralty Island and then 

underwater again to approximately 10 miles east of Hoonah, where it transitions 

onto land and continues to Hoonah. NEPA has been completed and the line has 

been constructed to Hawk Inlet at the north end of Admiralty Island (the Juneau to 

Greens Creek portion of the transmission line). The route is shown as a potential 

power transmission corridor on the alternative maps. 

The Kake to Petersburg Transmission Line would cross the Wrangell Narrows 

(going from Mitkof to Kupreanof Island) near the Tonka LTF and proceed west 

across Duncan Canal. It would follow existing logging roads for the majority of its 

length. The route is shown as a potential power transmission corridor on the 

alternative maps. 

Other potential projects include power lines between Juneau and Skagway, Juneau 

and Hoonah (the Juneau to Greens Creek portion has been completed), Hoonah 

and Pelican, Hoonah and Tenakee Springs, Tenakee Springs and Angoon, Angoon 

and Sitka, Sitka and Kake, Thorne Bay and Ketchikan, and Klawock and Hydaburg. 

Also planned are power lines between the proposed Lake Dorothy, Otter Creek, and 

Sunrise Lake Hydroelectric Projects and existing power lines or communities. A 

power line from the Tyee hydropower site along a potential Bradfield Canal/Craig 

River road corridor route to Canada is also a potential route that has been 

considered. 

Power 

Transmission 

Lines 
3 Environment and Effects

Transportation and Utilities 3-314 Final EIS

The Forest Plan applies the Transportation and Utility Systems LUD to the potential 

rights-of-way corridors and associated uses for selected potential and existing 

transportation systems and utility corridors. These systems include state and 

federal highways, power lines of 66 kilovolt capacity or greater, and pipelines 10 

inches or more in diameter, if they are a public utility. This LUD is intended to 

minimize potential conflicts, such as over-determining the appropriate visual quality 

objective, should development of any of these projects occur. With certain 

exceptions, transportation and utility systems are allowed throughout the Tongass 

as directed by Title XI of the Alaska National Interest Lands Conservation Act of 

1980. 

Environmental Consequences 

The following discussions address the direct, indirect, and cumulative effects of the 

alternatives on the transportation and utilities infrastructure of Southeast Alaska. 

Analyses examine both the existing system and all reasonably foreseeable changes. 

Effects on the National Forest Transportation Road System 

Table 3.12-1 displays the maximum anticipated road construction by alternative over 

the next 100 or more years. These numbers tend to overestimate total road miles 

because they include unauthorized roads, most of which are likely to be 

decommissioned during the next few decades. New road construction estimates 

are directly related to proposed timber harvesting activities; they are based on the 

maximum harvest levels projected for each alternative. These estimates are 

primarily based on the logging system and transportation analysis (LSTA) completed 

in 2007 for the majority of the mapped suitable lands on the Tongass under the 

alternatives (refer to the Timber section). Where suitable lands were not covered by 

the LSTA (primarily in portions of Alternatives 4 and 7), they were estimated using 

the ratio of road miles to suitable acres based on the LSTA by Value Comparison 

Unit. 

Table 3.12-1 

Estimated Maximum Road Construction and Cumulative Miles of 

National Forest System Roads by Alternative After Full 

Implementation (100+ years)1

Alternative 

New Road 

Construction Existing Roads 2 Cumulative Roads 2

1 774 4,941 5,715 

2 2,079 4,941 7,020 

3 2,799 4,941 7,740 

4 4,890 4,941 9,831 

5 3,874 4,941 8,815 

6 3,744 4,941 8,685 

7 5,825 4,941 10,766 1 Estimates are based on the maximum harvest allowed under each alternative; therefore, they represent 

a maximum estimate. Numbers do not include decommissioning of roads. 2 Includes unauthorized roads, most of which are likely to be decommissioned. 

Roads have the potential to affect fish habitat, soils, and water quality by increasing 

erosion and landslide potential, changing recreation settings and opportunities, 

altering scenery, and increasing legal and illegal wildlife harvest. These types of 

effects are discussed in the subject resource sections of this chapter, as applicable. 

Based on current practices, most new roads would be closed to motorized traffic 

once their initial use is over. These roads are built for silvicultural purposes under 

Transportation 

and Utility 

Systems in the 

Forest Plan 

Direct, Indirect, 

Effects 
 Environment and Effects 3 

Final EIS 3-315 Transportation and Utilities 

exemptions granted under Section 404(f)(1) of the Clean Water Act. The 

construction or maintenance of forest roads used for the sole purpose of silvicultural 

activities is exempt from regulation under Section 404 of the Clean Water Act. 

Roads that remain open for recreation or subsistence use do not qualify under this 

exemption (U.S. Army Corps of Engineers 2004); therefore, these roads should be 

closed following completion of silvicultural activities. The roads would either be 

decommissioned or placed in storage. Bridges and culverts may be removed (or 

culverts may be bypassed), erosion control measures would be applied as needed, 

and the roadbeds would be allowed to revegetate naturally. 

In addition to normal maintenance that would accompany all alternatives, each 

alternative would result in reconstruction of a portion of the existing road system in 

each decade, primarily roads that have been placed in storage (maintenance level 

1). Estimates range from 925 miles under Alternative 1 to 2,371 miles under 

Alternative 7 (Table 3.12-2). Reconstruction of a road maintains the original 

investment and makes the road suitable and safe for intended use. Reconstruction 

involves the rehabilitation of the original roadbed, and can include cleaning ditches, 

replacing drainage structures, re-installing bridges, and grading and shaping. 

Table 3.12-2 

Estimated Miles of Road to be Reconstructed by Alternative1

Alternative 

1 2 3 4 5 6 7 

925 1,784 1,932 2,182 2,100 2,046 2,371 1

 Estimates are based on the existing miles of maintenance level 1 and 2 roads, existing miles of 

unauthorized roads incorporated into the LSTA, and the amount of young growth to be treated over the long 

term (100 + years) for each alternative. 

Effects on Log Transfer Facilities 

LTFs can adversely affect the marine benthic habitat (plants and animals that live in 

and on the ocean bottom). Effects are expected from two sources: structural 

embankment (placing rock in the water) and bark deposition (bark that accumulates 

underwater). Structural embankment is estimated to cover approximately onequarter acre per site. 

LTFs have affected approximately 2 acres of marine benthic habitat for the average 

site (Faris and Vaughan 1985). Bark and debris accumulation may decrease over 

time due to water currents, but there are no reliable estimates on the length of time 

required before a bark accumulation is completely eliminated. Using this 2-acre 

average, about 232 acres of marine benthic habitat associated with the existing 

LTFs on NFS lands have bark accumulations. This is roughly 0.05 percent of the 

total estuarine area less than 60 feet deep. The biological effects of LTFs are 

described in the 1997 Tongass Forest Plan Revision Final EIS (USDA Forest 

Service 1997a). Currently, many timber sale contracts require logs to be loaded 

directly onto barges rather that placed in the water and bundled into log rafts. This 

greatly reduces the amount of bark and wood debris that enters the water. In 

situations where logs are rafted, placing of LTFs in areas where the current will 

disperse debris can greatly reduce bark accumulation. 

The 1991 Land Management Plan Revision Draft EIS estimated that 200 to 350 

acres of benthic habitat could be adversely affected by new LTFs over the next 30 

years (approximately another 0.04 to 0.08 percent of estuarine habitat under 60 feet 

deep). This figure was not recalculated for the 1997 Final EIS. The 1991 estimate 

was based on harvest levels that ranged from 139 to 513 million board feet (MMBF). 

Harvest levels associated with the alternatives considered under this analysis range 

from 49 to 421 MMBF. Based on the 2007 LSTA and modeling conducted for this 

EIS, it is estimated that a maximum of 115 new LTFs would be needed under 

Alternative 7, resulting in an estimated maximum of 230 additional acres of benthic 

habitat disturbance. Also, the 1991 estimate and the 2 acres of disturbance per LTF 
3 Environment and Effects

Transportation and Utilities 3-316 Final EIS

figure, assume that logs would be placed into the water and rafted, rather than 

loaded onto barges as is currently required on many sales. Therefore, the effects of 

the proposed alternatives are likely to be less than those anticipated in 1991 or 

1997, especially for Alternatives 1, 2, and 3. The effects of continuing operation at 

existing LTFs are likely to be similar under all alternatives; except under Alternative 

1, which would use fewer existing LTFs. 

Effects on Off-Highway Vehicle Access 

The Forest is in the process of preparing access and travel management plans for 

the Tongass National Forest. The travel management plans will designate a system 

of roads and trails for OHV use, and identify if any areas for cross country travel are 

appropriate and do not cause resource damage. The proposed alternatives would 

not affect this process because all alternatives include the roaded land base. Travel 

management decisions are scheduled to be completed in 2009. 

Effects on Transportation and Power Transmission Line Opportunities 

The Transportation and Utility LUDs proposed under the action alternatives include 

the transportation corridors covered by Public Law 109-59 and the subsequent 

Memorandum of Understanding with the State. There would be no difference in how 

these corridors would be managed under any of the action alternatives. Under all of 

the alternatives, the Transportation and Utility LUDs would be given priority over all 

underlying LUDs, including LUDs that do not normally allow road construction. 

None of the alternatives would affect other regional transportation opportunities or 

power transmission line opportunities. No new Wilderness or LUD II areas are 

proposed under any of the alternatives. None of the alternatives proposes changing 

any of the currently roaded areas to LUDs that would not allow road construction, 

road expansion, or transmission line construction. 

Wilderness and LUD II lands are identified in the current Forest Plan as 

Transportation and Utility System “Avoidance Areas.” Utility sites and corridors may 

be located in these LUDs if an analysis of potential Transportation and Utility LUD 

corridors has been completed and no feasible alternatives exist outside this LUD. 

Cumulative road miles projected for the next hundred years for each alternative are 

displayed in Table 3.12-1. In addition, there are approximately 3,756 miles of road 

on non-NFS lands within the Tongass National Forest boundary (including Annette 

Island). These include 400 miles on state land, 1,252 miles on Sealaska lands, 

1,535 on lands owned by Native corporations, and 569 miles on other lands 

(including towns and cities). There are another 149 miles on lands outside the 

Forest boundary. Table 3.12-3 displays the maximum cumulative road miles 

projected for Southeast Alaska over the next 100 years under the proposed 

alternatives. The total road miles are likely to be an over-estimate because these 

numbers include unauthorized roads on NFS lands, most of which are expected to 

be decommissioned. 

The road construction projected for non-NFS lands primarily includes roads needed 

for timber harvest, but also includes roads likely built to serve communities, such as 

the Juneau access road on the east side of Lynn Canal, which has an approved 

ROD. This road and other road corridors covered by Public Law 109-59 would, if 

approved under NEPA and funded, connect additional areas in Southeast Alaska to 

the continental highway system and improve transportation between communities. 

These transportation corridors are displayed on the alternative maps. If all roads 

envisioned under Public Law 109-59 are built, it would have a major effect on 

transportation in the region. 

Cumulative 

Effects 
 Environment and Effects 3 

Final EIS 3-317 Transportation and Utilities 

Table 3.12-3 

Estimated Maximum Road Construction and Cumulative Miles of 

Roads for All of Southeast Alaska by Alternative After Full 

Implementation (100+ years)1

Alternative 

New NFS 

Roads 

New NonNFS RoadsExisting NFS 

Roads2

Existing NonNFS Roads Cumulative 

Roads2

1 774 2,657 4,941 3,906 12,278 

2 2,079 2,657 4,941 3,906 13,583 

3 2,799 2,657 4,941 3,906 14,303 

4 4,890 2,657 4,941 3,906 16,394 

5 3,874 2,657 4,941 3,906 15,378 

6 3,744 2,657 4,941 3,906 15,248 

7 5,825 2,657 4,941 3,906 17,329 1 Approximately 100+ years 2 Includes unauthorized roads, most of which are likely to be decommissioned. 

Estimates are based on the projected harvest for each alternative; therefore, they represent a maximum 

estimate. If new wood processing facilities and markets are not developed, these levels of harvest are 

unlikely to occur. Numbers do not include decommissioning of roads. 

Reasonably foreseeable hydroelectric projects include the Ketchikan to Metlakatla 

transmission line, the Swan Lake to Lake Tyee transmission line, the Kake to 

Petersburg transmission line, and the Angoon hydro project and transmission line. 

There is considerable uncertainty concerning the future development of Southeast 

Alaska’s road and transmission system. New roads linking communities and linking 

Southeast Alaska to the continental highway system would be expensive to build 

and maintain, and funds have yet to be approved for their construction. The 2004 

SATP estimated in 2004 that the cost would be $1.8 billion over 20 years. Most of 

the funding was anticipated to come from the federal government. To date, there 

has been no commitment for this level of funding from either the state or federal 

governments. Similarly, power transmission lines would be difficult and expensive 

to build and a lack of funding may limit the development of a power transmission 

system in Southeast Alaska. 

Roads associated with timber harvest are based on the projected harvest for each 

alternative; therefore, they represent a maximum estimate. If new wood processing 

facilities and markets are not developed, these levels of harvest are unlikely to occur 

and new road construction would be less than projected in Table 3.12-3. There is 

also uncertainty concerning the funds to maintain the existing forest road network, 

place existing roads into storage status, and to decommission roads that are no 

longer needed. Risks associated with inadequate funding include adverse affects to 

fish and water quality and increased safety hazards as older roads and stream 

crossings deteriorate. 
3 Environment and Effects

Transportation and Utilities 3-318 Final EIS

This page is intentionally left blank. 
Environment and Effects 3 

Final EIS 3-319 Timber 

Timber 

Affected Environment ..............................................................................3-319

Current Condition of the Forest Land Base ............................................3-319

Current Condition of the Timber Resource .............................................3-322

Current Practices.....................................................................................3-327

Tongass Timber Sale Program ...............................................................3-331

Environmental Consequences................................................................3-336

Suitable Timber Lands ............................................................................3-336

Silvicultural Systems and Practices ........................................................3-338

Allowable Sale Quantity ..........................................................................3-343

Future Conditions....................................................................................3-348

Cumulative Effects ...................................................................................3-350

Affected Environment 

The forests of Southeast Alaska are the main source of raw materials for the 

region’s wood products industry. From 1980 through 2005, the Tongass National 

Forest accounted for between 18 and 49 percent of the total annual Southeast 

Alaska timber harvest, averaging approximately 42 percent. During this period, 

timber harvest on all ownerships in Southeast Alaska ranged from peak levels of just 

under 1,000 million board feet (MMBF) in 1989 and 1990 to a low of 169 MMBF in 

2004. Timber harvested on National Forest System (NFS) lands is available for 

processing by the local wood products industry but most timber harvested on nonNFS lands is exported. The State increased the sales volume from its forest lands in 

Southeast Alaska in most recent years to help bridge the gap between national 

forest harvest and local industry needs. The wood products industry and associated 

regional employment is discussed in more detail in the Economic and Social 

Environment section of this document. 

The forests of Southeast Alaska are primarily the western hemlock-Sitka spruce 

forest type. This forest type is part of the temperate rain forest that occupies a 

coastal strip 2,000 miles long from northern California to Southcentral Alaska. The 

most extensive occurrence of the western hemlock-Sitka spruce type is in Southeast 

Alaska. Within the Tongass, western hemlock-Sitka spruce stands cover 98 percent 

of the forest lands. Western hemlock and Sitka spruce comprise the majority of the 

stocking in this forest type, associated species include, depending on location, 

yellow-cedar, western redcedar, mountain hemlock, and silver fir (Harris and 

Johnson 1983). The remaining 2 percent of forest lands support relatively small 

stands dominated by yellow-cedar, lodgepole pine (shore pine), red alder, or black 

cottonwood. Western hemlock is used for pilings, poles, railway ties, windowsills, 

doors, and construction lumber, and has been an important fiber source for pulp. 

Sitka spruce is used for lumber and commodity products, as well as specialty 

products, such as piano sounding boards, guitar faces, oars, planking, masts, and 

spars for custom-made or traditional boats, and ladders. For centuries Alaska 

Natives have used cedar species for canoes and paddles, housing (along with Sitka 

spruce), and totem poles. Today, redcedar is primarily used as a roofing material 

and yellow-cedar has many uses, including boats, utility poles, heavy flooring, 

framing, and marine decking and piling. 

The timber inventory on the Tongass, including the forest type composition, age 

class distribution, and volume classes, is described in Chapter 3 of the 1997 

Tongass Forest Plan Revision Final EIS (USDA Forest Service 1997a). This 

Introduction 

Current 

Condition of the 

Forest Land Base 
3 Environment and Effects

Timber 3-320 Final EIS 

information was updated with inventory data published in 2001 (van Hees, W. W. S. 

2001). Current management practices are also described in the 1997 Final EIS 

(USDA Forest Service 1997a). Vegetation management practices prescribed under 

the current Forest Plan, including regeneration methods, reforestation, and 

intermediate treatments, are described in the standards and guidelines of the 1997 

Tongass Forest Plan (USDA Forest Service 1997b). Definitions for each of these 

practices, how they are applied, and the expected effects on the timber resource are 

provided. 

Forests occupy slightly less than 10 million acres, or approximately 60 percent of the 

Tongass land area. The remaining 40 percent is non-forested, e.g., water, muskeg, 

ice, snow, and rock. The forests vary from sparse muskeg forests to heavily 

timbered stands of 50 thousand board feet (MBF) (long-log bureau scale) per acre or 

more. 

Approximately 57 percent of the forest land on the Tongass National Forest 

(approximately 5.6 million acres) is classified as productive forest land; these lands 

are considered biologically capable of producing industrial wood products. 

Approximately 0.5 million acres of the productive forest lands on the Tongass have 

been harvested to date or have been converted to young growth due to fire or wind. 

This is approximately 3 percent of the total Tongass land base and 9 percent of the 

productive forest lands and represents approximately 15 billion board feet of 

harvested timber. In addition to productive forest lands, the Tongass includes 

approximately 4.2 million acres of “other forest land.” These are lands that are not 

capable of producing industrial forest products, but are important for watershed 

protection, wildlife habitat, recreation, and other uses. “Other forest land” is land 

incapable of yielding crops of industrial wood, usually because of adverse site 

conditions. These conditions may include sterile or poorly drained soil, subalpine 

conditions, and steep rocky areas where landslides or avalanches curtail timber 

development. This land has been called noncommercial or nonproductive forest 

land in previous documents. 

An analysis of timber resource land suitability on the Tongass was completed by the 

Forest Service for the 1997 Forest Plan Revision Final EIS and updated for this 

analysis (Appendix A). The National Forest Management Act (NFMA) requires the 

Secretary of Agriculture to identify lands not suited for timber production due to 

physical and other pertinent factors. NFMA also included consideration of economic 

factors in the identification of suitable lands, but the Tongass Timber Reform Act 

(TTRA) exempted economic considerations as a requirement for identifying suitable 

lands on the Tongass. 

Tentatively suitable lands are lands that have the biological capability, and 

availability, to produce commercial wood products. To be considered tentatively 

suitable, the forested land must (36 CFR 219.14): 

• Be at least 10 percent occupied by trees or have formerly had such tree cover, 

and not be developed for non-forest uses; 

• Be capable of harvest with available technology to ensure timber production 

without irreversible resource damage to soil productivity or watershed 

conditions; 

• Be capable of being restocked within 5 years after final harvest; and 

• Not be withdrawn from timber production by an Act of Congress, the Secretary 

of Agriculture, or the Chief of the Forest Service. 

Productive forest 

land – Forest land 

capable of producing at 

least 20 cubic feet of 

wood fiber per acre per 

year, or having greater 

than 8,000 board feet 

per acre. 
Environment and Effects 3 

Final EIS 3-321 Timber 

In the 1997 Forest Plan Revision Final EIS, it was estimated that there were 2.4 

million acres of tentatively suitable lands on the Tongass. The estimated tentatively 

suitable land base was recalculated for this analysis, and remains at slightly less 

than 2.4 million acres (Table 3.13-1). Small differences in the tentatively suitable 

land base are due to updates in the Tongass Geographic Information System (GIS) 

coverages resulting from changes in land ownership and updates from additional 

field work, as well as from a different computer measurement method, i.e., using 

polygon areas rather than extrapolation from a grid system. Figure 3.13-1 illustrates 

the changes that have occurred to the tentatively suitable forest land base on the 

Tongass as a result of legislation and the land allocation process over the past 100 

years. Of the 2.4 million acres of tentatively suitable land, approximately 1 million 

acres are estimated to be in land allocations that allow timber harvest and, thus, are 

mapped as suitable for harvest. After considering factors that are not apparent on 

aerial photos, such as Class III streams that are not visible under the canopy and 

unstable areas, there are an estimated 781,000 acres of actual suitable land. 

Appendix A in the Land and Resource Management Plan describes how the suitable 

land base was derived. 

Table 3.13-1 

Land Classification (thousands of acres) of Tentatively Suitable and 

Suitable Lands 

Classification Acres (thousands)1

Total National Forest land (items 1 and 2) 16,774 

1. Non-forest land (includes water) 6,918 

2. Forest land 9,856 

3. Forest land withdrawn from timber production 4,234 

4. Available forest land (item 2 minus item 3) 5,621 

5. Non-productive forest land 2,339 

6. Available forest lands (item 4 minus item 5) 3,282 

7. Forest lands physically unsuitable for timber management 572 

8. Forest lands with inadequate information 345 

9. Tentatively suitable forest land (item 6 minus items 7 and 8) 2,365 

10. Tentatively suitable forest land allocated to land use 

designations that do not allow timber management 1,328 

11. Mapped suitable forest land (item 9 minus item 10) 1,037 

12. Model implementation factor acreage (MIRF) 255 

13. Estimated suitable forest land available for timber production 781 

1 Sums and differences may not appear exact due to rounding. 

 Source: Forest Service GIS database. 

A detailed logging system and transportation analysis (LSTA) was completed in 

2007. The LSTA covered all suitable land supporting productive old-growth forest 

and young growth at least 35 years old, utilizing the Forest’s GIS database, 

orthophotos, aerial photos, existing LSTAs, and National Environmental Policy Act 

(NEPA) documents (EAs and EISs). Suitable lands with productive old-growth 

forest and with young-growth stands that may be candidates for thinning in 10 to 15 

years were divided into logging settings based on a range of factors, such as 

topography, visual absorption capacity (VAC), scenery integrity objectives (SIO), 

Land Use Designation (LUD), and logging system. Areas that could not be roaded 

because of physical limitations or economics were considered helicopter units. Risk 

factors were assigned to account for possible “falldown” based on photo 

interpretation and local knowledge. Possible falldown factors included low 

merchantable volume, slope stability, karst, steep V-notch streams, and riparian 

concerns. This information was used to complete an operability analysis for all 
3 Environment and Effects

Timber 3-322 Final EIS 

mapped suitable land on the Forest. Table 3.13-2 summarizes the gross acres and 

volumes (prior to falldown factors being considered). 

Figure 3.13-1 

Estimated Tentatively Suitable Forest Land (millions of acres) in the 

Tongass National Forest, 1907 to Present 

6.4 6.2

4.1

3.4

2.4 2.4

5.7

0

1

2

3

4

5

6

7

Tongass

National

Forest

Established

(1907)

Alaska

Statehood

(1959)

ANCSA (1971) ANILCA (1980) TTRA (1990) Forest Plan

Revision EIS

(1997)

Forest Plan

Amendment

(2008)

Millions of Acres

Notes: ANCSA – Alaska Natives Claims Settlement Act, ANILCA – Alaska National Interest Lands 

Conservation Act, TTRA – Tongass Timber Reform Act 

Source: Forest Service historical data and GIS analysis.

There are six conifer forest types within the Tongass. Western hemlock and 

western hemlock-Sitka spruce forest types account for approximately 96 percent of 

the tentatively suitable lands and about 75 percent of all forest lands on the 

Tongass. The remaining forest lands are occupied by the yellow-cedar (sometimes 

referred to as Alaska yellow-cedar), western redcedar, lodgepole pine, and Sitka 

spruce forest types (USDA Forest Service 1997a). 

Table 3.13-2 

Estimated Gross Acres and Volume by Logging System for Productive 

Old Growth Based on 2007 LSTA 

Logging System Acres Volume (MMBF) 

Ground Based 161,000 4,000 

Short-span Skyline 225,000 6,100 

Long-span Skyline 25,000 700 

Helicopter less than 0.75 mile 184,000 4,800 

Helicopter 0.75 to 2.0 miles 72,000 1,700 

Helicopter greater than 2.0 miles 57,000 1,400 

Total 724,000 18,600

Ground Based: areas up to 35 percent slope, 800 foot yarding distance 

Short-span Skyline: 1,300-foot yarding distance 

Long-span Skyline: 1,300-to 2,000-foot yarding distance 

Helicopter less than 0.75 mile: yarding distance less than 0.75 mile 

Helicopter 0.75 to 2.0 miles: yarding distance more than 0.75 mile, less than 2 miles 

Helicopter greater than 2.0 miles: yarding distance more than 2 miles 

Source: Tongass 2007 LSTA includes mapped suitable lands supporting productive old-growth forest and 

supporting young growth at least 35 years old. Mapped suitable acres do not include falldown factors. 

Numbers may not appear to add correctly due to rounding. 

Current 

Condition of the 

Timber Resource 
Environment and Effects 3 

Final EIS 3-323 Timber 

Age Class Distribution. The Tongass is a mix of old-growth stands and naturally 

regenerated young-growth forest, which consists of both wind-created and harvestcreated young-growth forest. Harvest-created young-growth amounts to less than 7 

percent of the total forest land area. Suitable forest lands are classified into five 

stand conditions: 1) old-growth sawtimber, 2) young growth sawtimber, 3) pole 

timber, 4) seedling and sapling, and 5) non-stocked. For timber inventory purposes, 

stands of trees 150 years old or older are designated as old growth. More than 85 

percent of forest lands meet the criteria for old-growth sawtimber (Table 3-13-3). 

To help define tree ages on the Tongass, Farr and McClellan (unpublished 

manuscript) measured and analyzed age data from 67 plots located throughout the 

Tongass (excluding the Yakutat Area). They found that 90 percent of all overstory 

trees were more than 180 years old; 84 percent were more than 200 years; 47 

percent were more than 300 years; 15 percent were more than 400 years; and 5 

percent were more than 500 years old. 

Forests less than 150 years cover approximately 0.7 million acres; forests that are 

150 years of age or greater cover nearly 5 million acres. Table 3.13-3 lists the total 

acres of productive forest land and the acres that are suitable for timber production 

within two broad age classes. 

Table 3.13.3 

Estimated Age Class Distribution of All Productive Forest Land 

and Suitable Productive Forest Land (acres) 

Age (Years) All Productive Forest Lands1 Suitable Forest Lands1,2

0 to 149 689,0003 250,0003

150+ 4,951,000 532,000 

Total 5,640,000 781,000 1

 Numbers may not appear to add correctly due to rounding.. 

2

 Mapped suitable acres adjusted (reduced) for falldown (MIRF). 3

 Includes natural young growth and regeneration after harvest.

Source: Tongass National Forest GIS database

Table 3.13-4 displays the acres harvested by age class. Approximately 45 percent 

of the area harvested over that past century is no longer suitable, due to changes 

instituted by Congress or due to Forest Plan decisions. For example, areas 

designated as Wilderness or LUD II by Congress are no longer tentatively suitable. 

Tentatively suitable areas harvested within the 1,000-foot-wide beach fringe, riparian 

areas, and old-growth reserves are no longer suitable for timber harvest. 

Table 3.13.4 

Estimated Age Class Distribution of Harvested Stands (acres) 

Age Class (Years) All Forest Lands1 Suitable Forest Lands1,2

0 to 35 282,000 163,000 

36 to 70 162,000 64,000 

>70 10,000 1,000 

Total 455,000 228,000 1 Numbers may not appear to add correctly due to rounding.. 2 Mapped suitable acres adjusted (reduced) for falldown (MIRF). 

Source: Tongass National Forest GIS database

Species Mix and Log Types 

Timber harvest on the Tongass generally results in a mix of species and log types. 

The majority of the logs cut in most sales are western hemlock; Sitka spruce is the 

second most common species. Together these two species account for the majority 

of the harvest, based on the SPECTRUM model results (refer to Appendix B for a 
3 Environment and Effects

Timber 3-324 Final EIS 

discussion of the Spectrum model) and the estimated species mix identified in the 

1997 FEIS for the current Forest Plan. Yellow-cedar and western redcedar account 

for most of the remaining volume. Cedar, especially yellow-cedar, often commands 

high prices on the export market and is generally exported (refer to the Economic 

and Social Environment section for discussion of utilization). 

Trees harvested from old-growth stands on the Tongass often contain three types of 

logs: sawlogs, utility logs, and cull logs. Figure 3.13-2 shows one possible example 

of a tree containing all three log types. Sawlogs are logs that come from that portion 

of the tree that is of suitable size and quality to be cut into dimension lumber. 

Sawlogs usually come from the lower portion of the tree, the part of the tree with 

larger diameter logs. Higher quality sawlogs come from that portion of the tree with 

fewer branches, which can result in lumber with fewer knots, while lower quality 

sawlogs often come from that portion of the tree that still retains a live crown. Utility 

logs are logs that cannot be used to produce lumber but are suitable for chips. They 

contain at least 50 percent sound wood. Utility wood is also produced from portions 

of sawlogs that cannot be cut into lumber (refer to Figure 3.13-2). The third type of 

logs, referred to as cull logs, are logs that do not have enough sound wood to be 

merchantable, even for chips. These logs are usually left in the woods and 

contribute to large woody debris (LWD) component and structure left on the forest 

floor. 

Timber Inventory Methodology and Scientific Accuracy 

The first Southeast Alaska-wide timber inventory began in 1953 and was completed 

in 1958. Due to the extensive area to be covered, the inventory was subdivided into 

Juneau, Sitka, Petersburg/Wrangell, Yakutat, and Ketchikan/Craig working circles. 

Ten years later, a portion of the original inventory was re-measured to improve 

estimates of growth and mortality trends in young-growth stands in Southeast 

Alaska. Young-growth stands, for timber management considerations, were defined 

as being less than 150 years old and normally less than 20 inches in diameter 

(measured at “breast height”). 

A complete re-inventory program to re-evaluate Southeast Alaska’s forest area and 

volume began in the early 1970s and was completed by 1975. Several new 

categories of information were collected, including data to evaluate the level of 

stocking (the number of existing trees compared to full stocking of trees for a site), 

strata classes (timber categorized by several attributes such as species, decadence, 

stocking, site index, and board feet per acre), soils, slope, a better definition of 

harvest categories, and a redefinition of quality guides. Detailed data, such as risk 

class and soil microsite, were collected on individual trees to better estimate their 

potential for timber management considerations. 

In 1979, an extensive point sampling system inventory developed for the Tongass 

Land Management Plan gathered specific information across the Tongass to provide 

specific information for the completed 1970s forest inventory. In the early 1980s, 

this inventory was redesigned by the three Administrative Areas (Chatham, Stikine, 

and Ketchikan, which correspond to the north, central, and southern portions of the 

Tongass). Field data collection for this inventory was completed in 1985. 

The 1980s inventory was designed to estimate the standing volume on the Forest 

within certain error limitations. The sampling errors for area and volume met the 

requirements of Forest Service Handbook (FSH) 2409.13 (plus or minus 10 percent 

per billion net cubic feet at a 68 percent confidence level). A review of the inventory 

methodology and results was conducted in September 1989 by a Forest Service 

Biometrician, Jim Brickell. He concluded that the inventory results are reliable as an 
Environment and Effects 3 

Final EIS 3-325 Timber 

Figure 3.13-2 

Product Components of a Tree 
3 Environment and Effects

Timber 3-326 Final EIS

assessment of forest areas and volumes at the forest and area levels (Brickell 

1989). Although the data for the inventory were gathered on a forest-wide basis, the 

inventory was designed to be specific only to the Administrative Area level. The 

inventory was not designed to collect all timber resource information, nor was it 

designed for comparison of individual plot results to timber type map polygons or 

volume strata. 

The results of the 1980-85 inventories showed that the Tongass National Forest had 

a net growing stock of 22.7 billion cubic feet on 4.3 million acres of available lands 

(5.3 thousand cubic feet per acre). This would indicate that the 2.42 million acres of 

tentatively suitable land had approximately 12.8 billion cubic feet of growing stock. 

The net growing stock for the 5.7 million acres of productive forest land was 31.5 

billion cubic feet, or 5.5 thousand cubic feet per acre (approximately 27.5 MBF per 

acre). 

Forest Strata 

The Forest established four volume classes of commercial timber in the 1979 Forest 

Plan (amended 1985). Using net inventory volumes per acre, these classes are: 

• Class 4: 8,000 to 20,000 board feet 

• Class 5: 20,001 to 30,000 board feet 

• Class 6: 30,001 to 50,000 board feet 

• Class 7: 50,001 board feet or greater 

There were a number of concerns from within and outside the agency regarding the 

reliability of this information (usually referred to as the volume class map). 

Therefore, a study addressing concerns about the volume class map reliability was 

commissioned in 1989. It concluded that there was no statistical difference among 

volume classes 5, 6, and 7 with respect to mean board feet per acre, and the 

existing volume class map should not be used to determine volume per acre 

(Brickell 1989). 

The volume class map was used by the Alaska Region to calculate long-term timber 

sale contract timber volume proportionality, as required by Section 301 of TTRA. 

However, this procedure was successfully challenged in court by The Wildlife 

Society, Alaska Chapter. The court disputes over TTRA Section 301 proportional 

harvest methodology were settled, with issuance of an updated Forest Service 

Handbook Supplement (Region 10, FSH 2409.18 Supplement No. 2409.18-96-1), 

and alternative methods of assigning timber volume (or the capability to produce 

different timber volumes) to lands currently supporting old-growth forests were 

considered for the 1997 Forest Plan Revision. Five different options were studied 

and evaluated (Julin and Caouette 1997). Statistical analysis indicated that three 

strata can be distinguished for the available forest lands (lands not legislatively or 

administratively withdrawn) using the existing inventory and additional information 

on soils and slope. The polygon characteristics of the three-strata approach are 

displayed in Table 3.13-5. In the development of the new size-density model (SDM) 

(see Biodiversity section), these strata were redefined using improved information 

on hydric soils and aspect. Table 3.13-5 is based on these redefined strata. These 

strata were used to model timber outputs for this analysis (refer to Appendix B for a 

discussion of the SPECTRUM model). 
 Environment and Effects 3 

Final EIS 3-327 Timber 

Table 3.13-5 

Tongass National Forest Strata Characteristics–Productive OldGrowth Forest

Geographic 

Area 

Trees/ 

Acre 

Gross 

Volume 

(MBF/ 

Acre) 

Net Sawlog 

Volume 

(MBF/Acre) 

Net Utility 

Volume 

(MBF/Acre) 

Total Net 

Sawlog and 

Utility Volume 

(MBF/Acre) 

North Islands1

Low 102 17.8 11.1 1.8 12.9 

Medium 89 27.8 17.7 3.0 20.7 

High 89 39.8 25.6 4.8 30.4 

North Mainland1

Low 137 12.3 7.6 0.9 8.5 

Medium 148 35.0 19.6 4.5 24.1 

High 89 39.8 24.6 4.7 29.3 

South Island1

Low 151 20.9 13.7 2.0 15.7 

Medium 100 30.3 20.7 2.9 23.6 

High 97 41.7 29.3 5.1 34.4 

South Mainland1

Low 97 22.9 15.1 2.0 17.1 

Medium 100 30.3 21.0 3.0 24.0 

High 111 41.3 30.2 5.4 35.6 

Yakutat 

Low 21 6.5 4.7 0.5 5.2 

Medium 187 40.4 27.7 5.0 32.7 

High 196 45.2 32.7 4.1 36.8 

1

 North Islands: Chichagof, Baranoff, Admiralty, and associated islands; North Mainland: mainland 

north of the Stikine River; South Islands: Kupreanof, Mitkof, Kuiu, Prince of Wales, and associated 

islands; South Mainland: mainland south of the Stikine River. 

Refer to USDA Forest Service 2006, SDM Data for documentation on why forests were grouped in 

these geographic areas. Numbers not exact due to rounding.

While the three-strata approach is useful for estimating timber volume for forest 

planning purposes, it is not a good tool for identifying other important forest 

elements, including forest structure, ecosystem diversity, and wildlife habitat. For 

example, two stands may have the same volume, but one may be a dense stand of 

medium-sized trees with a single canopy layer, while the other stand may be a 

combination of widely spaced large overstory trees and two or three lower canopy 

layers containing small- and medium-sized trees. The SDM, which uses a 

combination of two common forest measurements, tree sizes and tree densities 

(Caouette et al. 2001), has proven to be a better tool for representing these other 

forest elements. Using tree sizes and densities provides a more comprehensive 

forest measuring system for describing habitat than timber volume (Spies and 

Franklin 1991). The new SDM (Caouette and DeGayner 2005) is described and 

used in the Biodiversity and other sections.

Non-National Forest System Lands 

The State of Alaska, Native village corporations, Sealaska (the Native regional 

corporation) and individuals own over 1,050,000 acres of land in Southeast Alaska, 

inside the Forest boundary. Approximately 408,000 acres of this land currently 

consists of productive old-growth forest and 351,000 acres consists of young 

growth. This means that approximately 46 percent of the original productive old 

growth has been harvested (as of 2006 based on GIS analysis and information 

provided by the landowners). Most timber harvested from state lands in recent 

years has been processed locally, while timber harvested from University Trust and 

Mental Health Trust lands has been exported. 
3 Environment and Effects

Timber 3-328 Final EIS

Regeneration Methods 

Even-aged Systems. This system includes clearcuts, seed tree, and shelterwood 

harvest methods. These methods are described in detail in Appendix G of the 1997 

Tongass Land Management Plan Final EIS. Under an even-aged system, the 

intention is to replace the entire (or nearly the entire) stand with a new crop of trees 

that are all of the same age. Under NFMA, clearcutting can only be used when it is 

the optimum system. This is determined through a site-specific prescription 

approved by a certified silviculturist. Also under NFMA, a stand must have reached 

at least 95 percent of culmination of mean annual increment (CMAI). This is the 

point at which the stand reaches its highest average growth. The exact age that this 

occurs varies by site and stand treatment. A stand on a high site will generally 

reach CMAI sooner than one on a lower site. However, stand treatments, such as 

precommercial thinning and commercial thinning, will generally extend the period of 

fast growth, causing the stand to take longer to reach CMAI. 

Clearcutting, with reliance on natural seeding, has been the most commonly used 

silvicultural system in the Sitka spruce-western hemlock forest type of Southeast 

Alaska (Ruth and Harris 1979, Deal et al. 2002). Clearcutting is used where timber 

production is the primary use and where it is the optimal method. The clearcutting 

method is favored for several reasons. Clearcutting increases exposure to the sun, 

which raises soil temperature, speeds up organic decomposition, and thus improves 

soil productivity. Sitka spruce is less tolerant of shade than western hemlock (USDA 

Forest Service 1990); therefore, in the mixed spruce-hemlock forests of Southeast 

Alaska, the open conditions created by clearcutting favor the regeneration of Sitka 

spruce (Ruth and Harris 1979). Clearcutting in stands infected by dwarf mistletoe 

substantially reduces infection in the regenerated stand (Shaw and Hennon 1991). 

Logging costs are lower than with other systems, and the clearcut method has 

proven very successful in the regeneration (regrowth) of healthy forested stands 

(refer to Appendix G in the 1997 FEIS for additional discussion). 

A variant of this system, referred to as clearcutting with reserves, involves retaining 

approximately 10 percent of the stand, either in single trees or in small groups. This 

method is generally used to meet scenery or wildlife needs in areas where timber 

production is the primary goal. 

In 1992, the Chief of the Forest Service directed that the even-aged system 

(clearcutting) be limited to areas where it is essential to meet Forest Plan objectives. 

Clearcutting has traditionally been used in the hemlock-spruce forests of Southeast 

Alaska to reduce mistletoe infection by eliminating infected trees from the overstory, 

reduce heartrot and stem diseases that may result from logging damage to leave 

trees, and to eliminate the risk of blowdown of residual trees. In addition, it requires 

fewer miles of road for a given volume (Ruth and Harris 1979, USDA Forest Service 

1983). Because more volume is harvested from each acre than would be the case 

under uneven-aged management, many fewer acres are impacted for the same 

harvest volume. 

Two-aged Systems. In this system, for example, up to 30 percent of a stand is left 

as residual (or reserve) trees, either as single trees or in patches, and the rest of the 

stand is harvested. The reserve trees remain unharvested and provide structural 

diversity and an older aggregation of trees within the otherwise young-growth stand. 

This system has been used on the Tongass to meet scenery objectives. Logging 

costs can be higher because of the need to protect the reserve trees. 

Experience in other regions indicated that retaining overstory trees led to 

regeneration of more shade-tolerant species (which would favor hemlock over Sitka 

spruce in Southeast Alaska), reduced growth, increased dwarf mistletoe infection in 

understory trees, and resulted in windthrow of overstory trees (Harris and Farr 

Current Practices 
 Environment and Effects 3 

Final EIS 3-329 Timber 

1974). However, a retrospective study of 18 partial cut stands in Southeast Alaska 

found that partial cutting had little effect on tree species composition, diameter 

growth, or dwarf mistletoe levels (Deal and Tappeiner 2002, Deal 2002). Mortality of 

residual trees was only marginally higher in partial cut stands than in uncut stands; 

although the location of these stands may have contributed to the relatively low level 

of wind damage. The stands sampled in this study were all below 100 feet in 

elevation and within 1.25 miles of the shoreline. Stands on exposed south-facing 

ridges and on slopes are likely to have a greater risk of windthrow (Nowacki and 

Kramer 1998). Windthrow may be of particular concern because one of the 

predicted outcomes of climate change in Southeast Alaska is an increase in the 

frequency of severe wind storms. Juday et al. (1998) considered it highly likely that 

there would be increased blowdown across Southeast Alaska in the future. 

Uneven-aged Systems. This system typically involves harvesting of single trees or 

of small groups of trees (usually less than 2 acres) from within a stand. This method 

maintains a multi-aged, multi-layered stand structure by removing some trees in all 

age groups. It has been used on the Forest to meet scenery and wildlife habitat 

needs. Uneven-aged management often involves higher costs and affects larger 

areas than would be needed for the same harvest volume under an even-aged or 

two-aged system (Ruth and Harris 1979). Also, the frequent entries in the stand to 

remove individual or small groups of trees increases logging costs and the risk of 

damaging the remaining trees (USDA Forest Service 1983). 

There is little scientifically documented experience with uneven-aged harvest in 

Southeast Alaska (McClellan et al 2000). Deal (2001) concluded that it may closely 

mimic the natural disturbance regime of Southeast Alaska based on a retrospective 

study of 18 partial cut stands. Stand structures were similar to uncut old-growth 

stands, and cutting had no significant effect on species composition (Deal and 

Tappeiner 2002). Uneven-aged systems have potential benefits, including protection 

of wildlife habitat, scenery, and slope stability as well as the maintenance of 

biological diversity (McClellan et al. 2000). 

Young-Growth Management 

Managing young-growth forests in Southeast Alaska is likely to become an 

increasingly important component of forest management on the Tongass in the 

coming years. Young-growth stands can be treated through thinning and other 

intermediate treatments to concentrate growth in fewer, larger trees, improve lumber 

quality, and/or to enhance habitat conditions for wildlife. Zaborski et al. (2000) 

concluded that the types of treatments applied to young stands will have a profound 

effect on the types of materials available in the future, including log diameter, knot 

size, and wood strength. 

Over 100,000 acres have been precommercially thinned on the Tongass since 1979. 

In recent years, precommercial thinning has averaged approximately 5,600 acres 

per year. The Forest has much less experience with other young-growth 

management techniques, such as pruning and commercial thinning. 

Barbour et al: (2005) estimated that a precommercial thinning at age 20 with a 

spacing of 12 by 12 feet would produce more merchantable wood volume at age 70 

than wider spaced thinnings. However, there is a trend toward wider tree spacing in 

precommercial thinning prescriptions to maintain or enhance understory plant cover. 

These treatments could increase taper and stimulate the production of epicormic 

branches (in spruce) and knot size. These changes could adversely affect wood 

strength and stiffness (McClellan 2005). There is also a concern that wider spacing 

may increase the occurrence of fluting on sites where this is a problem (Julin et al. 

1993, Holsten et al. 2001). 

Pruning removes lower branches and can increase future lumber quality; however, 

care must be taken not to remove too much of the live crown. Petruncio (1994) 
3 Environment and Effects

Timber 3-330 Final EIS

recommends that 33 percent of the live crown (no more than 40 percent) can be 

removed in a western hemlock-Sitka spruce forest without affecting tree growth. 

Pruning may also increase epicormic branches in Sitka spruce. Deal et al. (2003) 

reported that 232 out of 236 Sitka spruce had between 9 and 11 sprouts per meter 

of tree bole. Significantly more large sprouts were produced in the highest pruning 

lift. 

There has been increased interest in commercial thinning in recent years, not only to 

improve timber values, but as a tool to improve wildlife habitat. Studies in other 

forest types in the Pacific Northwest indicate that stand structures that are similar to 

old-growth forest conditions can be developed through thinning (Thysell and Carry 

2000). However, there are many unanswered questions as to how to implement 

thinning treatments that provide a sustainable source of high-value wood products 

while maintaining biological diversity (Zaborske et al. 2000). In a study comparing 

the lumber harvested from thinned and unthinned, 90-year-old stands on the 

Tongass National Forest, Christensen et al. (2002) found that there was no 

difference in volume recovery or lumber grade in thinned and unthinned Sitka 

spruce. For western hemlock, the unthinned stands produced more wood volume, 

but the thinned stands produced more high-grade lumber. There was no difference 

in the bending module of elasticity for lumber produced from thinned or unthinned 

stands for either species. 

There is also increased interest in managing young-growth stands to increase and 

maintain understory vegetation, especially as forage for deer and other wildlife. 

Hanley et al. (2005) noted that much research is needed on new approaches 

involving thinning of older stands and on including red alder in the secondary 

successional sequence. Zaborske et al (2002) found that thinning greatly increased 

forage production, though the amount of useful forage produced varied by the type 

of thinning implemented. Refer to the Wildlife section for a discussion of habitat 

manipulation. 

In additional to their continuing research on managing young forests, scientists at 

the Pacific Northwest Research Station joined with the Tongass National Forest in 

2001 to establish an operational-scale adaptive management study of young-growth 

management options. This program, called the Tongass-wide Young-Growth 

Studies (TWYGS), is designed to evaluate the potential benefits of treating younggrowth stands to increase wildlife habitat and wood production. Currently, TWYGS 

includes experiments that test the effectiveness of alder interplanting, 

precommercial thinning, and pruning. 

Yarding Methods 

On the Tongass, most logs have been yarded downhill using cable logging systems 

such as highlead and skyline. Access has usually been from valley bottoms, 

because road building on steep slopes is difficult and costly. Most logging occurs 

inland, with logs transported via road systems to marine access points, also referred 

to as log transfer facilities (LTFs), at tidewater (see the Transportation and Utilities

section). Harvest by tractor (shovel yarding) has proven effective on flat to 

moderate slopes; it is not practical on steep slopes. Harvest by helicopter has been 

limited in the past but is increasing; it is typically the costliest method, but also has 

fewer adverse effects on other resources. 

Yarding methods can be divided into three "operability" classes, which relate to the 

methods necessary to harvest and transport trees under various conditions. Normal 

operability includes the standard ground-based and cable logging systems used in 

areas where access is relatively easy and helicopter logging with distances of up to 

0.75 mile. These areas have the lowest logging costs. Difficult operability includes 

long-span cable systems and helicopter logging with distances between 0.75 and 

2.0 miles, occurring where ground access is difficult or not possible. Difficult 
Environment and Effects 3 

Final EIS 3-331 Timber 

operability involves higher costs. The third class, isolated operability, consists of 

isolated stands 2.0 miles or more from a helicopter landing site. These tend to be 

uneconomical under even high timber markets. 

The recent LSTA indicates that approximately 89 percent of the suitable timber land 

would be accessible using normal harvest methods, 10 percent would be difficult, 

and 1 percent would be isolated. When economic and environmental risk factors 

are considered, additional areas are likely to be identified as difficult or isolated 

during project planning. Risk factors assigned by the LSTA team and district 

personnel, indicate that about 85 percent of the suitable acres with old-growth forest 

would be in the normal category. 

One objective of the Alaska National Interest Lands Conservation Act (ANILCA) was 

the maintenance of timber supply for the Southeast Alaska timber industry because 

of its contribution to the local and regional economies of Southeast Alaska. For 

similar reasons, TTRA (Section 101) directs the Forest Service to seek to provide a 

supply of timber from the Tongass that meets annual market demand and the 

market demand for each planning cycle to the extent consistent with providing for 

the multiple-use and sustained-yield of all renewable resources. The planning cycle 

is assumed to be the 10- to 15-year period between Forest Plan revisions. 

The Tongass timber program is part of a long-term cooperative effort among the 

federal government, the State of Alaska, and local governments to provide economic 

diversity and stability in Southeast Alaska and more year-round employment. 

During the 1920s, the Forest Service proposed several long-term sales to help 

establish a pulp industry in Southeast Alaska. The objective was to provide a sound 

economic base in Alaska through establishment of a permanent year-round pulp 

industry. The Forest Service established requirements to process timber in Alaska, 

including the construction of pulp mills, via 50-year timber sale contracts awarded in 

the early 1950s. The first successful sale was made in 1951, and the construction of 

a pulp mill was completed at Ward Cove near Ketchikan in 1954. This long-term 

contract was held by Ketchikan Pulp Company (KPC). During the 1950s, the Forest 

Service offered three additional long-term sale contracts. The belief was that a longterm sale was necessary to ensure the supply of timber and attract an integrated 

wood products industry to Alaska. 

These long-term timber sale contracts are no longer operating. The U.S. PlywoodChampion Paper contract in the Juneau District was canceled by mutual consent in 

1976; no operations were performed on the ground. The Pacific Northern Timber 

Company contract, located on the Wrangell District, required the construction and 

operation of both a sawmill and pulp mill for 50 years. Only the sawmill was built 

and operated and the contract was limited to 25 years. All ground activities for the 

Wrangell Unit were completed in 1981 (USDA Forest Service 1997a). The Alaska 

Pulp Corporation (APC) closed their Sitka pulp mill in 1993 and the Wrangell sawmill 

closed in 1995. Their contract was terminated by the Forest Service in 1994. An 

end to the KPC contract, which was due to expire in 2004, was negotiated in 

February 1997. The KPC pulp mill closed in 1997. 

The average annual timber harvest on the Tongass was about 40 MMBF per year 

from the early 1900s to 1952. Timber harvest averaged about 358 MMBF per year 

(sawlog and utility) for the next 45 years after establishment of the long-term 

contracts in the 1950s. This volume was generated primarily from the KPC, Pacific 

Northern Timber, and APC contracts. Harvests peaked in 1973 at approximately 

591 MMBF and then declined to a low of about 181 MMBF by 1985 (Figure 3.13-3). 

Harvest levels rose again until 1990 and then declined to their current levels. 

Long-term sales comprised almost three-quarters of the timber volume made 

available during the period of 1980 through 1991 (USDA Forest Service 1997a; 

Table 3-74). Between Fiscal Years 1980 and 1995, an annual average of 247 

MMBF of volume was made available to the long-term contract holders. Because of 

Tongass Timber 

Sale Program 
3 Environment and Effects

Timber 3-332 Final EIS

market fluctuations, appeals and litigation, and other factors, the long-term contract 

holder annual average harvest between 1980 and 1995 was about 249 MMBF. 

Total annual average harvest was approximately 340 MMBF over the same time 

period. KPC continued to harvest timber until 2000 (Figure 3.13-3). Annual timber 

harvest averaged approximately 46 MMBF from 2001 to 2005. This represents 

approximately 13 percent of the total average annual harvest from 1980 to 1995 

(340 MMBF). This decrease is largely due to the termination of the long-term 

contracts with APC and KPC. However, there has also been a decrease in harvest 

by independent timber operators since 1990 (Figure 3.13-4). Independent timber 

operators harvested an average of more than 100 MMBF per year between 1980 

and 1990. Harvest peaked at 173 MMBF in 1990, about 37 percent of that year’s 

total harvest. Independent harvest decreased sharply in the early 1990s, with a low 

of 27 MMBF harvested in 1996 (refer to the Economics and Social section for a 

discussion of this decline). Annual independent harvest has continued to fluctuate 

since then, ranging from 34 MMBF in 2002 to 67 MMBF in 2000 (Figures 3.13-3 and 

3.13-4). 

Figure 3.13-3 

Tongass National Forest Timber Harvest Histogram for 1980 to 2006 

0

50

100

150

200

250

300

350

400

450

500

1980

1981

1982

1983

1984

1985

1986

1987

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

Fiscal Year

MMBF

IND APC KPC

KPC – Ketchikan Pulp Company; APC – Alaska Pulp Corporation; IND – Independent timber operators 

Source: USDA Forest Service harvest records 
Environment and Effects 3 

Final EIS 3-333 Timber 

Figure 3.13-4 

Tongass National Forest Timber Harvest Line Graph for 1980 to 2006 

0

50

100

150

200

250

300

350

400

1980

1981

1982

1983

1984

1985

1986

1987

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

Fiscal Year

MMBF

Long-Term IND

Long-Term – Long-term contract holders (APC and KPC); IND – Independent Timber Operators 

Source: USDA Forest Service harvest records 

The current Tongass timber program is composed of a large sale program, a small 

sale program, and a firewood and personal use program. Harvest volumes 

averaged 45 MMBF between 2002 and 2006, notably lower than the average annual 

harvest of 358 MMBF for 1952 to 1997 (Table 3.13-6 in the following sub section) 

and the Allowable Sale Quantity (ASQ) of 267 MMBF per year approved in the 1997 

Record of Decision. 

The timber sale program has been in transition since the end of the long-term 

contracts. Many small operators are in the process of developing direct markets for 

value-added products, such as molding, tongue-in-groove, paneling, and furniture. 

There were 15 small mill operators on Prince of Wales Island alone as of August 2005 

(Petersen and Bruns 2005). The Forest has created a program to make wood 

available to small operators, referred to as the microsale program. This program 

makes dead and down wood with a value of $10,000 or less available to local 

purchasers by competitive means. The Forest Service and the University of Alaska 

have created the Ketchikan Wood Technology Center to focus on ways to help the 

local timber industry. Among other things, the center has developed log grades for 

Alaskan wood products. 

The primary sources of timber in Southeast Alaska are the Tongass National Forest, 

private corporations (principally Alaska Native Corporations formed through the 

Alaska Natives Claims Settlement Act [ANCSA]), and the State of Alaska (USDA 

Forest Service 1997a; Table 3-75). Timber harvest patterns are discussed in 

greater detail in the Economic and Social Environment section of this document.
3 Environment and Effects

Timber 3-334 Final EIS

Timber Sale Management 

The Forest Service employs a “pipeline” approach to timber sale planning to provide 

a stable timber sale program and a continuous flow of timber to regional timber 

processors. The resulting program is complex and requires that the Forest Service 

manage four “pools” of timber volume, commonly referred to as the timber pipeline: 

• Timber volume identified in the Forest Service’s 10-year Timber Sale Plan. 

This pool contains sales available for future timber sale planning and 

preparation. 

• Timber volume in preparation. This pool contains sales that are being 

analyzed and are undergoing public comment through the NEPA process. This 

can take from 2 to 4 years to complete and ends when a NEPA decision is 

made. 

• Timber volume available for sale. This pool contains NEPA-approved sales. 

Administrative appeals have been resolved, and litigation, if any, has also been 

resolved. This volume is available to program managers to schedule for sale 

offerings. Managers need to maintain enough volume in this pool to be able to 

schedule future sale offerings in an orderly manner and of the size and 

configuration that best meets regional demand. The Forest Service tries to 

announce probable future sale offerings at least a year in advance to allow 

potential purchasers an opportunity to conduct their own evaluations of these 

offerings in order to determine whether to bid and, if so, how much to offer. 

• Timber volume under contract. This pool contains sales that have been sold, 

but not yet harvested. Timber contracts typically give the purchaser 3 to 5 years 

to harvest or remove the timber purchased. The Forest Service attempts to 

maintain about 3 years of unharvested timber volume under contract to 

purchasers. This practice is not limited to the Alaska Region, but is particularly 

relevant to Alaska because of the nature of the land base. The relative absence 

of roads, the island geography, and steep terrain mean that much of the timber 

is isolated and timber purchasers need longer-than-average lead times to plan 

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

beginning harvest. 

• Timber sales can take from 3 to 5 years to complete. Sales offered by the 

Forest Service vary in size to meet the needs of different purchasers. The time 

taken to complete a sale may vary with the size of the offering. Uncertainty and 

delays may be introduced through appeals and litigation. The pipeline approach 

and the variable length of the timber sale process generally make it difficult to 

draw a direct relationship between particular sales and regional timber demand. 

Not all of the volume offered for sale since 2001 has been sold. Some sales did 

not receive bids and many others have been held up by appeals and/or litigation 

(Table 3.13-6). There were both project- and Forest Plan-related appeals and 

litigation (i.e., the Roadless Rule). 

Timber under Contract 

As of May 19, 2006, there were approximately 70 timber sales with approximately 

118 MMBF of timber volume under contract on the Tongass National Forest. 

Although there are nearly 50 timber companies and individuals that either purchase 

timber or have shown an interest in purchasing timber from the Tongass, over 85 

percent of the timber under contract is under contract with four operators: Viking 

Lumber Company (49.8 percent), Pacific Log and Lumber (26.1 percent), Icy Straits 

Lumber (7 percent), and Alcan Forest Products (5 percent). These figures do not 

include all microsales (sales under $10,000). Timber under contract is discussed in 

greater detail in the Economic and Social Environment section. 
 Environment and Effects 3 

Final EIS 3-335 Timber 

Long-term sales comprised almost three-quarters of the timber volume harvested 

during the period of 1980 through 1995 (Figure 3.13-3). During this period, an 

annual average of 249 MMBF of volume was harvested under the long-term 

contracts. During this same period, independent sales averaged 91 MMBF per year, 

ranging from a low of 36 MMBF in 1983 to a high of 173 MMBF in 1990. 

The primary sources of timber within Southeast Alaska are the Tongass National 

Forest, private corporations (principally Alaska Native Corporations formed through 

ANCSA), and the State of Alaska (Table 3.13-7). Between 1980 and 1990, harvest 

from the Tongass contributed about 50 percent of the timber supply in Southeast 

Alaska. However, timber harvest since 1990 has fallen to less than 50 percent of 

total supply. The Tongass contributed approximately 23.6 percent of the total timber 

supply in Southeast Alaska between 2001 and 2005. 

Table 3.13-6 

Volume of Timber Offered, Sold, and Harvested from the Tongass 

National Forest for FY 2002-2006 (MMBF) 1

Fiscal Year Offered Sold Harvested 

2002 56.9 24.4 33.8 

2003 88.8 30.5 51.3 

2004 72.6 87.1 46.4 

2005 110.4 67.3 49.6 

2006 24.0 85.0 43.0 

5-Year Average 70.5 58.9 44.8 1

 Volumes do not include re-offered sales, re-sold sales, or credit volumes 

Source: USDA Forest Service, Alaska Region. Data on file with Regional Economist, Ecosystems 

Planning, USDA Forest Service, PO Box 21628, Juneau, AK 99802-1628

Table 3.13-7 

Timber Harvest and Imports for Southeast Alaska, 1992-2005 (MMBF)1

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005

Tongass NF Sawlogs 303.1 268.3 221.8 181.3 97.4 94.4 107.6 132.8 133.7 39.8 30.0 44.1 40.9 43.3

Utility Logs2 66.6 56.7 54.0 39.8 22.8 12.2 12.2 12.9 13.0 7.9 3.8 6.7 5.4 6.2

State of Sawlogs 14.9 5.0 18.1 3.6 4.5 5.2 5.6 7.3 47.8 48.0 48.0 32.7 21.9 40.7

Alaska3 

Utility Logs 0.1 0.0 2.7 2.2 2.5 0.3 1.9 0.1 12.1 5.2 9.3 2.1 2.3 2.2

BIA Sawlogs 

and Utility2

4.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.4 0.0 0.0 0.0 0.0

Alaska Sawlogs 348.7 328.2 275.0 233.9 292.4 335.9 157.6 193.6 114.6 106.5 93.6 98.1 92.0 99.3

Native 

Corporations

4 

Utility Logs2 97.0 82.2 12.3 81.1 37.7 47.6 59.0 45.4 46.0 13.3 8.1 7.6 6.9 4.6

Sawlogs 671.2 601.5 514.9 418.8 394.3 435.5 270.8 333.7 296.2 194.3 171.6 174.9 154.8 183.3

Utility Logs2

 163.7 138.9 69.0 123.1 63.0 60.1 73.1 58.4 71.1 26.3 21.2 15.4 14.6 13.2

Southeast 

Alaska Total 

Total 834.9 740.4 583.9 541.9 457.3 495.6 343.9 392.1 367.2 220.6 192.8 190.3 169.4 196.5

Alaskan 

Imports5

Sawlogs 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 -- -- -- -- -- 

Utility Logs2 3.0 3.0 3.0 11.5 34.1 0.0 0.0 0.0 0.0 -- -- -- -- -- 

Chips 0.0 1.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 -- -- -- -- -- 

1

 National Forest and Bureau of Indian Affairs (BIA) harvests reported for fiscal years. All other ownerships reported in calendar 

years. 2

 Utility volume includes logs with less than one-third net sawlog but at least one-half firm usable pulp chips. 3

 Harvests from Alaska Mental Health Trust and University of Alaska lands omitted prior to 2000. 4

 Estimated by telephone survey. Metric tons converted to log scale at a ratio of 2.7 tons per thousand board feet (MBF). 5

 Compiled from trade statistics available from the U.S. Department of Commerce. Metric tons converted to log scale at a ratio of 2.7 

tons per MBF. 

Source: USDA Forest Service, Alaska Region. Data on file with: Regional Economist, Ecosystems Planning, USDA Forest Service, 

PO Box 21628, Juneau, AK 99802-1628 
3 Environment and Effects

Timber 3-336 Final EIS

Timber Demand 

Demand for timber products from the Tongass National Forest is discussed in detail 

in the Economic and Social Environment section. 

Environmental Consequences 

The analysis of the potential effects of the alternatives addresses the following 

questions: 

• How much land would be allocated to timber production? 

• What silvicultural systems and vegetative practices would be utilized? 

• What would the ASQ be under each alternative? 

• What projected log grade or quality would be provided? 

• What would the product mix be, in terms of sawlogs and utility logs? 

• What would the long-term sustained yield (LTSY) be under each alternative? 

• What are the factors that affect the attainment of the ASQ? 

• What would be the future condition of the Forest in 150 years? 

The analysis of timber supply and demand for timber products, as well as how 

existing sales under contract and timber volume in preparation may be affected by 

the alternatives, is discussed in the Economic and Social Environment section. 

The effects on the timber industry infrastructure and employment levels are also 

discussed in that section. 

There are approximately 2.4 million acres of tentatively suitable lands, as defined by 

NFMA regulations (36 CFR 219.14(a)) and Section 102 of TTRA. Slightly over 

1 million acres of this is mapped as suitable under Alternative 5 (No Action) 

However, as described below (see factors affecting the ASQ), only an estimated 

781,000 acres are suitable for harvest and only 687,000 acres are scheduled for 

harvest under Alternative 5. This includes old-growth and young-growth forest. 

Appendix A of the Forest Plan contains a detailed discussion of the tentatively 

suitable determination process. The amount of suitable land would vary by 

alternative. 

Table 3.13-8 displays the distribution of forest lands, tentatively suitable lands, and 

suitable lands by alternative. The amount of suitable land that would be scheduled 

for harvest in order to meet the ASQ under each alternative is also shown. The 

amount of suitable land would vary from less than 2 percent of the Forest under 

Alternative 1 to nearly 7 percent of the Forest in Alternative 7. No alternatives have 

a suitable land base greater than 1.2 million acres. Differences result from 

assigning the Old-growth Habitat, Remote Recreation, Semi-remote Recreation, and 

other non-development LUDs. Alternatives 1, 2, 3, 5, and 6 have substantial acres 

of tentatively suitable lands assigned to the Old-growth Habitat LUD. Alternative 4 

uses a different strategy to provide old-growth habitat and primarily assigns land to 

the Old-growth Habitat LUD in four Biogeographic provinces. In other areas, 33 

percent of the productive forest land in each Value Comparison Unit would be 

maintained in an old-growth condition. Alternative 7 would have the least restriction 

on harvest in old-growth forest; it does not include Old-Growth Habitat LUDs nor 

would it have minimum old-growth retention requirements. 

Suitable Timber 

Lands 
 Environment and Effects 3 

Final EIS 3-337 Timber 

Table 3.13-8 

Land Classification (thousands of acres), Tentatively Suitable and Suitable Lands1

Alternative 

Classification 1 2 3 4 5 6 7 

Total National Forest land (Items 1 and 2) 16,774 16,774 16,774 16,774 16,774 16,774 16,774 

1. Non-Forest land (includes water) 6,918 6,918 6,918 6,918 6,918 6,918 6,918

2. Forest land 9,856 9,856 9,856 9,856 9,856 9,856 9,856

3. Forest land withdrawn from Timber 

production 4,234 4,234 4,234 4,234 4,234 4,234 4,234

4. Available Forest Land (Item 2 minus 

item 3) 5,621 5,621 5,621 5,621 5,621 5,621 5,621 

5. Non-Productive Forests: Forest land not 

capable of producing crops of industrial 

wood 

 2,339 2,339 2,339 2,339 2,339 2,339 2,339 

6. Available forest lands (PFL) (Item 4 

minus item 5) 3,282 3,282 3,282 3,282 3,282 3,282 3,282

7. Forest lands: physically unsuitable 572 572 572 572 572 572 572

8. Forest lands: inadequate information 345 345 345 345 345 345 345

9. Tentatively suitable forest lands 2,365 2,365 2,365 2,365 2,365 2,365 2,365

(Item 6 minus Items 7 and 8) 

10. Tentatively suitable forest lands that are not appropriate for timber production by LUDs: 

a. Semi-Remote Recreation 1,231 853 669 367 494 494 381

b. Remote Recreation 127 122 109 95 77 76 95

c. Old-Growth Habitat 458 458 458 138 432 458 0

d. Wild Scenic or Recreation Rivers 42 42 42 42 42 42 42

e. Special Interest Areas 50 50 50 50 33 50 50

f. Experimental Forest (proposed) 6 6 6 6 - 6 6 

g. Scenic Viewsheds-SV (Beach Fringe, 

 Riparian) 8 28 38 90 55 53 63

h. Modified Landscapes-ML (Beach 

 Fringe, Riparian) 24 39 49 92 63 60 65

i. Timber production-TM (Beach Fringe, 

 Riparian) 42 85 105 177 133 126 128

Total (Items 10a through 10i): 2,116 1,682 1,526 1,058 1,328 1,364 829

11. Mapped Suitable (Item 9 minus 

 Item 10) 378 683 839 1,308 1,037 1,001 1,536

12. Model Implementation Reduction 

 Acreage 65 138 178 309 255 227 362

13. Suitable Acres Available for Timber 

 Production (Item 11 minus Item 12) 312 545 661 1,000 781 774 1,174

14. Suitable Acres Scheduled 144 394 514 892 687 663 1,070

14a Scheduled Old growth 86 215 313 656 463 445 807

14b Scheduled Young Growth 58 179 200 236 224 218 262

Allowable Sale Quantity (average annual volume) 

1st Decade 

 Sawlog (MMBF) 43 132 177 270 232 232 384

 Utility (MMBF) 7 20 27 42 35 35 37

Total 49 151 204 312 267 267 421

2nd Decade 

 Sawlog (MMBF) 43 130 179 310 231 230 384

 Utility (MMBF) 7 21 26 50 36 37 37

Total 49 151 205 360 267 267 421

1 Sums and differences may not appear exact due to rounding. 

 Source: Forest Service GIS database. 
3 Environment and Effects

Timber 3-338 Final EIS

Removing land from the suitable land base reduces both potential ASQ and 

long-term timber growth and yields. While the effect is not perfectly linear, the 

magnitude of the reduction is generally related to the proportion of lands removed. 

The timber production lost is irretrievable but is not irreversible. If future designation 

of these lands is changed to allow timber management, it would be possible to 

resume timber management activities. Where land is dedicated to road construction 

or development of facilities, minerals, or rock excavation, the loss of land for timber 

production is generally irretrievable and may be irreversible. 

This section describes vegetation management practices prescribed in the Forest 

Plan, including regeneration methods, reforestation, and intermediate treatments. 

Definitions for each of these practices, how they will be applied, and expected 

effects on the timber resource are provided. 

Regeneration Harvest Methods 

For modeling and planning purposes, the current Forest Plan considered the three 

regeneration methods discussed under Regeneration Systems: even-aged system, 

two-aged system, and uneven-aged system (group selection). These same 

methods were also considered in this Plan Amendment. This does not mean that 

these are the only these regeneration methods that will be used on the Tongass. 

Other even-aged methods such as shelterwood, which may be utilized to meet 

specific objectives, would be similar to clearcut with reserves in regards to 

appearance and effects (or to clearcuts if the shelterwood is later cut). For this 

reason, only these three methods were modeled and displayed. Appendix G of the 

1997 Land Management Plan Revision FEIS contains detailed descriptions of the 

various silvicultural systems and their advantages and disadvantages. In addition, 

other regeneration methods may be applied on a limited scale to test their utility in 

achieving other forest management objectives. 

Implementation of any Forest Plan alternative would include a full array of 

silvicultural prescriptions, including modification of these methods, depending on the 

site-specific conditions. The choice of the regeneration method and rotation length 

would be based upon site-specific analysis done at the project level, would consider 

multiple resource needs and objectives, and would include the rationale for using the 

selected regeneration method. This would be documented in the silvicultural 

prescription, which must be approved by a certified silviculturist. 

Table 3.13-9 displays the annual number of acres estimated for each of the three 

main regeneration methods by alternative for the first and fifth decades of the Plan 

(based on the SPECTRUM model outputs). The acreages displayed are for 

modeling purposes in order to estimate Forest Plan outputs and do not limit the 

manager’s ability to use any regeneration method to best meet project goals and 

objectives. The model used to develop the current Forest Plan (FORPLAN) 

estimated that 80 percent of the harvest under the selected alternative (the current 

Forest Plan) would be even-aged and the remaining 20 percent would be two-aged. 

Sales sold in recent years have averaged 76 percent even-aged harvest, 16 percent 

two-aged harvest, and 8 percent uneven-aged harvest. The acres modeled for 

regeneration harvest under the No-Action Alternative vary somewhat from estimates 

in the current Forest Plan. The regeneration harvest acres in the current Forest Plan 

were based on FORPLAN model outputs, while the estimates used in this analysis 

are based on the SPECTRUM model. Changes were made in the assumptions used 

in the SPECTRUM model based on experience gained under the current Plan. 

Silvicultural 

Systems and 

Practices 
 Environment and Effects 3 

Final EIS 3-339 Timber 

SPECTRUM models suitable land as either full, modified, or incidental timber yield 

(Table 3.13.10). For this analysis, lands identified by the model as full timber yield 

were categorized as likely to be prescribed for even-aged management. Lands 

identified as modified timber yield were categorized as likely to be prescribed as 

two-aged management or small patch cuts, while areas identified as incidental 

timber yield were categorized as likely to be prescribed as uneven-aged 

management, including openings less than 2 acres. 

Table 3.13-9 

Vegetative Management Practices 

Average Annual Harvest Acres of Suitable Lands Modeled in First Decade 

Alternative 

1 2 3 4 5 6 7 

Regeneration Harvest 

Even-aged1 1,180 3,758 5,220 7,226 5,902 6,829 10,033 

Two-aged2 600 1,534 2,081 3,695 3,819 2,269 5,484 

Uneven-aged3 2 60 115 351 244 234 429 

Regeneration Treatments 

Natural and Artificial 1,780 5,291 7,301 10,921 9,721 9,459 15,516 

Precommercial Thinning

 0 0 0 1,066 617 1,691 2,251 

Commercial Thinning

 0 183 169 629 451 430 435 

Average Annual Harvest Acres of Suitable Lands Modeled in Fifth Decade 

 Alternative 

 1 2 3 4 5 6 7 

Regeneration Harvest 

Even-aged1 820 2,367 2,912 7,992 4,445 4,976 8,549 

Two-aged2 595 1,464 2,064 3,259 3,577 2,583 4,541 

Uneven-aged3 64 310 386 793 529 563 820 

Regeneration Treatments 

Natural and Artificial 1,415 3,831 4,977 11,250 8,022 7,559 13,090 

Precommercial Thinning

2 1,055 717 2,256 1,355 994 1.330 

Commercial Thinning 

 0 571 910 1,779 1,227 1,550 2,307 

1 Acres modeled as Full Timber Yield by SPECTRUM. 2 Acres modeled as Modified Timber Yield by SPECTRUM, two-aged harvest or patch cuts. 3 Acres modeled as Incidental Timber Yield by SPECTRUM, uneven-aged harvest or openings less than 2 acres. 4 Natural regeneration refers to seedlings established from seeds falling to the ground from trees growing (or that 

grew) on the site. Artificial regeneration refers to planted seedlings. 

Note: Acres harvested per year decreases with time as more young-growth reaches harvest age. Young-growth forest 

generally has lower defect rates and higher volume per acre. 

Source: SPECTRUM Model (Forest-wide Activity and Output Results) 
3 Environment and Effects

Timber 3-340 Final EIS

Table 3.13-10 

Timber Management Intensity by Alternative over 100+ Years (acres)1 

Alternative High Timber Yields Moderate Timber Yields Incidental Yields2

1 80,682 48,074 4,865

2 284,729 121,791 30,065

3 397,585 164,152 37,628

4 758,520 263,744 72,679

5 504,600 176,504 48,232

6 563,090 205,897 49,117

7 823,478 445,896 76,133 1 Suitable timber lands, cumulative treatments over 100 years, including second entry to harvest mature younggrowth stands. Not all suitable lands would be harvested. 2 Suitable land in areas where maintenance of scenic quality is important and sensitive wildlife habitat areas. 

Source: SPECTRUM Model 

Species composition. Of the four major commercial tree species on the Tongass, 

western hemlock is the most shade tolerant, followed by western redcedar, yellowcedar, and Sitka spruce, in that order (USDA Forest Service 1990). Western 

hemlock is by far the most prevalent species, making up 83 percent of the oldgrowth forests (Farr and McClellan 1994). Dwarf mistletoe commonly infects 

western hemlock. Sitka spruce and yellow-cedar are rarely infected by dwarf 

mistletoe and western redcedar is not infected (Holsten et al. 2001). Having a 

diverse species mix contributes to wildlife habitat quality, species diversity, and 

minimizes losses due to insect and diseases that are species specific. In addition, 

Sitka spruce, yellow-cedar, and redcedar have higher economic values than western 

hemlock. 

Regeneration harvest methods that create open conditions and expose bare mineral 

soil, such as clearcutting, encourage germination and growth of Sitka spruce (Ruth 

and Harris 1979). Group selection with openings of at least 2 acres, could also 

encourage germination and growth of Sitka spruce and the cedars, but may do so to 

a lesser degree than clearcutting due to side shading. The amount of sun reaching 

the surface would vary depending on the size, shape, and aspect of the opening. 

Regeneration methods that create less ground disturbance and smaller openings in 

the canopy such as single tree selection, smaller sized groups in group selection, 

overstory removals, and treatments with many reserve trees may encourage growth 

of western hemlock at the expense of less shade-tolerant species (Sitka spruce and 

yellow-cedar). However, limited retrospective studies indicate that Sitka spruce can 

be maintained in mixed hemlock-Sitka spruce stands over a wide range of cutting 

intensities if enough Sitka spruce trees are present in the stand after harvest (Deal 

and Tappeiner 2002, Deal et al 2002). Regeneration under two-aged systems 

would be similar to regeneration under even-aged harvest if leave trees are 

concentrated near the unit boundaries but may be more like uneven-aged harvest if 

reserve trees are scattered through the unit, due to shading from the residual 

overstory. 

Alternatives 1, 2, and 3 are projected to have the least amount of two-aged and 

uneven-aged harvest (Table 3-13-9), followed by Alternatives 6 and 5, respectively. 

Alternatives 4 and 7 would have the most acres of two-aged and uneven-aged 

harvest. Alternatives that harvest fewer acres, especially Alternatives 1 and 2, 

would tend to maintain species composition across the Tongass similar to that found 

in the old-growth forests, because much less old-growth forest would be harvested. 

Forested areas in non-development LUDs normally subject to gap wind disturbance 

effects (refer to the Forest Health section) are likely to maintain the current species 

mix unless one of the predicted effects of climate change, an increase in 

catastrophic wind events, occurs. Juday et al. (1998) rated many potential impacts 
 Environment and Effects 3 

Final EIS 3-341 Timber 

on the coastal forests of Southeast Alaska due to climate change. They concluded 

that there was a high risk of increased large scale blowdown across Southeast 

Alaska and an increased windthrow around harvest units. If this occurs, more area 

may come to resemble natural forests currently exposed to catastrophic winds. 

Alternatives with higher even-aged harvest, especially Alternatives 4 and 7, but also 

Alternatives 5 and 6, are more likely to create stand conditions that mimic 

catastrophic disturbance to some extent. However, these stands would lack the 

large amount of down wood found in natural stands created by catastrophic 

windstorms and many would be in areas that normally are subjected to gap 

disturbance. 

Damage to residual trees. Western hemlock and Sitka spruce are thin-barked, 

shallow rooted species and are easily wounded during timber harvest activities 

(Harris and Farr 1974, USDA Forest Service 1983). These wounds provide an 

avenue for disease organisms to enter trees, causing rot and reducing their future 

economic value (Hennon and DeMars 1997). The size and shape of the opening 

affects the amount of damage. A retrospective study of 18 stands reported that 

overstory trees did have a greater incidence of wounding in stands that had been 

partial cut than in uncut stands and that the wounding increased with intensity of 

cutting; although, the study concludes that there was no significant increase in tree 

mortality, or in growth loss (Deal et al. 2002). McClellan (2005) reported that a 

recent operational-level study (part of the Alternatives to Clearcutting Study) found 

that there were increased problems during tree falling and yarding in group selection 

openings of less than 30 meters diameter (approximately 100 feet). Alternatives 1, 2, 

and 3 would have the least amount of two-aged and uneven-aged harvest, followed 

by Alternatives 6 and 5, respectively. Alternatives 4 and 7 would have the most 

acres of two-aged and uneven-aged harvest (Table 3.13-9). 

Diseased trees may be more susceptible to windsnap and snow breakage (Nowacki 

and Kramer 1998), although one retrospective study found that many uprooted or 

broken-stemmed trees had died before falling (Hennon and McClellan 2003). In 

either case, the loss of residual trees that are left standing to provide structural 

diversity would result in management objectives not being met. The cedars are also 

susceptible to damage and subsequent attack by disease organisms. However, 

their wood appears to be more resistant to decay (USDA Forest Service 1990). 

Refer to the Forest Health section for a discussion of how the alternatives may affect 

dwarf mistletoe, insects, disease, and windthrow. 

Growth rates. Estimation of future yields from young-growth stands created by 

timber harvest is critical for developing ASQs for the Forest Plan. Growth and yield 

tables have been developed for even-aged stands in Southeast Alaska (Taylor 

1934, Farr 1984). Published growth and yield tables have not been developed for 

stands regenerated under two-aged or uneven-aged methods. Unpublished yield 

tables for these harvest types were developed by the Forest Service for use in 

estimating ASQ. These are part of the planning record. 

Given that over 30 percent of the volume in old-growth stands is defective (Farr and 

Harris 1971), it is unlikely that these trees would respond to the additional growing 

space made available through partial harvest. While young western hemlock stands 

respond well to thinning, trees older than 100 years respond poorly to release 

(USDA Forest Service 1990). Information on growth rates for trees growing under a 

canopy in Southeast Alaska is limited. Western hemlock is shade tolerant and may 

grow well under partial shade. Sitka spruce is less shade tolerant than hemlock and 

it is reasonable to expect some growth loss when Sitka spruce is grown under 

residual overstory trees. However, Deal and Tappeiner (2002) reported that, in most 

cases, concerns about greatly reduced stand growth and vigor were 

unsubstantiated, based on a retrospective study of 18 stands in Southeast Alaska 

that had been partially cut 12 to 90 years earlier. Analysis of these stands did not 
3 Environment and Effects

Timber 3-342 Final EIS

detect significant changes in tree species composition, stand growth, hemlock dwarf 

mistletoe infection, or mortality rates (Deal et al. 2002). 

One measure of future growth rates is the total amount of slow-growing old forest 

that would be harvested over the rotation. Alternative 7 would result in the most 

harvest, and the most even-aged harvest, followed by Alternatives 4, 5, 6, 3, 2, and 

1, in that order. Alternative 7 would result in more than nine times the acres of old 

forest converted to productive young-growth stands as Alternative 1 (more than 

807,000 compared to nearly 86,000 acres) and approximately 75 percent more than 

Alternative 5, No Action (more than 807,000 compared to nearly 464,000 acres). 

Reforestation 

The NFMA requires assurance that all areas receiving final removal harvest can be 

adequately restocked with trees within 5 years of that harvest. On the Tongass, 

natural restocking is usually adequate to meet this objective because both western 

hemlock and Sitka spruce are prolific seed producers (USDA Forest Service 1983). 

The new stand originates from advance regeneration and from seeds that come 

from residual trees or from trees adjacent to the harvest unit. Since 1988, natural 

regeneration has accounted for 94 percent of the reforestation program. The 

remaining 6 percent has been artificial regeneration (planting). The future need for 

planting would be determined on a site-specific basis to achieve management 

objectives such as increasing the abundance of Sitka spruce where western 

hemlock or brush may have a competitive edge or increasing the abundance of 

yellow-cedar or western redcedar, where natural regeneration of these species is 

anticipated to be inadequate. The desired species composition, required number of 

seedlings, and method of regeneration should be displayed in the silvicultural 

prescription. Table 3.13-9 lists the acreages that would require reforestation (natural 

or artificial) in the first and fifth decades by alternative. 

Intermediate Treatment Methods 

Intermediate treatments are any manipulation in a stand that occurs between two 

regeneration periods (Daniel et al. 1979). The regeneration period establishes the 

new stand, either through natural regeneration or through planting. Intermediate 

treatments are done to ensure that the new stand has the desired species 

composition, tree health, growth, and spacing, as well as to recover product value. 

They can also be used to create or improve habitat for wildlife. Intermediate 

treatments may be used if approved as part of a site-specific silvicultural 

prescription. Currently, the only intermediate treatment commonly used on the 

Tongass is pre-commercial thinning. 

Precommercial thinning is applied in young stands that have not reached 

merchantable size. It is the most commonly applied intermediate treatment in 

Southeast Alaska. It is used to: 

• Favor preferred tree species. 

• Concentrate tree growth on fewer individuals to produce larger trees in a shorter 

period of time. 

• Increase the amount of light reaching the forest floor, thereby retaining 

understory vegetation that is valuable wildlife forage (DellaSalla et al. 1994). 

There are concerns over the effects of precommercial thinning on future wood 

quality, especially wider spacing of residual trees (McClellan 2005). Thinning can 

increase epicormic sprouting on the Sitka spruce trees (Deal et al. 2003). Lower 

density thinnings could increase taper and increase the size and longevity of lower 

branches, thus reducing future wood quality (McClellan 2005). Larger lower 
 Environment and Effects 3 

Final EIS 3-343 Timber 

branches increase fluting in western hemlock, which reduces wood quality (Julin et 

al. 1993) (refer to the Forest Health section for a discussion of fluting). 

Pruning removes the lower branches of a tree at an early age in order to produce 

knot-free wood. It is the only way to produce clear lumber in rotations less than 100 

years (Daniel et al. 1979). However, pruning Sitka spruce trees can encourage 

epicormic sprouting in Sitka spruce and can limit diameter growth for all species. 

Deal et. al. (2003) found that the total number of sprouts was similar among different 

levels of pruning but significantly more large sprouts were produced when more of 

the crown was removed. 

Commercial thinning is applied to young stands that have reached merchantable 

age. The primary difference between commercial and precommercial thinning is 

that the trees cut in a commercial thinning operation are removed and sold. 

Commercial thinning can be used to: 

• Meet market demand for wood products, either from suitable or unsuitable lands 

(harvest would only be used on unsuitable lands to meet resource objectives, 

such as improving wildlife habitat, and where no irreversible damage would 

occur). 

• Maintain or increase the growth rate of dominant and co-dominant trees by 

removing trees in the lower crown classes, increasing merchantable yields over 

the rotation. 

• Stimulate development of more complex canopy structures or enhance forage in 

the understory in order to meet wildlife habitat needs. 

• Improve scenic quality. 

By maintaining or increasing growth rates, commercial thinning lengthens the time 

needed for a stand to reach CMAI, extending the rotation length (Daniel et al. 1979). 

Precommercial thinning would be implemented under all alternatives based on 

funding. Pruning is likely to play a minor role in the foreseeable future under all 

alternatives. Commercial thinning is expected to play a larger role in meeting future 

demand under all alternatives over the next few decades, as areas harvested in 

earlier decades reach commercial size. Over the long term, alternatives with high 

harvest levels would create more stands, which in time would be available for 

commercial thinning. Also, alternatives that would facilitate creation of an integrated 

timber industry, especially Alternatives 4 and 7, are likely to lead to more 

commercial thinning because there would be a greater demand for smaller logs if, 

for example, a medium density fiberboard mill is built (refer to the Economic and 

Social Environment section for a discussion of the likely product mix under the 

proposed alternatives). 

Allowable Sale Quantity and Timber Sale Program Quantity 

The ASQ of each of the alternatives is an indicator of possible future timber supply 

level that each alternative could produce. ASQ is the maximum quantity of timber 

that may be scheduled for harvest from suitable lands on the entire Forest for the 

next 10 years (36 CFR 219.3). It is usually expressed as an annual average. The 

yearly quantity may exceed or be less than the annual average for the decade. The 

ASQ is a ceiling; it is not a future sale level projection or target and does not reflect 

all of the factors that may influence future sale levels. 

The ASQ is an expression of the biological potential of the forest to produce timber 

within the constraints of other resource needs; it is constrained by harvest limitations 

necessary to meet LTSY requirements, multiple-use considerations, and 

environmental restrictions. Changes in the timber land base, timber inventory, or 

silvicultural prescriptions would affect ASQ. An ASQ is, to some extent, imprecise 

Allowable Sale 

Quantity 
3 Environment and Effects

Timber 3-344 Final EIS

because it is based on estimating techniques (the SPECTRUM model) and Forestwide data rather than on detailed, on-the-ground data from the timber sale area. 

Given the uncertainties inherent in developing an ASQ, shortfalls between the ASQ 

and timber sales are very possible. 

The timber sale schedules for each Ranger District include that portion of the timber 

inventory that is scheduled for sale for a specific year. The schedule may include 

harvests from unsuitable lands and convertible products (such as beach log salvage 

and fuel wood) in addition to sales counting towards the ASQ. Schedules are 

updated annually or more frequently. 

Table 3.13-11 displays the projected timber output for the first and fifth decades that 

could result from implementing each of the seven alternatives in both board feet and 

cubic feet. This output is composed of two categories: sawlogs and utility logs. The 

use and marketability of these log types is discussed in the Economics and Social 

Environment section. Alternatives with higher timber outputs may require a “rampup period”; therefore, ASQ is higher for these alternatives in later decades than in 

the first. Refer to the discussion in the Economics and Social Environment section. 

Table 3.13-11 

Allowable Sale Quantity (First Decade, Average Annual) 

Alt 

Sawlog 

(MMBF)1

Sawlog & Utility 

(MMBF)1

Sawlog 

(MMCF)2

Sawlog & Utility 

(MMCF)2

1 42.6 49.3 8.5 9.9 

2 131.5 151.2 26.8 30.8 

3 176.9 204.0 36.4 41.9 

4 270.0 311.5 55.2 63.6 

5 231.9 267.0 47.7 54.9 

6 231.8 267.0 47.6 54.8 

7 384.0 421.0 78.5 85.9 

Allowable Sale Quantity (Fifth Decade, Average Annual)

Alt 

Sawlog 

(MMBF)1

Sawlog & Utility 

(MMBF)1

Sawlog 

(MMCF)2

Sawlog & Utility 

(MMCF)2

1 46.0 49.3 9.6 10.2 

2 147.7 153.6 31.9 33.1 

3 197.6 204.6 42.7 44.0 

4 326.9 360.0 68.4 75.1 

5 250.0 267.0 53.1 56.5 

6 250.8 267.0 53.8 57.1 

7 397.2 421.0 83.0 87.7 1

 MMBF = million board feet, long log bureau scale 

2

 MMCF = million cubic feet 

Source: SPECTRUM model outputs.

Factors Affecting the Allowable Sale Quantity 

Within LUDs where timber harvest is compatible with the resource objectives of the 

area, there may be “intrusions,” “physical factors,” and “unmapped” standards and 

guidelines that limit timber management opportunities. These factors (discussed 

below), often termed “falldown,” have been recognized at the forest level, and the 

anticipated timber output adjusted appropriately. These limitations may include 

lands that are not capable of supporting a sustained timber management program. 

In other cases, where there are physical limitations, a less intensive or perhaps 

unregulated output may be scheduled for this period. Other factors also contribute 

to differences between ASQs and timber sales, such as budgets and legal 

challenges. 
 Environment and Effects 3 

Final EIS 3-345 Timber 

The Forest-wide estimates used to develop the ASQ considered many of the factors 

contributing to differences between ASQs and the actual volumes produced in 

timber sales. These include factors affecting the suitability determination of forest 

lands that are usually encountered in on-the-ground examinations (e.g., sale 

reconnaissance, stand exams, layout, and sale preparation). For each alternative, 

areas were set aside (not scheduled for harvest) to allow for those factors most 

often encountered. Data from previous case studies, monitoring, site visits, 

inventory data, the GIS database, and the new Stand Density Model map were used 

to develop the acreage estimates (see Appendices A and B for more information). 

More specifically, the following questions were considered: 

1. Is it tentatively suitable? (36 CFR 219.14[a]) 

Appendix A of the proposed Forest Plan outlines the process used to determine the 

tentatively suitable land base. The three most common factors encountered during 

project implementation are: 1) unmapped streams that need buffers due to TTRA or 

Forest Plan standards and guidelines; 2) unmapped extreme hazard soils; and 3) 

forest land incorrectly mapped as capable of growing industrial wood products. 

2. Is it appropriate for timber production? (36 CFR 219.14[c and d]) 

The Forest Plan standards and guidelines were reviewed for elements that are not 

mapped or in the GIS database and that could cause a loss of suitable acres. Eight 

factors were identified: 

Land Selections – reduction due to the conveyance of selected lands to the State 

of Alaska and Native interests. 

TTRA Stream Buffers – reduction due to unmapped Class I and II stream buffers 

(i.e., streams that were not mapped as Class I or II). 

Non-Commercial Forest – reduction due to volume class mapping errors. 

Slope/Soil Hazard – reduction due to unmapped steep slopes (i.e., areas with steep 

slopes or high hazard soils that could not be identified correctly by GIS mapping). 

Cost Efficiency – excludes stands with the lowest economic potential from the 

suitable base. 

Riparian Habitat (Class III streams) – reduction due to unmapped Class III stream 

buffers (i.e., Class III streams that could not be identified during mapping, usually 

due to canopy cover). 

Karst/Caves – reduction due to upgrading of the karst classification to high 

vulnerability on some areas during field exams. 

Remaining Standards and Guidelines – reduction due to unmapped raptor and 

murrelet nests, wolf dens, mountain goat habitat, and habitat linkages. 

The sum of these subfactors produces the overall Model Implementation Reduction 

Factors (MIRF) for each category (geographical area, volstrata, operability class, 

alternative). The process and results are discussed in Appendix B. The average 

MIRF is 42 percent for the north districts, 17 percent for the central districts, and 23 

percent for the southern districts. 

Cost efficiency: TTRA provides that: 

ANILCA is further amended by deleting section 705(d)(16 U.S.C. 539d(d)) in its 

entirety and inserting in lieu thereof: 

[d] All provisions of section 6(k) of the National Forest Management Act 

of 1976 (U.S.C. 1604[k]) shall apply to the Tongass National Forest 
3 Environment and Effects

Timber 3-346 Final EIS

except that the Secretary need not consider economic factors in the 

identification of lands not suited for timber production. (TTRA, Sec. 102.) 

Economics is an important consideration in determining whether lands should be 

harvested; however, experience has proven that it is not feasible to effectively factor 

in economics as part of the suitability determination. Economic conditions fluctuate 

greatly during the course of a plan period. One year a certain area of land or 

species may be uneconomic to harvest, and another year market conditions may 

have changed to where the same area or species would be in demand. This makes 

it difficult to meaningfully assess the economics of harvesting a particular site over a 

10-year period. Also, the value of the timber sale program must be considered as a 

whole rather than by only evaluating individual timber sales or harvest units in 

isolation, because some sales or units of low value are offset by other higher-value 

sales or units. The economics of harvesting any particular site can be considered as 

part of the project decision to approve harvest of the area. 

Non-interchangeable components 

The ASQ is partitioned into two portions, referred to as non-interchangeable 

components (NICs). The ASQ is partitioned to prevent overharvest of the best 

operable ground and to identify that portion of the timber supply that is more 

economic to harvest. The total ASQ is derived from the sum of the timber volumes 

from both NICs. For the Tongass, the following are identified as the NICs: 

NIC I: Normal Operability (85 percent of the suitable land based on the LSTA). 

This is volume scheduled from suitable lands using existing logging systems. Most 

of these lands are expected to be economic under most market conditions. On 

average, sales from these lands have the highest probability of offering a reasonable 

opportunity for a purchaser to profit from his/her investment and labor. This is the 

best operable ground. The percent of volume from NIC I lands that contributes to 

ASQ varies from 87 to 99 percent, depending on the alternative (Table 3.13-12). 

Normal operability includes those systems most frequently used on the Tongass. 

These systems are tractor, shovel, standard cable, and helicopter yarding up to a 

distance of 0.75 mile. 

NIC II: Difficult and Isolated Operability (15 percent of the suitable land based 

on the LSTA). This is volume scheduled from suitable lands that are available for 

harvest using systems not in common use in Southeast Alaska. Most of these lands 

are presently considered economically and technologically marginal. The percent of 

volume from NIC II lands that contributes to ASQ varies from 1 to 13 percent, 

depending on the alternative (Table 3.13-12). 

Difficult operability includes those systems used on the Tongass that have 

significantly higher costs. These may include long-span skyline, multi-span, or 

helicopter with yarding distances greater than 0.75 mile. This category also includes 

lands that have limited access as a result of being isolated by prior harvest activities 

or other management activities. 

Isolated operability refers to small stands of isolated timber that are extremely 

difficult to harvest. The harvest system could vary, but would be more costly due to 

the location of the stand, with average yarding distances greater than 2 miles. 
 Environment and Effects 3 

Final EIS 3-347 Timber 

Table 3.13-12 

Estimated Harvest by Operability Class (NIC I and NIC II) in the First 

Decade (MMBF1

 and percent)

Alternativ

e NIC I NIC II Total 

1 48.8 99% 0.6 1% 49.3 

2 143.5 95% 7.6 5% 151.1 

3 185.5 91% 18.5 9% 204.0 

4 271.8 87% 39.8 13% 311.5 

5 238.5 89% 28.5 11% 267.0 

6 237.7 89% 29.3 11% 267.0 

7 366.5 87% 54.5 13% 421.0 1

 MMBF: million board feet 

Source: SPECTRUM model. Numbers may not appear to add correctly due to rounding. 

Harvest during the first few decades would come primarily for old-growth forests 

within NIC I areas. Harvest in the later decades would come, almost entirely, from 

mature young-growth forests (also in NIC I areas), which are expected to have less 

defect and, therefore, higher volumes per acre. 

Other Factors that Affect the Timber Sale Program 

Other factors that may affect the amount of timber actually sold include the cost of 

preparing a timber sale, administrative appeals and lawsuits (which may delay or 

forestall sales), transportation and fuel costs (which affect the cost of harvesting a 

sale, especially a helicopter sale), and market conditions that may discourage 

purchasers from bidding on sales. Additional harvest may occur on lands that are 

not suitable for timber management, for example, to stimulate development of more 

complex canopy structures or to enhance forage in the understory in order to meet 

wildlife habitat needs. This would only occur if it is determined that there would be 

no irreversible damage to resources. Another example would be incidental harvest 

on steep slopes. These types of harvest would not contribute to ASQ, but would 

add to the total timber harvest on the Forest. 

Allowable Sale Quantity and Long-term Sustained Yield Capacity 

LTSY is the maximum timber yield that can be sustained indefinitely from lands 

managed for timber production when all stands have been converted to a managed 

state. This varies by alternative, depending on the amount of suitable land and on 

standards and guidelines particular to each alternative. LTSY is a function of the 

total number of acres allocated to timber management, the management intensity, 

standards and guidelines, silvicultural systems, and the productive capacity (conifer 

growth) of the suitable lands. The harvest schedule is based on: 1) a harvest 

schedule that exhibits non-declining yield at or below LTSY capacity, 2) a 

regeneration harvest age at or beyond culmination (maximum) of Mean Annual 

Increment, and 3) a planning horizon of 150 years. 

The projected yield over the next 15 decades that could contribute to the ASQ is 

expected to increase over time as second-growth forests mature and become 

available for harvest. The average volume per acre of old-growth forest is 

approximately 29 MBF per acre. The expected volume of 100-year-old stands of 

second growth in the central portion of the Tongass is approximately 56 to 60 MBF 

per acre (based on the Forest’s managed yield tables for this area), depending on 

stand management (see below). As more 100-year-old stands become available for 

harvest, the ASQ could increase, or the land base needed to produce a given ASQ 

could decrease. In addition, commercial thinning would add to harvest volume. 
3 Environment and Effects

Timber 3-348 Final EIS

The ASQ does not exceed the LTSY during the 100-year-plus planning horizon. 

The potential ASQ is expected to be between 49 and 92 percent of LTSY for the 

rotation under all alternatives based on the LTSY calculations. Table 3.13-13 

displays the ASQ and LTSY by alternative. For all alternatives, the ASQ never 

exceeds the LTSY during the planning horizon. Alternatives that would allocate a 

greater number of acres for timber management and/or have more acres under 

intensive management would produce the highest LTSYs. 

Table 3.13-13 

Allowable Sale Quantity and Long-term Sustained Yield Capacity 

(MMBF1

) 

Alt. 

Decades 1 

to 5 Average 

Annual 

Decades 6 to 

10 Average 

Annual 

Decades 11 to 

15 Average 

Annual 

LTSY 

(MMCF) 2

Maximum 

Percent of 

LTSY 

1 49.3 49.8 52.0 21.5 49 

2 152.6 153.6 153.8 48.3 69 

3 204.5 204.6 204.7 59.9 76 

4 350.3 360.0 360.0 92.4 88 

5 267.0 267.0 267.0 68.4 87 

6 267.0 267.0 267.0 72.9 82 

7 421.0 421.0 421.0 102.5 92 1

 MMBF: million board feet 

2

 MMCF: million cubic feet. SPECTRUM only expresses long-term sustained yield in the cubic foot 

measure. Direct conversion from MBF to MCF is complex, varying by tree size and taper but is 

approximately 5 MBF to 1 MCF 

Approximately 90 percent of the existing timber stands on the Tongass are beyond 

CMAI. Timber stands that exceed CMAI are either in decline or are not growing at 

optimal rates for their site’s potential productivity. The western hemlock-Sitka 

spruce forest type is one of the world’s most productive forest types (USDA Forest 

Service 1983); it is capable of producing prodigious amounts of wood. The updated 

forest yield tables for the central part of the Tongass estimate that a normally 

stocked stand 40 years old would contain 7 MBF of merchantable wood per acre. 

By age 70, volume should increase to 29 MBF of wood per acre, assuming no 

precommercial thinning occurred. The age of CMAI would be around 100 years with 

a merchantable volume of 56 MBF per acre, assuming no precommercial or 

commercial thinning. If the same stand is thinned, volume at CMAI is estimated to 

be 60 MBF, in addition to an estimated 8 MBF of commercial thinning volume 

obtained at age 60. Yields from uneven-aged silvicultural systems would be 

considerably less, approximately 28 MBF at age 200, based on the updated forest 

yield tables. 

As a greater proportion of the Forest is converted from slower growing, highlydefective stands to stands well-stocked with vigorously growing conifers, total forest 

growth would increase. Because of higher volumes and lower defect, managed 

young-growth would be able to provide higher harvests on the same land base or 

support the same harvest on a smaller land base. Under a 100-year rotation, 

between one-forth and one-third of the suitable land would not be needed to provide 

a given ASQ, depending on alternative. This portion of the timber base could revert 

to some other land use and be available to provide old-growth habitat, or the ASQ 

could be increased if market conditions allowed. 

Only a portion of the Forest would emphasize timber management; most of the 

existing mature and old-growth stands on the Forest would be maintained. Various 

amounts of old-growth conifer stands would be maintained or allowed to develop 

under each alternative. Alternatives that allocate the most acres to developmentoriented land allocations would gradually have more stands in younger timber age 

classes, and fewer stands of old growth. However, more than 150 years from now, 

the predominant age class on the Tongass would still be greater than 150 years 

Future 

Conditions 
 Environment and Effects 3 

Final EIS 3-349 Timber 

(Table 3.13-14). The percent of total productive forest land that would be managed 

stands of less than 150 years of age is expected to be a relatively small component 

of the forest landscape on a Forest-wide basis for all alternatives. Old growth would 

still be the predominant vegetative structure on the Tongass (Table 3.13-15). 

Conifer growth in young stands can be accelerated through silvicultural treatments 

to control conifer stocking. Benefits from such treatments may include larger piece 

size and consequently lower logging costs, increased stand variability, higher quality 

wood, and employment opportunities. In addition, treatments may shorten the time 

period spent in the stem exclusion phase of stand development and offer other 

resource benefits. 

Table 3.13-14 

Age Class Distribution of Mapped Suitable Acres after 160 years 

Alternative 

Age Class 1 2 3 4 5 6 7 

0 to 10 8,537 37,229 50,026 92,198 71,233 69,918 109,874 

11 to 20 13,013 26,248 41,859 74,522 63,141 52,245 97,694 

21 to 30 11,385 27,044 40,029 79,772 67,128 55,510 104,374 

31 to 40 10,591 31,271 44,004 87,118 64,534 62,892 113,901 

41 to 50 11,030 34,182 50,868 99,463 78,711 70,789 120,941 

51 to 60 9,003 32,245 46,596 93,342 78,763 67,621 119,473 

61 to 70 10,549 34,125 49,027 83,138 69,299 62,176 111,485 

71 to 80 13,179 14,087 16,509 34,367 29,436 22,621 45,926 

81 to 90 7,189 24,038 28,096 50,227 31,847 43,327 54,324 

91 to 100 9,044 20,631 16,744 47,864 28,550 35,092 50,097 

101 to 110 10,556 22,024 25,545 70,148 42,499 40,866 71,307 

111 to 120 10,044 19,336 25,566 30,146 25,399 31,355 21,714 

121 to 130 17,419 23,609 34,580 15,481 10,483 21,019 9,019 

131 to 140 15,858 29,370 23,570 4,340 5,287 7,096 5,193 

141 to 150 8,236 6,586 5,189 1,624 1,423 2,910 2,121 

Total 0 to 150 Years 165,633 382,025 498,208 863,750 667,733 645,437 1,037,443 

Total Greater than 150 197,345 289,455 332,588 440,743 366,324 352,761 489,463 

Total 362,978 671,480 830,796 1,304,493 1,034,057 998,198 1,526,906 

Source: SPECTRUM model 2006. Numbers may not add correctly due to rounding. Represents all suitable, not just scheduled suitable. 

Table 3.13-15 

Forest-wide Stand Structures after 160 Years (acres) 

Alternative 

Stand Structure 1 2 3 4 5 6 7 

Stand Initiation 

(0 to 20 Years) 21,550 63,477 91,885 166,720 134,374 122,163 207,568

Stem Exclusion 

(21 to 120 years) 89,488 300,047 401,448 449,245 526,870 550,762 802,661

Understory Reinitiation 

(121 to 150 years) 102,570 258,983 342,984 675,585 516,166 492,249 813,542

Productive Old-growth 

(>150 years) 4,806,213 4,711,868 7,769,622 4,848,450 4,779,014 4,751,489 4,894,171

Source: SPECTRUM model 2006. Numbers may not add correctly due to rounding. 

Managing stands to enhance wildlife and fish habitat carrying capacity is one of the 

objectives of the Tongass National Forest. To help meet this objective, the Forest 

Service has implemented studies on stand management, including TWYGS, the 

Alternatives to Clearcutting study, and other Pacific Northwest research, some of 

which has been discussed in this section. Appendix B of the Forest Plan includes a 

list of information needs. 
3 Environment and Effects

Timber 3-350 Final EIS

Cumulative Effects 

Cumulative effects to timber include past and present and proposed harvest 

discussed above. Table 3.13-13 presents a comparison of harvest and LTSY by 

alternative, an important measure of the cumulative effect on the growing stock on 

NFS land. Maximum harvest levels on NFS lands proposed under all alternatives 

are well within the LTSY. Table 3.13-14 displays the age class of forests on NFS 

lands by decade for the next 160+ years; Table 3.13-15 displays the projected stand 

structure over the same period. Cumulative effects on timber resources across 

Southeast Alaska are presented below. 

In 1954, there were approximately 6.5 million acres of productive forest land on all 

ownerships in Southeast Alaska. The amount of forest land in Southeast Alaska 

that is available for timber management has declined over the past century, largely 

due to Wilderness and LUD II designation by Congress and to land allocated to nondevelopment LUDs in the current Forest Plan. This, along with mill closures and 

changes in timber markets, has contributed to a decline in timber harvest. Harvest 

on all lands in Southeast Alaska peaked in the 1980s and has been in decline since 

then. Total harvest on federal, state, and private lands declined from just under 

1,000 MMBF in 1989 to less than 200 MMBF in 2005. Approximately 767,000 acres 

of productive forest land have been harvested since 1954 in Southeast Alaska, 

approximately 59 percent of this is NFS land and 41 percent is on state, Native 

corporation, and other private lands. 

Currently, there are more than 0.75 million acres of NFS lands considered suitable 

for timber management on the Tongass. In addition, nearly 0.75 million acres of 

state, Native corporation, and other private lands are available for harvest. The 

maximum annual harvest from the Tongass National Forest is 267 MMBF under the 

current Forest Plan, although actual harvests have averaged near 50 MMBF per 

year for the last few years. Potential annual harvest on state and private land has 

been estimated to be approximately 109 MMBF (Brackley et al. 2006a); although, 

comments from Sealaska Corporation indicate it may be much lower. Based on 

past experience, most of the harvest on private land would be exported and would 

not contribute to meeting local demand. Using this estimate, cumulative harvest in 

Southeast Alaska would range from as low as 158 MMBF under Alternative 1 to 

approximately 530 MMBF under Alternative 7. Table 3.13-16 displays the 

cumulative harvest under the proposed alternatives. 

Table 3.13-16 

Maximum Estimated Annual Timber Harvest in Southeast Alaska 

during the First Decade (MMBF) 

Alternative National Forest1 State and Private2 Total 

1 49 109 158 

2 151 109 260 

3 204 109 313 

4 312 109 421 

5 267 109 376 

6 267 109 376 

7 421 109 530 1 SPECTRUM model estimates, 2007 2 102 MMBF/year from Native corporation lands and 7 MMBF/year from state land (Brackley et al. 

2006a). Most harvest on private land is exported. 

MMBF: million board feet.

There are several risk factors and uncertainties that may affect timber outputs; these 

include the reliability of existing information of forest stands, accessibility, 

economics, budget, harvest on private land, development of new markets, 

investments in new processing facilities, and climate change. 
 Environment and Effects 3 

Final EIS 3-351 Timber 

The recent LSTA indicates that approximately 85 percent of the suitable timber land 

would be accessible using normal harvest methods, just under 10 percent would be 

difficult, and just under 6 percent would be isolated. When economic and 

environmental risk factors are considered, additional areas are likely to be identified 

as difficult or isolated during project planning. Risk factors assigned by the LSTA 

team and district personnel indicate that about 85 percent of the suitable acres with 

old-growth forest would be in the normal category. However, until field work is 

completed, actual conditions remain uncertain and there is a risk that some areas 

considered suitable for timber management are actually unsuitable and that areas 

considered to be accessible using normal harvest methods will prove to be difficult 

or isolated. Increasing fuel costs may restrict the use of helicopters, which would 

mean some areas with suitable timber would be too expensive to harvest. Similarly, 

increases in road construction costs may affect the economic viability of some sales. 

In addition, funding levels for preparing timber sales are uncertain they depend on 

the amount Congress chooses to allocate in any given year. 

The harvest levels associated with the alternatives discussed above, especially 

Alternatives 4, 5, 6, and 7, depend on developing new processing facilities and/or 

new markets. If these are not developed, harvest levels may not increase much 

beyond current levels. Also, total harvest projections for Southeast Alaska depend, 

in part, on how much timber is harvested from state and private lands. The 

estimates used in this analysis are derived from published reports. However, 

comments received following publication of the DEIS indicate that actual harvest 

levels, especially on Sealaska land, may be lower than those estimates. Sealaska 

indicates that, without the land adjustments they propose, they will be unable to 

continue to harvest at current levels. Conversely, if suitable land is transferred to 

Sealaska in exchange for lands that, while valuable for wildlife habitat or recreation, 

are not suitable for timber production, harvests on NFS lands will likely need to be 

reduced. 

Timber harvest programs under any of the proposed alternatives, as well as on state 

and private land may be affected by factors related to climate change. Juday et al. 

(1998) rated many potential impacts on the coastal forests of Southeast Alaska due 

to climate change. They concluded that there was a high risk of increased large 

scale blowdown across Southeast Alaska, increased windthrow around harvest 

units, increased damage from black-headed budworm outbreaks and other insects, 

and increased risk that new fungal tree diseases will appear in Southeast Alaska. 

These factors, if they occur, could alter harvest and growth projections outlined in 

this analysis, as well as have a major affect on wildlife habitat. In contrast, Juday et 

al. also concluded that there was some likelihood of increased tree growth and 

increased site productivity; previously non-commercial forest could become 

commercial forest. Refer to the Forest Health and the Climate and Air sections for 

additional information. 
3 Environment and Effects

Timber 3-352 Final EIS

This page is intentionally left blank. 
 Environment and Effects 3 

Final EIS 3-353 Minerals 

Minerals 

Affected Environment............................................................................. 3-353

Locatable Minerals ................................................................................. 3-353

Leasable Minerals .................................................................................. 3-354

Salable Minerals..................................................................................... 3-355

Mineral Resource Inventory and Development Potential....................... 3-356

Tongass Land Management for Minerals .............................................. 3-359

Environmental Consequences............................................................... 3-360

Direct and Indirect Effects...................................................................... 3-360

Cumulative Effects ................................................................................. 3-364

Affected Environment 

A wide variety of mineral deposit types and mineral resources occur within the 

boundaries of the Tongass National Forest, including gold, silver, molybdenum, and 

uranium, and nationally designated “strategic” and “critical” minerals such as lead, 

zinc, copper, tungsten, and platinum group metals. The Forest Service recognizes 

that minerals are fundamental to the Nation’s well being and, as policy, encourages 

the exploration and development of the mineral resources it manages. The 

Secretary of Agriculture has provided regulations (36 Code of Federal Regulations 

[CFR] 228) to ensure surface resource protection, while encouraging the orderly 

development of mineral resources on National Forest System (NFS) lands. 

Southeast Alaska has a long history of mineral prospecting and mining. The first 

mineral location in Southeast Alaska was recorded in 1867 by a Russian trader near 

New Kasaan on Prince of Wales Island. In 1880, gold was discovered in placer 

gravels near Juneau. This discovery sparked keen interest and, by the turn of the 

century, dozens of mines were in production from the Juneau Mining District to the 

Ketchikan Mining District. Mining remained active until World War II. From the 

close of World War II to the mid-1970s, mineral exploration and production in 

Southeast Alaska remained low compared to the activity documented at the 

beginning of the century. Prospecting and exploration generally increased during 

the mid-1970s, in part due to the Quartz Hill and Greens Creek discoveries, 

improved metal prices, technological advances, and the deregulation of gold. Metal 

prices have maintained generally favorable trends since the mid-1980s, resulting in 

increased exploration and renewed interest in precious metals, mainly gold. 

With respect to National Forest management, mineral resources are legally divided 

into three groups: locatable minerals, leasable minerals, and salable minerals. The 

authority of the Forest Service to influence and regulate the exploration, 

development, and production phases of mining operations varies with each group. 

As a result, the Forest Service manages mineral resource programs that are specific 

to each group of minerals. 

A locatable mineral is any mineral that is “valuable” in the usual economic sense, or 

has a property that gives it distinct and special value. These are typically what are 

known as “hardrock” minerals. Locatable minerals may be recovered from load 

deposits (solid rock) or placer (surficial) deposits. Examples of some locatable 

minerals on the Tongass National Forest are gold, silver, copper, molybdenum, iron, 

nickel, lead, and zinc. 

The General Mining Law of 1872, as amended, grants every United States citizen 

the right to prospect and explore public domain lands open to mineral entry. The 

Locatable 

Minerals 
3 Environment and Effects

Minerals 3-354 Final EIS

right of access is guaranteed and is not at the discretion of the Forest Service. 

Upon discovering a valuable mineral deposit, citizens have the right to locate a 

mining claim and remove the mineral resources. The citizen holding a mining claim 

is called the claimant. The claimant is responsible for initiating mining activities and 

investing the capital required to conduct mineral exploration, site development, mine 

operation, and reclamation of the site. 

The Forest Service works with mining claimants to provide reasonable access to 

their claims, minimize adverse environmental impacts on surface resources, and 

ensure reasonable reclamation of disturbed lands affected by mining operations. 

Protection of surface resources is accomplished by reviewing the mining plan of 

operations submitted by the claimant, disclosing impacts of the proposed mining 

operations in a site-specific environmental document, approving only those activities 

that are reasonably necessary for the proposed operation, monitoring operations to 

ensure environmental standards are met, and ensuring prompt and reasonable 

reclamation of disturbed areas. 

By law, designated Wilderness, National Monuments, Research Natural Areas, 

Enacted Municipal Watersheds, and Wild Rivers (when designated by Congress) 

are withdrawn from mining claim location. These withdrawn areas are, however, 

subject to mining claims with valid existing rights established before the date the 

areas were withdrawn from mineral entry. As a consequence, some mining claims 

located within existing or proposed withdrawn areas could be developed in the 

future. 

On the Tongass, the Primitive Recreation, Semi-Remote Recreation, Old-Growth 

Habitat, Experimental Forest, Special Interest Areas, Scenic Rivers, and LUD II 

Land Use Designations (LUDs) remain open to mining activities. Special 

stipulations and more stringent mitigation measures are required for mining activities 

in these LUDs; therefore, there is a higher cost to develop minerals in these LUDs. 

Modified Landscape, Scenic Viewshed, Recreational Rivers, Timber Production, and 

Minerals LUDs remain open to mineral activities and do not require special 

stipulations or more stringent mitigation measures; therefore, mineral development 

in these LUDs would be at an average cost. 

Certain types of minerals, primarily energy resources, are not subject to mining 

claim location, but are available for exploration and development under provisions of 

the Mineral Leasing Act of 1920. Access to these types of minerals is provided 

through leases, permits, or licenses that include fee and/or royalty payment 

conditions. Federally owned leasable minerals include oil, gas, coal, geothermal 

resources, potassium, sodium, phosphates, and sulfur. The authority to manage 

these minerals is presently administered by the U.S. Department of Interior, Bureau 

of Land Management (BLM) in cooperation with the Forest Service. 

No leasable minerals are presently being produced on the Tongass National Forest, 

and the anticipated demand is expected to remain low. BLM recently conducted an 

assessment of mineral resource potential in support of a resource management plan 

for the Ring of Fire planning area (BLM 2006), which includes Southeast Alaska. 

The assessment indicated the potential for oil and gas occurrence in the Yakutat 

region was considered to be high, based on geologic factors (URS Corporation 

2006). While there has been exploration activity in the Yakutat area in the relatively 

recent past, the resource development potential is considered low; therefore, BLM 

expects no exploration or development activity within the next 10 to 15 years. 

Outside of the Yakutat area, oil and gas occurrence potential elsewhere in the 

Tongass is considered low to none. 

Occurrences of coal found at several locations in Southeast Alaska has prompted 

the identification of the Angoon, Admiralty, and Kuiu coal districts; the coals in the 

Leasable 

Minerals 
 Environment and Effects 3 

Final EIS 3-355 Minerals 

two former districts are classified as bituminous, while the Kuiu deposits are ligmite 

(URS Corporation 2006). Several small mines on Admiralty Island produced coal 

during the late 1800s and early 1900s. Lignite deposits also occur at several other 

locations in Southeast Alaska, although they are of small extent. Similarly, the 

occurrence potential for coalbed natural gas (coalbed methane) is considered high 

for the Admiralty and Kuiu Islands coal deposits and the Yakutat area. BLM 

considers development of these resources to be uneconomic over the next 10 to 15 

years, other than possibly for local use, and does not foresee associated exploration 

or development activity. 

Geothermal resources occur in 19 known locations in Southeast Alaska. Thermal 

springs in several locations have been developed for small-scale commercial uses 

such as tourism, aquaculture, community bathhouses, and district heating of 

buildings (URS Corporation 2006). There has been some recent interest in 

geothermal resources in the Bell Island area, but BLM has undertaken no leasing 

activity to date. While the occurrence potential for geothermal resources is 

considered high in several locations and some exploration could occur, BLM does 

not anticipate geothermal development activity over the next 10 to 15 years. 

Salable, or “common variety,” minerals on NFS lands are sold rather than located or 

leased. These minerals include petrified wood and common varieties of sand, rock, 

building stone, gravel, pumice, clay, and other similar materials. Such common 

variety mineral materials include deposits that, although they have economic value, 

tend to be relatively widely available and used close to the source of production. 

These minerals are most commonly used as building materials and are also used for 

agriculture, cleaners and abrasives, and as inputs to manufacturing processes. 

The predominant salable commodity extracted on the Tongass National Forest is 

crushed rock used to construct roads. The supply of quality rock sources is largely 

dependent upon the locations of active logging operations. Presently, there is an 

adequate supply of rock sources with suitable quality (hardness and durability) in the 

southern third of the Tongass. However, rock quality is poor in the northern twothirds of the Forest, and good material sources are difficult to locate in current timber 

production areas. Sand and gravel sources are scarce throughout the Forest, 

except within the Yakutat Ranger District. 

All roads built in the Tongass require rock for construction because the subgrade 

soils have poor strength characteristics. The demand for crushed rock will closely 

follow the need to construct new timber sale roads. The total in-service use of rock 

for existing roads was 43,962,500 cubic yards, which was used to construct 3,355 

miles of road. As the use of forest roads increases, and both the Alaska State 

Department of Transportation and the Federal Highway Administration assume 

responsibility for maintenance of some roads, the demand for crushed rock will 

increase. It will be expensive to locate mining sites with suitable quality and quantity 

in the northern part of the Forest, and haul distances will increase. Outside NFS 

lands, new and existing communities will require mineral materials for development 

of roads and for foundations for homes, schools, and other buildings. The demand 

for rock from public land in support of these growing communities is likely to 

increase. 

Limestone and marble are abundant in Southeast Alaska, and both have historically 

been produced from quarries in the region for use as building stone (BLM 2006). 

Identified marble resources in the region are estimated at over 800 million tons. 

Large quantities of limestone have been quarried from Prince of Wales and Dall 

Islands. Continued exploitation of these building material resources could be 

expected in the future. While several areas in Southeast Alaska also have geologic 

formations that are favorable for the occurrence of pumice deposits, market and 

Salable Minerals 
3 Environment and Effects

Minerals 3-356 Final EIS

location conditions indicate there will be little or no foreseeable development 

potential for pumice (URS Corporation 2006). 

Most estimates of locatable mineral resource potential use a format developed by 

the U.S. Bureau of Mines and the U.S. Geological Survey (U.S. Bureau of Mines 

and U.S. Geologic Survey 1980, as cited in USDA Forest Service 1997a). The U.S. 

Bureau of Mines was abolished in 1996. Mineral resources are divided into 

“identified resources” and “undiscovered resources.” The Tongass contains both 

identified and undiscovered reserves. 

Identified Mineral Resources 

The identified mineral resources on the Tongass were described by the U.S. Bureau 

of Mines, Alaska Field Operations Center, in An Economic Analysis, Tongass Land 

Management Plan, Mineral Resource Inventory (Coldwell 1990). For summaries of 

this report, see the 1991 Forest Plan Revision Supplement to the Draft EIS and the 

1997 Forest Plan Revision Final EIS (USDA Forest Service 1991, 1997a). 

The methods used by the U.S. Bureau of Mines included the steps discussed below. 

First, a mineral resource inventory was compiled from all available sources, resulting 

in the identification of 148 locatable mineral deposit areas within the Tongass 

National Forest. These 148 deposits were assigned to a mineral deposit model 

(Berg 1984). Tonnage and grade were determined for each based on published 

information, or were calculated using models developed by Cox and Singer (1986). 

The gross metal value for each deposit area was calculated by combining the 

tonnage and grade figures with an average price from 1978 to 1987 for each 

commodity. Each deposit area was evaluated to determine its pretax net present 

value. 

Next, the 148 deposit areas were grouped into 52 identified mineral activity tracts

that had high mineral development potential (MDP). These 52 tracts were further 

ranked from 1 to 3, based on the likelihood of exploration and development activity 

within the next 10 to 15 years. Areas assigned a ranking of 1 have the highest 

potential for development. Rank 1 areas contained at least one deposit with a 

positive after-tax net present value (at a 4 percent discounted cash flow rate of 

return) and/or at least one active gold deposit (site of current industry activity). Rank 

2 areas contained at least one deposit with a positive pre-tax net present value (at a 

zero percent discount rate) and/or at least one “critical” and “strategic” mineral 

deposit with a vulnerable supply source. Rank 3 areas do not meet these criteria; 

their lower rankings may be due to a lesser likelihood of mineral occurrence, or 

because of a lack of available information. 

Of the 52 tracts, 22 are categorized as Rank 1, 7 are categorized as Rank 2, and 23 

are categorized as Rank 3. The tracts are listed in Table 3.14-1. The gross metal 

value of the identified mineral resources within the boundaries of the Tongass was 

estimated at $37.1 billion (expressed as 1988 dollars) in the U.S. Bureau of Mines 

study (Caldwell 1990). Highest among the individual minerals were molybdenum 

($14.4 billion) and iron ($12.7 billion), with gold third at $2.26 billion. 

The Coldwell (1990) report is the most recent comprehensive study of mineral 

resources for the entire Tongass. Additional studies of mineral resources in the 

Tongass have since been conducted, however. These include Mineral 

Investigations in the Ketchikan Mining District, Southeastern Alaska (Maas et al. 

1995); Mineral Resources of the Chichagof and Baranof Islands Area, Southeast 

Alaska (Bittenbender et al. 1999); and Mineral Assessment of the Stikine Area, 

Central Southeast Alaska (Still et al. 2002). These studies conducted further 

investigations on known mineral deposit areas (KMDAs) within the Tongass. These 

Mineral Resource 

Inventory and 

Development 

Potential 
 Environment and Effects 3 

Final EIS 3-357 Minerals 

Table 3.14-1 

Identified Mineral Resources of the Tongass National Forest Displayed by Mineral Activity Tract 

Tract Name 

Ref. 1 

(acres) 

Ref. 1 

Rank 

Ref. 2 

MDP 

Ref. 3 

MDP 

Ref. 4 

MDP/ MEP 

Gold 

(tons)

Silver 

(tons)

Lead 

(tons)

Zinc 

(tons) 

Copper 

(tons) 

Moly 

(tons) 

Iron 

(tons) 

Other 

Minerals 

Chilkat Peninsula 40 3 1 - - - - - - 

Sullivan 7,938 1 - - - - - - - Critical Minerals 

Bohemia Basin 9,376 1 H - - - - 41,000 - - Nickel; Cobalt; Critical 

Minerals 

Berners Bay 10,318 1 69 - - - - - - 

Juneau Gold Belt 85,699 1 189 164 100,920 100,747 82 - - Critical Minerals 

Fremming 501 3 0 1 150 2,100 - - - 

Douglas Island 1,319 2 12 - - - - - - 

Funter Bay 11,499 1 - - - - 1,960 - - Nickel; Cobalt; Critical 

Minerals 

Greens Creek 7,528 1 22 2,880 136,500 339,500 - - - Critical Minerals 

Taku Mo 3,199 3 - - - - - 1,000 - 

Enterprise 1,505 3 0 - - - - - - 

Apex-El Nido 4,603 2 H 1 - - - - - - 

Basaltic Cu 4,484 3 M - - - - 1,360 - - Critical Minerals 

Mirror Harbor 2,242 2 M - - - - 1,265 - - Nickel; Critical Minerals 

Pinta Bay 1,301 3 H - - - - - - - Critical Minerals 

Chichagof 12,946 1 M 25 7 - - - - - Critical Minerals 

Slocum Arm 8,625 3 L - - - - - - - Critical Minerals 

Silver Bay 22,706 3 L - - - - - - - Critical Minerals 

Pyrola 3,261 2 - 196 8,255 27,800 - - - Barite; Critical Minerals 

Hasselborg 1,860 3 - - - - - - - Critical Minerals 

Crystal/Friday 1,391 2 2 - - - - - - Platinum 

Windham Bay 23,909 3 1 1 2 2 - - - Critical Minerals

Sumdum 41,419 3 0 279 112 18,501 156,988 - - Critical Minerals

Pt Astley 2,004 3 2 3 1,200 5,893 379 - - Critical Minerals

Zarembo 27,886 1 L/H 0 109 5,030 15,774 567 - - Critical Minerals

Portage Mountain 1,280 3 L/H 0 2 - - - - - Critical Minerals

Duncan 2,393 3 L/H - - - - 27 - - Critical Minerals

Grnd Hog/Glacier 15,859 1 L/H - 23 63,115 202,115 143 - - Critical Minerals

Shakan 42,763 1 M - - - - - 248 - 

N, Bradfield Cn 1,120 3 L/M - - - - 1,710 - 313,500 Critical Minerals 

Hyder 56,396 1 M 4 60 26,899 2,337 960 75 - Tungsten; Critical Minerals 

Franks Ridge 5,866 3 L - - - - - - - Critical Minerals

Khayyam 23,450 1 M 0 1 - 781 1,436 - - Critical Minerals

South Arm 7,943 3 H - - - - - - - Critical Minerals

Niblack 8,915 1 H - - - - - - - Critical Minerals

Dolomi 8,634 1 M - - - - - - - Critical Minerals 

Lime Point 900 3 M - - - - - - - Barite 

Big Harbor 3,535 3 M - - - - - - - Critical Minerals

Jumbo 12,326 1 M 1 2 - - 2,250 - 293,800 Critical Minerals

Hollis 17,148 1 L - - - - - - - 

Kasaan 8,176 1 M 1 3 - - 11,494 - 2,437,700 Critical Minerals 

Salt Chuck 4,817 1 M 1 1 - - 1,070 - - Palladium; Critical Minerals 

Union Bay 17,492 3 M - - - - - - 190,000,000 

Helm Bay 7,204 1 M 4 - - - - - - 

Tongass Narrows 4,488 1 M 6 - - - - - - 

Thorne Arm 7,657 1 L 4 - - - - - - 

George Inlet 6,198 3 M 3 - 156 - - - - Critical Minerals 

Quartz Hill 2,402 2 M 560 69 - - - 1,258,698 - 

Barrier Island 4,414 3 L - - - - - - - Critical Minerals

Nichols Mountain 16,882 3 L - - - - - - - Critical Minerals

Bokan 17,750 2 L - - - - - - - Uranium; Critical Minerals 

McLeod Bay 2,287 1 L - - - - - - - 

Notes: Critical minerals are those minerals necessary to supply military, industrial, and essential civilian needs during a national defense emergency, and not 

found or produced in sufficient quantities to meet emergency needs (as defined in the Strategic and Critical Materials Stock Piling Act of 1979). Examples of 

critical minerals include lead, zinc, copper, tungsten, and the platinum group metals. 

Reference 1: Coldwell 1990; Reference 2: Maas et al. 1995; Reference 3: Bittenberger et al. 1999; Reference 4: Still et al. 2002 

L=low; M=medium; H=high; MDP=mineral development potential; MEP=mineral exploration potential 
3 Environment and Effects

Minerals 3-358 Final EIS

KMDAs included the original tracts studied by Coldwell (1990). Each study reported 

estimates of MDP as low, medium, and high for each KMDA, as well as for 

individual mines, prospects, and occurrences. The designations given in Table 

3.14-1 for these reports are for the highest rating given for any prospect studied in 

that tract. 

The 1995, 1999, and 2002 area studies give essentially identical definitions for the 

following MDP designations: 

High—High grades and probable continuity of mineralized rock exist. 

The property is likely to have economically mineable resources under 

current economic conditions. A high potential exists for developing 

tonnage or volume with reasonable geologic support for continuity of 

grade. 

Medium—Either a high grade or continuity of mineralization exist. 

Mineralization is confined by geology, structures, and/or grades are 

overall low. It could serve as a material source if economics were not a 

factor, but is presently uneconomic at existing conditions. 

Low—The property exhibits uneconomic grades and/or little evidence of 

continuity of mineralized rock. There is little or no obvious potential for 

developing resources or is an insignificant source of the material of 

interest. 

Differences in MDP designations between these area studies and Coldwell (1990) 

reflect additional geologic and chemical data, changes in prices, and cost and 

likelihood of development based in part on LUDs at the time of the study. In 

addition, Still et al. (2002) ranked each mine prospect and occurrence by mineral 

exploration potential (MEP). The MEP ranking takes into account the potential for 

extent of mineralized rock but not current land status of the site. The highest MDP 

and MEP rankings for each area are summarized in Table 3.14-1. 

Undiscovered Mineral Resources 

The methods used by the U.S. Geological Survey, Branch of Alaskan Geology to 

identify "undiscovered" locatable mineral resources are detailed in their report, 

Undiscovered Locatable Mineral Resources of the Tongass National Forest and 

Adjacent Lands, Southeastern Alaska (Brew et al. 1991). Their work involved the 

definition of areas or "tracts" that may permit the occurrence of one or more deposit 

types; the estimation of the numbers of undiscovered deposits of each type in each 

tract, along with the expected tonnage and grade of each type; and the use of 

computer simulation using these estimates to produce a probability distribution of 

the quantities of metal contained in the tract. This resulted in the preparation of 

location maps along with descriptions of 930 metal-bearing localities. The 930 

metal-bearing localities were grouped into four classes, based on the estimated 

value of undiscovered mineral resources per acre: Class 1 has a relatively high 

mineral value per acre, Class 2 has a moderate mineral value per acre, Class 3 has 

a relatively low mineral value per acre, and Class 4 has nominal mineral value per 

acre. 

Each tract is considered likely to contain one or more different types of mineral 

deposits. The estimation of the number of deposits of a given type in a tract is the 

single most-critical step in probabilistic mineral resource assessment. It requires reevaluating all of the factors used in initially defining the tract, together with three 

additional factors: thoroughness of exploration (tracts already thoroughly explored 

are less likely to contain undiscovered deposits), size of tracts (smaller tracts are 

likely to contain fewer undiscovered deposits), and physical dimensions of deposit 

types (different types of deposits occupy different volumes of rocks). 
 Environment and Effects 3 

Final EIS 3-359 Minerals 

The U.S. Geologic Survey study (Brew et al. 1991) included estimation of the gross 

metal value of undiscovered mineral resources for the Tongass National Forest. In 

1990, this value was $28.3 billion (expressed as 1988 dollars). Highest among the 

individual minerals were copper ($6.8 billion), iron ($4.6 billion), molybdenum ($4.35 

billion), and tin ($3.4 billion). These totals cover the entire Tongass National Forest, 

and thus include areas currently withdrawn from mineral activity. 

Mineral Resource Demand 

The extent to which identified and undiscovered mineral resources on the Tongass 

will be exploited in the future will depend largely upon the level of demand for those 

resources. Demand for mineral resources can be inferred based on the amount of 

money spent by the mining industry to prospect and explore for mineral resources in 

Southeast Alaska. Increases in the amount of money spent on exploration reflect an 

increase in demand for mineral resources. Between 1982 and 1987, the mineral 

industry spent an average of $2.92 million per year on mineral exploration in 

Southeast Alaska, with a high of $5.85 million in 1987 (USDA Forest Service 

1997a). Exploration expenditures increased drastically for the 1988 to 1991 period, 

when the industry spent more than $20 million each year. Expenditures generally 

declined for the next 10 years, reaching $1.6 million in 2001, before increasing again 

to a level of $9.4 million in 2005 (Alaska Department of Natural Resources [ADNR], 

Alaska’s Mineral Industry annual reports and summaries for 1997 to 2005). 

Demand for mineral resources can also be inferred by modeling the economic 

viability of identified mineral resources. Identified mineral resources with high 

degrees of economic viability will reflect an increase in mineral-related activities or in 

demand for those resources by industry. The economic viability of 148 mineral 

deposits located within the Tongass National Forest were modeled by the U.S. 

Bureau of Mines (Coldwell 1990), as discussed previously. Based on economic 

criteria or the presence of an active gold deposit, 22 of 52 mineral activity tracts 

were identified as most likely to be developed (Rank = 1), and 10 were identified as 

likely to provide a positive rate of return when cash flow was discounted at zero 

percent. 

Mineral Production 

Mineral production in Southeast Alaska in recent years has been dominated by the 

Greens Creek Mine at the north end of Admiralty Island. Greens Creek is an 

underground mining operation that opened in 1989 and produces silver, zinc, lead, 

and gold. The mine processed nearly 806,000 tons of ore in 2004 and provided 265 

full-time jobs (ADNR 2005). Other Southeast Alaska mining activity in 2004 was 

comprised of at least 18 different rock, sand, and/or gravel operations. These mines 

produced a total of nearly 3 million tons of material during the year and supported 83 

employees. The Forest Service approved a Plan of Operations for the Kensington 

Gold Mine north of Juneau in 2005, and Coeur Alaska, Inc. subsequently began 

construction activities on the site. However, a lawsuit was filed against the U.S. 

Army Corps of Engineers and the Forest Service, challenging the permitted tailings 

disposal facility, citing violations to the Clean Water Act. The plaintiffs failed in 

District Court but were upheld on appeal by the 9th Circuit Court in 2007. The 

Forest Service anticipates the submittal of a revised Plan of Operations in 2008. 

As described previously, the Forest Service administers mineral exploration, 

development, and production activities through the legal/regulatory systems for 

locatable, leasable, and salable minerals. The Forest Service also accounts for 

mineral resources in the land management planning process. One way of 

recognizing the importance and potential of mineral resources is through the 

designation of Minerals LUDs in the Forest-wide land allocation. The intent of the 

Minerals LUD designation is to encourage exploration and development of locatable 

Tongass Land 

Management for 

Minerals 
3 Environment and Effects

Minerals 3-360 Final EIS

minerals in areas of high mineral potential, while taking other resource values into 

account. The Tongass Forest Plan includes management prescriptions for those 

areas, and standards and guidelines specific to minerals and geology. 

The current Tongass Forest Plan, as amended, allocates 13 areas of the Forest to 

the Minerals LUD. These areas total 170,514 acres and are widely distributed 

across most portions of the Tongass. Several Minerals LUDs are clustered around 

Juneau and Lynn Canal, and there is another cluster near Clarence Strait and the 

southern part of Prince of Wales Island. 

Unlike other LUDs, the Minerals LUD is an “overlay” designation that applies 

management prescriptions for minerals to the affected area, in addition to the 

prescriptions of the underlying LUD. For example, a Minerals LUD in the northern 

part of Admiralty Island, northeast of the Greens Creek mining area, overlies part of 

the Young Bay Experimental Forest LUD. The Minerals LUD and Experimental 

Forest management prescriptions both apply in this area, with the Minerals LUD 

having priority. 

Environmental Consequences 

Trend in expenditures for mineral prospecting and exploration, the demand for 

access to National Forest lands for the purpose of mineral exploration, and 

development is expected to increase over the next 10 years. Mineral entrants will 

continue to submit plans of operation to the Forest Service for approval, and 

regulations under which those operating plans are processed will not change by 

alternative. Identified and undiscovered mineral resource tracts, characteristics and 

location of mineral deposits, and Southeast Alaska geology will not vary as a result 

of implementing any of the alternatives. 

Locatable Minerals 

Under any alternative, future exploration and development (except for valid, 

currently existing rights) would be precluded in areas withdrawn from mineral entry, 

such as Wilderness. The availability of mineral resources of the Tongass National 

Forest may also be affected by the allocation of other LUDs in each alternative, and 

the use of Forest-wide standards and guidelines during project implementation. The 

standards and guidelines of certain LUDs could affect the cost of conducting 

exploration, development, and reclamation activities, and thus influence the 

exploration of some areas for their mineral resources. 

Most withdrawn lands are designated so by the U.S. Congress (i.e., wilderness 

withdrawals). On other NFS lands, the Forest Service does not have the authority to 

approve or disapprove most mineral operations (the exception being salable 

minerals), but can impose stipulations on how mineral resources are developed in 

order to protect surface resources. Thus, the potential effects of alternatives on 

mineral resources can be estimated by analyzing the relative degree to which LUDs 

and their associated prescriptions could economically constrain proposed mineral 

activities. 

For this purpose, three categories of LUDs are identified: withdrawn areas (which 

assume higher costs for the development of valid existing rights), and two “open” 

categories; one with average costs and one with higher-than-average costs. Table 

3.14-2 shows the LUDs corresponding to each category. 

Wilderness, National Monument, and LUD II acres remain the same for all Forest 

Plan alternatives, as do existing withdrawals within the Research Natural Area, 

Enacted Municipal Watershed, and Wild, Scenic, and Recreational River 

designations. Open areas with higher costs generally correspond to non-withdrawn 

areas in the Mostly Natural Setting LUD group, while open areas with average costs 

correspond to those areas within the moderate and intensive development LUD 

Direct and 

Indirect Effects 
 Environment and Effects 3 

Final EIS 3-361 Minerals 

groups. Alternative 5 (No Action) retains the existing acreage in Experimental 

Forest and Special Interest Area designations, while all of the other alternatives 

would increase the acreage in these LUDs. In addition, all alternatives except 

Alternative 5 would add or expand three Minerals LUD overlays; one new area north 

of Hyder, an 

Table 3.14-2 

Economic Availability of Minerals Relative to Land Use Designations 

Mineral Availability LUDs 

Withdrawn – Existing Wilderness 

(Areas remain open to mineral rights established National Monument 

prior to the area being withdrawn) Research Natural Area 

 Municipal Watershed 

 Wild River 

 

Open Areas – High Cost Remote Recreation 

(Mineral exploration and development Semi-Remote Recreation

requires special stipulations and more Old-Growth Habitat 

stringent mitigation measures) LUD II 

Experimental Forest 

Special Interest Area

Scenic River 

Minerals LUD Overlay on 

Withdrawn Areas (prior rights only) 

Open Area – Average Cost Recreational River 

Scenic Viewshed 

Modified Landscape 

Timber Production 

 Minerals LUD Overlay on 

All Open Area LUDs 

 

expansion of the area near Niblack (on the north side of Moira Sound) on south 

Prince of Wales Island, and a new area north and south of the West Arm 

Cholmondeley Sound on south Prince of Wales Island. The Minerals LUD overlay 

may have the effect of changing the exploration and development costs from high to 

moderate, depending on the basic LUD of the area. 

Locatable minerals are divided into identified resources and undiscovered 

resources. As described in the Affected Environment section, there are 52 identified 

mineral resource tracts on the Tongass. Using the Forest-wide acreage 

breakdowns of LUD groups (as grouped in Table 3.14-2) by alternative indicates the 

overall effects on economic availability of mineral resources. Table 3.14-3 

compares the Forest Plan alternatives using the cost/LUD group concept for the 52 

areas with identified mineral resources (593,000 acres). For all seven alternatives, 

25 percent of the acreage of identified mineral resources is in areas that have been 

withdrawn. Alternatives 7 and 4 have the fewest acres of identified mineral 

resources in allocations potentially causing higher costs for their exploration and 

development; Alternative 1 has the most acreage. The other four alternatives fall 

between these two in a fairly close grouping near the middle of the range. 

Rank 1 mineral tracts are those most likely to see mineral exploration or 

development. Identified mineral resource areas in the Rank 1 category encompass 

an area of approximately 380,000 acres on the Tongass. Table 3.14-4 compares 

the Forest Plan alternatives using the cost/LUD group concept for these Rank 1 

identified mineral resource areas. The results are similar to those indicated in Table 

3.14-3. For all seven alternatives, 15 percent of the acreage of Rank 1 mineral 
3 Environment and Effects

Minerals 3-362 Final EIS

Table 3.14-3 

Effects on Economic Availability of Identified Mineral Resources1

Open Areas 

Alternative 

Withdrawn 

Areas Higher Cost Average Cost 

Alternative 1 25% 36% 39% 

Alternative 2 25% 29% 45% 

Alternative 3 25% 26% 49% 

Alternative 4 25% 20% 55% 

Alternative 5 26% 29% 45% 

Alternative 6 25% 25% 50% 

Alternative 7 25% 18% 56% 

1

 Percentage of total area (593,000 acres) within each category.

Table 3.14-4 

Effects on Economic Availability of Rank 1 Identified Mineral 

Resources1

Open Areas 

Alternative 

Withdrawn 

Areas Higher Cost Average Cost 

Alternative 1 15% 36% 50% 

Alternative 2 15% 28% 58% 

Alternative 3 15% 25% 61% 

Alternative 4 15% 19% 66% 

Alternative 5 15% 31% 54% 

Alternative 6 15% 24% 61% 

Alternative 7 15% 17% 68% 

1

 Percentage of total area (380,000 acres) within each category. Rank 1 mineral tracts have the 

highest likelihood of being developed.

resources has been withdrawn. Alternatives 7 and 4 again have the fewest acres of 

Rank 1 mineral resources in allocations potentially causing higher costs for their 

exploration and development, at 17 and 19 percent, respectively; Alternative 1 has 

the most (36 percent). The other four alternatives fall between these two in a fairly 

close grouping near the middle of the range. 

A similar analysis has been performed for the 6.6 million acres of undiscovered 

mineral resources, as shown in Table 3.14-5 below. Here Alternative 1 again has 

the most acres in allocations potentially causing higher costs, followed by 

Alternatives 2, 3, and 5 or 6. Alternative 1 has the least area of LUDs assumed to 

have average costs for mineral development. 

Table 3.14-5 

Effects on Economic Availability of Undiscovered Mineral 

Resources1

Open Areas 

Alternative

Withdrawn 

Areas Higher Cost Average Cost 

Alternative 1 35% 57% 8% 

Alternative 2 35% 51% 14% 

Alternative 3 35% 45% 20% 

Alternative 4 35% 35% 30% 

Alternative 5 35% 41% 23% 

Alternative 6 35% 41% 23% 

Alternative 7 35% 33% 31% 

1

 Percentage of total area (6.6 million acres) within each category.
 Environment and Effects 3 

Final EIS 3-363 Minerals 

The undiscovered mineral resource areas are also classified according to their 

estimated development potential, based on resource value. Class 1 and 2 

undiscovered mineral areas are believed to have moderate to high per-acre mineral 

values. Table 3.14-6 shows the distribution of these Class 1 and 2 areas among the 

different LUD groups, by alternative. These table entries again show a consistent 

pattern in which Alternatives 7 and 4 are the least restrictive and Alternative 1 is the 

most restrictive with respect to likely mineral development costs. 

Table 3.14-6 

Effects on Economic Availability of Class 1 and 2 Undiscovered 

Mineral Resources1

Open Areas 

Alternative

Withdrawn 

Areas Higher Cost Average Cost 

Alternative 1 38% 50% 12% 

Alternative 2 38% 43% 19% 

Alternative 3 38% 37% 25% 

Alternative 4 38% 26% 36% 

Alternative 5 38% 39% 23% 

Alternative 6 38% 36% 26% 

Alternative 7 38% 25% 37% 

1

 Percentage of total area (989,000 acres) within each category. Class 1 has a high mineral value 

per acre; Class 2 has a moderate mineral value per acre.

Only the 52 mineral activity tracts (identified resources) and adjacent areas were 

considered for allocation to the Minerals LUD. Table 3.14-7 shows how these 

allocations are distributed by alternative in terms of likely development cost. Even 

though all LUDs in the Open Area categories are expected to have average costs if 

they have a Minerals LUD overlay, it is likely that, even with the Minerals LUD 

overlay the higher cost LUDs identified in Table 3.14-2 would have slightly higher 

costs than the average cost LUDs. Therefore, Table 3.14-7 provides an indication 

of these smaller differences. With Alternative 1, 97 percent of the lands assigned 

the Minerals LUD overlay have underlying LUDs in the high-cost category. By 

comparison, Alternative 7 would result in only 43 percent in the high-cost category. 

Alternatives 2, 3, and 6 are similar to Alternative 1 in placing a higher proportion of 

the Minerals LUDs in high-cost areas than the average-cost areas, while 

Alternatives 4 and 5 have percentage distributions closer to Alternative 7. 

Table 3.14-7 

Effects on Economic Availability of Areas Covered by the Minerals 

LUD Overlay1

Open Areas3 

Alternative 

Withdrawn 

Areas2

Higher Cost LUDs, 

in the absence of 

Minerals LUD Overlay 

Average Cost LUDs, 

in the absence of 

Minerals LUD Overlay 

Alternative 1 1% 97% 2% 

Alternative 2 1% 85% 14% 

Alternative 3 1% 69% 29% 

Alternative 4 1% 50% 49% 

Alternative 5 0% 49% 51% 

Alternative 6 1% 58% 40% 

Alternative 7 1% 43% 56% 

1

 Percentage of total area (249,570 acres). 

2 Note that the 3,000 acres in the Withdrawn Category are in Wilderness and cover prior rights only. 3 Note that the Minerals LUD overlay converts all of these areas to the Average Cost category; 

however, there may still be some differences in cost. 
3 Environment and Effects

Minerals 3-364 Final EIS

Leasable and Salable Minerals 

The effects of the Forest Plan alternatives on leasable minerals are not discussed in 

detail, as there are no aspects of the Forest Plan that would have a specific direct or 

indirect effect on activity related to leasable minerals. The Tongass has no current 

leasable mineral activity, and the anticipated demand for leasable minerals is 

expected to remain low. The Forest Service is aware of some level of interest in oil 

and gas, coal, and geothermal resources in specific areas of the Tongass. The 

proposed Forest Plan includes revisions to the standards and guidelines to address 

management of potential future leasable mineral activity. In general, those revisions 

provide that any mineral leasing activity would need to be consistent with the 

standards and guidelines for the respective LUDs affected by leasing. The revisions 

also include surface occupancy and other prescriptions intended to protect Forest 

resources in areas of leasing activity. The effects of any mineral leasing activity will 

be analyzed at the appropriate future time if the Forest Service receives specific 

requests for access to leasable minerals. 

Salable or common variety minerals, primarily crushed rock, are utilized in each of 

the alternatives. Their predominant use is to construct roads in support of the 

Tongass National Forest transportation system, and thus the amounts used will 

correspond closely to the miles of new road construction by alternative. These are 

shown in Chapter 2 as well as the Transportation section of this chapter. 

Effects on Other Resources 

The development of mineral resources in the Forest generally requires construction 

of an underground mine complex, a millsite, road and pipeline systems, tailings and 

waste rock disposal areas, a marine transfer/docking facility, and lodging 

accommodations if the mine location is not close to an existing community. Total 

surface-disturbing acreage can vary markedly with specific project characteristics; 

the operating Greens Creek mine involves about 320 acres for facility development, 

and the proposed Kensington mine project will use about 280 acres. The effects of 

any such development are analyzed at the time a specific project is proposed. 

The potential for cumulative effects associated with Forest Service management of 

minerals on the Tongass will depend upon the extent to which mining interests elect 

to pursue mineral exploration, development, and production activities on NFS lands 

in the future under the amended Forest Plan. Impacts from future mineral resource 

activities on the Tongass would add to the baseline impacts from past, present, and 

ongoing mineral activity within Southeast Alaska. Alterantive 5 would allocate about 

171,000 acres to the Minerals LUD, and all of the other alternatives would allocate 

about 250,000 acres. This difference may indicate that Alternative 5 has a slightly 

lower potential for long-term cumulative effects; however, no major projects are 

proposed on these additional acres and NEPA analyses would need to be 

conducted prior to any project authorizations. Alternatives 4 through 7 allocate 

similar proportions (66 to 68 percent) of the Rank 1 known mineral resource tracts to 

LUDs expected to produce average mineral development costs, while the other 

alternatives would allocate from 50 to 61 percent of these areas to average-cost 

LUDs. Therefore, Alternatives 4 through 7 would have a relatively greater, but 

unknown, potential to contribute to cumulative effects associated with mineral 

activity. Other than mineral resources that are currently under development 

(specifically, the Kensington deposit), the Forest Service does not have sufficient 

information to identify any specific mineral development as reasonably foreseeable. 

Cumulative 

Effects 
 Environment and Effects 3 

Final EIS 3-365 Recreation and Tourism 

Recreation and Tourism 

Affected Environment............................................................................. 3-365

Introduction and Overview ..................................................................... 3-365

Supply of Recreation Opportunities ....................................................... 3-367

Existing Use Levels and Trends ............................................................ 3-372

Environmental Consequences............................................................... 3-386

Direct and Indirect Effects...................................................................... 3-386

Effects by Alternative ............................................................................. 3-397

Cumulative Effects ................................................................................. 3-399

Risk and Uncertainty .............................................................................. 3-400

Affected Environment 

The affected environment portion of the recreation and tourism analysis is divided 

into two broad sections, the first addressing the supply of recreation opportunities, 

and the second addressing existing use levels and trends. The supply section 

discusses the existing supply of recreation opportunities in terms of the Forest 

Service’s Recreation Opportunity Spectrum (ROS) classes and inventoried 

recreation places on the Tongass. The existing use and trends section discusses 

overall forest use, resident recreation, tourism, and commercial outfitter/guide use. 

The remainder of this introductory section provides a general overview of recreation 

in Southeast Alaska and the Tongass National Forest, which comprises 

approximately 80 percent of the region. Southeast Alaska possesses a remarkable 

and unique combination of features including inland waterways with over 11,000 

miles of shoreline, mountains, fiords, glaciers, and large or unusual fish and wildlife 

populations that provide opportunities for a wide range of outdoor recreation 

experiences. Southeast Alaska imparts a sense of vastness, wildness, and solitude. 

These sentiments are enhanced by a small resident population and a relative 

absence of development compared to most other National Forests. 

Recreation and tourism on National Forests encompasses more than the provision 

of facilities or recreation sites. This is especially true on the Tongass National 

Forest where most recreation and tourism attractions occur in remote undeveloped 

areas. Many Alaska residents purposefully live in proximity to such settings as a 

part of their lifestyle. Most visitors who travel long distances to see Alaska expect to 

find it in a wild and “unspoiled” state, but also expect comfort and convenience, 

reliable transportation, and other features requiring some level of infrastructure and 

development. The challenge to managers is to identify and understand the 

relationship between the settings and the variety of client groups. Commercial 

providers of recreation activities base much of their marketing strategy on particular 

environmental settings and identified recreation places within those settings. 

The Tongass National Forest includes approximately 17 million acres of land 

available for recreation. This land contributes greatly to the feeling of vastness and 

solitude that dominates the region; however, much of the land is not suitable for 

outdoor recreation. Difficult and steep terrain, wetlands, icefields, glaciers, and 

heavy vegetation confine most recreation activities to accessible shorelines, river 

and stream bottoms, and around the many lakes within the Forest. Extensive use is 

made of some of the icefields and alpine areas (above tree line), but access to these 

areas is usually by aircraft. Both residents and visitors use the developed 

campground and picnic areas, beaches, trails, cabins, shelters, and visitor centers 

that are located near communities. A current inventory of developed recreation sites 

on the Tongass is presented in Table 3.15-1. 
3 Environment and Effects

Recreation and Tourism 3-366 Final EIS

Table 3.15-1 

Tongass Recreation Facilities

Type of Facility Number 

Anchor Buoys 28 

Major Campground Developments 10 

Number of Sites 207 

Minor Campground Developments 15 

 Number of Sites 28 

Major Interpretive Sites (Visitor Centers) 2 

Wildlife/Fish Viewing Sites 12 

Organized Camps 2 

Picnic Areas 24 

Number of units 95 

Recreation Cabins 

 - Wilderness 52 

 - Nonwilderness 97 

Total Recreation Cabins 149 

Recreation Residences 15 

Isolated Cabins 65 

Resorts and Lodges 3 

Trails (number of miles): 

 - Nonwilderness 419.4 

 - Wilderness 85.1 

 Total Trail Miles 504.5 

Shelters 38 

Developed Trailheads 13 

Source: USDA Forest Service 1997a (Table 3-34). 

The National Park Service manages 3.3 million acres in three park units in 

Southeast Alaska. The majority of this land is located within the Glacier Bay 

National Park and Preserve. The other two park units are the Sitka National Historic 

Park and Klondike Goldrush National Historic Park. 

The State of Alaska also administers land for recreation. Many of the state land 

selections were made with recreation opportunities for the residents of local 

communities in mind. Most of these opportunities are still undeveloped. State 

selections were also made for future development of a system of marine parks. 

Currently, Alaska State Parks manages about 80,000 acres and 34 park units, 

including 16 marine parks, in Southeast Alaska. In addition, the Alaska Department 

of Fish and Game (ADF&G) manages two state wildlife refuges, two critical habitat 

areas, and one wildlife sanctuary, and the Alaska Division of Forestry manages the 

247,000-acre Haines State Forest (Alaska State Parks 2004). 

Community road systems are limited and heavily used for access to recreation sites 

and attractions near local communities. Existing road systems are primarily located 

near the larger communities of Juneau, Sitka, Ketchikan, Petersburg, and Wrangell. 

There is an extensive road system connecting the small communities on Prince of 

Wales Island, to systems developing near the communities of Hoonah and Kake. 

There is no interconnecting highway system between islands or between 

communities on the mainland. 

Haines, Skagway, and Hyder all have highway connections to Canada and the 

Alaska Interior, as well as the lower 48 states, and serve as gateways for tourists 

heading north. Haines and Skagway are also visited by cruise ships and served by 

the Alaska Marine Highway System (AMHS). 

Roads exist in other locations where timber harvest has taken place. Independent 

visitors from outside the state and residents from other parts of Southeast Alaska 

use road systems that are accessible from the AMHS ferries or from local 

communities for recreational purposes. Roads in locations where there are no 
 Environment and Effects 3 

Final EIS 3-367 Recreation and Tourism 

communities or interconnecting access to the AMHS receive relatively low levels of 

recreation use. However, recreation-related vehicle use has been growing on some 

remote islands, including Kruzof, Zarembo, and Etolin Islands, and isolated systems 

on Kuiu and Kupreanof Islands. While the total amount of recreation use on these 

islands is low, it can be heavy at times, such as during hunting season. 

Cruise ship passengers account for a large and growing share of visitors to 

Southeast Alaska. For example, the number of cruise ship visitors to Juneau more 

than doubled over the past decade from 462,542 in 1996 to 948,226 in 2005 (see 

Table 3.15-10). Other Southeast Alaska ports visited by cruise ships include 

Ketchikan, Sitka, Wrangell, Skagway, and Haines. 

The supply of recreation opportunities is described in this analysis using two 

concepts: ROS and recreation places. These concepts describe the quantity of 

recreation opportunities. Quality is addressed using the “Home Range” concept and 

by assigning a value to the recreation places. These concepts are discussed in the 

following sections. 

Recreation Opportunity Spectrum 

The Tongass National Forest has the potential to provide a wide variety of 

recreation settings. The ROS has been developed to help identify, quantify, and 

describe these settings. The ROS system portrays the combination of activities, 

settings, and experience expectations along a continuum that ranges from highly 

modified to primitive environments. Seven classifications are identified along this 

continuum: Urban (U), Rural (R), Roaded Natural (RN), Roaded Modified (RM), 

Semi-Primitive Motorized (SPM), Semi-Primitive Non-Motorized (SPNM), and 

Primitive (P). The ROS inventory may be used to assess the potential effects of the 

alternatives on recreation settings. 

The seven ROS classes are summarized in Table 3.15-2, based on seven elements 

that are considered in the allocation and management of recreation settings. 

Forest-wide ROS acres are presented in Table 3.15-3. 

Viewed in terms of acres, the Primitive ROS setting is the largest on the Tongass, 

with approximately 10.4 million acres allocated to this setting (Table 3.15-3). The 

Wilderness and Natural Setting Land Use Designation (LUD) groups currently 

account for 47 and 45 percent of this total, respectively. Approximately 36 percent of 

the areas presently inventoried as SPNM (3 million acres) are located in the 

moderate development (12 percent) or intensive development (24 percent) LUD 

groups, with 19 percent located in existing Wilderness. Areas inventoried as SPM 

account for approximately 1.5 million acres Forest-wide and are mostly located in the 

Wilderness (31 percent) and Natural Setting (47 percent) LUD groups. 

Approximately 76 percent of areas allocated to the RN, RM, Rural, and Urban 

settings are located in the moderate development (23 percent) or intensive 

development (53 percent) LUD groups (Table 3.15-4). 

Existing Wilderness on the Tongass is mostly associated with the Primitive ROS 

setting (82 percent), with the remaining 18 percent comprised of SPNM (10 percent) 

and SPM (8 percent). Much of the area inventoried as SPM on the Tongass is 

accessed via motorized watercraft. The Primitive ROS setting also comprises a 

large share of the Natural Setting LUD group (65 percent), with the remaining area 

allocated to other ROS settings, including 19 percent inventoried as SPNM 

(Table 3.15-4). 

Supply of 

Recreation 

Opportunities 
3 Environment and Effects

Recreation and Tourism 3-368 Final EIS

Table 3.15-2 

Comparison of ROS Classes

 Urban (U) Rural (R) Roaded Modified (RM) Roaded Natural (RN)

Scenic 

Quality 

Alterations to landform 

and vegetation 

dominate landscape; 

nonrecreational 

activities not to exceed 

Low SIO - FG; Very 

Low SIO - MG. 

Alterations to landform 

and vegetation dominate 

landscape; 

nonrecreational activities 

not to exceed Low SIO - 

FG; Very Low SIO - MG. 

Alterations dominate 

the landscape; 

nonrecreational 

activities/structures 

evident, but do not 

exceed Very Low SIO. 

Alterations to 

landscape 

subordinate; 

nonrecreational 

activities not to 

exceed Low SIO 

though typically 

Moderate SIO. 

Access1 Access and travel 

facilities are highly 

intense, motorized, 

and often with mass 

transit supplements. 

All methods of access 

and travel may occur, but 

subject to formal 

regulation. 

All methods of access 

and travel when 

needed and compatible 

with intended activities. 

All methods of 

access and travel 

may occur when 

compatible with 

intended activities; 

zones of nonmotorized use. 

Remoteness Remoteness from sites 

and sounds of human 

activity not available or 

important. 

Remoteness from sites 

and sounds of human 

activity not available or 

important. 

Remoteness from 

continuous sounds of 

human activity is 

expected. 

Remoteness from 

continuous sounds 

of human activity is 

of moderate 

importance. 

Visitor 

Management 

Intensive on-site 

controls are numerous 

and obvious. 

On-site regimentation 

and control is obvious. 

On-site regimentation 

and controls are few. 

On-site 

regimentation and 

control is obvious. 

On-site 

Recreation 

Development 

Recreation structures 

and facilities readily 

evident, but 

appropriate for setting; 

designed for high use 

levels. Information 

and interpretive 

facilities may be large 

and complex. 

Recreation structures 

and facilities readily 

evident, but appropriate 

for setting, designed for 

high use levels. 

Information and 

interpretive facilities may 

be large and complex. 

Recreation structures 

and facilities may be 

present, but are 

provided primarily for 

protection of the 

resource rather than 

user convenience. 

Facilities are rustic and 

harmonize with a 

backcountry setting. 

Recreation 

structures and 

facilities provided 

for site protection 

and user 

convenience. 

Facilities are 

contemporary but of 

rustic design and 

harmonize with 

natural setting. 

Social 

Encounters 

High concentrations of 

people at one time. 

Moderate to high 

concentrations of people 

at one time. 

Moderate 

concentration of users 

on roads and little 

evidence of others or 

interactions at 

campsites. 

Interactions with 

others may be 

moderate to high. 

Moderate 

concentrations of 

people, especially 

on trails and in 

dispersed areas. 

Visitor 

Impacts 

Very noticeable, but 

managed to prevent 

physical resource 

degradation. 

Very noticeable, but 

managed to prevent 

physical resource 

degradation. 

Human use noticeable, 

but not degrading to 

resources. Site 

hardening dominates 

campsites, parking 

areas. 

Visitor use 

noticeable, but not 

degrading to 

resources; 

established SIOs. 
 Environment and Effects 3 

Final EIS 3-369 Recreation and Tourism 

Table 3.15-2 (continued) 

Comparison of ROS Classes

Semi-Primitive Motorized 

(SPM) 

Semi-Primitive NonMotorized (SPNM) Primitive (P) 

Scenic Quality Alterations few and subordinate 

to landscape; designed and 

located to not exceed Moderate 

SIO. 

Alterations few and 

subordinate to 

landscape; 

nonrecreational activities 

and structures designed 

not to exceed High SIO. 

Alterations to landscape 

not evident; structures do 

not exceed High SIO. 

Access1 Travel on trails designed 

for/open to motor vehicles; 

roads maintained for high 

clearance vehicles; motorboats 

operating on waterways; may 

establish zones of non-motor 

use for facility/resource 

protection. 

Trails closed to 

motorized use; 

nonmotorized boats used 

on freshwater lakes and 

streams. 

Trails closed to motorized 

use; non-motorized boats 

used on freshwater lakes 

and streams. 

Remoteness Nearby sights and sounds of 

human activity are rare; distant 

sounds may occur. 

Nearby sounds of human 

activity are rare; distant 

sounds may occur. 

Sounds of human activity 

are very infrequent to 

nonexistent. 

Visitor 

Management 

On-site regimentation and 

controls are few. 

On-site regimentation 

and controls are rare. 

On-site regimentation and 

controls are very rare. 

On-site 

Recreation 

Development 

Recreation structures and 

facilities may be present, 

provided primarily for protection 

of site rather than user 

convenience. Facilities, when 

present, are rustic and 

harmonize with natural setting. 

Recreation structures 

and facilities may be 

present but provided 

primarily for protection of 

site. Facilities, when 

present, are rustic and 

harmonize with natural 

setting. 

Recreation structures are 

rarely present, provided 

primarily for the protection 

of the site. Facilities, 

when present, are rustic 

and harmonize with 

natural setting. 

Social 

Encounters 

Low interaction between users. 

Campsites seldom within sight 

or sound of another group 

except during peak periods. 

Low interaction between 

users. Campsites 

seldom within sight or 

sound of another group 

except during peak 

periods. 

Very low interaction 

between users and no 

other groups in sight or 

sound of overnight camps. 

Visitor Impacts Human use noticeable, but not 

degrading to resource or 

backcountry setting. 

Human use noticeable, 

but not degrading to 

resource elements. 

Human use essentially 

unnoticeable. Site 

hardening—boardwalks, 

boat moorings, food 

caches. 1 Subject to ANILCA provisions. 

Note: SIO = Scenic Integrity Objective, FG = Foreground, MG = Middleground 

Source: USDA Forest Service 1997a (Table 3-30). 
3 Environment and Effects

Recreation and Tourism 3-370 Final EIS

Table 3.15-3 

Forest-wide Recreation Opportunity Spectrum Acres, 2006

ROS Class Acres 

Primitive (P) 10,358,097 

Semi-Primitive Non-Motorized (SPNM) 3,046,573 

Semi-Primitive Motorized (SPM) 1,486,874 

Roaded Natural (RN) 160,614 

Roaded Modified (RM) 1,713,361 

Rural and Urban (R and U) 5,728 

Note: 

The total acres by ROS class shown in this table is slightly lower than the Forest-wide total because the 

ROS inventory does not include the entire Forest.

Table 3.15-4 

Forest-wide Recreation Opportunity Spectrum Acres by LUD Group, 2006

LUD Group P SPNM SPM RN RM R+U 

Acres by LUD Group and ROS 

Wilderness 4,840,497 568,994 457,695 21,707 18,949 151

Mostly Natural 4,692,925 1,384,844 701,158 85,471 326,650 4,313

Moderate Development 172,876 363,111 184,202 40,428 388,568 508

Intensive Development 651,799 729,625 143,819 13,007 979,189 747

Percent of ROS Setting 

Wilderness 47 19 31 14 1 3

Mostly Natural 45 45 47 53 19 75

Moderate Development 2 12 12 25 23 9

Intensive Development 6 24 10 8 57 13

Percent of LUD Group 

Wilderness 82 10 8 0 0 0

Mostly Natural 65 19 10 1 5 0

Moderate Development 15 32 16 4 34 0

Intensive Development 26 29 6 1 39 0

Notes: 

1. P=Primitive, SPNM=Semi-Primitive Non-Motorized, SPM=Semi-Primitive Motorized, RN=Roaded Natural, 

RM=Roaded Modified, R+U=Rural and Urban 

2. The total acres by ROS class shown in this table is slightly lower than the Forest-wide total because the 

ROS inventory does not include the entire Forest.

Recreation Places 

The Tongass offers a unique recreation setting because it provides an island and 

marine environment in close proximity to major mountain ranges and icefields. 

Forested mountains rising from the saltwater provide unique and remote coastal 

recreation opportunities not found in other areas of the United States. Recreation 

enthusiasts are able to view a variety of natural landforms and wildlife, such as 

glaciers, old-growth forests, humpback whales, spawning salmon, brown bears, and 

bald eagles. The immense amount of land on the Tongass National Forest provides a 

great diversity of recreation attractions and opportunities. Most recreation activities 

take place in, and are dependent on, settings that are primarily undeveloped and 

widely dispersed. The surrounding saltwater, which is not managed by the Forest 

Service, allows for motorized boat and floatplane access throughout Southeast 

Alaska. 

The pattern of use associated with known protected boat anchorages, boat 

landings, aircraft landing sites, and the limited road systems makes it possible to 

identify specific “recreation places.” Recreation places are those areas that are 

used for recreation activities and are easy to access. Approximately 1,436 

recreation places, totaling about 3.6 million acres (22 percent of the total Tongass 

National Forest), have been identified. Approximately 22 percent, or 311 of these 

places, are located in existing designated wildernesses. Although these areas 

Recreation Places are 

areas that are used for 

recreation activities 

and are easy to 

access. These areas 

are identified based on 

patterns of use 

associated with 

protected boat 

anchorages and 

landings, aircraft 

landing sites, and 

roads. 
 Environment and Effects 3 

Final EIS 3-371 Recreation and Tourism 

comprise only 22 percent of the Forest-wide number of recreation places, they 

account for 36 percent of total recreation place acres. 

The setting of a recreation place plays a key role in its attractiveness and use. 

Many recreation opportunities, such as viewing scenery or pursuing solitude, are 

dependent on this relationship and require a natural type of setting, whereas others, 

such as hunting or fishing, are less dependent on the type of setting. Table 3.15-5 

identifies the distribution of recreation place acres by ROS class. Recreation places 

can be categorized into three general groupings based on their principle uses and 

attractions. These three general groupings, marine, freshwater, and land-based, 

are discussed in the Recreation and Tourism section of the 1997 Forest Plan 

Revision Final Environmental Impact Statement (EIS) (USDA Forest Service 1997a, 

pp. 3-107, 3-108). The distribution of recreation places among these general 

groupings is presented in Table 3.15-6. 

For the purposes of this analysis, recreation places are classified in two basic ways. 

First, recognizing that access plays a key role in recreation in Southeast Alaska, 

“home ranges” were defined for each community. Inventoried recreation places 

were classified into two categories: those located within a radius of approximately 

20 miles from communities (“home range”) and those outside (“rest of forest”). 

Almost half (48 percent) of the recreation place acres are within a community home 

range. Second, recreation places are identified as either important or ordinary/ 

common based on five categories: facilities, marine, hunting, fishing, and tourism. 

The Forest Service developed this rating system in response to public comments 

received on the 1990 Draft EIS. Recreation places may be important for one, 

several, or none of the identified categories. Important recreation places by 

category are summarized in Table 3.15-7 and discussed further in the Recreation 

and Tourism section of the current Forest Plan Revision Final EIS (USDA Forest 

Service 1997a, pp. 3-109, 3-111). 

Table 3.15-5 

Distribution of Recreation Place Acres by Recreation Opportunity 

Spectrum Class

ROS Class Acres (1,000s) 

Primitive 1,306 

Semi-Primitive Non-Motorized 916 

Semi-Primitive Motorized 870 

Roaded Natural 103 

Roaded Modified 432 

Rural and Urban 3 

Note: These totals include all identified recreation places within the Tongass National Forest boundary, 

including those on state and private lands. 

Table 3.15-6 

Distribution of Recreation Places by General Use 

Number of Places Percent of Total Acres (1,000s)1

 Percent of Total

Marine 617 43 1,234 34 

Freshwater 302 21 908 25 

Land-based 531 37 1,488 41 

Total 1,436 100 3,630 100 1

 Updated acreages were calculated using the ratios from USDA Forest Service 1997a (pp. 3-107, 

3-108) and the total acres identified in Table 3.15-5. Totals may not sum exactly due to rounding.
3 Environment and Effects

Recreation and Tourism 3-372 Final EIS

Table 3.15-7 

Important Recreation Places by Category1

Number of 

Places 

Percent of 

Total2 

Acres 

(1,000s) Percent of Total2

Facilities3 402 28 1,053 29 

Marine4 617 43 1,089 30 

Hunting5 373 26 1,452 40 

Fishing6

 187 13 472 13 

Tourism 876 61 1,924 53 

Total Acres/Places 1,436 NA 3,630 NA 

1

 Recreation places are rated as either important or common/ordinary. 2

 Percent columns sum to more than 100 because a recreation place can be rated important in more 

than one category. 3

 All recreation places with facilities were rated as being important. In addition, other recreation places 

with some type of facility, such as a viewing platform, and facilities authorized by a special use permit 

for recreation purposes, were identified as important. 4

 The marine category identified here is different to the marine type identified in Table 3.15-6. The 

marine category in this table only includes those recreation places that are truly unique or typify the 

Southeast Alaska marine experience. 5

 Important hunting areas were distinguished from ordinary hunting areas based on a number of factors, 

including heavy recurring use, hunter success, ease of access, opportunities for several species, and 

prized species, such as mountain goats and moose. 6

 Important fishing recreation places were identified using ADF&G ratings for recreational fishing. 

Note: This estimate of total recreation place acres is slightly higher than the estimate used in the current 

Forest Plan Revision Final EIS (USDA Forest Service 1997a). The database used to develop these 

estimates has been updated and these estimates were developed using a more precise methodology 

than the grid-sampling approach that was employed in the 1997 Forest Plan Revision Final EIS analysis. 

Source: USDA Forest Service 1997a (pp. 3-109, 3-111). 

The following section is divided into four parts that discuss forest use in general, 

resident recreation, tourism, and commercial outfitter/guide use on the Tongass 

National Forest. 

Forest Use 

Although there are some locations on the Tongass where fees are collected and 

locations where people can be easily counted, much of the information regarding 

general public use has been historically based on long-term observations, anecdotal 

information, and professional estimates, adjusted by quantitative indicators where 

available. In general, many residents and nonresidents seek the same type of 

recreation experiences and many engage in similar activities. Alaska has a 

reputation for vastness, rugged beauty, and solitude, and both residents and 

nonresidents usually expect to find these qualities in recreation settings. 

Expectations often vary by group and individual, however, with some people having 

higher expectations of wilderness and solitude than others. 

The Alaska Region of the Forest Service (Region 10) began participating in the 

Forest Service’s National Visitor Use Monitoring (NVUM) program in 2000. The final 

results of this program, which involved surveys conducted over 3 years, were 

published in August 2004 (Kocis et al. 2004). According to the NVUM analysis, 

there was an estimated total of 1.83 million National Forest visits and 2.13 million 

site visits to the Tongass in 2003 (Kocis et al. 2004). NVUM has standardized 

definitions of visitor use measurement to ensure that all National Forest visitor 

measurements are comparable. A National Forest visit, as defined by the NVUM, is 

the entry of one person onto the Forest to participate in recreation activities for an 

unspecified period of time and may include multiple site visits. A site visit, as 

defined by the NVUM study, is the entry of one person onto a National Forest site or 

area to participate in recreation activities for an unspecified period of time. 

The results of the NVUM surveys on the Tongass indicate that the top five activities 

of survey respondents were viewing natural features (64.4 percent), hiking/walking 

Existing Use 

Levels and 

Trends 
 Environment and Effects 3 

Final EIS 3-373 Recreation and Tourism 

(59.6 percent), relaxing (32.5 percent), viewing wildlife (16.4 percent), and nature 

center activities (15.1 percent) (Table 3.15-8). Survey respondents were also asked 

to identify the primary activity that they were engaged in at the time of the survey. 

The top activities were hiking/walking (30.5 percent), viewing natural features (26.7 

percent), fishing (8.3 percent), relaxing (8 percent), and gathering forest products 

(4.2 percent) (Table 3.15-8). Three of these activities (viewing natural features, 

hiking/walking, and relaxing) are also in the top five activities ranked by participation. 

Table 3.15-8 

Activity Participation and Primary Activities Identified in the 2004 

Tongass NVUM Survey

Activity 

Percent 

Participation 

Primary Activity 

(Percent)3

Viewing Natural Features 64.4 26.7 

Hiking/Walking 59.5 30.5 

Relaxing 32.5 8.0 

Viewing Wildlife 16.4 2.9 

Nature Center Activities 15.1 3.1 

Fishing 13.5 8.3 

Nature Study 9.9 2.3 

Picnicking 8.9 3.2 

Gathering Forest Products 8.9 4.2 

Driving for Pleasure 8.1 1.8 

Motorized Water Activities 7.9 0.4 

Visiting Historic Sites 6.2 0.3 

Resort Use 4.1 1.9 

Hunting 3.6 3.2 

Other Non-motorized 3.2 0.6 

Non-motorized Water 2.9 0.6 

Other Motorized Activity 2.6 0.2 

Bicycling 2.3 1.2 

Backpacking 2.2 0.0 

Developed Camping 1.7 0.6 

OHV Use 1.3 0.0 

Cross-country Skiing 1.0 1.0 

Primitive Camping 0.6 0.1 

Downhill Skiing 0.5 0.4 

Horesback Riding 0.3 0.0 

Snowmobiling 0.2 0.2 

Source: Kocis et al. 2004 (Table 13) 

Resident Recreation 

Many residents of Southeast Alaska place a high value on the quality and availability 

of outdoor recreation opportunities in the region. This is evidenced by the fact that 

the proportion of Alaskan residents who participate in outdoor activities is generally 

much higher than elsewhere in the United States (Bowker 2001). Many local 

residents engage in dispersed recreation activities on National Forest System (NFS) 

land and adjacent saltwater. Accurate data on this type of use are difficult to obtain 

and estimates tend to either underestimate the nature and extent of much of this use 

or overcompensate in inconsistent ways (USDA Forest Service 1997a, p. 3-120). 

The net result is that while there is a general consensus that outdoor recreation 

opportunities and activities provided by the Tongass are highly important to 

residents, there is limited data that accurately quantifies resident recreation use. 

Resident recreation demand is influenced by a number of factors, including regional 

population levels, per capita participation rates, and recreation travel behavior. Over 

time, the supply of certain recreation opportunities in Southeast Alaska has 
3 Environment and Effects

Recreation and Tourism 3-374 Final EIS

increased. Road systems have expanded into previously inaccessible areas and 

visitor services and tourism marketing have also increased. In some cases, supplyinduced increases in participation have occurred. This appears to be the case on 

Prince of Wales, Wrangell, and Mitkof Islands where road systems developed for 

timber harvesting created an opportunity for road-related access to previously 

inaccessible recreation settings and an opportunity for recreation activities involving 

wheeled vehicles. 

Supply-induced participation changes have also been accompanied by additional 

demand for specific recreation places or facilities for a related activity. Increased 

opportunities for roaded access and activities are typically accompanied by a need 

for parking, dispersed campsites, picnic sites, trails to scenic attractions, and 

additional short access routes to cabin sites and previously inaccessible beaches. 

Increased tourism has resulted in increased demand for interpretive services as well 

as walking and hiking opportunities near the major communities. 

The use of off-highway vehicles (OHVs) is another growing activity on the Tongass. 

Use is limited by topography, dense vegetation, and wet soils. These types of 

vehicles are most frequently used on road systems connected to communities, with 

riders seeking out primitive roads or spurs. Limited accessibility often results in 

OHV use on muskegs, beaches, tidal areas, and river channels during low flows. 

A new travel management policy established for the Forest Service in 2005 requires 

each National Forest to identify and designate those roads, trails, and areas that are 

open to motor vehicle use. This policy is presently being implemented on the 

Tongass with each District Ranger required to seek public input and coordinate with 

federal, state, county, and other local governmental entities, as well as tribal 

governments, before any decision is made to consider use on a particular road, trail, 

or area. This decisionmaking process also involves completing National 

Environmental Policy Act (NEPA) analyses, as appropriate. Unplanned, usercreated routes will be considered at the local level during the designation process 

(USDA Forest Service 2005e). 

Tourism 

Nonresident pleasure visitors or tourists can be divided into independent and 

package visitors. Independent visitors, who constitute a small but growing group, 

are characterized as those who get off the ferries and planes and engage in a 

variety of activities. They spend more time in the communities and on the Forest, 

and may secure the services of outfitters and guides, restaurants, motels, and 

transportation services such as floatplanes, boats, and gas stations. Independent 

travelers tend to plan their own itineraries, but often secure the services of minipackages, such as day excursions or fishing charters. Approximately 89 percent of 

non-cruise ship visitors to Southeast Alaska in 2006 purchased some type of multiday package (McDowell et al. 2007). These types of visitors compete more directly 

with residents for recreation opportunities on the Forest. Lodges have grown in 

popularity in recent years, with fishing lodges in particular playing an important role 

in the tourism industry in some local areas. A recent study, for example, identified 

nine recreational fishing lodges in the vicinity of Elfin Cove, a small town located 

west of Hoonah (Dugan et al. 2006). Fishing lodges accounted for 63 percent of the 

non-cruise, multi-day packages identified in 2006, with Wilderness lodges 

accounting for a further 13 percent of the total. Adventure tours (7 percent), rail 

packages (3 percent), motorcoach tours (3 percent), and “other” (12 percent) 

accounted for the remaining share of multi-day packages (McDowell et al. 2007). 

Package visitors are typically the cruise ship clients, though some arrive by ferry and 

airplane. This is a very large group that uses the Tongass National Forest primarily 

as a scenic resource. These visitors spend less time in the area and generally 

follow preplanned and regimented itineraries. Shore excursions have, however, 
 Environment and Effects 3 

Final EIS 3-375 Recreation and Tourism 

become an important part of the cruise ship experience, with much of this activity 

centered around communities. Half-day and day excursions into the Forest are also 

increasing in popularity. 

The marketing of recreation opportunities by commercial suppliers has important 

similarities to resident recreation concerns. For example, many businesses that 

provide boat or aircraft access for wildlife viewing and other activities have a low 

tolerance for the presence of other groups in the same area. The presence of more 

than two or three other parties in a bay or area may cause such operators to seek 

substitute locations. The ability to market Alaska tourism, in part due to the high 

cost of visiting Alaska, is dependent on meeting customer expectations of seeing 

and experiencing vast, untamed land and its wildlife. Resident recreationists who 

traditionally use an area may, however, be discouraged by commercial businesses 

operating in the same area. 

Reasons for Visiting Southeast Alaska 

Two of the top three attractions in the state in 1993 were directly associated with the 

Tongass: the Inside Passage ranked first and Mendenhall Glacier ranked third. 

Southeast communities accounted for four of the six most frequently visited 

communities and places in the state: Juneau ranked second, Ketchikan third, 

Skagway fourth, and Glacier Bay sixth (USDA Forest Service 1997a).1

 

The most recent comprehensive survey of the motivations of visitors to Southeast 

Alaska was conducted in 1988. Outstanding scenery was identified as the most 

cited reason for visiting the region (Table 3.15-9). Opportunities for seeing whales, 

bald eagles, bears, and other wildlife add to the experience. Wildlife was the 

second most cited reason for visiting the area. Scenery and wildlife were the most 

frequently cited attractions by both independents and visitors as a whole 

(Table 3.15-9). 

Table 3.15-9 

Reasons for Visiting Southeast Alaska 

Reason Independents All Visitors 

Scenery 66% 66% 

Wildlife 31% 35% 

Recommendations 25% 25% 

Visit friends/relatives 23% 7% 

Fishing/hunting 19% 8% 

Wildernesses 16% 13% 

Specific attractions 13% 10% 

Part of cruise 9% 60% 

Advertising 7% 10% 

Price 2% 8% 

Source: USDA Forest Service 1997a (Table 3-37). (Original Source: Data Decisions Group 1989. 

Southeast Alaska Pleasure Visitor Research Program, Summer 1988, p. 20.)

As noted, the 1988 survey is the most recent comprehensive survey of this type. 

The State of Alaska has not commissioned any similar comprehensive surveys of 

the motivations of Southeast Alaska visitors since that time. The information 

summarized in Table 3.15-9 provides an interesting snapshot of visitor motivations 

in 1988, but the number of visitors to the region has more than doubled since 1993, 

with the number of cruise ship visitors increasing more than threefold over this 

period. While the exact percentages may be different, it seems reasonable to 

assume that the Tongass-specific reasons identified in 1988—scenery, wildlife, 

fishing/hunting, and wilderness—continue to be valid today. 

 

1

 These data, presented in Table 3-35 of the current Forest Plan EIS, are originally from the 

1993 Alaska Visitor Statistics Program (AVSP). These data have not been collected in 

subsequent AVSPs. 
3 Environment and Effects

Recreation and Tourism 3-376 Final EIS

Although there has not been a similar comprehensive survey specifically designed 

to address the motivations of visitors to Southeast Alaska, the results of three more 

recent surveys provide some insight. These surveys are the 2001 statewide Alaska 

Visitor Statistics Program (AVSP)2

, a 2005 survey of non-cruise visitors to central 

Southeast Alaska, and a 2005 survey of cruise visitors to Juneau (Northern 

Economics 2002, McDowell Group 2006a, McDowell Group 2005). 

The 2001 statewide AVSP found that sightseeing was far and away the most 

common non-business activity for summer visitors to Alaska in 2001, cited by 53 

percent of visitors as the primary non-business activity they hoped to enjoy in Alaska 

on their trip (Table 3.15-10). The second most frequently cited activity—fishing—

was identified by only 9 percent of those surveyed. These relatively low figures for 

everything but sightseeing are partially a product of the survey design with survey 

respondents asked to identify the primary activity rather than multiple activities, but 

also reflect the importance of sightseeing and the range of other available activities. 

Table 3.15-10 

Most Common Non-Business Activities for Visitors to Alaska, 2001

Activity1 Percent of Surveyed Visitors

Sightseeing 53 

Fishing 9 

Touring Glaciers 3 

Hiking 3 

Wildlife Viewing 3 1

 These are the five most common responses to the question: “What is the primary non-business 

activity you hope to enjoy in Alaska on this trip?” The results were not disaggregated by region. 

Source: Northern Economics 2002. 

The McDowell Group (2006a) found that fishing, cited by 49 percent of surveyed 

visitors, was the primary reason to visit most frequently cited by non-cruise visitors 

to central Southeast Alaska in 2005. Visit friends/family and outdoors/scenic beauty 

were identified by 32 and 22 percent of surveyed visitors, respectively (Table 3.15-

11). Fishing was identified by 46 percent of surveyed visitors as the activity they 

enjoyed most on their trip, with outdoors/scenic beauty and visit family/friends cited 

by 43 percent and 20 percent of those surveyed, respectively (Table 3.15-11). 

These data are for visitors to central Southeast Alaska, but are likely to be broadly 

representative of all non-cruise visitors to rural areas in Southeast Alaska. 

The McDowell Group also surveyed cruise ship visitors to Juneau in 2005 and 

provided summary data from similar surveys conducted in 2003 and 2001. A survey 

of cruise ship passengers docking at Juneau may be considered broadly 

representative of all cruise ship visitors to Southeast Alaska because most cruise 

ships visiting Southeast Alaska stop there. These data again support the 

importance of scenery and sightseeing to the overall visitor experience, with 44 

percent of cruise ship passengers surveyed in Juneau in 2005 identifying 

scenery/sightseeing as one of their most enjoyed activities (Table 3.15-12). 

Glaciers and whale watching were identified by 27 percent and 16 percent of 

surveyed visitors in 2005, respectively. The top three cited activities in 2005—

scenery/sightseeing, glaciers, and whale watching—were also the most frequently 

cited activities in 2001 and 2003. 

 

2 The AVSP is a significant visitor industry research project conducted periodically by the 

State of Alaska. The most recent study was conducted in 2006 (McDowell et al. 2007).
 Environment and Effects 3 

Final EIS 3-377 Recreation and Tourism 

Table 3.15-11 

Reasons for Visiting and Most Enjoyed Activities for Rural (NonCruise) Visitors to Central Southeast Alaska, 2005

Percent of Surveyed Visitors1

Activity Reason for Visit2 Most Enjoyed3

Fishing 49 46 

Visit Friends/Family 32 20 

Outdoors/Scenic Beauty 22 43 

Wildlife 13 21 

Inside Passage 11 NA 

People NA 12 

1

 Central Southeast was defined for the purposes of the McDowell Group study as Petersburg, 

Wrangell, Kake, Alaska and Prince of Wales Island. Note: Multiple responses were allowed. 2

 Activities identified in response to the survey question: “Why did you choose to visit the Central 

Southeast Alaska area?” 3

 Activities identified in response to the survey question: “What did you enjoy most about visiting the 

Central Southeast Alaska area?” 

Note: NA = not included in the top five cited activities for this category 

Source: McDowell Group 2006a 

Table 3.15-12 

Most Enjoyed Activities for Cruise Visitors to Juneau, 2001, 2003, and 

2005

 Percent of Surveyed Visitors 

Activity 20051 2003 2001 

Scenery/Sightseeing 44 34 20 

Glaciers 27 20 18 

Whale Watching 16 8 9 

Shopping 15 5 7 

Weather 9 3 2 1

 The percentages for 2005 sum to more than 100 because multiple responses were allowed in the 

survey for that year. 

Source: McDowell Group 2005 

Taken together, these studies indicate that the scenery and sightseeing are 

consistently among the top reasons, and in most cases the top reason, attracting 

visitors to Alaska, Central Southeast, and Juneau. They are also most frequently 

cited as “most enjoyed” by surveyed visitors. This is largely consistent among 

different types of visitors (i.e., cruise and non-cruise) and consistent with the results 

of the 1988 survey (see Table 3.15-9). The other activities identified as reasons for 

visiting in 1988 also show up in the more recent surveys to varying degrees. These 

results also suggest that while the scenery is important for all visitors, the relative 

importance of other activities varies by the type of visitor (cruise versus non-cruise) 

and the survey location. 

Trends in Visitation 

The number of visitors to Southeast Alaska has increased considerably over the 

past decade. Statewide, the total number of summer visitors increased from 

861,100 in 1993 to 1,631,500 in 2006, which equates to an average annual growth 

rate of 5 percent and a total net increase of 89 percent. The number of summer 

visitors to Southeast Alaska increased by 131 percent over the same time period, 

increasing from 502,800 in 1993 to 1,160,000 in 2006 (McDowell Group et al. 2007). 

Statewide, increases in cruise ship passengers accounted for 66 percent of the 

The estimated number 

of summer visitors to 

Southeast Alaska more 

than doubled between 

1993 and 2007, 

increasing from 

502,800 in 1993 to 

1,160,000 in 2007. 
3 Environment and Effects

Recreation and Tourism 3-378 Final EIS

growth in visitors between 1993 and 2006. Arrivals by air increased by 44 percent 

over the same period, while the number of visitors arriving by ferry, highway, and 

other modes of entry decreased (Northern Economics 2002, McDowell et al. 2007). 

Data for 2006 indicate that 63 percent of visitors to Southeast Alaska entered Alaska 

via cruise ship, 32 percent entered by air, with 3 percent and 1 percent entering via 

highway and ferry, respectively (McDowell et al. 2007). 

The number of cruise ship passengers visiting Juneau more than doubled between 

1993 and 2000, increasing from approximately 306,600 in 1993 to 632,000 in 2000 

(Table 3.15-13). This number has continued to grow over the past 5 years, with a 

total of 953,000 cruise ship visitors to Juneau in 2006, a 51 percent increase from 

2000 and a more than threefold increase from 1993. The number of passengers 

docking at Juneau is considered representative of the total number of cruise ship 

passengers because most cruise ships visiting Southeast Alaska stop there. 

Other ports in Southeast Alaska, including Ketchikan, Skagway, and Haines, also 

experienced net increases in passenger volumes during the 1990s. Sitka and 

Wrangell were exceptions to this general trend with absolute decreases in 

passenger volumes during the latter half of the 1990s. Recorded passenger 

volumes at Sitka decreased from a high of 252,256 in 1996 to a low of 160,652 in 

2000, but have since increased, peaking with 256,782 passengers in 2003. A total 

of 229,793 cruise ship passengers visited Sitka in 2005 (USDA Forest Service 

2001c, Sitka Convention and Visitors Bureau 2006). The subsequent decrease in 

passenger volumes at Sitka was likely associated with the start-up of the Icy Strait 

Point development in Hoonah (see below). 

The rapid growth and sheer magnitude of the cruise ship industry has important 

implications for recreation planning on the Tongass. Shore excursions have 

become an integral part of the cruise ship experience, providing increased revenues 

for ship operators and opportunities for local entrepreneurs. Much of this activity 

has been concentrated at ports of call that accommodate large or mid-sized cruise 

ships. Recent survey data (2005) indicate, for example, that approximately 83 

percent of cruise visitors to Juneau participated in at least one tour while they were 

in Juneau. Glacier tours were the most popular type of tour in 2005, with 42 percent 

of cruise visitors taking this type of tour. Wildlife/marine life viewing, the Mt. Roberts 

Tramway, and flightseeing via helicopter were also popular (McDowell Group 2005). 

Alongside the international cruise lines, several small and mid-size cruise operators 

are active in the region, often taking their customers to places such as Metlakatla 

and Petersburg in addition to the larger communities. Icy Strait Point, an old 

cannery located approximately 1.5 miles from Hoonah, is Alaska’s first cruise 

destination built specifically for tourists. Owned by the Hoonah Totem Corporation 

and operated by Pt. Sophia Development Corporation, this facility opened in 2004. 

A total of 67,620 cruise passengers visited Hoonah in 2004, 77,498 visited in 2005, 

and 135,519 cruise visitors were projected for 2006 (Cruise Line Agencies of Alaska 

2006). Another destination of this type is planned by the Goldbelt Corporation for 

Hobart Bay, north of Petersburg. 

While the number of cruise ship passengers visiting Juneau has more than doubled 

over the past decade, the total number of Southeast Alaska State ferry passengers 

has shown an overall pattern of decline, with about 36 percent fewer passengers 

served in 2005 than in 1990, 233,618 versus 363,122 (Table 3.15-13). 

The number of cruise 

ship passengers 

visiting Juneau more 

than trebled between 

1993 and 2005, 

increasing from

approximately 306,600 

in 1993 to 948,200 in 

2005.
 Environment and Effects 3 

Final EIS 3-379 Recreation and Tourism 

Table 3.15-13 

Southeast Alaska Visitation, 1990 to 2005

Year 

Juneau Cruise 

Ship 

Passengers1,2

Southeast Alaska 

State Ferry 

Passengers2,3

Juneau 

Airline 

Departures2

Haines 

Arrivals by 

Land4

Skagway 

Arrivals by 

Land 

1990 237,070 363,122 183,677 52,719 63,237 

1991 248,428 368,780 190,244 51,605 64,610 

1992 269,000 372,680 236,824 45,355 79,946 

19935 306,600 342,613 200,066 56,406 80,709 

1994 372,923 347,998 229,820 55,356 81,172 

1995 380,529 332,312 242,084 55,148 87,977 

1996 462,542 318,864 225,397 52,326 86,536 

1997 513,181 300,653 225,397 51,495 91,849 

1998 568,348 303,076 228,842 50,234 100,784 

1999 595,595 323,540 244,645 48,997 92,291 

20006 640,477 301,176 269,880 43,621 94,925 

2001 690,648 270,443 275,074 39,865 82,629 

2002 741,512 263,040 259,759 42,290 87,851 

2003 776,991 245,818 265,815 40,238 74,750 

2004 876,203 240,666 273,152 40,438 77,837 

2005 948,226 233,618 281,870 37,756 71,387 1

 These figures for passengers at Juneau are representative of cruise ship visitation trends because the 

majority of cruise ships visiting Southeast Alaska stop at Juneau. 2

 These data are presented for 1980 through 1994 in the 1997 Forest Plan Revision Final EIS (USDA 

Forest Service 1997a, Table 3-38). 3

 These totals do not include Inter-Island Ferry Association passengers. 4

 Arrivals by land are per passenger. 

5

 The ferry Taku was out of service during May and June, which reduced total passengers. 6

 The ferry Columbia was out of service for most of the summer season, which reduced total passengers. 7

 The town of Hyder also receives a considerable number of arrivals by land. Based on estimates 

provided by the Hyder Community Association, approximately 28,000 visitors were recorded at the Fish 

Creek viewing platform in 1999. This number grew to 31,000 in 2001. A total of 35,676 visits were 

estimated at the viewing platform in 2005 (USDA Forest Service 2006f). 

Sources: Alaska Department of Transportation 2006, Alaska Travel Industry 2006, Haines Convention 

and Visitors Bureau 2006, Skagway Convention and Visitors Bureau 2006, USDA Forest Service 1997a 

(Table 3-38) (Original Sources: Alaska Marine Highway Traffic Reports, Juneau Convention and Visitors 

Bureau, and Juneau Airport Manager’s Office); USDA Forest Service 2001c. 

Juneau airline departures increased between 1990 and 2005, but at a much slower 

rate than cruise ship passengers. Skagway and Haines arrivals by land stayed 

relatively constant over this period, showing an overall downward trend since the 

late 1990s (see Table 3.15-13 and Figure 3.15-1). Hyder also receives arrivals by 

land but data are not available for the early part of the decade. Essentially, all 

cruise ship use is by nonresident tourists. Ferry and airline passenger volumes and 

arrivals by land, on the other hand, also include Alaska residents and nonresidents 

visiting for reasons other than recreation and tourism, such as business or visiting 

relatives or friends. Larger communities also provide medical and other services 

that are not available in smaller communities. 
3 Environment and Effects

Recreation and Tourism 3-380 Final EIS

Figure 3.15-1 

Southeast Alaska Visitation, 1990 to 2005 

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

800,000

900,000

1,000,000

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005

Number of Visitors

Juneau Cruise Ship Passengers

Southeast Alaska State Ferry Passengers

Juneau Airline Departures

Haines Arrivals by Land

Skagway Arrivals by Land

Notes: 

1. Longitudinal data are not available for arrivals in Hyder (see the note to Table 3.15-13). 

2. State ferry data do not include Inter-Island Ferry Authority (IFA) passengers. 

Source: See Table 3.15-13.

Data on the division between visitor and resident arrivals are not available for 

Southeast Alaska, but are available for the state as a whole. In summer 2004, 

residents accounted for an estimated 26 percent of total arrivals, down from 28 

percent in 2001 (Northern Economics 2004, 2002). The percent of total arrivals 

accounted for by residents varied by type of transport, ranging from 0 percent for 

cruise ship arrivals to 44 percent of arrivals by highway and personal vehicle. 

Residents accounted for 41 percent and 38 percent of domestic air and international 

air arrivals, respectively, and 29 percent of arrivals by ferry (Table 3.15-14). These 

data are for the state as a whole, but are likely broadly representative of Southeast 

Alaska and illustrate the importance of the state ferry and domestic airlines to local 

residents. 

Table 3.15-14 

Alaska Arrivals by Transport Type and Visitor/Resident, Summer 2004

 Total Arrivals Percent Visitor Percent Resident 

Domestic Air 1,030,200 59 41 

International Air 44,800 62 38 

Highway 

 Personal vehicle 123,900 56 44 

 Motorcoach 13,400 85 15 

Ferry 22,800 71 29 

Cruise Ship 712,400 100 0 

Total 1,947,500 74 26 

Source: Northern Economics 2004. 
 Environment and Effects 3 

Final EIS 3-381 Recreation and Tourism 

The ferry data provided in Tables 3.15-13 and 3.15-14 and Figure 3.15-1 are for the 

AMHS only. These data do not include passengers transported by the Inter-Island 

Ferry Authority (IFA), which is a public corporation providing transportation to island 

communities in southern Southeast Alaska. Roundtrip service is currently (as of 

summer 2006) provided between Hollis and Ketchikan and seasonally from Coffman 

Cove to Wrangell and Petersburg. 

Service has been provided between Hollis and Ketchikan since 2002. This service 

transported 25,197 passengers in 2002, its first year of operation. A total of 28,658 

passengers were served by this ferry in 2005. The service between Coffman Cove 

and Wrangell and Petersburg was established in 2005 and served 2,955 

passengers between May and August of that year (IFA 2006a). IFA ferries connect 

with vessels of the AMHS at Ketchikan, Wrangell, and Petersburg (IFA 2006b). The 

continued availability of these ferry services could affect resident recreation patterns 

in the future, as well as the recreation patterns of independent visitors to the region. 

Visitation trends for two popular excursions, Juneau Icefield and Mendenhall 

Glacier, are presented in Table 3.15-15. The number of visitors to these areas has 

increased considerably since 1990. There were almost three times as many Juneau 

Icefield helicopter landing tour passengers in 2005 than in 1990, 93,902 versus 

34,765. The number of visitors to the Mendenhall Glacier nearly doubled over this 

period, increasing from 188,000 in 1990 to 367,333 in 2005 (Table 3.15-15). 

Table 3.15-15 

Juneau Icefield and Mendenhall Glacier Visitation, 1990 to 2005

Year 

Juneau Icefield Tour 

Passengers1 Mendenhall Glacier Visitors1

1990 34,765 188,000 

1991 41,887 145,482 

1992 45,638 160,000 

1993 53,600 210,000 

1994 62,449 265,000 

1995 55,818 212,411 

1996 65,709 276,000 

1997 75,491 237,233 

1998 84,632 238,366 

1999 85,174 273,488 

2000 85,531 NA 

2001 89,961 236,340 

2002 85,680 250,363 

2003 85,407 284,867 

2004 94,928 319,630 

2005 93,902 367,333 1

 These data are presented for 1980 through 1989 in the 1997 Forest Plan Revision Final EIS (USDA 

Forest Service 1997a; Table 3-38). 

Sources: 1990 to 1994: USDA Forest Service 1997a (Table 3-38) (Original Source: Juneau Ranger 

District Records); 1994 to 2000: USDA Forest Service 2001c; 2001 to 2005: USDA Forest Service 

2006g; 2006h.
3 Environment and Effects

Recreation and Tourism 3-382 Final EIS

Commercial Outfitter/Guide Use 

The Forest Service authorizes commercial activities to make it easier for the public 

to visit National Forests. Due to its remote and rugged nature, recreation use on 

much of the Tongass National Forest requires good outdoor skills and/or specialized 

equipment. Commercial outfitters and guides provide access and equipment to 

assist people who might not otherwise be able to pursue certain recreation activities 

on the Forest. Outfitter/guides on the Tongass range from small family-run 

operations to larger corporations and non-profit organizations. 

A survey of commercial recreation businesses in Southeast Alaska conducted in 

2000 indicated that the majority of surveyed businesses were small, with 86 percent 

earning gross revenues of less than $100,000. Six firms reported revenues over $1 

million, including one firm with revenues exceeding $10 million. A similar distribution 

is evident in terms of clients served, with the majority of firms serving less than 100 

clients, a smaller number of firms serving considerably larger numbers, and one firm 

serving more than 100,000 clients in 1999 (Alaska Division of Community and 

Business Development [DCBD], 2001). 

Both residents and nonresidents use the services of outfitter/guides, but 

nonresidents tend to use outfitter/guides more often because they do not have the 

local knowledge or necessary equipment. Local residents tend to use their own 

boats and equipment to reach the Forest. Personal boats are often smaller than 

charter boats used by nonresidents, resulting in visiting groups of residents 

generally being smaller than nonresident groups. 

Outfitter/guides require special use permits to operate on the Tongass and are 

required to report annual use as part of their permit. In 2005, there were almost 270 

special use authorizations issued for outfitter/guide services on the Tongass 

National Forest. 

The survey of commercial recreation businesses in Southeast Alaska conducted in 

2000 found that 73 percent of the businesses surveyed had experienced an 

increase in the number of clients they serve since 1995 (Alaska DCBD 2001). 

Nineteen percent reported no change over this period, with the remaining 8 percent 

reporting a decrease in number of clients served. Sixty-eight percent of responding 

firms indicated that they had been in business less than 10 years. Cruise ship 

passengers accounted for 41 percent of total clients for all of the surveyed 

businesses, ranging from 22 percent of clients for businesses with fewer than 200 

clients a year to 91 percent of clients for businesses with more than 10,000 clients a 

year. 

Recreation activities in Southeast Alaska and on the Tongass National Forest cover 

a broad spectrum of uses, ranging from fishing and hunting to helicopter flights and 

photography. The principle activities engaged in by the businesses surveyed in 

2000 are identified in Table 3.15-16. Saltwater fishing was the most popular activity, 

followed by nature viewing/sightseeing, then wildlife viewing. The survey found that 

motorized watercraft was the most popular transportation mode used by commercial 

recreation businesses in Southeast Alaska. 

Most outfitter/guides using the Forest shorelines access them via boat from 

saltwater. Some clients are dropped off on beaches, while others are also guided 

on land. The majority of charter boats in Southeast Alaska operate exclusively on 

saltwater for fishing or sightseeing without ever using the Forest (USDA Forest 

Service 2004g). These businesses are included in the data presented 

in Table 3.15-16. 

While people often participate in several different activities in one or more settings 

on any given trip, different activities result in different numbers of people in a group 

and different amounts of time spent on the Forest. At one end of the spectrum, 

guided bear hunting consists of many small groups of one or two people. Hunters 

Outfitter/guides on the 

Tongass range from 

small family, run 

operations to larger 

corporations. Most 

firms serve less than 

100 clients per year, 

with a smaller number 

of firms serving much 

larger numbers and 

one firm serving more 

than 100,000 clients in 

1999. 
 Environment and Effects 3 

Final EIS 3-383 Recreation and Tourism 

Table 3.15-16 

Principle Activities Engaged in by Southeast Alaska Commercial Recreation 

Businesses in 1999

Activity Percent Activity Percent 

Saltwater Fishing 63 Hiking, Mountain Climbing 14 

Nature Viewing/Sightseeing 49 Cultural/Historical Sites 10 

Wildlife Viewing 44 Camping 6 

Photography 35 Backpacking 3 

Motorized Boating 25 Northern Lights Viewing 3 

Freshwater Fishing 21 Downhill Skiing, Snowboarding 1 

Bird Viewing 21 Cross-Country Skiing, Snowshoeing 1 

Non-Motorized Boating 15 Bicycling, Mountain Biking 1 

Hunting 14 

Source: Alaska DCBD 2001

are dispersed across a large area and are on the Forest for long periods of time, 

typically 5 to 10 days, during spring and fall. At the other end of the use spectrum 

are mid-sized nature-viewing tour boats with relatively large group sizes (from 12 to 

70 people). These groups are typically concentrated in a few areas of the Forest. 

Their use is short-term and concentrated in the summer season. 

The Shoreline Outfitter/Guide FEIS, prepared for four northern Ranger Districts on 

the Tongass (USDA Forest Service 2004g), notes that recreation group size is 

highly variable along shorelines in that study’s project area. Groups generally 

consist of less than 12 people, although larger groups, often associated with 

commercially guided groups from tour boats, may also be present. The largest 

shoreline group reported in the north part of the Forest in 1999 was a tour boat with 

70 people. 

This type of use accounts for a large number of visitors, but tends to be 

concentrated in relatively few areas of the Forest. Businesses providing services to 

these types of larger groups are heavily influenced by physical conditions that allow 

for large boat access and their schedules. 

Helicopter landing tours are another form of outfitter/guide use that has been 

increasing in popularity in recent years. The number of clients and groups 

participating in helicopter tours are identified by area in Table 3.15-17. 

Of 948,226 cruise ship passengers visiting Juneau in 2000, 93,902, or 10 percent, 

participated in helicopter landing tours on the Juneau Icefield (Tables 3.15-13 and 

3.15-15). These tours to the Juneau Icefield involve high volumes of people 

concentrated at specific locations for short periods of time, typically 2 to 4 hours. 

Helicopter traffic, in groups of one to three helicopters, is almost continuous to and 

from icefield locations during the summer. Clients are typically outfitted and guided 

to walk, photograph, hike, or trek on, and explore the glacial environment. 

Dogsled mushing tours on the Juneau Icefield are also increasing in popularity, with 

approximately 21,600 helicopter tour passengers engaging in this activity in 2005 

(USDA Forest Service 2006i). This is more than twice the number of passengers 

(approximately 9,550) who participated in this type of tour in 2001. The number of 

helicopter passengers visiting the Juneau Icefield increased by 4 percent over this 

period, from approximately 90,000 to 93,900 (see Table 3.15-15). The large 

increase in the number of people taking dogsled mushing tours reflects the number 

of permitted helicopter tour operators offering this type of tour, with operators likely 

offering this type of tour in response to expressed and perceived demand. There 

were four permitted helicopter tour operators from 2001 through 2005. In 2001 and 

2002, only one helicopter tour operator under permit offered dog mushing tours. In 

2003 and 2004, there were two helicopter tour operators under permit who offered 
3 Environment and Effects

Recreation and Tourism 3-384 Final EIS

Table 3.15-17 

Helicopter Tour Locations by Client and Group, 2005

Area 

Number of 

Groups1

Number of 

Clients

Juneau Icefield 1 – Gilkey Backcountry 600 2,702 

Juneau Icefield 3 – Herbert 1,992 8,965 

Juneau Icefield 4 – Mendenhall 11,736 52,813 

Juneau Icefield 5 – Lemon 16 70 

Juneau Icefield 6 – Death Valley 6 27 

Juneau Icefield 7 – Norris 535 2406 

Juneau Icefield 8 – Taku 1,982 8,920 

P24 Baird Patterson Glaciers 94 424 

Skagway Icefield – Denver 2,360 10,621 

Skagway Icefield – East Fork 58 262 

Skagway Icefield – LeGrande 10 47 

Skagway Icefield – Meade 811 3,648

Skagway Icefield – Shubee 32 142 

1

 These numbers are an estimate of the number of helicopters based on an average helicopter 

group size of four to five passengers per trip. 

Source: USDA Forest Service 2006h 

dogsled mushing tours. In 2005, three of the operators under permit offered 

dogsled mushing tours (USDA Forest Service 2006g). 

Helicopter landing tours also occur in a number of locations elsewhere on the 

Forest, including the Revilla and Spires (Patterson Glacier) roadless areas. The 

numbers of visitors are, however, much lower than those visiting the Juneau Icefield. 

In 2000, a total of 1,205 helicopter landing tour service days were reported for the 

Revilla Roadless Area, east of Ketchikan. A total of 727 helicopter landing service 

tour days were reported for the Spires Roadless Area, northeast of Petersburg. 

After 2000, this service was no longer available (USDA Forest Service 2006h). The 

number of helicopter passengers visiting Patterson Glacier, northeast of Petersburg, 

decreased by 42 percent, from 727 passengers in 2000 to 424 passengers in 2005 

(USDA Forest Service 2006h). 

Summary data for outfitter/guide use for 2004 and 2005 are presented in Table 

3.15-18. This table identifies the number of reported outfitter/guide clients and 

groups by Ranger District. A total of 618,000 clients and 12,250 groups were 

reported in 2005, which represented a 22 percent increase in clients from 2004 and 

a 5 percent increase in the number of groups. The Juneau Ranger District 

accounted for 88 percent of the total clients in 2005, with 68 percent of these clients 

(366,191) visiting the Mendenhall Glacier Visitor’s Center. 

This diversity in the range of activities and types of recreation experience offered by 

outfitter/guide businesses can lead to conflicts between businesses when 

incompatible activities occur in close proximity. Comments received during the 

Shoreline Outfitter/Guide EIS process highlighted conflicts between helicopter and 

wheeled airplane access on one hand and some boat or foot travel access on the 

other. Several comments noted that the activities of smaller operations often tend to 
 Environment and Effects 3 

Final EIS 3-385 Recreation and Tourism 

Table 3.15-18 

Outfitter/Guide Use by Ranger District, 2004 and 2005

 2004 2005 2004-2005 Change 

Ranger District Clients Groups Clients Groups Clients Groups 

Admiralty National 

Monument 3,553 760 3,318 702 -235 -58 

Craig 1,662 246 2,063 403 401 157 

Hoonah 4,890 664 4,668 647 -222 -17 

Juneau1 439,413 NA 541,941 NA 102,528 NA 

Ketchikan - Misty 22,630 2,710 22,036 2,618 -594 -92 

Petersburg 7,059 1,113 11,420 1,444 4,361 331 

Sitka 11,212 1,610 12,281 1,776 1,069 166 

Thorne Bay 1,392 484 802 318 -590 -166 

Wrangell 9,333 1,201 14,472 1,531 5,139 330 

Yakutat 4,246 1,889 4,572 2,005 326 116 

Total 505,390 NA 617,573 NA 112,183 NA 

Note: 

NA = Not available 

1

 Data on the number of groups on the Juneau Ranger District do not include an accurate accounting 

of the number of groups visiting Mendenhall Glacier and are, therefore, not reported here. 

Source: USDA Forest Service 2006i 

be similar and compatible resulting in minimal conflicts, while larger operations often 

tend to detract from the setting and expectations of smaller groups. Some smaller 

operators believe that they are being displaced from their traditional use areas by 

larger commercial operations. On the other hand, some tour boat operators 

providing services to large groups felt they have been progressively excluded from 

areas on the Tongass National Forest over the past two decades (USDA Forest 

Service 2004g). 

The number of big game guides has increased substantially over the past decade, 

which has raised concerns that current levels of guided hunting may not be 

sustainable due to increasing user conflicts and game population concerns. Some 

comments received on the Draft 2002 Forest Plan SEIS noted that growth in the 

guiding industry has led to these activities expanding into portions of Southeast 

Alaska that were not historically subject to this type of pressure. These types of 

concerns about user conflict are evaluated by the Forest Service when addressing 

the outfitter/guide experience provided on NFS lands. The Forest Service works 

with the State of Alaska and the Federal Subsistence Board to address game 

population concerns. The State of Alaska manages recreational hunting throughout 

the state, while the Federal Subsistence Board manages all federal lands in the 

state with respect to wildlife species taken for subsistence. 

While many Southeast Alaska residents support the growing tourism industry, some 

residents are questioning the benefits and believe that unregulated growth of this 

industry would be detrimental and result in high social costs to communities. 

Concerns have been expressed that the existing and increasing level of commercial 

use is causing crowding or displacement of local residents and independent 

travelers who recreate on the Forest (USDA Forest Service 2004g). However, while 

some members of the public support limits on commercial use, others are 

concerned about the economic impacts of restrictions and limitations on commercial 

use. 
3 Environment and Effects

Recreation and Tourism 3-386 Final EIS

Environmental Consequences 

This section describes the potential direct, indirect, and cumulative effects of the 

proposed alternatives on recreation and tourism. The section is divided into three 

parts. The first two parts address effects on the supply of recreation opportunities 

and effects on recreation use and demand, respectively. The supply section 

discusses the effects of the alternatives on the existing supply of recreation 

opportunities in terms of the Forest Service’s ROS settings and inventoried 

recreation places on the Tongass. The use and demand section discusses the 

potential effects on resident recreation and tourism. The final section summarizes 

the potential effects by alternative. 

Effects on Supply 

The following section discusses the potential effects of the proposed alternatives on 

ROS settings and recreation places. 

Recreation Opportunity Spectrum 

As discussed in the preceding affected environment section, the ROS system is 

designed to help identify and quantify different types of recreation setting on the 

Tongass National Forest and portrays the appropriate combination of activities, 

settings, and experience expectations along a continuum that ranges from highly 

modified to primitive environments (Table 3.15-2). The Forest-wide mix of ROS 

settings would vary by alternative. Estimated acres by ROS setting and alternative 

are presented in Table 3.15-19. The changes shown in this table are long-term 

changes that are expected to occur 150 years in the future and would take place 

gradually over several decades. ROS settings are projected to change in those 

areas allocated to intensive and moderate development LUDs. As a result, changes 

in settings are related to projected levels of future development. The ROS 

projections provide a general overview of how the recreation settings of the Forest 

would change over time with each alternative. 

Viewed in terms of total Forest-wide acres, Alternatives 1 and 2 would provide the 

greatest amount of primitive and semi-primitive opportunities, with little change 

occurring from the existing condition. Alternative 7 would result in the greatest shift 

from the existing condition to roaded opportunities, followed by Alternatives 4, 5, 6, 

and 3, in that order. These shifts would occur as a result of timber harvest activities. 

The percentage of acres classified as RM would increase over the 150-year period 

under all of the alternatives, including Alternatives 1 and 2. The largest gains would 

occur under Alternatives 4 and 7, with the percent of Forest-wide acres classified as 

RM increasing from approximately 10 percent to approximately 23 percent and 24 

percent, respectively (Table 3.15-19). Under the most intensive timber harvest 

alternative (Alternative 7), approximately 66 percent of the Forest would remain at 

the undeveloped end of the recreation opportunity spectrum (Primitive and SPNM) 

after 150 years, a decrease of 14 percent from the current distribution. 

It may be noted that these projections assume for the purposes of analysis that the 

supply of SPM settings would not increase over time. This is not necessarily the 

case. The ROS system helps identify, quantify, and describe recreation settings 

and essentially represents an inventory of existing recreation areas. Shoreline 

areas or other areas accessible by floatplane or helicopter that are presently 

allocated to Primitive or SPNM settings could be reallocated to the SPM setting in 

the future if patterns of use or other factors change. This type of change would 

result in an increase in the supply of SPM settings. 

Direct and 

Indirect Effects 
 Environment and Effects 3 

Final EIS 3-387 Recreation and Tourism 

Table 3.15-19 

Forest-wide ROS Acres after 150 Years of Implementation, by Alternative

 Primitive SPNM SPM RN RM R+U Total 

 Current 10,358,097 3,046,557 1,486,674 160,594 1,713,018 5,715 16,770,654 

62% 18% 9% 1% 10% 0% 100% 

1 10,246,686 2,957,732 1,424,696 393,438 1,744,877 5,749 16,773,179 

 61% 18% 8% 2% 10% 0% 100% 

2 10,202,344 2,644,438 1,345,098 408,886 2,166,667 5,749 16,773,181 

61% 16% 8% 2% 13% 0% 100% 

3 9,880,140 2,471,124 1,293,060 431,942 2,691,163 5,749 16,773,179 

 59% 15% 8% 3% 16% 0% 100% 

4 9,179,816 2,150,522 1,167,523 494,990 3,774,577 5,749 16,773,177 

55% 13% 7% 3% 23% 0% 100% 

5 9,501,363 2,374,608 1,267,907 449,592 3,173,962 5,749 16,773,181 

 57% 14% 8% 3% 19% 0% 100% 

6 9,553,690 2,401,633 1,266,316 448,995 3,096,797 5,749 16,773,180 

57% 14% 8% 3% 18% 0% 100% 

7 9,133,989 2,074,083 1,138,811 509,657 3,910,889 5,749 16,773,178 

 54% 12% 7% 3% 23% 0% 100% 

Notes: 

SPNM=Semi-Primitive Non-Motorized, SPM=Semi-Primitive Motorized, RN=Roaded Natural, RM=Roaded Modified, 

R+U=Rural and Urban 

1. The total acres shown in this table are slightly lower than the Forest-wide total because the ROS inventory does not 

include the entire Forest. 

2. ROS settings are projected to change in those areas allocated to the Semi-Remote Recreation, Scenic Viewshed, 

Modified Landscape, and Timber Production LUDs. These projected changes are based on the following assumptions: 

♦ Semi-Remote Recreation: 5 percent of Primitive, SPNM, and SPM would be converted to RN over the 150-year 

evaluation period. 

♦ Scenic Viewshed: 25 percent of Primitive, SPNM, and SPM would be converted to RM; 25 percent of Primitive would 

change to SPNM; and 50 percent of Primitive and 75 percent of SPNM and SPM would stay the same over the 150-

year evaluation period. 

♦ Modified Landscape: 50 percent of Primitive, SPNM, and SPM would be converted to RM; 50 percent of Primitive 

would change to SPNM; and 50 percent SPNM and SPM would remain the same 

♦ Timber Production: 80 percent of Primitive, SPNM, and SPM would be converted to RM; 10 percent of Primitive, 

SPNM, and SPM would change to RN; 10 percent of Primitive would become SPNM; and 10 percent of SPNM and 

SPM would remain the same. 

Recreation Places 

This analysis assesses the potential effects of the proposed alternatives on 

recreation places based on projected changes in the LUDs within which these 

places are located. In general, recreation places located in intensive and moderate 

development LUD groups would trend toward RM and RN setting opportunities in 

the future if they are not currently in these settings. Recreation places in the Natural 

Setting and Wilderness groups would likely retain their existing settings. It is 

important to remember that these effects are the result of long-term changes that 

are expected to occur gradually during the next 150 years. 

Home Range Recreation Places 

Home range recreation places are those inventoried recreation places within an 

approximate 20-mile radius from one or more communities. The long-term effects of 

the proposed alternatives on home range recreation places are summarized in 

Table 3.15-20. These effects are presented in terms of the distribution of recreation 

place acres by LUD group. Home range recreation places in development LUDs 

(moderate or intensive) would range from 10 percent of total home range acres 

under Alternative 1 to 44 percent and 40 percent under Alternatives 7 and 4, 

respectively. The percent of home range recreation place acres allocated to 

Wilderness LUDs would be 22 percent under all of the alternatives (Table 3.15-20). 
3 Environment and Effects

Recreation and Tourism 3-388 Final EIS

Table 3.15-20 

Home Range Recreation Places by LUD and Alternative (percent of 

acres)

Alternative Wilderness Natural Setting 

Moderate 

Development 

Intensive 

Development 

1 22 67 5 6 

2 22 58 9 10 

3 22 53 12 13 

4 22 37 19 21 

5 22 48 14 15 

6 22 49 13 15 

7 22 33 21 23 

Important Recreation Places 

Recreation places are identified as either important or ordinary/common based on 

five categories: facilities, marine, hunting, fishing, and tourism. Individual recreation 

places may be important for one, several, or none of these categories. The 

following sections discuss the long-term effects of the proposed alternatives on 

important recreation places by category. 

Facilities. The long-term effects of the proposed alternatives on important 

recreation places with facilities are summarized in Table 3.15-21. These effects are 

presented in terms of the distribution of recreation place acres by LUD group, which 

indicates the relative degree of potential impact that each alternative would have on 

existing recreation places with important facilities. The potential effects of timber 

harvest would likely vary by the type of facility. The importance of a remote public 

recreation cabin may, for example, be greatly enhanced by the solitude and natural 

scenery the area provides. This type of setting may be of only secondary 

importance for a similar cabin where the attraction might be the outstanding 

steelhead fishing in the spring. 

Approximately 29 percent of inventoried recreation places acres are currently 

important for recreation facilities. The overall percentage of these acres that would 

be allocated to development LUDs (moderate or intensive) ranges from 5 percent 

(Alternative 1) to 21 percent (Alternative 7). The percent of recreation place acres 

important for facilities allocated to Wilderness LUDs would be 41 percent under all of 

the alternatives (Table 3.15-21). 

Table 3.15-21 

Recreation Places Important for Facilities by LUD and Alternative 

(percent of acres)

Alternative Wilderness Natural Setting 

Moderate 

Development 

Intensive 

Development 

1 41 55 3 2 

2 41 49 6 4 

3 41 47 8 4 

4 41 40 13 6 

5 41 46 9 5 

6 41 46 9 4 

7 41 38 15 6 

Marine. The long-term effects of the proposed alternatives on recreation places that 

are important for marine recreation are summarized in Table 3.15-22. These effects 

are presented in terms of the distribution of recreation place acres by LUD group. 

The perception of naturalness and scenery are very important values among Forest 

visitors engaged in the unique marine recreation opportunities offered by the 
 Environment and Effects 3 

Final EIS 3-389 Recreation and Tourism 

Tongass. Approximately 30 percent of inventoried recreation places acres are 

currently important for marine recreation activities. Many of these recreation places 

are within the beach fringe and are allocated to the SPM ROS. 

The overall percentage of recreation place acres that are important for marine 

recreation and would be allocated to development LUDs (moderate or intensive) 

ranges from 4 percent under Alternative 1 to 33 percent under Alternative 7. The 

percent of recreation place acres important for marine recreation allocated to 

Wilderness LUDs would be 36 percent under all of the alternatives (Table 3.15-22). 

Table 3.15-22 

Recreation Places Important for Marine Recreation by LUD and 

Alternative (percent of acres)

Alternative Wilderness Natural Setting 

Moderate 

Development 

Intensive 

Development 

1 36 60 3 1 

2 36 54 6 5 

3 36 48 7 9 

4 36 33 15 15 

5 36 43 9 12 

6 36 43 9 12 

7 36 31 17 16 

Hunting. The long-term effects of the proposed alternatives on recreation places 

that are important for hunting are summarized in Table 3.15-23. These effects are 

presented in terms of the distribution of recreation place acres by LUD group. 

Hunters who favor hunting in an undisturbed, natural setting would likely prefer 

those alternatives that have the most acres in the Natural Setting and Wilderness 

LUD groups. Hunters who prefer using roads and road access would generally 

benefit from those alternatives with more acres in the intensive and moderate 

development LUD groups. Approximately 40 percent of inventoried recreation 

places acres are currently important for hunting. 

The overall percentage of recreation place acres that are important for hunting and 

are allocated to development LUDs (moderate or intensive) would range from 5 

percent under Alternative 1 to 41 percent under Alternative 7. The percent of 

recreation place acres important for hunting allocated to Wilderness LUDs would be 

26 percent under all of the alternatives. 

Fishing. The long-term effects of the proposed alternatives on recreation places 

that are important fishing places are summarized in Table 3.15-24. These effects 

are presented in terms of the distribution of recreation place acres by LUD group. 

There would be some variation in the Forest-wide standards and guidelines applied 

across the different alternatives, but all alternatives would maintain fish habitat. The 

Table 3.15-23 

Recreation Places Important for Hunting by LUD and Alternative 

(percent of acres)

Alternative Wilderness Natural Setting 

Moderate 

Development 

Intensive 

Development 

1 26 69 2 3 

2 26 64 4 7 

3 26 57 6 11 

4 26 35 12 27 

5 26 45 10 20 

6 26 49 9 16 

7 26 33 13 27 
3 Environment and Effects

Recreation and Tourism 3-390 Final EIS

quantity of fish available would likely remain constant across alternatives and 

immediate stream-side areas would remain natural along fish-bearing streams. It 

may, however, be noted that the Forest-wide beach and estuary fringe buffers would 

be reduced under Alternative 7. 

Access to streams and areas immediately adjacent to streams may be subject to 

modifications at various levels. This may affect the quality of the fishing experience 

for some. Approximately 13 percent of inventoried recreation places acres are 

currently important for fishing. 

Alternatives with more acres in the intensive and moderate development LUD 

groups would generally provide increased road access to fishing areas. However, 

the setting adjacent to the stream side corridors would appear more modified over 

time. The Natural Setting and Wilderness LUD groups maintain the settings in a 

more natural condition, with access generally more challenging. Access may affect 

the quality of the fishing experience regardless of the degree of setting changes 

leading up to the stream. 

The percentage of recreation place acres that are important for fishing and would be 

allocated to development LUDs (moderate or intensive) ranges from 3 percent under 

Alternative 1 to 41 percent under Alternative 7. The percent of recreation place 

acres important for fishing allocated to Wilderness LUDs would be 31 percent under 

all of the alternatives (Table 3.15-24). 

Table 3.15-24 

Recreation Places Important for Fishing by LUD and Alternative 

(percent of acres)

Alternative Wilderness Natural Setting 

Moderate 

Development 

Intensive 

Development 

1 31 66 2 1 

2 31 58 5 6 

3 31 48 7 14 

4 31 30 13 25 

5 31 43 8 18 

6 31 44 8 17 

7 31 28 15 26 

Effects on Use and Demand 

The following section is divided into two parts that discuss the potential effects of the 

alternatives in terms of resident recreation use and tourism, respectively. 

Resident Recreation 

Forest-wide LUD allocations are presented by alternative in Table 3.15-25. This 

table also highlights the net change in development LUDs from Alternative 5 (No 

Action). Net changes in development LUDs would range from a 16 percent 

decrease under Alternative 1 to a 9 percent increase under Alternative 7. Projected 

changes in ROS settings are shown for 150 years into the future in Table 3.15-19. 

The effects of the LUD allocations on important recreation places are discussed in 

the preceding section. 
 Environment and Effects 3 

Final EIS 3-391 Recreation and Tourism 

Table 3.15-25 

Forest-Wide LUD Allocations and Net Change in Development LUDs by 

Alternative (percent)

 Alternative

Land Use Designation 1 2 3 4 5 6 7 

Wilderness and Natural Monument 35 35 35 35 35 35 35 

Mostly Natural Setting 60 53 48 37 43 44 35 

Moderate Development 2 3 5 9 7 6 10 

Intensive Development 3 8 12 19 15 14 20 

Total 100 100 100 100 100 100 100 

Net Change in Development LUD 

from Alternative 5 (No Action) 

(percent)1

-16 -10 -5 7 0 -1 9 

1

 This is the net change in Development LUDs as a share of total LUDs. 

As noted in the Affected Environment part of this section, resident recreation 

demand, like other forms of recreation demand, is influenced by a number of factors, 

including regional population levels, per capita participation rates, and recreation 

travel behavior. The alternatives evaluated here are unlikely to affect broader trends 

in recreation behavior, but it is possible that they could result in different supplyinduced changes in participation. These potential changes, along with the potential 

effects of the alternatives on recreation places, would likely affect resident 

recreationists. 

Supply-induced changes in participation on the Tongass have, to date, been mainly 

related to changes in road systems and road access. This type of change in 

participation appears to have occurred on Prince of Wales, Wrangell, and Mitkof 

Islands, for example. In these locations, road systems developed for timber 

harvesting created an opportunity for road-related access to previously inaccessible 

recreation settings and, therefore, an opportunity for recreation activities involving 

wheeled vehicles. In addition, new roads that provide easier access to a wider area 

may create new semi-primitive opportunities that increases the capacity of a 

recreation place or creates a new recreation place. 

While there would be some new road access under all alternatives in the long run, 

nearly all new roads constructed under the alternatives would be closed following 

harvest. These roads would, therefore, not be available for use by highway vehicles 

or high-clearance vehicles. They would, however, be available for access by other 

methods and would, as a result, have the potential to affect existing recreation 

patterns. 

Viewed at a programmatic level, changes in participation related to road systems 

and access are more likely to occur under alternatives that involve higher levels of 

projected road construction. Based on the miles of new road construction projected 

under each alternative, Alternative 1 would have the lowest impact on existing 

recreation access patterns with less than half the road miles projected under 

Alternative 5 (No Action) (755 miles versus 3,881 miles). Also, new road 

construction under Alternative 1 would be almost entirely limited to areas outside 

existing Inventoried Roadless Areas (IRAs), and would, therefore, tend to increase 

road density in already roaded areas rather than provide new access to presently 

undeveloped areas. 

Alternatives 2 and 3 would also have relatively low impacts on existing recreation 

access patterns with 1,798 and 1,072 fewer projected new road miles, respectively, 

than under Alternative 5. These alternatives would also limit the construction of new 

roads in IRAs and, therefore, limit potential changes in access, but to a lesser extent 

than under Alternative 1. Alternative 6 (Proposed Action) would have an effect 
3 Environment and Effects

Recreation and Tourism 3-392 Final EIS

similar to Alternative 5, while Alternatives 4 and 7 would involve 854 and 1,893 more 

new road miles, respectively, than Alternative 5, and have the potential to provide 

new access to presently undeveloped areas. 

As the preceding discussion suggests, the general trend across all alternatives is 

toward an increase in motorized opportunities and a corresponding decrease in 

primitive recreation opportunities. Viewed at this level, Alternative 1 would have the 

lowest impact on primitive areas and associated opportunities because timber 

management would be limited to areas outside the existing IRAs on the Tongass. 

Alternatives 2 and 3 would have the next lowest potential impacts in that order, with 

timber management under Alternative 2 limited to areas outside the existing IRAs 

except in locations where existing roads could logically be extended. Alternative 3 

would keep the 23 areas proposed for wilderness in House Resolution (HR) 987 and 

the 18 special interest areas in the 1999 Record of Decision (ROD) in a natural 

condition. Alternatives 5 and 6 would be more likely to involve timber harvest in 

IRAs, and this likelihood would be increased further under Alternatives 4 and 7. 

Alternatives 4 and 7 have an increased emphasis on timber production with 

respective long-term annual Allowable Sales Quantities (ASQs) of 342 million board 

feet (MMBF) and 421 MMBF compared to 267 MMBF under Alternative 5 and 49 

MMBF under Alternative 1. 

Given the programmatic nature of this planning document, it is not possible to 

predict site-specific changes that would occur under any of the alternatives. 

Potential impacts to recreation places and recreation activities in other areas would 

be evaluated on a project-by-project basis and in accordance with the applicable 

Forest Plan standards and guidelines under all alternatives. The Forest-wide 

standards and guidelines and LUD prescriptions of the current Forest Plan would 

continue to be implemented as part of Alternative 5, where they apply. An updated 

and edited version of the current Forest Plan (Volume II), which includes edits to the 

existing Recreation and Tourism Standards and Guidelines, would apply under all of 

the action alternatives, with some exceptions for Alternatives 4 and 7. 

These edits include changes to OHV management and wilderness group sizes and 

use. Under the updated Forest Plan, OHV planning would be in accordance with 36 

CFR 212, 251, and 261—Travel Management; Designated Routes and Areas for 

Motor Vehicle Use. Under the existing Forest Plan, open roads on the Forest are 

designated open to OHVs unless site-specific closures are made. Although not 

specified in the current Forest Plan, the new travel management rule is presently 

being implemented on the Tongass. Travel management would, as a result, be the 

same under all alternatives. 

Recreation activities in Wilderness would be managed to meet appropriate levels of 

social encounters. This would include limiting group sizes to no more than 12 

persons for commercial and general public use of a wilderness, limiting the length of 

stay at one location to 14 days, and limiting commercial recreation use to two 

groups of 12 people from a single vessel (or other form of transportation), with the 

groups required to disperse out of sight and sound from each other. Exceptions 

may be approved by the District Ranger or Monument Ranger in response to 

unusual circumstances. The updated Forest Plan authorizes one exception—the 

Stikine River valley—where larger group size would be allowed for general public 

use. Outfitted groups would still be required to comply with the 12 person limit. 

The Forest will change over time under all of the alternatives, including Alternative 5, 

and recreation demand and use patterns are also likely to change. Recreationists 

may respond to changes to specific areas and locations in three general ways. 

Many will likely adapt to new situations, and changes in settings will have little or no 

impact to these current Forest users. For others, change may not be acceptable, 

and these users will be displaced to other areas where the setting and use patterns 

are more in line with their expectations and needs. A third group of current 
 Environment and Effects 3 

Final EIS 3-393 Recreation and Tourism 

recreationists may find that they cannot adapt to the new situation nor find suitable 

substitute areas, and as a result, substitute other leisure activities in place of 

recreating on the Forest. 

Tourism 

The tourism industry and number of visitors to Southeast Alaska has increased 

dramatically since the early 1990s, with much of this growth linked to increased 

cruise ship travel to the region. Cruise ships bring the most visitors to Southeast 

Alaska, accounting for approximately 63 percent of visitors in 2001 (McDowell et al. 

2007). Future development of the tourism industry in Southeast Alaska and 

elsewhere in the United States is dependent on a wide range of factors, including 

the value of the dollar in foreign countries, the price of oil, world events and 

international unrest, and political and social change. In addition, regions like 

Southeast Alaska directly compete with other locations and activities for tourist 

dollars. As a result, changes in other tourist markets, both positive and negative, 

have the potential to affect the tourism industry in Southeast Alaska. These factors 

are, for the most part, unrelated to management of the Tongass National Forest. 

Other potential factors affecting tourism development in the region include the 

reactions of local communities and residents to increased tourism development. 

Cruise ship visitation is concentrated in a few locations in the region with the large 

ships usually calling at five key ports: Juneau, Ketchikan, Skagway, Sitka, and 

Haines. This concentration results in an uneven distribution of tourism-related 

benefits throughout the region, as well as a concentration of tourism-related 

concerns in particular communities (Schroeder et al. 2005). There is some 

evidence that there may be limits to the amount of unconstrained tourism 

development that Southeast Alaska communities are willing to tolerate. Local 

initiatives aimed at managing tourism include an advisory measure to limit the 

number of cruise ship dockings in Haines, which was approved by voters in 2000, 

as well as initiatives in Juneau and Haines proposed in response to helicopter and 

floatplane traffic over residential areas. Another example of local reaction was 

provided by Sitka voters who rejected a measure in 2000 to expand the public dock 

in Sitka to accommodate cruise ships (Schroeder et al. 2005). In addition, Alaska 

voters recently approved the Alaska Cruise Ship Ballot Initiative that established a 

statewide tax of $50 per passenger on cruise ship passengers visiting Alaska. 

While it is reasonable to assume that the vast majority of tourism activity in the 

region is related to the natural environment, many visitors experience the Tongass 

passively—from the deck of a cruise ship, for example—without directly using the 

Forest for recreation purposes. The alternatives would have very little effect on this 

type of visitor because the scenic quality of heavily traveled cruise ship corridors 

and tourism industry use areas would be largely protected under all of the 

alternatives. The Scenery Standards and Guidelines provide special emphasis for 

scenic quality in LUDs allowing timber harvest in visual priority travel routes and use 

areas. This is discussed further in the Scenery section of this chapter. 

However, cruise ships have heavily marketed Forest-related activities in recent 

years, and many passengers take at least one trip to the Forest during their visit, 

with icefield helicopter tours and visits to the Mendenhall Glacier by cruise ship 

passengers increasing substantially (Table 3.15-15). As discussed in the affected 

environment portion of this section, the tourism industry and outfitter/guides in 

Southeast Alaska offer a wide spectrum of recreation activities, ranging from guided 

bear hunting through helicopter tours and guided wildlife-viewing boat tours. Viewed 

in terms of Forest management, the requirements of these activities are often at 

odds with one another. Some activities require developed facilities, utilities, and 

easy access, while others require vast and remote areas in a natural setting, with 

outfitter/guides providing only the basic essentials for their clients. 
3 Environment and Effects

Recreation and Tourism 3-394 Final EIS

The following discussion addresses the potential effects of the alternatives on 

recreation places important for tourism and future recreation and tourism 

developments. 

Recreation Places Important for Tourism 

The effects of the proposed alternatives on recreation places that are important for 

tourism are summarized in Table 3.15-26. These effects are presented in terms of 

the distribution of recreation place acres by LUD group. Approximately 53 percent 

of inventoried recreation places acres are currently considered important for 

tourism. All of the proposed alternatives provide a mix of opportunities, with some 

alternatives emphasizing natural settings and others allowing more timber harvest 

and road building. These changes may be viewed as opportunities or detriments to 

various sectors of the tourism industry and their clients. Based on numerous 

surveys and marketing campaigns for visitors, it is widely accepted that natural 

beauty and scenery are some of the principal factors attracting visitors to the region. 

However, the State of Alaska and part of the tourism industry expressed a desire 

during the planning process for the current Forest Plan for increased access and 

opportunities for development, as they believed that some existing areas are at or 

near capacity (USDA Forest Service 1997a, p. 3-136). 

There are indications that demand exceeds supply in some recreation places, 

especially those used more extensively by tourist operators and outfitter/guides. 

Activities that are presently near or at capacity include bear-viewing areas and 

helicopter use in the immediate vicinity of urban areas. Other areas may be able to 

accommodate current levels of tourism and potential increases in the future without 

negatively affecting the tourist experience or causing detrimental environmental 

effects. The number of visitors cruising the Inside Passage or viewing Mendenhall 

Glacier may, for example, be sustainable at current and future levels of use 

(Schroeder et al. 2005). 

Table 3.15-26 

Recreation Places Important for Tourism by LUD and 

Alternative (percent of acres)

Alternative Wilderness Natural Setting 

Moderate 

Development 

Intensive 

Development 

1 46 51 2 1 

2 46 47 4 3 

3 46 43 5 6 

4 46 34 10 10 

5 46 40 7 7 

6 46 40 6 7 

7 46 33 11 10 

The overall percentage of recreation place acres that are important for tourism and 

would be allocated to development LUDs (moderate or intensive) ranges from 2 

percent under Alternative 1 to 21 percent under Alternative 7. The percent of 

recreation place acres important for tourism allocated to Wilderness LUDs would be 

46 percent under all of the alternatives (Table 3.15-26). 

Given the programmatic nature of this planning document, it is not possible to 

predict site-specific changes that would occur under any of the alternatives. 

Management practices for specific areas, such as limiting the number of visitors by 

permit, would continue to be evaluated on a project-by-project basis and in 

accordance with the applicable Forest Plan standards and guidelines under all 

alternatives. The Forest-wide standards and guidelines and LUD prescriptions of 

the current Forest Plan would continue to be implemented as part of Alternative 5, 

where they apply. An updated and edited version of the current Forest Plan, which 

includes edits to the existing Recreation and Tourism Standards and Guidelines, 
 Environment and Effects 3 

Final EIS 3-395 Recreation and Tourism 

would apply under all of the action alternatives, with some exceptions under 

Alternatives 4 and 7. These edits are discussed further in the preceding section that 

address effects to resident recreation. 

Assuming that the volume of tourists remains at its current level or continues to 

increase as it has done over the last decade, the overall recreation trend would 

likely be toward more group experiences on the Tongass and less opportunities for 

solitude and isolation in natural areas close to cruise ship stops (Schroeder et al. 

2005). 

Developments 

Increased tourism has led to the development of new tourism facilities in Southeast 

Alaska, including the Icy Point Strait development near Hoonah. The rapid growth 

and large volume of cruise ship passengers and the growth in shore excursions 

suggest that there will be demand for new developed facilities on the Tongass in the 

future. This section identifies the share of the Forest that would be available for 

recreation and tourism developments under each alternative. 

The recreation and tourism Forest-wide standards and guidelines in the current 

Forest Plan address commercial development of facilities and opportunities by LUD. 

Developments are classified as either major or minor. These standards and 

guidelines remain substantially unchanged in the Proposed Forest Plan 

accompanying this EIS. Abbreviated definitions of these terms are provided below. 

Major Development. Major recreation and tourism developments 

provided by the private sector involve a long-term commitment of the land 

base, with a moderate to high level of site modification. They involve 

large buildings or complexes of buildings and facilities, and often provide 

several services in a concentrated area. Comfort and convenience are 

provided for guests, and facilities can generally accommodate more than 

12 people. Subsequent site reclamation involves extensive removal of 

facilities; improvements, revegetation, recontouring, etc.; and a period of 

at least 5 years to attain a natural appearance. 

Examples of this type of development include destination resorts and 

lodges, food and beverage services, downhill ski areas, marinas and gas 

stations, and full-service campgrounds. 

Minor Development. Minor recreation and tourism developments 

provided by the private sector involve only minor site modifications. They 

involve small rustic facilities and/or improvements, generally with a single 

purpose or service, and may involve several sites or an extensive area. 

Basic essentials are typically provided and can generally accommodate 

12 or fewer people per site. Site reclamation involves simple removal of 

facilities and little or no revegetation; a natural appearance can be 

attained in a few years. 

Examples of this type of development include cabins, huts, small docks, 

cross-country ski trails with simple facilities, temporary or portable camps, 

and simple rustic campgrounds. 

The major and minor recreation development standards and guidelines by LUD are 

summarized in Table 3.15-27. The percent of Tongass acres available for major or 

minor tourism development is presented by alternative in Table 3.15-28. 

Both major and minor developments are prohibited in Wilderness, National 

Monument Wilderness, and Research Natural Areas, which together account for 

approximately 35 percent of the Forest under all alternatives. Major developments 

are also prohibited in Wild River LUDs, which account for about 1 percent of the 

Forest. Major developments are discouraged in the Municipal Watershed, Remote 
3 Environment and Effects

Recreation and Tourism 3-396 Final EIS

Recreation, and Experimental Forest LUDs and LUD II areas (Table 3.15-27). 

These LUDs account for 17 to 19 percent of all of the alternatives (Table 3.15-28). 

Minor developments are discouraged in the Municipal Watershed and Experimental 

Forest LUDs, which, combined, account for less than 1 percent of the Forest (Table 

3.15-28). 

The share of the Forest that would be compatible with major or minor recreation 

developments ranges from 20 percent under Alternatives 4, 5, and 7 to 31 percent 

under Alternative 1. The Semi-Remote Recreation LUD accounts for most of the 

compatible lands and ranges from 15 percent of the Forest under Alternatives 4 and 

7 to 32 percent under Alternative 1 (Table 3.15-28). Developments in other parts of 

the Forest would be evaluated on a case-by-case basis. The share of the Forest 

where major developments would be evaluated on a case-by-case basis ranges 

from 13 percent under Alternative 1 to 27 percent under Alternatives 4 through 7. 

Table 3.15-27 

Major and Minor Recreation Developments by LUD

 Major Minor 

Not Allowed Wilderness Wilderness 

Wilderness National Monument Wilderness National Monument 

Research Natural Area Research Natural Area 

Wild River 

Discouraged Nonwilderness National Monument Municipal Watershed 

Remote Recreation Experimental Forest 

Municipal Watershed 

LUD II 

Experimental Forest 

Case-by-Case Special Interest Area Nonwilderness National Monument 

Old-growth Habitat Remote Recreation 

Scenic River Special Interest Area 

Modified Landscape Old-growth Habitat 

Timber production Wild River 

Minerals Modified Landscape 

Transportation and Utility Systems Timber production 

 Minerals 

 Transportation and Utility System 

 LUD II 

Compatible Semi-Remote Recreation Semi-Remote Recreation 

Recreational River Recreational River 

Scenic Viewshed Scenic Viewshed 

Scenic River 

Notes:

Not Allowed: Recreation special-use developments are not allowed by law or regulation or are not 

consistent with agency policy and regulations. 

Discouraged: Recreation special-use developments are generally not consistent with the objectives of 

the LUD. Development proposals require scrutiny of magnitude and scope for LUD conformance. 

Case-by-Case: Recreation special-use developments may be compatible with the LUD objectives 

depending upon the scope, purpose, and magnitude of the proposal. Proposals will be evaluated on 

a case-by-case basis. 

Compatible: Recreation special-use developments are generally compatible with this LUD, and 

applicants are encouraged to examine these areas first where there is a public need and no private 

lands are available or suitable for development. 

Source: USDA Forest Service 1997a (Table 3-51).
 Environment and Effects 3 

Final EIS 3-397 Recreation and Tourism 

Table 3.15-28 

Percent of Tongass Acres Available for Tourism Developments 

 Alternative 

 1 2 3 4 5 6 7 

Major Developments 

Not Allowed 36 36 36 36 36 36 36

Discouraged 19 19 18 17 17 17 17

Case-by-case 13 19 23 27 27 27 27

Compatible 32 27 23 19 20 21 20

Minor Developments 

Not Allowed 35 35 35 35 35 35 35

Discouraged 0 0 0 0 0 0 0

Case-by-case 32 37 41 44 44 43 44

Compatible 32 27 23 20 20 21 20

Note: See the notes to Table 3.15-27 for an explanation of Not Allowed, Discouraged, Case-by-Case, and 

Compatible. 

Development of tourism opportunities is a cooperative effort. Investments in the 

development of tourism facilities, such as destination resorts, are typically the 

responsibility of the private sector. Federal, state, and local agencies may also play 

a role in facilitating the development of these types of opportunities. The LUDs and 

standards and guidelines that would apply under each alternative provide a 

framework within which these types of developments may take place. They also 

provide direction for the Forest Service to respond to and address the needs of the 

recreation and tourism industry. 

Juneau Icefield Land Use Designation 

The LUD classification for the area north of Juneau that encompasses the Juneau 

Icefield would be changed from Remote Recreation to Semi-Remote Recreation 

under all of the action alternatives. The areas would remain classified as Remote 

Recreation under Alternative 5, No-Action Alternative. This change has been 

proposed because the snow accumulation zone on the icefield has retreated to 

higher elevations as a result of climate change, which has resulted in a number of 

minor development sites (e.g., dog sled camps) becoming unsuitable for use as the 

thinning snow layers expose crevasses during the middle of the operating season. 

The proposed change in LUD boundaries would allow the Forest Service to consider 

moving minor developments into areas with snow, where these types of 

development would not be allowed under the existing LUD. This proposed change 

would not affect the Forest Service’s ability to allow an expansion of helicopter 

landing sites in the area, because glacier landing tours are allowed under both the 

existing (Remote Recreation) and proposed (Semi-Remote Recreation) LUDs for 

this area. 

The following section discusses the potential impacts by alternative. 

Alternative 1. This alternative would keep all remaining IRAs in a natural condition. 

This alternative would preserve the largest amount of Primitive and Semi-Primitive 

recreation opportunities both Forest-wide and within community home ranges. 

Alternative 1 would also maintain existing recreation places located within IRAs in 

their current natural condition. Potential changes in access resulting from new road 

construction would be almost entirely limited to areas outside the existing IRAs. 

This alternative would most closely maintain current outdoor recreation setting 

conditions Forest-wide and support the maintenance of existing use patterns and 

opportunities. 

There would be a relatively small shift toward the Roaded end of the ROS under this 

alternative, with approximately 78 percent of the Forest expected to be either 

Primitive or SPNM after more than 100 years, compared to approximately 80 

Effects by 

Alternative 
3 Environment and Effects

Recreation and Tourism 3-398 Final EIS

percent at present. There would be an increase in the share of important recreation 

places in Natural Setting LUDs relative to Alternative 5. 

Alternative 2. This alternative would keep most IRAs in a natural condition and 

emphasize a wide range of recreation and tourism opportunities in a natural setting. 

This alternative would preserve the second largest amount of Primitive and SemiPrimitive recreation opportunities after Alternative 1 both Forest-wide and within 

community home ranges. Potential changes in access resulting from new road 

construction would take place on lands outside of IRAs except for some areas 

where roads could be logically extended. This alternative would largely maintain 

current outdoor recreation setting conditions Forest-wide and support the 

maintenance of existing use patterns and opportunities. 

The shift toward the Roaded end of the ROS would be larger under this alternative 

than under Alternative 1, but still relatively small, with approximately 77 percent of 

the Forest expected to be either Primitive or SPNM after 150 years, compared to 

approximately 80 percent at present. There would be an increase in the share of 

important recreation places in Natural Setting LUDs relative to Alternative 5. 

Alternative 3. This alternative provides a mix of National Forest uses and activities 

similar to Alternative 2, with additional emphasis on timber management. This 

alternative would keep the 23 areas proposed for Wilderness in HR 987 and the 18 

Areas of Special Interest in the 1999 ROD in a natural condition. 

There would be smaller amounts of Primitive and Semi-Primitive recreation 

opportunities preserved under this alternative than under Alternatives 1 and 2, but 

still a relatively large amount, both Forest-wide and within community home ranges. 

Potential changes in access resulting from new road construction would take place 

in lands outside of the 23 areas proposed for Wilderness in HR 987 and the 18 

Areas of Special Interest in the 1999 ROD. 

Approximately 73 percent of the Forest would be either Primitive or SPNM after 150 

years, compared to approximately 80 percent at present. There would be an 

increase in the share of important recreation places in the Natural Settings relative 

to Alternative 5 for all categories except facilities, where the share of important 

recreation places in Natural Setting LUDs would remain essentially the same as 

under Alternative 5. 

Alternatives 4 and 7. Alternative 4 would provide for a mix of National Forest uses, 

with an emphasis on timber production. Timber management would occur in some 

IRAs not managed for timber production in the current Forest Plan. This would also 

be the case under Alternative 7, which would place additional emphasis on timber. 

Timber would be managed on a considerably expanded land base compared with 

the current Forest Plan (Alternative 5) and on a larger land base than under 

Alternative 4. 

These alternatives would place a relative emphasis on the roaded end of the ROS 

spectrum, with 23 percent of the Forest expected to be RM after 150 years, 

compared to approximately 10 percent at present. This would be matched with a 

corresponding decrease in Primitive and SPNM settings, which combined would 

comprise about 67 percent of the Forest after 150 years under both alternatives 

compared to 80 percent at present. 

These alternatives would involve the largest amount of new road construction, with 

approximately 4,735 miles and 5,774 miles projected under Alternatives 4 and 7, 

respectively, compared to about 3,881 miles under Alternative 5. While there would 

be a relative increase in new roads, with access provided to presently undeveloped 

areas, nearly all new roads would be closed following harvest and would, as a 

result, not be available for use by highway or high-clearance vehicles. The closed 
 Environment and Effects 3 

Final EIS 3-399 Recreation and Tourism 

roads would, however, be available for access by other methods and would, as a 

result, have the potential to affect existing recreation patterns. 

The share of home range recreation places within Wilderness and Natural Setting 

LUD groups would decrease from 79 percent under the current Forest Plan 

(Alternative 5) to 59 percent and 55 percent under Alternatives 4 and 7, respectively. 

There would be a decrease in the share of important recreation places in Natural 

Setting LUDs relative to Alternative 5. 

Alternatives 5 and 6. Alternative 5 (No Action) is the current Forest Plan (1997 

ROD, as amended) and provides for a moderately high level of timber production 

along with strong resource protection measures. Alternative 6 (Proposed Action) is 

similar to Alternative 5, but includes adjustments to the plan based on information 

generated during the recent 5-Year Plan Review and other minor clarifications and 

updates. 

These alternatives would provide a mixture of Primitive and Roaded recreation 

opportunities relative to the other alternatives, which range from maintaining almost 

all IRAs in a natural condition (Alternative 1) to intensive timber management 

(Alternatives 4 and 7). Approximately 71 percent of the Forest would be either 

Primitive or SPNM under Alternatives 5 and 6 after 150 years, compared to 

approximately 80 percent at present. Approximately 19 percent of the Forest would 

be RM compared to 10 percent at present and 11 percent under Alternative 1 after 

150 years. 

There would be more new roads constructed under these alternatives than under 

Alternatives 1 through 3 and fewer than under Alternatives 4 and 7. The share of 

home range recreation places within Wilderness and Natural Setting LUD groups 

would be lower under these alternatives than under Alternatives 1 through 3 and 

higher than under Alternatives 4 and 7. This would also be the case with the share 

of important recreation place acres within Wilderness and Natural Setting LUDs. 

This section considers the incremental effects of the alternatives when added to 

other past, present, and reasonably foreseeable actions. The effects of past and 

present actions on recreation are included in the Affected Environment portion of 

this section, which discusses current recreation facilities and activities on the 

Tongass. Past actions include past timber harvest and road building that has 

facilitated roaded recreation and changed ROS settings, as well as the development 

of recreation facilities, such as cabins, campgrounds, interpretive sites, and visitor 

centers. Present actions include the impacts of current management policies on 

existing recreation patterns, particularly those that are authorized by special use 

permits. 

One of the major trends in recreation in Southeast Alaska has been the continued 

growth in the number of cruise ship passengers visiting the region. The effects of 

the alternatives are considered in conjunction with this trend because it underpins 

current and future recreation demand on the Tongass. Current recreation patterns 

on the Tongass also reflect past timber harvest and road building activities on 

adjacent private and Native corporation lands, as well as wildland recreation 

opportunities on federal- and state-managed lands elsewhere in the region. 

Reasonably foreseeable actions on NFS lands include the projected levels of future 

timber harvest and road building that are used in the preceding analysis to assess 

the potential impacts of the alternatives on the supply of recreation opportunities and 

recreation use and demand. 

Other reasonably foreseeable actions include transportation and utility 

developments proposed by the State of Alaska. These proposals are summarized 

in the Transportation and Utilities section of this document. A total of 1,523 miles of 

roads are projected to be constructed on non-NFS lands in Southeast Alaska after 

Cumulative 

Effects 
3 Environment and Effects

Recreation and Tourism 3-400 Final EIS

full implementation of the plan (100+ years) under each of the alternatives (see 

Table 3.12-3). Most of the projected non-NFS roads are forest roads that would be 

developed for timber harvest, but the total miles also include roads likely to be built 

to serve communities, such as the Juneau access road on the east side of Lynn 

Canal. This road, and other road corridors covered by Public Law 109-59, would, if 

approved under NEPA and funded, connect additional areas in Southeast Alaska to 

the continental highway system and improve transportation between communities. 

They would also improve access for recreation use and would in some cases likely 

facilitate new types of use. 

It is not possible at this time to predict exactly which roads would be developed or 

their likely impact on future recreation patterns. None of the alternatives is expected 

to affect this type of future road development, which would be expected to go or not 

go forward regardless of the selected alternative. The overall cumulative effect of 

new regional road corridors viewed in conjunction with the proposed Forest Plan 

alternatives would be a trend toward the roaded end of the ROS spectrum that 

would be relatively high under Alternative 7 and relatively low under Alternative 1. 

Planned timber harvest activities on adjacent private and Native corporation lands 

would also result in a cumulative trend toward more land in roaded ROS settings. 

This would also be most pronounced under Alternative 7 and least pronounced 

under Alternative 1. 

Other reasonably foreseeable future actions include an expected growth in 

recreation and tourism businesses based on continued growth in the cruise ship 

industry, as well as the development of additional fishing and other lodges. This 

type of development would facilitate additional recreation and tourism in the region 

and on the Forest. Human settlement expansion is expected to occur around the 

region’s larger cities, such as Juneau and Sitka, with residential expansion also 

expected as a result of state land auctions. These developments would likely result 

in increased demand for a range of recreation activities, with some developments 

favoring developed recreation opportunities, and others more dependent on 

undeveloped lands. 

Mining activities are expected to expand at existing sites, including Greens Creek on 

Admiralty Island and Berner’s Bay north of Juneau, with an increase in mining 

exploration and new development also anticipated. Regional energy and 

transmission projects are also expected to occur, including the Swan-Tyee 

transmission line and the Juneau-Hoonah transmission line. Mining and regional 

energy projects are for the most part expected to have a negative effect on 

recreation activities, because most recreational activities are incompatible with these 

types of land use. Improvements in reliable electrical service could, however, 

benefit some recreation businesses and, by extension, recreationists. 

As stated in a number of locations in this section, recreation and tourism in 

Southeast Alaska and on the Tongass is influenced by a number of factors that are 

largely independent of forest management decisions. Factors affecting the current 

level of visitation to the region, for example, likely include the impact of events at the 

World Trade Center on September 11, 2001, and the relatively weak U.S. dollar, 

both of which favor domestic over international travel and may have prompted some 

to take a trip to Southeast Alaska, rather than a trip abroad. Future recreation and 

tourism demand is difficult to predict with any precision and no attempt is made to 

quantify future demand in this section. The number of cruise ship visitors to the 

region is generally expected to remain at current levels or continue to increase, but 

there is uncertainty that this will be the case for the foreseeable future. 

Likely impacts to the supply of recreation opportunities on the Forest are easier to 

project, as they are directly affected by management decisions, at least to the extent 

that different LUD classifications influence potential ROS classes and, therefore, 

Risk and 

Uncertainty 
 Environment and Effects 3 

Final EIS 3-401 Recreation and Tourism 

different types of recreation. Much of the analysis in this section is based on this 

relationship, which allows a comparison between alternatives over time. 

Changes in Southeast Alaska’s climate (discussed in the Climate and Air section) 

could affect recreation and tourism in the region in the future. Many tourists visiting 

the region travel long distances from across the United States, as well as from other 

countries. Many tourists arriving by cruise ships travel a considerable distance by 

air before even boarding the cruise ship in Seattle, Vancouver, or elsewhere. 

Others travel directly to Southeast Alaska via air. Future regulatory or market-based 

pressures to reduce transportation-related greenhouse gases could affect the level 

of visitation to the region. 

Recreation activities could also be directly affected by global warming, with, for 

example, fewer winter recreation opportunities available and for shorter periods of 

time. Climate change could also affect recreational fishing through changes in 

biodiversity and water levels, as well as changes in the length of season and user 

experience (Kelly et al. 2007). 
3 Environment and Effects

Recreation and Tourism 3-402 Final EIS

This page is intentionally left blank. 
 Environment and Effects 3 

Final EIS 3-403 Scenery 

Scenery 

Affected Environment ...............................................................................3-403 

Existing Scenic Integrity ........................................................................3-404 

Environmental Consequences .................................................................3-406 

Direct, Indirect, and Cumulative Forest-wide Effects............................3-406 

Effects on Selected Viewsheds.............................................................3-410 

Affected Environment 

The Tongass National Forest offers a variety of scenery to its visitors, from 

spectacular mountain ranges and the glaciers of the mainland to low-lying marine 

landscapes composed of intricate waterways, bays, and island groups. The Forest 

is viewed from a variety of vantage points, including the communities of Southeast 

Alaska, the Alaska Marine Highway ferry route, cruise ship routes, existing road 

systems, popular small boat routes and anchorages, developed recreation sites and 

facilities, and hiking trails. Tourist-related flight seeing via small aircraft is increasing 

in popularity and provides aerial views of the forest landscape. 

The Forest Service developed a Visual Management System (VMS) in 1974 to 

integrate aesthetic considerations into large-scale resource management decisions. 

VMS included objective criteria, such as viewing distance and the degree of visual 

change to the landscape for estimating the effects of management activities. 

However, VMS used somewhat subjective definitions of what constituted an 

aesthetic landscape and relied on professional judgment to quantify effects. The 

Scenic Management System (SMS) was released in 1996 to integrate the increased 

understanding of ecosystem processes and cultural landscapes in identifying the 

effects of various management practices on scenic resources. The SMS was used 

in this analysis to inventory existing scenic resources, provide measurable scenic 

quality management objectives for each portion of the landscape, and estimate the 

landscape’s sensitivity based on the visibility from priority travelways and use areas. 

In order to apply SMS to the Forest, a viewshed analysis of the entire Tongass 

National Forest was completed using GIS. The analysis was completed separately 

for each Ranger District. Step one involved identifying the Visual Priority Routes 

(VPRs) and use areas. These are the major points from which people view the 

forest. They include the Alaska Marine Highway; cruise ship and small boat routes; 

major roads, trails, and anchorages; and important recreation areas on the land. 

The viewshed analysis identified points at regular intervals along the VPRs and use 

areas. Each viewpoint along a route was assigned a viewing height from which a 

person would observe the forest. For example, the average height of a person was 

selected for the viewing height along a hiking trail, and the height of the cruise ship's 

deck was used for the cruise ship route. Each cell in the digital elevation model was 

evaluated for visibility from each of the points along each VPR and use area. 

Visibility was assessed separately for each marine viewpoint and land viewpoint. 

The second phase of the analysis identified distance zones, breaking the visible 

areas into foreground, middleground, and background from each viewpoint, based 

on distance. Foreground is the visible area within 0.5 mile of a VPR; background is 

the visible area greater than 5 miles and less than 15 miles from a VPR; and 

middleground is the visible area between foreground and background of a VPR. 

Areas more than 15 miles from any viewpoint and those not seen from any of the 

VPRs or Use Areas were considered seldom seen. Distance zones were also 
3 Environment and Effects

Scenery 3-404 Final EIS

assessed separately for land and water viewpoints. The final layers for each 

Ranger District were generated by combining the results from the marine analysis 

and the land analysis. Any point that was visible from either a land or marine 

viewpoint was considered visible in the final layer. Any area that was foreground 

from either a land or marine viewpoint was considered foreground, and any land that 

was background from either a land or marine viewpoint became background. All 

other visible land became middleground. The distance zones were subsequently 

overlaid with the LUDs to generate the Scenic Integrity Objectives (SIOs) (refer to 

the Forest-wide standards and guidelines in the Tongass Land and Resource 

Management Plan for details on how SIOs were determined for each LUD). 

The existing scenic resources of the Tongass encompass everything from vast 

tracts unmodified by human activity to extensive areas of heavily modified 

landscapes. Existing Scenic Integrity (ESI) ratings are used by the Forest Service to 

analyze the degree of intactness of the landscape character. These ratings are 

used to categorize the degree of alteration visible in the landscape on a continuum 

from a natural setting to a heavily altered landscape. The ratings apply to the broad 

landscape affected, not just the acres altered. As described below, ESI ratings 

range over six levels of integrity, from Very High to Unacceptably Low. 

♦ Very High—Landscapes where the valued landscape character is intact with 

only minute deviations, if any. The existing landscape character and sense of 

place is expressed at the highest possible level. 

♦ High—Landscapes where the valued landscape character appears intact. 

Deviations may be present, but must repeat the form, line, color, texture, and 

pattern common to the landscape character so completely and at such scale 

that they are not evident. 

♦ Moderate—Landscapes where the valued landscape character appears slightly 

altered. Noticeable deviations must remain visually subordinate to the 

landscape character being viewed. 

♦ Low—Landscapes where the valued landscape character appears moderately 

altered. Deviations begin to dominate the valued landscape character being 

viewed, but they borrow valued attributes such as size, shape, edge effect and 

pattern of natural openings, vegetative type changes or architectural styles 

outside the landscape being viewed. They should not only appear as valued 

character outside the landscape being viewed, but compatible or complimentary 

to the character within. 

♦ Very Low—Landscapes where the valued landscape character appears heavily 

altered. Deviations may strongly dominate the valued landscape character. 

They may not borrow from valued attributes such as size, shape, edge effect 

and pattern of natural openings, vegetative type changes, or architectural styles 

within or outside the landscape being viewed. 

♦ Unacceptably Low—Landscapes where the valued landscape character being 

viewed appears extremely altered. Deviations are extremely dominant and 

borrow little if any form, line, color, texture, pattern or scale from the landscape 

character. 

Table 3.16-1 displays the acres of each ESI for the Tongass. In this and succeeding 

tables, a breakdown between “seen” and “seldom seen” areas is presented. Seen 

areas are those areas that can be viewed in the foreground, middleground, or 

background from inventoried VPR and Use Areas with a concern level of 1 or 2, the 

travelways and use areas with the highest number of users. Seldom seen areas are 

all the rest of the Forest. The ESI for wilderness is also included in this table. 

Approximately 88 percent of the Tongass is rated as a Very High ESI, which is a 

Existing Scenic 

Integrity 
 Environment and Effects 3 

Final EIS 3-405 Scenery 

visually unaltered condition. About 10 percent of the land is rated in as Low, Very 

Low, or Unacceptably Low, which indicates noticeable development activity. The 

remainder of the Forest is rated as High or Moderate. Some of the wilderness acres 

have a High or lower rating. This is mostly due to the landscape effect of 

developments adjacent to wilderness and past development activities 

within wildernesses. 

Table 3.16-1 

The Existing Scenic Integrity of the Tongass National Forest 

(percent)

ESI Rating 

Very 

High/High Moderate Low 

Very 

Low 

Unacceptably Low 

Seen 23.6 1.2 1.6 3.4 0.1 

Seldom seen 30.5 0.2 1.4 3.4 0.1 

Wilderness 30.2 0.1 0.1 - - 

Subtotals 88.3 1.5 3.1 6.8 0.2 

Note: Numbers are GIS estimates and are not exact. Columns and rows may not sum exactly due to 

rounding. Less than 2 percent of the Forest is unclassified.

Under the 1997 Forest Plan, all land has a designated Land Use Designation (LUD), 

which guides the types and intensity of development actions. The LUDs designate 

the SIOs for each area, which define the degree to which the natural landscape can 

be altered, and provide guidelines for timber harvest, road building, and other 

activities to ensure they are conducted in a way that allows the scenic objectives to 

be achieved. A LUD may have different SIOs depending on the distance zone 

(foreground, middleground, background) in which the development activity is to take 

place. SIOs are classified using the same terms outlined above for ESI: Very High, 

High, Moderate, Low, and Very Low. The Unacceptably Low rating is only used to 

inventory existing conditions and cannot be used as a management objective. 

1. The current adopted SIOs for all land within the Tongass are displayed in 

Table 3.16-2. This table separates the acres of each SIO into five categories: 

foreground, middleground, background, seldom seen, and other (municipal 

watersheds and non-wilderness national monuments where the SIO is 

determined on a project-by-project basis). The Very High SIO is typically 

assigned to wilderness; however, it is not used for Tongass wilderness because 

of the potential alterations allowed under the Alaska National Interest Lands 

Conservation Act (ANILCA). In reality, the vast majority of wilderness acreage 

will be managed through the specific wilderness plans with a Very High SIO. 

Thus, over 60 percent of the Tongass is to be managed at the High or Very High 

Scenic Integrity level. 

2. Demand for scenic quality can best be represented by the increase in 

tourist-related travel to the Tongass, as well as a heightened awareness and 

sensitivity of Alaskan residents to scenic resource values. Southeast Alaska’s 

Inside Passage is advertised and promoted by the Division of Tourism, cruise 

ship operators, and the Southeast Alaska Tourism Council. Their marketing 

strategy focuses on the scenery of the Tongass National Forest as a major 

attraction. The visitors to Southeast Alaska would, therefore, arrive with 

expectations and an image of the environment and scenery awaiting them. If 

current trends continue, demand for viewing scenic landscapes will increase. 

Studies published by the Alaska Department of Community and Economic 

Development show a 62 percent increase in visitor 
3 Environment and Effects

Scenery 3-406 Final EIS

Table 3.16-2 

Adopted Scenic Integrity Objectives for the Tongass (percent)

Visual Quality Objective 

High Moderate Low Very Low Other1

Foreground 8.0 3.7 1.6 - 0.2 

Middleground 24.2 9.3 2.2 8.0 0.3 

Background 1.6 0.6 - 0.4 - 

Seldom seen 25.9 6.3 - 5.7 0.7 

Unmapped 1.1 0.3 - - - 

Total 59.7 19.9 3.8 14.1 1.2 1 Includes land in the Municipal Watershed and Nonwilderness National Monument LUDs. SIOs in 

these LUDs are to be determined on a project-by-project basis. Generally, the High SIO will be 

met. 

Source: USDA Forest Service, GIS. Numbers are not exact and may not sum correctly due to 

rounding.

arrivals to Alaska since 1993. Lands adjacent to the Alaska Marine Highway, cruise 

ship routes, flight-seeing routes, high-use recreation areas, and other marine and 

land-based travel routes will be seen by more people, more frequently, and for 

greater duration. 

Environmental Consequences 

The Tongass has adopted specific management objectives for scenic resources 

(SIOs) for each LUD in the Forest. The adopted SIOs indicate the desired or 

acceptable level of human-induced alteration to the valued landscape character. 

Each alternative described in this FEIS would, if implemented, maintain, alter, or 

enhance the visual character of the landscape to varying degrees, depending on the 

mix of LUDs in that alternative. By varying the amount of land in each LUD, the 

alternatives would result in different amounts of land managed under each SIO. The 

adopted SIO is, therefore, the unit used to measure potential change in visual 

resources for each alternative. 

Adopted SIOs can be thought of as an indicator of long-term cumulative effects, 

especially on development LUDs. SIOs are adopted to provide a threshold for the 

amount of modification to the landscape during land altering activities; therefore, 

land may have an adopted SIO of Low, but currently meet the High SIO. 

The potential effects to the scenic resource are described in the following three 

ways: 

1. A Forest-wide display of acres of each SIO adopted as a result of each 

alternative. 

2. A display of the number of acres within the three development LUDs that 

would be suitable for timber harvest under each alternative. The acres 

suitable for harvest are listed by their location within the foreground, 

middleground, background, or seldom seen area. 

3. A display of the effects of each alternative on a selected group of 

viewsheds throughout the Tongass. 

Table 3.16-3 displays the acres in each SIO that would result from the seven 

alternatives. Table 3.16-3 also shows the acres under each alternative and SIO that 

would be located within seen and seldom seen areas. Seen areas are those areas 

Direct, Indirect, 

and Cumulative 

Forest-wide 

Effects 
 Environment and Effects 3 

Final EIS 3-407 Scenery 

Table 3.16-3 

Scenery Integrity Objectives (percent) 

Scenery Integrity Objectives 

High Moderate Low Very Low Other1

 Total 

Alternative 1 

Seen Areas 34% 22% 1% 2% 1% 60 

Seldom Seen Areas 27% 10% 0% 1% 1% 39 

Unmapped Areas2

 1% 0% 0% 0% 0% 1 

Total 62% 32% 1% 3% 2% 100 

 

Alternative 2 

Seen Areas 35% 18% 2% 5% 1% 60 

Seldom Seen Areas 27% 9% 0% 3% 1% 39 

Unmapped Areas2 1% 0% 0% 0% 0% 1 

Total 62% 27% 2% 7% 1% 100 

 

Alternative 3 

Seen Areas 35% 15% 3% 7% 1% 60 

Seldom Seen Areas 26% 8% 0% 4% 1% 39 

Unmapped Areas2

 1% 0% 0% 0% 0% 1 

Total 61% 23% 3% 11% 2% 100 

 

Alternative 4 

Seen Areas 31% 13% 5% 11% 1% 60 

Seldom Seen Areas 24% 6% 0% 7% 1% 39 

Unmapped Areas2 1% 0% 0% 0% 0% 1 

Total 56% 19% 5% 18% 2% 100 

 

Alternative 5 

Seen Areas 34% 13% 4% 8% 1% 60 

Seldom Seen Areas 26% 6% 0% 6% 1% 39 

Unmapped Areas2

 1% 0% 0% 0% 0% 1 

Total 61% 19% 4% 14% 2% 100 

 

Alternative 6 

Seen Areas 34% 13% 4% 8% 1% 60 

Seldom Seen Areas 25% 7% 0% 5% 1% 39 

Unmapped Areas2 1% 0% 0% 0% 0% 1 

Total 60% 20% 4% 13% 2% 100 

Alternative 7 

Seen Areas 29% 13% 5% 12% 1% 60 

Seldom Seen Areas 24% 6% 0% 8% 1% 39 

Unmapped Areas2 1% 0% 0% 0% 0% 1 

Total 54% 19% 5% 20% 2% 100 1

 Consists of land in the municipal Watershed and Nonwilderness National Monument LUDs. SIOs in these LUDs are to be 

determined on a project-by-project basis. Generally, the High SIO will be met. 2

 Consists of unmapped portions of the Forest.

Note: Numbers are based on GIS estimates and are not exact due to rounding.
3 Environment and Effects

Scenery 3-408 Final EIS 

that can be viewed in the foreground, middleground, or background from inventoried 

travelways and use areas. Wilderness areas are included in these acreages. The 

acres displayed for Alternative 5 (No Action) represent the current mix of adopted 

SIOs. 

The number of acres designated as High SIO would be similar under all alternatives 

except Alternatives 4 and 7, which have fewer acres in the High SIO category (56 

and 54 acres, respectively, compared to 61 percent under Alternative 5). However, 

the area with an SIO of Low or Very Low would vary considerably between 

alternatives, especially within the seen areas. The acres of Low or Very Low SIO in 

the seen area under Alternative 1 would be approximately 3 percent of the Tongass, 

compared to 12 percent under Alternative 5. Conversely, the seen area with an SIO 

of Low or Very Low under Alternatives 4 and 7 would be approximately 16 and 17 

percent, respectively. Alternatives 2 and 3 would be between Alternatives 1 and 5 in 

terms of the amount of seen area with an SIO of Low or Very Low. Alternative 6 

would result in a mix of SIOs that would be similar to Alternative 5. 

Another way to assess the relative effects of the alternatives on scenic integrity is to 

compare the area under each alternative that would be suitable for timber harvest. 

The percent of land that is suitable for timber harvest within the three development 

LUDs (Scenic Viewshed, Modified Landscape, and Timber Production) under each 

alternative is shown in Table 3.16-4. The table indicates the amount of land suitable 

for timber harvest within the foreground, middleground, and background as seen 

from high priority travel routes and use areas. The percent of suitable land within 

seldom seen areas is also shown. 

Under all the alternatives, approximately two-thirds of the suitable lands for timber 

harvest are within the Timber Production LUD. The number of suitable acres 

allocated to this LUD varies from approximately 312,000 acres under Alternative 1 to 

approximately 1,174,000 under Alternative 7. This compares to approximately 

781,000 under Alternative 5 (No Action). Although all harvest units would meet the 

SIO for the individual distance zone and LUD, the degree of change to the visual 

resources are likely to be the greatest in the Timber Production LUD. Approximately 

one-half of the suitable acres allocated to Timber Production would be in seen 

areas. 

Alternative 1. Under Alternative 1, approximately 62 percent of the Forest would 

have an adopted SIO of High and would be managed for a Natural Setting (Table 

3.16-3). This is similar to Alternative 5 (No Action), which would have 61 percent 

with an SIO of High. Areas with a High SIO are managed so that the valued 

landscape character appears intact. As is the case with all the alternatives, over 

one-half of the land with the High SIO would be within Wilderness or National 

Monument LUDs. Approximately 32 percent of the Forest under Alternative 1 would 

have a Moderate SIO. Landscapes with this SIO are managed to achieve a mostly 

natural condition. This alternative has the highest acreage designated as High and 

Moderate SIO. Most of the remaining Forest lands (6 percent) would have an 

adopted SIO of Low or Very Low (compared to approximately 18 percent under 

Alternative 5). Areas with these SIOs are managed so that the valued landscape 

character would appear moderately or heavily altered. 

This alternative has the least amount of land suitable for timber harvest compared to 

the other alternatives. Alternative 1 would have less than one-half the suitable acres 

as Alternative 5 (No Action). Approximately 7 percent of the suitable acres would be 

designated Scenic Viewshed, 22 percent Modified Landscape, and 71 percent 

Timber Production LUD (the LUD projected to have the greatest degree of change) 

(Table 3.16-4). Alternative 1 would result in the least amount of new road 

construction (approximately 1,766 miles) over the next 10 decades. 
 Environment and Effects 3 

Final EIS 3-409 Scenery 

Table 3.16-4 

Distance Zone breakdown of the Estimated Suitable Forest Land for 

Each Alternative by Development LUD

Alternatives 

1 2 3 4 5 6 7 

Scenic Viewshed 

Foreground 2% 4% 4% 5% 4% 3% 5%

Middleground 5% 7% 8% 11% 10% 9% 11%

Background 0% 0% 0% 0% 0% 0% 0%

Seldom Seen Area 0% 0% 0% 1% 1% 1% 1%

Unmapped 0% 0% 0% 0% 0% 0% 0%

Subtotal 7% 12% 13% 17% 14% 14% 18%

Modified Landscape 

Foreground 9% 7% 6% 4% 5% 5% 5%

Middleground 11% 10% 11% 10% 11% 11% 11%

Background 0% 0% 0% 0% 0% 0% 0%

Seldom Seen Area 2% 2% 2% 2% 2% 2% 2%

Unmapped 0% 0% 0% 0% 0% 0% 0%

Subtotal 22% 18% 18% 16% 18% 18% 18%

Timber Production 

Foreground 15% 12% 11% 9% 9% 9% 9%

Middleground 41% 42% 40% 40% 40% 40% 39%

Background 1% 2% 2% 1% 2% 2% 1%

Seldom Seen Area 14% 15% 16% 16% 17% 17% 15%

Unmapped 0% 0% 0% 0% 0% 0% 0%

Subtotal 71% 70% 69% 68% 68% 68% 65%

Total 100% 100% 100% 100% 100% 100% 100%

Estimated Suitable 

(thousands of acres)

312 545 661 999 781 774 1,174

Note: Numbers are based on GIS estimates and are not exact. Columns do not sum correctly due to 

rounding. 

Alternative 2. The overall distribution of adopted SIOs would be similar to those 

under Alternative 1 (Table 3.16-3), except that there would be fewer acres in the 

Moderate SIO (27 percent compared to 32 percent under Alternative 1 and 19 

percent under Alternative 5) and more in the Low and Very Low SIOs (9 percent 

compared to 4 percent for Alternative 1). This alternative has approximately onethird more suitable land than Alternative 1. Alternative 2 has slightly more acres of 

suitable lands for timber harvest in the Scenic Viewshed LUD than Alternative 1, and 

more of these lands are in the foreground, which is the area likely to have the least 

change in the visual condition (Table 3.16-4). Alternative 2 would result in 

approximately 2,600 miles of new road construction over the next 10 decades. 

Alternative 3. Alternative 3 would have more acres in the development LUDs than 

Alternatives 1 and 2, but there would be only a slight decrease in the amount of land 

in the High SIO (61 percent versus 62 percent under Alternatives 1 and 2). This is 

due primarily to allocating more land to the Scenic Viewshed LUD, in which the 

foreground lands are managed as High SIO (Table 3.16-3). There would be less 

land in the Moderate SIO than Alternatives 1 and 2, but more than under 
3 Environment and Effects

Scenery 3-410 Final EIS 

Alternatives 4, 5, 6, or 7. More land would have Low and Very Low SIOs compared 

to Alternatives 1 and 2 (slightly over 14 percent compared to 4 and 9 percent, 

respectively). Alternative 3 would have more suitable land for timber harvest than 

Alternatives 1 or 2 (Table 3.16-4). Alternative 3 would result in approximately 3,464 

miles of new roads over the next 10 decades. 

Alternative 4. Alternative 4 would have more acres in development LUDs than 

Alternative 5 and less land in the High SIO (nearly 56 percent compared to 62 

percent under Alternative 1 and 61 percent under Alternative 5). Alternative 4 would 

have more land in Low and Very Low SIOs (23 percent compared to 4 percent 

under Alternative 1 and 18 percent under Alternative 5). Alternative 4 would have 

more suitable land for timber harvest than Alternative 5 and more acres in the 

Timber Production LUD. Alternative 4 would result in approximately 5,487 miles of 

new road construction over the next 10 decades. 

Alternative 5. Alternative 5, the No-Action Alternative, would have approximately 

61 percent of the land in the High SIO, which is similar to Alternatives 1, 2, 3, and 6 

(Table 3.16.3). This alternative would have a relatively low percentage of land 

suitable for harvest in the foreground (18 percent), compared to 25 percent under 

Alternative 1. A relatively high percent of the suitable lands (20 percent) would be 

within the seldom seen areas. Alternative 5 would result in approximately 4,351 

miles of new roads over the next 10 decades. 

Alternative 6. Alternative 6, the Proposed Action, is very similar to Alternative 5 in 

terms of its effect on the visual resource. The mix of SIOs would be nearly the same 

under Alternative 6 as it would be under Alternative 5. Alternative 6, along with 

Alternative 5, would have a relatively high percentage of land in the seldom seen 

areas. Alternative 6 would result in approximately 4,285 miles of new roads over the 

next 10 decades, which is slightly less than under Alternative 5. 

Alternative 7. Alternative 7 would have the most acres in development LUDs of all 

the alternatives and the least land in the High SIO (nearly 54 percent compared to 

62 percent under Alternative 1 and 61 percent under Alternative 5). Alternative 7 

would have the most land in Low and Very Low SIOs (nearly 25 percent compared 

to 4 percent under Alternatives 1 and 18 percent under Alternative 5). Alternative 7 

would have more suitable land for timber harvest than Alternative 5 (over 3 times as 

much as Alternative 1 and approximately 50 percent more than Alternative 5) and 

more acres in the Timber Production LUD. Alternative 7 would result in the highest 

amount of new road construction (approximately 6,264 miles) over the next 10 

decades.

Effects on Selected Viewsheds 

To help focus the visual effects on more familiar areas, the alternatives were also 

analyzed by selected viewsheds in the Tongass. These viewsheds were selected 

for their popularity and intensity of public use and travel. Table 3.16-5 compares the 

amount of land in each SIO under the six alternatives for each of the viewsheds 

from these selected routes. Discussion of the effects on scenic resources for each 

viewshed follows the table. 

Two points to consider when reviewing the alternative effects are: 

1. Where an area is allocated to the Semi-remote Recreation LUD, the 

formally adopted SIO is Moderate; however, the resulting SIO is essentially 

High because this LUD precludes commercial timber harvest. The 

Moderate SIO is primarily intended to provide a standard for recreation and 

tourism types of development and facilities associated with these 

developments, from small 
 Environment and Effects 3 

Final EIS 3-411 Scenery 

Table 3.16-5 

Estimated Percentage of Selected Viewsheds Classified by Adopted SIOs 

under Each Alternative 1,2,3

Alternative Scenic 

Integrity 

Objective 1 2 3 4 5 6 7 

Behm Canal (West) 

High 16% 19% 19% 6% 19% 21% 6% 

Moderate 48% 21% 21% 19% 20% 19% 19% 

Low 24% 36% 36% 46% 36% 36% 46% 

Very Low 12% 24% 24% 29% 25% 24% 29% 

Caroll Inlet 

High 14% 14% 14% 0% 12% 14% 0% 

Moderate 50% 19% 19% 19% 20% 19% 19% 

Low 15% 22% 22% 26% 22% 22% 26% 

Very Low 21% 46% 46% 55% 46% 46% 55% 

Chatham Strait 

High 58% 59% 58% 47% 56% 59% 39% 

Moderate 31% 17% 8% 10% 9% 8% 11% 

Low 4% 5% 5% 7% 6% 5% 9% 

Very Low 7% 20% 29% 36% 30% 29% 41% 

Cholmondeley Sound 

High 39% 39% 39% 4% 35% 39% 4% 

Moderate 59% 6% 5% 7% 5% 5% 7% 

Low 1% 19% 19% 26% 20% 19% 26% 

Very Low 1% 36% 37% 63% 40% 37% 64% 

Clarence Strait 

High 44% 45% 46% 34% 45% 46% 22% 

Moderate 40% 27% 20% 20% 21% 20% 25% 

Low 6% 9% 13% 14% 13% 13% 20% 

Very Low 9% 19% 21% 32% 21% 21% 33% 

Duncan Canal 

High 21% 21% 21% 9% 18% 21% 1% 

Moderate 64% 52% 52% 18% 18% 18% 20% 

Low 5% 6% 6% 16% 12% 12% 19% 

Very Low 11% 22% 22% 58% 52% 49% 59% 

Eastern Passage 

High 15% 18% 19% 11% 19% 19% 9% 

Moderate 78% 66% 51% 59% 51% 51% 61% 

Low 5% 6% 13% 12% 13% 13% 12% 

Very Low 2% 10% 17% 18% 17% 17% 18% 

Ernest Sound

High 29% 29% 29% 23% 30% 29% 2% 

Moderate 71% 71% 38% 12% 11% 11% 13% 

Low 0% 0% 15% 18% 20% 18% 23% 

Very Low 0% 0% 18% 47% 39% 42% 63% 

Frederick Sound

High 21% 23% 25% 14% 23% 25% 6% 

Moderate 67% 52% 34% 23% 25% 28% 23% 

Low 2% 5% 8% 12% 10% 10% 12% 

Very Low 10% 21% 33% 52% 42% 37% 59% 
3 Environment and Effects

Scenery 3-412 Final EIS 

Table 3.16-5 (continued) 

Estimated Percentage of Selected Viewsheds Classified by Adopted 

VQOs under Each Alternative 1, 2, 3

Alternative Scenic 

Integrity 

Objective 1 2 3 4 5 6 7 

Hyder/Salmon River Highway

High 0% 10% 10% 18% 11% 11% 18% 

Moderate 100% 85% 85% 57% 83% 83% 57% 

Low 0% 0% 0% 0% 0% 0% 0% 

Very Low 0% 5% 5% 25% 6% 6% 25% 

Icy Strait

High 47% 49% 49% 27% 48% 49% 26% 

Moderate 46% 22% 22% 26% 22% 22% 26% 

Low 5% 7% 7% 8% 7% 7% 8% 

Very Low 2% 22% 22% 39% 23% 22% 40% 

Lynn Canal 

High 32% 33% 33% 32% 34% 34% 32% 

Moderate 67% 65% 58% 57% 57% 57% 57% 

Low 0% 0% 7% 9% 7% 7% 8% 

Very Low 0% 1% 2% 3% 2% 2% 3% 

Mendenhall Glacier 

High 34% 34% 34% 34% 55% 34% 34% 

Moderate 66% 66% 66% 66% 45% 66% 66% 

Low 0% 0% 0% 0% 0% 0% 0% 

Very Low 0% 0% 0% 0% 0% 0% 0% 

Peril Strait 

High 41% 42% 42% 16% 35% 37% 12% 

Moderate 59% 34% 30% 11% 19% 18% 15% 

Low 0% 3% 3% 8% 4% 3% 8% 

Very Low 0% 22% 25% 64% 43% 41% 65% 

Salmon Bay Lake 

High 38% 39% 38% 41% 39% 39% 4% 

Moderate 41% 37% 37% 19% 20% 20% 39% 

Low 15% 15% 15% 28% 29% 29% 32% 

Very Low 6% 10% 10% 12% 12% 12% 25% 

Stephens Passage 

High 38% 38% 38% 31% 38% 40% 31% 

Moderate 62% 62% 59% 44% 38% 40% 44% 

Low 0% 0% 0% 2% 1% 1% 2% 

Very Low 0% 0% 3% 23% 23% 20% 23% 

Stikine Strait 

High 28% 35% 38% 13% 36% 38% 13% 

Moderate 58% 32% 29% 45% 30% 29% 45% 

Low 3% 7% 7% 9% 7% 7% 9% 

Very Low 11% 26% 27% 33% 27% 27% 33% 

Sumner Strait

High 31% 31% 31% 23% 30% 31% 21% 

Moderate 52% 47% 30% 10% 20% 20% 10% 

Low 5% 6% 8% 14% 11% 11% 14% 

Very Low 12% 16% 31% 54% 40% 39% 55% 
 Environment and Effects 3 

Final EIS 3-413 Scenery 

Table 3.3.6-5 (continued) 

Estimated Percentage of Selected Viewsheds Classified by Adopted VQOs 

under Each Alternative 1, 2, 3

Alternative Scenic 

Integrity 

Objective 1 2 3 4 5 6 7 

Sweetwater Lake/Honker Divide

High 69% 69% 69% 50% 63% 63% 21% 

Moderate 16% 16% 14% 18% 16% 16% 30% 

Low 9% 9% 11% 18% 14% 14% 31% 

Very Low 5% 5% 6% 14% 7% 7% 18% 

Tenakee Inlet to Tenakee Springs

High 82% 82% 76% 21% 33% 40% 18% 

Moderate 13% 5% 1% 2% 1% 18% 3% 

Low 0% 1% 2% 7% 4% 3% 8% 

Very Low 4% 11% 22% 69% 62% 39% 72% 

West Coast Waterway/Prince of Wales

High 38% 38% 38% 27% 32% 35% 17% 

Moderate 39% 24% 20% 11% 19% 19% 11% 

Low 6% 9% 9% 15% 13% 11% 16% 

Very Low 17% 29% 33% 48% 36% 35% 56% 

Wrangell Narrows

High 31% 33% 37% 30% 38% 36% 20% 

Moderate 60% 48% 41% 45% 40% 41% 53% 

Low 9% 16% 18% 21% 18% 18% 22% 

Very Low 1% 3% 4% 4% 4% 4% 5% 

Zimova Strait

High 39% 40% 42% 22% 42% 42% 20% 

Moderate 42% 29% 19% 33% 19% 19% 36% 

Low 10% 10% 15% 21% 15% 15% 21% 

Very Low 9% 21% 24% 23% 23% 24% 24% 1

 VQO terms are defined in the Affected Environment portion of this section. 2 The percentages in the table are based on the approximate acres seen from a Visual Priority Travel Route 

and Use Area. The numbers are not exact and columns may not add correctly due to rounding. 3

 Other includes private lands, municipal watersheds, and National Monuments.

cabins to resorts. In most cases, the effects would be confined to small 

sites that would be inconspicuous over a landscape. Therefore, much of the 

area identified as Moderate would be managed as High. 

2. The Tongass adopts the High SIO for wildernesses rather than Very High 

because of the direction in ANILCA; however, the Very High SIO is likely to 

be achieved in most areas within wilderness. 

Behm Canal (West) 

Alternatives 4 and 7 would each adopt an SIO of High for approximately 6 percent of 

the viewshed and an SIO of Low or Very Low for 75 percent of the viewshed (Table 

3.16-5). This compares to Alternative 1 which would manage 16 percent with an 

SIO of High and 36 percent of the viewshed with an SIO of Low or Very Low. 

Therefore, Alternatives 4 and 7 would have the greatest effect on scenery in the 

Behm Canal Viewshed, while Alternative 1 would have the least. Effects on scenery 

under Alternatives 2, 3, 5, and 6 would be intermediate, with 19 to 21 percent 

managed with an SIO of High and 60 to 61 percent Low or Very Low. In some 

areas, particularly on the Revella Island side of the Canal, existing harvest has 

reached or exceeded the level allowed by the adopted SIOs. Additional harvest 

may need to be reduced or deferred in these areas in the coming decade. 
3 Environment and Effects

Scenery 3-414 Final EIS 

Carroll Inlet 

Alternatives 4 and 7 would manage approximately 81 percent of the viewshed with 

an SIO of Low or Very Low and almost none of it with a High (Table 3.16-5). This 

compares to Alternative 1 which would manage 14 percent in High and 36 percent in 

Low or Very Low. Alternatives 2, 3, 5, and 6 have similar distribution of LUDs and 

thus would result in similar SIO designations, with approximately 12 to 14 percent of 

the land with an SIO of High and 68 percent with an SIO of Low or Very Low. 

Therefore, Alternatives 4 and 7 would likely result in the highest level of change in 

visual condition of the alternatives and Alternative 1 would have the least. Effects 

on scenery under Alternatives 2, 3, 5, and 6 would be intermediate. 

Chatham Strait 

Under all of the alternatives except Alternatives 4 and 7, 56 to 59 percent of the 

Chatham Strait Viewshed would be managed as High SIO (Table 3.16-5). Under 

Alternatives 4, approximately 47 percent of the viewshed would have an SIO of High 

and under Alternative 7, 39 percent. Under Alternative 1, 11 percent of the viewshed 

would be managed with an SIO of Low or Very Low. This compares with 25 percent 

under Alternative 2, between 35 and 43 percent for Alternatives 3, 4, 5, and 6, and 

50 percent for Alternative 7. Therefore, Alternative 7, followed by Alternative 4, 

would result in the greatest level of change. In some areas, particularly between 

Peril Strait and Tenakee Inlet, where existing harvest has reached or exceeded the 

level allowed by the adopted SIOs. Additional harvest may need to be reduced or 

deferred in these areas in the coming decade. 

Cholmondeley Sound 

Approximately 90 percent of the viewshed would have an SIO of Low or Very Low 

under Alternatives 4 and 7, compared to 2 percent under Alternative 1 (Table 3.16-

5). Alternatives 2, 3, 5, and 6 would result in 55 to 60 percent in Low or Very Low 

SIOs. Between 35 and 39 percent of the viewshed would have a High SIO under all 

alternatives except Alternatives 4 and 7, which would manage 4 percent under a 

High SIO. Alternatives 4 and 7 would have a much greater effect on scenery than 

the other alternatives. Alternative 1 would have a much lower level of effects than 

Alternatives 4 and 7. Effects on scenery under Alternatives 2, 3, 5, and 6 would be 

intermediate. Under all of the alternatives, most of the outer part of the bay would 

be in an extensively altered condition due to harvest on private lands. 

Clarence Strait 

Clarence Strait is a large viewshed, extending along both sides of the strait from its 

northern end south to Gravinia Island. The viewshed includes portions of the South 

Etolin Wilderness Area, which would have an SIO of High under all alternatives. 

While the wilderness has a designated SIO of High, a Very High SIO would likely be 

achieved. All alternatives except Alternatives 4 and 7 would adopt an SIO of High 

for 44 to 46 percent of the viewshed (Table 3.16-5). Alternative 4 would adopt an 

SIO of High for 34 percent of the viewshed, while Alternative 7 would adopt an SIO 

of High for 22 percent. Alternatives 3, 5, and 6 would result in approximately 34 

percent Low or Very Low SIO, compared to 15 percent under Alternative 1 and 28 

percent under Alternative 2. Approximately 46 percent of the viewshed would be 

Low or Very Low under Alternative 4 and 53 percent would be Low or Very Low 

under Alternative 7. Therefore, Alternative 7 would result in the highest level of 

change to the viewshed, while Alternative 1 would result in the least. Effects on 

scenery under Alternatives 2, 3, 5, and 6 would be midway between the two, with 

slightly lower effects under Alternative 2 than under Alternatives 3, 5, and 6. Effects 

Under Alternative 4 would be similar, but somewhat lower, than under Alternative 7. 
 Environment and Effects 3 

Final EIS 3-415 Scenery 

Duncan Canal

All of the alternatives except Alternatives 4 and 7 would adopt an SIO of High for 

approximately between 18 and 21 percent of the viewshed (Table 3.16-5), due 

primarily to the Old-Growth LUD located along both sides of the southern end of 

Duncan Canal. Alternatives 4 and 7 would have 9 and 1 percent High, respectively. 

Alternatives 5 and 6 would designate 61 to 64 percent as Low or Very Low SIO. 

Alternatives 2 and 3 would adopt an SIO of Low or Very Low for 28 percent of the 

viewshed. Alternatives 4 and 7 would have 74 and 78 percent Low or Very Low, 

respectively, and thus would have the greatest effect on scenery in the viewshed. 

Alternative 1 would have the least, closely followed by Alternatives 2 and 3. 

Alternatives 5 and 6 would result in a greater level of change than Alternatives 1, 2 

or 3, but a lower level than Alternatives 4 or 7. 

Eastern Passage 

All alternatives except Alternatives 4 and 7 would adopt an SIO of High for 15 to 19 

percent of the viewshed, versus 11 percent under Alternative 4 and 9 percent under 

Alternative 7 (Table 3.16-5). Alternatives 1 and 2 would adopt an SIO of Low or 

Very Low for 7 and 16 percent of the viewshed, respectively, compared to 30 

percent under Alternatives 3, 4, 5, 6, and 7 (Table 3.16-5). Therefore, Alternatives 1 

and 2 would likely result in less change to the visual condition of the viewshed 

compared to the other alternatives. Alternatives 4 and 7 would likely have a 

somewhat greater effect on scenery than Alternatives 3, 5, and 6. 

Ernest Sound

Under all of the alternatives except Alternatives 4 and 7, 29 or 30 percent of the 

viewshed would be managed as High SIO (Table 3.16-5), due to the Old-Growth 

LUD located on the northwestern shore of Cleveland Peninsula. Approximately 23 

and 2 percent would have a High SIO under Alternatives 4 and 7, respectively. 

There would be no Low or Very Low SIOs under Alternatives 1 and 2, compared to 

33 percent under Alternative 3, and 59 or 60 percent under Alternatives 5 and 6. 

Alternatives 4 and 7 would designate 65 and 86 percent as Low or Very Low, 

respectively. Therefore, Alternatives 1 and 2 would likely result in less change to 

the visual condition of the viewshed compared to the other alternatives. Alternative 

7 would likely have the greatest effect on scenery, and Alternative 4 would likely 

have the second largest effect after Alternative 7. 

Frederick Sound 

All of the alternatives except Alternatives 4 and 7 would adopt an SIO of High for 

approximately 21 to 25 percent of the Frederick Sound Viewshed (Table 3.16-5). 

Most of the High SIO occurs within a large area of Old-Growth LUD on the northeast 

shore of Kupreanof Island, as well as several smaller Old-Growth LUDs along the 

eastern shore of Kupreanof and Mitkof islands. Under Alternatives 4 and 7, 

approximately 14 and 6 percent would have an SIO of High, respectively. 

Alternative 4 would adopt an SIO of Low or Very Low for 64 percent of the 

viewshed, compared to 52 to 47 percent for Alternatives 5 and 6, respectively, 41 

percent for Alternative 3, 26 percent for Alternative 2, and 71 percent for Alternative 

7. Alternative 1 would adopt an SIO of Low or Very Low for 12 percent of the 

viewshed, approximately one-sixth the Low and Very Low under Alternative 7 (Table 

3.16-5). Alternative 1 would have the least effect on scenery in the viewshed, and 

Alternatives 4 and, especially, 7 would have the greatest effect on scenery in the 

viewshed. The other alternatives would be intermediate. 

Hyder/Salmon River 

All alternatives would all have a moderate effect on scenery in the Hyder/Salmon 

River viewshed (Table 3.16-5). Alternatives 4 and 7 would likely have a somewhat 

greater effect on scenery in the viewshed than the other alternatives because they 
3 Environment and Effects

Scenery 3-416 Final EIS 

would adopt a Low or Very Low SIO for 25 percent of the viewshed, compared to 0 

to 6 percent under Alternatives 1, 2, 3, 5, and 6. 

Icy Strait 

All of the alternatives except for Alternatives 4 and 7 would adopt an SIO of High for 

between 47 and 49 percent of the viewshed (Table 3.16-5), due partly to the 

Wilderness LUDs on Pleasant and Lemesurier Islands and the LUD II and OldGrowth LUD at Point Adolphus. Wilderness areas would have an SIO of High under 

all alternatives, but would likely achieve an SIO of Very High. The amount of the 

viewshed with an SIO of High would drop to 27 to 26 percent under Alternatives 4 

and 7, respectively. Alternatives 2, 3, 5, and 6 would all adopt an SIO of Low or 

Very Low for 29 to 30 percent of the viewshed, compared to 7 percent for Alternative 

1 and 47 to 48 percent for Alternatives 4 and 7. Alternatives 4 and 7 would have the 

greatest effect on scenery in the viewshed, while Alternative 1 would have the least. 

There would be little difference between the other alternatives, which would have 

effects midway between Alternative 1 and Alternatives 4 and 7. Under all of the 

alternatives, much of the south shore of the strait would be in an altered condition 

due to harvest on private lands. 

Lynn Canal 

Scenic effects within the Lynn Canal Viewshed would be very similar under all of the 

alternatives (Table 3.16-5). All alternatives would adopt an SIO of High for 

approximately one-third of the viewshed, due primarily to the large Remote 

Recreation LUD on the east side of Lynn Canal. All of the alternatives would have 

relatively low percentages of land with an SIO of Low or Very Low, with less than 2 

percent for Alternatives 1 and 2 and 9 percent for Alternatives 3, 5, and 6. 

Alternatives 4 and 7 would have 11 to 12 percent of land with a Low or Very Low 

SIO (Table 3.16-5). Therefore, while all alternatives would have a moderate effect 

on scenery in the viewshed, Alternatives 1 and 2 would result in a somewhat lesser 

change to the scenery that the other alternatives. 

Mendenhall Glacier 

The effects of all of the alternatives on the Mendenhall Glacier Viewshed are similar 

for all alternatives except Alternative 5 (Table 3.16-5). Over half the viewshed would 

have an SIO of High, while the remainder would be Moderate under Alternative 5 

(No Action). In contrast, all of the action alternatives would adopt an SIO of High for 

34 percent of the viewshed and a Moderate for 66 percent (Table 3.16-5). All the 

alternatives have a large Remote Recreation LUD located north of Taku Inlet, with 

most of the remaining viewshed designated as Semi-Remote Recreation. Under 

Alternative 5, the Remote Recreation LUD is larger, extending further to the west, 

resulting in 55 percent of the viewshed managed as High SIO, compared to 34 

percent for the other alternatives. As noted above, Semi-Remote Recreation LUDs 

generally achieve an SIO of High, making Alternative 5 almost identical to the other 

alternatives in terms of effects on scenery. 

Peril Strait/Neva-Olga Strait/Sitka 

Approximately 35 and 42 percent of the viewshed would be have an SIO of High 

under all alternatives except Alternatives 4 and 7, which would adopt an SIO of High 

for 16 and 12 percent of the viewshed, respectively (Table 3.16-5). Approximately 

three-fourths of the viewshed would have an SIO of Low or Very Low under 

Alternatives 4 and 7, compared to 0 percent for Alternative 1, 25 percent for 

Alternative 2, 28 percent for Alternative 3, 47 percent for Alternative 5, and 44 

percent under Alternative 6. Therefore, the effects on scenery would be lowest 

under Alternative 1, followed by Alternatives 2 and 3, and then Alternatives 5 and 6. 

The level of change would be greatest under Alternatives 4 and 7. Existing harvest 

in a few areas (particularly the Sitkoh Bay/False Island areas) may have reached or 
 Environment and Effects 3 

Final EIS 3-417 Scenery 

exceeded the level allowed by the adopted SIOs. Site-specific analysis may 

indicate that even-aged harvest may need to be reduced or deferred in these areas 

for the next decade. 

Salmon Bay Lake

Between 38 and 41 percent of the viewshed would have an SIO of High under all 

alternatives except Alternative 7, which would adopt an SIO of High for 4 percent of 

the viewshed (Table 3.16-5). Alternatives 1, 2, and 3 would adopt an SIO of Low or 

Very Low for 21 to 25 percent of the viewshed, Alternatives 4, 5, and 6 would adopt 

an SIO of Low or Very Low for 40 to 41 percent of the viewshed, and Alternative 7 

would adopt an SIO of Low or Very Low for 57 percent, and would have the greatest 

effect on scenery in the viewshed. 

Stephens Passage 

All of the alternatives except Alternatives 4 and 7 would adopt an SIO of High for 38 

to 40 percent of the viewshed (Table 3.16-5), due in part to the Wilderness/National 

Monument LUDs, which include portions of the Admiralty Island National Monument 

and the Tracy Arm Ford’s Terror Wilderness Area. These areas would have an SIO 

of High under all alternatives but would likely achieve an SIO of Very High. 

Alternatives 4 and 7 would adopt an SIO of High for 31 percent of the viewshed. 

Alternatives 1 to 3 would adopt an SIO of Low or Very Low for between 0 and 3 

percent of the viewshed, while Alternatives 4, 5, 6, and 7 would have between 21 

and 25 percent. Alternatives 4 and 7, followed closely by Alternatives 5 and 6, 

would have the greatest effect on scenery, while Alternatives 1 to 3 would have the 

least. 

Stikine Strait 

All alternatives except Alternatives 4 and 7 would adopt an SIO of High for between 

28 and 38 of the viewshed (Table 3.16-5). Alternatives 4 and 7 would adopt an SIO 

of High for 13 percent. Alternative 1 would adopt an SIO of Low or Very Low for 14 

percent of the viewshed, while Alternatives 3, 5, and 6 would have 33 percent and 

Alternatives 4 and 7 would have 42 percent. Therefore, Alternative 1 would have 

the least effect on scenery, and Alternatives 4 and 7 would have the most; 

Alternatives 3, 5, and 6 would have an intermediate level of effects on scenery. 

Sumner Strait 

The Sumner Strait Viewshed includes portions of the Kuiu Wilderness and the Mt. 

Calder/Mt. Holbrook and Salmon Bay LUD II areas. These areas would have an 

SIO of High under all alternatives but would likely achieve an SIO of Very High. All 

alternatives except Alternatives 4 and 7 adopt an SIO of High for between 30 and 31 

percent of the Viewshed (Table 3.16-5). Alternatives 4 and 7 would adopt an SIO of 

High for 23 and 21 percent, respectively. Alternatives 4 and 7 would adopt an SIO 

of Low or Very Low for between 68 and 69 percent of the viewshed, compared to 50 

to 51 percent for Alternatives 5 and 6, 39 percent for Alternative 3, and 17 to 22 

percent for Alternatives 1 and 2 (Table 3.16-5). Therefore, Alternatives 4 and 7 

would have the greatest effect on scenery and Alternative 1 would have the least, 

closely followed by Alternative 2, and then by Alternatives 3, 5, and 6, in that order. 

Sweetwater Lake/Honker Divide 

All alternatives except Alternative 4 and 7 would adopt an SIO of High for between 

63 and 69 percent of the viewshed (Table 3.16-5). Alternatives 1, 2, and 3 would 

adopt an SIO of Low or Very Low for between 14 and 17 percent of the viewshed, 

while Alternatives 5 and 6 would adopt an SIO of Low or Very Low for 21 percent of 

the viewshed. Alternative 4 would adopt an SIO of High for 50 percent and an SIO 

of Low or Very Low for 32 percent. Alternative 7 would adopt an SIO of High for 21 

percent of the viewshed and a Low or Very low for 49 percent. Therefore, 
3 Environment and Effects

Scenery 3-418 Final EIS 

Alternative 7 would have the greateest effect on scenery in the viewshed, while 

Alternatives 1, 2, and 3 would have the least, followed closely by Alternatives 5 and 

6. Effects under Alternative 4 would be between those under Alternatives 5 and 7. 

Tenakee Inlet to Tenakee Springs 

This viewshed contains the Trap Bay and Kadashan LUD II areas, which have an 

SIO of High under all alternatives (Table 3.16-5). The viewshed also contains land 

designated as Research Natural Area and Wild River LUDs, which also have a High 

SIO under all alternatives. Alternatives 1, 2, and 3 would adopt an SIO of High for 

between 76 and 82 percent of the viewshed and an SIO of Low or Very Low for 

between 4 and 24 percent of the viewshed, while Alternatives 5 and 6 would adopt 

an SIO of High for 33 to 40 percent and an SIO of Low or Very Low for 66 and 42 

percent, respectively. Alternative 4 would adopt an SIO of High for 21 percent and 

an SIO of Low or Very Low for 76 percent. Alternative 7 would have the least area 

with an SIO of High (18 percent) and 80 percent with an SIO of Low or Very Low. 

Therefore, Alternative 7 would have greatest effect on scenery in the viewshed, 

while Alternative 1 would have the least, followed closely by Alternative 2 and then 

by Alternative 3. 

West Coast Waterway/Prince of Wales 

This viewshed contains the Mt. Calder/Mt. Holbrook LUD II area, which would have 

an SIO of High under all alternatives. All alternatives except Alternatives 4 and 7 

would adopt an SIO of High for between 32 and 38 percent of the viewshed, while 

Alternatives 4 and 7 would adopt an SIO of High for 27 and 17 percent, respectively 

(Table 3.16-5). Alternatives 2, 3, 5, and 6 would adopt an SIO of Low or Very Low 

for between 38 and 49 percent of the viewshed. Alternative 1 would have 23 

percent of the viewshed in the Low and Very Low SIOs. Alternative 4 would adopt 

an SIO of Low or Very Low for 63 percent of the viewshed and Alternative 7 for 72 

percent. Therefore, Alternative 7 would have a greatest effect on scenery in the 

viewshed, while Alternative 1 would have the least. Alternatives 2, 3, 5, and 6 would 

be midway between Alternatives 1 and 7 in terms of the degree of change to 

scenery in the viewshed, while Alternative 4 would be close to Alternative 7. 

Wrangell Narrows 

All alternatives except Alternative 7 would adopt an SIO of High for between 30 and 

38 percent of the viewshed (Table 3.16-5). Alternative 7 would adopt an SIO of 

High for 20 percent of the viewshed. Alternative 1 would adopt an SIO of Low or 

very Low for 10 percent of the viewshed, compared to between 19 and 27 percent 

for the other alternatives. Alternative 7 would have a somewhat greater effect than 

the other alternatives. A small portion of the viewshed would be in the Petersburg 

Municipal Watershed LUD where SIOs would be determined on a case-by-case 

basis for any projects proposed in the watershed. 

Zimova Strait 

All alternatives except Alternatives 4 and 7 would adopt an SIO of High for 39 to 42 

percent of the viewshed (Table 3.16-5). Alternatives 4 and 7 would adopt an SIO of 

High for 22 and 20 percent of the viewshed, respectively. Alternative 1 would have 

the least land with an SIO of Low or Very Low (19 percent). Alternatives 2, 3, 5, and 

6 would designate 31 to 39 percent as Low or Very Low, compared to 44 to 45 

percent for Alternatives 4 and 7. Alternative 1 would have the least effect, followed 

by Alternatives 2, 3, 5, and 6, which are very similar. Alternatives 4 and 7 would 

have the greatest effect. 
 Environment and Effects 3 

Final EIS 3-419 Subsistence 

Subsistence 

Affected Environment ...............................................................................3-419 

The Legal Context for Subsistence Use ...............................................3-420 

Abundance and Distribution..................................................................3-420 

Access...................................................................................................3-420 

Competition ...........................................................................................3-421 

Subsistence Users ................................................................................3-421 

Economy ...............................................................................................3-422 

Subsistence Use Areas.........................................................................3-426 

Environmental Consequences .................................................................3-427 

Direct and Indirect Effects.....................................................................3-427 

Abundance and Distribution..................................................................3-427 

Access...................................................................................................3-429 

Competition ...........................................................................................3-431 

Cumulative Effects ................................................................................3-432 

ANILCA Determination..........................................................................3-433 

Affected Environment 

Subsistence hunting, fishing, trapping, and gathering activities are a major focus of 

life for many Southeast Alaska residents. Some individuals participate in 

subsistence activities to supplement personal income and provide needed food. 

Nearly all rural Alaska communities depend on subsistence resources to meet some 

portion of their nutritional needs (Wolfe 2000). Others pursue subsistence activities 

to perpetuate cultural customs and traditions. Still others participate in subsistence 

activities for reasons unconnected with income or tradition. For all these individuals, 

subsistence is a lifestyle reflecting deeply held attitudes, values, and beliefs. 

Within the context of Southeast Alaska’s seasonal and cyclical resource-based 

employment, subsistence harvest of fish and wildlife resources takes on special 

importance. The use of these resources may play a major role in supplementing 

cash incomes during periods when the opportunity to participate in the wage 

economy is either marginal or nonexistent. Because of high prices of commercial 

products provided through the retail sector of the cash economy, especially in 

remote communities, the economic role of locally available fish and game takes on 

added importance. 

Native and non-Native communities both have high subsistence participation rates 

and rely heavily on wild foods, with approximately 86 percent of rural Alaska 

households using wild game and 95 percent using fish (Wolfe 2000). The 

opportunity to participate in subsistence activities reinforces a variety of cultural and 

related values in both Native and non-Native communities. For example, the 

distribution of harvested fish and wildlife contributes to the cohesion of kinship 

groups and community stability through the sharing of resources. Subsistence 

resources provide the foundation for Native culture, forming the basis for different 

clans and potlatch ceremonies, as well as reinforcing basic values of respect for the 

earth and its resources. Participating in subsistence activities contributes to the selfreliance, independence, and ability to provide for oneself; values that social surveys 

indicate are important reasons why many non-Native people emigrate to or remain 

in Southeast Alaska (USDA Forest Service 1997a). 
3 Environment and Effects

Subsistence 3-420 Final EIS

While there are a variety of cultural, popular, and sociological definitions and 

interpretations of subsistence, Congress addressed this subject in Title VIII of the 

1980 Alaska National Interest Lands Conservation Act (ANILCA). Section 803 of 

ANILCA defines subsistence use as: 

“the customary and traditional uses by rural Alaska residents of wild renewable 

resources for direct, personal, or family consumption as food, shelter, fuel, 

clothing, tools, or transportation; for the making and selling of handicraft articles 

out of non-edible byproducts of fish and wildlife resources taken for personal or 

family consumption; for barter, or sharing for personal or family consumption; and 

for customary trade.” 

ANILCA provides for “the continuation of the opportunity for subsistence uses by 

rural residents of Alaska, including both Natives and non-Natives, on the public 

lands.” It also states, in part, that “customary and traditional” subsistence uses of 

renewable resources “shall be the priority consumptive uses of all such resources 

on the public lands of Alaska.” 

The provisions in ANILCA established a harvest priority for rural residents in an 

attempt to protect subsistence resource harvest. Under ANILCA, in times of 

resource scarcity or when demand exceeds biologically sound harvest levels, 

subsistence harvests have priority over other consumptive use of resources. In 

practice, this meant that commercial, sport, or other harvests were to be curtailed by 

state or federal fish and wildlife management authorities before subsistence 

harvests were limited. The Alaska legislature subsequently passed a regulation to 

comply with ANILCA, but in 1989, the Alaska Supreme Court ruled in McDowell v. 

State of Alaska that a harvest priority for rural residents conflicted with the state 

constitution, which guarantees all Alaskans equal access to the state’s natural 

resources. This ruling took the state out of compliance with ANILCA and the federal 

government has managed subsistence resources on federal lands in Alaska since 

1990. As a result, subsistence harvests of fish and wildlife on the Tongass National 

Forest are presently managed by the Forest Service (Schroeder and Mazza 2005). 

ANILCA requires the analysis of the potential effects on subsistence uses of all 

actions on federal lands in Alaska. This analysis most commonly focuses on those 

food-related resources most likely to be affected by habitat degradation associated 

with land management activities. Three factors related to subsistence uses are 

specifically identified by ANILCA: 1) resource distribution and abundance, 2) access 

to resources, and 3) competition for the use of resources. These factors are 

discussed in general terms in the following paragraphs. 

Abundance and Distribution 

Southeast Alaska subsistence resources include terrestrial wildlife (including deer, 

moose, mountain goat, black and brown bear, furbearers, and small game), 

waterfowl (including ducks, geese, and seabirds), marine mammals (harbor seal), 

salmon, other finfish, marine invertebrates, plants, and firewood. The abundance 

and distribution of these resources on the Tongass is described in the 1997 Land 

Management Plan Revision Final EIS, as well as in other sections of this EIS. 

Access 

Road building, a byproduct of timber harvesting and, to a much lesser extent, 

mining, is an important agent of change in Southeast Alaska. These road networks 

provide greater access to areas previously unconnected and can affect subsistence 

both positively and negatively by providing access, dispersing hunting and fishing 

pressure, and creating the potential for increased competition. On Prince of Wales 

The Legal 

Context for 

Subsistence Use 
 Environment and Effects 3 

Final EIS 3-421 Subsistence 

Island, for example, areas that have become road-connected are now more easily 

reached through the ferry system, thus providing greater access from Ketchikan, 

one of the largest cities in the region. While road systems tend to bring more people 

into an area, they also give subsistence hunters access to previously remote regions 

and provide a greater opportunity for subsistence harvest. 

Southeast Alaska is comprised of isolated islands unconnected by road systems; 

however, with the transportation means available (floatplanes, ferry systems, 

automobiles, boats), Southeast Alaska residents are very mobile in their subsistence 

resource use activities. Wrangell, the fifth largest community in Southeast Alaska, 

has documented their subsistence gathering from the southern tip of Prince of 

Wales Island to Yakutat, covering most of the islands in between (Kruse and Muth 

1990). 

Competition 

The Tongass National Forest, with nearly 17 million acres of largely undeveloped 

land, includes extensive subsistence resources. These resources are not, however, 

distributed or used evenly across the Forest. Where the resources are confined to 

island groups or river systems and access is costly or nonexistent, use of the 

resources is low. Where the resource is abundant, and a community is present but 

access by other communities is costly, the resource tends to be used primarily by 

the community that resides in the area. Where resources are abundant and access 

is available to local and other communities of Southeast Alaska, competition for 

resources may exist. 

Increased competition may result when less expensive access to the area or within 

the area is provided. Such is the case when road systems are established to local 

communities. When areas historically not used for subsistence purposes are made 

available because of easier, more cost-effective access, the new area then tends to 

be used. When communities with road access to abundant resources are 

connected to the ferry systems or to commercial air services, competition for the 

resources may be generated from outside communities with lower abundance of the 

same resource. 

Examples of the effect of ease of access are readily available in Southeast Alaska. 

Chichagof Island, Prince of Wales Island, and the Yakutat Forelands at one time 

were isolated portions of the Tongass with limited use from communities in the 

vicinity. Today, road construction, primarily a result of timber harvest activities, has 

created relatively large areas that are easily accessed from local communities. 

Access provided by the ferry systems and small commuter planes to Chichagof and 

Prince of Wales Islands allows relatively easy access from off-island communities. 

Access to the Yakutat Forelands has been made easier because of commercial jet 

service and ferry service to the community of Yakutat. 

The Southeast Alaska Federal Subsistence Regional Advisory Council noted an 

increased use of subsistence resources in the 1990s, and recommended decreases 

in harvest of deer, moose, and other wildlife species for non-rural residents. 

Competition for these resources typically increases with growth in the regional 

population and changes in access, such as the addition of new ferry services. 

Under ANILCA only rural Alaska residents qualify for subsistence hunting and 

fishing on federal lands. Alaska residents living in urban areas can harvest under 

sport, personal use, or commercial regulations, but not under subsistence 

regulations. Following the Alaska Supreme Court’s 1989 ruling in McDowell v. State 

of Alaska, all Alaska residents qualify as subsistence users on state lands with 

federal lands continuing to be managed under ANILCA. 

Subsistence 

Users 
3 Environment and Effects

Subsistence 3-422 Final EIS

In 2005, Southeast Alaska had an estimated population of 70,800, with the majority 

(about 91 percent) living in 32 established communities (Alaska Department of 

Labor [DOL] 2006). About 63 percent of the area’s population lived in the city and 

borough of Juneau or Ketchikan Gateway Borough, the only two communities 

considered as urban areas for subsistence purposes. An additional 24 percent of 

the area’s population resided in the communities of Sitka, Petersburg, Wrangell, 

Haines, and Craig. The remaining 13 percent of the population lived in communities 

ranging in size from Meyers Chuck with 15 people to Metlakatla with 1,342 people 

(Alaska DOL 2006). 

In addition to permanent communities, there are a small number of logging camps 

across the Tongass National Forest that, in the past, were large enough and existed 

long enough to have had an effect on local uses of fish and wildlife. Currently, the 

remaining camps have few residents and do not have much effect on competition for 

resources. 

A relatively small number of Southeast Alaska residents live at remote isolated 

locations. These include people living at homesites throughout Southeast Alaska, at 

summer fishing sites along the outer coast, tree thinners camped near areas where 

they have Forest Service contracts, trappers, and people living on floathouses and 

fishing boats. This diverse group is typically transient, generally has very low cash 

income, and is closely tied to non-commercial harvest of fish, game, and other 

renewable natural resources. 

As in other parts of Alaska, Southeast Alaska’s population grew with the expansion 

of government services following the oil boom. A number of new communities 

evolved around State land selections or timber harvesting activities in the 1980s and 

1990s. Edna Bay, Coffman Cove, North Whale Pass, Thorne Bay, and other small 

Prince of Wales Island communities are examples. The population in Southeast 

Alaska increased in the 1990s, but has decreased since 2000, with approximately 

2,300 fewer people living in the region in 2005 than in 2000 (Alaska DOL 2006). 

Alaska Natives made up 17 percent of the region’s population in 2000 and 

comprised about 23 percent of the total population of Southeast Alaska’s 30 rural 

communities in 2000 (Figure 3.17-1). These rural communities include places that 

are predominately Native, such as Angoon, Hydaburg, and Metlakatla, other logging 

and fishing communities that may be predominately non-Native, and places with 

more mixed ethnicity. The Bureau of Indian Affairs identifies 17 localized Indian 

tribes in the region, including the Metlakatla of the Annette Island Reserve. At the 

time of contact, tribes occupied seasonal camps and temporary villages throughout 

traditional territories. In the late 1800s, the individual tribes of the region coalesced 

at what had been their winter villages. The area’s extant tribes live within their 

earlier territories and use a similar set of subsistence resources and in this way 

maintain long standing ties to place. For Native people, this tie to place and the 

harvest and use of traditional foods are key elements in fostering Native cultural 

identity (Alaska Native Heritage Center 2000). 

Subsistence use of fish and wildlife continues to be an important component of the 

economies of Southeast Alaska communities. In Native communities, harvest and 

use of wild resources supported the subsistence-based economy that predated the 

introduction of cash income. In the modern era, beginning in the late-1700s, the 

economies of Native communities have undergone a progressive transformation, 

incorporating cash income into the subsistence-based system. Southeast Alaska 

communities that were settled primarily by non-Native immigrants have also 

depended on a mix of subsistence use of wild resources and cash income. 

Cash income in most Southeast Alaska rural communities is limited and intermittent, 

and frequently supports the purchase of fuel and equipment that are part of 

subsistence harvest technology. Subsistence harvests have been found to fill 

Economy 
 Environment and Effects 3 

Final EIS 3-423 Subsistence 

essential food needs in most rural communities in the region. These harvests are 

also customarily shared among community residents and between members of 

different communities. Some subsistence products are traded and bartered within 

the region. Subsistence harvests are not geared toward market sale or commercial 

profit. A mixed subsistence-market economy in which subsistence harvests and 

cash income are complementary characterizes the economies of most of the 

region’s rural communities (Wolfe 2004). 

Subsistence research conducted in Southeast Alaska over the past two decades 

has included detailed community studies, use area mapping, household surveys, 

and studies of specific subsistence harvests. During the 1980s, the Forest Service 

supported research that examined the impacts of timber harvests in the Tongass 

National Forest on subsistence resources in the area. The Tongass Resource Use 

Cooperative Survey (TRUCS) was completed in 1988 and followed by the Tongass 

Subsistence Studies. Data from TRUCS are summarized in the 1997 Tongass Land 

Management Plan Revision Final EIS. 

Figure 3.17-1 

Native/Non-Native Components of Southeast Communities, 2000 

Source: U.S. Census Bureau 2001. 

0 10 20 30 40 50 60 70 80 90 100

Edna Bay

Elfin Cove

Hyder

Meyers Chuck

Port Protection

Whale Pass

Coffman Cove

Point Baker

Thorne Bay

Tenakee Springs

Skagway

Gustavus

Port Alexander

Hollis

Petersburg

Naukati Bay

Juneau city and borough

Haines

Wrangell

Ketchikan Gateway Borough

Sitka city and borough

Pelican

Craig

Kasaan

Yakutat

Klawock

Hoonah

Saxman

Kake

Metlakatla

Angoon

Hydaburg

Percent

Non-Native

Native
3 Environment and Effects

Subsistence 3-424 Final EIS

From 1987 to 2001, interviews were conducted with 1,064 households in 24 

Southeast Alaska communities as part of the Forest Plan subsistence administrative 

studies. This fieldwork was conducted cooperatively with the Forest Service, Alaska 

Department of Fish and Game (ADF&G), and the area's tribes and communities all 

participating. Summary data from this and past community harvest assessments 

were compiled from the ADF&G Subsistence Community Profile Database 

(www.state.ak.us) and harvest levels are presented by community and species in 

Figure 3.17-2. The data presented in Figure 3.17-2 are the most recent available in 

the ADF&G database. The year these data were collected does, however, vary by 

community and the data summarized in Figure 3.17-2 should be considered a 

general overview of harvest patterns rather than an exact representation of current 

harvest activities. 

The preliminary findings of this research are summarized in a recent unpublished 

paper by Schroeder and Mazza (2005) who identify a number of key subsistence 

characteristics that are evident in these data and generally consistent with the 

following past findings: 

♦ Wild foods account for a large share of the diet for residents of the studied 

communities, ranging from 48 pounds per capita for Skagway in 1986 to over 

500 pounds per capita for Hoonah in 1996 (see Figure 3.17-2). The average 

American diet includes about 225 pounds of meat, fish, and poultry on a per 

capita basis. In most of the study communities, wild foods came close to, or 

exceeded, this national average. Although residents of subsistence 

communities purchase food, most could meet their entire protein need from wild 

sources. 

♦ Marine resources, including fish, mammals, and plants, comprise the majority of 

subsistence harvests in all communities when measured by food weight. 

Marine resources account for more than half of total per capita harvest in all 

Southeast Alaska communities, ranging from 55 percent in Tenakee Springs to 

89 percent in Wrangell (Figure 3.17-2). As a result, management activities that 

restrict access for subsistence harvest of land mammals have had a relatively 

small effect on overall subsistence harvest by weight. 

♦ Recent subsistence harvest levels in the main Native communities and the 

larger non-Native communities appear very similar to harvest levels estimated in 

the late 1980s or before. Harvest levels identified in the recent assessments 

conducted in Angoon, Hoonah, Hydaburg, Kake, Petersburg, Wrangell, and 

Yakutat, for example, are very similar to those identified in earlier studies. In a 

few communities, such as Coffman Cove, Kasaan, Klawock, and Port 

Protection, there are large differences in harvest levels over time. However, 

these differences seem to be more influenced by special events or small 

community sizes than by patterned changes in subsistence harvests. 

♦ Subsistence harvest levels vary considerably from community to community. 

Recent research and other data suggest that intercommunity variability may not 

be fully explained by ethnicity, income, community size, or access to resources. 

Other factors, such as community demographic composition, cultural traditions 

and orientations, and community history, may have a larger influence on harvest 

levels than more easily analyzed standard socioeconomic variables. 

♦ Subsistence harvesters use a wide variety of species, but use tends to be 

concentrated on a relatively small number of species. In Yakutat, for example, 

individual subsistence harvesters use as many as 65 of the 150 different 

species that are harvested in the community, but 84 percent of overall 

community harvest (in food weight) involves just 10 species. That said, the 

contribution of a particular species to the total subsistence harvest generally 

appears to vary from year to year, although the overall total harvest in food 

weight may remain nearly constant. 
 Environment and Effects 3 

Final EIS 3-425 Subsistence 

Figure 3.17-2 

Per Capita Subsistence Harvest by Community and Resource Type 

0 100 200 300 400 500 600

Skagw ay

Metlakatla

Saxman

Thorne Bay

Wrangell

Hollis

Whitestone L.C.

Kake

Whale Pass

Haines

Petersburg

Sitka

Craig

Gustavus

Naukati Bay

Elfin Cove

Coffman Cove

Point Baker

Port Alexander

Klaw ock

Tenakee Springs

Hyder

Angoon

Pelican

Edna Bay

Hydaburg

Yakutat

Meyers Chuck

Port Protection

Kasaan

Hoonah

Per Capita Harvest (Ibs)

Fish Marine Invertebrates Land Mammals Marine Mammals Plants and Other

Note: 

The year these data were collected varies by community, as follows: 

1987: Elfin Cove, Gustavus, Hyder, Metlakatla, Meyers Chuck, Pelican, Petersburg, Port Alexander, Saxman, 

Skagway, Tenakee Springs, and Wrangell 

1996: Angoon, Haines, Hoonah, Kake, Point Baker, Port Protection, Sitka, and Whitestone Logging Camp 

1997: Craig, Hydaburg, and Klawock 

1998: Coffman Cove, Edna Bay, Hollis, Kasaan, Naukati Bay, Thorne Bay, and Whale Pass 

2000: Yakutat 

Source: ADF&G 2006 
3 Environment and Effects

Subsistence 3-426 Final EIS

♦ A small number of high harvesting households account for a disproportionate 

share of the total community harvest and tend to harvest more fish and wildlife 

than their family members can consume. The surplus is distributed to other 

subsistence users through a kinship network and through barter and trade. 

These networks are also used to distribute specialty subsistence products such 

as herring roe and hooligan oil, which are produced in large quantities in only a 

few communities. In Yakutat, for example, just 25 percent of subsistence 

households account for about 75 percent of total community subsistence 

harvest (in terms of food weight), with the lowest harvesting 50 percent of 

households taking just 8 percent of the total community harvest. 

Historically, subsistence use occurred where access to the resources cost less in 

energy than the resources gathered. Many of the gathering activities occurred in 

easily accessible areas. These activities occurred close to settlements where they 

could be accessed by foot or boat. Over time, as new technology developed, ease 

of access meant a movement outward into new resource use areas. The motorboat 

and development of road systems associated with timber harvest activities in 

Southeast Alaska have had perhaps the greatest influence on subsistence gathering 

activity. Today, all communities use motorized boats and many are tied to nearby 

lands by road systems. As new roads are developed, access is improved to a 

number of areas and subsistence use has moved to these areas. 

The distribution of subsistence harvest activity is described in further detail in the 

1997 Tongass Land Management Plan Revision Final EIS, with traditional 

household deer hunting areas mapped in Appendix H. These areas were identified 

based on the 1987 TRUCS (Kruse and Muth 1990). The traditional household deer 

hunting areas mapped in Appendix H show that the road systems are extensively 

used. This is particularly true on Prince of Wales Island. These maps also show that 

subsistence use is concentrated in close proximity to individual communities and 

along the beaches. 

Each of the communities in Southeast Alaska has a distinct home range with 

concentrated use occurring within this range. A wide range of use typically occurs 

on a less concentrated scale outside the normal home range. More than half (54 

percent) of all households surveyed in rural Southeast Alaska in 1987 traveled a 

minimum of 11 miles by boat to reach the one reliable deer hunting area that they 

chose to describe in TRUCS (Kruse and Muth 1990). An additional 18 percent of all 

households also used boats to reach their reliable deer hunting area, but traveled 

shorter distances (10 miles or less). Only 15 percent of all households used cars or 

trucks to travel to the most reliable areas. Thirteen percent used some other form of 

transportation, such as airplanes, walking, all-terrain vehicles, and the Alaska 

Marine Highway System (Kruse and Muth 1990). 

While the majority of use occurs within about a 15-mile radius of rural communities, 

nearly all of the forested lands of the Tongass are used to some degree for 

subsistence deer hunting (USDA Forest Service 1997a). Appendix H in the 1997 

Tongass Land Management Plan Revision Final EIS also displays, by community, 

the individual Wildlife Analysis Areas where approximately 75 percent of the 

average annual deer harvest occurred. 

Kruse and Muth (1990) found that nearly one-half of the households harvesting deer 

mentioned the existence of clearcuts of various ages occurring in presently reliable 

areas (44 percent), most-often-used areas (48 percent), and areas no longer used 

(55 percent). They also reported that old-growth forests were mentioned as most 

reliable by 90 percent of households harvesting deer, were most-often-used areas 

by 91 percent of households, and were areas no longer used by 90 percent of those 

households harvesting deer. 

Subsistence Use 

Areas 
 Environment and Effects 3 

Final EIS 3-427 Subsistence 

Many of the fish and wildlife resource values of Southeast Alaska watersheds, 

based on the Value Comparison Unit (VCU) classification of the Tongass, are 

summarized in the 1998 Tongass Fish and Wildlife Resource Assessment (ADF&G 

1998). This report shows the relative value of areas for black bear, brown bear, 

deer, sport fishing, salmon production, and subsistence use. This resource 

assessment also included a ranking of the VCUs that have the highest community 

use values. 

Environmental Consequences 

The analysis of the likely effects of the EIS alternatives on subsistence resources 

and uses is in two parts. Effects on subsistence resources and uses important to 

each rural community are discussed individually by community in the Subregional 

Overview and Communities section. Here, the Forest-wide evaluation is presented, 

based on general considerations in the three categories of effects previously 

identified: abundance and distribution, access, and competition. This general 

analysis relies on the community discussions and also on the Forest-wide effects 

analyses from the related resource sections (primarily Fish and Wildlife) where 

abundance and distribution are of concern. 

Section 810 of ANILCA requires the Forest Service, in determining whether to 

withdraw, reserve, lease, or otherwise permit the use, occupancy, or disposition of 

NFS lands in Alaska, to evaluate the potential effects on subsistence uses and 

needs, followed by specific notice and determination procedures should there be a 

significant possibility of a significant restriction of subsistence uses. The Alaska 

Land Use Council’s definition of “significantly restrict subsistence use” is one 

guideline used in the evaluation: 

“A proposed action shall be considered to significantly restrict subsistence uses, 

if after any modification warranted by consideration of alternatives, conditions, or 

stipulations, it can be expected to result in a substantial reduction in the 

opportunity to continue subsistence uses of renewable resources.” 

It should be noted that the term “significant” as used in this context does not have 

the same definition as used in the implementing regulations for NEPA. See 40 CFR 

Section 1508.27 for definitions of “significant” in a NEPA context. 

Considerations of abundance and distribution, access, and competition (by non-rural 

residents) are mentioned. 

The U.S. District Court Decision of Record in Kunaknana v. Watt provided additional 

clarification. In part it states: 

“restrictions for subsistence uses would be significant if there were large 

reductions in abundance or major redistribution of these resources, substantial 

interference with harvestable access to active subsistence-use sites, or major 

increases in non-rural resident hunting.” 

Abundance and Distribution 

Based on the 1987 survey information compiled as part of TRUCS, 61 percent of 

subsistence resources (by weight) are fish or marine invertebrates, 21 percent are 

deer, 4 percent are other land mammals, and another 3 percent are marine 

mammals. More recent community data compiled by ADF&G (2006) indicate that 

fish and marine invertebrates still comprise the majority of subsistence harvest per 

capita (in pounds), ranging from 53 percent in Tenakee Springs to 88 percent in 

Skagway (see Figure 3.17-2). 

Direct and 

Indirect Effects 
3 Environment and Effects

Subsistence 3-428 Final EIS

The subsistence analysis conducted for the 1997 Forest Plan Revision Final EIS 

found that the primary subsistence resource likely to be significantly affected by the 

alternatives was Sitka black-tailed deer. Some effects to fish habitat may also result 

from land management activities, but the magnitude of the effects could not be 

calculated. Risk to fish habitat is generally expected to increase with increased 

timber harvest, increased roading, and narrower riparian areas along streams. A 

panel evaluation of alternatives was conducted for the 1997 Final EIS. Alternative 

11, which essentially represents the adopted Forest Plan (Alternative 5 [No Action] 

in this EIS), was judged to have relatively low risk relative to the other alternatives. 

As a result of their association with old-growth forest habitat, which is the main 

terrestrial habitat type affected by the alternatives, deer are considered the 

“indicator” for potential subsistence resource consequences concerning the 

abundance and distribution of the resources. The community-based subsistence 

analysis (see the Subregional Overview and Communities section) focuses largely 

on deer, which is, in most cases, by far the largest terrestrial component of 

subsistence food resources. 

In the subsistence analysis in the 1991 Forest Plan Revision Supplemental Draft 

EIS (SDEIS), it was determined that at that time all of the Forest Plan alternatives, if 

implemented, could result in a significant restriction on the abundance and/or 

distribution of subsistence uses of Sitka black-tailed deer, brown bear, and marten 

sometime during the next 50 years. This conclusion was based on an analysis of 

the current status of huntable wildlife resources, and identified portions of the 

Tongass where such restrictions may already be occurring (i.e., were the result of 

existing conditions) (USDA Forest Service 1991, pp. 3-762 and 3-763). The 

unpublished 1992 Draft Final EIS reached the same conclusion for deer and brown 

bear. Such restrictions were most likely for communities with subsistence use areas 

in the northern portion of the Tongass (Chichagof and Baranof Islands, primarily). 

The Revised SDEIS came to the same conclusion in its analysis for deer. 

In the 1997 Forest Plan Revision Final EIS, hunting demand and huntable 

populations of wildlife were only re-examined for Sitka black-tailed deer. Using a 

revised habitat capability model, the new deer analysis reached similar conclusions 

to that of the Revised SDEIS, based on specific areas where recent deer harvests 

are high relative to deer habitat capability. (This analysis was summarized at the 

end of the affected environment portion of the Wildlife section of the 1997 Forest 

Plan Revision Final EIS; see also Iverson 1996.) This analysis identified seven 

areas (near Juneau, Hoonah, Sitka, and Craig/Klawock) where current deer 

harvests exceeded 20 percent of the estimated habitat capability. This analysis also 

found another 23 areas exceeding 10 percent of capability (four on Admiralty, five 

on Chichagof, four on Baranof, eight on Prince of Wales, and two near Ketchikan). 

Areas exceeding 20 percent are those where deer harvest may be restricted, either 

directly through restrictions in seasons and bag limits, or indirectly through reduced 

hunter efficiency and increased difficulty in obtaining deer relative to historical rates. 

Hunters in areas between 10 to 20 percent may experience reduced hunter 

efficiency and moderate difficulty in obtaining deer. This analysis may 

underestimate negative effects when deer populations are below carrying capacity. 

Adverse effects to deer hunters may be further amplified with either reductions in 

deer habitat capability or increases in deer demand/harvest or both. 

The 1997 deer analysis was much in line with the earlier (1991, 1992, and 1996) 

analyses, which also used the 10 and 20 percent harvest cutoffs and the same land 

units. It indicated that deer habitat capabilities in several portions of the Tongass 

may not be adequate to sustain the current levels of deer harvests, and that 

implementation of any Forest Plan alternative could, therefore, be accompanied by a 

significant possibility of a significant restriction on the abundance and/or distribution 

of subsistence uses of deer. (Sport hunting restrictions would, however, occur first, 

followed by selective subsistence reductions, based on ANILCA Section 804.) This 
 Environment and Effects 3 

Final EIS 3-429 Subsistence 

possibility, at least in the short term, is largely due to the continuation of reduced 

habitat capabilities resulting from past habitat alterations, which is why it applied to 

all alternatives. 

Under the alternatives analyzed in this EIS, the possibility of a significant restriction, 

resulting from a change in abundance or distribution, would be the same as or less 

than the possibility under Alternative 11 of the 1997 Forest Plan Revision Final EIS 

for five of the seven alternatives. This risk would, however, likely be higher under 

Alternatives 4 and 7 because these alternatives anticipate a higher level of timber 

harvest than the current Forest Plan (Alternative 5, No Action). It should be noted 

that actual timber harvest has been much lower under the current Forest Plan than 

the levels projected under Alternative 11. 

In the short term, the risk of a significant restriction would be about the same under 

any of the alternatives because the effects of past harvest would override the effects 

of new harvest during the next 10 years. In the long term, those alternatives that 

limit the areas available for future timber harvesting the most would result in the 

largest reduction in risk. 

Alternatives 5 and 6 would result in a similar possibility of a significant restriction 

relative to Alternative 11 of the 1997 Final EIS because they would not produce a 

substantial change in old-growth harvest rates relative to the that Forest Plan. 

Development LUD acreage under Alternative 5 is about 3 percent less than under 

Alternative 11 of the 1997 Final EIS and Alternative 6 would have about 7 percent 

fewer acres in development LUDs. These reductions are due to land adjustments 

that have occurred since 1997 and, in the case of Alternative 6, increases in the 

acreage of land in old-growth reserves and other non-development LUDs. 

Alternative 6 would have 4 percent fewer acres in development LUDs than 

Alternative 5, which is the 1997 Forest Plan, as amended. Alternatives 1, 2, and 3 

would reduce the possibility of a significant restriction because of a 67, 46, and 18 

percent reduction, respectively, in development LUD acreages compared with 

Alternative 5. Alternatives 7 and 4 would each result in an increase in the possibility 

of a significant restriction due to respective increases in development LUD acreages 

of 40 percent and 31 percent relative to Alternative 5. 

Access 

Subsistence users typically hunt and fish in traditional areas surrounding their 

communities. Many of the communities in Southeast Alaska are not located on the 

Alaska road system and tend to be compact, centralized places surrounded by 

undeveloped land with limited infrastructure. Most subsistence food production is 

supported by a central or core use area surrounding a community. Traditional 

household deer hunting areas are identified for the 32 communities in Southeast 

Alaska in Appendix H to the 1997 Forest Plan EIS. Access to and use of 

surrounding areas for subsistence activities may be guided by local customary rules, 

as well as federal and state regulation and economic considerations, with traditional 

use areas for different communities often overlapping at their margins. Customary 

rules guiding subsistence harvest may be related to local histories and social 

customs of clans and communities (Wolfe 2004). 

Forest plans are programmatic, meaning that they establish direction and allowable 

activities for broad land areas, rather than schedule specific activities in specific 

locations. This makes it difficult to evaluate the effects of the alternatives on 

particular groups of subsistence users or resources. The following discussion 

addresses potential impacts at the programmatic or forest scale and assesses 

relative potential impacts in terms of overall proposed road construction and timber 

management activities. 
3 Environment and Effects

Subsistence 3-430 Final EIS

Viewed at this scale, none of the alternatives would directly limit the use of public 

lands for the purposes of subsistence gathering activities. Historical access (by foot, 

boat, and floatplane) would remain available under all the alternatives for present 

and foreseeable future activities. 

Data on documented deer harvest by transportation type are available at the Game 

Management Unit (GMU) level (Table 3.17-1). Data from the 2003 Deer Harvest 

Survey are presented by transportation type and GMU in Table 3.17-1. GMU 4, the 

ABC Islands (Admiralty, Baranof, and Chicagof Islands), accounted for 69 percent of 

deer harvested in Southeast Alaska in 2003 (7,621 deer), with GMU 2, Prince of 

Wales Island, accounting for 16 percent (1,783 deer). Hunters accessing hunting 

areas by boat accounted for 63 percent of total deer harvest in 2003. Hunters 

accessing the area by highway vehicle accounted for 23 percent of total deer 

harvest. The relative share of harvest by transportation type varies by GMU, with 

boat access, for example, accounting for 76 percent of harvest in GMU 4, but just 20 

percent in GMU 2. Highway vehicle was the most frequently used method of access 

in GMU 2, Prince of Wales Island, accounting for 73 percent of deer harvest in 2003 

(Table 3.17-1). This relatively high share reflects the more densely roaded nature of 

Prince of Wales Island and may be considered generally indicative of the effects of 

timber harvest and associated road building. 

Table 3.17-1 

Deer Harvest by Game Management Unit and Transportation Type, 2003

Percent of Deer Harvested by Transportation Type2/

GMU 

Number1/ Area

Deer 

Harvested Airplane Boat 

3- or 4-

Wheeler 

Highway 

Vehicle Foot 

Unknown 

1A Ketchikan 211 0 64 11 18 6 0 

1B Petersburg 82 0 39 44 0 17 0 

1C Juneau 467 0 33 0 48 16 2 

2 Prince of Wales Island 1,783 2 20 1 73 3 2 

3 Central Islands 901 1 52 11 31 1 2 

4 ABC Islands3/ 7,621 11 76 2 9 1 1 

 Total 11,065 883 6,938 329 2,529 240 139 

Percent of Total 100 8 63 3 23 2 1 

Notes: 

1 Game Management Units (GMUs) are a geographic unit of measurement established and used by ADF&G. 

2 These data were compiled as part of the 2003 Deer Hunter Survey and were collected in response to a question requesting 

the survey respondent to identify the Transportation Used to Get to the Hunt Area. 

3 The ABC Islands are Admiralty, Baranof, and Chichagof Islands. 

Source: ADF&G 2004.

New road construction is likely to result in the development of new use patterns 

around some communities, but these changes are not likely to lead to a significant 

possibility of a significant restriction of subsistence access to the resources. New 

use patterns may, however, favor some subsistence groups and disadvantage 

others. Subsistence access may be via a number of different transportation types 

and often involves more than one form of transportation. Subsistence users may, 

for example, access an area via boat followed by road (and on-foot) or via boat and 

on-foot, with types of access varying by location and user. Some hunters may 

access specific areas using more than one form of transportation, but others may 

favor one form of transportation over another, say highway vehicle over foot. 

While there would be some new road access under all alternatives in the long run, 

nearly all new roads constructed under the alternatives would be closed following 

harvest. These roads would, therefore, not be available for use by highway vehicles 

or high-clearance vehicles. They may, however, be available for access by other 

methods and would, as a result, have the potential to affect existing subsistence 

patterns. 
 Environment and Effects 3 

Final EIS 3-431 Subsistence 

Based on the miles of new road construction projected under each alternative and 

viewed at a programmatic level, Alternative 1 would have the lowest impact on 

existing subsistence access patterns with only about 20 percent of the maximum 

road miles projected under Alternative 5 (No Action) (774 miles versus 3,874 miles). 

Also, new road construction under Alternative 1 would be limited to areas outside 

existing Inventoried Roadless Areas (IRAs) and would, therefore, tend to increase 

road density in already roaded areas rather than provide new access to presently 

undeveloped areas. 

Alternatives 2 and 3 would also have relatively low impacts on existing subsistence 

access patterns with 1,751 and 887 fewer projected new road miles than under 

Alternative 5, respectively. These alternatives would also limit the construction of 

new roads in IRAs and, therefore, limit potential changes in access, but to a lesser 

extent than under Alternative 1. Alternative 6 (Proposed Action) would have a 

similar effect to Alternative 5, while Alternatives 4 and 7 would involve 1,136 and 

1,913 more new road miles than Alternative 5 (No Action), respectively, and have 

the potential to provide new access to presently undeveloped areas. 

Some subsistence users have a preference for unroaded areas. Viewed at a 

programmatic level, Alternative 1 would have the lowest impact on subsistence 

users who prefer unroaded areas because timber management would be primarily 

limited to areas outside the existing IRAs on the Tongass. Alternatives 2 and 3 

would have the next lowest potential impacts, in that order, with timber management 

under Alternative 2 limited to areas outside the existing IRAs except in locations 

where existing roads could be logically extended. Alternative 3 would keep the 23 

areas proposed for wilderness in HR 987 and the 18 Areas of Special Interest in the 

1999 Record of Decision in a natural condition. Alternatives 5 and 6 would be more 

likely to involve timber harvest in IRAs; this likelihood would be increased further 

under Alternatives 4 and 7. Alternatives 4 and 7 have an increased emphasis on 

timber production with respective annual Allowable Sale Quantities (ASQs) of 313 

million board feet (MMBF) and 421 MMBF in the first decade, compared to 267 

MMBF under Alternative 5 (No Action) and 49 MMBF under Alternative 1. 

Another potential access impact relates to the effects of clearcut harvesting on the 

landscape. Subsistence hunters have varying opinions on the effects of clearcut 

harvest on hunting success. Some hunters say that timber harvest clearcuts are 

productive for some years after harvest, while others prefer not to use clearcuts. 

Hunters interviewed on Prince of Wales Island, for example, reported that the best 

hunting in clearcut areas begins approximately 2 years after an area is logged, with 

hunt quality typically starting to decline 9 years after the area was cut (Brinkman 

2006). Concern has been expressed by hunters that clearcuts in the process of 

regrowth become impassable to hunters after a period of time (Galginaitus 2004). 

In addition to long-term access effects, timber management activities may also have 

short-term, temporary displacement effects for subsistence users because it is 

standard practice to close logging roads to outside traffic when logging is taking 

place. Subsistence users who use existing roads for access would be preempted 

from using those roads for the duration of logging activity in the affected area. 

These types of effects would, however, be short term and temporary, and would not 

be likely to lead to a significant possibility of a significant restriction of subsistence 

access to the resources. In addition, as previously noted, most or all new roads 

would be closed following harvest. 

Competition 

Just over half of the population in Southeast Alaska in 2005 resided in Juneau or 

Ketchikan (55 percent) and is, therefore, considered non-rural from a subsistence 

perspective. Residents in the remaining 30 communities and surrounding areas are 
3 Environment and Effects

Subsistence 3-432 Final EIS

considered rural. Competition for the more abundant wildlife and fisheries 

resources near rural communities results from a combination of factors, such as fish 

and game regulations, mobility, the natural distribution of game species across the 

Tongass, decreases in resource populations as a result of habitat reductions, 

decreases in resource populations as a result of over-harvest, and access provided 

to rural communities in the form of roads, ferries, and commercial air carriers. 

For analyzing competition, the following assumptions are made: 

♦ New road construction adjacent to communities with ferry access will result in 

increased competition from outside communities. 

♦ New road construction adjacent to existing road systems where interties 

between communities exist will result in increased competition from surrounding 

communities associated with the interconnected roads. 

♦ Habitat reductions will result in increased competition if regulations allow sport 

use to remain constant, with the same number of users seeking fewer huntable 

resources. 

♦ The demand for resources will remain constant or increase slightly as the 

habitat capability remains the same or declines over time. 

Given these assumptions, the 1997 Forest Plan Revision Final EIS concluded that 

implementation of Alternative 11 (the Selected Alternative) would result in a 

significant possibility of a significant restriction of subsistence use by increasing 

competition for some subsistence resources by non-rural, as well as rural residents. 

This was judged most likely to occur on Chichagof, Baranof, and/or Prince of Wales 

Islands, where competition for deer and some other land mammals is currently 

heavy, and habitat capability has been reduced as a result of timber harvest. 

The possibility of a significant restriction, resulting from a change in competition, 

would be the same as or less than the possibility under Alternative 11 (the Selected 

Alternative) of the 1997 Forest Plan Revision Final EIS for Alternatives 5 and 6. 

There would be a relative reduction in risk under Alternatives 1, 2, and 3, and an 

increase in risk under Alternative 4 and especially under Alternative 7 (see the 

Transportation and Utilities section of this chapter). 

Cumulative effects are discussed in four categories. 

1. Effects Resulting from Timber Harvesting of Private Lands. Native 

corporation lands adjacent to the Tongass National Forest support extensive 

timber harvest operations. Over the last two decades, old-growth forest wildlife 

habitat capability on Native corporation lands (especially that for deer) has 

declined, and this decline is expected to continue for at least the next two 

decades. This decline has occurred primarily on North Chichagof, Kupreanof, 

Admiralty (localized), and Prince of Wales Islands, as well as on mainland 

areas. Overall, approximately 351,000 acres, or 46 percent, of the original old 

growth has been harvested on non-National Forest System lands within the 

Forest boundary. The resulting lower habitat capabilities on these private lands 

are likely to increase hunting demands in adjacent National Forest areas, 

increasing competition and potentially leading to reduced hunter success, 

reduced or eliminated sport seasons, and in some places reduced or eliminated 

subsistence seasons. 

2. Effects from Past Activities. Timber harvest has been more influential in 

changing the landscape than any other use of the resources of the Tongass 

National Forest. With timber harvest comes roading, log transfer facility 

development, and reductions in old-growth forest habitat. Intensive timber 

harvesting, which began in the 1950s, has resulted in approximately 455,000 

acres of old growth harvest on National Forest System (NFS) lands. 

Cumulative 

Effects 
 Environment and Effects 3 

Final EIS 3-433 Subsistence 

3. Effects of Present Activities. Implementation of the current Forest Plan 

allowed an annual maximum timber harvest of approximately 267 MMBF (based 

on the ASQ), with an annual conversion of up to 8,900 acres of old-growth 

habitat to young growth (although a much lower volume and acreage has been 

harvested in recent years). This timber harvest involved the projected 

construction of up to 106 miles of classified road each year. In reality, less than 

25 miles of new road has been built each year since the plan was implemented. 

One major mining operation, the Greens Creek Mine on Admiralty Island is 

currently operating. In addition, construction of the Kensington Mine project 

north of Juneau is partially underway and the mine may become operational in 

the near future. 

4. Effects of Reasonably Foreseeable Future Activities. The conversion of oldgrowth forest habitat to young growth would occur at varying rates under all 

alternatives. The principal subsistence resource effect will be on Sitka 

black-tailed deer habitat, as previously discussed. If timber harvesting were to 

continue at maximum allowable rates (under Alternative 7) over the next 10 

years, a maximum of 159,000 acres of old-growth habitat could change to 

young-growth and about 880 miles of road could be built on NFS lands. The 

comparison of alternatives at the end of Chapter 2, as well as the Timber and 

Transportation and Utilities sections, displays the estimated miles of road 

predicted under each alternative. With timber harvest activities would come new 

access, possibly new camps, and potential increased use of subsistence 

resources by rural and non-rural residents. The effects of timber harvest on 

deer habitat capability would be reduced somewhat, through more intensive 

management (e.g., thinning) of the existing and future closed-canopy, younggrowth forests. 

Counting all lands in Southeast Alaska, an estimated 87 percent of the original 

old growth remains today. After 100+ years, it is estimated that the percentage 

of the original old growth remaining would range from 71 percent (Alternative 7) 

to 82 percent (Alternative 1), due to combined harvest on NFS and non-NFS 

lands, assuming maximum rates of harvest. Although the overall percentage 

reduction would not be excessively high overall, areas of concentrated harvest 

would have higher effects on subsistence. Areas of concentrated harvest are 

described in the Biodiversity section, which quantifies the estimated effects of 

cumulative future harvest on the amount of old growth by biogeographic 

province for all of Southeast Alaska (see Tables 3.9-20, 3.9-21, and 3.9-22). 

Timber harvest of Native corporation lands is anticipated to continue at a relatively 

low but constant level over the next decade. New land selections could result in 

some previously unharvested areas being logged. Actual mineral development is 

difficult to predict, but effects to subsistence resources would be highly localized 

where it does occur. 

An ANILCA Section 810 evaluation and determination is not required for approval of 

a Forest Plan amendment, which is a programmatic level decision that is not a 

determination whether to “withdraw, reserve, lease, or otherwise permit the use, 

occupancy, or disposition” of National Forest land. This EIS is part of the Forest 

Plan Amendment process and, therefore, does not require an ANILCA Section 810 

evaluation and determination. A Forest-wide evaluation and determination was, 

however, included for the 1997 Tongass Forest Plan Revision Final EIS to facilitate 

project-level planning and decisionmaking in compliance with ANILCA Section 810. 

The analysis and findings conducted for this EIS complement the 1997 effort. 

Consistent with Section 810 of ANILCA, the alternatives considered in the Revised 

SDEIS (prepared prior to the 1997 Forest Plan EIS) were evaluated for potential 

effects on subsistence uses and needs, as described above. Based on that 

evaluation, it was determined that, in combination with other past, present, and 

ANILCA 

Determination 
3 Environment and Effects

Subsistence 3-434 Final EIS

reasonably foreseeable future actions, one or more of the Revised SDEIS 

alternatives (if implemented through project-level decisions and actions) may result 

in a significant restriction of subsistence uses of deer, and possibly other land 

mammals, due to potential effects on abundance and distribution, and on 

competition. 

As a result of this finding, the Forest Service notified the appropriate state agencies, 

local communities, the Southeast Alaska Federal Subsistence Regional Advisory 

Council, and State Fish and Game Advisory Committees, and held hearings in 

affected communities throughout Southeast Alaska after publication and 

dissemination of the Revised SDEIS. 

Using the information described earlier in this section and comments from the 

ANILCA 810 Subsistence Hearings, the alternatives considered in the 1997 Forest 

Plan Revision Final EIS were evaluated for potential effects on subsistence uses 

and needs, as described above. Based on this evaluation it was again determined 

that, in combination with other past, present, and reasonably foreseeable future 

actions, one or more of the 1997 Final EIS alternatives (if implemented through 

project-level decisions and actions) may result in a significant restriction of 

subsistence uses of deer, and possibly other land mammals, due to potential effects 

on abundance and distribution, and on competition. 

ANILCA 810 Subsistence Hearings were also held in conjunction with the public 

meetings/hearings on the 2002 Draft SEIS. These meetings took place in 17 

communities across Alaska; an internet hearing was also conducted. Subsistence 

hearings were also conducted for this EIS. They were held in 24 Alaska 

communities and on the internet as well (see Chapter 1). 

Considering the input from these hearings and the analysis presented here, the 

same overall conclusion is reached regarding the alternatives evaluated in this EIS. 

The risk of a significant restriction would be the same or less than for the Selected 

Alternative from the 1997 Final EIS (current Forest Plan) under five of the 

alternatives, with the potential risk expected to higher under Alternatives 4 and 7. 

Section 810 (a)(3) of ANILCA requires that when a significant restriction may result, 

three determinations must be made, including the following: 

1. Necessary and Consistent with Sound Management of Public Lands. The 

alternatives proposed in this EIS have been examined to determine whether 

they are necessary and consistent with sound management of public lands. In 

this regard, the National Forest Management Act, the Alaska National Interest 

Lands Conservation Act, the Tongass Timber Reform Act, the Wilderness Act, 

the Alaska Regional Guide, the 1997 Forest Plan Revision Final EIS, as 

amended, the Alaska State Forest Resources and Practices Act, and the Alaska 

Coastal Zone Management Program have been considered. 

National Forest land management plans are required by the National Forest 

Management Act and must provide for the multiple-use and sustained yield of 

renewable forest resources in accordance with the Multiple-Use Sustained Yield 

Act of 1960. Multiple-use is defined as “the management of all the various 

renewable surface resources of the National Forest System so that they are 

utilized in the combination that will best meet the needs of the American people” 

(36 CFR 219.3). The alternatives presented herein represent different ways of 

managing Tongass National Forest resources in combinations that are intended 

to meet the needs of the American people. Each provides a different mix of 

resources uses and opportunities and has some potential to affect subsistence 

uses, although the effects would be the same or less than under the current 

Forest Plan for five of the alternatives, with the potential effects expected to 

higher under Alternatives 4 and 7. The potential restrictions associated with 
 Environment and Effects 3 

Final EIS 3-435 Subsistence 

each alternative are necessary and consistent with the sound management of 

public lands. 

2. Amount of Public Land Necessary to Accomplish the Proposed Action. 

The amount of land necessary to implement each alternative is, considering 

sound multiple-use management of public lands, the minimum necessary to 

accomplish the purpose of that alternative. The entire forested portion of the 

Tongass is used by at least one rural community for subsistence purposes for, 

at a minimum, deer hunting. It is not possible to avoid all of these areas in 

implementing resource use activities, such as timber harvesting and road 

construction, under any Forest Plan alternative, and attempting to reduce effects 

in some areas can mean increasing the use of others. The current and 

proposed Forest-wide standards and guidelines and LUD prescriptions provide 

for special management or limit activities in many of the areas most important 

for subsistence uses, such as beaches and estuaries, areas adjacent to roads, 

and areas with high fish and wildlife habitat values. Forest-wide standards and 

guidelines and LUD prescriptions are discussed in more detail below. 

The alternatives considered in this EIS, with the exception of Alternatives 4 and 

7, would maintain the same levels of resource use and associated activities or 

would reduce them. There would be an increase in resource use under 

Alternatives 4 and 7. There would be a reduction in the beach and estuary 

buffers in the revised Forest Plan under Alternative 7. In addition, the OldGrowth Habitat LUD and its management prescription would be eliminated 

under Alternative 7. 

3. Reasonable Steps to Minimize Adverse Impacts to Subsistence Uses and 

Resources. The Forest-wide standards and guidelines and LUD prescriptions 

of the current Forest Plan would continue to be implemented as part of 

Alternative 5 (No Action), where they apply. An updated and edited version of 

the current Forest Plan has been developed for Alternative 6 (Proposed Action), 

and for Alternatives 1, 2, and 3. Alternatives 4 and 7 also follow the Proposed 

Forest Plan, with some exceptions. One important exception in this context is 

the reduction in the beach and estuary buffers that would occur under 

Alternative 7. Beaches and estuaries are often important subsistence areas and 

reducing the buffers in these areas would reduce the level of protection and 

could have long-term impacts on subsistence users. In addition, the Old-Growth 

Habitat LUD and its management prescription would be eliminated under 

Alternative 7. Under Alternative 4, there would be Old-Growth Reserves would 

be limited to four high risk-biogeographic provinces. In other areas, 30 percent 

of old-growth would be reserved in each VCU. 

Subsistence use is addressed specifically in a Forest-wide standard and 

guideline, and subsistence resources are covered by the Forest-wide standards 

and guidelines for wildlife, fish, riparian areas, and biological diversity, among 

others. Fish and wildlife habitat productivity would be maintained at the highest 

level possible under all alternatives, consistent with the overall multiple-use 

goals of the current Forest Plan, with improved protection under the Proposed 

Forest Plan. Alternatives 1, 2, 3, and 6 would harvest less productive oldgrowth than Alternative 5 (No Action) and maintain a larger proportion of original 

old-growth on the Tongass. Alternatives 4 and 7 would harvest more productive 

old-growth than Alternative 5. There would be less deer habitat maintained in 

old-growth reserves under Alternative 4 than under Alternatives 1, 2, 3, 5, and 6. 

Alternative 7 would not include old-growth reserves and would have the largest 

potential long-term effects on the availability of deer for subsistence purposes. 

The potential effects of the alternatives on wildlife productivity are discussed in 

more detail in the Wildlife section of this EIS. 
3 Environment and Effects

Subsistence 3-436 Final EIS

A final determination was made in the Record of Decision for the 1997 Tongass 

Forest Plan Revision Final EIS, which was consistent with the analysis above. A 

summary of the evaluation, findings, and determination for the alternative selected 

following this EIS process will be presented in the Record of Decision for this EIS. 
 Environment and Effects 3 

Final EIS 3-437 Heritage Resources and Sacred Sites 

Heritage Resources and Sacred Sites 

Affected Environment................................................................................ 3-437

Heritage Resources................................................................................. 3-437

Sacred Sites ............................................................................................ 3-438

Heritage Resource and Sacred Sites Management Program................. 3-439

Environmental Consequences.................................................................. 3-440

Direct and Indirect Effects ....................................................................... 3-440

Cumulative Effect .................................................................................... 3-442

Affected Environment 

Heritage resources located within the Tongass National Forest include a diverse 

range of ancient and historic sites and artifacts that span approximately 10,000 

years of human occupation and resource use. Ancient remains include campsites, 

village sites, graves, resource areas, rock art, portages, and rockshelters. Historic 

sites include houses, cabins, mines, trails, portages, canneries, boatworks, 

shipwrecks, and military installations. Many of these heritage remains provide the 

only record of former human occupation, work areas, and lifestyles. 

The Tongass has implemented a Forest-wide heritage database (INFRA) to provide 

a more definitive tracking system for heritage surveys and sites. Based on this 

database, as of the end of Fiscal Year 2005, approximately 295,567 acres of 

National Forest System (NFS) lands have been inventoried for heritage resources 

and 2,096 heritage resource sites have been identified. As of the end of Fiscal Year 

2005, 22 heritage resource sites or properties are listed in the National Register of 

Historic Places (National Register), while 878 sites or properties have been 

determined eligible for listing either through concurrence with the Alaska State 

Historic Preservation Office (SHPO) or by a decision of the keeper of the National 

Register. The Forest has added 421 newly discovered sites to the Alaska Heritage 

Resource Survey (a state-wide listing of heritage resources) in the last 4 years. 

Only a small portion of the Tongass National Forest has been surveyed; therefore, 

additional heritage sites are expected to be located within the Forest in the future. 

Information gathered from these inventory efforts provides information about 

heritage resource distribution and sensitivity to damage. Specific locations 

associated with Alaska Native traditional and religious use (sacred sites) are 

identified on an ongoing basis, with site-specific data kept confidential. 

Certain types of heritage resources, such as sites, artifacts, and other observable 

results of human activity, have a greater probability of being located in specific 

areas, which create patterns of human use across the landscape through time. The 

environmental characteristics that invited human use and habitation in ancient times 

are often the same factors that invite use today. These high sensitivity areas, which 

are not evenly distributed across the landscape, are often below 100 feet in 

elevation and/or are areas of animal, plant, or mineral resource abundance. In 

addition, because of elevation and sea level changes after deglaciation, the 

locations of the earliest human activity areas may be farther inland and at higher 

elevations than more recent activity areas. 

The Forest has established and maintains a heritage resource management 

program to identify, evaluate, protect, and enhance significant heritage resources on 

a Forest-wide and project-specific level in compliance with the National Historic 

Preservation Act (NHPA), as amended, as well as a number of other acts and 

implementing regulations. The Forest’s ability to protect its heritage resources is 

affected by four factors: the location of the heritage property, the type of 

Heritage 

Resources 
Environment and Effects 3 

Heritage Resources and Sacred Sites 3-438 Final EIS

management activity conducted in that location, the environmental characteristics of 

the locality, and an active, effective heritage resource management program. 

Impacts to the resource may result from natural forces, public use, or project-related 

activities. Future management options will vary and are likely to be influenced by 

increased demands for scientific study, educational interpretation, public enjoyment, 

and preservation of traditional resources and sacred sites. 

Inventory of these heritage resources is an ongoing process. Information gathered 

from inventories will provide insight into resource distribution and the sensitivity of 

sites to damage. Further scientific study will increase knowledge about early human 

migration, later exploration and development of the region, and human behavior in 

response to social and environmental change. Once data are collected, the Forest 

has the responsibility to curate artifacts and conserve records, photographs, and 

other data specific to heritage resource projects and sites under the 2005 Curation 

Agreement with the University of Alaska-Fairbanks Museum. 

Sacred sites are places that have traditional spiritual values for Alaska Native 

people (Indian tribes or Indian religious practitioners) that are reverently dedicated to 

a person, object, event, or activity, and are secured against violation or infringement 

or interference. 

In order to protect and preserve Indian religious practices, Executive Order 13007 

and other laws and Executive Orders of the U.S. Government require the Forest 

Service, to the extent practicable, permitted by law, and not clearly inconsistent with 

essential agency functions to: 

♦ Accommodate access to, and ceremonial use of, Indian sacred sites by Indian 

religious practitioners, 

♦ Avoid adversely affecting the physical integrity of sacred sites, and 

♦ Where appropriate, maintain the confidentiality of sacred sites. 

Alaska Native groups or an appropriately authoritative representative of an Indian 

religion shall be responsible for identifying such sites to the Forest Service as the 

managing agency. 

The Forest has developed Sacred Sites Protection Activities within the Heritage 

Resources Forest-wide standards and guidelines for the management of sacred 

sites as an integral part of its land management. The Forest also seeks to 

accommodate access to, and ceremonial use of, sacred sites by Indian religious 

practitioners, and to avoid adversely affecting the physical integrity of these sites. 

As early as possible, the Forest consults with tribes and their representatives on a 

government-to-government basis to provide notice of proposed actions or policies 

that may restrict access to or adversely affect the physical integrity of sacred sites. 

The Forest is developing a knowledge base about sacred sites and tribal protocols, 

management recommendations, proposed guidelines, policies, or concerns about 

proposed actions that may affect sacred sites. Management includes undertaking 

government-to-government consultations with Alaska Native tribes and corporations 

and their representatives to monitor and protect sites from public access or other 

disturbance as needed. The Forest is also providing information and assistance on 

Alaska Native rights, trust responsibilities, preserving traditional beliefs and 

practices, and the laws and policies affecting management of historical, cultural, and 

traditional uses of NFS lands. 

Sacred Sites 
 Environment and Effects 3 

Final EIS 3-439 Heritage Resources and Sacred Sites 

According to Forest-wide Heritage Resource Standards and Guidelines, the Forest 

maintains a heritage resource and sacred sites management program to identify, 

evaluate, protect, and enhance ancient heritage resources on a Forest-wide and 

project-specific level in compliance with federal legislation, their amendments, and 

implementing regulations. This includes coordinating management of heritage 

resources with the Alaska SHPO, Advisory Council on Historic Preservation 

(ACHP), and neighboring Alaska Native tribes and corporations. ACHP outlines this 

historic preservation review process in the Code of Federal Regulations (CFR) (36 

CFR 800). Public involvement is a cornerstone of successful Section 106 review, 

and 1992 amendments to the NHPA place major emphasis on the role of Indian 

tribes. Subsequent revisions to ACHP's regulations, published December 12, 2000, 

incorporate specific provisions for federal agencies to involve Indian tribes 

throughout the Section 106 review process. 

Heritage resource activities also include identifying and developing appropriate 

interpretive messages for heritage resource sites and activities; coordinating the 

management, access, and use of forest products to perpetuate Alaska Native 

culture and art forms; and developing a heritage resource management assessment 

that provides a framework for management decisions. The Forest annually reports 

upon all activities of the Heritage Program to the Alaska SHPO and the ACHP as 

stipulated in their Programmatic Agreement. 

The Programmatic Agreement between the Forest Service – Alaska Region, ACHP, 

and Alaska SHPO regarding heritage resource management on National Forests 

was first signed in 1995, with amendments in 1999 and 2002. The purpose of this 

Agreement is to expedite compliance with the ACHP’s regulations (36 CFR 800) 

implementing Section 106 of the NHPA. In lieu of the individual undertaking 

procedural requirements of the regulations, implementation of the Agreement 

enables the Forest Service to fufill some of its Section 110 responsibilities, such as 

the continuation of preservation and fostering appreciation of heritage resources 

through inventory, evaluation, protection, research, enhancement, education, 

restoration, stewardship, and interpretation programs. These programs are part of 

an effective heritage resource management program focused on heritage 

stewardship and public outreach. Section 110 of the NHPA and Executive Order 

13287 directs federal agencies to use, to the maximum extent feasible, historic 

properties available to the agency. This direction must be taken into account as the 

agency considers the future of its administrative and recreation facilities in light of 

decreasing budgets. The Agreement recognizes the role of consultation with Alaska 

Native tribes and corporations on a government-to-government basis as well as the 

public. 

The active participation of Alaska Native tribes and corporations and Alaska Native 

religious practitioners is critical to the success of sacred sites management. 

Heritage resource and tribal government relations specialists will collaborate to 

provide the Forest’s line officers information necessary to make decisions related to 

sacred sites management. Tribal consultation will be conducted in a professional 

manner with tribal government officials, recognized Tribal Elders, and authoritative 

representatives. The consultation process will include regular review of proposed 

federal actions, development of a sacred sites knowledge base, protection of the 

physical integrity of sacred sites, and use alternative dispute resolution processes, if 

needed. The Forest will implement procedures to protect confidential information 

related to sacred sites. 

If a tribal government chooses not to consult, the Forest will rely on the best 

available information to make decisions about sacred sites. 

Heritage 

Resource and 

Sacred Sites 

Management 

Program 
Environment and Effects 3 

Heritage Resources and Sacred Sites 3-440 Final EIS

Environmental Consequences 

Erosion and other environmental processes may deteriorate heritage sites through 

decomposition or mechanical destruction. Decomposition is most evident in objects 

or structures made of wood. Stabilization, regular maintenance, rehabilitation, and 

data recovery are means for preventing the loss of such objects or structures and 

the information they contain. 

Public use may destroy heritage sites or sacred sites inadvertently or by intent. 

Inadvertent damage results from accessing sites resulting in compaction, or from 

other ground-disturbing activities. Intentional damage is looting and vandalism, 

including relic collecting, theft, and defacement, which result in the loss of 

information and destruction of the resource. Significant sites may be protected from 

destructive public uses by establishing public education programs, maintaining 

confidentiality about site-specific locations, monitoring, and directing public use 

away from the most vulnerable sites. 

Areas managed for recreation provide opportunities for heritage resource protection 

and interpretation to promote public education and enjoyment. Active educational 

and interpretive programs can create a greater awareness of the importance of 

heritage resources and foster a sense of stewardship, while adding to the 

recreational experience. At the same time, protective measures must be 

implemented to control or eliminate intentional destruction of these areas by relic 

collecting, theft, and other forms of vandalism. 

While multiple-use activities have benefited heritage resources by providing 

opportunities for inventory, evaluation, and interpretation in remote areas of the 

Forest, ground-disturbing activities have the most potential to adversely affect these 

resources and their environmental settings. The amount of impact an activity has is 

determined largely by the location and nature of the activity, the characteristics of 

the soils, and the degree of use. 

Heritage resource and sacred sites management may increase the cost of project 

implementation. Some areas may need to be avoided entirely in order to protect the 

resource. This may increase the cost of site access and result in some loss of 

commercial products, such as timber. Protection of significant heritage resources or 

sacred sites often precludes ground-disturbing activities within a designated site 

boundary. When preservation of heritage resources in place is not desired or 

possible, mitigation of adverse effects to the resources may be necessary, and this 

in turn may delay projects and increase project costs. Normally, when the Section 

106 process of the NHPA is completed early in the planning process, project delays 

and additional costs are minimal. 

Under all of the alternatives, the preferred management of heritage resource sites 

eligible for, nominated to, or listed in the National Register is avoidance and 

protection. When this is not possible or feasible, it may be necessary to implement 

a mitigation program in order to achieve a finding of no adverse effect. Mitigation 

plans are developed in consultation with the Alaska SHPO, ACHP, Alaska Native 

tribes and corporations, and, possibly, other consulting parties. The potential for 

adverse effects, and therefore the need for mitigation, is diminished when the 

physical settings around significant heritage resources are maintained in a natural 

state. 

Management of sacred sites includes early consultation with Indian religious 

practitioners and Indian tribes, development of site-specific protection strategies and 

enforcement mechanisms, and protection of the confidentiality of site-specific 

information. If sacred sites are identified during a project, the surrounding natural 

environment should be maintained and protected while consultation takes place and 

a protection plan is developed. If a sacred site is inadvertently disturbed or sacred 

Direct and 

Indirect Effects 
 Environment and Effects 3 

Final EIS 3-441 Heritage Resources and Sacred Sites 

or burial objects are exposed by natural causes, affiliated tribal governments will be 

notified within 24 hours. 

LUDs allowing timber harvesting, mining, and road construction are most likely to 

affect heritage resources or sacred sites through alteration of environmental settings 

or damage to unknown sites as projects are implemented. However, existing 

standards and guidelines (e.g., those for riparian and beach and estuary buffer 

zones) result in the protection of most of the Forest’s heritage resources. 

Recreation and special uses pose the greatest threat to heritage resources or 

sacred sites today, simply because people want to recreate and use the forest in the 

same places people have for thousands of years. In many instances, retention of a 

natural setting is crucial to imparting and protecting the values that qualify a heritage 

resource for National Register status or allow the undertaking of religious practices 

at sacred sites. Conversely, the opportunity for identifying new heritage resource 

sites is greater within these areas because such developments require more 

intensive heritage resource inventory efforts. ACHP, in their direction on sacred 

sites, point to the possibility that a sacred site (per Executive Order 13007) may not 

meet the eligibility criteria for the National Register. For example, a property with 

poor integrity might not be eligible to the National Register, but it may still be an 

important sacred site worthy of protection and other future management under EO 

13007. An indirect effect common to all alternatives and prescriptions is that the 

discovery of new sites can lead to vandalism if locations become known to the 

public. An indirect effect specific to alternatives with proposed Wilderness 

designations is that such designation can indirectly lead to adverse effects to historic 

structures. 

Potential effects to heritage resources and the differences in risk between the 

alternatives are difficult to measure. Table 3.18-1 identifies the maximum estimated 

acres of old growth and second growth that can be harvested and miles of road 

likely to be constructed under each alternative. These acreages and mileages 

provide relative indicators of potential adverse effects, with the alternatives having 

the most acreage and mileage are likely to produce the highest risk of effects. 

Under this scenario, Alternatives 4 and 7 have the highest risk because they include 

more area where development would be permitted. They would be followed by 

Alternatives 5, 6, 3, 2, and 1, in decreasing order of risk level. However, because 

project areas are inventoried for ancient and historic heritage resource sites and 

tribal consultation for sacred sites should occur prior to implementation and 

avoidance of impacts is the preferred option for resource protection, the levels of 

risk are considered relatively low for all alternatives. In addition, existing standards 

and guidelines should result in the protection of most heritage resources and sacred 

sites in those areas. 

Table 3.18-1 

Approximate Maximum Acres Likely to be Disturbed over 100+ Years 

Alternative 

Estimated Maximum 

Acres of Old Growth 

to be Harvested 

Estimated Maximum 

Acres of Second 

Growth to be 

Harvested 

Estimated Maximum 

Miles of New Road 

Construction 

1 85,972 58,293 774 

2 214,511 179,426 2,079 

3 313,426 200,250 2,799 

4 656,473 235,513 4,890 

5 462,556 224,027 3,874 

6 445,103 218,368 3,744 

7 807,396 262,228 5,825 

Source: Tongass National Forest GIS database
Environment and Effects 3 

Heritage Resources and Sacred Sites 3-442 Final EIS

While it is true that increased project activity might accelerate the loss of heritage 

resources, primarily by improving public access and increasing the probability for 

looting and vandalism of heritage resource sites, there are potential positive effects 

as well. Over time, decay, neglect, and natural landscape changes threaten the 

preservation of significant heritage resources. By expanding the Forest’s inventory 

of its heritage resources, development projects result in identification of many sites 

that might otherwise decay unnoticed. Once sites are known, the Forest is better 

able to protect and encourage collection of information from a greater number of 

them. By providing sufficient staff and funding to monitor known heritage resources 

and sacred sites, the Forest should be able to minimize looting and vandalism. 

The Forest Plan and all of the alternatives include requirements for inventory, 

protection, preservation, and interpretation, and for consultation with Indian tribes or 

Indian religious practitioners and the Alaska SHPO as described in the Heritage 

Resource Standards and Guidelines. Effects are avoided or mitigated through a 

variety of measures at the project level. Avoidance measures may include 

protective enclosures, systematic monitoring of project activities, or mandatory 

restrictions on project design. Mitigation at heritage resources is undertaken when 

impacts cannot be avoided, and includes systematic recovery of the information 

through excavation, collection of materials, and detailed documentation as 

determined through consultation with the Alaska SHPO, ACHP, Indian tribes, and 

others. Protection of significant heritage resource sites and sacred sites from 

damage through public use includes establishing public education programs, 

maintaining confidentiality about specific locations, monitoring, and directing public 

use away from the vulnerable sites. The Forest is also required to consult with 

Alaska Native tribes and corporations when effects may involve sites of religious 

and/or cultural importance to them. 

The vast majority of Southeast Alaska (16.8 million acres) is occupied by the 

Tongass National Forest, so the disturbances described above for the Tongass are 

the major disturbances affecting heritage resources. However, Glacier Bay National 

Park, Haines State Forest, and other ownerships in the Haines/Skagway area 

occupy 3.6 million acres, while state, Native corporations, and other ownerships 

inside the Forest boundary occupy a combined 1.1 million acres. Therefore, 

activities on these lands contribute to Southeast Alaska cumulative effects. 

Disturbances in Glacier Bay and Haines/Skagway National Parks are generally very 

minor and contribute insignificantly to cumulative effects. However, extensive timber 

harvest, road construction, and urban development occur on these other 

ownerships. Because of the level of inventory required prior to development and the 

level of heritage resource protection required for discovered resources on Tongass 

National Forest lands, none of the alternatives should contribute significantly to the 

cumulative effects on heritage resources of Southeast Alaska. 

Extensive landscape changes and ground disturbance have occurred and will 

continue to occur on many non-federal lands in Southeast Alaska. Federal laws 

requiring consideration for the protection of heritage resources do not apply to nonfederal lands. Heritage resources are nonrenewable, and once disturbed they are 

permanently damaged or destroyed; their information and values are lost and 

cannot be recovered. Preservation of these resources and values on federal lands 

is critical so that future generations can continue to enjoy the heritage and 

knowledge about our past that we enjoy today. 

Cumulative 

Effects 
 Environment and Effects 3 

Final EIS 3-443 Roadless 

Roadless Areas 

Affected Environment................................................................................ 3-443

Introduction.............................................................................................. 3-443

Roadless Area Inventory ......................................................................... 3-443

Roadless Area Conservation Rule .......................................................... 3-444

Current Situation...................................................................................... 3-445

Environmental Consequences.................................................................. 3-450

Direct, Indirect, and Cumulative Effects .................................................. 3-450

Cumulative Effects................................................................................... 3-453

Affected Environment 

This section addresses inventoried roadless areas. The discussion is divided into 

three parts: the current roadless area inventory, the roadless area conservation 

rule, and the current situation on the Tongass. 

The 1996 Tongass roadless inventory was updated following the March 2001 U.S. 

District Court of Alaska ruling (Sierra Club v. Lyons), which ordered the Forest 

Service to prepare a Supplemental EIS (SEIS) to evaluate roadless areas and to 

consider wilderness recommendations. As part of that effort, the Analysis of the 

Management Situation relative to roadless areas and their relative contribution to the 

National Wilderness Preservation System was completed. 

This process involved a comprehensive update of the inventory of existing roads 

(including all classified and unclassified roads), harvest units, and land ownership 

on the Tongass National Forest. Developed areas were subsequently identified by 

buffering existing roads and harvest units. All areas within 1,200 feet of an existing 

road and within 600 feet of an existing harvest unit were considered developed; 

however, in order to be more inclusive, isolated beach-logged and helicopter units 

were not identified as developed areas. Narrow stringers of land between 

developed areas were also included as developed. All National Forest System 

(NFS) lands outside of areas defined as developed were identified as roadless 

areas. These roadless areas were then divided into two groups: areas greater than 

5,000 acres and areas less than 5,000 acres. Inventoried roadless areas were 

identified as all roadless areas greater than 5,000 acres, as well as all inventoried 

roadless areas identified in previous inventories, which included some areas less 

than 5,000 acres. In addition, all other areas less than 5,000 acres were examined 

to determine if they were eligible for wilderness consideration. These included small 

roadless areas adjacent to existing wilderness. 

The final inventory identified in the Final SEIS included 109 inventoried roadless 

areas covering 9.6 million acres. These inventoried roadless areas and other 

unroaded areas on the Tongass are identified on the roadless inventory map 

produced as part of this assessment and currently available on the SEIS Web site at 

www.tongass-seis.net. 

Detailed descriptions of each individual roadless area that include an overview and 

a description of the capability, availability, and need for each area to be designated 

as wilderness are included as Appendix C to the Final SEIS (USDA Forest Service 

2003b) and are also available on the SEIS Web site. These descriptions reflect 

current conditions and Forest Service Manual and Handbook direction. They also 

include an updated rating for each roadless area called the Wilderness Attribute 

Rating System (WARS), as well as a description of how each individual roadless 

area could contribute to the National Wilderness Preservation System. 

Roadless Area 

Inventory 

Roadless Area Terms 

Roadless Area: For 

purposes of this EIS, 

this is a generic term 

that includes 

inventoried roadless 

areas and unroaded 

areas. 

Inventoried Roadless 

Area: An undeveloped 

area typically 

exceeding 5,000 acres 

that meets the 

minimum criteria for 

wilderness 

consideration under 

the Wilderness Act. 

Unroaded Area: An 

undeveloped area 

typically less than 

5,000 acres but of a 

size and configuration 

sufficient to protect the 

inherent characteristics 

associated with its 

roadlless condition.
3 Environment and Effects

Roadless 3-444 Final EIS

The roadless area inventory displays the extent of the roadless resource and 

provides data for use by managers, legislators, and others to formulate land 

management proposals. Roadless areas may retain their roadless character by 

being managed in a way that emphasizes relatively large undeveloped or natural 

areas, such as areas usually required for old-growth habitat, scenic backdrops, or 

primitive recreation. Roadless areas identified in the inventory that are outside of 

existing the Wilderness Land Use Designation (LUD) may be considered for 

wilderness recommendation, or managed for a wide range of other resource 

management activities. 

On the Tongass, the goals for a number of LUDs include the maintenance of areas 

in a primarily roadless state. One of these is called LUD II; these areas are to be 

managed in a roadless state to retain their wildland character. LUD II is a 

permanent LUD that was used by Congress in the Tongass Timber Reform Act 

(TTRA). TTRA established 12 permanent LUD II areas totaling 730,463 acres 

(including 2,701 acres of non-NFS land) (Table 3.19-1). 

Table 3.19-1 

National Forest System Land, Non-National Forest System Land, and 

Productive Old Growth within Each of the Legislated LUD II Areas 

Designated by the Tongass Timber Reform Act (in acres)

Name of LUD II Area Total 

National Forest 

System 

Non-National 

Forest System 

Productive 

Old Growth 

Yakutat 139,045 139,035 10 72,312 

Berners Bay 45,233 45,233 0 15,390 

Anan 38,313 38,313 0 16,426 

Kadashan 34,441 34,281 160 20,609 

Lisianski/Upper Hoonah 149,088 147,132 1,956 44,178 

Mt. Calder-Holbrook 60,863 60,863 0 38,682 

Nutkwa 21,723 21,723 0 13,102 

Outside Islands 75,720 75,342 378 45,999 

Trap Bay 6,595 6,595 0 4,297 

Pt. Adolphus/Mud Bay 116,877 116,695 182 38,249 

Naha 31,365 31,350 15 17,875 

Salmon Bay 11,200 11,200 0 4,811 

Total 730,463 727,762 2,701 331,930 

Source: USDA Forest Service 1997a, Table 3-55.

In May 2001, the Forest Service issued the Roadless Area Conservation Rule 

(Roadless Rule). This rule established prohibitions on road construction, road 

reconstruction, and timber harvest in inventoried roadless areas on NFS lands. In 

May 2001, the U.S. District Court for the District of Idaho enjoined the Forest 

Service from implementing the Roadless Rule, a decision that was subsequently 

appealed. In December 2002, a three-justice panel of the Ninth Circuit Court of 

Appeals reversed the Idaho ruling. The case was returned to the Idaho District 

Court for evaluation of the merits, and the State of Idaho then requested review by 

the full Ninth Circuit. Several other states, including the State of Alaska, filed 

lawsuits similar to that filed by the State of Idaho. 

The litigation with the State of Alaska was settled in June 2003 and resulted in the 

July publication of a proposal to temporarily exempt the Tongass National Forest 

from the prohibitions of the Roadless Rule. On December 30, 2003, the Department 

of Agriculture adopted a final rule that withdrew the Tongass National Forest from 

the Roadless Rule, and the management of inventoried roadless areas on the 

Tongass is currently governed by the 1997 Forest Plan. 

In May 2005, in response to legal challenges and the ongoing controversy 

surrounding the Roadless Rule, the Forest Service issued the Special Areas; State 

Petitions for Inventoried Roadless Area Management Final Rule, and decision 

Roadless Area 

Conservation 

Rule 
 Environment and Effects 3 

Final EIS 3-445 Roadless 

memo (State Petitions Rule), which amended the Roadless Rule and established a 

petitioning process that provides Governors an opportunity to seek establishment of 

or adjustment to management requirements for NFS inventoried roadless areas 

within their states. Governors had until November 2006 to submit petitions. 

Three states—California, Oregon, and New Mexico—filed a lawsuit in August 2005 

challenging the May 2005 amendment, with Washington State later joining the case. 

In addition, Earthjustice filed a similar lawsuit in October 2005 on behalf of 20 

environmental groups. The U.S. District Court, Northern District of California ruling 

on this case in October 2006 overturned the State Petitions Rule and reinstated the 

Roadless Rule, including the Tongass Amendment. (Updated information on the 

Roadless Rule is regularly posted on the Forest Service’s Roadless Area 

Conservation Web site [www.roadless.fs.fed.us]). 

The inventoried roadless areas included in the 2001 Roadless Rule are identified in 

a set of maps, contained in the Forest Service Roadless Area Conservation, Final 

Environmental Impact Statement, Volume 2, dated November 2000. For the 

Tongass, these maps represent 9.3 million acres and correspond closely with the 

1996 roadless area inventory that was done for the 1997 Forest Plan Revision. 

Table 3.19-2 compares the areas protected by the Roadless Rule with the areas 

included in inventoried roadless areas for the 2003 Final SEIS, which covers 9.6 

million acres. The differences are due to additional road building between 1996 and 

2003, refinements of boundaries in 2003, and projects that were expected to be built 

in 1996 that were never implemented. Approximately 9.1 million of the 9.6 million 

acres in the Final SEIS inventoried roadless areas are also included under the 

Roadless Rule. 

The Tongass National Forest, the largest Forest in the NFS, is more than 90 percent 

roadless, including wilderness. Only small areas where communities are 

developing, or where road construction and timber harvest have occurred, are 

“developed” to any noticeable degree. At various times in the past, “boom and bust” 

development (associated with fox farming, salmon canneries, mining, and military 

activity) resulted in the temporary development and occupation of small areas, 

mostly near the shoreline, that have since been largely reclaimed by nature. 

Developed areas cover about 1.3 million acres, or about 8 percent, of the Tongass 

(based on the updated roadless mapping described above). Southeast Alaska 

residents (approximately 71,000) are, for the most part, surrounded by land that has 

many of the characteristics of wilderness. Routine travel and ordinary outdoor 

recreation activities typically require a higher degree of skill, risk-taking, and selfreliance than is usually required of adventurous backcountry visitors on other 

National Forests. This wildness and the lifestyles associated with it are highly prized 

by residents and visitors alike. 

Summary information is presented for the 109 inventoried roadless areas evaluated 

in the 2003 Final SEIS in Table 3.19-3 (USDA Forest Service 2003b). This 

information includes the size of each area in 2003, the amount of each area that is 

in productive old growth (POG), and the amount of each area that is considered 

suitable for timber harvest. The table also lists the WARS score for each of the 

roadless areas as a general indication of the wilderness attributes of the area. 

There are currently 9,514,105 acres in Inventoried Roadless Areas (IRAs) on the 

Tongass. This represents about a 44,000-acre reduction since the 2003 analysis, 

which is due to land adjustments, refinements to boundaries, additional road 

construction and harvest activity, and mapping corrections. If the additional 

5,749,083 acres of the Tongass in Wilderness and Wilderness National Monument 

are combined with the IRA acreage, the total of 15,263,188 acres represents 91 

percent of the Tongass. 

Current Situation 
3 Environment and Effects

Roadless 3-446 Final EIS

Table 3.19-2 

Tongass National Forest Inventoried Roadless Areas Analyzed in the Final 

2003 SEIS Compared with Roadless Areas Covered by the Roadless Area 

Conservation Rule

Roadless 

Area 

Number Roadless Area Name 

Final SEIS 

National Forest 

Acres 

Roadless Rule 

National Forest 

Acres 

Acreage 

Difference 

201 Fanshaw 48,446 48,194 252 

202 Spires 542,829 533,269 9,560 

203 Thomas 5,232 0 5,232 

204 Madan 69,126 68,502 624 

205 Aaron 79,147 78,689 458 

206 Cone 127,874 127,776 98 

207 Harding 179,350 174,209 5,141 

208 Bradfield 204,133 198,919 5,214 

209 Anan 38,162 36,648 1,514 

210 Frosty 45,522 39,865 5,656 

211 North Kupreanof 99,566 114,590 (15,023) 

212 Missionary 14,825 16,662 (1,837) 

213 Five Mile 19,284 19,433 (149) 

214 South Kupreanof 213,122 216,645 (3,523) 

215 Castle 52,432 49,151 3,281 

216 Lindenberg 25,136 25,836 (699) 

217 Green Rocks 11,059 11,074 (15) 

218 Woewodski 10,647 10,046 601 

220 East Mitkof 9,444 8,770 674 

223 Manzanita 10,436 8,394 2,042 

224 Crystal 19,609 18,962 647 

225 Kadin 2,022 2,022 0 

227 North Wrangell 11,602 8,089 3,513 

229 South Wrangell 14,959 14,211 748 

231 Woronkofski 12,932 11,097 1,835 

232 North Etolin 41,740 40,911 829 

233 Mosman 56,757 53,226 3,531 

234 South Etolin 28,678 26,230 2,449 

235 West Zarembo 8,544 6,781 1,764 

236 East Zarembo 16,175 10,844 5,331 

237 South Zarembo 41,999 36,246 5,752 

238 Kashevarof Islands 5,743 4,623 1,120 

239 Keku 11,170 10,829 340 

240 Security 35,497 31,375 4,122 

241 North Kuiu 9,544 6,352 3,192 

242 Camden 40,395 36,671 3,725 

243 Rocky Pass 79,103 77,580 1,523 

244 Bay of Pillars 28,728 27,363 1,365 

245 East Kuiu 46,395 27,513 18,882 

246 South Kuiu 63,063 62,150 913 

247 East Wrangell 7,634 7,610 24 

288 West Wrangell - 10,281 (10,281) 

289 Central Wrangell 15,210 13,394 1,815 

290 Southeast Wrangell 20,297 18,363 1,934 

301 Juneau-Skagway Icefield 1,201,473 1,186,606 14,867 

302 Taku-Snettisham 685,712 662,400 23,312 

303 Sullivan 66,143 67,252 (1,110) 

304 Chilkat-West Lynn Canal 198,109 199,418 (1,310) 

305 Juneau Urban 94,800 101,518 (6,718) 

306 Mansfield Peninsula 51,988 54,883 (2,895) 

307 Greens Creek 19,959 27,166 (7,207) 

308 Windham-Port Houghton 161,922 161,697 225 

310 Douglas Island 25,008 28,055 (3,047) 

311 Chichagof 534,309 555,200 (20,891) 

312 Trap Bay 13,821 13,213 608 

313 Rhine 16,675 22,979 (6,304) 

314 Point Craven 10,961 10,900 61 

317 Point Augusta 15,629 15,438 191 
 Environment and Effects 3 

Final EIS 3-447 Roadless 

Table 3.19-2 (continued) 

Tongass National Forest Inventoried Roadless Areas Analyzed in the Final 

2003 SEIS Compared with Roadless Areas Covered by the Roadless Area 

Conservation Rule

Roadless 

Area 

Number Roadless Area Name 

Final SEIS 

National Forest 

Acres 

Roadless Rule 

National Forest 

Acres 

Acreage 

Difference 

318 Whitestone 5,747 5,617 130 

319 Pavlof-East Point 4,731 5,368 (638) 

321 Tenakee Ridge 21,854 20,523 1,330 

323 Game Creek 51,436 54,432 (2,995) 

325 Freshwater Bay 47,070 44,909 2,160 

326 North Kruzof 25,373 32,961 (7,588) 

327 Middle Kruzof 15,127 14,698 428 

328 Hoonah Sound 97,329 79,661 17,668 

329 South Kruzof 55,726 55,074 653 

330 North Baranof 324,317 313,611 10,706 

331 Sitka Urban 114,460 111,983 2,477 

332 Sitka Sound 20,878 13,390 7,488 

333 Redoubt 74,570 67,993 6,577 

334 Port Alexander 124,021 120,183 3,838 

338 Brabazon Addition 500,597 498,589 2,008 

339 Yakutat Forelands 337,374 321,402 15,973 

341 Upper Situk 18,411 16,772 1,639 

342 Neka Mountain 53,019 6,130 46,889 

343 Neka Bay 7,826 7,090 736 

501 Dall Island 111,245 105,178 6,066 

502 Suemez Island 24,478 19,853 4,626 

503 Outer Islands 99,891 99,439 452 

504 Sukkwan 49,759 44,055 5,704 

505 Soda Bay 63,147 77,937 (14,790) 

507 Eudora 200,493 194,220 6,273 

508 Christoval 7,367 9,081 (1,714) 

509 Kogish 71,420 65,081 6,340 

510 Karta 55,527 52,106 3,421 

511 Thorne River 74,362 72,971 1,391 

512 Ratz 6,414 5,323 1,091 

514 Sarkar 62,170 51,635 10,535 

515 Kosciusko 71,578 63,878 7,699 

516 Calder 12,218 9,807 2,411 

517 El Capitan 30,854 26,688 4,166 

518 Salmon Bay 27,412 22,697 4,714 

519 McKenzie 80,650 82,766 (2,117) 

520 Kasaan 7,605 7,573 31 

521 Duke 46,863 44,535 2,328 

522 Gravina 38,978 37,299 1,679 

523 South Revilla 53,559 51,942 1,617 

524 Revilla 30,941 29,293 1,648 

525 Behm Islands 4,944 4,735 210 

526 North Revilla 225,444 215,371 10,073 

528 Cleveland 191,477 189,007 2,471 

529 North Cleveland 109,639 105,131 4,509 

530 Hyder 116,304 121,703 (5,399) 

531 Nutkwa 56,818 53,632 3,186 

532 Fake Pass 876 466 410 

533 Hydaburg 13,720 11,161 2,559 

534 Twelvemile 34,333 37,921 (3,587) 

535 Carroll 11,180 11,364 (184) 

536 Kasaan Bay - 7,358 (7,358) 

577 Quartz 146,657 142,941 3,716 

Total Acres 9,558,266 9,320,651 237,613 
3 Environment and Effects

Roadless 3-448 Final EIS

Table 3.19-3 

Tongass National Forest Inventoried Roadless Area Descriptors (2003)

Roadless 

Area 

Number Roadless Area Name 

National Forest 

Acres 

Productive OldGrowth Forest 

Acres 

Estimated 

Suitable Forest 

Lands Acres1

Wilderness 

Attribute Rating 

(WARS)2,3 

201 Fanshaw 48,443 29,508 8,251 26 

202 Spires 543,319 68,220 6,833 26(27) 

203 Thomas 5,297 2,031 480 18 

204 Madan 69,128 33,372 11,386 25 

205 Aaron 79,147 17,159 4 27 

206 Cone 127,874 10,698 - 28 

207 Harding 179,350 58,288 3,165 20(22) 

208 Bradfield 204,128 23,623 1,999 20 

209 Anan 38,162 16,038 - 22 

210 Frosty 45,522 22,583 4,989 19(21,24) 

211 North Kupreanof 103,094 20,746 5,475 19(22) 

212 Missionary 17,382 7,307 1,709 16 

213 Five Mile 19,272 8,247 2,232 23 

214 South Kupreanof 215,391 82,241 19,365 24 

215 Castle 52,432 20,313 3,098 25 

216 Lindenberg 26,757 11,793 4,639 18 

217 Green Rocks 11,216 5,052 337 19 

218 Woewodski 10,632 5,786 2,346 21 

220 East Mitkof 10,332 3,502 427 15 

223 Manzanita 10,792 6,037 1,921 18 

224 Crystal 20,003 8,330 2,129 19 

225 Kadin 2,022 1,997 - 20 

227 North Wrangell 11,518 7,202 2,206 15(17) 

229 South Wrangell 14,959 6,489 1,935 20 

231 Woronkofski 12,932 6,690 2,216 20 

232 North Etolin 42,519 20,276 3,973 18 

233 Mosman 56,757 27,040 5,576 22(21,23,24) 

234 South Etolin 28,678 11,109 3,204 24(23,25) 

235 West Zarembo 8,544 3,945 68 14 

236 East Zarembo 21,469 7,113 2,490 14 

237 South Zarembo 42,191 17,294 3,634 20 

238 Kashevarof Islands 5,743 4,197 - 23 

239 Keku 10,770 6,266 1,096 19 

240 Security 35,952 24,185 1,510 22 

241 North Kuiu 10,214 8,479 3,538 15 

242 Camden 40,260 20,549 5,901 23(19,26) 

243 Rocky Pass 81,107 39,493 863 26 

244 Bay of Pillars 28,994 20,541 3 25 

245 East Kuiu 46,438 29,626 7,656 26 

246 South Kuiu 63,063 37,388 - 27 

247 East Wrangell 7,634 5,032 1,241 17 

289 Central Wrangell 15,654 6,887 1,326 16 

290 Southeast Wrangell 20,353 8,686 1,109 17 

301 Juneau-Skagway Icefield 1,201,474 60,528 1,722 25(24,25) 

302 Taku-Snettisham 685,704 99,498 4,027 24 

303 Sullivan 66,143 12,883 955 26 

304 Chilkat-West Lynn Canal 198,525 47,442 5,981 25 

305 Juneau Urban 95,633 34,833 3,256 21 

306 Mansfield Peninsula 52,553 25,794 - 20 

307 Greens Creek 20,703 12,464 - 19(22) 

308 Windham-Port Houghton 161,867 107,308 20,546 25(25,25) 

310 Douglas Island 27,761 13,557 - 17 

311 Chichagof 545,419 173,701 11,164 25(20,22,23,23,26,26) 

312 Trap Bay 13,923 7,058 266 19(23) 

313 Rhine 19,628 2,332 335 18 

314 Point Craven 11,310 6,907 895 18 

317 Point Augusta 15,629 9,246 1,170 19(20) 
 Environment and Effects 3 

Final EIS 3-449 Roadless 

Table 3.19-3 (continued) 

Tongass National Forest Roadless Area Descriptors

Roadless 

Area 

Number Roadless Area Name 

National 

Forest Acres 

Productive OldGrowth Forest 

Acres 

Estimated 

Suitable Forest 

Lands Acres1

Wilderness Attribute 

Rating (WARS)2,3

318 Whitestone 5,745 2,841 439 19 

319 Pavlof-East Point 5,348 3,628 255 16 

321 Tenakee Ridge 22,014 6,375 1,309 18 

323 Game Creek 51,994 18,999 2,243 18 

325 Freshwater Bay 48,227 18,612 1,928 17 

326 North Kruzof 25,373 12,519 489 22 

327 Middle Kruzof 15,127 7,894 1,815 15 

328 Hoonah Sound 97,329 34,993 2,226 25 

329 South Kruzof 55,840 17,164 885 22 

330 North Baranof 331,425 82,901 6,521 25 

331 Sitka Urban 114,875 13,747 550 20 

332 Sitka Sound 20,878 10,260 486 20 

333 Redoubt 74,516 33,122 1,448 21 

334 Port Alexander 124,021 30,875 - 25 

338 Brabazon Addition 500,597 - 27 

339 Yakutat Forelands 336,976 34,829 4,137 22 

341 Upper Situk 18,411 6,885 1,236 19 

342 Neka Mountain 53,014 23,090 2,066 21 

343 Neka Bay 7,826 4,128 - 20 

501 Dall Island 110,667 64,784 2,547 23(21,23,24) 

502 Suemez Island 24,940 15,060 2,904 20 

503 Outer Islands 99,873 52,919 1,170 23(25) 

504 Sukkwan 49,614 19,801 1,829 23 

505 Soda Bay 63,363 21,288 5,621 20(20,20) 

507 Eudora 201,729 87,687 11,572 24(19.25) 

508 Christoval 7,367 5,396 24 19 

509 Kogish 72,553 29,497 8,090 20(23) 

510 Karta 56,816 19,863 6,121 19 

511 Thorne River 76,454 38,611 2,816 21(22) 

512 Ratz 6,414 3,298 812 19 

514 Sarkar 63,656 30,407 2,177 23 

515 Kosciusko 71,613 40,810 3,013 24 

516 Calder 12,519 8,983 302 22 

517 El Capitan 31,141 16,658 3,046 20 

518 Salmon Bay 28,602 11,157 1,682 20 

519 McKenzie 83,822 30,391 4,849 22(24) 

520 Kasaan 7,602 3,082 - 18 

521 Duke 46,863 7,360 - 26 

522 Gravina 38,845 18,849 4,468 21 

523 South Revilla 55,321 21,896 1,598 20(19,20,22) 

524 Revilla 30,826 10,427 585 17 

525 Behm Islands 4,943 3,263 - 14 

526 North Revilla 230,679 102,108 10,274 20(18,19,21,22,23) 

528 Cleveland 191,363 98,658 15,556 25 

529 North Cleveland 109,639 47,354 199 26 

530 Hyder 122,408 11,135 54 25 

531 Nutkwa 56,477 32,739 4,697 23 

532 Fake Pass 876 765 - 22 

533 Hydaburg 13,688 7,880 - 19 

534 Twelvemile 36,171 11,811 1,035 16 

535 Carroll 11,152 4,474 1,744 16 

577 Quartz 146,655 48,475 - 25 

 Total Acres 9,558,266 2,684,657 307,465 

1 The estimated suitable acreage is based on the 1997 Tongass Forest Plan and was adjusted by the Model Implementation 

Reduction Factor (MIRF) and a Scheduling factor (see the Timber section of this chapter). 2 The Wilderness Attribute Rating System (WARS), which was developed as part of the Roadless Area Review and Evaluation 

(RARE) II process in 1977, has a potential range from a minimum of 4 to a maximum of 28. WARS considers four main 

attributes and several supplemental ones. The main attributes are natural integrity, apparent naturalness, opportunity for 

solitude, and opportunity for primitive recreation. 3 When more than one number is given, the roadless area was rated once for the entire roadless area and separate rating(s) were 

done for identified portions of the area. The ratings for portions of the roadless area are in parentheses. 
3 Environment and Effects

Roadless 3-450 Final EIS

Several characteristics of roadless areas on the Tongass are rather unique relative 

to other areas in the NFS. The Tongass has very large undeveloped land areas that 

could potentially be managed as wilderness or in an unroaded condition. Several 

portions of the Forest constitute contiguous roadless areas exceeding 1 million 

acres, and thus represent large, unfragmented wildlife habitats and exceptional 

opportunities for solitude. 

Many of the Tongass roadless areas represent wildlife habitats, ecosystems, and 

visual character, such as coastal islands facing the open Pacific, extensive beaches 

on inland saltwater, old-growth temperate rain forests, ice fields, and glaciers that 

exist nowhere else in the NFS. Many of these areas are remote and difficult to 

access for primitive recreation, and many contain other important resources, such 

as timber, minerals, and salmon-producing streams. Of the slightly over 1 million 

acres of forest land that is mapped as suitable for timber production, approximately 

763,000 acres are POG forest. Approximately 307,000 acres, or 40 percent, is 

within roadless areas. 

Environmental Consequences 

There are currently 9,514,103 acres in IRAs on the Tongass. The allocation of 

these acres by LUD is presented for each alternative in Table 3.19-4. The individual 

LUDs are grouped into one of four categories: Wilderness and National Monument, 

Natural Setting, Moderate Development, and Intensive Development. The percent 

of IRA acres allocated to each category is summarized for each alternative in Table 

3.19-5. 

In general, management prescriptions for LUDs that allow moderate to intensive 

development include timber harvest with associated road and log transfer facility 

construction. There are guidelines for the extent and visual impact of such activities. 

LUDs that emphasize maintaining the natural setting and undeveloped character of 

the area generally do not allow timber harvesting or the development of major 

recreation facilities, although roads linking transportation systems, particularly major 

state corridors, may occur. 

Not all areas allocated to LUDs that allow development would actually be 

developed. Development would occur mainly in areas with suitable forest lands. 

Some of the road construction would occur in areas already roaded. Some of the 

road construction would fragment existing roadless areas, either creating new 

roadless areas (if more than 5,000 acres remains) or simply resulting in small blocks 

of undeveloped land surrounded by roads and harvest areas. In addition, not all of 

the effects of the alternatives would occur at once. 

Effects of Alternatives 

The roadless lands allocated to Natural Setting LUDs would essentially remain 

roadless for the life of the current/proposed Forest Plan and, therefore, there would 

be no effect on the roadless values in these areas unless a vital transportation 

linkage or major utility system was constructed. Site-specific environmental analysis 

would be undertaken if this type of development were proposed. 

Roadless lands allocated to moderate and intensive development LUDs would likely 

change over time. The amount of acres allocated to development LUDs and acres 

of forest land suitable for harvest are presented in Table 3.19-6. 

It should be noted that the discussion below for each alternative assumes that the 

current/proposed Forest Plan is in effect and does not assume any effects of the 

Roadless Rule that was originally promulgated in January 2001 and has since been 

the subject of a number of lawsuits. As noted in the Affected Environment section, 

Direct, Indirect, 

and Cumulative 

Effects 
 Environment and Effects 3 

Final EIS 3-451 Roadless 

Table 3.19-4 

Allocation of Inventoried Roadless Areas by LUD and Alternative (acres)

Alternative 

1 2 3 4 5 6 7 

Wilderness and National Monument1

Non-wilderness National Monument 155,092 155,092 155,092 155,092 155,092 155,092 155,092 

Subtotal 155,092 155,092 155,092 155,092 155,092 155,092 155,092 

Mostly Natural Setting

LUD II 709,892 709,892 709,892 709,898 709,898 709,892 709,897 

Research Natural Area 25,680 25,680 25,680 25,679 25,680 25,680 25,680 

Old Growth 996,902 996,902 996,902 306,488 974,757 996,902 0 

Special Interest Area 203,629 203,631 203,631 203,631 167,093 203,631 203,631 

Enacted Municipal Watershed 39,250 39,250 39,250 39,250 39,250 39,250 39,250 

Wild, Scenic, & Recreational River 101,421 101,421 101,421 101,417 101,421 101,421 101,421 

Remote Recreation 2,364,733 2,340,364 2,178,552 2,085,536 2,128,353 2,030,967 2,084,639 

Semi-Remote Recreation 4,890,486 4,130,193 3,431,241 2,458,814 2,781,758 2,937,123 2,527,327 

Subtotal 9,331,993 8,547,333 7,686,569 5,930,713 6,928,210 7,044,866 5,691,845 

Moderate Development

Modified Landscape 0 104,631 246,427 497,746 360,831 354,145 572,965 

Scenic Viewshed 0 93,714 199,460 554,770 344,424 312,913 599,569 

Experimental Forest 27,018 27,018 27,017 27,019 12,708 27,018 27,018 

Subtotal 27,018 225,363 472,904 1,079,535 717,963 694,076 1,199,552 

Intensive Development

Timber Production 0 586,317 1,199,538 2,348,764 1,712,839 1,620,071 2,467,614 

Subtotal 0 586,317 1,199,538 2,348,764 1,712,839 1,620,071 2,467,614 

Total 9,514,104 9,514,105 9,514,104 9,514,104 9,514,104 9,514,105 9,514,103 1 Table lists only Non-wilderness National Monument in this LUD group because Wilderness and Wilderness National Monument are not

identified as Inventoried Roadless Areas (IRAs), even though they are roadless. In addition to the 9,514,105 acres of IRAs, the 

Tongass has 5,749,083 acres of Wilderness and Wilderness National Monument , for a total of 15,,263,188 acres (representing 91% of 

the Tongass).

Table 3.19-5 

Allocation of Inventoried Roadless Area Acreage by LUD and Alternative 

(percent)

 Alternative 

 1 2 3 4 5 6 7 

Wilderness and National Monument1 2% 2% 2% 2% 2% 2% 2% 

Mostly Natural Setting 98% 90% 81% 62% 73% 74% 60% 

Moderate Development 0% 2% 5% 11% 8% 7% 13% 

Intensive Development 0% 6% 13% 25% 18% 17% 26% 

Total 100% 100% 100% 100% 100% 100% 100% 

1 Only Non-wilderness National Monument is included in this LUD group because Wilderness and Wilderness 

National Monument are not identified as Inventoried Roadless Areas (IRAs), even though they are roadless. 

The Tongass currently contains 15,263,188 acres (representing 91 percent of the Tongass) of roadless 

lands if IRAs are combined with Wilderness and Wilderness National Monument.
3 Environment and Effects

Roadless 3-452 Final EIS

Table 3.19-6 

Acres of Development LUDs and Forest Land Suitable for Harvest within Current 

Inventoried Roadless Areas1 by Alternative

Acres of Development LUDs (includes 

Experimental Forests) 

Acres of Forest Land Suitable and 

Scheduled for Harvest2

Alternative Acres Percent of IRA Acres Acres Percent of IRA Acres 

1 27,018 <0.5% 0 0.0% 

2 811,680 9% 88,773 0.9% 

3 1,672,442 18% 185,647 2.0% 

4 3,428,299 36% 497,596 5.2% 

5 2,430,802 26% 315,674 3.3% 

6 2,314,147 24% 306,592 3.2% 

7 3,667,166 39% 583,094 6.1% 1

 Inventoried Roadless Areas (IRAs) do not include Wilderness and Wilderness National Monument, even though they are 

roadless. In addition to the 9,514,105 acres of IRAs, the Tongass has 5,749,083 acres of Wilderness and Wilderness 

National Monument, for a total of 15,263,188 acres (representing 91 of the Tongass). 2

 Incorporates a reduction of 33 to 51 percent from mapped suitable, based on old-growth falldown and scheduling factors. 

the Roadless Rule including the Tongass Ammendment, was reinstated in October 

2006 by the U.S. District Court, Northern District of California. 

Alternative 1 

This alternative would keep virtually all existing IRAs in a natural condition. Less 

than 0.5 percent of the IRAs would be allocated to development LUDs under this 

alternative, compared to 26 percent under Alternative 5 (No Action). Less than 0.1 

percent of the IRAs (less than 200 acres) would potentially be harvested 

(Table 3.19-6). 

Alternative 2 

This alternative keeps most IRAs in a natural condition, with timber harvest featured 

on lands outside of these roadless areas except for some areas where roads could 

logically be extended. Approximately 9 percent of the IRAs would be allocated to 

development LUDs under this alternative, compared to 26 percent under Alternative 

5 (No Action). Approximately 0.9 percent of the IRAs (89,000 acres) would 

potentially be harvested under this alternative (Table 3.19-6). 

Alternative 3 

This alternative would keep the 23 areas proposed for wilderness in House 

Resolution 987 and the 18 Areas of Special Interest in the 1999 ROD in a natural 

condition. Approximately 18 percent of the IRAs would be allocated to development 

LUDs under this alternative, compared to 26 percent under Alternative 5 (No 

Action). Approximately 2.0 percent of the existing IRAs would potentially be 

harvested under this alternative (Table 3.19-6). 

Alternative 4 

Alternative 4 would provide for a mix of National Forest uses, with a greater 

emphasis on timber production relative to Alternatives 1, 2, 3, 5, and 6. Timber 

management would occur in some IRAs not managed for timber production in the 

current Forest Plan. Approximately 36 percent of the IRAs would be allocated to 

development LUDs under this alternative, compared to 26 percent under Alternative 

5 (No Action). Approximately 5.2 percent of the existing IRAs would potentially be 

harvested under Alternative 4 (Table 3.19-6). 
 Environment and Effects 3 

Final EIS 3-453 Roadless 

Alternatives 5 and 6 

Alternative 5 (No Action) is the current Forest Plan (1997 ROD, as amended) and 

provides for a moderately high level of timber production along with strong resource 

protection measures. Alternative 6 (Proposed Action) is similar to Alternative 5 (No 

Action), but includes an expansion of the old-growth reserves and other adjustments 

to the Plan based on information generated during the recent 5-Year Plan Review, 

minor clarifications, and updates. 

Approximately 26 and 24 percent of existing IRAs would be allocated to 

development LUDs under Alternatives 5 and 6, respectively. Approximately 3.3 and 

3.2 percent would potentially be harvested under Alternatives 5 and 6, respectively. 

Alternative 7 

Alternative 7 would emphasize timber production relative to the other alternatives. 

Timber would be managed on a larger land base than under Alternative 4. 

Approximately 39 percent of the IRAs would be allocated to development LUDs 

under this alternative and approximately 6.1 percent would potentially be harvested 

(Table 3.19-6). 

This section considers the incremental effects of the alternatives when added to 

other past, present, and reasonably foreseeable actions. The effects of past and 

present actions on roadless areas are included in the affected environment portion 

of this section, which discusses the existing IRAs on the Tongass. IRAs are 

identified based on past actions—specifically, timber harvest and road development, 

with all areas on the Forest within 1,200 feet of an existing road or within 600 feet of 

an existing harvest unit considered developed. Present actions include the impacts 

of current management policies on roadless areas. 

Reasonably foreseeable actions on NFS lands include the projected levels of future 

timber harvest and road construction. The direct and indirect effects analysis 

assesses the impacts of these actions on roadless areas under each alternative in 

terms of the percent of the IRAs that would be allocated to development LUDs and 

considered suitable for harvest. 

Other reasonably foreseeable actions include transportation and utility 

developments proposed by the State of Alaska. These proposals are summarized 

in the Transportation and Utilities section of this document and in the Introduction to 

Chapter 3. A total of 2,657 miles of roads are projected to be constructed on nonNFS lands throughout all of Southeast Alaska after full implementation of the plan 

(100+ years) under each of the alternatives (see Table 3.12-3). Most of the 

projected non-NFS roads are forest roads that would be developed for timber 

harvest, but the total miles also include road corridors that would connect different 

communities and connect additional areas in Southeast Alaska to the continental 

highway system. A number of these state-proposed corridors covered by Public 

Law 109-59, would, if approved under NEPA and funded, cross IRAs. The Lynn 

Canal Highway corridor, for example, crosses IRAs 301-Juneau-Skagway Icefield 

and 305-Juneau Urban, north of Juneau. The Sitka to Baranof Warm Springs road 

corridor crosses IRAs 331-Sitka Urban and 330-North Baranof. The Bradfield Canal 

road corridor crosses a number of IRAs, including 208-Bradfield and 207-Harding. 

If one or more of these or the other state-proposed corridors that cross IRAs were 

developed, the overall effect would be a reduction in the existing IRAs. It is not 

possible at this time to predict exactly which roads would be developed. None of the 

alternatives is expected to affect this type of future road development, which would 

be expected to go or not go forward regardless of the selected alternative. The 

overall cumulative effect of these regional road corridors viewed in conjunction with 

the proposed Forest Plan alternatives would be a reduction in existing IRAs. This 

trend would be would be most pronounced under Alternative 7 and least 

Cumulative 

Effects 
3 Environment and Effects

Roadless 3-454 Final EIS

pronounced under Alternative 1, which, with the exception of potential regional 

transportation corridors, would virtually all remaining IRAs in a natural condition. 

New utility line projects, if they were to go forward, would have similar effects. 

Potential utility projects include power lines between Juneau and Skagway, Juneau 

and Hoonah, Hoonah and Tenakee Springs, Tenakee Springs and Angoon, Angoon 

and Sitka, Sitka and Kake, Kake and Petersburg, Thorne Bay and Ketchikan, and 

Klawock and Hydaburg. Also planned are powerlines between the proposed Lake 

Dorothy, Otter Creek, Thayer Lake, and Sunrise Lake Hydroelectric Projects and 

existing powerlines or communities. A powerline from the Tyee hydropower site 

along a potential Bradfield Canal/Craig River road corridor route to Canada is also a 

potential route that has been considered. None of the alternatives would affect 

these developments, which would be expected to go or not go forward regardless of 

the selected alternative. The overall cumulative effects if one or more of the utility 

projects that cross IRAs were developed would be a reduction in the existing IRAs; 

this would be most pronounced under Alternative 7 and least pronounced under 

Alternative 1. 

The Tongass National Forest comprises about 78 percent of the land area of 

Southeast Alaska. Over 90 percent of the Tongass is currently roadless or 

wilderness. The other major land ownership in Southeast Alaska is Glacier Bay 

Park and Preserve (12.5 percent of Southeast Alaska), the vast majority of which is 

managed as wilderness by the National Park Service. In addition, the State of 

Alaska and the Bureau of Land Management manage another 6 percent of 

Southeast Alaska, a large portion of which is roadless. Combining all ownerships, 

approximately 90 percent of Southeast Alaska is currently roadless. In addition, it is 

estimated that at least 70 percent of all existing IRAs would remain roadless under 

any of the alternatives after 100+ years of Forest Plan implementation. As a result, 

it is estimated that at least 73 percent of Southeast Alaska would remain in 

wilderness or roadless after 100+ years (assuming all non-NFS lands become 

roaded, except for Glacier Bay and 50 percent of non-NFS lands in the 

Haines/Skagway area). Although these percentages remain high, it is likely that a 

higher proportion of lower elevation lands containing POG forest would become 

roaded over the long term. 
 Environment and Effects 3 

Final EIS 3-455 Wilderness 

Wilderness 

Affected Environment.................................................................................3-455

Introduction...............................................................................................3-455

Wilderness Overview................................................................................3-455

Wilderness in Alaska and the Tongass....................................................3-457

Relative Contribution of Tongass Wilderness ..........................................3-458

Wilderness Management in Alaska..........................................................3-464

Environmental Consequences...................................................................3-467

Direct and Indirect Effects ........................................................................3-467

Cumulative Effects....................................................................................3-467

Affected Environment 

This section provides a general overview of wilderness, describes existing 

wilderness in Alaska and on the Tongass National Forest, discusses the relative 

contribution of Tongass wilderness to the National Wilderness Preservation System, 

and addresses wilderness management direction in Alaska. The only other National 

Forest in Alaska, the Chugach National Forest, currently has no designated 

wilderness, but includes 2 million acres of wilderness study area. 

Roadless areas within the Tongass National Forest were evaluated for 

recommendations as potential wilderness in the 2003 Forest Plan Supplemental EIS 

(SEIS) (USDA Forest Service 2003b). The 2003 SEIS evaluated eight alternatives 

that ranged from no new recommended wilderness to 9.6 million acres (all 

inventoried roadless areas) of new recommended wilderness. None of the 

alternatives evaluated in this EIS includes new Wilderness or LUD II 

recommendations. 

The Wilderness Act of 1964 defines wilderness “as an area where the earth and its 

community of life are untrammeled by man, where man himself is a visitor who does 

not remain.” The Act further elaborates on the definition to mean: 

an area of undeveloped federal land retaining its primeval character and 

influence, without permanent improvements or human habitation, which is 

protected and managed so as to preserve its natural conditions and which 

1) generally appears to have been affected primarily by the forces of 

nature, with the imprint of man’s work substantially unnoticeable; 2) has 

outstanding opportunities for solitude or a primitive and unconfined type of 

recreation; 3) has at least five thousand acres of land or is of sufficient size 

as to make practicable its preservation and use in an unimpaired condition; 

and 4) may also contain ecological, geological, or other features of 

scientific, educational, scenic, or historical value. 

Wilderness Character 

The Wilderness Act does not define wilderness character, but according to Landres 

et al. (2005), wilderness character may be described as the “combination of 

biophysical, experiential, and symbolic ideals that distinguish wilderness from all 

other lands.” Landres et al. identify four qualities of wilderness that may be used to 

approximate wilderness character for the purposes of monitoring changes to 

wilderness character over time. These qualities, which were identified based on the 

Definition of Wilderness, Section 2(c) from the 1964 Wilderness Act, and are 

described below, are equally important and reinforce one another. 

Introduction 

Wilderness 

Overview 
3 Environment and Effects

Wilderness 3-456 Final EIS

Untrammeled—The Wilderness Act states that wilderness is “an area where the 

earth and its community of life are untrammeled by man” and “generally appears to 

have been affected primarily by the forces of nature.” This quality refers to 

wilderness being essentially unhindered and free from modern human control or 

manipulation. 

Natural—The Wilderness Act states that wilderness is “protected and managed so 

as to preserve its natural conditions.” This quality refers to the intended and 

unintended effects of modern people on ecological systems inside wilderness since 

the time of designation. 

Undeveloped—The Wilderness Act states that wilderness is “an area of 

undeveloped federal land retaining its primeval character and influence, without 

permanent improvements or human habitation.” The undeveloped quality refers to 

the presence of structures, construction, habitations, and other evidence of modern 

human presence or occupation, including the development level of trails and 

campsites. 

The undeveloped quality also refers to the absence of mechanical transport and 

motorized equipment. Wilderness was partly established “in order to assure 

that...growing mechanization, does not occupy and modify all areas within the 

United States...” (Wilderness Act, Section 2a). 

Outstanding opportunities for solitude or a primitive and unconfined type of 

recreation—The Wilderness Act states that wilderness has “outstanding 

opportunities for solitude or a primitive and unconfined type of recreation.” This 

quality includes the values of inspiration and physical and mental challenge. 

Primitive recreation in wilderness has largely been interpreted as travel by 

nonmotorized and nonmechanical means. It also encompasses reliance on 

personal skills to travel and camp in an area. Unconfined encompasses attributes 

such as self-discovery, exploration, and freedom from societal and managerial 

controls. 

The existing wilderness on the Tongass was established under the 1980 Alaska 

National Interest Lands Conservation Act (ANILCA) and the 1990 Tongass Timber 

Reform Act (TTRA), which subsequently amended ANILCA. In ANILCA, Congress 

reaffirmed and expanded upon the purposes of wilderness as stated in the 1964 

Wilderness Act, specifically for wilderness established in Alaska. In recognition of 

unique situations and established uses in Alaska, ANILCA also provided a number 

of important specific exceptions to the prohibitions of the Wilderness Act. These 

included exceptions related to subsistence, access, and public use cabins among 

others. These exceptions are addressed in detail in the final part of this Affected 

Environment section and also apply to wilderness established under TTRA. 

Wilderness Values 

People value wilderness for a variety of reasons, but most reasons involve three 

central themes: the experiential value, the scientific and ecological resource value, 

and the symbolic and spiritual values (slightly modified from Hendee and Dawson 

2002). The experiential value is the direct value of the wilderness experience. The 

experience is seen as valuable in its own right because of its primitive recreation, 

aesthetic, closeness to nature, education, freedom, solitude, simplicity, spiritual, and 

mystical dimensions. The value of wilderness as a scientific and ecological 

resource includes the importance of wilderness to science, including its importance 

in preservation of fauna and flora, particularly those species requiring large tracts of 

unmodified habitats. Finally, the symbolic and spiritual values of wilderness are 

represented by the high values some people place on the knowledge that 

wilderness exists, whether they use it or not. In a world characterized by rapid 

change and complexity, wilderness symbolizes comforting stability and simplicity to 

many. 
 Environment and Effects 3 

Final EIS 3-457 Wilderness 

Congress has the sole authority for designating additions to the National Wilderness 

Preservation System. Congressionally designated wilderness on the Tongass 

National Forest comes from two pieces of legislation: ANILCA of 1980 and TTRA of 

1990. Fourteen wildernesses totaling 5.5 million acres were established under 

ANILCA. Two of these areas, Admiralty Island and Misty Fiords, are also 

designated as National Monuments. Prior to ANILCA, there was no designated 

wilderness on the Tongass. TTRA subsequently amended ANILCA and designated 

five new wildernesses and one wilderness addition totaling 296,080 acres. As a 

result of these two pieces of legislation, there are currently 5.8 million acres of 

wilderness on the Tongass in 19 separate wildernesses (Table 3.20-1). 

Wilderness recommendations were not considered in the 1997 Forest Plan Final 

EIS and Record of Decision (ROD) because additional wilderness had been created 

under TTRA. In March 2001, the U.S. District Court of Alaska ruled in response to a 

lawsuit filed by the Sierra Club (Sierra Club v. Lyons) and other environmental 

groups that the 1997 Final EIS should have considered making additional 

wilderness recommendations and ordered the Forest Service to prepare a 

Supplemental EIS (SEIS) to evaluate wilderness recommendations and update the 

Analysis of the Management Situation (AMS) relative to roadless areas and their 

relative contribution to the National Wilderness Preservation System. The Forest 

Service subsequently updated the AMS and determined the eligibility of each of the 

inventoried roadless areas for wilderness recommendation. Eight alternatives that 

identified roadless areas within the Tongass for recommendation as potential 

wilderness were evaluated in a Final SEIS to the 1997 Forest Plan Final EIS in 2003 

(USDA Forest Service 2003b). The ROD for the Final SEIS concluded that it was 

not “the appropriate time for significantly changing land use designations on the 

Tongass National Forest” and did not recommend any additional wilderness on the 

Tongass at that time (USDA Forest Service 2003b). 

The wilderness acreages summarized in Table 3.20-1 reflect the legal descriptions 

as reported to Congress. These acres are not exactly the same as those generated 

by the geographic information system (GIS) used in the analysis for the 1997 

Tongass Forest Plan Revision Final EIS or for this Final EIS. The differences are 

due to different resolutions in mapping and the method of generating acres. The 

1997 Final EIS used a point grid system to measure acreage using the GIS, based 

on the legal descriptions. This Final EIS measures the area based on the mapped 

GIS polygons. In addition, there were slight differences in mapping small islands or 

large rocks in saltwater. These differences in measurement and mapping result in a 

total wilderness acreage of 5,756,472, compared to the legal description total of 

5,752,221. This represents a difference of less than 0.1 percent. The slightly higher 

total is used in this document for the purposes of analysis. 

Wilderness in 

Alaska and the 

Tongass 
3 Environment and Effects

Wilderness 3-458 Final EIS

Table 3.20-1 

Existing Wildernesses on the Tongass National Forest

Name Total Acres 

Non-National 

Forest Acres 

National 

Forest Acres 

Wildernesses Established December 2, 1980, by ANILCA

Kootznoowoo Wilderness (Admiralty Island National Monument) 988,0501 32,129 955,8581 

Coronation Island Wilderness 19,232 0 19,232 

Endicott River Wilderness 98,729 0 98,729 

Maurelle Islands Wilderness 4,937 0 4,937 

Misty Fiords National Monument Wilderness 2,142,907 600 2,142,307 

Petersburg Creek-Duncan Salt Chuck Wilderness 46,849 0 46,849 

Russell Fiord Wilderness 348,701 0 348,701 

South Baranof Wilderness 319,568 0 319,568 

South Prince of Wales Wilderness 91,018 50 90,968 

Stikine-LeConte Wilderness 449,951 1,025 448,926 

Tebenkof Bay Wilderness 66,839 27 66,812 

Tracy Arm-Fords Terror Wilderness 653,179 0 653,179 

Warren Island Wilderness 11,181 0 11,181 

West Chichagof-Yakobi Wilderness 265,529 1,038 264,491 

Wildernesses Established November 28, 1990, by TTRA

Chuck River Wilderness 74,990 692 74,298 

Karta Wilderness 39,894 5 39,889 

Kuiu Wilderness 60,581 0 60,581 

Pleasant-Lemusurier-Inian Islands Wilderness 23,151 55 23,096 

South Etolin Wilderness 83,371 752 82,619 

Total Acreage 5,788,657 36,436 5,752,221 1

 Kootznoowoo Wilderness includes 18,486 acres, including 24 acres of Non-National Forest System lands in the Young Lake 

Addition established by TTRA, November 28, 1990. 

Source: Total acreages are as reported to Congress with official boundary maps. These wildernesses include only the public 

lands above mean high tide. 

General Perspective 

The National Wilderness Preservation System includes almost 105 million acres. 

More than half of this acreage is in Alaska (Figure 3.20-1). In addition to having the 

largest land area in wilderness, Alaska also has the highest percentage of its land 

area in wilderness among the 50 states (Figure 3.20-2). The states with both the 

greatest land area and highest percent land area in wilderness are Alaska, 

California, Washington, Idaho, and Arizona (Landres and Meyer 2000). 

In addition to having the greatest amount of land and the highest percentage of its 

land base in wilderness, Alaska also has the highest number of wilderness acres 

per resident, with almost 90 acres per resident. This ratio increases to slightly more 

than 120 acres per resident when only Southeast Alaska is considered. The next 

closest state is Wyoming with about 6 acres of wilderness per resident. 

Existing wilderness on the Tongass, approximately 5.8 million acres, represents 

about 34 percent of the forest land base and 28 percent of the land in Southeast 

Alaska. Viewed on a national basis, existing wilderness on the Tongass represents 

17 percent of all wilderness on National Forest System (NFS) lands and 5.5 percent 

of all lands in the National Wilderness Preservation System (USDA Forest Service 

2000a). 

Two of the largest wildernesses on the Tongass, Misty Fiords National Monument 

Wilderness (2.1 million acres) and Kootznoowoo (Admiralty Island) Wilderness 

(almost 1 million acres), contain vast, virtually intact ecosystems. Five other 

wildernesses are each more than 250,000 acres. The wildernesses of the Tongass 

are mostly in a pristine condition, with the imprint of humans generally not 

noticeable. They offer outstanding opportunities for solitude and primitive 

recreation. 

Relative 

Contribution of 

Tongass 

Wilderness 
 Environment and Effects 3 

Final EIS 3-459 Wilderness 

In the remainder of this section, the Tongass National Forest is evaluated in terms of 

how well its landforms and ecosystems are represented in existing wilderness (and 

LUD II areas). Four ways of classifying the Tongass landforms and ecosystems are 

considered, ranging from very broad (e.g., ecoregions, with two categories covering 

the Tongass) to fairly detailed (e.g., ecological subsections, with 73 categories 

covering the Tongass). 

Ecoregions 

DeVelice and Martin (2001) provide a national summary of acreage in National 

Forest roadless areas versus designated wilderness, National Parks, and other 

areas primarily managed to maintain natural values (i.e., conservation reserves). In 

Alaska, all but 1 of 15 ecoregions (as defined by Ricketts et al. 1999) have greater 

than 12 percent of its area in reserves. No other region in the country surpasses 

Alaska in ecological representation in reserves. 

Two ecoregions cover the Tongass National Forest: the Northern Pacific Coastal 

Forest and the Pacific Coastal Mountain Tundra and Ice Fields (Ricketts et al. 

1999). These two ecoregions extend from eastern Kodiak Island to the southern 

end of the Alaska panhandle. Approximately 19 percent of the Northern Pacific 

Coastal Forest and 37 percent of the Pacific Coastal Mountain Tundra and Ice 

Fields ecoregions are in reserves (DeVelice and Martin 2001). The portions of both 

of these areas protected in wilderness are well above the 12 percent threshold 

considered by some authorities (e.g., World Commission on Environment and 

Development 1987) as the minimum area for representation (DeVelice and Martin 

2001). 

Figure 3.20-1. Acres of Wilderness by State 

Wilderness 
3 Environment and Effects

Wilderness 3-460 Final EIS

Figure 3.20-2. Percentage of Land Area in Wilderness by State 

When the acreage of inventoried roadless areas is added to the acreage of 

conservation reserves in the two ecoregions, the percentage increases to 

64 percent for the Northern Pacific Coastal Forest and 66 percent for the Pacific 

Coastal Mountain Tundra and Ice Fields ecoregions (DeVelice and Martin 2001). 

These values are in the 25 to 75 percent range that Noss and Cooperrider (1994) 

argue is required to achieve representation and are substantially higher than the 

12 percent threshold. 

When one considers only NFS lands, the percentage of NFS lands area in 

wilderness in these ecoregions is 25 percent for the Northern Pacific Coastal Forest 

and 21 percent for the Pacific Coastal Mountain Tundra and Ice Fields. If all 

inventoried roadless areas are counted along with wilderness, the total area of 

wilderness plus inventoried roadless areas on the Tongass in these ecoregions 

increases to 69 percent and 79 percent, respectively (DeVelice and Martin 2001). 

Land Cover Classes 

The various wildland ecosystems of Southeast Alaska are generally represented 

within the Tongass’ wilderness. These areas include glaciers and ice fields, 

off-shore islands and seacoasts facing both the open Pacific Ocean and inland 

passages, major river systems, and 1.5 million acres of old-growth temperate rain 

forests. Viewed in terms of broad National Forest land cover classes, designated 

Wilderness on the Tongass exceeds 12 percent of the area in five land cover 

classes that are prevalent in Southeast Alaska. These five classes are: 

1) Evergreen Forest (23 percent), 2) Tundra (15 percent), 3) Barren Land (37 

percent), 4) Water (23 percent), and 5) Glaciers-Snow (15 percent). Designated 

15 Other States Have Less Than 1% Wilderness Designated 
 Environment and Effects 3 

Final EIS 3-461 Wilderness 

Wilderness does not exceed 12 percent of the area for Deciduous Forest 

(0 percent), Mixed Forest (0 percent), and Shrub-Brush (9 percent) (Martin et al. 

2000). However, these latter three land cover types are not prevalent in Southeast 

Alaska. 

Biogeographic Provinces 

The extent to which identifiable landform types and ecosystems are represented in 

the wildernesses (and other natural setting LUDs) of the Tongass National Forest is 

addressed by reviewing the extent to which the biogeographic provinces of 

Southeast Alaska are represented. The Tongass can be subdivided into 21 

biogeographic provinces characterized by similar species composition, similar 

patterns in distribution for many species, similar geologic barriers and historic events 

(such as glaciation), and similar climatic conditions. These provinces are discussed 

in the Biodiversity section of this chapter. Table 3.20-2 identifies the percentage of 

each biogeographic province that is included in existing wilderness. This table also 

identifies the percentage in LUD II areas because these are Congressionally 

designated areas managed for long-term protection to retain their wildland 

character. It also includes the percentage of each biogeographic province in other 

natural setting LUDs. 

Table 3.20-2 

Percent of Each Biogeographic Province in Wilderness, LUD II, or other Natural 

Setting LUD (within the Tongass National Forest boundary)

Province 

Percent in 

Wilderness or 

National 

Monument 

Percent in 

LUD II 

Percent 

in Other 

Natural 

Setting 

LUDs1 

Total Percent 

in Wilderness 

or Natural 

Setting LUDs1 

1 Yakutat Forelands 2% 39% 38% 79% 

2 Yakutat Uplands 37% 0% 62% 100% 

3 East Chichagof Island 6% 25% 16% 47% 

4 West Chichagof Island 81% 6% 12% 99% 

5 East Baranof Island 23% 0% 50% 73% 

6 West Baranof Island 29% 0% 55% 84% 

7 Admiralty Island 90% 0% 5% 96% 

8 Lynn Canal 15% 6% 58% 78% 

9 North Coast Range 23% 0% 48% 71% 

10 Kupreanof/Mitkof Island 6% 0% 27% 32% 

11 Kuiu Island 26% 1% 38% 64% 

12 Central Coast Range 38% 0% 37% 75% 

13 Etolin Island 16% 0% 25% 41% 

14 North Central Prince of Wales 3% 5% 28% 35% 

15 Revilla Island/Cleveland 18% 5% 35% 58% 

16 South Outer Islands 16% 33% 23% 72% 

17 Dall Island and Vicinity 0% 0% 51% 51% 

18 South Prince of Wales 22% 5% 33% 61% 

19 North Misty Fiords 82% 0% 14% 96% 

20 South Misty Fiords 100% 0% 0% 100% 

21 Ice Fields 33% 0% 62% 95% 

 Total 33% 4% 37% 74% 

1 Note that totals may not add due to rounding.
3 Environment and Effects

Wilderness 3-462 Final EIS

Seventeen of the 21 biogeographic provinces on the Tongass have 20 percent or 

more of their lands within the National Forest boundary, in Wilderness, National 

Monument, or LUD II areas; 18 of the 21 have 15 percent or more. Three 

provinces—Dall Island and Vicinity, Kupreanof/Mitkof Island, and North Central 

Prince of Wales—have from 0 to 8 percent in Wilderness, National Monument, or 

LUD II areas. However, these areas have from 32 to 51 percent of their land areas 

within wilderness or natural setting LUDs. Overall, 17 of the 21 provinces have 

more than 50 percent of their land areas in either wilderness or natural setting 

LUDs. The remaining four have 32 to 47 percent. 

Ecological Subsections 

The extent to which identifiable landform types and ecosystems are represented in 

wilderness LUDs (and other natural setting LUDs) of the Tongass can also be 

evaluated by reviewing the extent to which the ecological subsections of Southeast 

Alaska are represented (Nowacki et al. 2001). These subsections are discussed in 

the Biodiversity section of this chapter. Table 3.20-3 identifies the percentage of 

each subsection that is covered by existing Wilderness (or National Monument), 

LUD II areas, and other natural setting LUDs.

Table 3.20-3 

Percent of Each Ecological Subsection in Wilderness, LUD II, or Other Natural 

Setting LUD (within the Tongass National Forest boundary)

Number Ecological Subsection 

Percent in 

Wilderness 

or National 

Monument 

Percent in 

LUD II 

Percent in 

Other Natural 

Setting 

LUDs1 

Total Percent 

in Wilderness 

or Natural 

Setting LUDs1 

 M244Ca St. Elias-Fairweather Icefields 27% 1% 70% 98% 

 M244Cb Puget Peninsula Metasediments 100% 0% 0% 100% 

 M245Bc Yakutat-Lituya Forelands 9% 33% 39% 80% 

 M246Aa Chilkat Complex 0% 0% 95% 95% 

 M246Ba Boundary Ranges Icefields 32% 1% 61% 94% 

 M246Bb Stikine-Taku River Valleys 43% 0% 53% 97% 

 M247Ac Wachusett-Adams Hills 100% 0% 0% 100% 

 M247Ag Berg Bay Complex 99% 0% 0% 99% 

 M247Ak Chilkat Peninsula Carbonates 26% 0% 51% 77% 

 M247Bb North Chichagof Granitics 19% 38% 15% 72% 

 M247Bc Outer Coast Wave-cut Terraces 75% 0% 21% 96% 

 M247Bd West Chichagof Complex 94% 6% 0% 99% 

 M247Be Ushk-Patterson Bay Granitics 19% 43% 6% 67% 

 M247Bf Peril Strait Granitics 0% 25% 15% 40% 

 M247Bg North Baranof Complex 0% 0% 36% 36% 

 M247Bh Sitka Sound Complex 0% 0% 67% 67% 

 M247Bi Mount Edgecumbe Volcanics 0% 0% 75% 75% 

 M247Bj Central Baranof Metasediments 20% 0% 64% 84% 

 M247Bk Necker Bay Granitics 83% 0% 16% 100% 

 M247Bl South Baranof Sediments 32% 0% 68% 100% 

 M247Ca Point Adolphus Carbonates 0% 16% 32% 48% 

 M247Cb Freshwater Bay Carbonates 0% 0% 28% 28% 

 M247Cc Kook Lake Carbonates 0% 15% 16% 31% 

 M247Da Stephens Passage Glaciomarine 

Terraces 

36% 5% 31% 72% 

 M247Db North Admiralty Complex 82% 0% 7% 89% 

 M247Dc Stephens Passage Volcanics 58% 0% 26% 84% 

 M247Dd Thayer Lake Granitics 100% 0% 0% 100% 

 M247De Mitchell-Hasselborg Till Lowlands 100% 0% 0% 100% 
 Environment and Effects 3 

Final EIS 3-463 Wilderness 

Table 3.20-3 (continued) 

Percent of Each Ecological Subsection in Wilderness, LUD II, or Other Natural 

Setting LUD (within the Tongass National Forest boundary) 

Number Ecological Subsection 

Percent in 

Wilderness 

or National 

Monument 

Percent in 

LUD II 

Percent in 

Other Natural 

Setting 

LUDs1 

Total Percent 

in Wilderness 

or Natural 

Setting LUDs1 

 M247Df Hood-Gambier Bay Carbonates 98% 0% 0% 98% 

 M247Dg South Admiralty Volcanics 100% 0% 0% 100% 

 M247Ea Holkham Bay Complex 32% 0% 28% 60% 

 M247Eb Cape Fanshaw Complex 0% 0% 29% 29% 

 M247Ec Thomas Bay Outwash Plains 0% 0% 25% 25% 

 M247Ed Wrangell Narrows Metasediments 11% 0% 18% 29% 

 M247Ee Eastern Passage Complex 23% 3% 29% 55% 

 M247Ef Stikine River Delta 77% 0% 5% 82% 

 M247Eg Bell Island Granitics 14% 9% 57% 81% 

 M247Eh Stikine Strait Complex 0% 0% 42% 42% 

 M247Ei Etolin Granitics 37% 0% 19% 55% 

 M247Ej Zimovia Strait Complex 5% 0% 26% 30% 

 M247Ek Clarence Strait Volcanics 15% 0% 34% 50% 

 M247El Ketchikan Mafics/Ultramafics 0% 0% 46% 46% 

 M247Em Vixen Inlet Till Lowlands 0% 0% 40% 40% 

 M247En Traitors Cove Metasediments 0% 10% 26% 36% 

 M247Eo Behm Canal Complex 65% 0% 18% 83% 

 M247Fa Kuiu-POW Granitics 19% 23% 36% 78% 

 M247Fb Rowan Sediments 27% 0% 27% 54% 

 M247Fc North POW-Kuiu Carbonates 0% 2% 25% 27% 

 M247Fd Alvin Bay Sediments 53% 0% 25% 78% 

 M247Fe Affleck Canal Till Lowlands 38% 2% 60% 100% 

 M247Ff North POW Complex 0% 28% 18% 46% 

 M247Fg Elevenmile Till Lowlands 0% 0% 52% 52% 

 M247Fh Gulf of Esquibel Till Lowlands 12% 40% 48% 100% 

 M247Fi Klawock Inlet Till Lowlands 0% 0% 7% 7% 

 M247Fj Soda Bay Till Lowlands 0% 0% 44% 44% 

 M247Ga Kake Volcanics 0% 0% 23% 23% 

 M247Gb Duncan Canal Till Lowlands 6% 0% 35% 41% 

 M247Gc Sumner Strait Volcanics 0% 1% 32% 32% 

 M247Gd Central POW Till Lowlands 0% 3% 42% 45% 

 M247Ge Kasaan Peninsula Volcanics 0% 0% 21% 21% 

 M247Gf Skowl Arm Till Lowlands 0% 0% 29% 29% 

 M247Ha Outer Islands Complex 100% 0% 0% 100% 

 M247Hb Dall-Outside Complex 0% 19% 40% 59% 

 M247Ia Central POW Volcanics 8% 0% 23% 31% 

 M247Ib Hetta Inlet Metasediments 1% 9% 14% 25% 

 M247Ic Moira Sound Complex 23% 0% 35% 59% 

 M247Ja South POW Granitics 39% 0% 48% 88% 

 M247Jb Duke Island Till Lowlands 0% 0% 72% 72% 

 M247Jc Thorne Arm Granitics 19% 0% 40% 58% 

 M247Jd Princess Bay Volcanics 62% 0% 8% 70% 

 M247Je Foggy Bay Till Lowlands 100% 0% 0% 100% 

 M247Jf Boca De Quadra Complex 100% 0% 0% 100% 

 M247Ka Misty Fiords Granitics 96% 0% 2% 98% 

Total 33% 4% 37% 74% 1 Note that totals may not add due to rounding.
3 Environment and Effects

Wilderness 3-464 Final EIS

Forty-two of the 73 ecological subsections on the Tongass National Forest have 20 

percent or more of their lands inside the National Forest boundary within 

Wilderness, National Monument, or LUD II areas; 47 of the 73 subsections have 15 

percent or more. Twenty-six of the subsections are not represented in Wilderness, 

National Monument, or LUD II areas. All of these subsections are represented in 

natural setting LUDs. Sixteen of the 17 ecological subsections with no Wilderness, 

National Monument, or LUD II representation have more than 20 percent of their 

areas in natural setting LUDs. The Klawock Inlet Till Lowlands has only 7 percent in 

natural setting LUDs. 

Monitoring has been minimal in most of the wilderness, but some resource damage 

and user conflicts have been observed in localized concentrated use areas. 

Monitoring in some of the more remote areas, such as the South Prince of Wales 

and Coronation Island wildernesses, indicates very little use but some resource 

damage and occupancy trespass. The areas with the greatest use and most 

management activities tend to have the greatest need for additional management 

direction to help resolve user conflicts and preserve the wilderness resource. 

Implementation of existing direction has varied greatly between the various 

wildernesses. Some areas, such as Kootznoowoo (Admiralty Island) and Misty 

Fiords Wildernesses, have had significant management programs and 

accomplishments, while others have had minimal management activities. Some of 

these activities, such as fisheries enhancement projects and the authorization of 

temporary facilities for the taking of fish and wildlife, have resulted in administrative 

appeals by user groups who view these activities as conflicting with their use or 

wilderness values. 

Management under the Wilderness Act 

The Wilderness Act of 1964 mandates that designated “wilderness areas ... shall be 

administered for the use and enjoyment of the American people in such a manner 

as will leave them unimpaired for future use and enjoyment as wilderness, and so as 

to provide for the protection of these areas, the preservation of their wilderness 

character, and for the gathering and dissemination of information regarding their use 

and enjoyment as wilderness.” 

Subject to existing private rights, the Act prohibits permanent roads and, except as 

necessary for realizing the recreation and other wilderness purposes of the area, 

commercial enterprises. Temporary roads, the use of motor vehicles, motorized 

equipment, other mechanized equipment, motorboats, the landing of aircraft, and 

structures and installations are prohibited except as necessary to meet minimum 

requirements for the administration of the area as wilderness. The Act provides that 

the use of aircraft or motorboats, where these uses have already become 

established, may be permitted to continue subject to restrictions by the Secretary of 

Agriculture. Wildernesses were withdrawn from mineral entry as of December 31, 

1983, and patenting of valid claims is limited to subsurface mineral rights. 

Management under the Alaska National Interest Lands Conservation Act 

In ANILCA, Congress reaffirmed and expanded upon the purposes of wilderness as 

stated in the Wilderness Act of 1964, specifically for wilderness established in 

Alaska. In recognition of unique situations and established uses in Alaska, ANILCA 

also provided a number of important specific exceptions to the requirements of the 

Wilderness Act. These apply equally to TTRA Wilderness. 

Wilderness 

Management in 

Alaska 
 Environment and Effects 3 

Final EIS 3-465 Wilderness 

Subsistence Policy 

Section 811 mandates that the Secretary “shall ensure that rural residents engaged 

in subsistence uses shall have reasonable access to subsistence resources on 

public lands.” This section further directs that, other laws (including the Wilderness 

Act) notwithstanding, the Secretary “shall permit on the public lands appropriate use 

for subsistence purposes of snowmobiles, motorboats, and other means of surface 

transportation traditionally employed for such purposes by local residents, subject to 

reasonable regulation.” 

Transportation and Utility Systems 

Section 1105 provides that in any case in which there is no applicable law with 

respect to a transportation or utility system, the head of the federal agency 

concerned shall make recommendations to authorize the system within the 

Conservation Unit concerned (including Wilderness) if he determines that the 

system would be compatible with the purposes for which the unit was established, 

and there is no economically feasible and prudent alternative route for the system. 

ANILCA (Section 506) includes specific exceptions for Admiralty Island National 

Monument Wilderness regarding the right to develop hydroelectric resources and 

public access and use. 

Special Access 

Section 1110(a) requires that the Secretary “shall permit” on Conservation Units, 

which include Wilderness, “the use of snowmachines (during periods of adequate 

snow cover or frozen river conditions, in the case of Wild or Scenic rivers), 

motorboats, airplanes, and nonmotorized surface transportation methods for 

traditional activities (where such activities are permitted by this Act or other law) and 

travel to and from villages and homesites.” Such use is subject to reasonable 

regulation, but shall not be prohibited unless after notice and hearing the Secretary 

finds that such use would be detrimental to the resource values of the area. 

Inholding Access 

Section 1110(b) assures adequate and feasible access to state and private land and 

to valid occupancies, including valid mining claims. 

Navigation Aids and Facilities 

Section 1310(a) provides that reasonable access to, and operation and 

maintenance of, existing air and water navigation aids, communication sites, 

facilities for national defense, and related facilities and existing facilities for weather, 

climate and fisheries research, and monitoring shall be permitted. “Nothing in the 

Wilderness Act shall be deemed to prohibit such access, operation and 

maintenance within wilderness areas designated by this Act.” Section 1310(b) 

provides that the establishment, operation, and maintenance of new such facilities 

shall be permitted within wilderness after consultation with the Secretary and in 

accordance with mutually agreed upon terms and conditions to minimize the 

adverse effects within the unit. 

Aquaculture 

Section 1315(b) provides that the Secretary may permit fishery research, 

management, enhancement, and rehabilitation activities within National Forest 

System Wilderness, in a manner that adequately assures protection, preservation, 

enhancement, and rehabilitation of the wilderness resource. Subject to reasonable 

regulations, permanent improvements and facilities such as fishways, fish weirs, fish 

ladders, fish hatcheries, spawning channels, stream clearance, egg planting, and 
3 Environment and Effects

Wilderness 3-466 Final EIS

other accepted means of maintaining, enhancing, and rehabilitating fish stocks may 

be permitted. 

Public Use Cabins 

Section 1315(c) provides for the continued use, maintenance, and replacement of 

existing public use cabins within wilderness. Section 1315(d) authorizes the 

construction and maintenance of a limited number of new public use cabins and 

shelters, if necessary, for public health and safety, and also requires the Secretary 

to notify Congress of his intention to remove an existing or construct a new public 

use cabin or shelter. 

Beach Log Salvage 

Section 1315(f) allows the Secretary to permit or otherwise regulate the recovery 

and salvage of logs from the coastlines of National Forest Wilderness and National 

Monuments. 

Temporary Hunting and Fishing Facilities 

Section 1316(a) provides that the Secretary shall permit, subject to reasonable 

regulation to ensure compatibility, the continuation of existing uses and future 

establishment and use of temporary campsites, tent platforms, shelters, and other 

temporary facilities and equipment directly and necessarily related to the taking of 

fish and game. Facilities and equipment shall be constructed, used, and maintained 

in a manner consistent with the protection of the area where they are located. New 

facilities shall be constructed of materials that blend with and are compatible with 

the surrounding landscape. Section 1316(b) allows the Secretary to deny new 

facilities and equipment upon making a determination, after public notice, that the 

establishment and use of new facilities or equipment would constitute a significant 

expansion of existing facilities or uses that would be detrimental to the purposes for 

which the unit was established, including “wilderness character.” 

Other Forest Plan Restrictions 

In spite of its many exceptions to the Wilderness Act, ANILCA defines “wilderness” 

as having the same meaning as when it is used in the Wilderness Act (Sec. 

102(13)). Further, Section 707 states that, except as expressly provided in ANILCA, 

Alaskan wilderness “shall be administered in accordance with applicable provisions 

of the Wilderness Act governing areas designated by that Act as Wilderness.” 

Some of the additional restrictions identified for Tongass wilderness by the current 

Forest Plan include the following: 

♦ New roads and airstrips are not permitted, except to access state and private 

inholdings and valid mining claims, subject to stipulations for protection of 

natural and other values of the land. 

♦ Helicopter use is generally not permitted, except on a case-by-case basis. In 

the 1997 Record of Decision for the Helicopter Landings in Wilderness Final 

EIS, the Regional Forester decided not to allow establishment of helicopter 

access areas within wilderness on the Tongass National Forest for use by 

individuals and helicopter companies transporting the general public. 

♦ There is a party size limitation for outfitter/guide operations of no more than 

12 persons for any one site or activity. 

♦ No new permanent administrative facilities are allowed, except as consistent 

with ANILCA. 
 Environment and Effects 3 

Final EIS 3-467 Wilderness 

Environmental Consequences 

None of the alternatives involves recommending new areas for Wilderness or LUD II 

designation. Roadless areas within the Tongass National Forest were evaluated for 

recommendations as potential wilderness in the 2003 Forest Plan SEIS (USDA 

Forest Service 2003b). The 2003 SEIS evaluated eight alternatives that range from 

no new recommended wilderness to 9.6 million acres (all inventoried roadless 

areas) of new recommended wilderness. This evaluation and the ROD for the 2003 

SEIS are incorporated here by reference. 

Existing wilderness on the Tongass, which encompasses approximately 5.8 million 

acres and represents about 34 percent of the forest land base and 28 percent of the 

land in Southeast Alaska, would remain unchanged under all of the alternatives. 

The existing 19 wildernesses on the Tongass are identified in Table 3.20-1. The 

acres of each biogeographic province and ecological subsection presently in 

Wilderness or LUD II areas on the Tongass would also remain unchanged (see 

Tables 3.20-2 and 3.20-3). 

Alternatives 1 through 4, 6, and 7 would, however, differ from Alternative 5 (No 

Action) because under these alternatives wilderness on the Tongass would be 

managed under the updated and edited version of the current Forest Plan presented 

as Volume II to this EIS. The updated version of the Forest Plan includes 

substantial edits and clarifications to the Wilderness and Wilderness National 

Monument LUD prescriptions. These edits emphasize that wilderness should 

remain untrammeled and free from modern human control or manipulation, including 

actions taken to manage wilderness. The edits also modify the objectives of both 

LUD prescriptions to emphasize primitive Recreation Opportunity Spectrum (ROS) 

classes, rather than both primitive and semi-primitive ROS classes. Areas managed 

as semi-primitive within a wilderness are an exception and are not encouraged. In 

addition, new standards and guidelines that address forest health with respect to 

non-native, invasive species, sacred site protection activities, and karst 

management are included in the revised Wilderness and Wilderness National 

Monument LUD prescriptions. These edits and others are shown in the revised 

Forest Plan included in Volume II. 

The updated Forest Plan also provides more specific standards and guidelines with 

respect to managing recreation activities to meet appropriate levels of social 

encounters. This includes limiting group sizes to no more than 12 persons for 

commercial and general public use of a wilderness, limiting the length of stay at one 

location to 14 days, and limiting commercial recreation use to two groups of 12 

people from a single vessel (or other form of transportation), with the groups 

required to disperse out of sight and sound from each other. Implementation of 

these standards and guidelines is expected to help preserve outstanding 

opportunities for solitude and emphasize primitive recreation opportunities. 

These edits and revisions are not intended to change the management of 

Wilderness or Wilderness National Monument areas. Rather, the intent is to ensure 

that the objectives of the LUD prescriptions laid out in the current Forest Plan are 

met. As a result, with the possible exception of the revised Recreation and Tourism 

Standards and Guidelines (discussed above), there is not expected to be a 

substantial difference between Alternative 5 (No Action) and the other alternatives in 

this respect. 

There would be no change in the number of acres with Wilderness or LUD II 

designations on the Tongass under any of the alternatives. While there are edits 

and clarifications to the Wilderness and Wilderness National Monument LUD 

prescriptions under six of the alternatives, these would not substantially change the 

management of these areas. 

Direct and 

Indirect Effects 

Cumulative 

Effects 
3 Environment and Effects

Wilderness 3-468 Final EIS

The Tongass National Forest comprises about 78 percent of the land area of 

Southeast Alaska. The other major land ownership is Glacier Bay Park and 

Preserve, the vast majority of which is managed as wilderness by the National Park 

Service. Combining the Glacier Bay Wilderness with the wildernesses on the 

Tongass, nearly 40 percent of Southeast Alaska is in wilderness under existing 

conditions. Thus, the proportion of lands in wilderness in Southeast Alaska is 

substantially higher than the statewide average for Alaska (15 percent). Further, the 

State of Alaska contains more wilderness, on both an acreage and percentage 

basis, than any of the other 49 states. In addition, as discussed in the Roadless 

section of this EIS, at least 60 percent of all existing inventoried roadless areas 

would remain roadless after 100+ years of Forest Plan implementation. As a result, 

it is estimated that at least 73 percent of Southeast Alaska would remain in 

wilderness or roadless after 100+ years (assuming all non-NFS lands become 

roaded, except for Glacier Bay and 50 percent of non-NFS lands in the 

Haines/Skagway area). Thus, the potential for cumulative effects associated with 

precluding options for future wilderness is considered low. 
 Environment and Effects 3 

Final EIS 3-469 Other Special Land Use Designations 

Other Special Land Use Designations 

Affected Environment................................................................................ 3-469

Experimental Forests............................................................................... 3-469

Research Natural Areas .......................................................................... 3-470

Special Interest Areas ............................................................................. 3-472

Wild and Scenic Rivers ........................................................................... 3-474

Environmental Effects ............................................................................... 3-479

Direct and Indirect Effects ....................................................................... 3-479

Cumulative Effects................................................................................... 3-487

A number of specific areas on the Tongass National Forest that have not been 

designated as Wilderness or Land Use Designation (LUD) II areas are given special 

LUDs because they possess outstanding resources, research opportunities, or other 

factors of special interest. These areas include experimental forests, research 

natural areas, Special Interest Areas, and wild and scenic rivers. Each of these 

special areas is described, as are the effects of the alternatives on these areas, in 

this section. 

Affected Environment 

Experimental forests provide areas for conducting manipulative research that serves 

as a basis for forest management. Natural resources in experimental forests are 

used or altered under controlled scientific studies. The Tongass currently has two 

experimental forests, Maybeso and Young Bay, with a combined area of 17,260 

acres. Their locations are indicated on the alternative maps. 

Maybeso 

Established in the early 1950s as a part of an intensive research program to 

document the effects of large-scale clearcutting on hydrology, fisheries, and timber 

productivity, the Maybeso Experimental Forest (10,600 acres) is located in a large 

steep-sided alluvial valley with a south to southeast-facing aspect near the centraleastern coast of Prince of Wales Island. By the early 1960s, most of the suitable 

forest land on the experimental area had been harvested. Permanent research 

plots were established and monitored to study hillslope erosion, movement of large 

woody debris in and through streams, forest regeneration, and silvicultural 

responses to precommercial thinning. Most of these plots are still monitored. The 

upper slopes of the Maybeso watershed are included in Roadless Area 510. 

Because nearly all of the old-growth timber on the Maybeso Experimental Forest 

has been harvested, the timber in the area is primarily young growth. Consequently, 

there are limited opportunities to design new harvest-related experiments, except 

potential experiments concerning second-growth timber of up to 45 years in age. 

Only a limited variety of vegetation and timber types are now available within the 

area. 

Young Bay 

The Young Bay Experimental Forest (6,660 acres) is located just south of Juneau 

on northern Admiralty Island. Originally selected for long-term hydrologic and 

Experimental 

Forests 
Environment and Effects 3 

Other Special Land Use Designations 3-470 Final EIS

fisheries monitoring with a paired comparison between streams, this site was used 

extensively for fisheries and hydrology research in the 1960s and 1970s. 

The Young Bay Experimental Forest has an extensive terrace, or bench, underlain 

by poorly drained marine silt (the Gastineau Formation) that extends across its lower 

slopes between sea level and an elevation of 100 feet. As a result of this formation, 

part of the experimental forest is open and relatively unproductive, which is atypical 

of areas normally managed for timber production in Southeast Alaska. Young Bay 

exhibits little forest vegetation-type diversity, making its use for studies not related to 

timber production difficult. High winds often limit access to the area during winter. 

There are no roads and, to date, no experimental vegetation treatments have 

occurred. The Young Bay Experimental Forest is located entirely within the Greens 

Creek Roadless Area 307. 

The Tongass Timber Reform Act (TTRA) designated lands to the east of the Young 

Bay Experimental Forest as the “Young Lake Addition” to be managed as part of the 

Admiralty National Monument and Kootznoowoo Wilderness. 

Young Bay has been considered for delisting as an experimental forest. This area 

has limited research opportunity, and limited applicability to other areas of the 

Forest. Manipulative research may not be compatible with the adjacent 

Monument/Wilderness addition. 

Because of the TTRA legislation or other resource conflicts, Shaheen Creek, Trap 

Bay, Staney Creek and Chicken Creek watersheds, previously identified as possible 

experimental forests in the 1990 DEIS, are no longer appropriate for consideration 

and these areas were not included in the 1997 Forest Plan. 

Research Natural Areas (RNAs) are part of a national network of ecological areas 

designated for research and education and/or to maintain biological diversity of 

representative ecosystems on National Forest System (NFS) lands. RNAs are used 

for non-manipulative research, observation, and study. They also may serve to 

carry out provisions of special acts, such as the Endangered Species Act and the 

monitoring provisions of the National Forest Management Act. 

Current Situation 

Six RNAs were established within the Tongass National Forest prior to 1996. One 

of the six, Pack Creek, was declassified in the Record of Decision (ROD) for the 

1997 Tongass Land Management Plan due to a long history of human presence 

related to viewing brown bears. At the same time, Pack Creek was re-designated 

as a zoological area to be managed under the Special Interest Area LUD. Seven 

additional areas were classified as RNAs by the 1997 ROD. That action resulted in 

the current total of 12 Tongass RNAs incorporating a total area of 66,059 acres. 

Brief descriptions of each follow below. 

Cape Fanshaw RNA 

Established in 1965, this 614-acre RNA is located at the junction of Frederick Sound 

and the Stephens Passage in Roadless Area 201. This area was established to 

represent undisturbed old-growth yellow-cedar and western hemlock forests. It 

represents a good example of cedar decline on the mainland, and has been used for 

long-term monitoring of changes in species composition and stand dynamics. 

Dog Island RNA 

Established in 1976, this 705-acre RNA is located on Dog Island in Roadless Area 

521. The area represents a small island ecosystem containing the northern limit of 

Research Natural 

Areas 
 Environment and Effects 3 

Final EIS 3-471 Other Special Land Use Designations 

Pacific yew (Taxus brevifolia), associated scrub timber, and low-volume, mixedconifer sites of southern Southeast Alaska. 

Kadin Island RNA 

Established in 1997, this 1,623-acre RNA is located just north of Wrangell in 

Roadless Area 225. Kadin Island experiences high winds blowing down through the 

Stikine River corridor. The high winds pick up silt from the unvegetated glacial river 

floodplain and cause the deposition of loess on the island at the river’s mouth. The 

continuing rain of loess onto the upper soil layers provides a supply of unleached, 

nutrient-rich soil material to the forests of the island. The loess deposition 

overcomes the process of acid bog formation (paludification) that overtakes most 

stable sites of moderate topographic relief on the Tongass National Forest. Few 

areas in the world have a combination of high rainfall and recent loess deposition, 

so the properties of the soils here are of special interest. The fringe of the island is 

subject to tidal influence and changes in water level because of shifts of the river. 

Wetland marsh communities are included in this area. The bald eagle nest 

concentration on Kadin Island is second only to parts of Admiralty Island, according 

to the U.S. Fish and Wildlife Service. 

Marten River RNA 

Established in 1997, this 6,213-acre RNA is located within the Misty Fiords National 

Monument Wilderness adjacent to the Red River RNA. The Marten River RNA 

contains riparian spruce stands and has excellent habitat for brown bears along its 

major mainland streams. 

Limestone Inlet RNA 

Established in 1951 and expanded in 1971, this 9,102-acre RNA is located in 

Stephens Passage in Roadless Area 302. The area represents typical vegetation 

types common to the Juneau mainland, including many avalanche chutes and a 

mainland stream with a good fish population. In 1951, Limestone Inlet was 

considered the most pristine drainage in the northern mainland coast, making it an 

excellent area for documenting baseline conditions on the mainland. Alaska 

Department of Fish and Game has altered the native salmon runs since 1980 by 

operating a hatchery in nearby Snettisham Lake; however, upland areas 

remain intact. 

Old Tom Creek RNA 

Established in 1951, this 4,544-acre RNA is located on central Prince of Wales 

Island in Roadless Area 519. Situated in a low-site, cedar-dominated watershed, 

this RNA was established as an example of cedar-hemlock old-growth forest. It also 

includes some examples of riparian spruce forest, extensive tidal meadows, and 

dense bald eagle and black bear populations. 

Red River RNA 

Established in 1980, this 8,031-acre RNA is located in Misty Fiords National 

Monument Wilderness. This RNA represents the northern range of Pacific silver fir 

(Abies amabilis). 
Environment and Effects 3 

Other Special Land Use Designations 3-472 Final EIS

Rio Roberts RNA 

Established in 1997, this 1,560-acre RNA is located on central Prince of Wales 

Island in Roadless Area 511. This area contains riparian flood plain spruce stands, 

upland old-growth and natural young-growth stands, and upland hemlock on drumlin 

fields. A high level of recreation use occurs in the area, including hiking, camping, 

boating, and fishing in the Thorne River near this RNA. 

Robinson Lake RNA 

Established in 1997, this 4,297-acre RNA is located in the Misty Fiords National 

Monument Wilderness. This RNA focuses on a natural slump lake, forest types 

typical of the southern portion of mainland Southeast Alaska, and some uncommon 

plants of restricted distribution in Alaska. Robinson Lake formed in recent years 

when a natural earthslide dammed Robinson Creek. The area extends to the shore 

of Behm Canal in order to include habitat diversity associated with the shoreline and 

proximity to deep water. 

Tonalite Creek RNA 

Established in 1997, this 9,515-acre RNA is located south of Tenakee Springs 

across Tenakee Inlet in Roadless Area 311. This RNA includes pristine examples of 

Sitka spruce, western and mountain hemlock, and yellow cedar forest types. The 

Tonalite drainage is a narrow glacial valley that supports runs of pink, chum, and 

coho salmon. The drainage is prime brown bear, Sitka black-tailed deer, and 

beaver habitat. 

Warm Pass Valley RNA 

Established in 1997, this 8,306-acre RNA is located along the U.S.-Canada border 

between the Taku River and Chilkat Pass in Roadless Area 301; the valley includes 

the northernmost example of subalpine fir in Alaska. The valley is also an important 

migration corridor for interior vegetation species that mix with the coastal forest and 

tundra. The Warm Pass Valley RNA has a very different climate caused by a 

pronounced rain shadow effect. The valley supports a good population of moose 

that use both the alpine shrub belt and riparian shrubs at lower elevation. 

West Gambier Bay RNA 

Established in 1997 to replace the Pack Creek RNA, this 11,549-acre RNA is 

located at the head of the west arm of Gambier Bay in Admiralty Island National 

Monument-Kootznoowoo Wilderness. The area includes long, narrow Pybus Lake 

and several smaller lakes; productive wildlife habitat; an anadromous fish stream; 

and a variety of geological features, including karst. West Gambier Bay contains 

forest and nonforest vegetation types typically found on the islands of northern 

Southeast Alaska. 

Special Interest Areas are areas possessing unique or unusual scenic, historic, 

prehistoric, scientific, natural, or other characteristics. The objective of designating 

and managing such areas is to protect their unique values and, where appropriate, 

to foster public use and enjoyment of these areas. Special Interest Areas may be 

designated as scenic, recreation, historic, archaeological, geological, botanical, 

zoological, or paleontological areas. Special Interest Areas differ from RNAs in that 

management may promote public use as well as scientific study. 

Special Interest Area designations are intended to maintain natural to near-natural 

conditions in most cases; the Recreation Area designation may include developed 

Special Interest 

Areas 
 Environment and Effects 3 

Final EIS 3-473 Other Special Land Use Designations 

facilities within a natural or near-natural setting. The resources contained within 

these areas are not available for development, except for public facilities designed 

to allow recreation use while protecting the values of the area, or for interpretation 

and scientific study. Each area may require unique management direction 

determined through individualized study and planning. Special Interest Areas may 

be withdrawn from mineral entry. The LUD for Special Interest Areas applies to all 

the designated areas. 

Current Situation 

Twenty-four Special Interest Areas have been designated within the Tongass 

National Forest. They occupy a total area of 629,782 acres (it should be noted that 

many of these acres are sometimes tabulated under another LUD category when 

the Special Interest Area occurs within a Congressionally designated area, e.g., 

Wilderness, National Monument, and LUD II). Eight of the 24 areas were 

designated prior to the 1997 Land Management Plan Revision. These include the 

following: 

♦ Mendenhall Glacier Recreation Area (5,791 acres) 

♦ Ward Lake Recreation Area (440 acres) 

♦ Walker Cove-Rudyerd Bay Scenic Area (93,540 acres) 

♦ Admiralty Lakes Recreation Area (8,710 acres) 

♦ New Eddystone Rock Geological Area (1 acre) 

♦ Hubbard Glacier Geological Area (46,000 acres) 

♦ Tracy Arm-Fords Terror Scenic Area (283,000 acres) 

♦ Naha Recreation Area (2,363 acres) 

The remaining 16 Special Interest Areas, plus 1 expansion, were identified and 

designated with the 1997 Land Management Plan Revision as the following: 

♦ Arena Cove/Cape Felix Geological Area (9,465 acres) 

♦ Bailey Bay Hot Spring Recreation Area (3,510 acres) 

♦ Blind Slough Recreation Area (8,150 acres) 

♦ Blue River Lava Flow Geological Area (13,520 acres) 

♦ Clear River Zoological Area (11,530 acres) 

♦ Duke Island Zoological Area (44,650 acres) 

♦ Falls Creek Windthrow Botanical Area (820 acres) 

♦ Fish Creek Hotsprings Recreation Area (100 acres) 

♦ Karst Areas Geological Areas (multiple areas totaling 13,635 acres) 

♦ Keku Islet Geological and Scenic Area (2,300 acres) 

♦ Mt. Edgecumbe Geological Area (49,050 acres) 

♦ North Hamilton River Red Cedar Cultural and Botanical Area (80 acres) 

♦ Pack Creek Zoological Special Interest Area (5,837 acres) 

♦ Patterson Glacier Geological and Botanical Area (13,900 acres) 
Environment and Effects 3 

Other Special Land Use Designations 3-474 Final EIS

♦ Pike Lakes Recreation Area (2,340 acres) 

♦ Soda Springs Geological Area (3,515 acres) 

♦ Ward Lake Recreation Area Expansion (7,535 acres) 

Eight of the Special Interest Areas have been designated within Wildernesses 

and/or National Monuments, or LUD II areas. These areas are already managed in 

a way that accounts for the Wilderness, National Monument, or LUD II area 

surrounding them. They include the following: 

♦ Admiralty Lakes (Admiralty Island National Monument and Kootznoowoo 

Wilderness) 

♦ Blue River Lava Flow (Misty Fiords National Monument and Wilderness) 

♦ Hubbard Glacier (Russell Fiord Wilderness) 

♦ Naha Recreation Area (Naha LUD II) 

♦ New Eddystone Rock Geological Area (Misty Fiords National Monument and 

Wilderness) 

♦ Pack Creek Zoological Special Interest Area (Admiralty Island National 

Monument and Kootznoowoo Wilderness) 

♦ Tracy Arm-Fords Terror (Tracy Arm-Fords Terror Wilderness) 

♦ Walker Cove-Rudyerd Bay (Misty Fiords National Monument and Wilderness) 

Because the National Monument, Wilderness, and LUD II designations recognize 

and protect the same values for which the areas were originally designated, the 

Special Interest Area designation may have become redundant, and the possibility 

of declassifying these areas as Special Interest Areas is being explored by the 

Forest Service. No proposals for declassification are being made at this time. 

The Tongass also contains a small portion of the 5-acre Fort Durham National 

Historic Landmark (most of which is on private land). 

Special Interest Areas are not available for timber harvest, and roads would be 

allowed only if they are compatible with the interpretive goals of a particular area. 

Other restrictions may be imposed on a case-by-case basis to protect an area’s 

unique values. These could include closures to off-highway (or off-road) vehicle 

(OHV) use, and withdrawals from mineral entry. Currently, the Mendenhall Glacier, 

Ward Lake, and Naha Recreation Areas are withdrawn from mineral entry. The 

need for such restrictions for newly designated or expanded areas may be 

determined during Forest Plan implementation. 

This section describes the process for Wild and Scenic River designation, and the 

rivers on the Tongass National Forest that are currently managed as wild and scenic 

rivers. 

Background 

The Wild and Scenic Rivers Act of 1968, as amended, provides a means for 

recognizing and protecting the “outstandingly remarkable” scenic, recreation, 

geologic, fish and wildlife, historic, cultural, ecological, and other values of selected 

rivers. The intent of including a river in the National Wild and Scenic Rivers System 

is to preserve the free-flowing condition of the river itself, as well as the 

characteristics of the river’s immediate environment for the enjoyment and benefit of 

present and future generations. The U.S. Congress is responsible for final 

designation of rivers to be included in the National Wild and Scenic Rivers System. 

Wild and Scenic 

Rivers 
 Environment and Effects 3 

Final EIS 3-475 Other Special Land Use Designations 

ANILCA designated 26 rivers in central and northern Alaska as components of the 

National Wild and Scenic Rivers System under the Wild and Scenic Rivers Act of 

1968. No rivers in Southeast Alaska or the Tongass National Forest were 

designated under ANILCA. An additional 12 rivers were designated as “study rivers” 

by ANILCA, of which only one, the Situk River near the community of Yakutat, is in 

Southeast Alaska and in the Tongass National Forest. 

The Situk River, including the West Fork and Old Situk Creek, was studied in 1983 

and was found to possess outstandingly remarkable fish, wildlife, and recreational 

values of national significance, but was not recommended for designation. The 

community of Yakutat, the local and regional Native corporations, the Citizens 

Advisory Council of Federal Areas, the Governor of the State of Alaska, and the 

Regional Forester on behalf of the Forest Service, signed an agreement to 

recognize each others’ responsibility in cooperative management of the Situk River 

corridor in lieu of designation as a Wild and Scenic River. The Alaska Land Use 

Council supported development of a management plan for the Situk River, rather 

than designation as a Wild and Scenic River (USDA Forest Service 1993a)) and the 

Secretary of the Interior formally determined to not recommend designation of the 

Situk River. The Situk River corridor continues to be managed through a cooperative 

process among the signatories to that agreement. 

The National Park Service initiated an evaluation to determine the eligibility of the 

rivers within the National Parks and Preserves in Alaska. The Alsek River near 

Yakutat is included in that evaluation. The Tongass National Forest includes the 

surface and west bank of an 18-mile segment that was found to be eligible and 

meeting a “Scenic” classification. 

The analysis and planning that led to the 1997 Forest Plan included a process for 

identifying rivers that could be eligible for inclusion in the National Wild and Scenic 

Rivers System. The process started with an inventory and evaluation to determine 

the eligibility, potential classification, and suitability for inclusion in the National Wild 

and Scenic Rivers System. 

Rivers are eligible to be considered for inclusion in the National Wild and Scenic 

River System if they are essentially free-flowing (without major dams, diversions, or 

channel modifications), and if they possess at least one “outstandingly remarkable” 

scenic, recreational, geologic, fish and wildlife, historic, cultural, or other similar 

value. These values should be a unique or exceptional representation for the area 

studied, and must be related to the river or its immediate environment. 

The potential classification for each eligible stream segment was done according to 

the criteria in the Wild and Scenic Rivers Act into either Wild, Scenic, or 

Recreational Rivers defined as follows: 

♦ Wild River areas are defined as those rivers or sections of rivers that are free of 

impoundments and generally inaccessible except by trail, with watersheds or 

shorelines essentially primitive in character and waters unpolluted. These 

represent vestiges of primitive America. 

♦ Scenic River areas are defined as those rivers or sections of rivers that are free 

of impoundments with shorelines or watersheds still largely primitive and 

shorelines largely undeveloped, but accessible in places by roads. 

♦ Recreational River areas are defined as those rivers or sections of rivers that 

are readily accessible by road or railroad, that may have undergone some 

development along their shorelines, and that may have undergone some 

impoundment or diversion in the past. 

Eligible rivers are further evaluated for “suitability.” Generally this analysis considers 

the appropriateness of Congressional designation as a Wild, Scenic, or Recreational 
Environment and Effects 3 

Other Special Land Use Designations 3-476 Final EIS

River in light of social and economic values, or the resource opportunities enhanced, 

curtailed, or foregone, and the effect on private lands and other uses of the area. 

Suitable rivers may be recommended to Congress by the administration for 

designation. If designation occurs, a final boundary is established and a 

management plan developed. 

There are nearly 900 watersheds on the Tongass National Forest containing some 

42,500 miles of perennial stream. All of the rivers and streams on the Forest were 

examined and evaluated for eligibility for the National Wild and Scenic Rivers 

System. An initial evaluation identified 300 rivers and streams for further study. Of 

these, 112 rivers with 1,394 stream miles were determined to be eligible for 

consideration as components of the National Wild and Scenic Rivers System. More 

detail about the process that was used and the individual rivers studied is available 

in the 1997 Tongass Forest Plan Revision Final EIS. 

Based on a suitability analysis, the Regional Forester recommended 32 of the 112 

eligible rivers for inclusion in the National Wild and Scenic Rivers System as either 

Wild, Scenic, or Recreational (Table 3.21-1). Appendix E of the 1997 Tongass Land 

Management Plan Revision Final EIS provides descriptions of each river. The 1997 

ROD contains the rationale for the decision made for each river. The 

recommendation was a preliminary administrative recommendation that would be 

forwarded to the Chief of the Forest Service. It could receive further review and 

possible modification by the Secretary of Agriculture and the President of the United 

States. Congressional action is necessary to designate rivers as part of the National 

Wild and Scenic Rivers System. 

Because this was a preliminary administrative recommendation, the 1997 Forest 

Plan directs that the rivers be managed, within the existing authorities of the Forest 

Service, to retain their free-flowing character and outstandingly remarkable values. 

Three LUDs were created for these rivers, one for each classification: Wild River, 

Scenic River, and Recreational River. The 1997 Forest Plan includes goals, 

objectives, desired conditions, and specific management prescriptions for each 

LUD. The Wild and Scenic Rivers Act provides that the study boundary includes, at 

a minimum, the area within 0.25 mile of the ordinary high water mark on each side 

of the river (USDA Forest Service 1993b). Final boundaries can and do vary from 

this minimum, but generally follow the 0.25-mile guideline. The area of the 

recommended rivers managed under the Wild, Scenic, and Recreational River 

LUDs were determined so as to maintain the eligibility of the total miles of river for 

each classification. 

Subsequent to the Regional Forester’s 1997 Wild and Scenic River 

recommendations, the Acting Forest Supervisor determined that the 

recommendation for Niblack Lakes and Streams was based on incorrect information 

related to the anadromous fish productivity of the system. In November 1998, a 

non-significant of the 1997 Forest Plan rescinded the Wild and Scenic River 

recommendation and associated LUDs for Niblack Lakes and Streams (USDA 

Forest Service 1999c); therefore, Niblack Lakes and Streams is not included in this 

analysis. 
 Environment and Effects 3 

Final EIS 3-477 Other Special Land Use Designations 

Table 3.21-1 

Rivers (Segments) Recommended for Inclusion in National Wild and Scenic 

River Program (in miles)

Outstandingly Remarkable 

Values 

River Name Wild Scenic Rec. 

Fish Wildlife Recreation Scenic Hist./Cult. Geology Ecology 

Aaron, Oerns, Berg Creeks - 21 16 X X X X - - - 

Anan Creek 17.5 .5 - X X X - - - - 

Blind River - - 5 X X X - - - X 

Blue River 26 - - - X - X - X X 

Chickamin River 94 2 - X X X X X X - 

Essowah Lake and Streams 13 - - X X - X - - - 

Fall Dog Creek (local) 4 - - X X - X X - - 

Farragut River 29 1 - X X - X - - - 

Gilkey River 9 - - - - - X - X - 

Glacial River 10 - - - - - X - X X 

Gokachin-Mirror-Low-Fish Creeks 30 - - X X X X X - - 

Harding River - 16 - X X X - - - - 

Hasselborg River and Lakes 24 - - X X X - X - - 

Kadake Creek - - 23 X X X X X - - 

Kadashan River - 8 - X X - - - - X 

Kah Sheets Creek and Lake 5 4 - X X X - X - - 

Katzehin River 10 - - X - - X - X - 

Kegan Lake and Streams 9 - - X - X X - - - 

King Salmon River 8 - - X X - - - - - 

Kutlaku Creek and Lake 2 - - X - - - - - - 

LeConte Glacier 6 - - - - - X - X - 

Lisianski River 5 - - - X - - - - X 

Naha River 17 2 - X X X - X - - 

Niblack Lakes and Streams1 5 - - X - - - - - - 

Orchard Creek and Lake 10 - 16 X X X X - - X 

Petersburg Creek 7 - - X - X X X - - 

Salmon Bay Lake and Stream 4 2 - X X - X - - - 

Santa Anna Creek - L. Helen - 4 - X - X - - - X 

Sarkar Lakes 14 3 2 X X - X X - - 

Thorne River-Hatchery Creek - 24 18 X X X X - - - 

Virginia Lake and Creek - - 9 X - X - - - - 

Wolverine Creek-McDonald Lake 6 - - X X X - - - - 

Total Miles 359.5 87.5 89.0 

1

 Niblack was later removed from the list.

Current Situation 

Congress has not yet designated any rivers on the Tongass National Forest to be 

included in the National Wild and Scenic Rivers System. 

The goal for management of the rivers that were recommended for Wild and Scenic 

designations is to maintain their outstandingly remarkable values and their freeflowing conditions. The objective is to manage the 31 rivers (or segments), pending 

designation by Congress as Wild, Scenic, or Recreational Rivers, to maintain the 

eligibility of the total miles of river for the Wild, Scenic, or Recreational classification. 

The goal is to be achieved through the management of the rivers (or segments) 

under the LUD of Wild River, Scenic River, or Recreational River and 

implementation of the standards and guidelines specified for the LUD. These are 

summarized below and described in more detail in the 1997 Forest Plan. 
Environment and Effects 3 

Other Special Land Use Designations 3-478 Final EIS

Wild River LUD. This is the most restrictive of the three LUDs. Scheduled timber 

harvest and construction of major recreation facilities, roads, and hydroelectric 

power projects are not allowed. Mining may be allowed or the area may be 

withdrawn from mineral entry by Congress at the time of designation as a Wild 

River. Some fish and wildlife habitat enhancement are permitted. This is a 

Transportation and Utility Systems “Avoidance Area,” but corridors will be allowed in 

accordance with ANILCA, Title XI. Twenty-three river segments, or 359.5 river 

miles, are currently managed under this LUD. 

Scenic River LUD. Hydroelectric power projects are not allowed, but timber 

harvest is allowed if the adjacent LUD allows timber harvest. Major recreational 

developments may be compatible with this LUD and minor developments are 

allowed. The construction of NFS roads is allowed and bridges may occasionally 

span the river. Mining and some fish and wildlife habitat enhancement are 

permitted. This is a Transportation and Utility Systems “Avoidance Area” but 

corridors will be allowed in accordance with ANILCA, Title XI. Twelve river 

segments, or 87.5 river miles, are currently managed under this LUD. 

Recreational River LUD. Although hydroelectric power projects are not allowed, 

many other management activities are permitted. Timber harvest is allowed if the 

adjacent LUD allows timber harvest. Major and minor recreational developments 

and NFS roads that make the river easily accessible are allowed. Mining and some 

fish and wildlife habitat enhancement are permitted. This is a Transportation and 

Utility Systems “Avoidance Area,” but corridors will be allowed in accordance with 

ANILCA, Title XI. Seven river segments, or 89 river miles, are currently managed 

under this LUD. 

The LUD(s) for adjacent land can have significant influence on the management of 

resources inside Wild, Scenic, or Recreational River LUDs. Many of the corridors 

designated to the Wild River, Scenic River, or Recreational River LUD are narrow 

and include the width of the river plus 0.25 mile on each side. The most obvious 

example of the adjacent LUD influence is that the ability to harvest timber in Scenic 

or Recreational River LUDs is dependent on the management prescription for timber 

in the LUD(s) of the adjacent land. In a more indirect way, it may influence other 

resources, such as scenery, recreation, or road building. For example, if the 

surrounding land is designated Remote Recreation where no new roads are 

allowed, it is less likely that a road will be proposed for a Scenic or Recreational 

River area. 

Of the 536 miles of recommended Wild, Scenic, or Recreational Rivers, 221 miles of 

seven rivers, or 41 percent of the river miles in Wild, Scenic, or Recreational River 

LUDs, are already in areas allocated to Wilderness or National Monument 

Wilderness. Most of the remaining Wild, Scenic, or Recreational River miles outside 

of designated wilderness are surrounded by land currently in non-development LUD 

designations. Although there are differences in specific management prescriptions 

for each of the LUDs, there are some common directions. In general, timber harvest 

is not suitable in the non-development LUDs, and new roads are not allowed or are 

restricted to specific uses. Minor recreational development is consistent with most 

non-development LUDs and major recreational development is consistent only with 

Semi-Remote Recreation. Generally, the non-development status and resulting 

management prescriptions in these adjacent lands may reduce the likelihood of 

development in the Scenic or Recreational River LUD. 

Wild and Scenic Rivers and Wilderness Management 

According to the Wild and Scenic Rivers Act, any portion of a component of the Wild 

and Scenic Rivers System that is within a wilderness shall be subject to the 

provisions of both the Wilderness Act and the Wild and Scenic Rivers Act. In the 
 Environment and Effects 3 

Final EIS 3-479 Other Special Land Use Designations 

case of conflict between the provisions of these Acts, the more restrictive provisions 

shall apply (USDA Forest Service 1993b). Thus, there are the dual, but overlapping 

goals of the preservation of the wilderness resources while at the same time 

preserving the river and its immediate environment. Because the two laws differ 

somewhat, legislative action should address specific issues in a particular river 

corridor. 

A variety of recreation types are allowed by managing the rivers as Wild, Scenic, or 

Recreational. Wild River designation is compatible with wilderness designation 

because they both provide primitive and semi-primitive recreation opportunities. 

Scenic and Recreational River designations provide other opportunities that are 

more developed than those allowed in areas designated as Wild River. 

Environmental Effects 

Experimental Forests 

The primary proposed change involving experimental forests under the action 

alternatives is the recommended replacement of one of the two existing 

experimental forests with a management unit better suited to this purpose. As 

indicated in the Affected Environment discussion, the Young Bay Experimental 

Forest provides limited opportunities for forestry research and has not been used for 

experimental purposes in recent decades. Therefore, all alternatives except 

Alternative 5 propose to eliminate the Young Bay Experimental Forest and 

designate the Cowee-Davies area as a new experimental forest. Alternative 5, No 

Action, continues the current designations and retains the Young Bay Experimental 

Forest. 

The current Forest Plan provides standards and guidelines to maintain research 

opportunities within the two existing experimental forests. Those standards and 

guidelines have been updated for the Forest Plan Amendment, primarily to include 

protection for sacred sites and to address inventory and interpretation activities for 

minerals and geologic resources. Those changes would have no substantive 

effects on resources present within the experimental forest areas, other than to 

provide updated management direction for protection of sacred sites, minerals, and 

geologic resources. The updated standards and guidelines would be applied to the 

experimental forests designated under all of the action alternatives. 

The potential effects associated with the land use allocations of the alternatives on 

existing and proposed experimental forest areas are described below. 

Maybeso Experimental Forest 

The Maybeso Experimental Forest offers limited opportunities in the near term to 

design new experiments (except relative to thinning regimes and management of 

very young second-growth timber) because most of the suitable forest land had 

been harvested by the 1960s. Monitoring of research plots established in this area 

some time ago would continue under all alternatives. New experiments could be 

conducted in the future. If so, they would likely be rather limited in scope and would 

probably occur in areas that had previously been harvested. 

Young Bay Experimental Forest 

The Young Bay Experimental Forest has for some time been considered for 

delisting as an experimental forest because of the vegetative and access conditions 

that limit the value of the area for research. The primary reason to retain Young Bay 

as an experimental forest is to maintain options in light of the Alaska Region’s 

Ecosystem Management Strategy. Potential research could include alternative 

Direct and 

Indirect Effects 
Environment and Effects 3 

Other Special Land Use Designations 3-480 Final EIS

silvicultural systems and/or manipulating vegetation to create desired wildlife habitat 

conditions. 

If or when such research activities are undertaken, any silvicultural activity would 

likely use a helicopter yarding method with no road construction, and would likely 

focus on alternatives to clearcutting. Vegetative manipulation for desired wildlife 

habitat conditions would likely result in small openings or single tree selection 

harvesting, also using a helicopter with no roads. This type of research activity 

would be a possible occurrence under Alternative 5. 

Under Alternatives 1, 2, 3, 4, 6, and 7, the Young Bay area would no longer be 

designated as an experimental forest. Under these alternatives, the Young Bay 

area would be changed to the Semi-Remote Recreation LUD, consistent with the 

adjacent NFS lands to the northwest on the Mansfield Peninsula of Admiralty Island. 

While this is a non-development, mostly natural LUD that is nominally more 

restrictive of management activities than the Experimental Forest LUD, there would 

actually be little tangible change in management of the area given the lack of 

research activities conducted in this area under the past designation. 

Cowee-Davies Experimental Forest 

Alternatives 1, 2, 3, 4, 6, and 7 include changing the LUD of approximately 22,300 

acres in the Cowee-Davies watershed to experimental forest and recommending 

this area for official designation as an experimental forest. This area comprises 

Value Comparison Units 230 and 240 and is located on the east side of Lynn Canal 

approximately 40 to 50 miles north of Juneau. The southwestern side of the 

proposed experimental forest follows the Lynn Canal shoreline but is set back a few 

miles, and the northern edge abuts the Berners Bay LUD II designation. The current 

LUD for the proposed Cowee-Davies Experimental Forest is Scenic Viewshed 

which, like the Experimental Forest designation, is a moderate development LUD. 

There would be little change in the type and intensity of management activities in 

this area under the proposed designation compared to current management. 

Research Natural Areas 

This section focuses on the effects of the alternatives on current RNAs. All seven 

alternatives include continued RNA designation for the 12 existing RNAs at their 

current respective acreages. Likewise, none of the alternatives includes proposed 

designation of any new RNAs. Therefore, none of the alternatives would have any 

direct effects on RNAs. Any potential effects of the proposal would be indirect 

effects associated with changes in LUDs in areas adjacent to RNAs. 

Table 3.21-2 summarizes the types of LUDs surrounding RNAs under each 

alternative. Alternatives 1 and 2 are the same with respect to the distribution of 

LUDs in areas adjacent to RNAs. Both alternatives maintain current management 

practices that would have little to no effect on 10 of the 12 RNAs. In both cases, the 

only changes from current management direction are that the Limestone Inlet and 

Tonalite Creek RNAs would be entirely surrounded by LUDs in the natural setting 

group, while those areas currently have LUDs in the natural setting, moderate 

development, and intensive development groups. Alternatives 1 and 2 would 

slightly reduce the chance that management activities in adjacent areas would 

indirectly affect research activities in those two RNAs. 

LUDs surrounding the 12 RNAs under Alternative 3 are very similar to those 

currently in effect (Alternative 5) and to what would occur under Alternatives 1 and 

2. Limestone Inlet would also be surrounded by natural setting LUDs under 

Alternative 3, instead of the current mix of natural setting, moderate development, 

and intensive development LUDs. Both natural setting and intensive development 
 Environment and Effects 3 

Final EIS 3-481 Other Special Land Use Designations 

Table 3.21-2 

Summary of LUDs Surrounding Research Natural Areas by Alternative

Alternative 

Research Natural Area 1 2 3 4 5 6 7 

Cape Fanshaw N N N M N N M 

Dog Island - - - - - - - 

Kadin Island - - - - - - - 

West Gambier Bay W W W W W W W 

Marten River W W W W W W W 

Limestone Inlet N N N M/I M/I/N M/N/I M/N/I 

Old Tom Creek N/I N/I N/I N/I N/I N/I I 

Red River W W W W W W W 

Rio Roberts N N N M/I N N N/M/I 

Robinson Lake W W W W W W W 

Tonalite Creek N N N/I N/I N/I N/I N/I 

Warm Pass Valley N N N N N N N 

Note: Letter symbols represent the following: N = Natural Setting LUD group; W = Wilderness LUD group; M = 

Moderate Development LUD group; I = Intensive Development LUD group.

LUDs would adjoin the Tonalite Creek RNA under Alternative 3 because they do 

under current management. 

Under Alternative 4, management designations would change for some lands 

adjacent to three of the RNAs. The Rio Roberts RNA would be surrounded by LUDs 

in the moderate and intensive development groups. This would be a change from 

current management, under which natural setting LUDs surround the RNA. 

Similarly, the Limestone Inlet RNA would be surrounded by LUDs in the moderate 

and intensive development groups, while a natural setting LUD (old-growth habitat) 

currently abuts the west and south sides of this RNA. Finally, the NFS lands 

adjacent to the Cape Fanshaw RNA would be changed from a natural setting LUD 

(old growth) to a moderate development LUD (scenic viewshed). Based on these 

changes, Alternative 4 would increase the chance that management activities in 

adjacent areas would indirectly affect research activities in these three RNAs. 

Alternative 6 would maintain the current LUDs in areas adjacent to all 12 RNAs. 

Therefore, Alternative 6 would have no direct or indirect effects on RNAs. 

Similar to Alternative 4, Alternative 7 would intensify management designations 

adjacent to three RNAs. As with Alternative 4, the NFS lands adjacent to the Cape 

Fanshaw RNA would be changed from a natural setting LUD (old growth) to a 

moderate development LUD (scenic viewshed). The Rio Roberts RNA would be 

surrounded by LUDs in the natural setting and moderate and intensive development 

groups, while under current management only natural setting LUDs surround the 

RNA. Similarly, the Old Tom Creek RNA would be adjoined by an intensive 

development LUD (timber production), rather than the current mix of natural and 

intensive development LUDs. Overall, Alternative 7 would increase the chance that 

management activities in adjacent areas would indirectly affect research activities in 

these three RNAs. 

The West Gambier Bay, Marten River, Red River, and Robinson Lake RNAs are 

already part of designated wildernesses, and the management situation for these 

areas would not change under any alternative. Similarly, the Dog Island and Kadin 

Island RNAs are surrounded by water and would not be affected by any LUD 

changes among the alternatives. 
Environment and Effects 3 

Other Special Land Use Designations 3-482 Final EIS

The current Forest Plan provides standards and guidelines to preserve areas of 

ecological importance and maintain research opportunities within the existing RNAs. 

Those standards and guidelines have been updated for the Forest Plan 

Amendment, primarily to include consultation and protection for heritage and sacred 

sites and to address inventory and interpretation activities for minerals and geologic 

resources. The updated standards and guidelines also direct that designation of 

motorized routes for OHVs in RNAs is generally not allowed. Those changes would 

have no substantive effects on resources present within the RNAs, other than to 

provide updated management direction for protection of sacred sites, minerals, and 

geologic resources. The updated standards and guidelines would be applied to the 

RNAs designated under all of the action alternatives. 

Special Interest Areas 

This section focuses on the effects that each alternative would have on existing or 

proposed Special Interest Areas. Alternative 5 (No Action) would maintain the 24 

existing Special Interest Areas at their current acreages, and would result in no 

direct effects on these areas. Alternatives 1 through 4 and 6 and 7 would also 

continue the current designations and acreages for 23 of the 24 existing Special 

Interest Areas, modify the acreage of one geologic area, and add new geologic 

Special Interest Areas in nine regions of the Tongass. 

Under Alternative 5, the total acreage within Special Interest Areas (outside of 

Wilderness, National Monument, and LUD II) would remain at approximately 

174,000 acres. Under all other alternatives this figure would be approximately 

221,000 acres, an increase of 47,000 acres. Alternatives 1 through 4 and 6 and 7 

would provide increased management protection for sensitive geologic resources on 

the Tongass, primarily karst and cave areas, and would result in a reduced chance 

that these resources would be damaged by development activities. 

The proposed acreage reduction among geologic Special Interest Areas involves 

the Arena Cove/Cape Felix area on Suemez Island. The current boundary of this 

area includes approximately 9,700 acres; the revised boundary encompasses 

approximately 7,400 acres, which is sufficient to protect the volcanic features that 

are the primary interest for this area. This change in the LUD represents a technical 

adjustment to correct a mapping error from the 1997 Tongass Land and 

Management Plan. 

Increased acreage in proposed Special Interest Area LUDs under Alternatives 1, 2, 

3, 4, 6, and 7 reflect both designation of new areas and expansion of existing areas. 

These changes are summarized as follows: 

♦ Eastern Chichagof Geological Areas – 12 new areas encompassing 

approximately 23,900 acres, primarily to protect alpine karst areas, except for 

one that includes the Kook Lake cave system. 

♦ Kosciusko Island Geological Areas – two new areas including approximately 

9,400 acres with intense karst development. 

♦ Northern Prince of Wales Geological Areas – three new areas and one 

expanded area (part of the Karst Areas Geological Area) covering 

approximately 2,800 acres (adding to 11,100 existing designated acres in this 

region), primarily to protect several cave systems in karst areas. 

♦ Heceta Island Geological Area – one new area of approximately 4,100 acres 

that includes a number of karst-related caves. 

♦ North-central Prince of Wales Geological Areas – two new areas including 

approximately 700 acres with similar cave systems. 
 Environment and Effects 3 

Final EIS 3-483 Other Special Land Use Designations 

♦ Dall Island Geological Areas – minor reductions to two existing areas (part of 

the Karst Areas Geological Area), based on improved inventory work on cave 

systems, and one new area for a net increase of approximately 9,100 acres. 

♦ Big Creek Geological Area – one new area of alpine karst near Big Creek, just 

south of the West Arm of Cholmondeley Sound on southern Prince of Wales 

Island, incorporating approximately 2,000 acres. 

♦ Calamity Creek Caves Geological Area – one new area of approximately 200 

acres on Revillagigedo Island, to protect the Calamity Creek Caves and 

associated karst features. 

♦ Blake Channel Geological Area – one new area of approximately 700 acres 

near Aaron Creek, to protect a karst and cave system. 

The current Forest Plan provides standards and guidelines for managing the 

existing Special Interest Areas. Those standards and guidelines have been updated 

for the Forest Plan Amendment, primarily to include direction to inventory and 

manage karst resources and minerals and geologic resources. The updated 

standards and guidelines also direct that designation of motorized routes for OHVs 

in Special Interest Areas is generally not allowed. Those changes would have no 

substantive effects on resources present within the Special Interest Areas, other 

than to provide additional specific direction for protection of resources in those 

areas. The updated standards and guidelines would be applied to the Special 

Interest Areas designated under all of the action alternatives. 

The acreage allocated to the existing and proposed Special Interest Areas is 

believed to be sufficient to include and protect the resources of interest for each 

respective unit. Therefore, none of the alternatives are expected to result in indirect 

effects associated with management activities that might occur in LUDs adjacent to 

Special Interest Areas. 

Wild and Scenic Rivers 

All seven alternatives include continued Wild, Scenic, and/or Recreational River 

LUD designation for the 31 existing river segments designated as potential Wild, 

Scenic, and/or Recreational Rivers under the current Forest Plan, and at their 

current respective acreages. These river segments would continue to be managed 

to protect the outstandingly remarkable values that make them eligible for 

designation as Wild, Scenic and/or Recreational Rivers by Congress. Likewise, 

none of the alternatives include proposed designation of any new Wild, Scenic, 

and/or Recreational Rivers. Therefore, none of the alternatives would have any 

direct effects on the potential future status of any Wild, Scenic, and/or Recreational 

Rivers. Any potential effects of the proposal would be indirect effects associated 

with changes in LUDs in areas adjacent to RNAs. 

The current Forest Plan provides standards and guidelines for managing the 

existing Wild, Scenic, and Recreational River LUDs. Those standards and 

guidelines have been updated for the Forest Plan Amendment, primarily to include 

consultation protection for heritage and sacred sites and direction to inventory and 

manage karst resources and minerals and geologic resources. The updated 

standards and guidelines also direct that designation of motorized routes for OHVs 

in Special Interest Areas is generally not allowed in Wild River LUDs, but is allowed 

in Scenic and Recreational rivers. Those changes would have no substantive 

effects on resources present within the Wild, Scenic, and Recreational River LUDs, 

other than to provide additional specific direction for protection of resources in those 

areas. The updated standards and guidelines would be applied to the Special 

Interest Areas designated under all of the action alternatives. 
Environment and Effects 3 

Other Special Land Use Designations 3-484 Final EIS

Management Provisions 

The kinds and amounts of activities and changes acceptable within a river corridor 

depend on whether it was recommended as a Wild, Scenic, or Recreational River 

and, to some extent, the LUDs of areas adjacent to the river segment. Variations in 

management restrictions among Wild, Scenic, and Recreational River LUDs are 

summarized below. 

Recreation. The recreational objectives for management of Wild, Scenic, and 

Recreational River LUDs are substantially different. While the Wild River LUD ROS 

class is the same as Wilderness, there are small differences in specific 

implementation guidelines. Wilderness management has much more restrictive 

management than Scenic and Recreational River LUDs. LUD II management is 

less restrictive than Wild River or Wilderness, but more restrictive than Scenic or 

Recreational River. 

Timber Harvesting. Timber harvesting and associated roads and log transfer 

facilities are presently only allowed in the Scenic and Recreational Rivers when they 

are adjacent to LUDs that allow timber harvest. There are only 13 miles of rivers in 

this situation. Costs of harvest in the Scenic and Recreational River LUDs may be 

higher than other LUDs as a result of standards to maintain identified values. 

Water Project Development. New diversions, water supply dams, and 

hydroelectric power development are not allowed under the Wild, Scenic, and 

Recreational River LUDs. 

Transportation and Utility Corridors. All three river designations are in 

Transportation and Utility System “Avoidance Areas.” Thus, transportation and 

utility sites or corridors may be located within these LUDs only after an analysis of 

potential sites shows that there is no feasible alternative outside these LUDs. 

Mining. Mineral entry is not denied in Wild, Scenic, or Recreational River LUDs, but 

it does need to be consistent with the purposes of the LUD so the eligibility for 

Congressional designation is maintained. Costs of mining in these areas may be 

higher than in other LUDs as a result of standards to maintain identified river values. 

Congressional designation of a river as Wild under the national program would then 

deny mineral entry, subject to valid claims, but would not affect Scenic or 

Recreational Rivers. 

Roads. New road construction is not allowed in the Wild River LUD. Roads are 

allowed in the Scenic and Recreational River LUDs and bridges can span the river. 

If road construction is not allowed in the adjacent area, it is less likely that roads 

would be planned in the river area. Only 13 miles of the river corridors in roadless 

areas are within LUDs that allow road construction for forest development. 

Fish Improvement Projects. Fish habitat improvements are generally more 

restricted under Wild, Scenic, and Recreational River designations than under 

Wilderness or LUD II. In the three Wild and Scenic River LUDs, the free-flowing 

characteristic and outstandingly remarkable values must be maintained, which limits 

the projects that can be implemented. Weirs and other stream obstructions are 

either prohibited or discouraged. However, weirs are a tool of state management of 

fisheries, installed seasonally, and are not considered to be stream obstructions in 

the same vein as dams and permanent facilities. 

Wildlife Habitat Improvements. In Wild, Scenic, and Recreational River 

designations, the wildlife habitat improvements are limited to those with the objective 

of protecting or restoring the river resource and enhancing the outstandingly 

remarkable value. Manipulation of vegetation or improvements, such as fencing or 

artificial nest structures, would likely be incompatible with Wild classification. Other 

improvements might be compatible with a Scenic designation, as long as the 
 Environment and Effects 3 

Final EIS 3-485 Other Special Land Use Designations 

undeveloped character was maintained. Most improvements would be acceptable 

in a Recreational classification, consistent with the outstandingly remarkable values. 

Area-Specific Considerations 

In addition to the general issues for the Forest activities described above, there are 

specific resource issues associated with some individual rivers (segments). 

Aaron, Oerns, Berg Creeks – Approximately 4 miles of Aaron and Berg creeks are 

within and adjacent to a corridor with known mineral potential for zinc, copper, silver, 

and lead. The Bureau of Land Management (BLM) lists this area’s potential for 

mineral development at its highest level (USDA Forest Service 1997a). It has a 

Mineral LUD overlay that encourages mineral development and may allow road 

building for mining purposes. There are no existing mineral claims on the river 

corridor, but the claims in adjacent land may require roads through the river corridor. 

This corridor has been recommended as Scenic or Recreational River, and 

designation by Congress as such would not deny mineral rights. 

Glacial River – This is not an area of identified high mineral potential for known 

resources, but the upper half of the river is in a Class 3 tract of undiscovered mineral 

resources, as mapped by the U.S. Geologic Survey (USGS). This area was 

recommended to be included in the National Wild and Scenic Rivers System as 

Wild. Congressional designation as a Wild River would close the corridor to mineral 

entry, subject to valid existing claims. 

Gokachin-Mirror-Low-Fish Creeks – The area within and adjacent to the corridor 

near Gokachin Creek has been identified by the BLM as having high priority for 

minerals development. There are several unpatented mine claims within the 

corridor. This area was recommended to be included in the National Wild and 

Scenic Rivers System as Wild, which, with Congressional action, would withdraw it 

from mineral entry. 

Kadake Creek – The timber sale schedule identifies numerous entries in and 

adjacent to this corridor. The river was recommended as a recreational river, thus 

preserving the ability to harvest timber on most of the corridor’s 23 miles (USDA 

Forest Service 1997a). 

Kah Sheets Creek and Lake – Approximately 5 miles of this area are in the Wild 

River LUD, where timber production is not allowed. Approximately 2 miles are in a 

Scenic River LUD and are adjacent to a Timber Production LUD. Timber production 

is allowed in those 2 miles. 

Orchard Creek and Lake – The lower portion of the river was recommended as 

Recreational River to allow the construction of the Swan Lake-Lake Tyee 

transmission line (USDA Forest Service 1997a). The transmission line has since 

been located outside this area. 

Sarkar Lakes – This area is extremely popular for recreation, with an emphasis on 

fishing (USDA Forest Service 1997a). Portions of it were recommended as Scenic 

and Recreational Rivers. The area on the south side of Sarkar Cove is known to 

have potential mineral development. BLM has not identified the area as having high 

potential for mineral development and no mining claims exist (USDA Forest Service 

1997a). 

Virginia Lake – USGS estimates the undiscovered mineral resource to have a 

moderate value. BLM lists this area as having potential for mineral development. 

There are no existing claims in the river corridor in the Recreational River LUD 

(USDA Forest Service 1997a). The timber sale schedule identifies two sales for this 

management area that could occur within and adjacent to this corridor, consistent 

with the Recreational River prescription (USDA Forest Service 1997a). 
Environment and Effects 3 

Other Special Land Use Designations 3-486 Final EIS

Ecological, scenic, and recreational attributes within the Wild, Scenic, and 

Recreational River LUDs could be indirectly affected by activities permitted within 

adjacent LUDs. Table 3.21-3 summarizes the types of LUDs adjacent to Wild, 

Scenic, and Recreational River LUDs under each alternative. 

For most of the river segments, all seven alternatives are identical with respect to 

the LUDs for lands adjacent to the rivers. Six of the river LUDs (Blue River, 

Chickamin River, Hasselborg River and Lakes, King Salmon River, LeConte Glacier 

and Petersburg Creek) are within designated wilderness areas. Similarly, five river 

LUDs (Anan Creek, Kadashan River, Lisianski River, Naha River, and Salmon Bay 

Lake and Stream) are entirely or predominantly within LUD II areas. Aside from 

these river segments within Congressionally designated units, lands adjacent to nine 

other Wild, Scenic, or Recreational River LUDs remain the same for all seven 

alternatives. In almost all cases, these adjacent LUDs are in the mostly natural 

setting LUD group. 

Differences among the alternatives with respect to LUDs adjacent to Wild, Scenic or 

Recreational Rivers apply to 11 of the river LUDs. In most cases, Alternatives 1 and 

2 would result in more lands adjacent to river segments in natural setting LUDs. 

Alternative 7 and, to a lesser extent, Alternative 4 would result in more extensive 

areas of moderate and intensive development LUDs adjacent to river segments. 

Table 3.21-3 

LUDs Adjacent to Wild, Scenic, and Recreational Rivers by Alternative

Alternative 

River Name 1 2 3 4 5 6 7 

Aaron, Oerns, Berg Creeks N N N N N N N 

Anan Creek N N N N N N N 

Blind River N N N N N N N/M 

Blue River W W W W W W W 

Chickamin River W W W W W W W 

Essowah Lake and streams N N N N N N N 

Fall Dog Creek (local) N N N N N N N 

Farragut River N N N N N N N 

Gilkey River N N N N N N N 

Glacial River N N N N N N N 

Gokachin-Mirror-Low-Fish Creeks N/W N/W N/W N/W/I N/W N/W W/M/I 

Harding River N N N N/M N/M N/M N/M 

Hasselborg River and Lakes W W W W W W W 

Kadake Creek N/M/I N/M/I N/M/I N/M/I N/M/I N/M/I N/M/I 

Kadashan River N N N N N N N 

Kah Sheets Creek and Lake N N N/I N/I N/I N/I N/I 

Katzehin River N N N N N N N 

Kegan Lake and streams N N N/I N/M/I N/I N/I N/M/I 

King Salmon River W W W W W W W 

Kutlaku Creek and Lake N N N N N N N 

LeConte Glacier W W W W W W W 

Lisianski River N N N N N N N 

Naha River N N N N N N N 

Orchard Creek and Lake N N N/I N/M/I N N/I N/M/I 

Petersburg Creek W W W W W W W 

Salmon Bay Lake and stream N/M N/M N/M N/M N/M N/M N/M 

Santa Anna Creek - Lake Helen N N N/I I N/M/I N/I M/I 

Sarkar Lakes N/M/I N/M/I N/M/I N/M/I N/M/I N/M/I N/M/I 

Thorne River-Hatchery Creek N/M/I N/M/I N/M/I N/M/I N/M/I N/M/I M/N 

Virginia Lake and Creek N N M M M M M 

Wolverine Creek-McDonald Lake N N I N N N N 

Note: Letter symbols represent the following: N = Natural Setting LUD group; W = Wilderness LUD group; 

M = Moderate Development LUD group; I = Intensive Development LUD group.
 Environment and Effects 3 

Final EIS 3-487 Other Special Land Use Designations 

There would be no change in the number of units or acres with RNA or Wild, Scenic, 

or Recreational River LUDs under any of the alternatives. As a result, there would 

be no cumulative effects associated with these types of special LUDs under the 

Forest Plan Amendment. With respect to both Experimental Forests and Special 

Interest Areas, Alternative 5 would maintain the current acreage within these LUDs, 

while all other alternatives would recommend increases in the acreage. The net 

effect of these proposed changes would be a minor increase in the total acreage 

within mostly natural setting LUDs, and a slight decrease in the extent of 

developmental activities within the Tongass. As a result, there would be no 

cumulative effects associated with special LUDs under Alternative 5, and a slightly 

reduced potential for cumulative effects to Tongass resources under all other 

alternatives. 

Cumulative 

Effects 
Environment and Effects 3 

Other Special Land Use Designations 3-488 Final EIS

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 Environment and Effects 3 

Final EIS 3-489 Economic and Social Environment 

Economic and Social Environment 

Affected Environment.................................................................................. 3-490

Introduction ............................................................................................... 3-490

Regional Economic Overview.................................................................. 3-491

Natural Resource-Based Industries....................................................... 3-494

Wood Products.......................................................................................... 3-499

Overview ................................................................................................ 3-499

Harvest................................................................................................... 3-500

Production and Employment.................................................................. 3-501

Current Status of the Industry ................................................................ 3-502

Market Demand...................................................................................... 3-504

Recreation and Tourism........................................................................... 3-511

Recreation and Tourism in Southeast Alaska........................................ 3-511

Recreation and Tourism on the Tongass National Forest ..................... 3-513

Commercial Fishing and Seafood Processing ...................................... 3-518

Mining and Mineral Development............................................................ 3-520

Natural Amenities and Quality of Life..................................................... 3-521

Payments to the State............................................................................... 3-524

Environmental Consequences ................................................................... 3-525

Economic Impact Analysis....................................................................... 3-526

Wood Products and Timber Demand—Long-Term Effects ................... 3-526

Wood Products and Timber Demand —Short-Term Effects ................. 3-537

Recreation and Tourism......................................................................... 3-539

Mining..................................................................................................... 3-541

Transportation and Utilities .................................................................... 3-542

Salmon Harvesting and Processing....................................................... 3-542

Natural Amenities and Quality of Life..................................................... 3-542

Summary of Impacts .............................................................................. 3-543

Economic Efficiency Analysis ................................................................. 3-544

Introduction............................................................................................. 3-544

Comments on the Draft EIS ................................................................... 3-545

Revised Economic Efficiency Analysis .................................................. 3-546

Timber .................................................................................................... 3-546

Recreation and Tourism......................................................................... 3-548

Management Costs ................................................................................ 3-549

Salmon Harvesting and Processing....................................................... 3-550

Mining..................................................................................................... 3-550

Subsistence............................................................................................ 3-550

Non-use Values and Ecosystem Services............................................. 3-551

Natural Amenities and Quality of Life..................................................... 3-556

Tongass National Forest Budget............................................................. 3-557

Payments to the State............................................................................... 3-558

Cumulative Effects.................................................................................... 3-558
3 Environment and Effects

Economic and Social Environment 3-490 Final EIS

Affected Environment 

Introduction 

The Tongass National Forest stretches roughly 500 miles from Ketchikan in the 

southeast to Yakutat in the northwest and includes approximately 80 percent of the 

land area in Southeast Alaska. The region is sparsely settled with more than 70,000 

people living in 32 towns and villages located in and around the Forest. The 

communities of Southeast Alaska depend on the Tongass National Forest in various 

ways, including employment in the wood products, commercial fishing and fish 

processing, recreation, tourism, and mining and mineral development sectors. Many 

residents depend heavily on subsistence hunting and fishing to meet their basic 

needs. In addition, natural amenities, subsistence resources, and recreation activities 

associated with the Tongass National Forest form an important part of the quality of 

life for many residents of Southeast Alaska. Since there is very little private land in 

the region to provide these resources and opportunities, appropriate management of 

the Tongass National Forest is extremely important to local communities and the 

overall regional economy. 

The Tongass National Forest is also an important national and international resource, 

with an estimated 948,000 cruise ship passengers visiting Juneau in 2005 (McDowell 

Group 2005), representing a 48 percent increase since 2000. For many, a visit to the 

Tongass is a once-in-a-lifetime experience and the spending by these visitors drives 

the recreation and tourism sector, which is the largest natural resource-based sector 

in the regional economy. The Tongass National Forest contains large areas of 

essentially undisturbed forest lands, which represent increasingly scarce and, 

therefore, increasingly valuable ecosystems. These lands have value for many 

people who may never visit Southeast Alaska, but benefit from knowing that the 

Tongass National Forest is there. This type of value, often referred to as non-use 

value, includes existence, option, and bequest values. These values represent the 

value that individuals obtain from knowing that the Forest exists, knowing that it would 

be available to visit in the future should they choose to do so, and knowing that it 

would be left for future generations to inherit. 

The economic and social assessment prepared for this EIS is divided into two main 

sections: 1) Regional and National Economy, and 2) Subregional Overview and 

Communities. This section—Economic and Social Environment—evaluates the 

potential regional and national economic impacts. The next section—Subregional 

Overview and Communities—also assesses impacts to the economic and social 

environment, but at the subregional and community level. 

Southeast Alaska is divided into five boroughs and three census areas. The five 

boroughs correspond with the county governments found elsewhere in the United 

States. Three of these boroughs, Juneau, Sitka, and Yakutat, are city/boroughs. The 

other two, Ketchikan Gateway and Haines, have independent incorporated 

communities within their boundaries. The remaining areas that are not part of a 

borough are allocated to three census areas: Prince of Wales-Outer Ketchikan, 

Skagway-Hoonah-Angoon, and Wrangell-Petersburg. While census areas are only 

statistical units, they are widely recognized from a data reporting standpoint by federal 

agencies and most state agencies as county equivalents. 

More than 70,000 people live in the towns, communities, and villages of Alaska’s 

southeastern panhandle, most of which are located on islands or along the narrow 

coastal strip. Only four of Southeast Alaska’s 32 communities met the U.S. Census 

Bureau’s 2000 definition of an urban cluster (population greater than 2,500) in 2005 

(Juneau, Sitka, Ketchikan, and Petersburg). Juneau, which is the state capital and a 
 Environment and Effects 3 

Final EIS 3-491 Economic and Social Environment 

regional trade center, accounted for 43 percent of Southeast Alaska’s total population 

in 2005 (Alaska Department of Labor [DOL] 2006a). Ketchikan Gateway Borough, the 

second largest borough in Southeast Alaska, accounted for about 19 percent of the 

region’s population in 2005. Ketchikan is a smaller regional trade center that serves 

Prince of Wales Island and the surrounding area. Population is discussed in more 

detail in the Subregional Overview and Communities section of this EIS. 

The remote nature of the region is reflected in a population density of approximately 

two persons per square mile, which is much lower than the United States’ average of 

80 persons per square mile. Population densities by borough/census area in 2000 

ranged from 0.4 in the Skagway-Hoonah-Angoon census area to 11.4 in Ketchikan 

Gateway Borough (U.S. Census Bureau 2001). Many locations are accessible only 

by boat or plane, and landing strips or seaplane facilities are located in virtually all 

communities. The Alaska State ferry system transports people and vehicles between 

several ports in Southeast Alaska, and Prince Rupert, British Columbia, and 

Bellingham, Washington. Haines and Skagway, at the northern end of the Forest, and 

Hyder at the southern end, offer access to interior and Southcentral Alaska via the 

Alaska Highway, and Canada via the Cassiar Highway. 

The following sections provide an overview of the social and economic conditions in 

Southeast Alaska and provide a baseline against which the potential effects of the 

proposed alternatives are measured. 

Regional Economic Overview 

The Tongass National Forest plays an important role in the formal and informal 

economies of Southeast Alaska. The formal economy includes those economic 

activities that are recorded in official statistics. The informal economy includes 

activities that are not typically recorded in official statistics, such as subsistence, inkind contributions, non-cash income, unpaid labor and labor exchanges, and care 

giving to the young and old (Ratner 2000). 

Summary economic data are presented for Southeast Alaska for 1996 and 2005 in 

Table 3.22-1. Annual rates of growth are presented for this period. These data 

indicate that employment in Southeast Alaska increased by approximately 2 percent 

over this period (Table 3.22-1). Data compiled by the Alaska DOL indicate that 

employment in Southeast Alaska has fluctuated over the last decade with a year of 

job growth often followed by a year of net job loss (Gilbertson 2006). 

Adjusted for inflation, total personal income in Southeast Alaska was almost the same 

in 2005 as it was in 1996 ($2,598 million versus $2,587 million). Total personal 

income in Alaska and the U.S. increased over this period with respective annual 

growth rates of 2.2 percent and 2.7 percent. Per capita income in Southeast Alaska 

was higher in 2005 than 1996, but increased at a slower rate than the Alaska and U.S. 

averages. Average earnings per job in Southeast Alaska, adjusted for inflation, were 

7 percent lower in 2005 then 1996, a decrease of 0.8 percent per year, compared to 

state and U.S. annual growth rates of 0.2 percent and 1.4 percent over the same time 

period (Table 3.22-1). 

Per capita income in Southeast Alaska was similar to the statewide average in 2005, 

and six percent higher than the national average. Average earnings per job, which 

were higher than the national average in 1996 were lower in 2005, with average 

earnings per job in Southeast Alaska equal to 88 percent of the national average 

(Table 3.22-1). The region’s unemployment rate (7.9 percent) was higher than the 

state (6.9 percent) and national (5.1 percent) averages in 2005. 
3 Environment and Effects

Economic and Social Environment 3-492 Final EIS

Table 3.22-1 

Southeast Alaska Economic Overview

 1996 to 2005 

SE AK 

1996 2005 

SE AK 

Percent 

Change 

SE AK 

Growth 

Rate (%) 

Alaska 

Growth 

Rate (%) 

U.S. 

Growth 

Rate (%) 

Total Personal Income 

(Million 2005 dollars) 2,598 2,587 0% 0.0 2.2 2.7 

Population 74,559 71,043 -5% -0.5 1.0 1.1 

Average Annual Employment 50,208 51,188 2% 0.2 1.8 1.5 

Per Capita Personal Income 

(2005 dollars) 34,848 36,411 4% 0.5 1.2 1.6 

As percent of Alaska 

Average 109% 102% 

- - - - 

As percent of U.S. 

Average 116% 106% 

- - - - 

Average Earnings per Job 

(2005 dollars /year) 37,801 35,170 -7% -0.8 0.2 1.4 

As percent of Alaska 

Average 95% 87% 

- - - - 

As percent of U.S. 

Average 107% 88% 

- - - - 

Non-Job Related Earnings 

Per Capita (2005 dollars) 11,148 11,171 0% 0.0 0.2 0.7 

As percent of Total Per 

Capita Income 32% 31% 

- - - - 

SE Alaska Unemployment 

Rate 7.0 7.9 

- - - - 

Alaska Unemployment Rate 7.3 6.9 - - - - 

U.S. Unemployment Rate 5.4 5.1 - - - - 

Notes: 

SE AK = Southeast Alaska 

1. Income and earnings figures for 1996 are adjusted for inflation and presented as the amount they would be 

worth in 2005. 

2. Full and part-time employment includes self-employed workers. Employment data are by place of work, not 

place of residence, and therefore include people who work in Southeast Alaska but do not live there. The 

nonresident share of total private employment in Southeast Alaska was estimated to be approximately 28.1 

percent in 2004 (Hadland et al. 2006). Employment is measured as the average annual number of jobs, fulltime plus part-time, with each job that a person holds counted at full weight. 

Source: Alaska DOL 2007a, 2007b, 2007c; U.S. Department of Commerce, Bureau of Economic Analysis 2007a, 

2007b, 2007c, 2007d; U.S. Department of Labor, Bureau of Labor Statistics 2007 

Southeast Alaska employment is summarized by sector in Table 3.22-2. State and 

local government, consumer services, and retail trade were the largest employers in 

2001 and 2005, accounting for 21, 14, and 12 percent of total employment in 2005, 

respectively. Total employment increased by about 1,630 jobs or 3 percent between 

2001 and 2005, with self-employed workers (proprietors) accounting for 66 percent of 

this increase. The largest increases in absolute terms were in the health care (1,235 

jobs), retail trade (510 jobs), and real estate and rental and leasing (444 jobs) sectors. 

The largest absolute decreases occurred in the construction (-346 jobs) and the 

professional and technical services (-242) sectors. These gains and losses were not 

evenly distributed throughout the region, as discussed in the Subregional Overview 

and Communities section. 
 Environment and Effects 3 

Final EIS 3-493 Economic and Social Environment 

Table 3.22-2 

Southeast Alaska Employment by Sector, 2001 and 2005

Number of Jobs 

Share of Total 

(percent) 

Percent 

Change 

2001 2005 2001 2005 

2001 to 

2005 

2005 Location 

Quotient3 Total full-time and parttime employment1 49,556 51,188 100 100 3 1.0 

Type of Employment

 Wage and salary employment 37,850 38,401 76.4 75.0 1 1.0 

 Proprietors employment 11,706 12,787 23.6 25.0 9 1.1 

Wage and Salary Employment by Industry

 Farming 29 30 0.1 0.1 3 0.3 

 Forestry, fishing, related 

activities, and other 805 775 1.6 1.5 -4 0.5 

 Mining 36 38 0.1 0.1 6 0.0 

 Construction 2,388 2,040 4.8 4.0 -15 0.6 

 Manufacturing 1,838 1,764 3.7 3.4 -4 1.0 

 Wholesale trade 60 67 0.1 0.1 12 0.1 

 Retail trade 5,442 5,952 11.0 11.6 9 1.1 

 Transportation and 

warehousing 2,757 2,655 5.6 5.2 -4 1.0 

 Finance and insurance 965 917 1.9 1.8 -5 0.7 

 Real estate and rental and 

leasing 1,105 1,549 2.2 3.0 40 0.7 

 Services (Consumer)2

 7,117 7,073 14.4 13.8 -1 1.0 

 Services (Producer)2

 2,405 2,361 4.9 4.6 -2 0.4 

 Services (Social)2

 3,306 4,719 6.7 9.2 43 0.8 

 Federal government 2,827 3,226 5.7 6.3 14 0.7 

 State and local government 11,072 10,928 22.3 21.3 -1 1.5 1

 See Table 3.22-1, note 2. 

2

 Nine 2-digit North American Industry Classification System (NAICS) categories are combined into these three divisions for 

ease of presentation. Consumer service includes: other services; arts, entertainment, and recreation; and accommodation 

and food services. Producer services includes: information; professional and technical services; management of companies 

and enterprises; and administrative and waste services. Social services includes: educational services; and health care and 

social assistance. 3

 The location quotient is a relative measure of industry specialization that compares the percentage of employment 

concentrated in each sector in the study region with a benchmark region, in this case the State of Alaska. A location quotient

of 1.0 indicates that the study region has the same percentage of employment in this sector as the benchmark region does. 

Location quotients above or below 1.0 indicate that the study region is over or under represented in this sector, respectively.

Source: U.S. Department of Commerce, Bureau of Economic Analysis 2007b. 

The location quotients in Table 3.22-2 (see note 3) compare the regional employment 

distribution with the state average and indicate Southeast Alaska’s economy is 

specialized in the state and local government and retail trade sectors (Table 3.22-2). 

The relative concentration in the government sector largely reflects the location of the 

state capital in Juneau, but the relatively high proportion of government employment 

in the other Southeast Alaska communities also plays a part. With the exception of 

manufacturing, transportation and warehousing, and consumer services, which have 

location quotients of 1.0, all other sectors in Southeast Alaska are relatively 

underrepresented. 

The government sector is the main source of year round employment in all the 

communities in Southeast Alaska. In addition to direct employment in the government 

sector, many of the area’s private sector jobs are also dependent on government 

funding and contracts. Private sector activities dependent on government funding 

include road construction and even health services, with the region’s largest private 

employer, Southeast Alaska Regional Health Corporation, relying heavily on 

government funding (Gilbertson 2004). 
3 Environment and Effects

Economic and Social Environment 3-494 Final EIS

Recreation and tourism are heavily represented in the economy of Southeast Alaska. 

This is not readily apparent from Table 3.22-2 because recreation and tourism-related 

activities are distributed over a number of standard economic sectors, mainly retail trade 

and consumer services. The percent of the total workforce that is self-employed in 

Southeast Alaska is slightly higher than the state average, 24 percent compared to 22 

percent (location quotient of 1.1), and higher than the national average of 19 percent. 

Much of this self-employment is associated with the retail trade and consumer services 

sectors and is sensitive to recreation and tourism activity. Commercial fishing also 

accounts for a large share of self-employment in Southeast Alaska. 

The following section discusses the relative contribution of natural resource-based 

industries to the regional economy, and more specifically those industries that could 

be potentially affected by the proposed alternatives. 

Overview 

Wood products, recreation and tourism, and mining are the primary natural resourcebased industries that could be affected by the alternatives. The following discussion 

focuses on these industries, but also provides summary information on commercial 

fishing and seafood processing to provide a more complete overview of the 

contribution of natural resource-based industry to the regional economy of 

Southeast Alaska. 

In most cases, the employment, income, and revenue figures derived for these 

industries required a series of steps, each involving assumptions and potential 

sources of error. Where possible, these assumptions are stated and the nature of the 

associated problems discussed. 

Direct Employment 

Direct employment in natural resource-based industries accounted for 21 percent of 

total employment in Southeast Alaska in 2005 (Table 3.22-3). The distribution of 

resource-dependent employment is shown by industry in Figure 3.22-1. The leisure 

and hospitality sector, used here to represent recreation and tourism, accounted for 

45 percent of direct resource-dependent employment in 2005. Fish harvesting and 

seafood processing accounted for an estimated 28 percent and 18 percent, 

respectively. Forestry and logging and wood products together accounted for 5 

percent of natural resource employment, with mining accounting for the remaining 4 

percent (Figure 3.22-1). 

Natural 

Resource-Based 

Industries 
 Environment and Effects 3 

Final EIS 3-495 Economic and Social Environment 

Table 3.22-3 

Natural Resource-Based Industry Employment, 2005 

Industry 

2005 Direct 

Employment 

Direct 

Employment 

as a Percent 

of SE Alaska 

Total4/

2005 Total 

Employment 

Total 

Employment 

as a Percent of 

SE Alaska 

Total 

Forestry and Logging 351 1% 674 2% 

Wood Products 105 0% 219 1% 

Mining 312 1% 462 1% 

Leisure and Hospitality1/ 3,586 9% 4,339 11% 

Seafood Processing 1,500 4% 2,460 6% 

Resource Dependent Total2/ 5,854 15% NA NA 

Total Wage and Salary 

Employment3/ 36,700 94% 36,700 93% 

Fish Harvesting (proprietors) 2,281 6% 2,806 7% 

Southeast Alaska Total4/ 38,981 100% 39,506 100% 

1/There are no recent available estimates of recreation and tourism employment available for Southeast Alaska. The Leisure 

and Hospitality sector is used here as a relative indication of the importance of this industry. This sector includes the Arts, 

Entertainment, and Recreation and Accommodation and Food Services sub-sectors. 

2/There is no total provided for 2004 Total Employment because indirect employment for the seafood processing sector 

includes salmon harvesting and summing the totals for these sectors would result in some salmon harvesting employment 

being double counted. 

3/This total and the direct employment numbers for the above sectors represent non-agricultural wage and salary employment 

and do not include proprietors or self-employed workers. 

4/This total includes proprietors employment for the fish harvesting sector only. 

Sources: Alaska DOL 2006a, 2006b, 2007d. 

Figure 3.22-1 

Direct Resource-Dependent Employment by Sector 2005 

Seafood 

Processing

18%

Fish 

Harvesting

28%

Mining

4%

Forestry and 

Logging

4%

Wood Products

1%

Leisure and 

Hospitality

45%

Total = 8,135 Employees (Average Annual Employment) 

Source: see Table 3.22-3 
3 Environment and Effects

Economic and Social Environment 3-496 Final EIS

Total Employment and Earnings 

Economic activity in one sector generates activity in others as firms purchase services 

and materials as inputs (termed “indirect” effects) and employees spend their earnings 

within the local economy (“induced” effects). In what is known as the multiplier effect, 

each industry possesses a multiplier that represents its impact on the regional 

economy given its particular distribution of local purchases and payments. The total 

effects (i.e., direct, indirect, and induced) generated by an industry are calculated by 

multiplying employment within that industry (“direct” effects) by the appropriate 

multiplier. 

The analysis presented in this EIS uses industry-specific multipliers to assess the total 

employment and income effects of the alternatives. These multipliers are also used to 

estimate total natural resource-based employment in 2005 (Table 3.22-3). The 

multipliers used in this analysis are presented in Table 3.22-4. These multipliers were 

estimated using IMPLAN, an input-output model commonly used in this type of 

application. Total employment and income estimates derived using these multipliers 

include both indirect and induced effects. 

Table 3.22-4 

Employment and Income Multipliers 

 Employment Income 

 Sawmills 2.09 1.51 

 Logging 1.92 1.39 

 Mining 1.48 1.25 

 Recreation and Tourism 1.21 1.32 

 Salmon Harvesting 1.23 2.37 

 Seafood Processing 1.64 1.32 

Notes: 

1. These multipliers were estimated using the 1998 IMPLAN model. 

2. The multipliers shown in this table are for total (direct, indirect, and induced) employment or income. Ten direct 

sawmill jobs would, for example, result in total (direct, indirect, and induced) employment of approximately 21 jobs.

The software and databases necessary to run IMPLAN are available commercially 

from the Minnesota IMPLAN Group. The IMPLAN system adjusts national level data 

to fit the economic composition and estimated trade balance of a chosen region and 

can be used to construct county or multi-county models for any region in the United 

States. The model used for this analysis consists of the boroughs and census areas 

that comprise Southeast Alaska. The data used to estimate the multipliers in Table 

3.22-4 were obtained from standard data sets produced and maintained by the 

Minnesota IMPLAN Group. Concerns have been raised with respect to the ability of 

IMPLAN and similar input-output models to accurately predict indirect and induced 

effects. Alternate techniques for estimating these effects are, however, subject to the 

same, or similar, criticisms and more accurate estimates are not readily available for 

this analysis. While the multipliers presented here should be viewed with caution, the 

resulting estimates of indirect and induced employment provide a basis for 

comparison between alternatives. 

The estimates of resource-dependent employment shown in Figure 3.22-1 are only for 

direct employment and, as a result, do not fully illustrate the role that resourcedependent industries play in the regional economy. Adding indirect and induced 

employment effects alters the relative contribution of the various sectors because 

employment multipliers vary by industry, but provides a more complete picture of the 

economic importance of resource dependent industries. The relative contribution is 

also different when measured in terms of income because wage rates vary by sector, 

with higher average wages paid in the mining and wood products sectors. Total 

employment estimates are presented in Table 3.22-3 to provide perspective on the 

overall contribution of natural resource-based industries to the region’s economy, as 

well as the relative significance of each sector. 
Environment and Effects 3 

Final EIS 3-497 Economic and Social Environment 

Nonresident and Seasonal Employment 

Nonresident and seasonal employment are two important and related aspects of 

resource-dependent employment in Southeast Alaska. Nonresident employment 

shares are shown for each resource-dependent industry and the region as a whole in 

Figure 3.22-2. Nonresident workers accounted for 44 percent of employment in the 

resource-dependent sector as a whole in 1994, approximately twice the regional 

average. Seafood processing and recreation and tourism had the largest nonresident 

shares, but all of the resource-dependent industries, with the exception of guided 

hunting, had nonresident shares above the regional average. Many nonresidents 

work a relatively short time in Alaska, often for just 2 or 3 months, generally spend the 

bulk of their earnings elsewhere, and, as a result, contribute less to the regional 

economy than resident workers. 

Figure 3.22-2 

1994 Nonresident Share of Direct Employment in Southeast Alaska, Total 

and Resource-Dependent Industries 

0%

10%

20%

30%

40%

50%

60%

70%

80%

Southeast

Alaska Total

ResourceDependent

Total

Wood

Products

Mining Recreation/ 

Tourism

Fish

Harvesting

Seafood

Processing

Hunting Sport

Fishing

Note: All employment figures are standardized to annual average employment. 

Source: USDA Forest Service 1997a (Figure 3-16). 

Figure 3.22-2 was prepared for the 1997 Forest Plan EIS using data compiled by the 

Alaska DOL. More recent comparable data are not available. However, statewide 

nonresident data suggest the nonresident shares shown in Figure 3.22-2 are 

generally representative of current patterns. Seafood processing had the highest 

percentage of nonresident workers in Alaska in 2004, with almost three quarters of the 

labor force (72 percent) comprised of nonresidents. This is comparable with the 1994 

data, which showed that 75 percent of workers in the seafood processing sector in 

Southeast Alaska were nonresidents. Similarly, statewide in 2004, nonresident 

workers comprised 33 percent of statewide employment in the logging and wood 

products sector in 2004, compared to 35 percent in Southeast in 1994 (Hadland et al. 

2006). 

Nonresidents accounted for approximately 28.1 percent of private sector employment 

in Southeast Alaska in 2004, compared to 21.3 percent for the state as a whole. 

Within Southeast Alaska, the nonresident share of employment ranged from 18.9 

percent in Juneau to 44.3 percent and 49.7 percent in Haines and Skagway-HoonahAngoon, respectively. The relatively low level of nonresident employment in Juneau 

reflects the importance of the government sector, which accounted for 42 percent of 

employment in Juneau in 2005 (Alaska DOL 2006b). 
3 Environment and Effects

Economic and Social Environment 3-498 Final EIS

Average annual seasonal variations in employment are shown for resourcedependent industries and the region as a whole in Figure 3.22-3. As shown in this 

figure, seasonal variations in resource-based employment—the difference between 

peak levels of employment in the summer and dips in the winter—are often quite 

pronounced. The measure shown in the figure is calculated by dividing the difference 

between summer maximum and winter minimum employment by annual average 

employment. Expressed as a percentage, this figure allows comparison between 

different industries and the regional economy as a whole. Seafood processing shows 

a very high degree of seasonal variation. Data for 2000 through 2004 for salmon 

harvesting are not shown in Figure 3.22-3, but using the same measure show an 

annual degree of seasonal variation that is slightly more than twice the variation for 

seafood processing, with employment ranging from about 100 people in January to as 

many as 18,700 in July (Patton and Robinson 2006). 

Although not reported here, it is safe to assume, based on the distribution of visitors 

throughout the year among other things, that recreation and tourism also shows a 

high degree of seasonal variation. Data are presented for the Leisure and Hospitality 

sector in Figure 3.22-4 as a proxy for recreation and tourism and show a degree of 

variation substantially lower than the salmon harvesting and seafood processing 

sectors, but more than twice the Southeast Alaska average. Data for the logging 

sector also show a high degree of seasonal variation; about half the variation for the 

seafood processing sector. Seasonal variation for wood products manufacturing was 

generally comparable with the Southeast Alaska average. The mining sector showed 

no seasonal variation, with 300 people reported in this sector for the entire three year 

period that data are available. Data are also presented for the government sector, 

which showed much less seasonal variation than the Southeast Alaska average 

(Figure 3.22-4). There is, however, some variation by type of government 

employment, with the seasonal variation for federal government employment more 

than twice the variation for state and local government, but still less than the 

Southeast Alaska average. 

These data indicate that much of the employment in resource-based industries in 

Southeast Alaska is seasonal and typically relies on a transient labor force. 

Communities that rely on this type of employment often have difficulty attracting other 

service providing industries that rely upon year round customers. Gilbertson (2004) 

suggests that Juneau has experienced relatively large private sector growth over the 

last decade or so because the stable year round government employment there 

attracts service providing industries. This is not, unfortunately, the case with many 

smaller Southeast Alaska communities. 

Industry-Specific Descriptions 

The following subsections contain more detailed descriptions of each resourcedependent industry. 
 Environment and Effects 3 

Final EIS 3-499 Economic and Social Environment 

Figure 3.22-3 

Average Annual Seasonal Variation in Employment 2001-2005 (percent) 

Notes: 

1. Average seasonal variation is calculated here by dividing the difference between summer maximum and winter 

minimum employment by annual average employment. The resulting measure is expressed as a percentage. 

2. The estimates for logging and mining are based on three years data only (2001 to 2003). The wood products 

manufacturing estimate is based on just two years (2001, 2002). The other estimates are based on five years of 

data (2001 to 2005). 

3. There was no seasonal variation in mining employment during 2001 through 2003. 

4. Data for the salmon harvesting sector are available for 2000 through 2004. These data are not included in the 

graph because the degree of annual seasonal variation is an estimated 447 percent, slightly more than twice the 

variation for seafood processing. 

5. Data for the Leisure and Hospitality sector are used here to represent the Recreation and Tourism sector. 

Source: Alaska DOL 2006a, Patton and Robinson 2006 

Wood Products 

Direct employment in the wood products industry declined dramatically from its peak 

of 3,543 jobs in 1990 to 456 jobs in 2005, accounting for approximately 1 percent of 

total regional employment in 2004. Much of this job loss was associated with closure 

of the large pulp mills in Sitka (1993) and Ketchikan (1997), which collectively 

accounted for 899 jobs in 1990. These pulp mills accounted for about half of the 

federal timber harvest from 1970 up until their closure and also processed much of the 

chip by-products (manufacturing residues) from the region’s sawmills over this period. 

Closure of the pulp mills had a major effect on the regional demand for timber and the 

market for wood chips, which has directly affected the region’s remaining sawmills. 

A larger absolute decline in wood products employment over this period occurred in 

the logging sector with a net decline of 1,842 jobs over the same period, a decrease 

from 2,144 jobs in 1990 to just 302 jobs in 2004. This decline in logging employment 

partly occurred due to a reduction in harvest from the Tongass National Forest, with 

annual harvest declining from 471 million board feet (MMBF) in 1990 to 46.3 MMBF in 

2004, but large reductions in annual harvest also occurred on private lands, with 

Overview 

0

50

100

150

200

250

Southeast

Alaska Total

Logging Minin Seafood

Processing

Wood

Products

Manufacturing

Leisure and

Hospitality

Government

Economic Sector

Percent

Seasonal Variation
3 Environment and Effects

Economic and Social Environment 3-500 Final EIS

annual private harvests declining from 506.1 MMBF to 98.9 MMBF over the same 

period. 

There have been major shifts in markets served by Alaska sawmills over the past 

decade. Up to 95 percent of production was exported to Japan prior to 1997. Foreign 

exports have fallen since 2000 and the proportion of volume shipped to domestic 

markets in the lower 48 states has increased, ranging from 60 percent to 83 percent 

of total production. Shipments to domestic markets are primarily shop lumber or niche 

specialty products. Western hemlock is the main species processed by Alaska mills, 

accounting for 50 to 56 percent of total production (Brackley et al. 2006a). Sawn 

wood products, like any other commodity, will be sold in the markets that create the 

most profit for the seller. Domestic markets for Southeast Alaskan sawn wood 

products are often more attractive at present than foreign markets. Changes in 

demand, prices, and cost structures have had dramatic effects on the Southeast 

Alaskan timber industry and on the profitability of the remaining facilities. 

Timber harvest within Southeast Alaska is the main source of raw materials for the 

region’s wood products industry. Raw material imports averaged just two percent of 

Southeast Alaska’s total round wood consumption from 1983 through 1994 and there 

have been no notable saw log or utility log imports into the region in recent years (USDA 

Forest Service 2007d). The Ketchikan veneer mill restarted in 2007 using timber 

imported from British Columbia. More recently, the mill has acquired timber from a 

logging contractor that purchased timber from several Southeast Alaska timber sales 

(Brackley and Haynes, in press; Damstedt 2007). Annual Southeast Alaska timber 

harvest is shown by landowner for 1986 through 2005 in Figure 3.22-4. Total harvest 

levels ranged from peak levels of just under 1,000 MMBF in 1989 and 1990 to a low of 

169 MMBF in 2004. Total annual harvest increased to about 197 MMBF in 2005, with an 

increase in harvest on State lands accounting for much of this increase. Total harvest 

decreased in 2006, with much of the decline (33 MMBF) attributable to further reductions 

in harvest on Native Corporation lands (USDA Forest Service 2007d). 

The overall pattern of harvest levels shown in Figure 3.22-4 generally reflects broader 

trends in the wood products market. These include the global recession in the wood 

products industry that depressed output in the early to mid 1980s, the following boom, 

and the subsequent decline. In Southeast Alaska, harvest levels have shown an overall 

pattern of decline since 1990 (Figure 3.22-4). 

Figure 3.22-4 

Southeast Alaska Total Timber Harvests by Ownership, 1986-2006 

0

100

200

300

400

500

600

700

800

900

1,000

1,100

1986

1987

1988

19891990

1991199219931994199519961997

1998

1999

2000

2001

2002

200320042005

2006

Year

MMBF Log Scale 

State & BIA

Tongass

Private

Total

Notes: Harvests from Alaska Mental Health Trust and University of Alaska lands omitted prior to 2000. 

BIA = Bureau of Indian Affairs 

Source: USDA Forest Service 2002a, 2007d 

Harvest 
 Environment and Effects 3 

Final EIS 3-501 Economic and Social Environment 

The majority of the region’s harvest has historically come from two ownerships: the 

Tongass National Forest and Native corporation (private) lands. Prior to 2000, 

harvest from these two ownerships ranged from 96 percent to 99 percent of total 

harvest in Southeast Alaska. The combined Tongass and Native corporation share 

dropped to 83 and 76 percent in 2000 and 2001, respectively, with the inclusion of the 

Alaska Mental Health Trust and University of Alaska harvests as part of the state total 

(Figure 3.22-5). Harvest from the Tongass and Native corporation lands comprised 

78 percent of total harvest in 2005. Harvest from Native corporation lands accounted 

for the majority of this, with harvest from the Tongass accounting for 25 percent (49.5 

MMBF) of the total. Harvest from state lands since 2000 has ranged from 59.9 MMBF 

in 2000 to 24.2 MMBF in 2004, with a total of 42.9 MMBF harvested from state lands 

in 2005. Most timber harvested from state lands is processed in Alaska. In recent 

years the state has sold above its annual projected harvest levels to help bridge the 

gap between national forest harvest and local industry needs. 

Timber harvested from the Tongass and Native corporation lands largely flows into 

different markets which are not solely driven by price. In the case of the Tongass 

National Forest there are restrictions on shipments of raw materials that dictate how 

and to whom products can be sold. Yellow-cedar for example can be exported into 

foreign markets while western redcedar is appraised for local manufacture. Much of 

the Sitka spruce and western hemlock is processed locally, although under certain 

circumstances, those species can be shipped out of state. Low grade and small 

diameter Sitka spruce and western hemlock are appraised for shipment to markets in 

the lower 48 U.S. states. Once a timber sale is purchased, under certain 

circumstances, the purchaser can apply for a permit to ship logs to markets other than 

those they were appraised for. From 2001 to 2006, an average of 19 percent of the 

total volume harvested on the Tongass has been shipped in whole log form to 

domestic markets in other states or exported to foreign markets. Levels fluctuated 

greatly from year to year over this period, ranging from a low of 8 percent to a high of 

39 percent. Virtually all of timber harvested on Native corporation land is sold as 

whole log exports. 

The 1997 Forest Plan EIS (USDA Forest Service 1997a) noted that log exports 

comprised 43 percent of total Southeast Alaska production on a volume basis from 

1981 to 1995. At 36 percent of the total, pulp was the second largest production 

component over this period and far more stable than log exports. Lumber was noted 

as the smallest component of total production, averaging 19 percent of the total from 

1981 to 1995. The Ketchikan Pulp Corporation (KPC) pulp mill closed in 1997 and 

brought pulp production in the region to an end. Since 2000, logging has comprised 

70 percent of timber sector employment with sawmill employment accounting for the 

remaining 30 percent. 

In 2000 the total annual active sawmill processing capacity in Southeast Alaska was 

340 MMBF. A total of 87 MMBF was processed that year, utilizing 26 percent of the 

existing active capacity. Total active capacity has since declined to around 250 

MMBF and the volumes processed from 2003 to 2006 ranged from 31 MMBF (2004) 

to 34 MMBF (2005), and 12 to 13 percent of total capacity (Brackley et al. 2006b, 

Juneau Economic Development Council 2006, 2007).

Employment in the Southeast Alaska wood products sector has declined substantially 

since the peak of 1990 (see Figure 3.22-6), decreasing by 3,093 jobs, or 87 percent, 

between 1990 and 2004. While this total includes the entire pulp mill labor force, 

which accounted for 899 jobs in 1990, a larger absolute loss occurred in the logging 

sector, with 1,842 jobs lost between 1990 and 2004. A total of 456 people were 

employed in the wood products sector in 2005. Wood products-related indirect and 

induced employment was estimated at 437 jobs, resulting in a total of 893 jobs 

supported by the wood products industry in that year (Table 3.22-3). 

Production and 

Employment 
3 Environment and Effects

Economic and Social Environment 3-502 Final EIS

Employment increased slightly in 2005, with a total of 499 people employed in the 

wood products sector. Logging and sawmills accounted for 70 percent and 30 

percent of the total, respectively (USDA Forest Service 2007d). This small increase 

was mainly associated with an increase in logging employment not related to the 

Tongass National Forest (Figure 3.22-6). Employment decreased to 421 wood 

products jobs in 2006, with decreases in employment in all three active categories 

(Tongass logging, sawmill, and other logging) shown in Figure 3.22-6 (USDA Forest 

Service 2007d). 

Employment decreases tend to lag behind decreases in production, and further 

declines in employment levels are possible even if there are no further changes in 

harvest levels. 

It is clear from the preceding sections that the wood products industry in Southeast 

Alaska has undergone considerable change over the past decade. The closure of the 

Alaska Pulp Corporation (APC) pulp mill in Sitka and the KPC pulp mill in Ketchikan in 

1993 and 1997, respectively, had a substantial effect on the overall regional demand 

for timber. Wood consumption by these pulp mills accounted for about half of 

Tongass National Forest timber harvest from 1970 through the early 1990s and chip 

by-products from the region’s sawmills were historically used in pulp production 

(Brooks and Haynes 1997). The KPC pulp mill, for example, required 190 MMBF of 

pulpwood and/or chips to operate at its reported full annual capacity of 210,000 tons 

of pulp (USDA Forest Service 1997a). The analysis prepared for the 1997 Forest 

Plan Revision Final EIS noted that, on average, 19 percent of Native Corporation 

harvests were reportedly used in pulp production. The 1997 Forest Plan Revision 

Final EIS also noted that an average of 17 percent of Tongass National Forest logs 

were classified as utility grade, meaning that they were more likely to be used for pulp 

or chips because they could not be made into boards. 

Figure 3.22-6 

Southeast Alaska Timber Sector Direct Employment by Type, 1986-2006 

0

500

1,000

1,500

2,000

2,500

3,000

3,500

4,000

1986198719881989

1990

1991

1992

199319941995199619971998199920002001

2002

2003

2004

20052006

Employees-Average Annual 

Tongass Logging

Pulpmill

Sawmill

Other Logging

Total

Sources: USDA Forest Service 2002a, 2007d 

Recent harvest data indicate the utility share of total annual harvests on the Tongass 

decreased from approximately 19 percent in 1996 to around 12 percent in 2004 and 9 

percent in 2006 (USDA Forest Service 2002a, 2007d). Approximately 46.1 MMBF of 

utility and low grade saw logs were chipped in 2000 (26.9 and 19.2 MMBF, 

respectively). The majority of these chips were shipped to pulp mills in the continental 

U.S. (61.6 percent) and Canada (31.3 percent), with just 7.1 percent consumed in 

Current Status of 

the Industry 
 Environment and Effects 3 

Final EIS 3-503 Economic and Social Environment 

Alaska. While these data indicate that a market existed for chips in 2000, the market 

is limited for low-grade log chips at this time (Brackley et al. 2006a). 

Utility logs are logs that are at least two-thirds defective and, therefore, do not meet 

sawlog specifications. Since utility logs and sawlogs are mixed in the same tree 

stands, the loss of the market for wood chips has important implications for the 

economic viability of timber sales on the Tongass. (This is discussed further in the 

environmental consequences part of this section). As a result, timber sales on the 

Tongass include an Optional Removal clause (Forest Service Handbook [FSH]: 

2409.22 Chapter 630) that allows sale purchasers to leave behind utility logs. These 

logs still have to be purchased as part of the timber sale but the purchaser no longer 

has to remove them, saving on logging and haul costs. 

The Alaska Regional Forester (Region 10) signed a new policy in March 2007 that 

approved limited interstate shipments of unprocessed Sitka spruce and western 

hemlock (Bschor 2007). The policy allows shipment to the lower 48 states of 

unprocessed Sitka spruce and western hemlock sawlogs smaller than 15 inches in 

diameter at the small end of a 40-foot log, and grade 3 or 4 logs of any diameter. 

Shipments are 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 the Regional Forester grants an exception in advance based on 

case-specific unusual circumstances. 

This policy, referred to as the Limited Interstate Shipment Policy, is expected to 

increase the utilization of timber harvested on the Tongass and improve the 

economics of timber sales by providing a market for smaller diameter and low grade 

material that cannot be processed profitably by sawmills in Southeast Alaska 

(Alexander et al. 2007). 

A federal grant program was approved in 2001 and 2002 to help Alaska operators 

purchase drying and secondary processing equipment and mills in Alaska now have 

the ability to dry about 6.6 MMBF annually, with about 3.9 MMBF or 59 percent of the 

total State capacity located in Southeast Alaska. Approximately 0.8 MMBF of dry, 

surfaced lumber was produced in Alaska in 2004, with slightly more than half (51 

percent or 412 thousand board feet [MBF]) of this total produced in Southeast Alaska 

(Nicholls et al. 2006). In addition, the Ketchikan Wood Technology Center (KWTC), a 

nonprofit research and product development center that operates in partnership with 

the USDA Forest Service and the University of Alaska, was established in 2000. The 

center’s projects include development of new lumber grades and structural design 

values for Alaska wood species. Yellow cedar, hemlock, Sitka spruce and white 

spruce have been accepted as unique species for grading purposes by the American 

Lumber Standards Committee, with new design values for the species. In addition, 

KWTC implemented a testing program to develop new glued laminated timber beam 

designs utilizing Alaskan species and has been conducting other tests with potential 

future benefits to the industry in Southeast Alaska. The increased ability to produce 

dry, planed wood and updated grading rules for Alaskan lumber has allowed Alaskan 

producers to sell dimension lumber in local markets. 

Market shifts partly reflect the movement of smaller operators away from exporting 

round logs, chips, or rough-cut green lumber toward value added products and a 

movement toward direct marketing of finished products. Value-added products 

produced by small mills on Prince of Wales Island, for example, include molding, 

tongue-and-groove, log cabin-style paneling, and shingles (Petersen and Bruns 

2005), as well as wood for musical instruments. 

Utilization of Mill Capacity 

Changes in demand and prices have affected the Southeast Alaskan wood products 

industry and the profitability of the remaining facilities. The 1997 Forest Plan Revision 
3 Environment and Effects

Economic and Social Environment 3-504 Final EIS

Final EIS reported an average utilization rate of 66 percent during the 1985 to 1994 

time period (USDA Forest Service 1997a, Table 3-133). Utilization rates have shown 

a consistent downward trend in recent years, with mills in Southeast Alaska using just 

12 percent (31 MMBF) of total active capacity in 2004 and 13 percent (32.1 MMBF) in 

2005 (Table 3.22-5). Not only has the utilization rate decreased since the 1985 

through 1994 time period, but the total active capacity that production is measured 

against has also declined, stabilizing at 250 MMBF since 2002 (Brackley et al. 2006a). 

Actual mill output has, however, been fairly consistent over the past five years: 39.7 

MMBF in 2002, 32.0 MMBF in 2003, 31.0 MMBF in 2004, 34.7 MMBF in 2005, and 

32.1 MMBF in 2006 (Brackley et al. 2006b; Juneau Economic Development Council 

2006, 2007). 

The results of the utilization studies summarized in Table 3.22-5 include the larger 

mills and operators in Southeast Alaska. There are also a number of smaller mills not 

included in the study. According to Petersen and Bruns (2005), for example, there are 

16 small operations on Prince of Wales Island and only six of the facilities are 

included in Table 3.22-5. Although they are relatively small, these facilities may be 

important sources of economic activity for the communities they are located in or 

nearby. 

Table 3.22-5 

Active Timber Processors in Southeast Alaska in Calendar Years 2005 and 2006

 2005 2006 

Mill1 Location 

Estimated 

Mill 

Capacity 

(MBF)2

Actual 

Mill 

Output 

(MBF)3

Utilization 

of Installed 

Capacity 

(Percent) 

Actual 

Mill 

Output 

(MBF)3

Utilization 

of Installed 

Capacity 

(Percent) 

Viking Lumber Co. Craig 80,000 18,000 22.5 19,000 23.8 

Silver Bay, Inc. Wrangell 65,000 8,747 13.5 6,031 9.3 

Pacific Log & Lumber Ketchikan 39,600 4,824 12.2 4,234 10.7 

Icy Straits Lumber Co. Hoonah 20,000 500 2.5 700 3.1 

Northern Star Cedar Products4

 Thorne Bay 14,500 322 2.2 0 0 

Porter Lumber Co. Thorne Bay 12,500 600 4.8 500 4.0 

The Mill Petersburg 8,500 30 0.4 45 0.5 

Thuja Plicata Lumber Co. Thorne Bay 7,500 100 1.3 130 1.7 

Thorne Bay Wood Products Thorne Bay 5,000 682 13.6 600 12.0 

Southeast Alaska Wood Products Petersburg 4,500 100 2.2 200 4.4 

D&L Woodworks Hoonah 1,750 100 5.7 100 5.7 

Alaska Fiber4 Petersburg 1,500 0 0.0 0 0 

W.R. Jones and Son Lumber Co Craig 1,000 690 69.0 600 60.0 

Total Location 261,350 34,695 13.3 32,140 13.1 1 Only mills that were active in 2005 are included here. Two inactive mills were identified in the 2006 mill survey: KPC/Annette

Island Hemlock Mill (70 MMBF) and Gateway Forest Products Veneer Mill (30 MMBF), and (15 MMBF). Five mills were identified 

in the 2006 survey as “out-of-business”: Chilkoot Lumber Co., Gateway Forest Products Sawmill, Herring Bay Lumber Co., Kasaan 

Mountain Lumber & Log, and Metlakatla Forest Products. There are also a number of smaller mills not included in this study. 2 Annual capacity is estimated based on the volume of material used during 500 eight-hour shifts. 3 Actual mill production is the net sawlog volume (Scribner log scale) that was used during the year to manufacture sawn products. 4 The Northern Star Cedar Products and Alaska Fiber facilities did not process timber in 2006. Northern Star was subdivided among 

three owners and Alaska Fiber sold its primary processing equipment, but reportedly has plans to purchase and install new 

equipment. 

Source: Juneau Economic Development Council 2006, 2007 

Demand can be thought of as the different amounts of a product buyers are willing to 

purchase at different prices. Demand is not a single number, but instead a series of 

price-quantity relationships. The same is true of supply. It is the combination of 

supply and demand that determines the quantity and price of goods produced and 

consumed. When we talk about “timber” on the Tongass we are talking about a 

spectrum of products that are not necessarily freely exchangeable or replaceable with 

one another or other sources of timber. Thus, timber includes a mix of species, each 

with a potentially different demand and price. Timber also includes a range of log 

types from high quality saw logs to utility logs for which demand and price differ 

Market Demand 
 Environment and Effects 3 

Final EIS 3-505 Economic and Social Environment 

markedly. Finally, the ability of timber to satisfy demand will differ according to the 

location of that timber relative to mills and other existing infrastructure. Under current 

market conditions, standing timber in the northernmost portions of the Tongass is 

unlikely to satisfy the demand for timber by mill operators in Ketchikan almost 500 

miles away. 

Accurately projecting future demand is difficult and cannot be considered an exact 

science. Market demand for Southeast Alaska timber and wood products depends 

upon numerous difficult to predict factors, including changes in technology, growth 

and exchange rates in key markets, changes in consumer tastes and preferences, as 

well as developments in other producing regions whose products compete with those 

of Alaska. While demand is difficult to predict, industry relies on a stable timber 

supply in order to conduct long-term business planning. 

This section examines a number of indicators of demand for Tongass timber for the 

planning cycle, and discusses the methodologies, limitations, and conclusions of 

each. The analysis then considers the extent of the timber land base likely to be 

necessary to satisfy differing levels of demand. 

Demand Indicators 

Pacific Northwest Research Station Projections 

The Forest Service has commissioned the Pacific Northwest Research Station to 

prepare a number of projections of demand for Tongass timber over time, including 

Brooks and Haynes 1990, 1994, 1997. In connection with ongoing monitoring and 

preparation of this EIS, the Forest Service commissioned the Pacific Northwest 

Research Station to prepare a new set of projections, resulting in Brackley et al. 

2006a. Brackley et al. prepared a “derived demand” analysis and projected various 

demand figures for four potential scenarios using different assumptions about future 

markets and future processing facilities in Southeast Alaska. Derived demand looks 

at the overall end-market demand in foreign and domestic markets, and considers 

what portion of that demand Alaska is likely to fill. An example of end market demand 

in this case would be projected demand for Southeast Alaskan lumber (a final timber 

product) from markets in Asia. 

Brackley et al.’s model is a trend-based projection of quantities. Trends in 

consumption (e.g., sawn wood in Japan) and trends in exports (e.g., pulp to all 

destinations) constitute the basic structure of the model. In preparing this analysis, 

Brackley et al. used information about U.S. exports to Japan, and Japanese import 

and consumption data, as a benchmark for the historic data since those exports 

represented, until recently at least, the majority of sawn-wood production from 

Southeast Alaska. They considered about 40 years of historic data and trends in 

manufactured wood products exports to Japan to project 20 years into the future and 

adjusted projections to address recent shifts and potential additional shifts towards the 

continental U.S. and other parts of the entire Pacific Rim (including North America), as 

an end-market for Alaska wood products. Additional information on the Brackley et al. 

analysis is provided in an addendum report that addresses questions and concerns 

raised with respect to the original analysis (Brackley and Haynes, in press). 

Brackley et al.’s analysis has a number of limitations. Because it is based on trends 

over a long historic period, it has “smoothed out” short-term fluctuations. The timber 

industry is currently in a period of transition, increasing the likelihood of volatile shifts. 

In addition, demand cannot be considered in a vacuum. Demand will be influenced by 

costs of production, which in turn will be influenced by the willingness of producers to 

invest in improvements to efficiency. Decisions made in the Forest Plan relating to 

the timber base are believed likely to also have an impact on the producers 

willingness to invest. 
3 Environment and Effects

Economic and Social Environment 3-506 Final EIS

Although Brackley et al. (2006a) described the following four scenarios, those are not 

necessarily the only possible scenarios, and considerable variation is possible within 

any of the scenarios. Each scenario described below assumes the foundation of the 

preceeding scenario. In other words, Scenario 2, for example, describes an increase 

in demand beyond Scenario 1 and so forth. 

Scenario 1, Limited Timber Production, was an approximation of the current status of 

the timber industry in Southeast Alaska in 2006 with no market for lower grade logs. 

The recent policy change (March 2007) that resulted in the Limited Interstate 

Shipment Policy is expected to change this situation, with timber sale purchasers now 

able to export lower grade logs to the continental U.S. The current status is believed 

to be largely the result of supply limitations and not necessarily related to market 

demand. 

Scenario 2, Expanded Timber Production, assumes an increase in the Alaska share 

of the Pacific Rim markets, but no creation of facilities to process lower grade logs. 

However, a veneer plant could be a portion of the demand stimulation assumed in 

Scenario 2, as could the Limited Interstate Shipment Policy. 

Scenario 3, Medium Integrated Industry, assumes a demand stimulation in 2008 that 

creates demand for lower grade logs. Potential forms of demand stimulus identified 

by Brackley et al. (2006a) included medium density fiberboard (MDF) plants or 

biomass facilities. The Limited Interstate Shipment Policy could also contribute to this 

demand stimulus. 

Scenario 4, High Integrated Industry, assumes the demand stimulus in Scenario 3 

plus an additional stimulus, such as another facility coming on line in 2012. 

Scenarios 3 and 4 also assume a form of demand stimulation, such as a veneer plant, 

that uses medium and low-grade logs. Based on these scenarios, Brackley et al. 

developed the projections shown in Table 3.22-6. Brackley et al.’s projected volumes 

for the first two scenarios include decked sawlogs at the sawmills plus a portion of 

cedar logs that would be exported. They do not reflect the total amount of timber that 

needs to be sold to produce these decked sawlog timber and cedar volumes. 

Table 3.22-6 

Timber Production 1983 to 2002 and Demand Projections for 2003 to 2025 

(MMBF) 

 Brackley et al. Scenarios 

Period1

Limited 

Lumber 

Production 

Expanded 

Lumber 

Production 

Medium 

Integrated 

Industry2

High Integrated 

Industry2

1983-1987 281.0 281.0 281.0 281.0 

1988-1992 414.0 414.0 414.0 414.0 

1993-1997 200.2 200.2 200.2 200.2 

1998-2002 93.3 93.3 93.3 93.3 

2003-2007 30.0 33.7 44.4 44.4 

2008-2012 34.7 52.0 169.0 185.8 

2013-2017 38.7 75.4 204.4 299.0 

2018-2022 43.0 108.1 204.0 317.0 

2022-2025 46.7 142.9 204.4 360.1 1 The projections are for 2003 through 2025 and shown in bold in this table. The data for 1983 through 2002 

are the actual volumes processed in the years shown. 2 These projections assume an industry (one or more facilities) will be created that uses pulp chips produced 

by Southeast Alaska sawmills, low grade logs, and other biomass products in fiber based board, chemical, 

or energy facilities. Medium density fiberboard is one possible alternative identified in Brackley et al. 

(2006a). Chemical and energy uses are also possible. 

Source: Brackley et al. 2006a, Table 3
 Environment and Effects 3 

Final EIS 3-507 Economic and Social Environment 

Annual projections are presented for all four scenarios in Table 3.22-7. In addition to 

Brackley et al.’s estimated volume projections, this table also includes the total timber 

sale volume that would be needed under Scenarios 1 and 2. The total sale volumes 

for 2022 for each scenario are used in the long-term effects analysis in the 

Environmental Consequences part of this section. 

Installed Capacity and the McDowell Group et al. (2004) Southeast Conference 

Projections 

Another way to consider the potential volumes that might be demanded by the timber 

industry in Southeast Alaska is to look at installed mill capacity and determine how 

much timber must be sold and harvested to run the mills at various rates of mill 

capacity utilization. While we can assume mill owners want to operate their mills at an 

efficient level if economic timber supply is available, a limitation to this type of analysis 

is that it assumes there is a purchaser willing to buy the product at a price equal to or 

greater than the cost of production. In the long run, a mill owner cannot be expected 

to operate a mill at an “efficient” rate if the mill owner cannot sell the product at a 

profit. It should also be noted that a mill may not be able to operate indefinitely at a 

utilization rate far below the economically efficient rate without risking bankruptcy. 

Table 3.22-7 

Projected Demand for National Forest Timber from Brackley et al. (MMBF)

Limited Lumber 

Production 

Expanded Lumber 

Production 

Medium 

Integrated 

Industry 

High 

Integrated 

Industry 

Year 

Estimated 

Volume1

Total Sale 

Volume2

Estimated 

Volume1

Total Sale 

Volume2

Estimated 

Volume1

Estimated 

Volume1

2005 31 47 35 53 45 45 

2006 32 48 38 57 55 55 

2007 33 50 41 62 67 67 

2008 33 50 44 66 139 139 

2009 34 51 48 72 151 151 

2010 35 53 52 78 166 166 

2011 35 53 56 85 184 184 

2012 36 54 60 91 204 286 

2013 37 56 65 98 204 291 

2014 38 57 70 106 204 295 

2015 39 59 75 113 204 299 

2016 39 59 81 122 204 303 

2017 40 60 87 131 204 308 

2018 41 62 93 140 204 312 

2019 42 63 100 151 204 317 

2020 43 65 108 163 204 325 

2021 44 66 116 175 204 333 

2022 45 68 124 187 204 342 

2023 46 69 133 201 204 351 

2024 47 71 143 216 204 360 

2025 48 72 153 231 204 370 1

 The projections for Scenarios 1 and 2 include sawlogs, cedar export, and chip volumes available from sawmill 

production. They do not include low grade material or utility logs. Scenarios 3 and 4 include sawlogs, cedar exports, 

chip volumes, low-grade material, and utility. 2

 The total sale volume projections represent the total harvest that would be necessary to produce the estimated volume 

under the first two scenarios. These total volumes include the low quality material (low grade material or utility logs) not 

included in the demand projections. These figures assume that the initial estimated volume would comprise 66 percent 

of the total required harvest. 3

 The data presented in this table were used to calculate the 4-year averages summarized in Table 3.22-6. The effects 

analysis uses the projected demand numbers for 2022 to compare scenarios and alternatives. 

Source: Appendix G, Table 2
3 Environment and Effects

Economic and Social Environment 3-508 Final EIS

An analysis prepared for the Southeast Conference—“Timber Markets Update and 

Analysis of an Integrated Southeast Alaska Forest Products Industry” (McDowell 

Group et al. 2004)—considered installed capacity of Southeast mills, projected a 

harvest volume that would allow the mills to operate at an efficient level assuming the 

existence of an integrated industry, and concluded that a minimum of 200 MMBF total 

harvest would be required.1

 However, they concluded that the most efficient use of 

timber from the Tongass National Forest would most likely include other added-value 

manufacturing, such as a veneer mill. The industry would be most efficient with at 

least two of each type of manufacturing facility to foster competitive bidding for 

materials and labor. Depending upon the types of facilities, this could require an 

annual harvest of 350 MMBF or more from the Tongass (McDowell Group et al. 2004; 

McDowell Group 2006b). 

Recent Sales and Harvest Figures 

Another possible way to assess timber demand is to consider sale and harvest figures 

in recent years. Table 3.22-8 shows annual timber sale harvest since 1994. 

Use of recent harvest figures as an indicator of demand has several limitations. Since 

1997, much of the timber prepared for sale has been subject to appeal and litigation 

activities that have postponed our ability to offer the material. In recent years, 

Congressional Appropriation Act provisions have prohibited the Tongass National 

Forest from offering timber sales that do not appraise positively using the residualvalue appraisal method. Many timber sales have not appraised positively and others 

have been delayed through litigation; it is unclear what the actual harvest levels would 

have been if these constrictions on supply were not present. 

Table 3.22-8 

Tongass National Forest ASQ compared to Actual Harvest, 1994 to 2006 

(MMBF)

Fiscal Year1 ASQ Actual Harvest 

1994 (End of APC contract)2 549 276 

19952 549 221 

19962 549 120 

1997 (End of KPC contract)2 549 107 

1998 267 120 

1999 267/1873 146 

2000 (Last KPC harvest) 1873 147 

2001 187/2673 48 

2002 267 34 

2003 267 51 

2004 267 46 

2005 267 50 

2006 267 43 

1

 Fiscal Year: October 1 to September 30 the following year. 

2

 The Allowable Sale Quantity (ASQ) for 1994 through 1997 included 450 MMBF net sawlog volume and 

549 MMBF total harvest. 3 In May 1997, the Tongass Plan was revised, with a resulting allowable sale quantity of 267 MMBF. In April 

1999, a new Record of Decision was issued with a resulting allowable sale quantity of 187 MMBF. In 

March 2001, the 1999 ROD was vacated by the US District Court, District of Alaska and the allowable sale 

quantity reverted back to 267 MMBF.

 

1 Southeast Conference is a regional, nonprofit corporation and the State-designated Alaska 

Regional Development Organization, the federally designated Economic Development District, 

and the federally designated Resource Conservation and Development Council for Southeast 

Alaska (see http://www.seconference.org/index.html). 
 Environment and Effects 3 

Final EIS 3-509 Economic and Social Environment 

The Tongass Forest Plan assigns Land Use Designations (LUDs) to various portions 

of the Forest and designates the types of activities allowable within those LUDs. 

Suitable land in LUDs where timber management can be considered constitutes the 

“timber land base” of the Forest. As part of the Forest Plan development process, the 

Forest Service calculates the average decadal volume that could be produced from 

that timber base over the rotation period, observing all of the legal requirements and 

standards and guidelines associated with the Plan. The figure resulting from that 

calculation is the Allowable Sale Quantity (ASQ). The ASQ should not be equated 

with the ability of the Forest Service to satisfy timber demand alone. Additional 

volume, for example, can be produced from wildlife habitat enhancement thinning in 

young-growth forest in the beach fringe and old-growth reserves. Production of this 

type of additional volume may be appropriate to meet objectives other than timber 

production provided no irreversible damage would occur and restocking was assured. 

Conversely, not all suitable land is likely to be harvested. Some lands within the 

suitable base may not be economically feasible to harvest for example. The Forest 

Plan distinguishes between two types (components) of lands within the suitable base 

as a function of logging system implications. The two non-interchangeable 

components (NICs) are referred to as NIC I and NIC II lands. NIC I includes lands 

that can be harvested with normal logging systems; NIC II, is comprised of lands with 

especially high logging costs usually due to isolation or special harvesting equipment 

requirements. Although NIC I timber does not exhibit the problems of NIC II timber, 

not all NIC I timber, is necessarily economic. The proportion of NIC I lands that would 

render economic timber sales could increase as the timber industry becomes more 

integrated. In the absence of a facility that utilizes utility and lower grade logs, a 

timber sale must be sustained solely on the profits made from the higher grade 

sawlogs, even though the operator must harvest and pay for the lower grade logs. 

The Limited Interstate Shipment Policy increases the likelihood that timber sales in 

parts of the Tongass National Forest will have a positive appraisal under current 

market conditions. The policy is also expected to increase the utilization of timber 

harvested on the Tongass, by increasing the amount of material that can be 

economically removed from the woods, and concurrently decreasing the amount of 

material that formerly had to be chipped, stored, or disposed of by the mills 

(Alexander et al. 2007). 

Logistics in Southeast Alaska also influence where and when timber is economic to 

harvest. Currently the timber base is spread throughout the entire Tongass National 

Forest, while most of the saw mills are located in the southern portions of the Forest. 

The high cost of access and transportation between the timber supply and processing 

mills reduces the likelihood of meeting the needs of mill owners where distances are 

great. 

The ASQ reflects the maximum allowable level of timber harvest under each 

alternative and assumes every acre modeled and scheduled for timber harvest will 

actually be harvested. The preceding paragraphs describe the considerations and 

constraints that make it unlikely that every acre will be scheduled for harvest. 

Juneau Economic Development Council and a Subcommittee of the Tongass 

Futures Roundtable 

These groups have made estimates of the minimum timber volume required for the 

efficient operation of various processing facilities, as discussed later in the effects 

section and shown in Tables 3.22-17 and 3.22-18. The estimated minimum volume 

for efficient sawmill operation is approximately 66 percent of existing mill capacity 

(138 MMBF) based on the four largest existing sawmills in Southeast Alaska, with 

some allowance for smaller mills (see Table 3.22-17). The minimum estimated 

volume necessary to supply a veneer plant is 30 MMBF of mid-value logs, with 80 to 

100 MMBF of No. 3 sawlogs and utility logs required to support an MDF or Bioenergy 
3 Environment and Effects

Economic and Social Environment 3-510 Final EIS

facility. Using these estimates a total of 248 MMBF to 268 MMBF is the minimum 

volume necessary to support an integrated industry. The limitations of this analysis 

are similar to those in the installed capacity discussion above, in that there must be an 

end purchaser willing to buy the product at a price equal to or greater than the cost of 

production. 

Relationship between Demand over the Planning Cycle and Annual Demand 

The Tongass Timber Reform Act (TTRA) speaks of annual market demand and 

demand over each planning cycle (10 to 15 years into the future and beyond). The 

Forest Plan itself does not authorize any timber harvest. Such harvest is authorized 

by site-specific timber sale projects, which implement the plan. Thus, it could be said 

that the Plan itself does not directly meet demand for timber. Rather the Plan sets the 

conditions under which the Forest Service can seek to meet market demand through 

the cumulative sales of the annual timber sale program over the planning cycle. 

The Forest Service seeks to meet market demand for Tongass timber on an annual 

basis by establishing annual timber sale objectives using a methodology developed by 

Morse (2000). This methodology uses a number of inputs including the Pacific 

Northwest Research Station projections, installed mill capacity, utilization rates, and 

market trends to determine annual sale offer levels (supply) (see Appendix G, Timber 

Demand). The goal of the Forest Service is to have a 3-year supply (approximately) 

of timber under contract to meet sale objectives. The 3-year supply approach 

recognizes timber cannot be harvested instantaneously and that purchasers must 

have some flexibility to respond to market changes. Once the 3-year level is reached, 

the agency builds shelf volume (sale projects with completed NEPA and field work – 

ready for offer) and sells additional timber as existing inventories are harvested. In 

this way, the agency seeks to enable the industry to respond to short term changes in 

markets. The ratio of contract volume to harvest peaked in 2002, at 6.8, but dropped 

closer to the 3-year supply objective in 2003. In 2004 and 2005 the ratio dropped to 

1.7. Recent ratios of volume under contract to harvest are potentially misleading. 

Harvests have declined considerably over the past few years, resulting in increasing 

contract volume to harvest ratios through 2002 in spite of declining contract volumes. 

Some of the volume under contract in 2002 and 2003 was in sales cancelled in 2004 

and 2005. 

In 2004, Section 339 of the Department of the Interior and Related Agencies 

Appropriations Act for fiscal year (FY) 2004, Public Law No. 108-108, provided that 

the Secretary of Agriculture may cancel, with the consent of the timber purchaser, a 

number of timber sale contracts on the Tongass National Forest awarded between 

October 1 1995 and January 1 2002. A given sale could be cancelled provided that 

the Secretary determined, at the Secretary’s sole discretion, that the sale would result 

in a financial loss to the purchaser, and the costs to the government of seeking a legal 

remedy against the purchaser would likely exceed the cost of terminating the contract. 

By the end of FY 2005, a total of seventeen sales (with approximately 122 MMBF) on 

the Tongass National Forest were cancelled. It is the intent of the Tongass National 

Forest to reconfigure cancelled timber sales and re-offer that portion of the volume 

that is economically viable. 

Projecting demand over the planning cycle has a higher degree of uncertainty and 

depends on numerous factors that are difficult to predict, including changes in 

technology, growth and exchange rates in key markets, changes in consumer tastes 

and preferences, as well as developments in other producing regions whose products 

compete with those of Alaska. The difficulty in developing long-term projections for 

the timber industry in Southeast Alaska is further exacerbated by the current 

circumstances confronting the industry, which, as discussed in the preceding 

sections, has been in a period of transition since closure of the pulp mills in the 1990s. 

With this in mind, recent studies (Brackley et al. 2006a; McDowell Group et al. 2004; 

Section 705 (a) of the 

Tongass Timber Reform 

Act of 1990 states: 

Subject to appropriations, 

other applicable law, and 

the requirements of the 

National Forest 

Management Act of 1976 

(Public Law 94-558), 

except as provided in 

subsection (d) of this 

section, the Secretary 

shall, to the extent 

consistent with providing 

for the multiple use and 

sustained yield of all 

renewable forest 

resources, seek to 

provide a supply of timber 

from the Tongass 

National Forest which (1) 

meets the annual market 

demand for timber from 

such forest and (2) meets 

the market demand from 

such forest for each 

planning cycle. 
 Environment and Effects 3 

Final EIS 3-511 Economic and Social Environment 

McDowell Group 2006b) have considered the demand for timber based on a number 

of different scenarios that assume different futures for the timber industry. The 

identified future scenarios range from a projected longer-term demand of 47 MMBF 

through 360 MMBF. Based on these studies, the Forest Service identified an upper 

planning cycle demand of 360 MMBF. 

Recreation and Tourism 

The following section is divided into two subsections or parts. The first part discusses 

trends in recreation and tourism and related employment for Southeast Alaska as a 

whole. This discussion draws upon region-wide visitor numbers and related 

employment estimates to the extent they are available. The second part discusses 

the same issues with specific reference to the Tongass National Forest. Trends in 

visitation to Southeast Alaska and the Tongass National Forest are discussed in detail 

in the Recreation and Tourism section of this document and, as a result, are only 

briefly summarized in the following subsections. 

Trends in Visitation 

The number of visitors to Southeast Alaska has grown substantially since the early 

1990s. Summer visitors to Southeast Alaska more than doubled between 1993 and 

2006, increasing from 502,800 in 1993 to 1,160,000 in 2006, an increase of 131 

percent (McDowell Group et al. 2007). Statewide, the total number of visitors 

increased by 40 percent over the same period. The relatively large increase in 

visitation to Southeast Alaska reflects the dramatic growth in the number of cruise 

ship passengers visiting the region. The number of cruise ship passengers visiting 

Juneau, for example, more than tripled between 1993 and 2006, increasing from 

approximately 306,600 in 1993 to 953,000 in 2006 (Table 3.15-13 in the Recreation 

and Tourism section; Juneau Convention and Visitors Bureau 2007). The number of 

passengers docking at Juneau is considered representative of the total number of 

cruise ship passengers because most cruise ships visiting Southeast Alaska stop 

there. 

Anecdotal evidence suggests that the number of independent visitors (i.e., non-cruise 

ship visitors) remained relatively constant from 1980 through 2002. Recent estimates 

by the Juneau Convention and Visitors Bureau suggest, for example, that the number 

of independent visitors to Juneau has held relatively constant at around 100,000 

(Schroeder et al. 2005) over this same period. Data for Southeast Alaska as a whole 

indicate cruise ship visitors increased from about 64 percent of total visitors to the 

region in 1985 to 75 percent of the total in 2001. About 90 percent of visitors to 

Juneau in 2003 were estimated to be cruise ship passengers (Schroeder et al. 2005). 

Employment and Contribution to the Regional Economy 

Recreation and tourism-related employment is difficult to accurately quantify because 

visitors spend their money throughout the local economy. There is no single “tourism 

industry” and no direct measures of tourist-related income or employment. 

Components of travel and tourism activities are instead partially captured in other 

economic sectors, such as retail trade (e.g., grocery stores and gift shops), 

transportation, hotels and other lodging places, and amusement and recreation 

services. 

There are no readily available current estimates of total recreation and tourism-related 

employment for Southeast Alaska. The most recent study that provided data by 

Alaska region (McDowell Group 1999) estimated that recreation and tourism (or in 

their terms vacation/pleasure visitors) supported approximately 4,154 direct jobs in 

Southeast Alaska in 1998, approximately 22 percent of Alaska’s total recreation and 

Recreation and 

Tourism in 

Southeast Alaska 
3 Environment and Effects

Economic and Social Environment 3-512 Final EIS

tourism-related employment. The Draft and Final SEIS used the basic approach 

employed in the McDowell analysis and estimated that recreation and tourism 

supported 4,185 and 4,278 direct jobs in Southeast Alaska in 1999 and 2001, 

respectively (USDA Forest Service 2002b, 2003b). Based on these estimates, 

recreation and tourism accounted for 7 percent and 8 percent of total employment in 

Southeast Alaska in 1999 and 2001, respectively. Unfortunately it is not possible to 

update these estimates because the baseline employment data compiled by the 

Alaska DOL are no longer available in the same format following the national shift 

from the Standard Industrial Classification (SIC) system to the North American 

Industrial Classification System (NAICS). 

In the absence of a reliable current estimate of recreation and tourism-related 

employment for Southeast Alaska, employment in the leisure and hospitality sector is 

used as a proxy for recreation and tourism employment in 2005. Employment in this 

sector accounted for approximately 9 percent of total employment in Southeast Alaska 

in 2005 (see Table 3.22-3 for details). 

While there are no current estimates of total recreation and tourism-related 

employment for Southeast Alaska, two studies offer some insight into the economic 

contribution that recreation and tourism makes to the regional economy. The first 

study was a survey of commercial recreation businesses that use the public lands and 

waters of Southeast Alaska. Conducted in 2000, this survey found that cruise ship 

passengers accounted for 41 percent of total clients, ranging from 22 percent of 

clients for businesses with fewer than 200 clients a year to 91 percent of clients for 

businesses with more than 10,000 clients a year (Alaska Division of Community and 

Business Development [DCBD] 2001). This survey also found that 86 percent of 

outfitter/guide businesses had annual revenues of less than $100,000 in 1999. Six 

firms reported revenues over $1 million, including one firm with revenues exceeding 

$10 million. A similar distribution is evident in terms of clients served, with the majority 

of firms serving less than 100 clients, a smaller number of firms serving considerably 

larger numbers, and one firm serving more than 100,000 clients in 1999. 

Given the rapid growth in the number of cruise ship passengers visiting the region 

since 2000, it seems reasonable to assume that the number of clients seeking guided 

recreation opportunities and the number of outfitter/guides operating in the region has 

grown. Outfitter/guide data for the Tongass, for example, indicate a 22 percent 

increase from 2004 to 2005 in the number of clients served by outfitter/guides Forestwide (see Table 3.15-18 in the Recreation and Tourism section). 

A second study that provides important insight into the contribution of nature-based 

tourism to the regional economy was prepared by the Institute of Social and Economic 

Research at the University of Alaska Anchorage and involved field research 

conducted in the summers of 2005 and 2006 (Dugan et al. 2006). This study focused 

on a limited number of communities and sought to provide insight into revenues 

generated, the types of activities attracting tourists, and the flows of money through 

the economy. The findings of the study indicate that nature-based tourism generates 

substantial revenues in the region, with an estimated $250 million generated in annual 

direct business revenues for the companies surveyed in Sitka, Juneau, and Chichagof 

Island (Dugan et al. 2006). The study also found that nature-based tourism takes a 

number of different forms and the ratio of cruise ship passengers to independent 

travelers varies by location. Most nature-based activities that originate in Ketchikan, 

for example, fell into four general categories: flightseeing, marine charters, adventure 

experiences, and general sightseeing. In all cases, the majority of clients participating 

in these activities were cruise ship passengers. Nature-based tourism on Chichagof 

Island, on the other hand, included a mix of cruise ship passengers and independent 

travelers, depending on the location and activity involved (Dugan et al. 2006). 
 Environment and Effects 3 

Final EIS 3-513 Economic and Social Environment 

The following discussion focuses on existing and projected recreation use levels and 

related employment. The existing supply of recreation opportunities, which forms an 

important part of the recreation analysis presented in the environmental 

consequences part of this section, is discussed with respect to Recreation Opportunity 

Spectrum (ROS) settings and inventoried Recreation Places in the Recreation and 

Tourism section of this document. 

Forest Use and Visitation 

The preceding discussion indicates that there has been a substantial growth in the 

number of visitors to Southeast Alaska over the past decade or so. 

While it is reasonable to assume that the vast majority of visitor recreation and tourism 

activity in the region is related to the natural environment, not all of the activity 

generating this employment can be directly linked to the Tongass National Forest. 

Many visitors experience the Tongass passively, from the deck of a cruise ship, for 

example, without directly using the Forest for recreation purposes. In addition, while 

the Tongass includes approximately 80 percent of the land area in Southeast Alaska, 

there are other lands that offer wildland recreation opportunities in the region, 

including the 3.3 million acres of National Park Service lands and recreation lands 

managed by the State of Alaska. Further, other popular recreation and tourism 

activities, such as saltwater fishing, sea kayaking, and shopping, do not take place on 

the Tongass. 

It should, however, be noted that cruise ship companies have heavily marketed 

Forest-related activities in recent years and many passengers do take at least one trip 

to the Forest during their visit. Icefield helicopter tours and visits to the Mendenhall 

Glacier by cruise ship passengers have, for example, increased substantially (see 

Table 3.15-15 in the Recreation and Tourism section). Recent survey data (2005) 

indicate approximately 83 percent of cruise visitors to Juneau participated in at least 

one tour while in port. Glacier tours were the most popular type of tour in 2005, with 

42 percent of cruise visitors taking this type of tour. Wildlife/marine life viewing, the 

Mt. Roberts Tramway, and flightseeing via helicopter were also popular (McDowell 

Group 2005). 

With these caveats in mind it is apparent that not all of the recreation and tourism 

employment and economic activity in Southeast Alaska can be directly attributed to 

the Tongass. In addition, visitors to the region comprise only part of total recreation 

use on the Tongass. Residents of local communities also make extensive use of the 

Forest for recreation purposes. 

The question of recreation use is complicated because only limited forest visitation 

data are presently available. There are currently two main sources of data: the results 

of the first Alaska National Visitor Use Monitoring (NVUM) program, which were 

published in 2004, and data that were collected for specific recreation places in the 

1980s and early 1990s. 

The final results of the first Alaska NVUM program, which involved surveys conducted 

over 3 years, were published in August 2004 (Kocis et al. 2004). According to the 

NVUM analysis there were an estimated 1.83 million national forest visits and 2.13 

million site visits to the Tongass in 2003 (Kocis et al. 2004). NVUM has standardized 

definitions of visitor use measurement to ensure that all national forest visitor 

measurements are comparable. A national forest visit, as defined by the NVUM, is 

the entry of one person onto the Forest to participate in recreation activities for an 

unspecified period of time and may include multiple site visits. A site visit, as defined 

by the NVUM study, is the entry of one person onto a national forest site or area to 

participate in recreation activities for an unspecified period of time. 

Recreation and 

Tourism on the 

Tongass National 

Forest 
3 Environment and Effects

Economic and Social Environment 3-514 Final EIS

Prior to the NVUM program, Forest-wide recreation use statistics were last compiled 

for the Tongass National Forest in 1995. The basic measurement of recreational 

activity was the Recreation Visitor Day (RVD), which is usually obtained through the 

counting of use permits, visitor surveys, or observation. An RVD is 12 hours of 

recreation use by one individual. The measures used in the NVUM program are not 

directly comparable with these estimates. In addition, the NVUM estimates were 

developed for the entire forest, while the data collection efforts in the 1980s and early 

1990s focused on identified and specific recreation places (see the Recreation and 

Tourism section of this document). 

While the NVUM data are more recent, it is not possible to extrapolate future use from 

just one year of data, even though all indications suggest that recreation use in the 

region and on the Tongass has been increasing in recent years. In the absence of 

more recent detailed information, the following analysis uses RVD data compiled for 

identified recreation places from 1984 through 1995 to assess existing and future 

conditions. These data may not accurately reflect current levels of use on the 

Tongass, but they are sufficient to allow a comparison of alternatives. This 

comparison is based on the projected effects of the alternatives on recreation supply 

(in the form of ROS settings). Demand is assumed to be consistent across all the 

alternatives and the exact number is less important in this analysis than the overall 

trend. 

Existing and Projected Use (RVDs) 

The RVD data compiled for 1984 through 1995 are divided into three groups based on 

the ROS system that is used to inventory and classify different recreation settings on 

the Forest (see Table 3.15-2 in the Recreation and Tourism section). These three 

groups consist of Primitive and Semi-Primitive Non-Motorized settings (here termed 

ROS 1); Semi-Primitive Motorized settings (ROS 2); and Roaded Natural, Roaded 

Modified, Rural, and Urban settings (ROS 3) (see Table 3.15-2). Semi-Primitive 

Motorized settings (here termed ROS 2) accounted for a majority of recreation use on 

the Tongass in 1994, with 62 percent of recorded RVDs occurring in ROS 2 settings. 

ROS 1 settings, as defined here, accounted for 20 percent of the use, with the 

remaining 18 percent of RVDs taking place in ROS 3 settings. 

Historic and projected recreation use is presented in Figure 3.22-7. Future use 

projections are based on actual use estimates from 1984 to 1995, with a trend line 

(based on these data) used to project future levels of demand. Annual estimated use 

is presented by ROS class for 1984 through 1995 and for 2000, 2005, and 2010 in 

Table 3.22-9. Total RVDs are divided into ROS classes based on the shares 

identified for 1994, which are assumed to remain constant throughout this analysis. 

These shares are presented graphically in Figure 3.22-8, which also identifies the 

projected supply of these settings based on the Forest-wide Geographic Information 

System (GIS) database that was updated for this analysis (see the Recreation and 

Tourism section of this document). 

Although outfitter/guides charge clients for services that involve the Tongass National 

Forest, recreational use on public lands is not typically a market good. In other words, 

the Forest Service does not typically charge individuals to use the Forest for 

recreation. As a result, where supply is binding, use restrictions rather than price 

increases are the most likely result. This analysis assumes that RVD use within a 

certain ROS class will not exceed supply within that class (for this analysis, supply is 

equated to the current level available; alternative supply levels are evaluated in the 

Effects Analysis). ROS 2 is the only class in which demand exceeds supply over the 

next decade, with the projected number of RVDs having exceeded estimated supply 

in 1998. In this case, demand is assumed to be constrained by the available supply. 

The second part of Table 3.22-9 and the dashed line shown in Figure 3.22-7 show the 

effect that constraining ROS 2 in this manner would have upon projected use. This 

RVD data are presented 

for three groups based on 

the Recreation Opportunity 

Spectrum (ROS) system. 

ROS 1: 

Primitive 

Semi-Primitive NonMotorized 

ROS 2: 

Semi-Primitive Motorized 

ROS 3: 

Roaded Natural, Roaded 

Modified, Rural and Urban 

A comparison of projected 

demand with supply by 

ROS class and recreation 

place indicates that ROS 

2 (Semi-Primitive 

Motorized) is the only 

class in which demand is 

expected to exceed 

supply over the next 

decade. 
 Environment and Effects 3 

Final EIS 3-515 Economic and Social Environment 

modified projection, which serves as the baseline for the effects analysis, assumes 

that recreation use in ROS 1 and ROS 3 settings would not be substituted for the 

projected unmet ROS 2 demand. 

The supply of ROS settings used in this analysis is limited to specifically identified 

recreation places, with demand also assumed to occur in these places. There are an 

estimated 870,000 ROS 2 acres in identified recreation places compared to 

approximately 1.5 million ROS 2 acres Forest-wide (see Tables 3.15-3 and 3.15-5 in 

the Recreation and Tourism section of this document). The recreation economic 

analysis assumes that demand would continue to focus on ROS 2 areas in recreation 

places and, therefore, exceed supply in these areas. Viewed on a Forest-wide basis, 

ROS 2 demand would not exceed Forest-wide supply until sometime after 2010. 

This approach recognizes that recreation use is not evenly distributed on the Forest, 

with some areas, identified here as inventoried Recreation Places, receiving much 

higher levels of use than others. High levels of recreation activity generally take place 

during the summer and correspond with cruise ship activity, increased private boating 

by both residents and non-residents, and a general increase in resident recreation 

activity. High use levels and/or limited capacity have resulted in reports of use 

exceeding capacity in certain areas, which generally correspond with the ROS 2 areas 

evaluated here. The Shoreline Outfitter/Guide EIS prepared for the north portion of 

the Forest, for example, identified 15 “hotspots” where there was a perception of 

crowding (USDA Forest Service 2002c). These areas mainly involved popular 

saltwater bays adjacent to the Forest and included Eliza Harbor, Gambier Bay, 

Greens Creek, Brothers Islands, George Island, Idaho Inlet, Mud Bay, Pinta Cove, 

Point Adolphus, Mallard Bay, Williams Cove, Slocum Inlet, Kelp Bay, Lake Eva Trail, 

and Patterson Bay. Perceptions of and actual crowding exist at other locations on the 

Forest, including the Anan Creek Wildlife Viewing Area and Margaret Bay near 

Ketchikan. 

The following analysis also assumes that there would be no change in the current 

availability of recreational settings. This is not necessarily the case for identified 

recreation places or the Forest as a whole. Shoreline areas or other areas accessible 

by floatplane or helicopter that are presently allocated to Primitive or Semi-Primitive 

Non-Motorized settings (ROS 1) could be reallocated to the Semi-Primitive Motorized 

setting (ROS 2) in the future if patterns of use or other factors change. While these 

assumptions represent a simplification of underlying realities, they are necessary to 

produce a quantified estimate of the relation between recreation supply and demand 

and allow a comparison of alternatives. 
3 Environment and Effects

Economic and Social Environment 3-516 Final EIS

Figure 3.22-7 

Historical and Projected Recreational Activity on the Tongass National Forest in RVDs 

0

1,000

2,000

3,000

4,000

5,000

6,000

1984 1986 1988 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

Year

1,000 RVDs

Historical Activity

Projected Demand

Projected Activity

Note: The dashed line represents future recreational activity constrained by the supply of ROS 2 settings. 

Source: USDA Forest Service 1997a (Figure 3-23; updated using 2006 ROS supply data). 

Figure 3.22-8 

Historical Consumption, Projected Demand, and 2006 Supply for Recreation Activity on 

the Tongass National Forest by ROS Group 

0

500

1,000

1,500

2,000

2,500

3,000

3,500

1984 1986 1988 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

Year

1,000 RVDs

ROS 1 ROS 2 ROS 3 ROS 1 ROS 2 ROS 3

Consumption/Demand Supply
 Environment and Effects 3 

Final EIS 3-517 Economic and Social Environment 

Employment and Earnings 

The direct employment estimates presented in Table 3.22-9 are based on a job/RVD 

ratio of 0.00074. This ratio was developed for the 1997 Forest Plan EIS analysis 

based on visitor survey data and data from a regional economic model (IMPLAN) 

(USDA Forest Service 1997a, p. 3-460). This approach assumes that the average 

amount of employment generated by a single RVD is constant over time and that this 

number is the same for both Tongass-related recreation and the region as a whole, as 

well as for different types of recreation on the Tongass. While these assumptions 

may not accurately reflect underlying realities, they are necessary to produce a 

quantified estimate of the relation between recreation activity and employment. 

Nonresidents were assumed to account for 44 percent of historic and projected RVDs 

and a commensurate share of employment for the purposes of this analysis. Total 

employment (direct, indirect, and induced) generated by nonresidents is presented in 

the last row of Table 3.22-9, entitled “Total from Nonresident.” A reduction in out-ofstate recreational activity due to decreased recreational opportunities (ROS settings) 

is assumed to result in a net economic loss to the region. Local residents, on the 

other hand, are assumed to spend their money elsewhere in Southeast Alaska, and 

no net loss in economic activity is incurred. This is not to say that this type of effect 

would be neutral if it were to occur. This is discussed further in the Environmental 

Consequences section. 

Table 3.22-9 

Tongass-Related Recreation and Tourism: Historic and Predicted Consumption in Recreation 

Visitor Days (RVDs) 

Consumption to 1995 and Projected Demand for Tongass-Related Recreation, 2000, 2005, and 2010 (1,000 RVDs)1

 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 2000 2005 2010

ROS 1 197 293 215 263 297 348 461 487 511 414 433 528 672 816 960 

ROS 2 612 907 665 815 922 1,077 1,428 1,509 1,584 1,284 1,342 1,638 2,084 2,530 2,976 

ROS 3 178 263 193 237 268 313 415 438 460 373 390 476 605 734 864 

Total 987 1,463 1,073 1,315 1,487 1,738 2,303 2,435 2,554 2,071 2,165 2,642 3,361 4,080 4,800 

Available Recreation Opportunities 

RVDs by Class in 20052

Projected Consumption of RVDs by Class 

(1,000 RVDs)3 

(1,000 RVDs) 1995 2000 2005 2010 2015 

ROS 1 1,289 ROS 1 528 672 816 960 1,104 

ROS 2 2,053 ROS 2 1,638 1,819 1,819 1,819 1,995 

ROS 3 2,206 ROS 3 476 605 734 864 993 

Total 5,548 Total 2,642 3,096 3,369 3,643 4,092 

Historic and Projected Employment Generated in Average Annual Employment 

 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 2000 2005 2010

Direct Employment4 730 1,083 794 973 1,100 1,286 1,704 1,802 1,890 1,533 1,602 1,955 2,291 2,493 2,696

From Nonresident5 321 476 349 428 484 566 750 793 832 674 705 860 1,008 1,097 1,186

Total from Nonresident6 389 576 423 518 586 685 907 959 1,006 816 853 1,041 1,220 1,327 1,435 1

 Figures for 1984 to 1995 are estimated from historical use data. Figures in subsequent years are estimates based on a linear projection 

using the 1984 to 1995 estimates of actual use (see Figure 3.22-7). The distribution of RVDs by ROS setting is based on estimates for 

1994 ROS classes 1, 2, and 3 are assumed to account for 20 percent, 62 percent, and 18 percent of total RVDs, respectively. 2

 Estimated available recreation opportunities are based on the supply of ROS settings in identified recreation places on the Tongass. These 

estimates are for National Forest System (NFS) lands only. They do not include State or private lands in recreation places within the 

Tongass National Forest boundary. 3

 Projected consumption of RVDs by ROS class is based on projected demand with the consumption of ROS 2 opportunities constrained by 

the existing supply. 4

 Direct employment is calculated using a job/RVD ratio of 0.00074. This ratio was developed for the 1997 Forest Plan Revision Final EIS 

analysis (see USDA Forest Service 1997a, p. 3-460). 5

 Nonresident use is estimated to be 44 percent of total forest use. This analysis focuses upon nonresident visitors because jobs generated 

by nonresident expenditures on goods and services are considered comparable to an export industry that brings new money into the region, 

creating new wealth and development opportunities. Resident recreational activity, on the other hand, brings no new money into the region, 

and thereby does not expand the local job base. 6

 Total employment generated by nonresident activities is estimated using a multiplier of 1.21. 

Source: USDA Forest Service 1997a (Table 3-136)
3 Environment and Effects

Economic and Social Environment 3-518 Final EIS

Commercial Fishing and Seafood Processing 

While commercial salmon fishing represents the largest share of Southeast Alaska’s 

fishing industry (42 percent based on ex-vessel value in 2005), halibut, crab and 

herring fishing combined make up a substantial proportion of the region’s total catch 

(approximately 31 percent in 2005 on a value basis) (Alaska DOL 2007e). There is an 

important connection between salmon and other wildlife and fish species on the 

Tongass National Forest. Crab, halibut, herring, bears, eagles, and other species 

depend on the annual return of millions of salmon and juvenile salmon produced in 

the streams and lakes of these public lands. As a result, management decisions that 

affect salmon are known to indirectly affect other species that are commercially fished. 

These relationships are, however, poorly understood and difficult to quantify. The 

commercial fishing discussion presented in this section, therefore, focuses on the 

salmon fishery. Data available for the seafood processing industry, however, do not 

allow for an easy distinction between salmon processors and other firms. Data 

presented for the seafood processing sector, therefore, include the entire seafood 

processing industry. 

Although the profitability of the seafood industry in Southeast Alaska continuously 

changes, it remains a major component of the regional economy. Together, the fish 

harvesting and seafood processing sectors accounted for approximately 3,781 direct 

jobs in 2005, and approximately 10 percent of regional employment (Table 3.22-3). 

Indirect and induced employment for the fish harvesting sector is estimated to be 525 

jobs, resulting in a total of 2,806 jobs supported by this sector in 2005. The seafood 

processing sector in Southeast Alaska had estimated indirect and induced 

employment of 960 jobs and supported a total of 2,460 jobs (Table 3.22-3). 2

Employment data compiled by the Alaska DOL indicate that the salmon fishery 

accounted for approximately 45 percent of commercial fishing employment (1,026 

jobs) in 2005, with the other fisheries combined supporting 1,255 jobs (Alaska DOL 

2007d). Other important fisheries in 2005 included halibut (567 jobs), sablefish (226 

jobs), and crab (176 jobs) (Alaska DOL 2007d). 

Unlike other basic sectors of Southeast Alaska’s economy, components of the 

seafood industry are spread throughout the region with an important presence in 

virtually every community. Alaska’s market share of the global salmon supply 

(estimated at 31 percent in 1990) has, however, been falling. The loss of market 

share is not a function of poor stocks or low supply, but a consequence of the growing 

acceptability of farmed fish as a source of fresh salmon and other seafoods. 

Southeast Alaskan fishermen have also been negatively affected by weaker Asian 

markets and competition from fish from eastern Russia (Schroeder et al. 2005). 

Seafood processing has also undergone fundamental changes in recent years with 

the increased use of floating fish processing facilities and a trend toward frozen rather 

than canned salmon. The seafood industry is discussed in more detail in the 1997 

Tongass Land Management Plan Revision Final EIS (USDA Forest Service 1997a, p. 

3-452 to 3-456). 

Value and volume measures of salmon harvest for Southeast Alaska are shown in 

Figure 3.22-8. Both measures show considerable variation from year-to-year. In 

contrast to revenue and catch figures, employment has remained relatively stable, but 

has exhibited an overall downward trend (Figure 3.22-9). Statewide, fleet participation 

in the Alaska salmon fisheries dropped in 2002, partly as a result of low ex-vessel 

prices (the prices fishermen receive for their catch), but also due to processor 

limitations on the number of vessels they would serve. Low prices and loss of market 

 

2

Note that indirect employment for the seafood processing sector includes fish harvesting. As a 

result, the total (direct and indirect) employment estimates for these sectors should not be 

added together because this would result in some salmon harvesting employment being double 

counted.
 Environment and Effects 3 

Final EIS 3-519 Economic and Social Environment 

opportunities resulted in a notable decline in the value of limited entry permits in the 

salmon fisheries, declining in total value from approximately $1.25 billion in 1990 to 

$226 million in 2002. Wards Cove Packing Company, the eighth largest processor in 

Alaska, announced in December 2002 that it was terminating its Alaska salmon 

operations. 

Southeast Alaska accounted for approximately 29 percent of employment in Alaska 

fisheries in 2004 (Patton and Robinson 2006). Fisheries employment in Southeast 

declined by about 9 percent from 2000 to 2003, but recovered slightly in 2004, 

increasing by 2.4 percent. Most of these changes were due to the decline and partial 

recovery in the salmon fishery, which accounted for approximately 45 percent of all 

Southeast harvesting employment in 2005 (Patton and Robinson 2006) (see Figure 

3.22-9). The commercial fishing and seafood processing industries are generally 

characterized by high degrees of nonresident participation. Nonresidents accounted 

for approximately 34 percent of gross earnings in the fish harvesting industry in 

Southeast Alaska in 2005 (Alaska DOL 2007f). Nonresidents made up a higher share 

of the fish processing industry, accounting for approximately 67 percent of 

employment in this sector in Southeast Alaska in 2005 (Alaska DOL 2007g). 

Figure 3.22-8 

Southeast Alaska Salmon Harvest: Gross Landings and Gross Revenue, 1984 to 

2005 

$0

$20

$40

$60

$80

$100

$120

$140

$160

1984198519861987198819891990199119921993199419951996199719981999200020012002200320042005

Year

Gross Earnings (Millions of $2005)

0

50

100

150

200

250

300

Gross Landings (Millions of Pounds)

Gross Earnings

Gross Landings

Sources: Martin 2006; Bachman et al. 2005; ADF&G 2004; Alaska Commercial Fisheries Entry Commission 2006. 
3 Environment and Effects

Economic and Social Environment 3-520 Final EIS

Figure 3.22-9 

Direct Salmon Harvesting and Fish Processing Employment in Southeast Alaska, 1984 

to 2005 

0

500

1,000

1,500

2,000

2,500

3,000

3,500

4,000

1984

1985

1986

1987

1988

1989

1990

1991

1992

1993

1994

1995

1996

19971998199920002001

2002200320042005

Average Annual Employment

Salmon Harvesting

Seafood Processing

Total

1. Salmon harvesting employment totals presented in this figure were estimated based on data by Fishery and average crew sizes,

time spent fishing, and preparation time for different fisheries. The employment coefficients used in this analysis are presented in 

Table 3-135 of the 1997 Forest Plan Revision Final EIS (USDA Forest Service 1997a). 

2. Seafood processing employment for 1995 through 2005 was obtained from the Alaska DOL, who provided these data rounded to 

the nearest 50 employees. 

Source: Alaska CFEC 2002, 2006; Alaska DOL 2001, 2006a; and USDA Forest Service 1997a (Table 3-135). 

Mining and Mineral Development 

Mineral exploration and mining have been a part of life in Southeast Alaska for over 

120 years. Today, the mining industry is exploring new areas for potential mineral 

deposits and is revisiting historic mining areas using modern exploration techniques. 

The 1997 Forest Plan Revision Final EIS analysis noted that there are 13 identified 

mineral deposits on the Tongass National Forest that appeared economically viable 

under certain conditions. The Present Net Value of these 13 deposits was estimated 

at $25.6 billion (USDA Forest Service 1997a, p. 3-464). Existing and potential mining 

development activities identified in the 1997 Final EIS analysis included the Quartz 

Hill molybdenum site in Misty Fiords, the Greens Creek zinc, lead, and silver mine on 

Admiralty Island, and the Kensington mine north of Juneau. 

In 2005, 312 workers were directly employed by the mining industry. Mining-related 

indirect and induced employment is estimated at 150 jobs, resulting in a total of 462 

jobs supported by the mining industry in that year (Table 3.22-3). Estimated annual 

average employee earnings of $60,971 per year in 1995 were twice the regional 

average. This annual average estimate is equal to $78,043 in 2005 dollars. Based on 

this estimate, direct and total employee earnings in the mining sector were 

approximately $24.3 million and $30.4 million in 2005. Approximately 93 percent of 

direct mining employment was located in Juneau Borough and mainly associated with 

the Greens Creek Mine on Admiralty Island. 

The Forest Service approved a plan of operations for the Kensington Gold Mine north 

of Juneau in 2005 and Coeur Alaska, Inc. subsequently began construction activities 

on the site. However, a lawsuit was filed against the United States Army Corps of 
Environment and Effects 3 

Final EIS 3-521 Economic and Social Environment 

Engineers and the Forest Service challenging the permitted tailings disposal facility, 

citing violations to the Clean Water Act. The plaintiffs failed in District Court but were 

upheld on appeal by the 9th Circuit Court in 2007. The Forest Service anticipates the 

submittal of a revised plan of operations in 2008. 

Natural Amenities and Quality of Life 

Natural amenities and local quality of life have increasingly been recognized as 

important factors determining the economic prospects of many rural communities in 

the American West and elsewhere (Rudzitis and Johnson 2000). While local amenities 

and life quality do not directly generate income in the same sense as, say, a sawmill or 

tourist lodge, they do act to attract and keep residents. This, in turn, supports 

communities and their economies in several ways. First, many of these residents may 

earn a substantial proportion of their income from non-job related sources that are 

independent of local economic activity. Much of this income will then be spent locally, 

resulting in additional employment and income in the community. Second, residents 

bring with them important skills and energy that constitute valuable assets for the 

community. Broadly termed “human capital” by economists, these skills (and the 

energy with which residents apply them) can earn additional outside income as well as 

provide essential social resources to the community. These residents may also help 

attract and retain businesses that are dependent on a skilled labor force, but otherwise 

relatively footloose from a location standpoint. 

Since it is tracked as a separate category in standard income statistics, non-wage 

income and its contribution to local economies is directly measurable. Investment 

income (dividends, interest, and rent) and transfer payments from government 

represent the two major categories of non-wage income. As shown in Table 3.22-10, 

non-job related income (i.e., transfer payments and dividends, interest, and rent) 

accounted for 35 percent of total income in Southeast Alaska in 2000, compared to 17 

percent in 1980. Non-job related income in the state of Alaska as a whole exhibited a 

similar change over this period, increasing from 16 percent to 33 percent of total 

income. Non-job related income accounted for 31 percent of total income for the 

United States as a whole, but showed relatively little change over the past two 

decades increasing from 28 percent of total income in 1980 (Table 3.22-10). 

Data compiled for 2005 indicate that the non-wage income as a share of total income 

has decreased from 2000 to 2005 in Southeast Alaska, Alaska as a whole and in the 

U.S. (Table 3.22-11). In Southeast Alaska this decrease is entirely in dividends, 

interest, and rent, with transfer payments increasing as a share of total income over 

this period. This was also the case for the U.S. as a whole. Both non-wage 

categories decreased in Alaska. 
3 Environment and Effects

Economic and Social Environment 3-522 Final EIS

Table 3.22-10 

Components of Per Capita Income, 2000

Southeast Alaska Alaska United States 

2000 2000 2000 

Total 

($) 

Percent 

of Total

% 

Change 

1980-

2000 

Total 

($) 

Percent 

of Total

% 

Change 

1980-

2000 

Total 

($) 

Percent 

of Total

% 

Change 

1980-

2000 

Personal income 31,243 100 0 29,642 100 0 29,469 100 0

Earnings 20,270 65 -18 19,861 67 -18 20,287 69 -3

Transfer payments 4,793 15 9 4,801 16 10 3,793 13 1

Dividends, interest, and rent 6,180 20 9 4,980 17 7 5,389 18 2

Notes: 

1. Earnings includes wages and salaries, other labor income, and proprietors’ income. 

2. Transfer payments consist mainly of government payments to individuals, including retirement, disability, and unemployment 

insurance benefit payments, income maintenance payments, and veterans benefit payments. Government payments to 

individuals in Alaska include Alaska Permanent Fund benefits, which are derived from oil revenues and paid to every 

resident. 

3. 1980-2000 Change is the change in percentage share of total per capita income (e.g., earnings in Southeast Alaska in 1980 

comprised 83 percent of total per capita income compared to 65 percent in 2000, a difference of 18 percent). In inflationadjusted dollars this represented a 14 percent decrease from $23,597 to $20,270. 

Sources: U.S. Department of Commerce, Bureau of Economic Analysis 2002. 

Table 3.22-11 

Components of Per Capita Income 2005

Southeast Alaska Alaska United States 

Per Capita Income Total ($) 

Percent of 

Total Total ($) 

Percent of 

Total Total ($) 

Percent of 

Total 

Total 36,411 100 35,564 100 34,471 100

Earnings 25,240 69 25,630 72 23,956 69

Transfer payments 5,893 16 4,762 13 5,366 16

Dividends, interest, and rent 5,278 14 5,172 15 5,149 15

See notes 1 and 2 to Table 3.22-10. 

Sources: U.S. Department of Commerce, Bureau of Economic Analysis 2007a.

Transfer payments can be further broken out into various categories with social 

security payments and medical benefits being among the most important. Transfer 

payments per capita in 2005 in Southeast Alaska were slightly higher than the U.S 

and Alaska averages (Table 3.22-11). 

“Other payments” comprised approximately 40 percent of per capita transfer 

payments in Southeast Alaska and Alaska in 2000, compared to less than 1 percent 

nationwide (Table 3.22-12). This category includes certain income categories that are 

directly linked to birthrights or residence in Alaska, notably annual payments from the 

Alaska permanent fund, which have averaged between $1,000 and $2,000 per 

resident in recent years, and dividends from various Alaska native corporations, which 

are variable but often quite substantial. Much of the growth in transfer payments in 

Southeast Alaska and Alaska between 1980 and 2000 was due to increases in the 

other payments category, which exhibited a more than five-fold increase over this 

period. Other payments comprised a smaller share of total Southeast Alaska transfer 

payments in 2005 (Table 3.22-13). 
 Environment and Effects 3 

Final EIS 3-523 Economic and Social Environment 

Table 3.22-12 

Components of Per Capita Transfer Payments, 1980 and 2000

Southeast Alaska Alaska United States 

2000 2000 2000 

Total 

($) 

Percent 

of Total

Change 

1980-

2000 

Total 

($) 

Percent 

of Total

Change 

1980-

2000 

Total 

($) 

Percent 

of Total

Change 

1980-

2000 

Retirement and disability 950 20 -8 769 16 -6 1,508 40 -6

Medical payments 1,028 21 6 1,156 24 4 1,500 40 17

Income maintenance benefits 382 8 -4 466 10 -10 377 10 -2

Unemployment insurance 200 4 -10 178 4 -11 73 2 -5

Other payments1 1,966 41 24 1,909 40 30 7 0 0

Miscellaneous other2 266 6 -7 325 7 -6 328 9 -4

Total transfer payments 4,793 100 0 4,801 100 0 3,793 100 0

1

 Consists largely of Bureau of Indian Affairs payments, education exchange payments, Alaska Permanent Fund dividend 

payments, compensation of survivors of public safety officers, compensation of victims of crime, disaster relief payments, 

compensation for Japanese internment, and other special payments to individuals. 2

 Miscellaneous other includes veterans benefit payments, federal education and training assistant payments (excluding 

veterans), payments to nonprofit institutions, and business payments to individuals. 3

 1980-2000 Change is the change in percentage share of total per capita income (e.g., “other payments” in Southeast Alaska in 

1980 comprised 17 percent of total per capita income compared to 41 percent in 2000, a difference of 24 percent). In inflationadjusted dollars this represented a more than five-fold increase, as other payments increased from $300 per capita to $1,966. 

Source: U.S. Department of Commerce, Bureau of Economic Analysis 2002.

Table 3.22-13 

Components of Per Capita Transfer Payments, 2005

Southeast Alaska Alaska USA 

Total ($) 

Percent 

of Total Total ($) 

Percent 

of Total Total ($) 

Percent 

of Total 

Retirement and disability 1,280 24 1,026 20 1,839 36 

Medical payments 2,107 40 2,171 42 2,205 43 

Income maintenance benefits 509 10 548 11 532 10 

Unemployment insurance 185 4 162 3 109 2 

Other payments1 886 17 866 17 16 0 

Miscellaneous other2 309 6 399 8 447 9 

Total transfer payments 5,275 100 5,172 100 5,149 100

See Table 3.22-12, notes 1 and 2 

Source: U.S. Department of Commerce, Bureau of Economic Analysis 2007c. 

Retirees comprise the most common (but by no means the only) source of non-wage 

income in many rural communities (Colt 2001). In fact, this has given rise in some 

places to local marketing strategies specifically aimed at attracting retirees and 

thereby developing the local “retirement industry.” The growing economic importance 

of retirees was not readily apparent in Southeast Alaska in Table 3.22-12 because the 

increase in the “other payments” category tends to overshadow other changes. 

However, although retirement and disability payments comprise a relatively small 

share of total income by national standards, they almost doubled over this period, 

while medical payments increased by approximately 300 percent. This is partially the 

result of natural aging processes, but the mean age in the study area, and Alaska as a 

whole, has been rising at a much faster rate than elsewhere in the United States. 

This, in turn, may serve as a partial indication that Alaska is becoming more attractive 

for people as a place to live and not merely as a place to earn money. 

Retirement and disability payments and medical payments increased in Southeast 

Alaska in absolute terms and as a share of transfer payments between 2000 and 

2005 accounting for 64 percent of Southeast Alaska transfer payments in 2004, 

compared to 79 percent nationwide (Table 3.22-13). 
3 Environment and Effects

Economic and Social Environment 3-524 Final EIS

The role of “human capital” in local economies is not directly measurable, but it is 

undoubtedly substantial. The skills possessed by a community’s population can be 

essential in determining its adaptability to negative changes and its ability to take 

advantage of new economic opportunities. Skilled employees, for example, constitute 

a key resource for existing or potential employers, and local entrepreneurs can help 

identify and grow new business opportunities if they exist. Owing to improvements in 

transportation and telecommunications, other residents may be able to sell their skills 

in distant or “virtual” labor markets without leaving home. Equally important is the 

skills and energy residents can bring to local government and other community 

organizations. Research has indicated that effective and energetic local government 

supported by strong community involvement is an important ingredient in community 

resiliency and the ability to weather adverse economic events. 

Although it is difficult to directly measure the importance of natural amenities in 

attracting and keeping residents, proximity to natural environments and the 

recreational activities they support are undeniably a benefit enjoyed by residents, 

especially in the more rural communities of Southeast Alaska. At the same time, the 

atmosphere of a community also constitutes an important amenity, and this may often 

be linked to more traditional forms of economic activity, such as fishing or timber. In 

other words, changes in the local economy such as a shift to tourism may impact local 

atmosphere and amenities even if the surrounding natural environment remains 

essentially unchanged. These impacts are often assumed to be negative as tourism 

leads to crowding and the loss of traditional charm, but this need not always be the 

case. Certain tourism establishments, such as restaurants, meeting centers or 

entertainment facilities, often serve local residents as well, and thus add to the 

amenities available to them. Finally, the size of a community has important effects on 

the local amenities available. If a community is too small, or too poor, for example, it 

may not be able to provide many of the basic social and economic amenities many 

residents require, local natural amenities notwithstanding. 

Payments to the State 

Prior to 2000, in states with national forests, 25 percent of the returns to the US 

Treasury from revenue producing Forest Service activities such as timber sales, were 

returned to each state for distribution back to counties (or in Alaska, boroughs) having 

acreage within a national forest. Those payments were called the “25 percent fund 

payments” and were dedicated by law to be used for roads and schools. In October 

2000, the Secure Rural Schools and Community Self Determination Act of 2000 was 

enacted to stabilize federal payments to states in response to declining federal 

receipts. 

The legislation was authorized for implementation for fiscal years 2001 through 2007 

and allowed counties and/or boroughs to choose between 25 percent of current 

receipts or a full payment amount based on the average of the highest three 

payments made to the state during the 14-year period between 1986 and 1999. 

Alaska boroughs and communities have elected to receive a full payment amount 

rather than 25 percent of receipts since enactment of this legislation. Those annual 

full payment amounts are primarily dedicated to roads and schools, with provisions for 

special project funding under certain conditions. Under the full payment approach, 

Forest Service payments to the State of Alaska have been based on the high 3-year 

historic average, rather than linked to annual Forest Service revenue, and, as a result, 

Alaska has received payments of approximately $9 million per year. Payments made 

to the state of Alaska from 1986 through 2007 are shown in Table 3.22-14. 
 Environment and Effects 3 

Final EIS 3-525 Economic and Social Environment 

Table 3.22-14 

Federal Payments to Alaska from NFS Receipts 1986 to 

2006 (Amounts in $1,000s)

Year Payment ($000s)1

1986 820.2 

19872 0.0 

1988 581.4 

1989 6,892.6 

1990 11,703.0 

1991 11,870.3 

1992 4,216.7 

1993 4,847.0 

1994 10,764.7 

1995 9,053.9 

1996 6,874.2 

1997 1,377.3 

1998 2,133.8 

1999 2,295.3 

2000 2,553.1 

2001-20073 9,921.7 1

 Data are adjusted for inflation using the U.S. producer price index and presented in 

2004 dollars and 1,000s. 2

 Tongass receipts in Fiscal Year (FY) 1987 were negative due to Comptroller General 

Decision B-224730 of March 31, 1987, to retroactively implement the emergency rate 

redeterminations for short-term sales. Without this reduction, Tongass receipts would 

have been positive by $2.1 million (unadjusted for inflation). As a result of the 

negative receipt, no payments were made to the State of Alaska that year. 3

 Represents legislated annual payment for FY 2001 to FY 2007 

Source: USDA Forest Service 1997a, 2002b.

Environmental Consequences 

This section describes the potential direct, indirect, and cumulative economic effects 

of the seven alternatives examined in detail in the EIS. The analysis is divided into 

two main sections: 1) economic impact analysis, and 2) economic efficiency analysis. 

The Tongass National Forest budget and payments to the State are addressed in two 

short sections at the end. In addition, a fifth and final section summarizes the 

cumulative effects which are included in the overall analysis. 

The impact analysis section addresses the effects of the proposed alternatives on 

regional employment and income. The efficiency analysis attempts to measure all of 

the costs and benefits to society, both future and present, of each alternative. The 

costs and benefits assessed in an economic efficiency analysis are not restricted to 

cash transactions, but also include non-market benefits such as consumer surplus. 

The concepts and methodologies used in each of these analyses are described in 

detail in the following sections. In general, it should be remembered that impact and 

efficiency analyses measure different things and are not directly comparable. 

Alternatives with positive impacts on jobs and income will not necessarily have high 

benefits under efficiency analysis. 

The cumulative effects of the alternatives are assessed as part of the impact and 

efficiency analyses in the following sections. These effects are addressed in a 

number of ways including the following: The regional economic overview in the 

Affected Environment portion of this section addresses the regional economy as a 

whole to establish context for this analysis. Potential changes in the wood products 

industry are viewed in the context of ongoing changes in other sectors of this industry, 

particularly past and projected future trends in logging on Native corporation lands. 
3 Environment and Effects

Economic and Social Environment 3-526 Final EIS

Effects on the recreation and tourism industry are viewed in the broader context of 

ongoing and possible future trends in visitation to Southeast Alaska. The effects 

analysis also considers the economic implications of the potential effects of the 

alternatives on possible future transportation and public utility projects. 

Economic Impact Analysis 

This section addresses the potential effects of the proposed alternatives on regional 

employment and income and is divided into seven main parts. The first six parts 

address the effects of the alternatives on the wood products industry, recreation and 

tourism, mining, transportation and utilities, salmon harvesting and processing, and 

quality of life, respectively. The final part provides a summary of the effects discussed 

in the preceding sections. 

The economic impact analysis addresses the potential effects of the alternatives on 

the wood products sector in two ways. This section evaluates the long-term impacts 

of the proposed alternatives based on the four projected demand scenarios developed 

by Brackley et al. (2006a). The following section (Wood products—Short-Term 

Effects) discusses the short-term implications of the alternatives by addressing their 

potential effects on national forest timber sale volume under contract, as well as 

NEPA-cleared volume and timber volume in preparation. 

The potential effects of the alternatives on the future supply of national forest timber 

may be evaluated based on the amount of timber available under each alternative. 

The ASQ is the maximum quantity of timber that may be harvested from suitable lands 

on the entire Forest for a 10-year period (36 CFR 219.3). It is usually expressed as 

an annual average. In addition to the volume harvested from suitable lands, timber 

harvested from unsuitable lands can also contribute to market demand needs. The 

Forest contains extensive areas of young-growth forest that are in the stem exclusion 

phase (see the Timber section of this EIS). Thinning these dense stands to improve 

wildlife habitat may result in merchantable volume. Other examples include timber 

that may be salvaged from unsuitable land following windthrow if these trees are in 

excess to dead and down wood habitat needs and timber from harvest on 

oversteepened slopes that is incidental to other harvest operations. 

As discussed earlier, the ASQ is a ceiling and does not represent a future sale level 

projection or target, nor does it reflect all of the factors that may influence future sale 

levels. This is discussed further in the Timber section of this document. As noted in 

the Affected Environment portion of this section, the ASQ consists of two noninterchangeable components (NICs): NIC I, which includes lands that can be 

harvested with normal logging systems, and NIC II, which includes lands with 

especially high logging costs usually due to isolation or special harvesting equipment 

requirements. Acres included in the ASQ but not in NIC I are more costly to harvest 

and not likely to be cut under current market conditions with the current industry 

structure. 

Estimated annual average ASQ and NIC I volumes are presented by alternative for the 

second decade following implementation in Table 3.22-15. These volumes are divided 

into general log class and species type based on recent estimates of the net standing 

volume by species and grade for the Tongass National Forest (Alexander 2006). This 

table also includes projected non-national forest annual harvests for Southeast Alaska, 

which are assumed to be 109 MMBF based on Brackley et al. (2006a). Harvest from 

private lands accounts for the largest share (102 MMBF) of the non-national forest 

harvest, with harvest from other public lands accounting for the remaining 7 MMBF. 

This overall estimate is lower than the volume harvested from non-national forest lands 

in 2004 (123 MMBF) and 2005 (147 MMBF) and lower than estimates of future nonnational forest harvest developed by the McDowell Group et al. (118 MMBF) (McDowell 

Wood Products 

and Timber 

Demand—LongTerm Effects 

The Economic Impact 

Analysis addresses the 

effects of the alternatives 

on regional employment 

and income. 
 Environment and Effects 3 

Final EIS 3-527 Economic and Social Environment 

Group et al. 2004)3. Non-national forest harvest decreased from 221 MMBF in 2000 to 

123 MMBF in 2005 (Figure 3.22-5). As previously noted, harvests from private lands 

are typically exported as logs and are not processed locally. 

Table 3.22-15 

Estimated Timber Supply (second decade annual average) 

Alternative 1 2 3 4 5 6 7 

Entire ASQ Harvested (MMBF Log Scale)

No.1 Spruce/Hemlock1/ 4 14 18 33 24 24 38

No. 2 Spruce/Hemlock 20 62 84 148 110 110 173

Alaska yellow-cedar 5 15 21 36 27 27 42

Western red-cedar 3 9 13 22 17 17 26 

No. 3 Spruce/Hemlock 9 29 39 69 51 51 81

Utility Spruce/Hemlock 7 22 30 52 39 39 61

Total Tongass 49 151 205 360 267 267 421

Non-Tongass National Forest3 109 109 109 109 109 109 109

Total Southeast Alaska 158 260 314 469 376 376 530

NIC 1 Only Harvested (MMBF Log Scale)

No.1 Spruce/Hemlock1/ 4 13 17 28 22 21 33

No. 2 Spruce/Hemlock 20 59 77 129 98 97 152

Alaska yellow-cedar 5 14 19 31 24 24 37

Western red-cedar 3 9 12 19 15 15 23 

No. 3 Spruce/Hemlock 9 27 36 60 46 45 71

Utility Spruce/Hemlock 7 21 27 46 35 34 54

Total Tongass (NIC I only) 49 143 187 314 239 236 370

Non-Tongass National Forest2 109 109 109 109 109 109 109

Total Southeast Alaska 158 252 296 423 348 345 479 1

 The No.1 Spruce/Hemlock category also includes peeler and select logs. 

2

 The 109 MMBF consists of 102 MMBF from private lands and 7 MMBF from other public lands. Harvest from private 

lands is assumed to be exported in log form and not processed in Southeast Alaska. Non-Tongass harvest levels are 

assumed constant across alternatives and time periods. 

NIC I=Non-Interchangeable Component I. NIC I includes lands that can be harvested with normal logging systems.

The following discussion is divided into two main sections. The first section 

addresses the potential effects of the alternatives on the timber industry. The second 

section discusses the potential effects the alternatives would have on timber-related 

employment and income in Southeast Alaska. 

Effects on the Timber Industry 

The following sections evaluate the alternatives with respect to: a) the Pacific 

Northwest Research Station demand projections (Brackley et al. 2006a), and b) 

current production levels, installed capacity, and the minimum volumes required by 

various processing facilities. 

Demand Indicators 

Pacific Northwest Research Station Projections 

The Affected Environment part of this section provides an overview of current 

conditions for the Southeast Alaska wood products industry, outlines the current 

status of the industry, and discusses projected demand, as identified by Brackley et 

al. (2006a) (see Table 3.22-6). One key difference between the demand projections 

prepared by Brackley et al. and those used in past Tongass National Forest planning 

efforts (Brooks and Haynes 1990, 1994, 1997) is that the Brackley et al. (2006a) 

publication presents four specifically designed scenarios, as opposed to three general 

 

3 McDowell Group (2006b) clarified and provided some updated information on their 2004 study 

and noted that they now understand that respective annual harvests from private and state 

lands are likely to be closer to 50 MMBF and 10 to 13 MMBF into the future, respectively.
3 Environment and Effects

Economic and Social Environment 3-528 Final EIS

assumptions of long-term demand. In addition, Brackley et al. (2006a) estimated 

demand in two scenarios for decked logs and a portion of cedar exports only, not total 

harvest, as done in previous projections (see the Affected Environment part of this 

discussion). 

The four scenarios are generally described as limited lumber, expanded lumber, 

medium integrated industry, and high integrated industry. A key issue in these 

scenarios is the use of low-quality material (low-grade and utility logs). The limited 

and expanded lumber scenarios both assume that this material will be left in the 

Forest, sent directly to sawmill chippers, shipped to the lower 48 states, or exported. 

The local wood products industry is assumed to consist primarily of sawmills that 

process higher value material and it is assumed that the economic disposition of lower 

value material (No. 3 sawlogs and utility logs) will continue to be a challenge. The two 

integrated industry scenarios, in contrast, assume the addition of one or more facilities 

that will process this low-quality material. Facilities that could be developed to 

process lower quality material include veneer, medium density fiberboard (MDF), and 

bioenergy facilities among others. The four different scenarios result in total derived 

demand projections that range for the year 2022 from 68 MMBF under Scenario 1 

(Limited Lumber Production) to 342 MMBF under Scenario 4 (High Integrated 

Industry) (Table 3.22-7). 

These scenarios provide a good basis for discussion of where the industry currently 

is, and provide insight into what that industry could look like in the future given various 

assumptions about industry investment and end markets. Of course many factors 

would be involved to shape what the actual industry looks like in the future. The “seek 

to provide a supply of timber from the Tongass National Forest” language of the TTRA 

indicates the Forest should consider a full range of possibilities. The four scenarios 

evaluated by Brackley et al. are useful in this context, especially as the Deciding 

Official works to balance the land base available to provide timber along with all other 

resource values and needs. These four scenarios are hypothetical and presented 

here to illustrate the type of developments that might take place in cases where 

different volumes are made available for harvest. An implicit assumption of all four 

scenarios is that an economically viable and stable timber supply is available from 

multiple sources in Southeast Alaska, including the Tongass National Forest. The 

transition from one scenario to the next involves new private investment and market 

development. A key factor in attracting new investment is whether or not a supply of 

timber “shelf volume” is available for purchase. 

The four scenarios provide one series of benchmarks that the proposed alternatives 

may be measured against. Recognizing that the Southeast Alaska wood products 

industry has essentially been in a period of transition since the APC and KPC pulp 

mills closed in the 1990s, the alternatives evaluated in this document also consider 

alternate futures for the industry, with Alternatives 1 through 4 designed to correspond 

with Brackley et al.’s Scenarios 1 through 4, while also responding to other concerns. 

Alternative 5, No Action, is the current Forest Plan (1997 ROD, as amended). 

Alternative 6, Proposed Action, is also based on the existing plan, but includes 

adjustments based on information generated during the recent 5 Year Plan Review 

and other minor clarifications and updates. Alternative 7 assumes that all wood 

processed in Southeast Alaska would come from the Tongass National Forest. 

Scenario 1 – Limited Lumber Production. This scenario approximates the status of 

the timber industry in Southeast Alaska at the time that the Brackley et al. study was 

completed. Transition of the industry from the pulp mill era, which involved a much 

more integrated industry, toward an industry that is centered around the manufacture 

and supply of a different suite of products has been slow. Uncertainty about a stable 

supply of timber from the Tongass is believed to have contributed to the timeframe of 

this transition. 
 Environment and Effects 3 

Final EIS 3-529 Economic and Social Environment 

Total derived demand is projected to be 68 MMBF in 2022 under this scenario (Table 

3.22-7). It is likely that this volume would be primarily logs from more economical 

(NIC I) lands. Existing mills would continue to have insufficient timber to operate 

efficiently. The lower value logs sold in federal, state, and private timber harvest 

projects would continue to be left in the woods, exported, or chipped and sold when 

favorable markets conditions exist. 

Alternative 1 with a maximum annual average harvest level of 49 MMBF could 

not provide sufficient volume to meet this scenario as currently modeled. 

Alternatives 2, 3, 4, 5, 6, and 7 could all provide sufficient volume to meet this 

scenario during the next 10 to 15 years. 

Scenario 2 – Expanded Lumber Production. This scenario also projects only 

higher value logs are processed, with limited new investments in the existing mills in 

Southeast Alaska. The scenario assumes that there will be sufficient sawlog wood 

supply, primarily from federal and state timber lands, to efficiently operate the existing 

mills in Southeast Alaska. No new mills will be installed to utilize the lower value logs 

from any lands in Southeast and this material could be left in the woods, exported, or 

chipped and sold when favorable market conditions exist.. 

Total derived demand is projected to be 187 MMBF in 2022 under this scenario (Table 

3.22-7). As in Scenario 1, it is likely that this volume would be primarily higher value 

logs from the more economical (NIC I) lands. 

Alternatives 1 and 2 with maximum annual average harvest levels of 49 MMBF 

and 151 MMBF, respectively, could not provide sufficient volume to meet this 

scenario. 

Alternatives 3, 4, 5, 6, and 7 could all provide sufficient NIC I volume to meet this 

scenario. 

Scenario 3 – Medium Integrated Industry. This scenario builds on Scenario 2 and 

would establish processing capacity to fully utilize sawlogs and low grade and utility 

logs from federal and state timber sales. Under this scenario the current sawlog 

milling capacity would operate efficiently and new processing capacity would be 

developed to utilize the material that has been left in the woods or exported. Some 

material from other land ownerships has the potential to be used by local mills. Lowgrade logs would be used to produce chemicals, energy, or engineered wood 

products. 

Total derived demand is projected to be 204 MMBF in 2022 under this scenario (Table 

3.22-7). It is likely that this volume would come from both the more economical (NIC 

I) lands and the less economical (NIC II) lands. 

Alternatives 1 and 2 with maximum annual average harvest levels of 49 MMBF 

and 151 MMBF, respectively, could not provide sufficient volume to meet this 

scenario. 

Alternatives 3, 4, 5, 6, and 7 could provide sufficient volume to meet this 

scenario. 

Scenario 4 – High Integrated Industry. This scenario builds on Scenario 3 and 

provides an estimate of the upper market level for the foreseeable future. In order for 

this situation to be realized, new investments in processing capacity would need to be 

made and additional market shares established. 

Total derived demand is projected to be 342 MMBF in 2022 under this scenario (Table 

3.22-7). It is likely that this volume would come from both the more economical (NIC 

I) lands and the less economical (NIC II) lands. Note that Brackley et al. (2006a) 

indicate that it would likely take several years to fully achieve Scenario 4. 
3 Environment and Effects

Economic and Social Environment 3-530 Final EIS

Alternatives 1, 2, 3, 5 and 6 with maximum annual average harvest levels of 49 

MMBF, 151 MMBF, 205 MMBF, 267 MMBF, and 267 MMBF respectively, could 

not provide sufficient volume to meet this scenario. 

Alternatives 4 and 7 could provide sufficient volume to meet this scenario. 

The ability of the seven alternatives to supply enough timber to satisfy the projected 

demand for timber under each scenario is summarized in Table 3.22-16.

Table 3.22-16 

Ability of the Alternatives to meet the Timber Demand Scenarios in 2022

 Alternative1

 1 2 3 4 5 6 7 

Scenario 1 No Yes Yes Yes Yes Yes Yes 

Scenario 2 No No Yes Yes Yes Yes Yes 

Scenario 3 No No Yes Yes Yes Yes Yes 

Scenario 4 No No No Yes No No Yes 

1. While an alternative may be technically able to meet a given demand scenario, the ability to do so in the 

short-term is highly dependant on budgets, resolution of current litigation and success in implementing 

new projects. It takes several years to initiate and complete a new analysis and implement the decision 

through sale layout and contract award. 

Current Production Levels, Installed Capacity, and Minimum Volumes Required 

by Various Processing Facilities 

The following sections evaluate the potential effects of the alternatives using three 

sets of evaluation criteria: current production levels, installed capacity, and the 

minimum volumes required to operate by various processing facilities. Current (2005) 

production levels and active and total installed capacity are shown by facility in Table 

3.22-5. 

The minimum timber volumes required by various processing facilities are identified in 

Table 3.22-17. These minimum estimated volumes are compared with the estimated 

annual ASQ for the second decade following Plan implementation for each alternative 

in Figure 3.22-11. As shown in Table 3.22-18, the different types of potential facilities 

would use different types of logs, although in most cases different types of logs may 

be used by more than one type of facility. Both sawmills and a veneer plant would, for 

example, be able to process No. 2 spruce and hemlock sawlogs (Table 3.22-18). In 

addition, different facilities would be able to process more than one type of log. A 

veneer plant may, for example, process No. 2 spruce and hemlock sawlogs, No. 3 

spruce and hemlock sawlogs, and cedar (Table 3.22-18). These points should be 

kept in mind when viewing the simplified comparison presented in Figure 3.22-11. 
 Environment and Effects 3 

Final EIS 3-531 Economic and Social Environment 

Table 3.22-17 

Minimum Timber Volumes Required by Various Processing Facilities

Facility Volume (MMBF) 

Sawmills1 138 

Veneer Plant2 30 

MDF or Bioenergy 2 80 to 100 1

 The estimated sawmill volume is approximately 66 percent of existing mill capacity based on the four largest existing 

sawmills, with some allowance for smaller sales. It is not 66 percent of the estimated mill capacity shown in Table 3.22-5. 2

 These volumes are the minimum required to operate the identified types of facilities. 

Source: Estimates developed by the Forest Service based on McDowell Group et al (2004), Brackley et al. (2006b), and the 

Juneau Economic Development Council (2006) with updates by Southeast Alaska sawmills. 

Table 3.22-18 

Log Utilization by Facility

Log Grade/Species 

Percent of Average 

Harvest Facility Type 

Peeler/Select/No.1 Spruce/Hemlock 9 Sawmill 

No. 2 Spruce/Hemlock 41 Sawmill, veneer 

Alaska yellow-cedar 10 Sawmill, veneer 

Western red-cedar 6 Sawmill, veneer 

No. 3 Spruce/Hemlock 19 Veneer, MDF, Bioenergy 

Utility Spruce/Hemlock 15 MDF, Bioenergy 

Total 100 NA 

Source: Alexander 2006

Figure 3.22-11 

Minimum Timber Volumes Required by Various Processing Facilities and 

Estimated Average Annual Supply (NIC I), Second Decade 

0.0

50.0

100.0

150.0

200.0

250.0

300.0

350.0

400.0

1234567

Alternative

MMBF

No.1 S/H No. 2 S/H Cedar No. 3 S/H Utility S/H

Saw mills--138 MMBF

Veneer Plant--30 MMBF

MDF, Bioenergy, etc.--80 to 100 MMBF

Notes:

S/H = Spruce/Hemlock 

1. No. 1 S/H includes Peeler, Select, and No.1 spruce and hemlock sawlogs. 

2. The minimum timber volumes required by various processing facilities are shown in Table 3.22-17. Log utilization by 

facility is shown in Table 3.22-18. 

3. Estimated supply by alternative is based on the projected ASQ and average timber sale composition in terms of 

species and log grades (see Table 3.22-15). 
3 Environment and Effects

Economic and Social Environment 3-532 Final EIS

Table 3.22-19 

Projected Second Decade NIC I Volumes and Active and Total Installed 

Capacity 

 Alternative 

 1 2 3 4 5 6 7 

Log Grade/Species Projected NIC I (MMBF Log Scale) 

Higher Value1 24 72 94 157 119 118 185 

Cedar2 8 23 30 51 39 38 60 

Lower Value3

 9 27 36 60 46 45 71 

Utility 7 21 27 46 35 34 54 

Total 49 143 187 314 239 236 370 

Capacity Percent of 2006 Active and Total Installed Capacity 

Active Installed Capacity4 9% 27% 36% 60% 46% 45% 71% 

Total Installed Capacity5 7% 20% 26% 43% 33% 33% 51% 

Notes: 

1/Higher value consists of No.1 and No.2 Spruce/Hemlock (see Table 3.22-15) 

2/Cedar includes Alaska yellow-cedar and Western red-cedar (see Table 3.22-15) 

3/Lower value includes No. 3 Spruce/Hemlock (Table 3.22-15) 

4/Active installed capacity was 261 MMBF in 2005 (Table 3.22-5) 

5/Total installed capacity was estimated at 361 MMBF in 2006 (see Table 3.22-5, Note 1) 

Alternative 1—The maximum annual average timber harvest under Alternative 1 

would be approximately 49.3 MMBF per year in the second decade, with a NIC I 

component of approximately 48.8 MMBF. This harvest level could be met in the first 

year if this alternative was selected and the timber volume presently under litigation 

was made available for harvest. As of September 2007, there was 43.5 MMBF under 

active litigation, with an additional 165 MMBF withdrawn under the 2007 Natural 

Resources Defense Council settlement until completion of this forest planning 

process. 

Based on the typical log mix for the Tongass National Forest, the NIC I volume would 

include approximately 24 MMBF of higher-value spruce and hemlock logs 

(peeler/select, No. 1, and No. 2), 8 MMBF of cedar logs, and 16 MMBF of lower-value 

spruce and hemlock sawlogs (No. 3 and utility) (Table 3.22-19). This volume would 

not be sufficient to support the existing Southeast Alaska sawmills operating at their 

recent production levels (32.1 MMBF in 2006). Further, the Southeast Alaska sawmill 

industry is currently operating at less than 14 percent of the active mill capacity and 

less than 10 percent of total installed capacity (Table 3.22-19). 

Viewed in terms of the minimum timber volumes required by various processing 

facilities, this volume would be insufficient to meet the estimated sawmill requirement 

of 138 MMBF of high value timber (Table 3.22-17). The available supply of higherquality material (including cedar) would account for about 32 MMBF of the total 

harvest under this alternative (Table 3.22-15). There would be sufficient volume to 

support a veneer plant (30 MMBF) if 14 MMBF or more of No. 2 spruce/hemlock 

sawlogs were processed by this type of plant, rather than the existing sawmills. The 

projected supply of No. 3 spruce/hemlock sawlogs (9 MMBF) and utility logs (7 

MMBF) would not be sufficient to support a chip related facility, such as a MDF plant. 

This alternative would not meet the potential upper planning cycle demand of 360 

MMBF. 

Alternative 2—The maximum annual average harvest level under Alternative 2 would 

be approximately 151 MMBF per year in the second decade, with a NIC I component 

of approximately 143 MMBF. Based on the typical log mix for the Tongass, the NIC I 

volume would consist of approximately 72 MMBF of higher-value logs, 23 MMBF of 

cedar logs, and 48 MMBF of lower-value sawlogs and utility logs (Table 3.22-19). 
 Environment and Effects 3 

Final EIS 3-533 Economic and Social Environment 

This volume would be sufficient to support the existing Southeast Alaska sawmills 

operating at their current production levels (32.1 MMBF in 2006). The estimated 

higher-value component under this alternative (72 MMBF) would allow regional 

sawmills to operate at approximately 27 percent of the active installed processing 

capacity and 20 percent of total installed production capacity in 2006 (Table 3.22-19). 

Viewed in terms of the minimum timber volumes required by various processing 

facilities, this volume would be insufficient to meet the estimated sawmill requirement 

of 138 MMBF of high value timber. However, if all the sawlogs were to go to existing 

sawmills, these mills would operate at a higher rate than they are at present, and 

assuming their ability to use the lower grade sawlogs more efficiently, approximately 

100 MMBF would be available for processing under this alternative. Improved 

efficiency could result from investments in existing equipment or new capacity. If the 

existing sawmills were not to operate at this level and processed only higher grade 

sawlogs, there would be sufficient volume to support a veneer plant. 

This alternative would not meet the potential upper planning cycle demand of 360 

MMBF. 

Alternative 3—The maximum annual average harvest level under Alternative 3 would 

be approximately 205 MMBF per year in the second decade, with a NIC I component 

of approximately 187 MMBF 

Based on the typical log mix for the Tongass, the NIC I volume would consist of 

approximately 94 MMBF of higher-value logs, 30 MMBF of cedar logs, and 63 MMBF 

of lower-value sawlogs and utility logs (Table 3.22-19). This volume would be 

sufficient to support the existing Southeast Alaska sawmills operating at their current 

production levels (32.1 MMBF in 2005). The estimated higher-value component of the 

ASQ under this alternative (94 MMBF) would allow regional sawmills to operate at 

approximately 36 percent of the active installed processing capacity and 26 percent of 

total installed production capacity calculated in 2006 (Table 3.22-19). 

Viewed in terms of the minimum timber volumes required by various processing 

facilities, this volume would not have enough high grade sawlogs to meet the 

estimated sawmill requirement of 138 MMBF of high value timber. However, similar to 

Alternative 2, if all sawlogs were to go to the existing sawmills they would operate at a 

higher rate and use lower grade sawlogs more efficiently. There would also be 

enough volume to support a veneer plant and export the remainder; support two 

veneer mills; or operate an MDF or similar facility. Over the long-term, a relatively 

stable level of harvest around the 185 MMBF range would be expected to encourage 

the development of a moderate level of integration for the local industry. 

This alternative would not meet the potential upper planning cycle demand of 360 

MMBF. 

Alternative 4—The maximum annual average harvest level under Alternative 4 would 

be approximately 360 MMBF per year in the second decade, with a NIC I component 

of approximately 294 MMBF. This is the second highest projected volume in any of 

the alternatives. Alternative 7 has the highest. 

Based on the typical log mix for the Tongass, the NIC I volume would consist of 

approximately 157 MMBF of higher-value logs, 51 MMBF of cedar logs, and 106 

MMBF of lower-value sawlogs and utility logs (Table 3.22-19). The estimated highervalue component would allow regional sawmills to operate at approximately 60 

percent of active installed processing capacity and 43 percent of total installed 

production capacity calculated in 2006 (Table 3.22-19). 

Viewed in terms of the minimum timber volumes required by various processing 

facilities, this volume would be sufficient to meet the estimated sawmill requirement of 

138 MMBF of high value timber and the estimated veneer plant requirement of 30 
3 Environment and Effects

Economic and Social Environment 3-534 Final EIS

MMBF. There would also be available cedar to either run through the existing 

sawmills or support a new mill that specializes in cedar. In addition, the available 

supply of low grade sawlogs and utility logs would be sufficient to support a chip 

related facility, such as an MDF plant. 

As industry becomes more integrated, it is possible that the veneer plant and chip 

related operations would expand operations to efficiently take advantage of this 

excess material. There could also be additional new investment in sawmills in the 

region, with, for example, investment in new facilities closer to sources of raw 

materials, which would reduce transportation costs. The amount of cedar harvested 

may continue to exceed the local capacity to process it, but investments in production 

of high end wood products may reduce the amount that is surplus. 

This alternative would not meet the potential upper planning cycle demand of 360 

MMBF. 

Alternative 5, No Action and Alternative 6, Proposed Action—The maximum 

annual average harvest levels under Alternative 5 and 6 would be approximately 267 

MMBF under either alternative, with respective NIC I components of approximately 

239 MMBF and 236 MMBF, respectively. These alternatives are midway between 

Alternatives 3 and 4 in terms of projected volume. 

Based on the typical log mix for the Tongass, the volume for these alternatives would 

be comprised of approximately 119 MMBF of higher-value logs, 39 MMBF of cedar 

logs, and 81 MMBF of lower-value sawlogs and utility logs (Table 3.22-19). The 

estimated higher-value component would allow regional sawmills to operate at 

approximately 45 percent of the active installed processing capacity and 33 percent of 

total installed production capacity calculated in 2006 (Table 3.22-19). 

Based on the existing active installed sawmill processing capacity, these alternatives 

would almost provide sufficient higher-value timber supply for existing sawmills to 

operate at or near full capacity. There would be sufficient timber to operate the 

existing sawmills at or near full capacity if they were also able to process cedar. The 

total projected NIC I volume under these alternatives would not be quite sufficient to 

support a fully integrated industry. There would be sufficient volume to support one or 

more veneer plants or an MDF or other chip-related operation, but not both. 

These alternatives would not meet the potential upper planning cycle demand of 360 

MMBF. 

Alternative 7—The maximum annual average harvest level under Alternative 7 would 

be approximately 421 MMBF per year in the second decade, with a NIC I component 

of approximately 370 MMBF. This is the highest projected volume under any of the 

alternatives. 

Based on the typical log mix for the Tongass, the NIC I volume would be comprised of 

approximately 185 MMBF of higher-value logs, 60 MMBF of cedar logs, and 125 

MMBF of lower-value sawlogs and utility logs (Table 3.22-19). The estimated highervalue component represents approximately 71 percent of the active installed 

processing capacity and 51 percent of total installed production capacity in 2006 

(Table 3.22-19). 

Viewed in terms of the minimum timber volumes required by various processing 

facilities, Alternative 7 would be sufficient to meet the estimated sawmill requirement 

of 138 MMBF of high value timber and the estimated veneer plant requirement of 30 

MMBF. There would also be cedar available to run through the existing sawmills or 

support a new mill that specializes in cedar. In addition, the available supply of low 

grade sawlogs and utility logs would be sufficient to support one or more chip related 

facilities, such as an MDF plant. 
 Environment and Effects 3 

Final EIS 3-535 Economic and Social Environment 

The potential effects under this alternative would be similar to those described for 

Alternative 4 above. Although there would be more volume available under 

Alternative 7 than under Alternative 4, the general trend would be expected to be the 

same and is based on the assumption that a reliable supply of timber would allow the 

development of an integrated industry and encourage the development of new 

facilities and the utilization of existing facilities. This alternative also assumes that all 

wood processed in Southeast Alaska would come from the Tongass National Forest. 

As with Alternative 4, the highly integrated nature of the timber industry that could be 

supported by this level of projected harvest could involve the entry of more 

businesses and/or facilities in Southeast Alaska. As industry becomes more 

integrated, it is possible that the veneer plant and chip related operations would 

expand operations to efficiently take advantage of this excess material. There could 

also be additional new investment in sawmills in the region, as discussed with respect 

to Alternative 4. 

This alternative would meet the potential upper planning cycle demand of 360 MMBF. 

Discussion 

How the timber industry would respond to a stable supply of timber under any of the 

alternatives described above is speculative. The projected scenarios are based on 

the assumption that as stable volumes increase, the industry will develop in an 

integrated fashion, with operations and production that utilize materials that are 

inefficient or excess to one another’s production needs. An integrated industry could 

also promote the establishment of other businesses that provide both direct and 

indirect support services, such as lumber and/or specialty wood product grading and 

certification. Coordinated or consolidated marketing of Alaskan wood products could 

be another example of integrated operations. 

Several developments hold promise for the timber industry in Southeast Alaska 

regardless of which harvest level stabilizes. A wood-burning boiler is being installed 

by the community of Craig to heat school buildings and a recreation facility, reducing 

energy costs by utilizing waste wood. Several other communities have shown interest 

in this type of system. Investments in dry kilns and planers in several facilities 

suggest an increase in production of high value wood products. Wood technology 

and testing has helped secure a set of Alaska lumber grades for Alaska species. 

Hemlock, for example, with the Alaska lumber grade can now compete directly with 

Douglas fir construction grade lumber. To take best advantage of this, the lumber 

needs to be dried, planed and graded. In Alaska alone, the construction lumber 

market consumes approximately 120 MMBF per year. 

Once positioned, Southeast Alaskan facilities could tap into that high end market, 

which is currently supplied by material imported from the lower 48 states. Other 

examples include development of specialty and finished wood products from hemlock 

and development of dried, sawn, and finished house kits. Products such as glue 

laminated materials are being tested and show promise. Specialty products made of 

yellow-cedar are currently marketed internationally. Collective marketing of local 

wood products could have a positive impact on sales of locally produced material. 

With a stable supply of material, it might be possible for the local wood industry to 

regain market share in world wide wood product markets, as well as continue to 

develop niche markets that take advantage of the high quality and uniqueness of 

Alaska woods. 
3 Environment and Effects

Economic and Social Environment 3-536 Final EIS

Employment and Income 

Projected levels of employment and income are presented by alternative in Table 

3.22-20. These estimates are based on the annual average NIC I component of the 

ASQ. Direct employment is calculated using a coefficient of 3.31 jobs/MMBF for 

sawmill employment and 2.31 jobs/MMBF for logging employment (Alexander 2007). 

These coefficients are based on average levels of forest-related employment per unit 

of net sawlogs harvested on the Tongass for the 2000 to 2005 period. This time 

period excludes volume from long-term contracts and the employment volatility of the 

late 1990s, and is, therefore, representative of current conditions. Total employment 

is calculated using regional multipliers estimated using IMPLAN. (See note 6 in Table 

3.22-20 for an explanation of the difference between the various multipliers). 

The estimates presented in Table 3.22-20 assume the entire NIC I component for the 

first decade would be harvested. They also assume a linear relationship between 

harvest and employment levels, with a one percent change in harvest resulting in a 

one percent change in employment. In reality, changes in volume will have a lagged 

response in employment, but this assumed linear relationship is an approximation that 

can be used to compare alternatives. Estimated changes in sawmill and logging 

employment are presented in job-years, which represent the equivalent of one year’s 

employment. This potential employment would not necessarily occur all in one year 

and estimated job totals do not directly translate into estimated numbers of affected 

workers. 

The logging employment totals identified in Table 3.22-20 also include jobs associated 

with non-Tongass National Forest harvest activities. Non-Tongass harvest in 

Southeast Alaska is assumed to be 109 MMBF for all alternatives and, with the 

exception of the approximate 7 MMBF harvested from state lands, is assumed for the 

purposes of this analysis to be exported in unprocessed form (Brackley et al. 2006a). 

As noted in a preceding section, this estimate is lower than the volume harvested from 

non-national forest lands in 2004 (123 MMBF) and 2005 (147 MMBF), and lower than 

estimates of future non-national forest harvest developed by the McDowell Group et 

al. (118 MMBF) (McDowell Group et al. 2004).4

 

Assuming the entire NIC I component were harvested over the next decade, average 

annual direct wood products employment would range from 494 annualized jobs 

under Alternative 1 to 1,922 jobs under Alternative 7. Approximately 226 of these 

annualized jobs would be associated with non-Tongass harvest under each 

alternative. Average annual total employment (direct, indirect, and induced) would 

range from 970 jobs under Alternative 1 to 3,829 jobs under Alternative 7. The 

potential effects on direct and total income are also summarized by alternative in 

Table 3.22-20. 

The impact of the recent policy change (March 2007), referred to as the Limited 

Interstate Shipment Policy, on wood products-related employment at the Forest level 

will most likely be positive. The policy is expected to increase the likelihood that 

timber sales on the Tongass will have a positive appraisal and is expected to increase 

the utilization of timber harvested on the Tongass and improve the economics of 

timber sales by providing a market for smaller diameter and low grade material that 

cannot be processed profitably by sawmills in Southeast Alaska at present (Alexander 

et al. 2007). 

Under Alternatives 1 and 2, only a portion of the NFS timber harvested would be 

processed in Southeast Alaska sawmills because there is a limited market for utility 

 

4

As noted above, the McDowell Group (2006b) have since adjusted their annual estimate for 

private and state lands to 60 to 63 MMBF.
 Environment and Effects 3 

Final EIS 3-537 Economic and Social Environment 

logs and lower value sawlogs. The higher volume alternatives are, however, based 

on the assumption that as sale volumes increase and perceptions of risk decrease, 

the industry will develop in an integrated fashion, with different operations using 

materials that are inefficient or excess to one another’s production needs. If this were 

to occur the percent of the harvest that would be processed locally would likely be 

higher than current levels (66 percent). As a result, the employment estimates 

presented in Table 3.22-20 should be viewed as minimum employment levels that 

likely underestimate the amount of sawmill (or other processing facility) employment 

that would occur at higher harvest levels. 

Table 3.22-20 

Projected Timber Industry Employment at Maximum Allowable Timber Harvest Levels 

(First Decade, Annual Average)

 Alternative 

 2005 1 2 3 4 5 6 7 

Actual (2005) and Projected NIC I Volume (MMBF)1

Tongass National Forest 43 49 144 186 272 239 238 367 

Total Southeast Alaska Harvest2

 197 158 253 295 381 348 347 476 

Employment (Average Annual)

Direct Employment3 

 Logging4

 351 365 583 680 880 803 801 1,098 

 Sawmills5

 148 129 336 428 616 544 542 823 

 Total 499 494 919 1,108 1,496 1,346 1,343 1,922 

Total Employment (Direct, Indirect, Induced)6

 Logging 674 700 1,120 1,306 1,689 1,541 1,538 2,109 

 Sawmills 309 270 702 894 1,288 1,136 1,132 1,720 

 Total 983 970 1,822 2,200 2,977 2,677 2,670 3,829 

Income (million 2005 $)

Direct Income7

 

 Logging 14.8 15.4 24.6 28.7 37.2 33.9 33.8 46.4 

 Sawmills 4.7 4.1 10.6 13.6 19.5 17.2 17.2 26.1 

 Total 19.5 19.5 35.3 42.3 56.7 51.1 51.0 72.5 

Total Income (Direct, Indirect, Induced)6

 Logging 20.6 21.4 34.3 40.0 51.7 47.1 47.0 64.5 

 Sawmills 7.1 6.2 16.1 20.5 29.5 26.0 25.9 39.4 

 Total 27.7 27.6 50.3 60.4 81.2 73.2 73.0 103.9 1

 It is important to note that the NIC I levels by alternative that form the basis of these employment and income estimates are not 

projected harvest levels. Rather, they represent the maximum NIC I volumes that could be harvested under each alternative. 2

 Total Southeast Alaska harvest includes Tongass, private (Native corporation), and state harvests. Private and State harvests are 

assumed to remain constant at 109 MMBF under all alternatives (Brackley et al. 2006a). 3

 Logging and sawmill job/MMBF ratios, 2.31 jobs/MMBF and 3.31 jobs/MMBF, respectively, are based on 2000 to 2005 average levels

of employment per MMBF of net sawlog volume harvested (Alexander 2007). 4

 Logging employment is calculated by multiplying total Southeast Alaska harvest (including non-Tongass harvest) by 2.31 jobs/MMBF. 

Note: these estimates are based on current industry structure and assumed behavior. 5

 Sawmill employment is calculated based on the estimated sawlog share of harvest on the Tongass (66 percent) (Alexander 2006). 

Non-Tongass harvest, with the exception of about 7 MMBF harvested from state lands, is assumed to be exported in unprocessed 

form. Note: these estimates are based on current industry structure and assumed behavior. 6

 Total employment and income multipliers are from the 1998 IMPLAN model (see Table 3.22-4). Note that the estimate of direct 

employment embedded in the IMPLAN number will not be the same as direct employment calculated using actual Southeast Alaska 

logging and sawmilling data. You cannot subtract the direct employment estimates from the total employment numbers to get indirect 

and induced employment. 7

 Direct income is estimated using the annual average wage for the Alaska Forestry and Logging ($42,257) and Wood Products 

Manufacturing ($31,690) sectors from 2001 to 2005 (Alexander 2007).

In order to provide a stable timber sale program and provide a continued flow of 

timber to regional timber processors, the Forest Service employs a “buffer stock” 

approach to timber sale planning. The resulting timber sale program is complex and 

requires that the Forest Service manage four “pools” of timber volume, commonly 

referred to as the “timber pipeline.” These pools of timber volume include: volume 

under contract, NEPA-cleared volume, timber volume in preparation, and timber 

Wood Products 

and Timber 

Demand—ShortTerm Effects 
3 Environment and Effects

Economic and Social Environment 3-538 Final EIS

volume identified in the Forest Service’s 5-year Plan. The “timber pipeline” and its 

constituent parts are discussed in more detail in the Timber section of this EIS. 

Timber sales can take from 3 to 5 years to complete. Sales offered by the Forest 

Service vary in size to meet the needs of different purchasers and in preparation time 

as a function of the sale offering size. Uncertainty and delays may be introduced 

through appeals and litigation. The buffer stock approach and the variable length of 

the timber sale process generally make it difficult to draw a direct relationship between 

particular sales and regional timber demand. It is, however, apparent that under 

current conditions a reduction in the timber volume under contract (i.e., the volume 

included in timber sales that have been purchased, but not logged or only partially 

logged) would affect regional timber operators, with related effects to regional 

employment and income. The affected volumes could be replaced or substituted in 

part or fully, but this would take time and reductions in the volume under contract 

would have direct and relatively immediate effects upon the affected operators. 

The following discussion addresses the potential effects of the alternatives on three 

key components of the “timber pipeline”: volume under contract, NEPA-cleared 

volume (i.e., sales that have approved NEPA documents but have not yet been sold), 

and timber volume in preparation (i.e., proposed sales that are currently being 

evaluated under the NEPA process). 

Volume Under Contract 

As noted above, volume under contract refers to the volume included in timber sales 

that have been purchased, but not logged or only partially logged. Volume under 

contract is, therefore, essentially a measure of inventory that changes on a regular 

basis, increasing as timber is sold and added to the total and decreasing when sales 

are actually harvested. The following discussion illustrates the potential effects of the 

alternatives on volume under contract with reference to data from August 2006. It 

should be noted that while these data provide an indication of potential impacts, the 

actual impacts would depend on the volume that is under contract when the decision 

is implemented and whether potentially affected existing sales were cancelled as part 

of the decision. 

The Forest Service had approximately 104 MMBF in uncut volume under contract in 

August 2006. The majority of this volume (92 percent) was located in Ranger Districts 

on the south end of the Forest, with the Ketchikan and Wrangell ranger districts 

accounting for 41 percent and 25 percent of the total, respectively. This volume was 

under contract with five purchasers, including Pacific Log and Lumber (41 percent of 

the total), Viking Lumber Company (25 percent), and Alcan Forest Products (23 

percent). Note that the corresponding volume in July 2007 was 102 MMBF (USDA 

Forest Service 2007e). 

Review of the proposed alternatives indicated that 52 percent of the volume under 

contract in August 2006 could be affected under Alternative 1, which would maintain 

all Inventoried Roadless Areas on the Tongass in a natural condition and not permit 

timber harvest in these areas. The volume currently under contract would not be 

affected under any of the other alternatives. 

Existing volumes under contract likely represent the majority of the short-term timber 

supply for the affected purchasers and reductions in the existing volume under 

contract would be difficult to make up from other areas in the near future. Reductions 

in the volume under contract could, therefore, potentially affect both sawmill and 

logging employment. Using the logging and sawmill job/MMBF ratios employed for 

the preceding long-term effects analysis (2.31 jobs/MMBF and 3.31 jobs/MMBF, 

respectively) and assuming the entire volume would be harvested and approximately 
 Environment and Effects 3 

Final EIS 3-539 Economic and Social Environment 

50 percent of the total would be processed locally, the potentially affected volume of 

54 MMBF would support approximately 214 job-years. 

NEPA-Cleared Volume 

The Forest Service had approximately 454 MMBF in the NEPA-cleared volume pool in 

August 2006. It should be noted that not all this volume is considered economic under 

current market conditions. Review of the proposed alternatives indicated that 

approximately 56 percent and 44 percent of this volume could be affected under 

Alternatives 1 and 2, respectively. These data are intended to illustrate the potential 

effects. As noted with respect to the volume under contract, actual impacts would 

depend on the NEPA-cleared volume when the decision is implemented. The NEPAcleared volume in September 2007 was 309 MMBF (USDA Forest Service 2007f). 

Timber Volume in Preparation 

The third component of the timber supply is the timber volume in preparation. The 

Forest Service had approximately 536 MMBF in preparation in September 2006 

spread across 17 separate projects. Under Alternative 1 approximately 56 percent of 

the proposed total would not be available for harvest. Alternatives 2 and 3 would 

each affect 7 percent of the proposed total. As noted above, these data are intended 

to illustrate the potential effects. Actual impacts would depend on the timber volume 

in preparation when the decision is implemented. The Forest Service had 

approximately 384 MMBF in preparation in September 2007 (USDA Forest Service 

2007f).

The following analysis addresses recreation and tourism over the decade following 

implementation. Recreation supply is subject to cumulative impacts with the effects of 

timber harvest activities on recreation places accumulating over time and increasing 

impacts felt in later decades. 

Supply 

The general methodology for deriving projected levels of recreation and tourism 

employment is described in detail in the Affected Environment part of this section. 

Three types of recreation opportunity settings (ROS 1, ROS 2, and ROS 3) are used 

in the economic analysis. Timber harvest and other activities result in a 

reclassification of certain acres from one ROS group to another. Road construction, 

for example, will generally cause a given area to be reclassified as ROS 3 (Roaded 

Natural, Roaded Modified, and Rural). The availability for use of ROS 3 designations 

also depends on the connection between proposed road networks and ferry landings 

or local communities. Had these acres been classified as ROS 1 (or ROS 2) 

previously, the result would be a net reduction of ROS 1 (or ROS 2) and an increase 

in ROS 3. Depending on the relative demand for different ROS groups, the result 

could be an increase, a decrease, or no change in recreation and tourism activity. If, 

in the current example, demand for ROS 1 exceeds supply and ROS 3 settings are in 

surplus, then the net result would be a decrease in recreational activity. If, however, 

supply exceeds demand for both ROS classes, the net impact on recreation and 

tourism activity is assumed for the purposes of this analysis to be zero. 

Each ROS group has a maximum capacity based on the type of experience expected 

within the setting. ROS 1 has the lowest capacity per acre because it provides 

primitive recreation opportunities that require that users not be within sight or sound of 

other parties. While ROS 2 has a higher capacity per acre than ROS 1, users in this 

setting expect to see only a few other parties during their experience. ROS 3 has the 

highest capacity and users in this setting may expect to interact frequently with others. 

Timber harvest activity could, therefore, result in an increase in recreation capacity 

Recreation and 

Tourism 
3 Environment and Effects

Economic and Social Environment 3-540 Final EIS

measured in terms of RVDs, because areas classified as ROS 1 or ROS 2 would be 

converted to ROS 3.

Demand 

Future demand for recreational activity on the Tongass National Forest was predicted 

using a linear projection of total RVDs (see Figure 3.22-7). Historical patterns of RVD 

use by ROS class were then used to predict future recreation and tourism demand by 

ROS class. Using this methodology, estimated demand for ROS 2 class RVDs (SemiPrimitive Motorized) exceeded estimated supply of ROS 2 settings in 1998. Differences 

in projected levels of recreation use between alternatives are small because ROS 2 is the 

only setting where demand exceeds supply in the first decade of this analysis and effects 

related to harvest activity have had little time to accumulate. As discussed in the Affected 

Environment section, the finding that demand exceeds supply is based on the supply of 

ROS 2 opportunities in specifically identified recreation places only and assumes there 

would be no change in the current availability of recreational settings. These 

assumptions do not accurately reflect underlying supply realities but are necessary to 

allow a quantitative comparison of the alternatives. 

Consumption 

Projected supply and consumption are presented in RVDs by alternative for the next 

decade in Table 3.22-21. 

Table 3.22-21 

Recreation/Tourism Supply, Demand, and Consumption (First Decade, 

Annual Average)

Alternative 

 2015 1 2 3 4 5 6 7 

Supply (1,000 RVDs) 

ROS1 1,245 1,289 1,282 1,269 1,227 1,245 1,252 1,223 

ROS2 1,995 2,018 2,007 2,000 1,972 1,995 1,994 1,966 

ROS3 2,616 2,262 2,335 2,435 2,779 2,616 2,566 2,819 

Total 5,856 5,569 5,623 5,705 5,978 5,856 5,812 6,009 

Demand (1,000 RVDs) 

ROS1 1,104 

ROS2 3,422 

ROS3 993 

Total 5,519 

Projected Consumption (1,000 RVDs) 

ROS1 1,104 1,104 1,104 1,104 1,104 1,104 1,104 1,104 

ROS2 1,995 2,018 2,007 2,000 1,972 1,995 1,994 1,966 

ROS3 993 993 993 993 993 993 993 993 

Total 4,092 4,115 4,104 4,097 4,069 4,092 4,091 4,064 

Employment and Income 

Projected average annual recreation and tourism-related employment and income is 

presented by alternative in Table 3.22-22. Direct employment was calculated using a 

job/RVD ratio of 0.00074, which was developed for the 1997 Forest Plan Revision 

Final EIS (see the Affected Environment subsection of this section). The direct and 

total employment rows, and the corresponding rows under income, include both 

resident and nonresident Tongass-related recreation. 

The rows that address nonresident recreation include nonresident Tongass-related 

employment, as well as an estimate for non-Tongass-related, nonresident recreation 

and tourism in Southeast Alaska. Nonresident recreational activities were assumed to 

account for 44 percent of direct employment. Direct nonresident employment also 
 Environment and Effects 3 

Final EIS 3-541 Economic and Social Environment 

Table 3.22-22 

Recreation/Tourism Related Employment and Income (First Decade, Annual Average)

 Alternative 

 2015 1 2 3 4 5 6 7 

Employment (Jobs) 

Resident and Nonresident Tongass-Related Recreation Employment 

Direct Employment1

 3,028 3,045 3,037 3,032 3,011 3,028 3,027 3,007 

Total Employment2

 3,664 3,685 3,675 3,669 3,643 3,664 3,663 3,639 

Nonresident Tongass-Related and Non-Tongass-Related Employment 

Nonresident Recreation-Related 

 Direct Employment3 4,319 4,327 4,323 4,321 4,312 4,319 4,319 4,310 

Total Nonresident Recreation- 

 Related Employment 

5,226 5,235 5,231 5,228 5,217 5,226 5,226 5,215 

Income (Million 2005) 

Resident and Nonresident Tongass-Related Recreation Income 

Direct Income4

 53.9 54.2 54.1 54.0 53.6 53.9 53.9 53.5

Total Income5 71.2 71.6 71.4 71.3 70.8 71.2 71.1 70.7

Nonresident Tongass-Related and Non-Tongass-Related Income 

Nonresident Recreation-Related 

 Direct Income 

76.9 77.0 77.0 76.9 76.8 76.9 76.9 76.7

Total Nonresident Recreation- 

 Related Income 

101.5 101.7 101.6 101.5 101.3 101.5 101.5 101.3

1 Direct employment was estimated using a job/RVD ratio of 0.00074 (average annual) and includes both resident and nonresident 

Tongass-related employment. 2 Total (direct, indirect, and induced) employment estimates were calculated using a 1.21 employment multiplier (see Table 3.22-4). 3 Nonresident recreation-related employment was calculated using the assumption that 44 percent of ROS 1, 2, and 3 RVDs are 

consumed by nonresidents. This estimate also includes non-Tongass-related recreation and tourism employment, which is assumed to 

remain constant across all of the alternatives. The non-Tongass employment was estimated based on total direct employment in the 

leisure and hospitality sector in 2005. This component was estimated to increase by 20 percent between 2005 and 2015, which is

equivalent to less than half the increase in growth of Juneau cruise ship passenger volumes between 2000 and 2005. 4 Direct income is estimated based on the 2004 statewide average annual salary for the Leisure and Hospitality sector ($17,220) adjusted 

for inflation to $17,803 in 2005 dollars and includes both resident and nonresident Tongass-related incomet. 5

 Total (direct, indirect, and induced) income estimates were calculated using a 1.32 income multiplier (see Table 3.22-4). 

includes an estimate of the jobs associated with non-Tongass recreation and tourism 

activities pursued by nonresidents. This category is intended to represent the jobs 

associated with recreation and tourism activities that do not physically take place on 

the Tongass National Forest. These types of activities include viewing scenery from 

cruise ships (see Table 3.22-22, note 3). 

The distinction between resident- and nonresident-related employment is important 

because jobs generated by nonresident expenditures on goods and services are 

considered comparable to an export industry that brings new money into the region. 

Expenditures by local residents, on the other hand, represent a recirculation of money 

that is already present in the regional economy and are, therefore, not typically 

identified as “new” money. However, if residents are substituting local recreation for 

non-local recreation then their money can be considered to be money that would 

otherwise not be present in the local economy. The extent to which this is the case 

can only be identified by surveying local residents and asking detailed questions 

about their substitution decisions with respect to Tongass-based recreation (Rudzitis 

and Johnson 2000). This type of information is not available for the Tongass and, 

more importantly, inclusion of resident recreation-related employment in the final 

summary table would have little effect on these results, which show very little 

difference across the alternatives under either scenario. 

While it is not possible to project the potential effects of the proposed alternatives on 

mining employment or income, allocating areas to non-development or development 

LUDs could affect mining activities in the future. None of the alternatives would 

allocate areas to Recommended Wilderness or LUD II. However, alternatives that 

would increase the roaded portion of the Forest, such as Alternatives 7 and 4, may 

facilitate mining exploration and development more that those that retain Roadless 

Mining 
3 Environment and Effects

Economic and Social Environment 3-542 Final EIS

areas (especially Alternatives 1, 2, and 3). Alternatives 5 and 6 would be 

intermediate, representing little or no change from allocations under the current Forest 

Plan. The effect on future mining employment and income would depend on whether 

the potentially affected locatable deposits are economically viable in the future. 

Residents of Southeast Alaska are dependent on air and water transportation for 

travel between most communities, rather than roads or rail. There are limited road 

connections between the region and the continental road system and between 

communities. Several possibilities exist for State Highways that could connect some 

Southeast Alaska communities to the continental road system, as well as possibilities 

for new internal corridors. 

The State of Alaska has proposed corridors for transmission lines and/or undersea 

cables to link many Southeast Alaska communities to British Columbia. An intertie 

corridor, connecting the Swan Lake project (near Carroll Inlet) with the Tyee project 

(on the Bradfield Canal) has been permitted and with construction initiated in 2002. A 

number of other potential interties could include powerlines between a number of 

different communities, including some of the smaller and more remote communities, 

such as Kake and Meyers Chuck. 

None of the alternatives would affect regional transportation opportunities or power 

transmission line opportunities. This is discussed in further detail in the 

Transportation and Utilities section of this document. 

There is not expected to be any significant change to the commercial fishing or fish 

processing industries over the next decade as a result of national forest activities. As 

noted in the Affected Environment discussion, much of the future of the fishing 

industry in Southeast Alaska is expected to depend on occurrences outside of the 

Tongass National Forest such as hatchery production, off-shore harvest levels and 

changes in ocean conditions. In addition, a large segment of the commercial fishing 

industry operates under a limited entry harvest system. New permit holders are not 

usually added to the market during high fish harvest years, nor are they removed 

during periods of low harvest. The result in either case is the same number of 

commercial fishers catching either more or less fish. 

The 1997 Final EIS noted that the amount of acreage of timber harvest was at most 

less than 20,000 acres per year, representing approximately 0.5 percent of the total 

remaining productive old growth (or 5 percent over the next decade) and less than 

0.02 percent of the entire Forest. That EIS concluded that this was not expected to 

result in a significant change to commercial fishing employment. Under the proposed 

alternatives, the estimated harvest would range from less than 2,000 to approximately 

16,000 acres per year (see Table 3.13-9 in the Timber section). This level of harvest, 

which is under the maximum proposed in the 1997 EIS, in conjunction with the 

Riparian Management Standards and Guidelines established in the current Forest 

Plan and included in the updated Forest Plan prepared for the action alternatives 

(Volume II in this EIS), is not expected to have a significant effect on commercial 

fisheries employment over the next 10 years. 

As discussed in the Affected Environment portion of this section, natural amenities 

and local quality of life have increasingly been recognized as important factors that 

serve to attract and retain residents. It is, however, very difficult to determine the 

effect of the different alternatives on local amenities and, further, on the economic 

activity that these amenities are believed to indirectly generate. In most cases and 

localities the impacts of the action alternatives relative to the No-Action Alternative on 

amenities are not expected to be significant enough in themselves to result in 

measurable changes in economic activity. 

This conclusion is based on the Forest Plan standards and guidelines that are 

designed to protect and/or mitigate negative effects to natural resources on the 

Tongass, as well as the relatively small proportion of the Forest that would be 

Transportation 

and Utilities 

Salmon 

Harvesting and 

Processing 

Natural Amenities 

and Quality of 

Life 
 Environment and Effects 3 

Final EIS 3-543 Economic and Social Environment 

disturbed under any of the proposed alternatives. The importance of the standards 

and guidelines are discussed with respect to quality of life and other difficult to 

quantify values below in the part of this Economic Efficiency analysis that discusses 

Ecosystem Services. Potential harvest activities under the proposed alternatives 

would affect a relatively small proportion of the Tongass and would be unlikely to 

affect the predominantly wild and undeveloped nature of the region and the role it 

presently plays in attracting visitors and residents. 

Projected annual average employment and income levels are summarized for the next 

10 years in Table 3.22-23. In terms of direct employment in the wood products and 

recreation and tourism industries, the alternatives range from 4,820 jobs under 

Alternative 1 to 6,231 jobs under Alternative 7 (Table 3.22-23). Most of the difference 

between these two values (1,411 jobs) is caused by differences in timber-related 

employment. Recreation and tourism employment shows much less variation across 

the alternatives, with a difference between high and low employment levels of less 

than 20 direct jobs. Direct earnings follow a similar pattern, as do total employment 

and earnings. 

The employment and income estimates for the wood products sector assume the 

entire NIC I volume projected for each alternative for the first decade following 

implementation would be harvested. This outcome is dependent on the scenarios 

developed for each alternative, which assume for the more timber-intensive 

alternatives that as stable volumes get higher, the industry will develop in an 

integrated fashion. Recreation and tourism employment and income estimates are for 

nonresident, recreation and tourism activity only. 

Potential direct employment effects are displayed in Table 3.22-24, which shows the 

projected change in employment by sector as a percent of current totals. Projected 

recreation and tourism employment is expected to increase by approximately 20 

percent from 2005 levels under all of the alternatives. The majority of this projected 

increase is due to the projected change in non-Tongass, recreation and tourismrelated employment, which does not vary by alternative in this analysis. Projected 

changes in wood products employment from 2005 levels range from a decrease of 

approximately 1 percent under Alternative 1 to a 285 percent increase under 

Alternative 7. These increases are relatively large because they assume that the 

entire NIC I component of the projected ASQ would be harvested under each 

alternative. This outcome is dependent on multiple factors beyond the Forest 

Service’s control, as discussed in the Wood Products, Long-Term Effects section. 

None of the alternatives are expected to affect regional transportation or power 

transmission line development opportunities. 

Summary of 

Impacts 
3 Environment and Effects

Economic and Social Environment 3-544 Final EIS

Table 3.22-23 

Projected Annual Average Employment and Income Effects by Alternative 

(First Decade, Annual Average)

Alternative 

2005 1 2 3 4 5 6 7 

Direct Employment and Income

Employment (Jobs) 

 Wood Products 499 494 919 1,108 1,496 1,346 1,343 1,922

 Recreation/Tourism 3,586 4,327 4,323 4,321 4,312 4,319 4,319 4,310

 Total 4,085 4,820 5,242 5,429 5,808 5,665 5,661 6,231

Earnings (Million 2000$) 

 Wood Products 19.5 19.5 35.3 42.3 56.7 51.1 51.0 72.5

 Recreation/Tourism 63.8 77.0 77.0 76.9 76.8 76.9 76.9 76.7

 Total 83.4 96.5 112.3 119.2 133.5 128.0 127.9 149.2

Total Employment and Income

Employment (Jobs) 

 Wood Products 983 970 1,822 2,200 2,977 2,677 2,670 3,829

 Recreation/Tourism 4,339 5,235 5,231 5,228 5,217 5,226 5,226 5,215

 Total 5,322 6,205 7,053 7,429 8,194 7,903 7,896 9,044

Earnings (Million 2000$) 

 Wood Products 27.7 27.6 50.3 60.4 81.2 73.2 73.0 103.9

 Recreation/Tourism 84.3 101.7 101.6 101.5 101.3 101.5 101.5 101.3

 Total 112.0 129.3 151.9 162.0 182.5 174.7 174.5 205.2

Notes: 

1. Recreation/tourism employment and income estimates are for nonresident, recreation and tourism-related employment only. 

Sources: Tables 3.22-20 and 3.22-22.

Table 3.22-24 

Projected Change in Direct Employment by Sector as a Percent of Current Totals

Alternative 

Sector 2004 1 2 3 4 5 6 7 

Wood Products 499 -1 84 122 200 170 169 285

Recreation/Tourism 3,586 21 21 20 20 20 20 20

Source: Table 3.22-23. 

Economic Efficiency Analysis 

The 1982 planning regulations (36 CFR 219) require that land and resource 

management plans for National Forest System (NFS) lands “provide for multiple use 

and sustained yield of goods and services from the NFS in a way that maximizes long 

term net public benefits in an environmentally sound manner” [36 CFR 219.1 (a)]. 

These regulations define the term net public benefits as “the overall long-term value to 

the nation of all outputs and positive effects (benefits) less all associated inputs and 

negative effects (costs) whether they can be quantitatively valued or not.” The 

definition continues: “(n)et public benefits are measured by both quantitative and 

qualitative criteria rather than a single measure or index” (36 CFR 219.3). 

Net public benefits are evaluated in this EIS through an economic efficiency analysis, 

which is one type of measure the Forest Service Manual (FSM) encourages the 

economic and social analyses for Forest Service resource plans to provide (FSM 

1970.61). Economic efficiency analysis seeks to measure the costs and benefits to 

society associated with each alternative and summarize them in the form of a present 

net value (PNV). PNV figures are calculated by subtracting costs from benefits to 

Introduction 

The Present Net Value of 

a given alternative is the 

discounted sum of all 

benefits minus the 

discounted sum of all 

costs associated with that 
 Environment and Effects 3 

Final EIS 3-545 Economic and Social Environment 

yield a net value. Future values (i.e., costs and benefits incurred and received in the 

future) are discounted using an appropriate discount rate to obtain a present value. 

The PNV of a given alternative is the discounted sum of all benefits minus the 

discounted sum of all costs associated with that alternative. Following Forest Service 

standard procedures, a 4 percent real discount rate is used in the following analysis. 

The 1982 planning regulations direct that analysis of the estimated effects of 

alternatives include, among other things “the expected real-dollar value (discounted 

when appropriate) of all outputs attributable to each alternative to the extent that 

monetary values can be assigned to nonmarket goods and services, using 

quantitative and qualitative criteria when monetary values may not reasonably be 

assigned” [36 CFR 219.12 (g) (3) (ii)]. Potential forest management outputs that could 

be affected by the various Forest Plan alternatives include those generated from 

commodity production, the value experienced by recreationists and other users of the 

Forest, the “non-use” values held by those who value the existence of the Forest 

resource even if they do not use it, and the value of various services (ecosystem 

services) provided by the Forest, such as water resource enhancement, that are not 

directly traded in any economic market place. 

Economists face several challenges when they attempt to summarize the values of 

various goods and services produced by Forest management. First, while economists 

generally follow a typology of values that includes both use and non-use values there 

are concerns about the tendency of many economists to use monetary values for both 

types. Most economists acknowledge that monetary measures while convenient and 

easily communicated, are weak approximations of social values. Difficulties exist in 

trying to assign values to beliefs (sometimes called held values) and other forms of 

social values. Second, since no markets exist for many ecosystem goods and 

services economists have to rely on non market valuation techniques such as 

willingness-to-pay (WTP) approaches. The mix of market and non-market values 

poses theoretical problems by mixing both marginal and average values depending on 

the processes used to establish the values. Third, any estimate of value is temporally 

specific, and this complicates summation processes and relative comparisons. 

Comments on the economic efficiency analysis presented in the Draft EIS were 

concerned with two main aspects of the analysis: 1) the absence of non-market 

values, other than recreation and tourism, and 2) the misleading comparison of actual 

timber costs and revenues with estimated recreation and tourism consumer surplus 

values, which were estimated using WTP values. These issues are briefly 

summarized below and discussed in more detail in Appendix H, Comments and 

Responses. 

Non-Market Values 

The Draft EIS provided a brief overview of comments received on the 2002 Draft SEIS 

that expressed concern that the economic efficiency analysis presented in that 

document did not assign monetary values to all the goods and services provided by 

the Tongass National Forest. Several organizations commenting on the 2006 Draft 

EIS made the same or very similar comments on the Draft EIS analysis. Concerns 

were expressed that the analysis presented in the Draft EIS did not assign monetary 

values to uses, such as commercial fishing and subsistence, or quantify potential 

effects to non-use values, ecosystem services, and quality of life or off-site benefits in 

monetary terms. Several comments argued that by failing to assign monetary values 

to non-market goods and services—such as fish and wildlife habitat, water purification 

and regulation, carbon sequestration, genetic material, long-term forest productivity, 

and quality of life—the Forest Service has essentially assigned these goods and 

services a value of zero and discounted them relative to commodity production. 

Comments on the 

Draft EIS 
3 Environment and Effects

Economic and Social Environment 3-546 Final EIS

Given the complexity of forest ecosystems and the elusive nature of many of the 

values associated with them, accurately accounting for all of these values in a single 

PNV measure is not feasible at this time. This, as explained in the Draft EIS, is by no 

means intended to imply that the Forest Service believes the other types of values 

mentioned above are unimportant. Many of the other sections in this document, in 

fact, present substantial amounts of information and analysis relative to the resources 

supporting these other values. Decision-makers will consider the economic values 

presented in this section within the context of the information presented elsewhere in 

this document, much of which cannot readily be translated into economic terms. 

Misleading Comparison 

Others providing comments on the Draft EIS expressed concern about the analysis 

summarized in Table 3.22-29 of the Draft EIS, which they believed provided a 

misleading comparison between timber and recreation and tourism. The table 

presented a PNV that consisted of projected timber revenues and costs to the Forest 

Service and recreation and tourism consumer surplus benefits that were estimated 

based on WTP estimates. Concerns were expressed about the overall validity of 

WTP methodologies and comments suggested that including consumer surplus 

estimates to value recreation and projected revenues and costs for timber resulted in 

a misleading comparison between these sectors. Others were concerned that the 

analysis was unbalanced because it did not include Forest Service costs for 

recreation, only user benefits. 

The following analysis has been revised to include estimated Tongass National Forest 

costs and revenues for the NFS budget items based on costs and revenues from 

2005 and 2006. In addition, we have separated the estimated costs and revenues 

from the recreation and tourism consumer surplus to emphasize the difference 

between these types of measures. 

The following analysis assumes that any alternative would be fully implemented in the 

first year of the planning period, and future values were discounted at four percent. 

Table 3.22-25 displays these cost and benefits followed by more detailed explanations 

of their derivation. The potential effects of the proposed alternatives on salmon 

harvesting and processing, subsistence, and non-use and ecosystem service values 

are assessed qualitatively. 

The timber benefits presented in Table 3.22-25 are the present value of expected 

Forest Service revenues from the timber sale program. Future timber sale revenues 

were estimated for the 160-year planning period using projected harvest volumes for 

each alternative. These volumes were calculated based on the estimated NIC I 

volumes by alternative. The analysis in the Draft EIS used an average rate of 

$11.69/MBF, which was the average value per MBF harvested on the Tongass in 

2005/2006. We have revised this analysis and the estimated timber benefits identified 

in Table 3.22-25 are instead based on the minimum prices or “base rates” established 

for timber species on the Tongass National Forest. The base rate is the minimum 

value that must be bid for timber to be sold or cut. 

The timber benefit estimates presented in Table 3.22-25 were calculated by 

developing an average base rate value per MBF based on the average timber sale 

composition (by species) and current base rates (see Table 3.22-25, note 1). The 

resulting estimates are, therefore, the minimum revenues or benefits that would be 

generated over the period of analysis (160 years). These estimates are also based 

on the assumption that all the NIC I volume identified under each alternative would 

sell and this may not necessarily be the case. 

Revised 

Economic 

Efficiency 

Analysis 

Timber 
 Environment and Effects 3 

Final EIS 3-547 Economic and Social Environment 

Table 3.22-25 

Economic Efficiency Analysis (million 2006$)

 Alternative 

 1 2 3 4 5 6 7 

Benefits

Revenues 

Timber Revenue1

 9 26 34 55 44 44 68 

Recreation Revenue2

 54 54 54 54 54 54 54 

Land Use Revenue3

 7 7 7 7 7 7 7 

Power3

 1 1 1 1 1 1 1 

Minerals3

 1 1 1 1 1 1 1 

Consumer Surplus 

Recreation/Tourism Consumer Surplus4

 7,637 7,640 7,643 7,610 7,645 7,645 7,599 

Costs5

Timber Variable Costs6 128 376 489 787 625 620 967 

Inventory & Monitoring7

 67 67 67 67 67 67 67 

Land Management8

 75 75 75 75 75 75 75 

Minerals and Geology7

 32 32 32 32 32 32 32 

Recreation/ Heritage/ Wilderness Mgmt7

 111 111 111 111 111 111 111 

Vegetation, Watershed, Wildlife & Fisheries 

Habitat8

 184 184 184 184 184 184 184 

Present Net Value 7,112 6,884 6,782 6,472 6,657 6,662 6,294 

Note: Cost and benefit streams extended over a 160-year analysis period and discounted at 4% per year. 1

 Based on the average base rate per MBF using the average timber sale composition and the following current base rates: Sitka 

Spruce—$12, Western Hemlock—$2, Western Red Cedar—$12, Alaskan Yellow Cedar—$20. 2

 Recreation revenue was estimated based on the average recreation revenues received in 2005 and 2006. Revenue categories 

included in this total are: Recreation, Recreation User Fees, Recreation Fee Collection, and Recreation Site Fees (USDA Forest 

Service 2006d, 2007g). These revenues are assumed for the purposes of this analysis to remain at current levels and constant 

across all alternatives. 3

 Land use, power, and minerals revenues were estimated based on average revenues received in 2005 and 2006. These 

revenues are assumed for the purposes of this analysis to remain at current levels and constant across all alternatives. 4

 Unlike timber or minerals, recreation and tourism is not directly traded in the market place and recreationists on the Tongass

generally pay for only a small portion of the total benefits they receive from the Forest. In other words, the recreation revenue 

category above does not capture the full value of the experience to recreationists. Economists have developed techniques to try 

and estimate the amount that recreationists would be willing-to-pay for a Recreation experience above and beyond what they 

actually pay. This is discussed further in the following section under recreation. It is important to understand that the 

recreation/tourism consumer surplus values shown here assign a monetary value to the share of the recreation good that is not 

traded in the market place and, as a result, are not directly comparable with actual revenues paid to the Forest Service. 5

 The following cost items include the major NFS cost items based on actual costs for 2005 and 2006 (USDA Forest Service 

2006d, 2007g). They do not include other costs that are classified under Capital Improvement, Fire, Miscellaneous Funds, or 

Other. The cost categories included in this summary were approximately $31,000 in 2005 and 2006, accounting for 

approximately 37 percent and 44 percent of total costs in 2005 and 2006, respectively. This is discussed further in the following 

section under Management Costs. 6

 Based on per MBF planning and support charges: $41 for NEPA preparation; $23 for sale preparation; $9 for sale administration;

and $28 for engineering support. 7

 Inventory & Monitoring, Minerals and Geology, and Recreation/ Heritage/ Wilderness Mgmt costs were estimated based on 

average costs in 2005 and 2006. These costs are assumed for the purposes of this analysis to remain at current levels and 

constant across all alternatives. 8

 Land Management and Vegetation, Watershed, Wildlife & Fisheries Habitat costs were estimated based on average costs in 

2005 and 2006. Cost categories included in these totals are Land Management Planning and Land Ownership Management 

(Land Management) and Vegetation & Watershed Management and Wildlife & Fisheries Habitat Mgmt (Vegetation, Watershed, 

Wildlife & Fisheries Habitat). These costs are assumed for the purposes of this analysis to remain at current levels and constant 

across all alternatives. 

The Spectrum model analysis—used to identify the ASQ for each alternative—

suggests that under current market conditions stumpage values for some stands 

would be negative (see Appendix B for more detail on this model). In other words, the 

estimated costs of harvesting and transporting the timber exceed the current value of 

the timber at the mill (the pond log value) and, as a result, volume from these stands 

would be unlikely to sell. While the Spectrum model analysis suggests that there 

would be sufficient economic timber to provide projected NIC I volumes (should there 
3 Environment and Effects

Economic and Social Environment 3-548 Final EIS

be demand) in the short-term under current market conditions, market prices would 

need to improve over the long-term for stands that would be potentially harvested in 

later decades to sell. 

Timber variable costs are also presented for each alternative in Table 3.22-25. These 

costs are estimated based on a flat rate of $101/MBF and assume the identified NIC I 

volumes for each alternative would be sold. This flat rate includes NEPA preparation 

($41/MBF), sale preparation ($23/MBF), sale administration ($9/MBF), and 

engineering support ($28/MBF), and includes timber sale-related road construction 

costs, among others. This average cost per MBF ($101/MBF) exceeds the average 

base rate value per MBF ($7.12/MBF) used to estimate timber benefits to the 

government for this analysis. As noted above, the average base rate is the minimum 

value that must be bid for a timber sale to go forward. The average value for 

2005/2006 was $11.69 per MBF. The 2003 SEIS identified an average value of 

$36.17 per MBF harvested on the Tongass from 1997 to 2001 (USDA Forest Service 

2003b). Recent sales on Alaska State lands have generated an average return of 

$49.54 per MBF for sales totaling 54 MMBF (Slenkamp 2007). 

Industry revenues and profits are omitted from the calculation. This is because 

efficiency analysis commonly assumes perfect competition in the private sector. This 

implies, in turn, that competing purchasers of federal timber will bid up the price of 

stumpage to the point where all economic profits (i.e., profits over and above a 

competitive rate of return to capital) are dissipated. 

It is important to note that the PNV calculation for timber does not assign monetary 

values to perceived local benefits associated with timber-related employment and 

salaries and related economic activity, as well as other perceived benefits associated 

with capital investment in roads and log transfer facilities. Employment and income 

are addressed in the preceding economic impact assessment. 

As previously noted, it is also important to recognize that the NIC I component is not a 

future sale level projection or target. Rather, it represents the maximum volume that 

could be harvested with normal logging systems. 

The analysis presented in Table 3.22-25 provides two sets of values for recreation 

benefits: 1) recreation revenues and costs paid to the Forest Service, and 2) 

recreation and tourism benefits to the consumer, identified in Table 3.22-25 as 

recreation and tourism consumer surplus. 

Recreation Revenues and Costs 

Recreation revenues and costs were estimated based on the average receipts paid to 

the Forest Service in 2005 and 2006. The values used for the analysis were based on 

the average values for those two years. Forest Service revenue categories included 

in this total are the general recreation category, recreation user fees, recreation fee 

collection, and recreation site fees. Recreation cost categories are shown in Table 

3.22-25 as part of the Recreation/Heritage/Wilderness budget line item. This budget 

item was about $4.3 million in 2005 and $4.6 million in 2006. In addition to these 

budget item costs, other recreation-related costs incurred in 2005 and/or 2006 and not 

included in this cost category are trail improvement and maintenance costs, 

outfitter/guide program management costs, recreation site maintenance and 

operation, and recreation fee collection costs. These costs are included elsewhere in 

the Forest Service’s accounting system (e.g., capital improvement, miscellaneous 

funds, and other) and varied substantially between 2005 and 2006, the years used to 

establish the baseline used here. 

Recreation revenues and costs are included in this analysis to address concerns 

about misleading comparisons and also provide an indication of the relative 

Recreation and 

Tourism 
 Environment and Effects 3 

Final EIS 3-549 Economic and Social Environment 

management costs and revenues associated with different Forest resources. Budget 

figures from 2006 are also summarized in Table 3.22-28. 

Recreation and Tourism Consumer Surplus 

Unlike timber, recreation and tourism is, for the most part, not directly traded in the 

market place. Recreational users of the Tongass National Forest generally pay for 

only a small proportion of the total benefits they receive from the Forest. Consumer 

surplus, or willingness-to-pay, is the value of a recreation activity beyond what must 

be paid to enjoy it. Total economic use value is the cost to participate plus consumer 

surplus. This type of approach is very different to those used to estimate the other 

benefits and costs summarized in Table 3.22-25. 

The consumer surplus estimates presented in Table 3.22-25 are derived from 1988 

survey data. For general recreational activity, this figure is estimated at $33.00 

(2005$) per RVD, and for recreational fishing the estimate is approximately $1,025.27 

per RVD (2005$). Using the proportion of 1994 total RVDs comprised by recreational 

fishing use, a weighted average of $69.13 per RVD was derived. This figure 

represents the average amount a Tongass National Forest recreational user would be 

willing to pay for a day’s recreation over and above expenses already incurred. These 

net willingness-to-pay figures are from the 1997 Forest Plan Revision Final EIS 

adjusted for inflation (USDA Forest Service 1997a, p. 3-503). 

Future recreation and tourism use on the Tongass was estimated using techniques 

described in the Affected Environment portion of this section and further detailed in 

the recreation and tourism impact analysis presented above. Projected future value 

was derived by multiplying total RVD use by the average net WTP estimate of $69.13. 

These values were then discounted using the standard 4 percent rate, and the 

resulting estimates are shown in the second row of Table 3.22-25. Recreation and 

tourism consumer surplus estimates are much higher than the other benefits and 

costs addressed in Table 3.22-25, but are relatively constant across the alternatives. 

The finding that these values are relatively constant across alternatives is consistent 

with the expected outcome of the Forest Plan, which seeks to protect high value and 

high use recreation areas under all alternatives, while the high values reflect the wide 

range of unique recreation opportunities on the Tongass National Forest. 

There is the potential for substantial error in these value estimates, and decision 

makers and the public should avoid a mistaken sense of precision when considering 

them. Various aspects of recreation and tourism-related value, for example, were 

impossible to measure or estimate for this analysis. All RVDs have been treated as 

equivalent, but it is likely that net WTP varies for different recreation experiences and 

associated ROS classes. Likewise, the net WTP value for a given recreation 

experience will vary according to a host of factors which may be impacted differently 

under the different alternatives. By using a constant dollar per RVD estimate, this 

takes only quantity into account and ignores quality. This quality can take many 

forms, but must include aesthetic considerations, personal attachments (in the case of 

local residents who habitually frequent the same “favorite places”), availability of fish 

and game, the effects of crowding, and ease of access. Moreover, these quality 

considerations will extend beyond recreational use directly occurring on the Tongass 

National Forest to include cruise ship passengers and others who have come to the 

region to mainly experience its beauty and wild character. 

The Forest Service incurs various costs in the management of the national forests. 

Some of these can be directly attributed to a specific management activity or 

objective, but many others cannot. Likewise, some costs will vary depending upon 

specific activities stipulated in the Forest Plan. Others, however, are essentially fixed 

operating costs that will likely not vary for different alternatives. 

Management 

Costs 
3 Environment and Effects

Economic and Social Environment 3-550 Final EIS

The timber variable costs presented in Table 3.22-25 are based on average costs 

(dollars per MBF) resulting from planning and administration activities in conjunction 

with recent timber sale projects on the Tongass National Forest. Costs are also 

presented for the following NFS program costs: Inventory and Monitoring; Minerals 

and Geology; Recreation, Heritage, and Wilderness Management; Land Management 

Planning and Land Ownership Management; Vegetation and Watershed 

Management; and Wildlife and Fisheries Habitat Management. The costs assigned to 

these categories are estimated based on the average 2005/2006 costs for these cost 

categories and are assumed to remain constant across all alternatives. The choice of 

alternatives would undoubtedly affect these fixed operating costs, but we are unable 

to predict how they would be affected. 

Additional costs may be imposed on organizations or individuals outside of the Forest 

Service. These costs are commonly termed “negative externalities” by economists. 

The current analysis makes no attempt to assign dollar values for the negative 

externalities that may be associated with the alternatives. Instead, the Forest Service 

addresses these by providing as much information as possible about the physical and 

ecological impacts of the alternatives, and using this information in the public 

participation process associated with the Plan. 

With the exception of Alternatives 4 and 7, the effects of the alternatives on fish 

resources are expected to be at or below the level predicted for Alternative 11 in the 

1997 Forest Plan Revision Final EIS (USDA Forest Service 1997a, pages 3-46 

through 3-73). Alternative 4 is expected to have similar effects to Alternative 6 in the 

1997 Forest Plan Final EIS. The effects of Alternative 7 are expected to be similar but 

less than those projected under Alternative 2 in the 1997 Forest Plan Final EIS. 

Effects are expected to be lower than those projected under the 1997 Alternative 2 

because Alternative 7 includes improved riparian protections. The analysis of effects 

on fish habitat included in the 1997 Forest Plan Final EIS is incorporated into this EIS 

by reference. This is also the case with the commercial fishing portion of the 

economic efficiency analysis presented in the 1997 Final EIS (page 3-504). This 

section of the 1997 Final EIS explains why PNV estimates were not prepared for the 

economic efficiency analysis presented in the Final EIS and these reasons also apply 

here. In addition, there has been a reduction in commercial harvest dependence on 

natural fish production from the Tongass in recent years. 

The absence of quantified salmon harvesting and processing benefits in Table 3.22-

25 should not be taken as an indication that this resource is not valued or that current 

and future management decisions are made without careful consideration of the 

potential impacts to these values. Potential impacts to fish are discussed in the Fish

section of this EIS. 

Estimates of mining PNV are also omitted from this analysis because it is not possible 

to quantify the potential effects of the alternatives on future mining activities. 

Subsistence activities have significant economic, as well as cultural and spiritual value 

for many Southeast Alaska residents. However, there are a number of difficulties 

involved in trying to quantify these values in monetary terms. A 2001 study that 

attempted to quantify the economic importance of Alaska’s ecosystems used three 

different standard methods to estimate the statewide net economic benefits 

associated with subsistence (Colt 2001). This study concluded: “(i)n summary, it 

remains quite difficult to measure the net economic value of subsistence in economic 

terms. Using standard techniques, one can come up with estimates that range from 

zero (using a $4.00/lb replacement value less the cost of cash and labor input) to 

more than $1.7 billion (upper bound on net willingness to accept compensation for lost 

subsistence opportunities)” (Colt 2001; 37). Assigning an accurate economic value to 

subsistence is one significant problem in trying to calculate a PNV for subsistence. A 

second major problem involves quantifying the potential effects of the alternatives in 

Salmon 

Harvesting and 

Processing 

Mining 

Subsistence 
 Environment and Effects 3 

Final EIS 3-551 Economic and Social Environment 

terms of pounds of subsistence harvest foregone. This type of information is not 

available, as discussed in the Subsistence section of this document. 

It is important to recognize that while it is not possible to assign subsistence a net 

economic value for the economic efficiency analysis, this does not mean that the 

potential effects of the alternatives on subsistence are not important. These potential 

effects are addressed programmatically in the Subsistence section of this document. 

They are also discussed on a community basis in the Subregional Overview and

Communities section. The analysis presented in the Subsistence section assesses 

the potential effects of the alternatives in terms of abundance and distribution, access, 

and competition. 

This section discusses non-use and ecosystem service values. Definitions of 

ecosystem services can be broad, including both use and non-use values. The 

following discussion uses a more narrow definition that applies to the group of 

services that is sometimes referred to as “life-support services.” This definition 

excludes non-use and quality of life values, which are discussed separately below, as 

well as recreation use. 

Non-use Values 

Economists have argued that recreation use represents only a portion of the 

economic value of natural areas. There are also non-use values associated with 

natural areas. Non-use values represent the value that individuals assign to a 

resource independent of their use of that resource. These types of values, which 

include existence, option, and bequest values, are usually measured via surveys that 

ask people how much they would be willing to pay to preserve a particular area. 

These values represent the value that individuals obtain from knowing that an area or 

resource exists, knowing that it would be available to visit in the future should they 

choose to do so, and knowing that it would be left for future generations to inherit. 

While the non-use values associated with the Tongass National Forest as a whole are 

no doubt considerable, they are extremely difficult to accurately measure, particularly 

on a per acre basis. The results from surveys in other areas do provide some insight 

to potential non-use values that might be associated with the proposed alternatives. 

The findings of a number of recent studies are summarized in Table 3.22-26. These 

studies attempt to quantify the non-use values associated with wilderness and other 

types of natural areas in Alaska and other areas. WTP values are typically calculated 

on a per household basis and then expanded to a broader population. A critical issue 

here becomes identifying the extent of the survey area. Summing these types of 

values per household across large areas generates very high values. This issue is 

evident in the different geographical extent of the areas surveyed in the studies 

summarized in Table 3.22-26. 

Examining the results of two of the studies summarized in Table 3.22-26 (Walsh et al. 

1984 and Pope and Jones 1990), Loomis (2000) noted two trends that are relevant to 

this discussion. First, WTP per household increases with an increase in the number of 

acres proposed for wilderness protection, but at a decreasing rate. Second, existence, 

option, and bequest values in both cases represented about half the total value of 

wilderness. There are no new wilderness areas proposed under any of the 

alternatives, but these findings may also apply to areas preserved in a natural 

condition. 

The results of the studies summarized in Table 3.22-26 suggest that the non-use 

values associated with maintaining areas on the Tongass in a natural condition are 

likely to be high, especially given the national importance of the Tongass. These 

values would likely increase with the number of acres, but at a lower rate. In terms of 

the proposed alternatives, the value per household is likely to be highest for 

Alternatives 1, 2, 3, 5 and 6, 4, and 7 in that order. 

Non-use Values 

and Ecosystem 

Services 

Non-use values represent 

the value that individuals 

assign to a resource 

independent of their use 

of that resource. Non-use 

values include existence, 

option, and bequest 

values. 
3 Environment and Effects

Economic and Social Environment 3-552 Final EIS

Table 3.22-26 

Summary of Willingness-to-Pay Estimates of Existence Values 

Author 

(Date) Study Location Description of Resource 

Description of 

Commodity 

Annual Willingness-toPay (2000$)1

Carson et al. 

1992 

Alaska: Prince 

William Sound 

Prince William Sound coast 

and waters 

WTP for spill prevention 

plan 

$3.13 per U.S. 

household per year 

($32.31 one-time) 

Goldsmith 

and Hill 1998 

Alaska: Bristol Bay 

Wildlife Refuges 

13.2-million-acre wildlife 

refuges made up of three 

separate refuges 

WTP for preserving 

wildlife habitat in Bristol 

Bay. 

$26.05 to $52.11 per 

household U.S. 

Walsh, et al. 

1984 

Colorado 1.2-million-acre designated 

wilderness area (2% of total 

state acreage) made up of 

13 separate areas. 

WTP to preserve existing 

wilderness areas in 

Colorado 

-- 1.2 million acres 

-- 10 million acres 

$23.07 per Colorado 

household 

$52.75 (1984$) per 

Colorado household 

Reid et al. 

1993 

British Columbia Current Wilderness in British 

Columbia. 

WTP for doubling 

wilderness in British 

Columbia 

WTP for tripling 

wilderness in British 

Columbia 

$11.80 per B.C. 

household ($118.02 onetime) 

$15.02 per B.C. 

household ($150.21 onetime) 

Pope and 

Jones 1990 

Utah Bureau of Land 

Management land (BLM) 

WTP for designation of 

BLM land in Utah million 

acres as wilderness. 

--2.7 million acres 

--16.2 million acres 

$69.50 per household 

$121.49 per household 

Loomis 20002 Western U.S 

outside Alaska 

National Forest Roadless 

areas in Western U.S. 

WTP to preserve 

roadless lands in the 

west 

$6.72 per acre 

1

 Values were adjusted to 2000 dollars using the Anchorage CPI for Alaska values and the U.S. CPI for all other areas. 2

 Estimated by Loomis using benefit-transfer approach from Walsh et al. (1984) and Pope and Jones (1990). 

Sources: Colt 2001; Loomis 2000.

The summary of recent studies presented in Table 3.22-26 is meant to provide some 

indication of the results of other studies, only. While there is a general consensus that 

non-use values of this type exist and federal policy includes approval of such 

techniques, the methodologies for measuring the size of these values are both 

controversial and difficult to apply in a consistent fashion. 

A recent study prepared by The Wilderness Society (Phillips and Silverman 2007), for 

example, used the values from the three of the studies shown in Table 3.22-25 

(Carson et al., Goldsmith and Hill, and Loomis) to estimate annual passive use values 

of “wildlands” on the Tongass and Chugach National Forests that ranged from $6.8 

million to $387.9 million. They then divided the difference to get an average annual 

passive value of $196.2 million. This analysis suggests that there is a passive use 

value associated with the Tongass National Forest, but the wide possible range 

identified for this value (with the high estimate [$387.9 million] 57 times as large as the 

low estimate [$6.8 million]) underlines the difficulty in estimating this type of value 

using a benefit transfer approach. This study is discussed in more detail in 

Appendix H. 
Environment and Effects 3 

Final EIS 3-553 Economic and Social Environment 

Ecosystem Services 

Ecosystem services are those services and benefits provided by healthy ecosystems. 

Definitions of ecosystem services can be broad, including both use and non-use 

values. A number of different definitions and groupings have been identified (Colt 

2001; Costanza et al. 1997; Krieger 2001; Morton 2000). These include the typology 

developed by the Millennium Ecosystem Assessment (2005), which is featured on the 

Forest Service’s Ecosystem Services web site 

(http://www.fs.fed.us/ecosystemservices/) and identifies four general categories of 

ecosystem services: provisioning, regulating, cultural, and supporting. This typology 

is also highlighted in Chapter 2 of this EIS. The Forest Service’s Pacific Northwest 

Research Station recently issued a technical report that attempts to define an 

economics research program to describe and evaluate ecosystem services (Kline 

2006). 

Some definitions of ecosystem services include consumptive uses—such as logging, 

fishing, and hunting—that can be considered market goods, as well as non-use or 

passive use values. The values associated with these types of market goods and 

non-use values are discussed in the preceding sections. Other types of ecosystem 

services provide what might be considered long-term life support benefits to society 

as a whole. Examples of these types of benefits that pertain to forests include 

watershed services, soil stabilization and erosion control, improved air quality, climate 

regulation and carbon sequestration, and biological diversity (Krieger 2001). 

Some economists have expressed concerns that ecosystem service values are not 

adequately considered in decision-making processes because they are not valued on a 

par with goods and services that are traded in commercial markets. A number of 

methods have been used to assign monetary values to these types of services. These 

methods include travel cost, hedonic pricing, and defensive expenditure approaches 

that use observed behavior to estimate values, as well as contingent valuation 

approaches that ask people what they would be willing to pay for an ecosystem 

service. 

Costanza et al. (1997) estimated the total value of the services provided by the 

world’s ecosystems ranges from $16 trillion to $54 trillion per year, with an average 

value of $33 trillion. Costanza et al.’s estimate involved the review and synthesis of a 

wide variety of existing studies and included estimates of recreation and cultural 

values, as well as more life-support-related services. Many of the studies used in 

their synthesis were based directly or indirectly on estimates of WTP. Colt (2001) 

applied Costanza et al.’s values to Alaska and estimated that the ecosystem values 

associated with the state’s lands and waters ranged from $1.2 billion to $1.6 billion. 

Colt’s estimate only included the components of Costanza et al.’s analysis that he 

considered to relate directly to life support services. 

Phillips and Silverman (2007) applied the global values adopted by Colt (2001) to the 

Tongass National Forest and estimated that the annual ecosystem value of 15.7 

million acres of the Tongass is $293.7 million. This analysis involved applying dollar 

per acre values for various ecosystem services, such as gas regulation, climate 

regulation, disturbance regulation, soil formation, and nutrient cycling, to five different 

forest biomes. Colt (2001, 42) notes that while the Costanza et al. estimates that form 

the basis of this analysis represent an important first step, they are “extremely 

primitive.” Colt (2001, 43-44) also noted two obvious sources of bias with his 

analysis, which also apply to Phillips and Silverman’s (2007) analysis. First, the 

average values per acre estimated by Costanza et al. and applied here are global 

averages derived from studies of population places and may have limited applicability 

to Alaska. Second, the data Colt adopted from Costanza et al., which Phillips and 

Silverman also use, does not address all “life support system” services and in this 

respect excludes categories of ecosystem services, such as wildlife habitat. 
3 Environment and Effects

Economic and Social Environment 3-554 Final EIS

The results of Phillips and Silverman’s (2007) analysis suggests there are ecosystem 

service values associated with the Tongass National Forest and these values are, as 

the resource-by-resource analyses presented in the other sections of this EIS 

suggest, undoubtedly high. These estimates are not, however, suitable for a detailed 

comparison of alternatives at the Forest level. 

The uncertainty surrounding the accuracy of these estimates is compounded by the 

difficulty involved in accurately quantifying the effects of the alternatives on physical 

and biological resources in unit values. As Kline (2006, 15) notes, even if we were to 

accept this overall estimate as a reasonable benchmark for the total existing value of 

Tongass-related ecosystem services, “total ecosystem values provide little guidance 

to policy or management decisions unless these decisions can be expressed as 

marginal or incremental changes in ecosystem services.” With respect to wetlands, 

which make up 91 percent of the annual ecosystems services value estimated by 

Phillips and Silverman, for example, the impacts are evaluated in this EIS in terms of 

potential risk based on projected road building and acres identified as suitable for 

harvest. Impacts are not quantified in terms of acres lost or acres of wetland function 

impaired. 

However, as noted earlier, the fact that no monetary value is assigned to ecosystem 

services in this document does not lessen their importance in the decision making 

process. A large proportion of this document is devoted to assessing impacts to the 

Forest resource that cannot be readily expressed in monetary terms. 

It should also be noted that ongoing initiatives in Southeast Alaska to develop 

ecosystem services markets such as the Fuels for Schools program, thinning of 

second growth for wildlife habitat improvement, and implementation of practices and 

technologies to reduce the carbon ‘footprint’ of Forest Service operations will con 

tinue under all of the alternatives. 

It is important to recognize when evaluating the potential effects of the alternatives on 

non-commodity forest values, such as non-use values, ecosystem services, and 

quality of life issues, that there are a number of options available and in place to 

protect these values and resources. Under the current Forest Plan, LUDs specify 

ways of managing an area of land and the resources it contains. LUDs may 

emphasize certain resources, such as remote recreation or old-growth wildlife habitat, 

or combinations of resources, such as providing scenic quality in combination with 

timber harvesting. Each LUD has a detailed management prescription, which 

includes standards and guidelines. 

Under the current Forest Plan, there are 19 LUDs that range from Wilderness to 

Timber Production, in terms of the level of development permitted. While each LUD 

has a different purpose and management emphasis, they may be generally grouped 

into four categories based on the kind of effects they potentially create. These four 

categories are wilderness, natural setting, moderate development, and intensive 

development. Timber management and other types of development are only allowed 

in the moderate and intensive development LUDs. Not all lands allocated to 

development LUDs are available for timber production. Under the current Forest Plan 

(Alternative 5), 3.6 million acres or 21 percent of the Forest is allocated to 

development LUDs. Approximately 687,000 acres of this area, or 4 percent of the 

Forest, suitable and scheduled for timber production (Table 3.22-27). This total 

includes both productive old growth and young-growth acreage. Under Alternative 1, 

the most restrictive alternative from a development perspective, 5 percent of the 

Forest would be allocated to development LUDs, with approximately 144,000 acres 

estimated to be suitable for timber production. 
Environment and Effects 3 

Final EIS 3-555 Economic and Social Environment 

Table 3.22-27 

Land Use Designations and Mapped Suitable Lands by Alternative (1,000s Acres) 

LUD Group/Alternative 1 2 3 4 5 6 7 

Wilderness and Natural Monument 5,916 5,916 5,916 5,916 5,916 5,916 5,916 

Mostly Natural Setting 10,019 8,928 8,054 6,130 7,252 7,400 5,808 

Moderate Development 279 577 830 1,503 1,096 1,064 1,653 

Intensive Development 560 1,353 1,974 3,225 2,510 2,394 3,396 

Total 16,774 16,774 16,774 16,774 16,774 16,774 16,774 

Percent of Forest in Development LUDs 7 12 18 28 22 21 30 

Scheduled Suitable Lands1

 

 Thousands of Acres 144 394 514 892 687 664 1,070 

 Percent of Total 1 2 3 5 4 4 6 

1

 Scheduled suitable acres appropriate for harvest occur in moderate and intensive development LUDs only. 

Under the current Forest Plan, timber management activities are governed by a large 

number of rules and regulations designed to protect or mitigate negative impacts to 

resources. These standards and guidelines, presented in Chapter 4 of the current 

Forest Plan, address the following resource areas and apply to Alternative 5, the NoAction Alternative, in this EIS: 

♦ Air ♦ Riparian 

♦ Beach and Estuary Fringe ♦ Rural Community Assistance 

♦ Facilities ♦ Scenery 

♦ Fire ♦ Soil and Water 

♦ Fish ♦ Subsistence 

♦ Forest Health ♦ Threatened, Endangered, & Sensitive Species 

♦ Heritage Resources ♦ Timber 

♦ Karst and Caves ♦ Trails 

♦ Lands ♦ Transportation 

♦ Minerals and Geology ♦ Wetlands 

♦ Recreation and Tourism ♦ Wildlife 

A number of changes to the Forest Plan text are being proposed under the action 

alternatives, based on the Forest Plan 5-Year Plan Review and Forest Service staff 

recommendations. Most changes were incorporated into the Proposed Forest Plan 

(Land and Resource Management Plan), which accompanied the Draft EIS. These 

changes were modified and updated for the Final EIS and the major changes being 

proposed are summarized in Chapter 2. The Final Proposed Forest Plan forms the 

basis for Alternatives 1, 2, 3, and 6. A summary of the major differences between the 

Final Proposed Forest Plan and the current Forest Plan are summarized below. 

Management Prescriptions

♦ Edits and clarifications were made regarding karst management programs, 

sacred site protection, minerals and geology, off-highway vehicle use, 

scenery management, and other areas for most LUD prescriptions 

♦ Substantial edits and clarifications were made to the Wilderness and 

Wilderness National Monument LUD prescriptions 

Forest-wide Standards and Guidelines

♦ Clarifications and edits were made to the standards and guidelines regarding 

steep slopes and soil stability, Class III and IV streams, karst and cave 
3 Environment and Effects

Economic and Social Environment 3-556 Final EIS

resources, minerals and geology, recreation and tourism, scenery, offhighway vehicle use, road storage and decommissioning, and other 

resources. 

♦ New sections were added to Chapter 4 on Invasive Species and Plants, and 

new standards and guidelines on sacred site protection. 

♦ Conversion of the goshawk foraging habitat and the marten habitat standards 

and guidelines in the Wildlife section to a Forest-wide legacy standard and 

guideline in the Wildlife section. 

♦ Revision of the goshawk nesting habitat standard and guideline in the Wildlife

section. 

♦ The requirement to conduct inventories to determine the presence of nesting 

goshawks for proposed goshawks that affect goshawk habitat is included in 

the Final Proposed Forest Plan. 

Alternatives 4 and 7 also follow the Final Proposed Forest Plan, with some exceptions 

including the following: 

• The Beach and Estuary Fringe buffer is changed to 500 feet along the 

beach fringe and 1,000 feet around estuaries under Alternative 7 

• Neither the goshawk foraging habitat, the marten habitat, nor the new 

Legacy Standards and Guidelines would be implemented 

• The goshawk nesting standard and guideline would not be implemented 

As a result, the levels of resource protection are expected to be lower in these areas 

under Alternatives 4 and 7. In addition, the Old-Growth Habitat LUD and its 

management prescription is not used under Alternative 7, resulting in a reduction in 

protection for old-growth habitat. 

Although data availability and specificity continue to be a challenge to refining the 

scale at which ecosystem service provision is assessed and valued, measurement, 

modeling, and valuation of ecosystem service efforts are increasing rapidly in scope, 

resolution, and ability to reflect system complexities. In addition, markets for 

ecosystem services are a topic of growing interest within the Forest Service, its 

partners and stakeholder groups. A prominent challenge to establishment of 

ecosystem service markets is the understanding of the current provision of ecosystem 

services as a baseline, against which progress (termed by economists as 

additionality) can be measured. A second challenge is to understand in a forwardlooking manner the potential direct and indirect benefits of emerging market 

opportunities related to ecosystem services. Ongoing initiatives in Southeast Alaska 

illustrate some of the potential in this regard and include the Fuels for Schools 

programs, thinning of second growth for habitat, and implementation of practice and 

technologies to reduce the carbon ‘footprint’ of Forest Service operations, among 

other examples. 

As discussed in the Affected Environment portion of this section, natural amenities 

and local quality of life have increasingly been recognized as important factors that 

serve to attract and retain residents. It is, however, very difficult to determine the 

effect of the different alternatives on local amenities and, further, on the economic 

activity that these amenities are believed to indirectly generate. In most cases and 

localities the impacts of the action alternatives relative to the no-action alternative on 

amenities are not expected to be significant enough in themselves to result in 

measurable changes in economic activity. 

Natural Amenities 

and Quality of 

Life 
Environment and Effects 3 

Final EIS 3-557 Economic and Social Environment 

Tongass National Forest Budget 

The Forest Service budget is appropriated through Congress on a yearly basis. 

National forest budget requests are considered as part of total budget requests 

submitted to the United States Congress by the executive branch each year, with 

Congress having final say. The relevant portions of the Tongass National Forest 

budget are summarized for 2007 in Table 3.22-28. In general, funding for the 

Tongass National Forest has followed a downward trend in recent years. The Fiscal 

Year (FY) 2007 budget allocation was, for example, approximately $46 million (Table 

3.22-28) compared to approximately $72 million in 2001 (see Table 3.22-26 in the 

2003 SEIS [USDA Forest Service 2003b]). This overall decline in funding means that 

an increase in overall funding would be required relative to 2007 levels to fully 

implement the Forest Plan under all of the alternatives, including Alternative 5, No 

Action. 

Variations in the level of timber harvest would affect the cost of operating the related 

programs including the following budget items, which include all the resource support, 

like wildlife biologists, necessary for timber harvesting. 

The budget items that would be affected by variations in timber harvest volumes are 

as follows: 

NFPN – Land Management Planning 

NFIM – Inventory and Monitoring 

CMRD – Roads Capital Improvements & Maintenance 

NFTM – Timber Management 

NFVW – Vegetation and Watershed Management 

The amounts required to adequately fund these budget items would vary by 

alternative based on the estimated level of timber harvest. Projected budget 

requirements would be higher for these items under Alternatives 4, 5, 6, and 7, with 

Alternative 1 requiring the lowest amount of funding for timber management related 

activities. As the preceding discussion suggests, budget shortfalls are likely in the 

future, especially for the more timber-intensive alternatives. 
3 Environment and Effects

Economic and Social Environment 3-558 Final EIS

Table 3.22-28 

Fiscal Year 2007 Budget Allocation by Resource Item 

Fund Code Budget Line Item Allocation

National Forest System 

NFPN Land Management Planning $ 1,306,700

NFIM Inventory and Monitoring 1,945,500

NFRW Recreation/Heritage/Wilderness 4,240,600

NFWF Wildlife and Fish Habitat Management 3,570,100

NFTM Timber Management 12,699,300

NFVW Vegetation and Watershed Management 2,430,400

NFMG Minerals 1,017,800

NFLM Landownership Management 1,625,700

NFLE Law Enforcement 

 Total $ 28,836,100

Wildland Fire Management 

WFPR Fire Preparedness $ 890,700

WFHF Hazardous Fuels 

WFSU Fire Operations 

 Total $ 890,700

Capital Improvement & Misc. 

CMFC Facilities Capital Improvements and Maintenance $ 2,752,600

CMRD Roads Capital Improvements and Maintenance 12,179,400

CMTL Trails, Capital Improvements and Maintenance 1,412,200

 Total 16,344,200

Total $ 46,071,000

Note: This table only summarizes those portions of the 2007 Tongass National Forest allocation that 

pertain to this analysis. 

Source: USDA Forest Service 2007h.

Payments to the State 

As noted in the Affected Environment discussion, the Secure Rural Schools legislation 

expired in 2006 with the last payments under this authorization made in December 

2006. However, payments under this legislation were extended for 2007 as part of 

the Iraq Accountability Appropriations Act of 2007, which was signed into law on May 

25, 2007 (USDA Forest Service 2007i). 

Cumulative Effects 

This section considers the incremental effects of the alternatives when added to other 

past, present, and reasonably foreseeable actions. The effects of past and present 

actions on the economic and social environment are included in the Affected 

Environment portion of this section, which discusses the regional economy, as well as 

providing a subregional overview, and assessing potential impacts at the community 

level. These sections summarize current employment levels and other key aspects of 

natural resource-based industries, and also assess recent trends. 

The effects analyses presented in the preceding sections also take into consideration 

reasonably foreseeable actions. The impact analyses that address the wood products 

industry include, for example, projected future harvest levels for other land ownerships 

in Southeast Alaska. The effects of past and present harvest actions on other land 

ownerships are also implicitly incorporated into this analysis because they influence 

projected future levels of timber harvest. The influence of other factors not directly 
 Environment and Effects 3 

Final EIS 3-559 Economic and Social Environment 

related to the Tongass, such as the major shifts in the markets served by Alaskan 

sawmills over the past decade, are also considered as part of the analysis. 

The continued growth in the number of cruise ship passengers visiting the region is 

one of the major trends in recreation in Southeast Alaska. The effects of the 

alternatives are considered in conjunction with this trend because it underpins current 

and future recreation demand on the Tongass. In addition, the recreation and tourism 

economic impact analysis includes estimated non-Tongass-related recreation 

employment, as well as the potential effects of the alternatives on the supply of 

recreation opportunities on the Tongass. 

Other reasonably foreseeable future actions include an expected growth in recreation 

and tourism businesses based on the continued growth in the cruise ship industry, as 

well as the development of additional fishing and other lodges. This type of 

development would facilitate additional recreation and tourism in the region and on the 

Forest. Human settlement expansion is expected to occur around the region’s larger 

cities, such as Juneau and Ketchikan, with residential expansion also expected as a 

result of state land auctions. These developments would likely result in increased 

demand for a range of recreation activities, with some developments favoring 

developed recreation opportunities, and others more dependent on undeveloped 

lands. 

Reasonably foreseeable actions on NFS lands include the projected levels of future 

timber harvest and development that are used in the preceding analysis to assess the 

potential impacts of the alternatives on the regional and local economies. These 

projected activities were also used to assess the potential impacts of the alternatives 

on the supply of recreation opportunities and recreation use and demand. 

Other reasonably foreseeable actions include transportation and utility developments 

proposed by the State of Alaska. These proposals are summarized in the 

Transportation and Utilities section of this document. A total of 1,523 miles of roads 

are projected to be constructed on non-NFS lands in Southeast Alaska over the life of 

the Plan (100+ years) under each of the alternatives (see Table 3.12-3 in the 

Transportation and Utilities section). Most of the projected non-NFS roads are forest 

roads that would be developed for timber harvest, but the total miles also include 

roads likely to be built to serve communities, such as the Juneau access road on the 

east side of Lynn Canal. This road, and other road corridors covered by Public Law 

109-59, would, if approved under NEPA and funded, connect additional areas in 

Southeast Alaska to the continental highway system and improve transportation 

between communities. They would also improve access for recreation use and in 

some cases would likely facilitate new types of use. 

It is not possible at this time to predict exactly which roads would be developed or 

their likely impact on future recreation patterns and associated employment. None of 

the alternatives are expected to affect this type of future road development, which 

would be expected to go forward regardless of the selected alternative. The overall 

cumulative effect of new regional road corridors viewed in conjunction with the 

proposed Forest Plan alternatives would be a trend toward more developed recreation 

opportunities that would be relatively high under Alternative 7 and relatively low under 

Alternative 1. Planned timber harvest activities on adjacent private and Native 

Corporation lands would also result in a cumulative trend toward more developed 

recreation opportunities that would be most pronounced under Alternative 7 and least 

pronounced under Alternative 1. 

Mining activities are expected to expand at existing sites, including Greens Creek on 

Admiralty Island and Berners Bay north of Juneau, with an increase in mining 

exploration and new development anticipated. Continued mining at existing sites and 

ongoing exploration efforts would likely support existing levels of mining employment 
3 Environment and Effects

Economic and Social Environment 3-560 Final EIS

and income. This employment and income would increase if there were an increase 

in exploration and development. 

Regional energy and transmission projects are also expected to occur, including the 

Swan-Tyee transmission line and the Juneau-Hoonah transmission line. These 

projects are expected to improve and expand local and regional electrical service and 

reliability. 
 Environment and Effects 3 

Final EIS 3-561 Subregional Overview and Communities 

Subregional Overview and 

Communities 

Introduction............................................................................................ 3-562 

Subregional Overview ........................................................................... 3-562 

Southeast Alaska Boroughs and Census Areas .................................. 3-562 

Alaska DOL Community Groups .......................................................... 3-568 

Communities .......................................................................................... 3-571 

Community Assessments..................................................................... 3-571 

Analyzing Impacts to Communities ...................................................... 3-574 

Potential Effects by Resource Area...................................................... 3-574 

Angoon ................................................................................................. 3-576 

Coffman Cove....................................................................................... 3-580 

Craig ..................................................................................................... 3-584 

Edna Bay .............................................................................................. 3-589 

Elfin Cove ............................................................................................. 3-594 

Gustavus............................................................................................... 3-598 

Haines................................................................................................... 3-602 

Hollis..................................................................................................... 3-607 

Hoonah ................................................................................................. 3-611 

Hydaburg .............................................................................................. 3-616 

Hyder .................................................................................................... 3-620 

Juneau and Vicinity .............................................................................. 3-624 

Kake...................................................................................................... 3-627 

Kasaan.................................................................................................. 3-632 

Ketchikan.............................................................................................. 3-636 

Klawock ................................................................................................ 3-641 

Metlakatla ............................................................................................. 3-645 

Meyers Chuck....................................................................................... 3-650 

Naukati Bay .......................................................................................... 3-653 

Pelican.................................................................................................. 3-657 

Petersburg and Kupreanof ................................................................... 3-661 

Point Baker ........................................................................................... 3-665 

Port Alexander...................................................................................... 3-670 

Port Protection...................................................................................... 3-673 

Saxman................................................................................................. 3-677 

Sitka...................................................................................................... 3-681 

Skagway ............................................................................................... 3-686 

Tenakee Springs .................................................................................. 3-690 

Thorne Bay ........................................................................................... 3-694 

Whale Pass .......................................................................................... 3-699 

Wrangell................................................................................................ 3-703 

Yakutat.................................................................................................. 3-708 

Environmental Justice .......................................................................... 3-712 
3 Environment and Effects

Subregional Overview and Communities 3-562 Final EIS

Introduction 

The preceding section of this document addressed the potential impacts of the 

proposed alternatives upon the regional economy as a whole. Potential impacts 

would not, however, be viewed similarly by all boroughs or communities in 

Southeast Alaska or distributed equally among them. It is, therefore, important to 

consider the potential effects at a more detailed geographic scale. The following 

section is divided into two parts. The first part, entitled Subregional Overview, 

addresses the economic and social composition of the boroughs and census areas 

(CAs) that comprise Southeast Alaska, as well as providing summary data at the 

community group level. This discussion provides an important perspective on the 

likely distribution of the potential effects identified in the regional economy analysis, 

as well as setting the stage for the second part of this section, which discusses the 

potential effects of the alternatives on each of Southeast Alaska’s 32 communities. 

Subregional Overview 

Addressing potential effects at the subregional level can be difficult because the 

types of data available at the state or regional level are often not available for 

smaller localities. In addition to problems arising from inadequate data, the lack of 

detailed information on the exact location of expected harvests and on the 

competitive position of individual firms makes it impossible to know which jobs or 

firms may be affected under a given alternative. Any attempt to provide numerical 

estimates of long-term impacts at the community level would be prone to error, and 

give a false sense of accuracy and certainty. As a result, the following analysis 

presents a more detailed picture of the current situation and past trends at the 

Borough/CA and community group levels, but does not attempt to quantify potential 

impacts by alternative. 

Economic developments are discussed in the following sections using data 

compiled at the borough/CA level, as well as employment data compiled by the 

Alaska Department of Labor (Alaska DOL) at the community group level. 

Community groups are sub-areas of boroughs and CAs developed by the Alaska 

DOL. Some of the community groups consist of one community; others include 

several communities (see Table 3.23-6). Information at the community group level 

provides a more detailed picture of local employment patterns than is usually 

available. 

Southeast Alaska Boroughs and Census Areas 

There are large differences in the economic structure and development of the 

boroughs and CAs (referred to as the “boroughs” in the following discussion) that 

comprise Southeast Alaska. A common problem encountered in the analysis of the 

Southeast Alaska economy is that, owing to its relative size, Juneau dominates 

statistics at the regional level. As a result, regional trends in population, 

employment, or income tend to closely represent developments in Juneau and often 

do not reflect changes in other boroughs. By analyzing certain economic statistics 

at the borough level, differences in economic structure and trends that are obscured 

at the regional level, are more apparent. The following sections discuss population, 

employment, and income trends at the borough level. 

The population of Alaska grew during the 1980s and 1990s increasing from about 

402,000 in 1980 to approximately 627,000 in 2000, an increase of 56 percent. 

Southeast Alaska’s population increased by 36 percent over the same time period. 

Increases at the borough level ranged from 8 percent for Wrangell-Petersburg to 

Population 
 Environment and Effects 3 

Final EIS 3-563 Subregional Overview and Communities 

57 percent and 61 percent for Juneau and Prince of Wales-Outer Ketchikan, 

respectively, with Juneau accounting for about 55 percent of Southeast Alaska’s 

population growth over this period. Population increases were larger in the 1980s 

than in the 1990s in all cases, and population in the Northern Complex, WrangellPetersburg, and Prince of Wales-Outer Ketchikan actually declined between 1990 

and 2000 (Table 3.23-1). 

Table 3.23-1 

Borough/Census Area Population, 1990, 2000, and 2006

1990 to 2000 2000 to 2006 

Borough/Census Area/ 

Region 1990 2000 2006 

Absolute 

Change 

Percent 

Change 

Absolute 

Change 

Percent 

Change 

Northern Boroughs 

Haines Borough 2,117 2,392 2,241 275 13 -151 -6 

Juneau Borough 26,751 30,711 30,650 3,960 15 -61 0 

Sitka Borough 8,588 8,835 8,833 247 3 -2 0 

Northern Complex1

 4,404 4,244 3,654 -160 -4 -590 -14 

Southern Boroughs 

Ketchikan Gateway Borough 13,828 14,059 13,174 242 2 -885 -6 

Prince of Wales-Outer 

Ketchikan CA 6,278 6,157 5,477 -132 -2 -680 -11 

Wrangell-Petersburg CA 7,042 6,684 6,024 -358 -5 -660 -10 

Southeast Alaska 69,009 73,082 70,053 4,073 7 -3,029 -4

Alaska 550,043 626,931 670,053 76,889 14 43,122 7 

CA=Census Area 

1

 1990 data are for the Skagway-Yakutat-Angoon Census Area. 2000 data combine the Skagway-Hoonah-Angoon Census 

Area and Yakutat Borough. Yakutat Borough was incorporated in 1992. 

Source: Alaska DOL 2001a, 2007a; U.S. Census Bureau 1995.

Alaska has continued to grow since 2000 with total population increasing by 7 

percent between 2000 and 2006. Southeast Alaska, in contrast, lost population over 

this period, with the total population decreasing by an estimated 3,029 people or 

about 4 percent. All of the boroughs have lost population since 2000, with the largest 

absolute decrease (-885 people) occurring in Ketchikan Gateway Borough. Juneau 

and Sitka experienced relatively modest decreases in population from 2000 to 2006, 

less than 0.5 percent in both cases (Table 3.23-1). 

Components of regional population change for 2000 through 2006 indicate that all of 

the boroughs in Southeast Alaska experienced natural increase (more births than 

deaths) over this period (U.S. Census Bureau 2006). All of the boroughs also 

experienced net out-migration (more people leaving than moving in) and in all cases 

the net loss of population through out-migration exceeded the net gain through 

natural increase. Juneau City and Borough experienced the largest absolute net 

out-migration over this period. 

Alaska DOL released new statewide population projections in 2007 (Alaska DOL 

2007h). These projections extend from 2010 through 2030, with low, middle, and 

high estimates available at the borough level at 5 year intervals. The general trend 

from 2006 to 2030 is for some degree of population growth for all Alaska regions, 

with the exception of Southeast Alaska. The boroughs with the greatest levels of 

annualized projected population decrease from 2006 to 2030 are both located in 

Southeast Alaska. Skagway-Hoonah-Angoon CA and Haines borough are 

projected to see annual decreases in population of 1.8 percent and 1.5 percent over 

this period, respectively (Alaska DOL 2007h). 

Population in Alaska as a whole is projected to increase between 2006 and 2030 

under all three sets of estimates, with anticipated increases ranging from 9 percent 

to 42 percent. Population estimates for Southeast Alaska anticipate a 19 percent 

decrease (low), a 7 percent decrease (middle), or a 5 percent increase (high) over 

the same time period. Population is expected to decrease in all Southeast Alaskan 
3 Environment and Effects

Subregional Overview and Communities 3-564 Final EIS

boroughs under the low set of projections, for all the boroughs except Juneau (+5 

percent) under the middle set, and all boroughs except Juneau (+19 percent), Sitka 

(+11 percent), and Yakutat (+3 percent) under the high set (Alaska DOL 2007h). 

Total full- and part-time employment is presented by borough for 1990 and 2000 in 

Table 3.23-2. These data compiled by the U.S. Department of Commerce, Bureau 

of Economic Analysis include proprietors and self-employed workers. These data 

indicate that overall employment in Southeast Alaska increased by approximately 11 

percent during the 1990s, with population increasing by 6 percent over the same 

period (Table 3.23-1). Employment increased in all boroughs with the exception of 

Ketchikan Gateway, which experienced a net loss of 529 jobs or 4.9 percent of total 

employment over this period. Total employment in Juneau increased by 4,036 jobs 

or 22 percent. Employment in Haines also saw a relatively large gain, increasing by 

31 percent or 520 jobs. 

Table 3.23-2 

Borough/Census Area Employment, 1990 and 2000

Total Employment1 Wood Products2,3 Lodging, Rest. & Rec2,3,4

2000 

1990-2000 

Change 

(%) 2000 

1990-2000 

Change 

(%) 

% Local 

Total 2000 

1990-2000 

Change 

(%) 

% 

Local 

Total

Northern Boroughs

Haines Borough 2,174 31.4 0 -100.0 0.0 214 112.4 21.6

Juneau Borough 22,046 22.4 68 NA 0.4 1,873 60.5 11.0

Sitka Borough 6,385 3.0 1 -100.0 0.0 371 2.7 5.2

Northern Complex5 3,093 4.4 183 -43.7 9.0 319 52.3 15.7

Southern Boroughs

Ketchikan Gateway Borough 10,239 -4.9 383 -73.2 9.4 698 3.6 17.1

Prince of Wales-Outer Ketchikan CA 2,951 5.3 281 -59.9 15.1 226 57.2 12.1

Wrangell-Petersburg CA 4,734 9.3 158 -64.3 6.0 161 -22.3 6.1

Southeast Alaska 51,622 10.5 1,074 -69.3 3.0 3,862 35.0 10.8 1

 These data, compiled from U.S. Department of Commerce, Bureau of Economic Analysis (BEA) data and are for full and part-time 

employment, including proprietors and self-employed. 2

 These data, compiled from Alaska DOL (NAWS) data (Alaska DOL 2006c) and the 1997 Forest Plan Revision Final EIS, do not 

include proprietors and self-employed workers. Bureau of Economic Analysis data, the source for the total employment column, is 

not available at this level of disaggregation. 3

 The percent of local total is benchmarked against total NAWS employment, which excludes proprietors and self-employed, not the 

Bureau of Economic Analysis numbers shown in the left column. 4

 Lodging, Restaurants, and Recreational and Entertainment Services. This measure does not directly reflect recreation and tourismrelated employment but is included as an indicator of trends and relative concentration of recreation and tourism-dependent jobs. 

The numbers presented here do not include proprietors or the self-employed and, therefore, are likely underestimates as proprietors 

and self-employed workers tend to comprise a large share of total employment in these sectors. 5

 Aggregate of Skagway-Hoonah-Angoon Census Area and Yakutat Borough. 

Source: Alaska DOL 2006c; U.S. Department of Commerce, Bureau of Economic Analysis 2002; USDA Forest Service 1997a (Table 

3-154).

Employment in wood products and lodging, restaurants, and recreational and 

entertainment services is also summarized by borough in Table 3.23-2. These data 

compiled by the Alaska DOL are for covered employment only. Covered 

employment data include workers covered by State or federal unemployment 

insurance laws programs. Covered employment does not include proprietors or 

self-employed workers. As a result, the numbers presented in Table 3.23-2 are 

likely underestimates. This is particularly the case with lodging, restaurants, and 

recreational and entertainment services because proprietors and self-employed 

workers tend to comprise a large share of total employment in these sectors. U.S. 

Department of Commerce, Bureau of Economic Analysis data, which include 

proprietors and self-employed workers, are not available at this level of 

disaggregation. 

Employment 
 Environment and Effects 3 

Final EIS 3-565 Subregional Overview and Communities 

Employment in the wood products sector declined in all boroughs during the 1990s, 

with the largest absolute loss (1,046 jobs) occurring in Ketchikan Gateway. Losses 

ranged from a low of 44 percent of 1990 wood products employment in Northern 

Complex to 100 percent in Sitka and Haines. The wood products sector accounted 

for 433 and 141 jobs in Sitka and Haines in 1990, respectively. These sharp 

declines in employment in part reflect the years selected for comparison. Wood 

products employment, which has followed cyclical trends over the past two decades, 

peaked in 1990 (see Figure 3.22-6 in the Economic and Social Environment

section). A comparison between 1985 and 1999, for example, would show a less 

dramatic decline. Comparing two points in time also has the effect of suggesting a 

linear trend that may not be the case. Wood products employment in WrangellPetersburg CA, for example, declined by 64 percent between 1990 and 2000, but 

actually increased by about 88 percent between 1995 and 2000. 

That said, APC and KPC ceased their Southeast Alaska operations in the 1990s 

and mill closures in Ketchikan, Sitka, and Wrangell had dramatic effects on these 

communities because they eliminated their main source of private sector year round 

employment. In addition, the seasonal but well-paid logging activities in Prince of 

Wales-Outer Ketchikan, Wrangell-Petersburg, and Skagway-Hoonah-Angoon were 

reduced over this period (Gilbertson 2004). As a result, by 2000 wood products 

accounted for a relatively small share of total employment in most boroughs. Wood 

products did, however, continue to comprise a relatively large share of employment 

in Prince of Wales-Outer Ketchikan (15.1 percent), Ketchikan Gateway (9.4 

percent), and Northern Complex (9.0 percent) (Table 3.23-2). 

In contrast to wood products employment, employment in lodging, restaurants and 

recreation-related services demonstrated strong gains between 1990 and 2000. 

The contrast between losses in wood products employment and gains in lodging, 

restaurants and recreation-related employment is consistent with overall trends 

discussed in the Economic and Social Environment section, but there is 

considerable variation across boroughs. Employment in this category in Haines, for 

example, more than doubled, with lodging, restaurants and recreation-related 

services accounting for 22 percent of total employment in 2000. The WrangellPetersburg CA, on the other hand, saw a substantial decrease (22 percent) in 

employment in this category, which represented just 6 percent of total employment 

in 2000. Certain boroughs (and, by extension, the communities that they 

encompass) have benefited more from the expansion of the tourist-related economy 

than others. 

Employment data for 2000 and 2005 are summarized in Table 3.23-3 and indicate 

that while statewide employment increased by 9.8 percent over this period, 

employment in Southeast Alaska stayed relatively constant increasing by just 0.7 

percent or 333 jobs. Employment in Juneau declined over this period, with 1,041 

fewer jobs in 2005 than in 2000. Employment stayed relatively constant in Haines (-

19 jobs) and increased in all the other boroughs, with the largest absolute increase 

occurring in Sitka (777 jobs) (Table 3.23-3). 

Covered employment data compiled by Alaska DOL for 2005 are also presented in 

Table 3.23-3 and shown graphically in Figure 3.23-1. These data are not directly 

comparable with those presented in Table 3.23-2 because of the change from the 

SIC to NAICS measurement systems employed by federal and state agencies in 

2001. Comparison of these data does, however, suggest that wood products has 

continued to decline as a share of total employment in all Southeast Alaska 

boroughs since 2000 (see Tables 3.23-2 and 3.23-3). Employment in the leisure 

and hospitality sector accounted for about 10 percent of total Southeast Alaska 

covered employment in 2005, ranging from 6.6 percent of total employment in 

Wrangell-Petersburg to 18.9 percent in Yakutat (Table 3.23-3). 
3 Environment and Effects

Subregional Overview and Communities 3-566 Final EIS

Table 3.23-3 and Figure 3.23-1 highlight the distinction between northern and 

southern boroughs. With the exception of Skagway-Hoonah-Angoon, there was no 

wood products employment in the northern boroughs in 2005. Nearly all of the 

covered forestry and logging and wood products manufacturing employment in 

Southeast Alaska (96 percent) is concentrated in the southern boroughs. Leisure 

and hospitality employment, by contrast, generally shows higher concentrations in 

the north, with northern boroughs accounting for 70 percent of total regional 

employment in this category. 

Table 3.23-3 

Borough/Census Area Employment, 2000 and 2005

2005 Employment by Sector 

Total Employment1 Forestry and 

Logging2,3 Wood Products2,3

Leisure and 

Hospitality2,3,4

2005 

Employment 

2000-2005 

Change 

(%) 

Employment Percent 

of Total 

Employment Percent 

of Total 

Employment Percent 

of Total 

Northern Boroughs 

Haines Borough 2,469 -0.9 0 0.0 0 0.0 168 16.0 

Juneau Borough 20,536 -5.2 0 0.0 0 0.0 1,545 8.8 

Sitka Borough 6,928 11.8 0 0.0 0 0.0 503 11.4 

Skagway-HoonahAngoon CA 2,552 1.0 13 0.8 7 0.4 241 15.4 

Yakutat Borough 712 22.5 0 0.0 0 0.0 63 18.9 

Southern Boroughs 

Ketchikan Gateway 

Borough 

10,370 1.8 95 1.4 55 0.8 741 10.7 

Prince of WalesOuter Ketchikan CA 2,984 4.5 161 7.9 43 2.1 155 7.6 

WrangellPetersburg CA 4,637 2.8 82 3.2 0 0 170 6.6 

Southeast Alaska 51,188 0.7 351 1.0 105 0.3 3,586 9.8 

Alaska 437,010 9.8 486 0.2 364 0.1 31,000 10.1 1

 These data, compiled from U.S. Department of Commerce, Bureau of Economic Analysis (BEA) data and are for full and parttime employment, including proprietors and self-employed. 2

 These data, compiled from Alaska DOL (NAWS) data (Alaska DOL 2006b), do not include proprietors and self-employed 

workers. Bureau of Economic Analysis data, the source for the total employment column, is not available at this level of 

disaggregation. 3

 The percent of local total is benchmarked against total NAWS employment, which excludes proprietors and self-employed, not 

the Bureau of Economic Analysis numbers shown in the left column. 4

 Leisure and hospitality does not directly reflect recreation and tourism-related employment but is included as an indicator of the 

relative concentration of recreation and tourism-dependent jobs. This sector includes the Arts, Entertainment, and Recreation 

and Accommodation and Food Services sectors. The numbers presented here do not include proprietors and self-employed 

and, therefore, are likely underestimates as proprietors and self-employed workers tend to comprise a large share of total 

employment in these sectors. 

Source: Alaska DOL 2006b; U.S. Department of Commerce, Bureau of Economic Analysis 2006b

Average real per capita income in Southeast Alaska (expressed in constant 2005 

dollars) increased by 4 percent between 1996 and 2005. The change from 1996 to 

2005 varied by borough, ranging from a decrease of 1 percent in Juneau to 

relatively large increases in the smaller northern boroughs (Haines [16 percent], 

Skagway-Hoonah-Angoon [20 percent], Yakutat [18 percent]). Average real per 

capita income increased in Alaska (11 percent) and nationwide (15 percent) over 

this period 

The absolute level of per capita income is considerably lower for Prince of WalesOuter Ketchikan, indicating that in 2005, on average, residents at this area received 

36 percent less income than the regional average. Per capita incomes are above 

the regional average in Ketchikan (111 percent), Haines (110 percent), and Juneau 

(106 percent) (Table 3.23-4). 

Income 
 Environment and Effects 3 

Final EIS 3-567 Subregional Overview and Communities 

Figure 3.23-1 

Wood Products and Lodging, Restaurant, and Recreation Services Share 

of Total Employment by Borough, 2005 (Percent) 

0

2

4

6

8

10

12

14

16

18

20

Haines Juneau Sitka SkagwayHoonahAngoonYakutat Ketchikan

Gateway

Borough

Prince of

Wales-Outer

Ketchikan

WrangellPetersburgSoutheast

Total

Percent of Total Employment

Timber Leisure & Hospitality

Northern Boroughs

Southern Boroughs

Notes: 

NAWS=Non-agricultural wage and salary employment. Excludes proprietors and self-employed. 

See notes to Table 3.23-3. 

1. Timber includes both forestry and logging and wood products manufacturing employment. 

Source: Alaska DOL 2006b (see Table 3.23-3) 

Table 3.23-4 

Per Capita Income, 1996 to 2005

1996 to 2005 

1996 2005

Absolute 

Change 

Percent 

Change 

Share of 

Regional 

Average 

(2005)

Northern Boroughs 

Haines Borough 34,725 40,185 5,460 16% 110% 

Juneau Borough 39,122 38,702 -420 -1% 106% 

Sitka Borough 31,124 33,115 1,991 6% 91% 

Skagway-Hoonah-Angoon CA 28,459 34,265 5,806 20% 94% 

Yakutat Borough 28,467 33,716 5,249 18% 93% 

Southern Boroughs 

Ketchikan Gateway Borough 38,678 40,291 1,613 4% 111% 

Prince of Wales-OK CA 22,053 23,305 1,252 6% 64% 

Wrangell-Petersburg CA 29,269 33,446 4,177 14% 92% 

Southeast Alaska 34,848 36,411 1,563 4% 100%

Alaska 31,998 35,564 3,566 11% 98% 

USA 29,977 34,471 4,494 15% 95%

Note: 

1. Per capita income figures for 1996 are adjusted for inflation and presented here in 2005 dollars. 

Source: U.S. Department of Commerce, Bureau of Economic Analysis 2007a. 
3 Environment and Effects

Subregional Overview and Communities 3-568 Final EIS

Dividends, interest, and rent decreased as a share of total income from 1996 to 

2005 in Alaska, the U.S as a whole, and all Southeast Alaska boroughs 

(Table 3.23-5). Transfer payments increased as a relative share of employment 

over the same period in all Southeast Alaska boroughs, as well as in Alaska as a 

whole and nationwide. Increases in Southeast Alaska ranged from 1.4 percent in 

Sitka to 6.8 percent in Yakutat Borough. 

Table 3.23-5 

Components of Personal Income, 1996 to 2005 (percent of total)

Earnings 

Dividends, Interest, 

and Rent Transfer Payments 

2005 

1996-2005 

Change 2005 

1996-2005 

Change 2005 

1996-2005 

Change 

Northern Boroughs 

Haines Borough 64.6 2.4 18.0 -4.6 17.5 2.2

Juneau Borough 72.0 2.5 16.3 -4.3 11.7 1.8

Sitka Borough 67.7 4.8 17.9 -6.2 14.5 1.4

Skagway-Hoonah-Angoon CA 64.9 -0.3 16.0 -3.6 19.2 3.9

Yakutat Borough 61.8 -2.4 16.3 -4.4 21.9 6.8

Southern Boroughs 

Ketchikan Gateway Borough 69.3 -1.3 15.6 -1.6 15.0 2.9

Prince of Wales-OK CA 64.0 -3.9 13.1 -2.0 22.9 5.9

Wrangell-Petersburg CA 64.9 1.8 15.8 -4.2 19.3 2.4

Southeast Alaska 69.3 1.3 16.2 -3.7 14.5 2.4

Alaska 72.1 2.7 13.4 -4.0 14.5 1.3

USA 69.5 2.4 15.6 -3.2 14.9 0.7

Notes: 

1. Earnings includes wages and salaries, other labor income, and proprietors’ income. 

2. Transfer payments consist mainly of government payments to individuals, including retirement, disability, and 

unemployment insurance benefit payments, income maintenance payments, and veterans benefit payments. 

Government payments to individuals in Alaska include Alaska Permanent Fund benefits, which are derived from oil 

revenues and paid to every resident. 

3. Percent of total income. 

Source: U.S. Department of Commerce, Bureau of Economic Analysis 2007a. 

Earnings as a share of personal income increased from 1995 to 2004 in Southeast 

Alaska (0.5 percent), Alaska (1.7 percent), and the U.S as a whole (2.3 percent) 

(Table 3.23-5). Earnings decreased as a share of total income in all the southern 

boroughs, with the largest decrease (-7.7 percent) occurring in Prince of WalesOuter Ketchikan, as well as Skagway-Hoonah-Angoon and Yakutat. Earnings 

increased as a share of total income in Haines, Juneau, and Sitka. 

Alaska DOL Community Groups 

In this portion of the document, the employment data provided by Alaska DOL is 

analyzed using the community groups defined by that agency—the most detailed 

level available for this data. At this level of disaggregation there is a much greater 

potential for substantial errors in the data. Changes in reporting jurisdictions or 

industry definitions, for example, may result in large and abrupt changes in reported 

employment for a given community or industry with no underlying change in actual 

employment patterns. It is also important to remember that Alaska DOL community 

groups are not necessarily synonymous with actual communities. The individual 

communities included in each community group are identified in Table 3.23-6. The 

following discussion focuses on the wood products and recreation and tourism 

industries. Data are presented for 1990 and 1999, which is the most recent year 

that data are available in this format. 
 Environment and Effects 3 

Final EIS 3-569 Subregional Overview and Communities 

Table 3.23-6 

Alaska DOL Community Groups Defined

Boroughs and 

Census Areas 

Community 

Groups Communities/Places 

City & Borough of

Juneau 

Juneau Auke Bay, Berners Bay, Douglas, Dupont, Fritz Cove, Hawk Inlet, Juneau, Lemon 

Creek, Lena Cove, Lynn Canal, Mendenhall Valley, North Douglas, Salmon Creek, 

Snettisham, Switzer Creek, Taku Harbor, Taku Lodge, Tee Harbor, Thane, and 

West Juneau. 

Ketchikan Carlanna, Charcoal Point, Clover Pass, Herring Cove, Ketchikan, Mountain Point, 

Mud Bay, North Tongass Highway, Peninsula Point, Pennock Island, Point Higgins, 

Refuge Cove, Saxman, Shoreline Drive, Thomas Basin, Totem Bight, Upper 

Nickeyville, Wacker, and Ward Cove. 

Ketchikan 

Gateway 

Borough 

Revillagigedo Fire Cove, Gedney Pass, George Inlet, Gravina Island, Guard Island, Hassler Pass, 

Loring, Neets Bay, Princess Bay, Shoal Cove, and Twin Peaks. 

Haines Borough Haines Eldred Rock, Excursion Inlet, Haines, Letnikof Cove, Moose Valley, Mosquito Lake, 

Pleasant Camp, Porcupine, Port Chilkoot, and Saint James Bay. 

Baranof Baranof, Big Port Walker, Chatham, Corner Bay, False Island, Lake Eva, Little Port 

Walter, Port Armstrong, Port Conclusion, Rodman Bay, Saook Bay, Todd, and 

Warm Spring Bay. 

Sitka Borough 

Sitka Biorka Island, Chichagof, Cobol, Deep Bay, Goddard, Halibut Point, Jamestown 

Bay, Japonski Island (Mt. Edgecumbe), Katlian Bay, Klag Bay, Nakwasina Cove, 

Redfish Cape, Saint John Baptist Bay, Schulze Cove, Sitka, and Sitka Logging 

Camp. 

Yakutat Borough Yakutat Situk and Yakutat

Chatham Strait Angoon, Catherine Island, Cube Cove, Hanus Bay, Tenakee Springs, Tyee, and 

Whitewater Bay. 

Gustavus Bartlett Cove, Cape Spencer, and Gustavus (Strawberry Point). 

North 

Chichagof 

Elfin Cove, Gull Cove, Hoonah, Idaho Inlet, Lisianski, Pelican, Port Althorp, Port 

Frederick, and Yakobi Island. 

Stephens 

Passage 

Cape Fanshaw, Five Fingers, Freshwater, Bay, Funter Bay, Hobart Bay, Point Retreat, 

Port Houghton, Sawyers Landing, Sumdum, and Windham Bay. 

Angoon-HoonahSkagway Census 

Area 

Skagway Clifton, and Skagway. 

Central Prince 

of Wales 

Craig, Hollis, and Klawock. 

Southeast 

Prince of 

Wales 

Bokan Mountain, Campbell, Dall Island, Dora Bay, Kendrick Bay, Klakas Inlet, Rose 

Inlet, Twelvemile Arm, View Cove and Waterfall. 

Hydaburg Hydaburg 

North Prince of 

Wales 

Cape Pole, Coal Bay, Coffman Cove, Edna Bay, El Capitan, Kasaan, Labouchere 

Bay, Little Naukati Bay, Naukati Bay, Noyes Island, Point Baker, Port Alice, Port 

Protection, Ratz Harbor, Red Bay, Salt Chuck, Shakan, Steamboat Bay, Thorne 

Bay, Thorne Island, Tokeen, Warren Cove, and Whale Pass. 

Metlakatla Annette, Mary Island, and Metlakatla. 

Hyder Hidden Inlet, Hyder, Smeaton Bay, Tongass, and Tree Point 

Prince of WalesOuter Ketchikan 

Cleveland Pen. Bell Island, Meyers Chuck, Union Bay and Yes Bay. 

Kake Kake. 

Kuiu Island Alvin Bay, Cape Decision, Coronation Island, Duncan Canal, Fairway Island, 

Hamilton Bay, Kah Sheets Bay, Port Alexander, Rowan Bay, Saginaw Bay, 

Security Bay, Tebenkof Bay, and Washington Bay. 

Petersburg Kupreanof, Mitkof Island, Petersburg, Scow Bay, and Vank Island. 

Thomas Bay Thomas Bay. 

Wrangell City Wrangell. 

Wrangell 

Petersburg 

Census Area 

Wrangell IslandBradfield River, Burnette Inlet, Deer Island, Ernest Sound, Etolin Island, Kakwan 

Point, Roosevelt Harbor, Saint John Harbor, Tyler Logging Camp, and Zarembo 

Island. 

Notes: 

1. Some of these community groups have been renamed to more clearly represent the communities/places included. 

2. The listing of communities/places included in each community group identifies named places in these areas. Some of 

these places are presently uninhabited. 

3. Communities identified in bold are discussed in the Communities section of this document. 

Source: USDA Forest Service 1997a (Table 3-155). 
3 Environment and Effects

Subregional Overview and Communities 3-570 Final EIS

The following tables and figures provide some insight into which areas are more 

likely to be affected by the alternatives, as well as those that are likely to have been 

affected by changes in the economy since 1990. 

Employment information, presented by community group in Table 3.23-7, shows an 

extremely high variation in the rate of job creation (or loss) experienced by the 

different community groups. The highest positive or negative changes are, not 

surprisingly, concentrated in those groups with the smallest total employment 

numbers. This highlights an important aspect of community level impacts—the most 

severe impacts (relative to total local employment) are often experienced in smaller 

communities, where even small job losses may be large relative to total 

employment. 

Smaller communities also often exhibit higher concentrations of employment in a 

single industry, such as logging camps or resorts and fishing lodges. 

Table 3.23-7 

Employment by Community Group, 1990 to 1999 

Wage & Salary1 Wood Products2 Lodging, Rest., & Rec.3

Community Group

1999 

Jobs 

1990-1999 

Change (%)

1999 

Jobs 

1990-1999 

Change (%)

% of Local 

Total 

1999 

Jobs 

1990-1999 

Change (%)

% of Local 

Total 

 Borough 

Haines 865 - 3 0 - 100 0 192 + 90 22

City and Borough of Juneau 

Juneau 16,284 15 55 -- 0 1,783 52 11

Ketchikan Gateway Borough 

Ketchikan City 7,014 - 10 404 - 72 6 682 1 10

Revillagigedo 31 -- 0 -- 0 0 -- 0

Subtotal 7,045 - 11 404 - 72 6 682 1 10

Northern Complex 

Chatham Strait 223 - 33 40 - 55 18 22 17 10

Gustavus Island 189 53 0 -- 0 75 27 40

North Chichagof 411 - 31 99 - 29 24 33 11 8

Skagway 578 14 0 -- 0 147 101 25

Stephens Passage 14 - 96 0 - 100 0 0 -- 0

Yakutat 381 92 13 - 65 3 74 164 19

Subtotal 1,795 - 16 152 - 53 8 352 68 20

Prince of Wales/Outer Ketchikan 

Central Prince of Wales 1,051 8 116 - 63 11 140 -- 13

Cleveland Peninsula 195 786 180 -- 92 14 - 37 7

Hydaburg 75 - 3 1 -- 1 0 -- 0

Hyder 54 73 0 -- 0 4 - 61 7

Metlakatla 472 - 20 40 - 65 9 0 - 100 0

North Prince of Wales 361 - 29 83 - 69 23 28 368 8

Southeast Prince of Wales 50 528 0 -- 0 42 -- 84

Subtotal 2,258 2 420 - 40 19 228 406 10

Sitka Borough 

Baranof 13 - 75 1 - 98 8 0 -- 0

Sitka 4,000 - 1 0 - 100 0 415 15 10

Subtotal 4,014 - 2 1 - 100 0 415 15 10

Wrangell-Petersburg Census Area 

Kake 257 - 10 53 - 57 21 0 -- 0

Kuiu Island 13 - 85 0 - 100 0 0 -- 0

Petersburg 1,395 0 5 - 93 0 109 - 16 8

Wrangell City 823 - 7 70 - 57 9 70 - 9 9

Subtotal 2,488 - 6 128 - 70 5 179 - 14 7

Southeast Alaska Total 34,748 2 1,160 - 67 3 3,830 38 11 1

 Full and part-time average annual employment. Self-employed people and proprietors are not included in this data-set. 2

 Wood products includes both mill and logging employment. 3

 Lodging, Restaurants and Recreational and Entertainment Services. This measure does not directly reflect recreation and tourism-related 

employment, but is included as an indicator of trends and relative concentration of recreation and tourism-dependent employment. 

Source: Alaska DOL 2002. 
 Environment and Effects 3 

Final EIS 3-571 Subregional Overview and Communities 

Communities 

Community is a concept with multiple dimensions and definitions. Basic definitions 

of community include: 1) a geographic/political entity, such as a town or village; 2) a 

network of people with shared values, world views, or identities (sometimes called a 

community of meaning), such as an ethnic or racial group (e.g., Native Alaskans) or 

an occupational group (e.g., loggers); 3) a working social system; 4) a rural social 

landscape, which would include the first three definitions in a rural setting; 5) a 

community of interest, or people with a common stake, profession, interest, activity, 

or set of values, who may live far apart (e.g., anglers, environmentalists, off-roadvehicle operators). 

This section uses the geographic/political community—towns and villages—as its 

basis for several reasons. There are relatively few communities in Southeast 

Alaska, they are typically isolated geographically, most are recognized as being 

unique, and data are more commonly available at this level (although some local 

economic data is compiled by the State for groups of communities). Geographic/ 

political communities represent an aggregate of individuals and it is important to 

remember that residents within the same community may be affected differently by 

the same action. Potential effects that do not appear that significant when viewed at 

a community level may be very significant for the individuals that are directly 

affected. 

Community Assessments 

The 1997 Forest Plan EIS included discussions of 32 Southeast Alaska 

communities with a state land selection base. These discussions provided brief 

descriptions of each community, including aspects of their histories, population 

trends, economic bases, and the subsistence resources used by each community. 

Each community discussion also included a summary of the public comments and 

testimony received by the Forest Service on the 1990 Draft EIS, 1991 SDEIS, and 

the 1996 Revised Supplement. Much of the baseline community information 

provided in those discussions was taken from the Alaska Department of Community 

and Regional Affairs (Alaska DCRA) Community Profiles (1996) and 1990 U.S. 

Census data. Subsistence information was mainly based on the findings of the 

1989 Tongass Resource Use Cooperative Survey (TRUCS). Updated summary 

data are presented by community in Table 3.23-8. These data suggest that these 

communities are diverse in terms of population, income, and subsistence use. 

There is also a good deal of variation within many of the communities, as reflected 

by the range of public comments received during preparation of the 1997 Forest 

Plan EIS and the 2003 SEIS (USDA Forest Service 1997a; 2003b). 

This document provides brief updates of the affected environment sections of the 

community discussions, where applicable. The reader is referred to the 1997 

Tongass Forest Plan EIS for more detailed information on community history, 

economic base, and subsistence resources. The 1987 TRUCS data used in the 

1997 Forest Plan EIS discussions is still the most current consistent source of 

subsistence information available. Updated information from the ADF&G, 

Subsistence Community Profile Database is provided in the following discussions, 

where available. 

Data from the 2000 Census has been incorporated in the community discussions, 

as appropriate. This includes estimates of the number of people who work in 

differrent industries. These estimates are generally extrapolated from a sample of 

each community’s population with the sample size varying by community. In cases 

where the community is small, the extrapolation may not be exact but should in most 

cases provide a general indication of distribution of employment. Employment data 
3 Environment and Effects

Subregional Overview and Communities 3-572 Final EIS

are available by community group for 1990, 1995, and 1999 in the planning record 

for this EIS. 

The effects of the alternatives considered in the 1997 Forest Plan EIS were 

evaluated in terms of community use area effects. Community use areas depict the 

approximate extent of each community’s day-to-day use area. Potential community 

effects were also estimated with the help of a Socioeconomic Panel and 

Subsistence Workshop, which were convened to assess the potential effects of the 

planning alternatives for the 1997 Forest Plan EIS. The Socioeconomic Panel 

assessed these potential effects in terms of timber employment, tourism/recreation 

employment, mining employment, economic structure/diversity, community stability, 

quality of life, recreation opportunities, and access to traditional lifestyles. The 

Subsistence Workshop involved a group of subsistence specialists who met to offer 

professional judgement regarding the potential effects of planning alternatives on 30 

selected subsistence communities (Juneau and Ketchikan do not meet the federal 

definition of subsistence community). In addition, the Sitka black-tailed deer habitat 

capability model output was analyzed for the Wildlife Analysis Areas (WAAs) where 

each community obtained approximately 75 percent of their average annual deer 

harvest. This analysis is discussed further in the 1997 Forest Plan EIS. An updated 

deer habitat capability model-based analysis is used here and is presented in the 

Wildlife section. 

The analysis presented here draws upon these information sources to assess the 

effects of the seven alternatives under consideration by community. Each 

community discussion includes a map of that community’s use area, as defined by 

the 1997 Forest Plan EIS. These maps are accompanied by tables that provide 

summary information on the LUDs and suitable acres in each community use area 

by alternative. The community use area maps and tables are intended to help 

community residents (and other readers) gain a better understanding of what 

management direction is proposed for their immediate surroundings under each 

alternative. 

The summary tables for each alternative compare the acres allocated to types of LUD 

group by alternative. Variations in the amount of National Forest System land allocated 

to the different LUD groups under each alternative show what land use opportunities 

would be available during the next 10 to 15 years within each community use area. The 

variations in how many suitable acres are programmed for timber management under 

each alternative provide additional information indicating how much of the local forest 

environment (that is allocated to LUDs in the Moderate and Intensive Development LUD 

groups) could potentially be harvested over rotation-length time frames. The tables also 

present summary information on total suitable acres by alternative, which indicate how 

much of the community use area’s forest land remains available for possible future 

harvesting. Whether any timber harvesting would actually take place on the suitable 

lands within the community use area over the next decade would depend on the timber 

sales that are actually carried out during plan implementation. All proposed timber 

sales would be evaluated on a project-specific basis in accordance with NEPA. 
 Environment and Effects 3 

Final EIS 3-573 Subregional Overview and Communities 

Table 3.23-8 

Southeast Alaska Community Statistics

Population 

2006 

Percent 

Change 

2000 to 

2006 

Percent 

Native in 

2000 

2000 

Median 

Household 

Income

Percent of 

Households 

Below 

Poverty Line 

in 2000

Percent of 

Labor Force 

Unemployed 

in 2000

Subsistence 

Use (Ibs per 

capita)1

Angoon 482 -16 82 29,861 27 13 349 

Coffman Cove 162 -19 3 43,750 7 10 276 

Craig 1,105 -21 22 45,298 8 9 232 

Edna Bay 41 -16 0 44,583 15 0 373 

Elfin Cove 25 -22 0 33,750 0 23 263 

Gustavus 441 3 44 34,766 10 14 241 

Haines 1,492 -18 15 39,926 6 14 196 

Hollis 156 12 5 43,750 6 3 169 

Hoonah 829 -4 61 39,028 14 21 518 

Hydaburg 352 -8 85 31,625 21 31 384 

Hyder 92 -5 0 11,719 44 47 345 

Juneau 30,650 0 11 62,034 4 5 NA 

Kake 536 -25 67 39,643 13 25 179 

Kasaan 59 51 38 43,500 0 20 452 

Ketchikan 7,662 -3 18 45,802 5 8 NA 

Klawock 776 -9 51 35,000 14 16 320 

Metlakatla 1,377 -5 82 43,516 8 21 70 

Meyers Chuck 11 -48 0 64,375 0 0 414 

Naukati Bay 129 -4 10 NA NA NA 241 

Pelican 106 -35 21 48,750 0 0 355 

Petersburg 3,129 -3 7 49,028 3 3 198 

Point Baker 16 -54 3 28,000 0 0 289 

Port Alexander 64 -21 5 31,563 25 25 312 

Port Protection 59 -6 0 10,938 44 44 451 

Saxman 422 -2 66 44,375 7 7 94 

Sitka 8,833 0 19 51,901 4 4 205 

Skagway 854 -1 3 49,375 1 1 48 

Tenakee Springs 109 5 3 33,125 9 9 330 

Thorne Bay 482 -13 3 45,625 6 6 118 

Whale Pass 61 5 2 62,083 0 0 185 

Wrangell 1,911 -17 16 43,250 7 7 132 

Yakutat 609 -10 47 47,054 12 12 385 

Notes: 

NA = not available 

1

 The year these data were collected varies by community, as follows: 

1987: Elfin Cove, Gustavus, Hyder, Metlakatla, Meyers Chuck, Pelican, Petersburg, Port Alexander, Saxman, Skagway, Tenakee 

Springs, and Wrangell; 

1996: Angoon, Haines, Hoonah, Kake, Point Baker, Port Protection, Sitka, and Whitestone Logging Camp. 

1997: Craig, Hydaburg, and Klawock 

1998: Coffman Cove, Edna Bay, Hollis, Kasaan, Naukati Bay, Thorne Bay, and Whale Pass. 

2000: Yakutat 

Source: USDA Forest Service 2003b (Table 3.4-35); ADF&G 2006; Alaska DOL 2007a 
3 Environment and Effects

Subregional Overview and Communities 3-574 Final EIS

Analyzing Impacts to Communities 

Small, rural communities are seldom self-contained economic units. Although it is 

possible to describe a community’s economic structure, complex social and economic 

forces, many of which are outside the control of community residents, have great 

influence on community economics. This makes it difficult to precisely predict the 

effects of forest-wide management alternatives on individual communities. Forest 

Service activities provide economic opportunities to the private sector. How that sector 

and the various industries that comprise it respond depends on many variables in 

addition to Forest Service management. 

Forest plans are programmatic, meaning that they establish direction and allowable 

activities for broad land areas, rather than schedule specific activities on specific 

patches of land. This also makes it difficult to predict effects on individual communities. 

This is a common source of frustration to local residents, who want to know exactly how 

they and the places they care about could be affected. While many outputs of forest 

management, such as scheduled timber harvest, generally translate into social and 

economic activity, such as employment in the timber industry, it is difficult to predict 

which communities would benefit the most from that activity. Communities may even 

compete with each other in many instances. Communities that rely on a given 

resource-related industry would, however, be expected to be the first to benefit or lose 

from significant changes in planned output levels affecting that industry. 

Another factor affecting the accuracy of predicting specific impacts at the community 

scale is that people and businesses have proven themselves highly adaptable. 

Researchers have used the term community resiliency (Harris 1996) or community 

capacity (FEMAT 1993) to describe a community’s ability to weather significant 

changes. Some of the factors judged important for small, rural communities in the 

Pacific Northwest include community infrastructure, the presence of amenities, social 

cohesion and effective community leadership, and economic diversity. Some 

communities will be more effective than others in coping with changes that do result. 

While information such as population size can be used as a rough proxy for resiliency 

(generally, larger communities tend to be more resilient than smaller ones), this is not 

always the case. However, analyses have not been conducted regarding the resiliency 

of Southeast Alaska communities, and we do not know how well information gained 

elsewhere applies to understanding Southeast communities. It is also worth noting that 

while a community as a whole may be resilient to change, individuals within that 

community will still be negatively affected. 

Given these considerations, it is more accurate to identify areas of concern for which 

the risks of effects from a given alternative are higher or lower, rather than say, “Here is 

what we know will happen to each and every community.” One of the hazards 

associated with such attempts to assess impacts is that analyses tend to view social 

and economic conditions as static, failing to consider that economies are dynamic, and 

adjust to different impacts in different ways. 

Potential Effects by Resource Area 

The alternatives have implications for specific places on the Forest and particular parts 

of the community use areas of various communities. They also have potential 

implications in terms of employment in resource dependent industries and the 

availability of subsistence resources. The following paragraphs discuss the potential 

implications for wood products, recreation and tourism, and subsistence in general 

terms to provide some background to the reasoning employed in the community effects 

discussions presented in the following sections. 
 Environment and Effects 3 

Final EIS 3-575 Subregional Overview and Communities 

Based on the analysis presented in the preceding section, projected direct wood 

products employment would be higher than current (2005) levels (499 jobs) under all of 

the alternatives, except Alternative 1 (Table 3.22-20). These projections assume in all 

cases that the timber supply would be stable and that the entire NIC I component of the 

projected ASQ would be harvested under each alternative. These projected increases 

range from 1.8 times the 2005 harvest level under Alternative 2 to 3.9 times under 

Alternative 7. 

As noted in the preceding section, while forest management activities can generally 

translate into social and economic activity, it is difficult to predict where this activity will 

actually occur. It is, however, reasonable to assume that increased harvest levels 

would likely benefit those communities that have historically been dependent on the 

wood products industry, including the communities where the existing mills are located. 

The more timber intensive alternatives, especially Allternatives 4 and 7, assume that an 

integrated industry would develop over time in response to stable supplies of timber. If 

this were to occur, much of the associated employment would be in the communities 

where new facilities would be located. 

The mix of primitive and roaded recreation opportunities would vary by alternative 

based on the allocation of the Forest to different LUD groups and range from 

maintaining almost all the existing Inventoried Roadless Areas in a natural condition 

(Alternative 1) to intensive timber management (Alternatives 4 and 7). Viewed in 

terms of projected recreation and tourism employment over the next decade, there 

would be very little difference between the alternatives. 

Among the subsistence resources of greatest importance (salmon, other finfish, marine 

invertebrates, and deer), deer is the only one that is potentially significantly affected by 

the alternatives. Therefore, the subsistence analysis presented here uses deer as a 

key indicator for potential subsistence resource consequences concerning the 

abundance and distribution of the resources. Timber harvest tends to affect deerrelated subsistence activities in two ways. In the short run, approximately 20 to 30 

years following harvest, deer populations tend to increase in harvested areas. In the 

long-run, populations tend to decline as the canopy in even-aged forest stands closes, 

resulting in lower habitat quality. Reductions in habitat quality can be reduced through 

management (e.g., thinning) of young-growth stands. Deer populations in unharvested 

areas are likely to remain at fairly constant levels that are typically lower than a 

comparable harvested area in the short run, but higher in the long run. Road 

construction also affects subsistence by providing subsistence hunters with ready 

access to areas that may have been previously inaccessible. This effect may be 

perceived as either positive or negative depending on the parties involved, as increased 

access may lead to increased competition for resources. Potential effects are likely to 

vary by community and may be perceived differently by members of the same or 

neighboring communities. 

While there would be some new road access under all alternatives in the long run, 

nearly all new roads constructed under the alternatives would be closed following 

harvest. These roads would, therefore, not be available for use by highway vehicles 

or high-clearance vehicles. They would, however, be available for access by other 

methods and would, as a result, have the potential to affect existing subsistence 

patterns. 

The subsistence analysis for deer presented for each community is based on several 

pieces of information. First, it analyzes recent harvest and harvest trends for the WAAs 

that comprise each community’s community use area. For this analysis, hunters are 

divided into three groups: residents of the community in question, all rural hunters, and 

all hunters. Next, it considers the results of deer habitat capability modeling presented 

in the Wildlife section, which addresses current and future habitat capability under each 

alternative relative to the habitat capability available in 1954. Finally, it draws upon the 

findings of the 1997 Forest Plan EIS (USDA Forest Service 1997a) because four of the 

Wood Products 

Recreation and 

Tourism 

Subsistence 
3 Environment and Effects

Subregional Overview and Communities 3-576 Final EIS

current alternatives are very similar to three alternatives in the 1997 EIS. Alternatives 5 

and 6 in this analysis are similar to the selected alternative in the 1997 analysis 

(Alternative 11) and Alternatives 4 and 7 in this analysis are similar to Alternatives 6 and 

2 in the 1997 analysis, respectively. For the 1997 EIS, projected harvest levels were 

compared with estimated deer habitat capability, which was converted into long-term 

deer carrying capacities, by alternative in the short term (2005) and long term (2095). 

This analysis assumed that a deer population at carrying capacity should be able to 

support a hunter harvest of approximately 10 percent that is both sustainable and 

provides a reasonably high level of hunter success for their effort. At 20 percent it was 

assumed that the hunter success for their effort may decrease, and, if the population is 

at carrying capacity, 20 percent may approach a rate that is not sustainable. 

Individual Community Assessments 

The following sections present socioeconomic descriptions and assessments of 

impact for 32 Southeast Alaska communities with a state land selection base. 

These are presented in alphabetical order. 

Angoon, located on the west coast of Admiralty Island at the mouth of Kootznoowoo 

Inlet, has been there so long that no precise date can be established for its original 

occupation. As the only permanent community on Admiralty Island, Angoon had a 

population of about 572 in 2000. It remains a traditional Tlingit Alaska Native village 

with 82 percent of its population identified as Alaska Native in the 2000 Census 

(U.S. Census Bureau, 2001). 

The lands immediately adjacent to Angoon are part of Admiralty Island National 

Monument-Kootznoowoo Wilderness and would not be affected by any of the 

proposed alternatives. Other areas within Angoon’s community use area would, 

however, be affected. Angoon’s population increased 37 percent between the 1970 

and 1990 census. Population was, however, approximately 13 percent below the 

1990 level in 2000 and continued to decline in the first part of this decade, with an 

estimated total population of 497 in 2005. Total estimated population was 482 in 

Angoon in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 400 465 638 572 497 482 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a 

The Chatham School District and commercial fishing provide the majority of 

employment for Angoon. Approximately 10 percent of Angoon (72 residents) held 

commercial fishing permits (94 permits) in 2005. These permits were primarily used 

for hand-trolling for king and coho salmon. State and Federal grants recently funded 

a new shellfish farm in the area. Logging on Prince of Wales Island provides 

occasional jobs (Alaska DCED 2002). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 13 percent of the labor force in 

Angoon was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $29,861, 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Angoon 
 Environment and Effects 3 

Final EIS 3-577 Subregional Overview and Communities 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 10 5 

Construction 14 7 

Manufacturing 3 2 

Wholesale Trade 0 0 

Retail Trade 22 11 

Transportation, Warehousing & Utilities 10 5 

Information 0 0 

Finance, Insurance, Real Estate, Rental & Leasing 10 5 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

2 1 

Education, Health & Social Services 77 39 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

30 15 

Other Services (Except Public Admin) 1 1 

Public Administration 16 8 

Total Employment 195 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, and 

subsistence use of this community. Angoon is part of the Chatham Strait community 

group (see Table 3.23-6). Detailed employment data are available for this community 

group by economic sector for 1990, 1995, and 2000 in of the planning record for this 

EIS. The non-federal government, wood products, and service sectors were the major 

employers in the Chatham Strait community group in 1999, accounting for 49, 18, and 

17 percent of total employment, respectively. The wood products employment was 

entirely in the logging sector. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Angoon 

in their local day-to-day work, recreational, and subsistence activities is shown in 

Figure 3.23-2. This area contains 1,083,231 acres of National Forest System land 

(among other land ownerships). Table 3.23-9 shows how the lands within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3 of this document. 

Development LUDs presently account for 32 percent of the total acreage within the 

Angoon community use area. Alternatives 5 and 6 would not have a significant effect 

on existing LUD allocations in the community use area because the acreage by LUD 

group would remain the same as under the existing Forest Plan. The acreage 

allocated to Wilderness/National Monument LUDs would remain constant under all 

alternatives. The amount of acreage allocated to Mostly Natural LUDs would 

increase under Alternatives 1 through 3. The largest increase would occur under 

Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing from 27 

percent under Alternative 5 (No Action) to 55 percent under Alternative 1, with a 

commensurate reduction in development LUDs (Table 3.23-9). Alternatives 4 and 7 

would increase the acreage in development LUDs. Development LUDs would 

account for 40 percent and 42 percent under Alternatives 4 and 7, respectively, 

compared to 32 percent under Alternative 5. 
3 Environment and Effects

Subregional Overview and Communities 3-578 Final EIS

Figure 3.23-2 

Angoon’s Community Use Area 

Table 3.23-9 

LUD Groups in Angoon’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 17,334 61,675 74,138 113,750 91,130 85,871 129,236

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 440,588 440,588 440,588 440,588 440,588 440,588 440,588

Mostly Natural 599,119 447,753 381,812 207,876 296,339 319,769 192,331

Moderate Development 5,817 25,449 27,846 62,047 33,487 31,131 67,920 

Intensive Development 37,707 169,440 232,985 372,720 312,817 291,743 382,392

Total 1,083,231 1,083,231 1,083,231 1,083,231 1,083,231 1,083,231 1,083,231 1

 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.
 Environment and Effects 3 

Final EIS 3-579 Subregional Overview and Communities 

Total suitable acres would range from 2 percent of the Angoon community use area 

under Alternative 1 to 12 percent under Alternative 7, compared to 8 percent under 

Alternative 5 (No Action) and Alternative 6 (Proposed Action). 

Economy 

Angoon is a traditional native community. Commercial fishing and subsistence use 

are the primary factors influencing Angoon. For subsistence use, Admiralty and 

Catherine Islands are especially important to Angoon. All of the National Forest 

System land within the Angoon community use area on Admiralty Island would be 

maintained in their current condition under all alternatives. Commercial fishing 

would not be affected under any of the alternatives. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 52 

percent of the total edible pounds of subsistence resources harvested by Angoon 

households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates), primarily salmon, accounted for the majority (81 percent) of per 

capita subsistence harvest in Angoon in 1996 (ADF&G 2006). 

The 1988 TRUCS study found that deer accounted for 30 percent of the total edible 

pounds of subsistence resources harvested by Angoon households (Kruse and 

Frazier 1988). Deer accounted for 15 percent of per capita subsistence harvest by 

Angoon residents in 1996 (ADF&G 2006). 

The WAAs used by Angoon residents for hunting deer lie within Game Management 

Unit (GMU) 4. Deer harvest in GMU 4 is considered very high relative to other 

areas of Southeast Alaska, which is indicative of relatively high deer populations 

(ADF&G 2005). Over 1997-2004, there has been no significant trend in the number 

of deer harvested or in the number of hunters (ADF&G 2005). However, as shown 

above, from 1990 to 2005 Angoon’s human population has been on a declining 

trend and is currently 22 percent below 1990 levels. 

Angoon residents take the majority (59 percent) of their deer from three WAAs on 

Admiralty Island (4042, 4054, and 4055). As shown in Table 3.23-10, these three 

WAAs will not be affected by any of the alternatives. The next two WAAs in 

importance contribute 20 percent of Angoon’s deer harvest and would each be 

affected under the alternatives, with the greatest effects occurring under Alternatives 

4 and 7. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that all of the alternatives should be able to provide 

habitat capability for deer hunted by Angoon residents, all rural hunters, and all 

hunters within the WAAs where Angoon hunters derive most of their deer harvest. 

Because Alternative 7, the most timber-intensive alternative in this EIS, is similar to 

Alternative 2 in the 1997 Forest Plan EIS, all alternatives in this EIS should be able 

to provide habitat capability for deer hunted by Angoon residents, as well as for all 

deer hunted within the WAAs. 
3 Environment and Effects

Subregional Overview and Communities 3-580 Final EIS

Table 3.23-10 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 1954 

Habitat Capability, for the WAAs where Angoon Residents Obtain Approximately 75% of 

their Average Annual Deer Harvest* 

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA

Angoon 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

4042 47 49 53 100 100 100 100 100 100 100 100 

4055 34 36 50 96 96 96 96 96 96 96 96 

4054 24 25 30 100 100 100 100 100 100 100 100 

3315 20 85 107 83 82 75 75 71 74 74 69 

3308 16 98 158 66 64 59 57 53 56 57 51 

*Calculated based on harvest where location is known. 

In summary, use of most subsistence resources (fish and marine invertebrates) by 

Angoon residents is not expected to be affected under any of the alternatives. In 

addition, subsistence use of deer by Angoon households is unlikely to be directly 

affected by any of the alternatives as the areas most heavily used by Angoon 

residents (on Admiralty Island) will be essentially unmodified under all alternatives. 

It is possible, however, that the more timber-intensive alternatives, especially 

Alternatives 4 and 7, would create increased competition for deer within Angoon’s 

subsistence use areas if hunters from other communities are displaced due to 

timber harvest activity. These impacts are estimated to be minor based on the 

limited accessibility of these areas to non-local hunters. The three WAAs of highest 

importance to Angoon hunters, which occur on Admiralty Island, have very low road 

densities. Open and total road densities range from 0 to 0.1 mile per square mile 

(for all ownerships combined).and road densities in these WAAs are expected to 

increase insiginificantly in the future under any of the alternatives. Although the 

WAAs of importance to Angoon across Chatham Strait on Chichagof, Baranof, and 

Catherine Islands have considerably higher road densities, these roads are 

generally isolated and not connected to a community road system. 

Coffman Cove is located on northeast Prince of Wales Island. Settlement of 

Coffman Cove began in 1956 with development of a logging camp. A road 

connecting Coffman Cove to the larger community of Craig was built in the 1980s. 

Two scheduled airlines serve the community from Ketchikan. The population of 

Coffman Cove shows little change between 1980 and 2000. According to the 2000 

Census, Coffman Cove had a 2000 population of 199, with Alaska Natives 

comprising 3 percent of the total (U.S. Census Bureau 2001). The population 

decreased by 22 percent between 2000 and 2005, with an estimated population of 

156 in 2005. Total estimated population was 162 in Coffman Cove in 2006 (Alaska 

DOL 2007a). 

Year 1980 1990 2000 2005 2006 

Population 193 186 199 156 162 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a

The logging industry and the local school system provide the majority of 

employment for Coffman Cove. One of the major log transfer sites on Prince of 

Wales Island is located at Coffman Cove. Oyster farming and commercial fishing 

also occur in the area. The city is conducting a study of the feasibility of creating a 

commercial/ industrial complex (Alaska DCED 2006). Roundtrip service is currently 

(summer 2006) provided to Coffman Cove from Wrangell and Petersburg by the 

Inter-Island Ferry Authority. 

Coffman Cove 
 Environment and Effects 3 

Final EIS 3-581 Subregional Overview and Communities 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 11 percent of the labor force in 

Coffman Cove was identified as unemployed and seeking work in 2000, compared 

to 7 percent for Southeast Alaska as a whole. Median household income was 

$43,750, compared to a regional median of $44,118 (Alaska DCED 2002). 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 56 50 

Construction 19 17 

Manufacturing 0 0 

Wholesale Trade 2 2 

Retail Trade 4 4 

Transportation, Warehousing & Utilities 0 0 

Information 7 6 

Finance, Insurance, Real Estate, Rental & Leasing 0 0 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

5 5 

Education, Health & Social Services 7 6 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

0 0 

Other Services (Except Public Admin) 3 3 

Public Administration 8 7 

Total Employment 111 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Coffman Cove is located in the Thorne Bay Ranger District and is part of the North 

Prince of Wales community group (see Table 3.23-6). Detailed employment data 

are available for this community group by economic sector for 1990, 1995, and 2000 

in the planning record for this EIS. Wood products employment in the North Prince 

of Wales community group declined by 186 jobs or 69 percent between 1990 and 

1999. Wood products employment accounted for 83 jobs or 23 percent of total 

employment in this community group in 1999. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Coffman 

Cove in their local day-to-day work, recreational, and subsistence activities is shown 

on Figure 3.23-3. This area contains 1,228,787 acres of National Forest System 

land (among other land ownerships). Table 3.23-11 shows how the lands within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 50 percent of the total acreage within the 

Coffman Cove community use area. Alternatives 5 and 6 would not have a 

significant effect on existing LUD allocations in the community use area because the 

acreage by LUD group would remain the same as under the existing Forest Plan. 

The acreage allocated to Wilderness/National Monument LUDs would remain 

constant under all alternatives. The amount of acreage allocated to Mostly Natural 

LUDs would increase under Alternatives 1 through 3. The largest increase would 

occur under Alternative 1, with the acreage allocated to Mostly Natural LUDs 

increasing from 40 
3 Environment and Effects

Subregional Overview and Communities 3-582 Final EIS

Figure 3.23-3 

Coffman Cove’s Community Use Area 

Table 3.23-11 

LUD Groups in Coffman Cove’s Community Use Area by Alternative 

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 171,404 198,276 213,748 258,716 231,727 224,744 342,754

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 122,719 122,719 122,719 122,719 122,719 122,719 122,719

Mostly Natural 758,086 631,548 546,866 370,813 489,516 499,352 218,709

Moderate Development 98,294 144,517 184,157 247,719 208,000 204,089 340,708

Intensive Development 249,686 330,004 375,047 487,558 408,556 402,628 546,652

Total 1,228,786 1,228,787 1,228,789 1,228,809 1,228,790 1,228,787 1,228,788 1

 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative. 
 Environment and Effects 3 

Final EIS 3-583 Subregional Overview and Communities 

percent under Alternative 5 (No Action) to 62 percent under Alternative 1, with a 

commensurate reduction in development LUDs (Table 3.23-11). Alternatives 4 and 

would increase the acreage in development LUDs. Development LUDs would 

account for 60 percent and 72 percent under Alternatives 4 and 7, respectively, 

compared to 50 percent under Alternative 5. 

Total suitable acres would range from 14 percent of the Coffman Cove community 

use area under Alternative 1 to 28 percent under Alternative 7, compared to 19 

percent of the total community use area under Alternative 5 (No Action) and 

Alternative 6 (Proposed Action). 

Economy 

Coffman Cove is primarily a logging community and would, therefore, be directly 

affected by the amount of logging opportunities on northern Prince of Wales Island 

and elsewhere on the Tongass. Approximately 6.5 MMBF was under contract in the 

Thorne Bay Ranger District in August 2006. This volume would not be affected 

under any of the alternatives. These data provide an indication of potential impacts, 

actual impacts would depend on the volume that is under contract when the decision 

is implemented and whether potentially affected existing sales were cancelled as 

part of the decision. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 65 

percent of the total edible pounds of subsistence resources harvested by Coffman 

Cove households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for the majority (71 percent) of per capita subsistence 

harvest in the community in 1998 (ADF&G 2006). 

The 1998 TRUCS study found that deer accounted for 32 percent of the total edible 

pounds of subsistence resources harvested by Coffman Cove households (Kruse 

and Frazier 1988). Deer accounted for 20 percent of per capita subsistence harvest 

by Coffman Cove residents in 1998 (ADF&G 2006). 

Coffman Cove residents harvest deer almost entirely on Prince of Wales Island, 

which is included in GMU 2. Deer harvest and hunter effort in GMU 2 generally 

increased during 1997-2000 and subsequently declined during 2000-2004; however, 

no change has been noted in the average number of hunter-days required to 

harvest a deer (ADF&G 2005). As noted above, Coffman Cove’s human population 

was relatively stable between 1980 and 2000, but has recently declined 22 percent 

below 2000 levels. 

Residents of Coffman Cove harvest the majority (81 percent) of their deer from two 

WAAs in the eastern half of north-central Prince of Wales Island (1420 and 1421). 

As shown in Table 3.23-12, the Coffman Cove portion represents about one-third of 

the total harvest and about one-half of the rural hunter harvest in these WAAs. 

About 36 percent of the combined harvest in these WAAs is by non-rural hunters, 

suggesting that there is a harvest buffer that could be restricted, if necessary, before 

restrictions are placed on rural harvests. 

WAAs 1420 and 1421 occur in an area with substantial past harvest and, therefore, 

deer habitat capabilities are currently estimated to be considerably below 1954 

levels (Table 3.23-12). Under each of the alternatives, additional harvest would 

occur that would reduce habitat capabilities after 100+ years to 36 to 43 percent of 

1954 levels in WAA 1420 and 55-66 percent in WAA 1421. 
3 Environment and Effects

Subregional Overview and Communities 3-584 Final EIS

Table 3.23-12 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 1954 

Habitat Capability, for the WAAs where Coffman Cove Residents Obtain Approximately 75% 

of their Average Annual Deer Harvest* 

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA

Coffman 

Cove 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

1420 87 151 231 52 43 42 40 39 40 40 36

1421 22 47 76 74 66 64 64 64 63 63 55

*Calculated based on harvest where location is known. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that 1997 Alternatives 2, 6, and 11, which are similar to 

the four highest harvest alternatives in this EIS, should be able to provide sufficient 

habitat capability over the long term for deer hunted by Coffman Cove residents. 

However, it concluded that demand would exceed the capability of the habitat to 

produce deer populations sufficient to avoid effects on hunter success for all rural 

hunters in the long term and for all hunters in both the short and long terms. 

In summary, use of most subsistence resources by Coffman Cove residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. The 

risks of this occurring are greatest under Alternative 7 because of its general lack of 

Non-development LUDs within the Coffman Cove use area, and lower under the 

other six alternatives. The risk of hunting restrictions would be reduced somewhat, 

through more intensive management (e.g., thinning) of the existing and future closedcanopy, young-growth forests in this area. Indirect effects associated with increased 

competition for deer within Coffman Cove’s subsistence use areas could also occur 

under all alternatives due to displacement of hunters from other communities due to 

timber harvest activity. Additional road development under the alternatives would 

improve access but may increase competition with other non-local hunters. The level 

of road development is already relatively high in these WAAs. Existing open road 

densities are 1.1 and 0.7 miles per square mile and existing total road densities are 

1.8 and 1.3 miles per square mile in WAAs 1420 and 1421, respectively (for all 

ownerships combined). Long-term (100+ years) road development would vary by 

alternative and would result in estimated maximum total road densities ranging from 

1.6 to 2.0 miles per square mile in these WAAs under Alternative 1, to 2.0 to 2.2 

miles per square mile in these WAAs under Alternative 7 (for all ownerships 

combined). 

Craig is situated on a small island connected to the west coast of Prince of Wales 

Island by a causeway. Craig is located approximately 56 air miles northwest of 

Ketchikan and 6 and 23 road miles from Klawock and Hydaburg, respectively. A 

floatplane dock and heliport are maintained in Craig, and the State ferry serves 

Hollis 30 miles away enabling transportation of passengers, cargo, and vehicles. 

Tlingit fish camps and seasonal villages originally occupied the present location of 

Craig. It was named for its contemporary founder, Craig Miller, who in 1907, with 

the help of local Haidas, established a saltery at Fish Egg Island. 

The Forest Service established a permanent ranger station here around 1919. The 

city of Craig was incorporated in 1922 as a second-class city under the laws of the 

Craig 
 Environment and Effects 3 

Final EIS 3-585 Subregional Overview and Communities 

territory of Alaska and became a first-class city in 1973. Shaan-Seet Inc. (the village 

corporation established under the Alaska Native Claims Settlement Act of 1971) 

received an interim conveyance of 20,852 acres in 1979 (ADF&G 1994). 

The population of Craig more than tripled between 1970 and 1990. According to the 

2000 Census, Craig had a 2000 population of 1,397, with Alaska Natives comprising 

22 percent of the total (U.S. Census Bureau 2001). The total population was 10 

percent higher in 2000 than in 1990. The population decreased by an estimated 

301 residents or 22 percent from 2000 to 2005. Total estimated population was 

1,105 in Craig in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 272 527 1,260 1,397 1,096 1,105 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a

The Craig economy is primarily based on the fishing and timber industry with 

commercial fishing, fish processing, logging, sawmill operations, government and 

commercial services providing the majority of employment. Estimated gross fishing 

earnings of local residents exceeded $2.6 million in 2000. Columbia Ward 

Fisheries, a fish buying station, and a major cold storage plant are located in Craig 

and 200 residents hold commercial fishing permits. Shan-Seet Village Corporation 

timber operations is a major employer of local residents. Craig’s increased role as a 

service and transportation center for the Prince of Wales Island communities has 

largely been responsible for its growth (Alaska DCED 2002). The Viking Lumber 

sawmill is located near Craig. According to the 2006 mill survey conducted for the 

USDA Forest Service, this mill, which has an installed production capacity of 80 

MMBF, processed approximately 19 MMBF in 2006 and employed 42 people 

(Juneau Economic Development Council 2007). 

W.R. Jones and Son Lumber Company is also located in Craig. This mill with an 

installed production capacity of 1 MMBF, processed approximately 600 MBF in 2006 

and employed 4 people (Juneau Economic Development Council 2007). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 9 percent of the labor force in 

Craig was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $45,298, 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 174 24 

Construction 57 8 

Manufacturing 34 5 

Wholesale Trade 18 3 

Retail Trade 90 13 

Transportation, Warehousing & Utilities 41 6 

Information 12 2 

Finance, Insurance, Real Estate, Rental & Leasing 11 2 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

7 1 

Education, Health & Social Services 127 18 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

65 9 

Other Services (Except Public Admin) 46 6 

Public Administration 37 5 

Total Employment 719 100 

Source: Alaska DCED 2002 
3 Environment and Effects

Subregional Overview and Communities 3-586 Final EIS

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Craig is part of the Central Prince of Wales community group (see Table 3.23-6). 

Detailed employment data are available for this community group by economic 

sector for 1990, 1995, and 2000 in the planning record for this EIS. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Craig in 

their local day-to-day work, recreational, and subsistence activities is shown on 

Figure 3.23-4. This area contains 766,935 acres of National Forest System land 

(among other land ownerships). Table 3.23-13 shows how the land within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 55 percent of the total acreage within the 

Craig community use area. Alternatives 5 and 6 would not have a significant effect 

on LUD allocations in the Craig community use area because the acreage in 

development LUD groups would remain virtually the same as under the current 

Forest Plan. The acreage allocated to Wilderness/National Monument LUDs would 

remain constant under all alternatives. The amount of acreage allocated to Mostly 

Natural LUDs would increase under Alternatives 1 through 3. The largest increase 

would occur under Alternative 1, with the acreage allocated to Mostly Natural LUDs 

increasing from 39 percent under Alternative 5 (No Action) to 63 percent under 

Alternative 1, with a commensurate reduction in development LUDs (Table 3.23-13). 

Alternatives 4 and 7 would increase the acreage in development LUDs. 

Development LUDs would account for 64 percent and 72 percent under Aternatives 

4 and 7, respectively, compared to 55 percent under Alternative 5. 

Total suitable acres would range from 15 percent under Alternative 1 to 28 percent 

under Alternative 7, compared to 20 percent of the total community use area under 

Alternative 5 (No Action). 

Economy 

Craig is primarily a commercial fishing, retail trade, and timber community. It is most 

likely to be affected by changes in timber employment, commercial fishing, and retail 

services. Viking Lumber, one of the larger remaining sawmills in the region, is 

located between Craig and Klawock. 

Viking Lumber had 27 MMBF under contract in August 2006. Approximately 17 

percent (4.6 MMBF) of this volume could be potentially affected under Alternative 1, 

which would maintain all Inventoried Roadless Areas on the Tongass in a natural 

condition and not permit timber harvest in these areas. None of the other 

alternatives would affect this volume. These data provide an indication of potential 

impacts, actual impacts would depend on the volume that is under contract when 

the decision is implemented and whether potentially affected existing sales were 

cancelled as part of the decision. 

Several small timber operators produce value-added products in Craig. These value 

added products include music wood, cabinets, and other products. These operators 

process relatively low volumes of timber, but require specific species and grades to 

meet their needs. All alternatives should meet their needs. 

Commercial fisheries employment is not likely to be affected any of the alternatives. 
 Environment and Effects 3 

Final EIS 3-587 Subregional Overview and Communities 

Figure 3.23-4 

Craig’s Community Use Area 

Table 3.23-13 

LUD Groups in Craig’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 113,371 132,673 147,957 170,424 153,413 149,162 212,194

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 45,518 45,518 45,518 45,518 45,518 45,518 45,518 

Mostly Natural 479,982 386,022 314,182 229,123 302,146 308,274 166,626 

Moderate Development 42,759 59,597 71,035 86,288 76,686 74,907 100,174 

Intensive Development 198,674 275,797 336,201 406,006 342,585 338,235 454,615 

Total 766,933 766,933 766,935 766,935 766,934 766,933 766,934 1

 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative. 
3 Environment and Effects

Subregional Overview and Communities 3-588 Final EIS

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 70 

percent of the total edible pounds of subsistence resources harvested by Craig 

households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for 67 percent of per capita subsistence harvest in Craig in 

1997 (ADF&G 2006). 

The 1988 TRUCS study found that deer accounted for 22 percent of the total edible 

pounds of subsistence resources harvested by Craig households (Kruse and Frazier 

1988). Deer accounted for 19 percent of per capita subsistence harvest by Craig 

residents in 1997 (ADF&G 2006). 

Craig residents harvest deer almost entirely on Prince of Wales and adjacent 

islands, which are included in GMU 2. Deer harvest and hunter effort in GMU 2 

generally increased during 1997-2000 and subsequently declined during 2000-2004; 

however, no change has been noted in the average number of hunter-days required 

to harvest a deer (ADF&G 2005). As noted above, the human population of Craig 

more than tripled between 1970 and 1990, continued to grow and peaked around 

2000, and then declined by 21 percent as of 2005. 

Deer harvest by Craig residents is spread over many WAAs, but the majority (55 

percent) of their deer are harvested from five WAAs in central and northern Prince of 

Wales Island (top five WAAs in Table 3.23-14). The Craig portion of the harvest in 

these five WAAs represents about one-quarter of the total harvest and about 40 

percent of the rural hunter harvest (Table 3.23-14). About 30 percent of the 

combined harvest in these WAAs is by non-rural hunters, indicating that there is a 

harvest buffer that could be restricted, if necessary, before restrictions are placed on 

rural harvests. 

Table 3.23-14 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 1954 

Habitat Capability, for the WAAs where Craig Residents Obtain Approximately 75% of their 

Average Annual Deer Harvest* 

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA

Craig 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

1318 115 198 234 92 85 78 76 66 72 75 64 

1422 66 209 300 60 50 48 47 46 47 47 43 

1317 43 53 93 54 51 49 47 45 47 47 38 

1319 37 177 220 74 69 67 66 59 64 64 54 

1529 35 110 226 73 63 61 60 56 59 59 50 

1214 34 49 91 79 70 66 65 62 64 64 53 

1315 34 171 270 55 50 49 47 44 47 47 41 

1332 25 31 37 85 83 82 78 75 77 78 70 

1420 25 151 231 52 43 42 40 39 40 40 36 

*Calculated based on harvest where location is known. 

The majority of the WAAs used heavily by Craig residents are in areas with 

substantial past harvest and deer habitat capabilities are currently estimated to be 

considerably below 1954 levels (Table 3.23-14). Under each of the alternatives, 

additional harvest would further reduce habitat capabilities after 100+ years. 

Reductions would be smallest under Alternative 1 and highest under Alternative 7. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that 1997 Alternatives 2, 6, and 11, which are similar to 
 Environment and Effects 3 

Final EIS 3-589 Subregional Overview and Communities 

the four highest harvest alternatives in this EIS, should be able to provide sufficient 

habitat capability over the long term for deer hunted by Craig residents. However, it 

concluded that demand would exceed the capability of the habitat to produce deer 

populations sufficient to avoid effects on hunter success for all rural hunters in the 

long term and for all hunters in both the short and long terms. 

In summary, use of most subsistence resources by Craig residents (fish and marine 

invertebrates) is not expected to be affected by any of the alternatives. However, 

subsistence use of deer may be affected to the point that some restriction in hunting 

might be necessary over the long term, even under Alternative 1. The risks of this 

occurring are greatest under Alternative 7 because of its general lack of nondevelopment LUDs throughout most of Prince of Wales Island, and second highest 

under Alternative 4 because of its lower use of non-development LUDs than the 

other alternatives. Alternatives 1, 2, and 3 would have the lowest risk and 

Alternatives 5 and 6 would be intermediate. The risk of hunting restrictions would be 

reduced somewhat, through more intensive management (e.g., thinning) of the 

existing and future closed-canopy, young-growth forests in this area. Indirect effects 

associated with increased competition for deer within Craig’s subsistence use areas 

could also occur under all alternatives due to displacement of hunters from other 

communities due to timber harvest activity. Additional road development under the 

alternatives would improve access but may increase competition with other nonlocal hunters. The level of road development is already relatively high in these 

WAAs. Existing open road densities range from 0.6 to 1.9 miles per square mile and 

existing total road densities range from 1.2 to 1.9 miles per square mile in the five 

most important WAAs for Craig deer harvest (for all ownerships combined). Longterm (100+ years) road development would vary by alternative and would result in 

estimated maximum total road densities ranging from 1.3 to 2.8 miles per square 

mile in these WAAs under Alternative 1, to 1.6 to 3.0 miles per square mile in these 

WAAs under Alternative 7 (for all ownerships combined). 

Edna Bay is located on southeast Kosciusko Island, west of Prince of Wales Island, 

and north of Sea Otter Sound. Originally, Tlingit Indians from west Prince of Wales 

Island used Edna Bay on a seasonal basis. In 1943, a logging camp was 

established when the demand for aircraft-quality spruce was high. The camp closed 

in the late 1960s and the buildings were burned and the site cleaned. In 1977, the 

State selected part of the Tongass National Forest at Edna Bay, with the U.S. Forest 

Service reserving two administrative sites. In 1982, the State sold several lots 

around Edna Bay to private landowners. A small community developed as families, 

mainly those involved in commercial fishing, moved to Edna Bay. A school was 

constructed and a road connecting dispersed segments of the community was 

completed (ADF&G 1994). 

Edna Bay remains an unincorporated city. The community has a local Fish and 

Game Advisory Committee and has shown a strong commitment to protecting local 

commercial fishing and subsistence resources (ADF&G 1994). Edna Bay is 

accessible by water or by float plane from Ketchikan. Most households own skiffs 

for transportation around the bay and to other near shore areas not accessible by 

road (ADF&G 1994). 

Edna Bay’s population fluctuated a great deal between 1970 and 1990. The 

population in 2000 was very similar to that identified in 1990. According to the 2000 

Census, Edna Bay had a 2000 population of 49, with no Alaska Native population 

(U.S. Census Bureau 2001). The population declined by 16 percent—an estimated 

eight people—between 2000 and 2005, with an estimated population of 41 in 2005. 

Total estimated population was also 41 in Edna Bay in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 112 6 86 49 41 41 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a

Edna Bay 
3 Environment and Effects

Subregional Overview and Communities 3-590 Final EIS

The majority of employment in Edna Bay is provided by a local sawmill, commercial 

fishing, and the local school district. Thirteen residents hold commercial fishing 

licences, primarily used for power trolling. During the summer, a fish buyer is also 

located in the bay (Alaska DCED 2002). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. This data is an extrapolation based on 

information from a sample of residents. Because the sample size was small, the 

extrapolation may not be exact, but it should provide a general indication of 

distribution of employment. The potential work force was estimated to be 35 people 

and total employment estimated to be 18. While no adults in Edna Bay were 

identified as unemployed and seeking work in 2000, 49 percent of the population 

was identified as not employed and not seeking work. Median household income 

was $44,583, compared to a regional median of $44,118 (Alaska DCED 2002). 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 4 22 

Construction 0 0 

Manufacturing 0 0 

Wholesale Trade 0 0 

Retail Trade 2 11 

Transportation, Warehousing & Utilities 4 22 

Information 0 0 

Finance, Insurance, Real Estate, Rental & Leasing 0 0 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

0 0 

Education, Health & Social Services 8 44 

Arts, Entertainment, Recreation, Accommodation & Food Services 0 0 

Other Services (Except Public Admin) 0 0 

Public Administration 0 0 

Total Employment 18 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. Edna Bay is part of the North Prince of 

Wales community group (see Table 3.23-6). Detailed employment data are 

available for this community group for 1990, 1995, and 2000 in the planning record 

for this EIS. Wood products employment in the North Prince of Wales community 

group declined by 186 jobs or 69 percent between 1990 and 1999. Wood products 

employment accounted for 83 jobs or 23 percent of total employment in this 

community group in 1999. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Edna 

Bay in their local day-to-day work, recreational, and subsistence activities is shown 

on Figure 3.23-5. This area contains 665,386 acres of National Forest System land 

(among other land ownerships). 

Development LUDs presently account for 49 percent of the total acreage within the Edna 

Bay community use area. Table 3.23-15 shows how the lands within this community 

use area would be distributed among the LUD groups by alternative. The LUD 

groups are explained in the introduction to Chapter 3. Alternatives 5 and 6 would not 

have a significant effect on existing LUD allocations in the community use area 

because the acreage by LUD group would remain the same as under the existing 

Forest Plan. The acreage allocated to Wilderness/National Monument LUDs would 

remain constant under all alternatives. The amount of acreage allocated to Mostly 
 Environment and Effects 3 

Final EIS 3-591 Subregional Overview and Communities 

Natural LUDs would increase under Alternatives 1 through 3. The largest increase 

would occur under Alternative 1, with the acreage allocated to Mostly Natural LUDs 

increasing from 46 percent under Alternative 5 (No Action) to 67 percent under 

Alternative 1, with a commensurate reduction in development LUDs (Table 3.23-15). 

Alternatives 4 and 7 would increase the acreage in development LUDs. 

Development LUDs would account for 54 percent and 62 percent under Alternatives 

4 and 7, respectively, compared to 49 percent under Alternative 5. 

Total suitable acres would range from 16 percent under Alternative 1 to 25 percent 

under Alternative 7, compared to 19 percent of the total community use area under 

Alternative 5 (No Action). 

Economy 

Edna Bay is primarily a commercial fishing and subsistence community. 

Commercial fishing is not expected to be significantly affected under any of the 

alternatives. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources accounted for 59 

percent of the total edible pounds of subsistence resources harvested by Edna Bay 

households based on the 1998 TRUCS study (Kruse and Frazier 1988). Marine 

resources (fish and marine invertebrates) accounted for 69 percent of per capita 

subsistence harvest in Edna Bay in 1998 (ADF&G 2006). 

The 1988 TRUCS study found that deer accounted for 21 percent of the total edible 

pounds of subsistence resources harvested by Edna Bay households (Kruse and 

Frazier 1988). Deer accounted for 23 percent of per capita subsistence harvest by 

Edna Bay residents in 1998 (ADF&G 2006). 

Three WAAs have been identified as most important to Edna Bay residents for deer 

harvest: WAA 1525, covering Kosciusko Island; WAA 1003, covering Heceta Island; 

and WAA 3315, covering Catherine Island and adjacent parts of Baranof Island. 

Over 75 percent of Edna Bay’s harvest is derived from the first two WAAs, which are 

included in GMU 2. Deer harvest and hunter effort in GMU 2 generally increased 

during 1997-2000 and subsequently declined during 2000-2004; however, no 

change has been noted in the average number of hunter-days required to harvest a 

deer (ADF&G 2005). As noted above, Edna Bay’s human population has fluctuated 

considerably from 1970 to 1990 and has declined since then, with the 2005 

population at less than half the 1990 level. 

Residents of Edna Bay are responsible for the majority (62 percent) of the deer 

harvested on Kosciusko Island (WAA 1525), but only a small portion of the deer 

harvested on Heceta Island and in other WAAs. As shown in Table 3.23-16, the 

Edna Bay portion represents about 14 percent of the total harvest and about 29 

percent of the rural hunter harvest in these WAAs. About 43 percent of the 

combined harvest in these WAAs is by non-rural hunters, suggesting that there is a 

harvest buffer that could be restricted, if necessary, before restrictions are placed on 

rural harvests. 
3 Environment and Effects

Subregional Overview and Communities 3-592 Final EIS

Figure 3.23-5 

Edna Bay’s Community Use Area 

Table 3.23-15 

LUD Groups in Edna Bay’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 93,739 109,869 118,889 130,966 125,071 121,641 169,454

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 36,103 36,103 36,103 36,103 36,103 36,103 36,103 

Mostly Natural 442,587 364,760 325,637 269,822 305,207 309,110 218,426 

Moderate Development 36,975 51,326 63,788 75,899 66,066 68,935 94,381 

Intensive Development 149,720 213,197 239,859 283,563 258,011 251,238 316,476 

Total 665,385 665,386 665,387 665,388 665,387 665,386 665,386 1

 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.
 Environment and Effects 3 

Final EIS 3-593 Subregional Overview and Communities 

Table 3.23-16 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 1954 

Habitat Capability, for the WAAs where Edna Bay Residents Obtain Approximately 75% of 

their Average Annual Deer Harvest* 

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA

Edna Bay 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

1525 8 11 13 51 48 47 46 46 46 46 43 

1003 4 31 61 66 54 53 53 49 51 52 47 

*Calculated based on harvest where location is known. 

The two WAAs used heavily by Edna Bay residents are in areas with substantial 

past harvest and deer habitat capabilities are currently estimated to be considerably 

below 1954 levels (Table 3.23-16). Under each of the alternatives, additional 

harvest would further reduce habitat capabilities. Reductions would be smallest 

under Alternatives 1 and 2 and greatest under Alternative 7. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that all of the alternatives should be able to provide 

habitat capability for deer hunted by Edna Bay residents, all rural hunters, and all 

hunters, within the WAAs where Edna Bay hunters derive most of their deer harvest. 

Because Alternative 7, the most timber-intensive alternative in this EIS, is similar to 

Alternative 2 in the 1997 Forest Plan EIS, the 1997 analysis indicates that all 

alternatives in this EIS should be able to provide habitat capability for deer hunted 

by Edna Bay residents, as well as for all deer hunted within the WAA’s. 

In summary, use of most subsistence resources by Edna Bay residents (fish and 

marine resources) is not expected to be affected under any of the alternatives. In 

addition, subsistence use of deer by Edna Bay households is unlikely to be directly 

affected by any of the alternatives, as the area most heavily used by Edna Bay 

residents appears to have a low current rate of harvest by local hunters and all 

hunters combined and it is unlikely that demand will increase sufficiently in the future 

to result in a direct effect. Future young-growth management (e.g., thinning) would 

further reduce the potential for effects on local hunters. It is possible, however, that 

additional timber harvest throughout Prince of Wales and adjacent islands would 

create increased competition for deer within Edna Bay’s subsistence use areas if 

hunters from other communities are displaced due to timber harvest activity. These 

impacts are estimated to be relatively minor based on the limited accessibility of 

these island areas to non-local hunters. The two WAAs of highest importance to 

Edna Bay hunters have relatively high existing road densities. Existing open road 

densities range from 1.1 to 1.5 miles per square mile and total road densities range 

from 2.0 to 2.3 miles per square mile (for all ownerships combined). However, these 

road systems are not connected to any community road systems outside of Edna 

Bay. Long-term (100+ years) road development would vary by alternative and 

would result in estimated maximum total road densities ranging from 2.4 to 2.5 miles 

per square mile in these WAAs under Alternative 1, to 2.7 to 2.8 miles per square 

mile in these WAAs under Alternative 7 (for all ownerships combined). 
3 Environment and Effects

Subregional Overview and Communities 3-594 Final EIS

Elfin Cove is a small fishing town located on northwest Chichagof Island. Prior to its 

development as a community, Native Tlingit groups, now based largely in Hoonah, 

used the Elfin Cove area for hunting, fishing, and gathering, as well as a safe 

harbor. According to the 2000 Census, Elfin Cove had a 2000 population of 32, 

none of whom were Alaska Natives (U.S. Census Bureau 2001). 

A fish buyer established a business here in 1927. The opening of a cold storage 

plant at Pelican, less than 20 miles from Elfin Cove in Lisianski Inlet, meant that fish 

no longer had to be hauled all the way to Juneau. Today, the cove still serves as a 

key stopover and supply center for fishermen and the year-round community is 

made up largely of fishing households. In the 1980s, a school was completed that 

also functions as a community center. 

Elfin Cove is an unincorporated community. The community has a local Fish and 

Game Advisory Committee and is accessible by floatplane from Juneau. Elfin 

Cove’s population, which fluctuated between 1970 and 1990, was 25 people or 44 

percent lower than it was in 1990. The population remained fairly stable between 

2000 and 2005, with an estimated decrease in total population of three people. 

Total estimated population was 25 in Elfin Cove in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 49 28 57 32 29 25 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a

The economy of Elfin Cove is highly seasonal and primarily based on the fishing 

industry. It is a fish buying and supply center for fishermen and residents participate 

in commercial fishing, sport fishing and charter services. Eighty percent of the 

population (26 residents) holds commercial fishing permits. Seasonal employment 

is also provided by summer lodges and local retail businesses (Alaska DCED 2006). 

A recent study of nature-based tourism in Southeast Alaska found that although 

Elfin Cove had been dependent on the commercial fishing industry for decades, the 

focus of the town’s economy had shifted toward tourism and sportfishing (Dugan et 

al. 2006). This study also found that the community’s population ranged from 12 in 

the winter to 200 in the summer, with much of the summer increase associated with 

employment in nine sport fishing lodges. The study estimated that 54 people, 

mostly non-residents, were employed by these lodges during the summer. Small 

cruise ships, mostly carrying 60 to 70 passengers, dock at Elfin Cove, with 30 

dockings in 2005 (Dugan et al. 2006). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. This data is an extrapolation based on 

information from a sample of residents. Because the sample size was small, the 

extrapolation may not be exact, but it should provide a general indication of 

distribution of employment. Approximately 23 percent of the labor force in Elfin 

Cove was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $33,750, 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Elfin Cove is part of the North Chichagof community group (see Table 3.23-6). 

Detailed employment data are available for this community group by economic 

sector for 1990, 1995, and 2000 in the planning record for this EIS. Manufacturing 

and non-federal government were the major employers in the North Chichagof 

community group in 1999, accounting for 34 and 30 percent of total employment, 

respectively. Logging and seafood processing accounted for 24 and 10 percent of 

total employment, respectively. 

Elfin Cove 
 Environment and Effects 3 

Final EIS 3-595 Subregional Overview and Communities 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 3 30 

Construction 0 0 

Manufacturing 0 0 

Wholesale Trade 0 0 

Retail Trade 0 0 

Transportation, Warehousing & Utilities 5 50 

Information 0 0 

Finance, Insurance, Real Estate, Rental & Leasing 0 0 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

0 0 

Education, Health & Social Services 0 0 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

2 20 

Other Services (Except Public Admin) 0 0 

Public Administration 0 0 

Total Employment 10 100 

Source: Alaska DCED 2002 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Elfin 

Cove in their local day-to-day work, recreational, and subsistence activities is shown 

on Figure 3.23-6. This area contains 357,385 acres of National Forest System land 

(among other land ownerships). Table 3.23-17 shows how the land within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

The proposed alternatives would not have a significant effect on existing LUD 

allocations in the Elfin Cove community use area because the acreage in 

development LUDs would remain essentially the same as under the existing Forest 

Plan under all of the alternatives, with a very slight increase in development LUDs 

and suitable acres under Alternatives 4 and 7. 

Economy 

Commercial fishing, recreation and tourism, and subsistence use are important to 

Elfin Cove. The acreage in the Elfin Cove community use area is either Wilderness 

or Mostly Natural LUD allocations. Local timber production is not a significant part 

of the local economy. Commercial fishing is not expected to be significantly affected 

under any of the alternatives. Tourism, especially sportfishing, has recently become 

more important to Elfin Cove. A number of lodges operate out of the community. 

Recreation and tourism based on sportfishing is expected to increase by the same 

amount under all of the alternatives. 

Icy Strait, northwest Chichagof Island, and Yakobi Island are the most important 

areas in terms of subsistence use to Elfin Cove. Portions of these areas are 

legislatively withdrawn from timber harvest as either Wilderness or LUD II and would 

be maintained in their current condition under all alternatives. The remaining area is 

allocated to Mostly Natural LUDs and would continue to be either mostly natural or 

further restricted by re-allocation as Recommended Wilderness or LUD II. 
3 Environment and Effects

Subregional Overview and Communities 3-596 Final EIS

Figure 3.23-6 

Elfin Cove’s Community Use Area 

Table 3.23-17 

LUD Groups in Elfin Cove’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 0 0 0 1,928 0 0 1,943

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 161,929 161,929 161,929 161,929 161,929 161,929 161,929

Mostly Natural 195,456 195,455 195,451 190,078 195,438 195,451 190,078

Moderate Development 0 0 0 363 0 0 363

Intensive Development 0 1 5 5,015 18 5 5,015

Total 357,385 357,385 357,385 357,385 357,385 357,385 357,385 1

 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.
 Environment and Effects 3 

Final EIS 3-597 Subregional Overview and Communities 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources accounted for 63 

percent of the total edible pounds of subsistence resources harvested by Elfin Cove 

households based on the 1988 TRUCS study (Kruse and Frazier 1988). Marine 

resources (fish and marine invertebrates) accounted for 62 percent of per capita 

subsistence harvest in Elfin Cove in 1987 (ADF&G 2006). 

The 1988 TRUCS study found that deer accounted for 27 percent of the total edible 

pounds of subsistence resources harvested by Elfin Cove households (Kruse and 

Frazier 1988). Deer accounted for 28 percent of per capita subsistence harvest by 

Elfin Cove residents in 1987 (ADF&G 2006). 

The WAAs used by Elfin Cove residents for hunting deer lie within Game 

Management Unit (GMU) 4. Deer harvest in GMU 4 is considered very high relative 

to other areas of Southeast Alaska, which is indicative of relatively high deer 

populations (ADF&G 2005). Over 1997-2004, there has been no significant trend in 

the number of deer harvested or in the number of hunters (ADF&G 2005). However, 

as shown above, although from 1970 to 2005 the number of residents in Elfin Cove 

has fluctuated, the number in 2005 is 51 percent of the peak in 1990. 

Elfin Cove residents take the majority (74 percent) of their deer from two WAAs on 

northwestern Chichagof Island (3417 and 3421). As shown in Table 3.23-18, these 

WAAs would not be affected by any of the alternatives because they are in 

wilderness, LUD II areas, or are in other Non-development LUDs. The next two 

WAAs in importance are also in the same area and also would not be affected by 

any of the alternatives because of their LUDs. 

Table 3.23-18 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 1954 

Habitat Capability, for the WAAs where Elfin Cove Residents Obtain Approximately 75% of 

their Average Annual Deer Harvest* 

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA

Elfin Cove 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

3421 14 29 36 100 100 100 100 100 100 100 100 

3417 7 100 159 100 100 100 100 100 100 100 100 

*Calculated based on harvest where location is known. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that all of the alternatives should be able to provide 

habitat capability for deer hunted by Elfin Cove residents, all rural hunters, and all 

hunters within the WAAs where Elfin Cove hunters derive most of their deer harvest 

in the short term. In the long term, sufficient habitat would be provided for Elfin 

Cove residents and all rural hunters, but not for all hunters. However, the predicted 

deficit for all hunters in the long term would be a natural condition and not due to 

timber harvest. 

In summary, use of most subsistence resources (fish and marine invertebrates) by 

Elfin Cove residents is not expected to be affected under any of the alternatives. In 

addition, subsistence use of deer by Elfin Cove households would not be directly 

affected by any of the alternatives as the areas most heavily used by Elfin Cove 

residents are in Non-development LUDs. It is also unlikely that Elfin Cove residents 
3 Environment and Effects

Subregional Overview and Communities 3-598 Final EIS

would be affected by increased competition or access because of the limited access 

and the lack of activities under the alternatives in this area. 

Gustavus is located in northern Southeast Alaska on the north shore of Icy Straits, 

east of the entrance to Glacier Bay. Prior to the founding of the present community, 

Huna Tlingit used the land and resources in the immediate vicinity of the community 

site. Use of a salmon camp near the mouth of the Salmon River was noted by early 

Gustavus settlers; however, after a short period of settlement by the new 

community, the Huna Tlingit generally discontinued use of the camp (ADF&G 1994). 

According to the 2000 Census, Gustavus had a 2000 population of 429, with Alaska 

Natives comprising 44 percent of the total (U.S. Census Bureau 2001). 

Gustavus was settled and named “Strawberry Point” in 1914 by a small group of 

immigrants from the lower 48 planning to develop the land as agricultural 

homesteads. World War II brought development to Gustavus in the form of an 

airstrip and Federal Aviation Administration communications facilities. Nearby 

Glacier Bay National Monument was established in 1925 (ADF&G 1994). 

The population of Gustavus, which increased considerably between 1970 and 1990, 

increased by 66 percent between 1990 and 2000 and continued to increase in the 

first part of this decade, although at a much slower rate with an estimated total 

population of 459 in 2005. Total estimated population was 441 in Gustavus in 2006 

(Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 64 98 258 429 459 441 

Source: USDA Forest Service 1997a, U.S. Census Bureau 2001; Alaska DOL 2007a 

The economy of Gustavus is seasonal, at least partly due to its proximity to Glacier 

Bay National Park. The park and its lodge attract tourists and recreation enthusiasts 

during the summer months and there is also a commercial fishing industry. The 

lodge, airport, school, small businesses, and the Park Service are primary 

employers of local residents (Alaska DCED 2002). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 14 percent of the labor force in 

Gustavus was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $34,766, 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 7 4 

Construction 23 12 

Manufacturing 7 4 

Wholesale Trade 0 0 

Retail Trade 7 4 

Transportation, Warehousing & Utilities 19 10 

Information 2 1 

Finance, Insurance, Real Estate, Rental & Leasing 2 1 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

10 5 

Education, Health & Social Services 26 14 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

60 32 

Other Services (Except Public Admin) 10 5 

Public Administration 17 9 

Total Employment 190 100 

Source: Alaska DCED 2002 

Gustavus 
 Environment and Effects 3 

Final EIS 3-599 Subregional Overview and Communities 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Gustavus is part of the Gustavus community group (see Table 3.23-6). Detailed 

employment data are available for this community group by economic sector for 

1990, 1995, and 2000 in the planning record for this EIS. 

The services and Federal government sectors were the largest employers in the 

Gustavus community group in 1999, accounting for 40 and 36 percent of total 

employment, respectively. There is no wood products employment in this 

community. Recreation and tourism-related activities (lodging, restaurants, and 

recreation services) accounted for 40 percent of total employment in 1999. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Gustavus 

in their local day-to-day work, recreational, and subsistence activities is shown on 

Figure 3.23-7. This area contains 480,541 acres of National Forest System land 

(among other land ownerships). Table 3.23-19 shows how the land within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 35 percent of the total acreage within the 

Gustavus community use area. Alternatives 5 and 6 would not have a significant 

effect on existing LUD allocations in the community use area because the acreage 

by LUD group would remain the same as under the existing Forest Plan. The 

acreage allocated to Wilderness/National Monument LUDs would remain constant 

under all alternatives. The amount of acreage allocated to Mostly Natural LUDs 

would increase under Alternatives 1 through 3. The largest increase would occur 

under Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing 

from 59 percent under Alternative 5 (No Action) to 89 percent under Alternative 1, 

with a commensurate reduction in development LUDs (Table 3.23-19). Alternatives 

4 and 7 would increase the acreage in development LUDs. Development LUDs 

would account for 46 percent and 56 percent under Alternatives 4 and 7, 

respectively, compared to 35 percent under Alternative 5. 

Total suitable acres would range from 2 percent under Alternative 1 to 16 percent 

under Alternative 7, compared to 7 percent of the total community use area under 

Alternative 5 (No Action) and Alternative 6 (Proposed Action). 

Economy 

Gustavus is a small community located near Glacier Bay National Park. Recreation 

and tourism are important to Gustavus, especially in relation to use of the National 

Park. Commercial fishing and subsistence use are also important to the community. 

Commercial fishing is not expected to be significantly affected by Forest Service 

activities under any of the alternatives. 
3 Environment and Effects

Subregional Overview and Communities 3-600 Final EIS

Figure 3.23-7 

Gustavus’ Community Use Area 

Table 3.23-19 

LUD Groups in Gustavus’ Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 9,588 31,446 32,587 57,039 35,168 34,056 74,892

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 26,740 26,740 26,740 26,740 26,740 26,740 26,740

Mostly Natural 429,439 343,865 327,090 232,949 283,366 309,137 182,377

Moderate Development 447 11,468 11,467 31,122 13,169 12,479 40,146

Intensive Development 23,915 98,468 115,244 189,726 157,266 132,184 231,278

Total 480,541 480,541 480,541 480,537 480,541 480,541 480,541 1

 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.
 Environment and Effects 3 

Final EIS 3-601 Subregional Overview and Communities 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. Marine resources (fish and marine 

invertebrates) accounted for 69 percent of per capita subsistence harvest in 

Gustavus in 1987. 

The 1988 TRUCS study found that deer accounted for 70 percent of the total edible 

pounds of subsistence resources harvested by Gustavus households (Kruse and 

Frazier 1988). Deer accounted for 27 percent of per capita subsistence harvest by 

Gustavus residents in 1987 (ADF&G 2006). 

The primary WAAs used by Gustavus residents for hunting deer lie within Game 

Management Unit (GMU) 4. Deer harvest in GMU 4 is considered very high relative 

to other areas of Southeast Alaska, which is indicative of relatively high deer 

populations (ADF&G 2005). Over 1997-2004, there has been no significant trend in 

the number of deer harvested or in the number of hunters (ADF&G 2005). However, 

as shown above, the number of residents in Gustavus has increased steadily from 

1970 to 2005, and the 2005 population is seven times the size it was in 1970. 

Gustavus residents take the majority (80 percent) of their deer from two WAAs on 

northern Chichagof Island and Pleasant, Lemesurier, and Inian Islands (4256 and 

4222). As shown in Table 3.23-20, WAA 4256, which provides over half of 

Gustavus’ harvest, would not be affected by any of the alternatives because it is in 

wilderness. WAA 4222 would be affected by timber harvest, especially by 

Alternatives 4 and 7. 

Table 3.23-20 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 1954 

Habitat Capability, for the WAAs where Gustavus Residents Obtain Approximately 75% of 

their Average Annual Deer Harvest* 

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA

Gustavus 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

4256 26 30 45 100 100 100 100 100 100 100 100 

4222 12 45 64 97 96 95 94 86 94 94 86 

*Calculated based on harvest where location is known. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that all of the alternatives should be able to provide 

habitat capability for deer hunted by Gustavus residents, all rural hunters, and all 

hunters within the WAAs where Gustavus hunters derive most of their deer harvest 

in the short term. In the long term, sufficient habitat would be provided for Gustavus 

residents and all rural hunters, but not for all hunters. The predicted deficit for all 

hunters in the long term would be a natural condition, but would occur earlier with 

timber harvest in the area. 

In summary, use of most subsistence resources (fish and marine invertebrates) by 

Gustavus residents is not expected to be affected under any of the alternatives. In 

addition, subsistence use of deer by Gustavus households may be slightly affected 

to the point that some restriction in hunting by non-rural hunters might be necessary 

over the long term. It is also unlikely that Gustavus residents would be affected by 

increased competition or access because of the limited access and the lack of 

activities under the alternatives in this area. 
3 Environment and Effects

Subregional Overview and Communities 3-602 Final EIS

Haines is located in the northern portion of Southeast Alaska, near the north end of Lynn 

Canal on the Chilkat Peninsula. Haines is one of three Southeast communities 

connected by road to Canada. According to the 2000 Census, Haines had a 2000 

population of 2,292, with Alaska Natives comprising 11 percent of the total (U.S. Census 

Bureau 2001). Haines Borough includes the city of Haines, which had a 2000 population 

of 1,811, and several surrounding communities. These communities include Lutak, just 

north of Haines, which had a population of 39 in 2000 and Mosquito Lake, historically 

Chilkat Tlingit territory, which was home to 221 residents in 2000, 5 percent identified as 

Alaska Natives. Covenant Life, a religious community, had 102 residents in 2000. 

The Haines area was originally settled by the Chilkat Tlingits. The Chilkat Tlingits 

are now considered as two groups: the Chilkats of the Chilkat River, with Klukwan 

being the major population center, and the Chilkoots living in and near Haines. 

Haines itself was a trade center and mission site (ADF&G 1994). Klukwan, a Chilkat 

Indian Village near the Chilkat River and 22 miles north of Haines, had a population 

of 139 in 2000. The village is known for its woven artwork of cedar bark and 

mountain goat hair. The area is host to the largest concentration of bald eagles in 

the world during the fall and winter at the nearby Chilkat Bald Eagle Reserve. 

Settlement did not concentrate in Haines until the late 1800s. The commercial fishing 

industry located several canneries in the Chilkat Inlet area near Haines beginning in 

1882; the Klondike gold rush brought thousands of prospectors to the town in the late 

1890s; and the Dalton Trail was established as an open access route into the interior in 

the 1890s. Haines incorporated as a city in 1910 and as a third class borough in 1968 

(ADF&G 1994). 

Haines is a major trans-shipment point because of its ice-free, deep-water port and 

dock, and year-round road access to Canada and Interior Alaska on the Alaska 

Highway. It is a northern terminus of the Alaska Marine Highway System and a hub 

for transportation to and from Southeast Alaska (Alaska DCED 2006). 

The population of Haines has increased steadily since 1970. In the last decade, 

between 1990 and 2000, it increased 46 percent (U.S. Census Bureau 2001). The 

estimated total population decreased by about 16 percent between 2000 and 2005. 

Total estimated population was 1,492 in Haines in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 463 993 1,238 1,811 1,525 1,492 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a

The economy of Haines is highly seasonal. Commercial fishing, tourism, 

government, and transportation are the primary employers. Estimated gross fishing 

earnings of local residents neared $3 million in 2000 and 128 residents hold 

commercial fishing permits. Haines’ road connection to the State Ferry has become 

increasingly important to the tourism businesses. In 2001, Royal Caribbean Cruise 

Lines ceased serving Haines as a port of call. Today, around 45,000 cruise ship 

passengers visit each year (Alaska DCED 2006). Approximately 38,000 visitors 

arrived by land in 2005. 

Employment by industry data, as compiled by the Alaska DCED from the 2000 

Census, are summarized in the table below. Approximately 14 percent of the labor 

force in Haines was identified as unemployed and seeking work in 2000, compared 

to 7 percent for Southeast Alaska as a whole. Median household income was 

$39,926, compared to a regional median of $44,118 (Alaska DCED 2002). 

Haines 
 Environment and Effects 3 

Final EIS 3-603 Subregional Overview and Communities 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 46 6 

Construction 92 12 

Manufacturing 19 2 

Wholesale Trade 7 1 

Retail Trade 96 12 

Transportation, Warehousing & Utilities 54 7 

Information 20 3 

Finance, Insurance, Real Estate, Rental & Leasing 28 4 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

52 7 

Education, Health & Social Services 125 16 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

108 14 

Other Services (Except Public Admin) 72 9 

Public Administration 53 7 

Total Employment 772 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Haines is part of the Haines community group (see Table 3.23-6). Detailed 

employment data are available for this community group by economic sector for 

1990, 1995, and 2000 in the planning record for this EIS. 

Retail trade, services, and non-federal government were the main employers in the 

Haines community group in 1999, accounting for 26, 26, and 20 percent of total 

employment, respectively. Recreation and tourism-related activities (lodging, 

restaurants, and recreation services) accounted for 22 percent of total employment in 

1999. Approximately 140 sawmill jobs were lost with the closure of the Chilkoot Lumber 

Mill in 1991. There was no wood products employment identified in the Haines 

community group in 1999. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of the 

Haines Borough in their local day-to-day work, recreational, and subsistence 

activities is shown on Figure 3.23-8. This area contains 232,496 acres of National 

Forest System land (among other land ownerships). Table 3.23-21 shows how the 

land within this community use area would be distributed among the LUD groups by 

alternative. The LUD groups are explained in the introduction to Chapter 3. 
3 Environment and Effects

Subregional Overview and Communities 3-604 Final EIS

Figure 3.23-8 

Haines’ Community Use Area 

Table 3.23-21 

LUD Groups in Haines’ Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 233 326 2,208 8,732 6,066 5,694 9,733

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 253 253 253 253 253 253 253

Mostly Natural 231,717 231,393 216,585 180,501 195,999 199,757 180,501

Moderate Development 527 850 15,659 51,424 36,244 32,487 51,423

Intensive Development 0 0 0 318 0 0 319

Total 232,496 232,496 232,496 232,496 232,496 232,496 232,496 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.
 Environment and Effects 3 

Final EIS 3-605 Subregional Overview and Communities 

Development LUDs presently account for 16 percent of the total acreage within the 

Haines community use area. Alternatives 5 and 6 would not have a significant effect 

on existing LUD allocations in the community use area because the acreage by LUD 

group would remain the same as under the existing Forest Plan. The acreage 

allocated to Wilderness/National Monument LUDs would remain constant under all 

alternatives. The amount of acreage allocated to Mostly Natural LUDs would 

increase under Alternatives 1 through 3. The largest increase would occur under 

Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing from 84 

percent under Alternative 5 (No Action) to 100 percent under Alternative 1, with a 

commensurate reduction in development LUDs (Table 3.23-21). Alternatives 4 and 7 

would increase the acreage in development LUDs. Development LUDs would 

account for 22 percent under both of these alternatives compared to 16 percent 

under Alternative 5. 

Total suitable acres would range from 0 under Alternatives 1 and 4 percent under 

Alternatives 4 and 7, compared to 3 percent of the total community use area under 

Alternative 5 (No Action). 

Economy 

Commercial fishing, recreation and tourism, and subsistence use are important to 

Haines. Haines has an Alaska Marine Highway System ferry terminal and provides 

road access into Interior Alaska. Timber harvest on State land and wood processing 

were historically a major sector of the Haines economy, but there was no wood 

products employment in Haines in 2004 (see Table 3.23-3). Mining at the 

Kensington Mine southeast of Haines may become a more significant employer in 

the future. Construction activities initiated on the mine site were halted by legal 

challenges and the Forest Service now anticipates the submittal of a revised plan of 

operations in 2008. Although the major mine support is anticipated to be located in 

Juneau, it is likely that some benefits would accrue to Haines. 

Commercial fishing is not expected to be significantly affected under any of the 

alternatives. Mining, and the potential opening of the Kensington Mine, is not 

anticipated to be affected differently by any alternative. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 68 

percent of the total edible pounds of subsistence resources harvested by Haines’ 

households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for 76 percent of per capita subsistence harvest in Haines 

in 1996. 

The 1988 TRUCS study found that deer accounted for 15 percent of the total edible 

pounds of subsistence resources harvested by Haines households (Kruse and 

Frazier 1988). Deer accounted for 4 percent of per capita subsistence harvest by 

Haines residents in 1996 (ADF&G 2006). 

Haines residents mainly harvest deer in GMU 4. Deer harvest in GMU 4 is 

considered very high relative to other areas of Southeast Alaska, which is indicative 

of relatively high deer populations (ADF&G 2005). Over 1997-2004, there has been 

no significant trend in the number of deer harvested or in the number of hunters 

(ADF&G 2005). As noted above, the human population of Haines increased steadily 

from 1970 through 2000, but experienced an estimated decrease of 16 percent 

between 2000 and 2005. Haines had an estimated population of 1,525 in 2005. 

Nineteen WAAs account for about 75 percent of deer harvest by Haines residents. 

The two most heavily used WAAs—3418 and 3104—accounted for 12 percent and 
3 Environment and Effects

Subregional Overview and Communities 3-606 Final EIS

7 percent of total deer harvest by Haines residents, respectively. As these numbers 

suggest, deer harvest by Haines residents is spread over a fairly wide area in GMU 

4 (Table 3.23-22). As a result, Haines residents tend to comprise a relatively small 

share of total harvest by WAA, with two main exceptions—WAAs 1106 and 4146, 

which are located on Chichagof Island and Admiralty Island, respectively, and have 

very low levels of deer harvest. About 38 percent of the combined harvest in the 19 

WAAs used by Haines residents is by non-rural hunters, suggesting that there is a 

harvest buffer that could be restricted, if necessary, before restrictions are placed on 

rural harvests. 

Table 3.23-22 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 1954 

Habitat Capability, for the WAAs where Haines Residents Obtain Approximately 75% of 

their Average Annual Deer Harvest* 

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA

Haines 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

3418 19 62 70 100 100 100 100 100 100 100 100 

3104 11 177 193 73 73 69 68 65 68 68 64 

3731 9 54 87 92 92 91 91 86 90 91 83 

3421 9 28 36 100 100 100 100 100 100 100 100 

3525 8 107 171 78 71 67 67 62 65 66 58 

4044 7 16 228 100 99 99 99 99 99 99 99 

4252 7 75 99 92 92 78 78 70 77 76 69 

3524 6 71 90 100 100 86 85 79 83 84 78 

3523 6 99 164 81 76 74 74 72 73 73 63 

3551 5 146 226 83 77 73 72 68 71 72 62 

3627 5 35 72 76 70 67 65 62 64 65 61 

3630 5 7 15 99 99 99 99 87 91 94 86 

1106 5 6 20 99 99 99 99 99 99 99 99 

4222 4 45 64 97 96 95 94 86 94 94 86 

3310 4 127 140 93 93 93 93 93 93 93 93 

4043 4 7 62 100 100 100 100 100 100 100 100 

4146 4 5 35 100 100 100 100 100 100 100 100 

3836 3 4 196 100 100 100 100 100 100 100 100 

3001 3 422 431 81 81 79 79 72 78 79 71 

*Calculated based on harvest where location is known. 
 Environment and Effects 3 

Final EIS 3-607 Subregional Overview and Communities 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, should be able to provide 

sufficient habitat capability for deer hunted in the Haines community use area by 

Haines residents, all rural hunters, and all hunters in the short term. The selected 

alternative should also provide sufficient habitat capability for Haines residents in the 

long term. Projected harvest for all rural hunters and all hunters in the Haines 

community use area would exceed 10 percent habitat capability, the level that the 

analysis assumed would provide a reasonably high level of hunter success for their 

effort. The Final EIS analysis concluded that at some point a restriction in hunting 

might be necessary. 

In summary, use of most subsistence resources by Haines residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer in some of the WAAs hunted by Haines residents 

may be affected to the point that some restriction in hunting might be necessary 

over the long term, even under Alternative 1. The risks of this occurring are greatest 

under Alternative 7 because of its general lack of Non-Development LUDs under 

this alternative, and lower under the other six alternatives. The risk of hunting 

restrictions would be reduced somewhat, through more intensive management (e.g., 

thinning) of the existing and future closed-canopy, young-growth forests in this area. 

Indirect effects associated with increased competition for deer within Haine’s 

subsistence use areas could also occur under all alternatives due to displacement of 

hunters from other communities due to timber harvest activity. Additional road 

development under the alternatives would improve access but may increase 

competition with other non-local hunters. 

Hollis is located on east Prince of Wales Island, 19 miles east of Craig. According to 

the 2000 Census, Hollis had a 2000 population of 139, with Alaska Natives 

comprising 5 percent of the total (U.S. Census Bureau 2001). 

Hollis, initially settled as a mining camp at the turn of the century, developed into a 

logging camp in the mid-1950s. In 1960, when Thorne Bay became center of the 

logging industry on central Prince of Wales Island, most Hollis residents moved to 

Thorne Bay. In recent years, Hollis has grown as a community, due in part to an 

Alaska Marine Highway terminal there. Roads now connect Hollis with most other 

communities on Prince of Wales Island. A State land sale at Hollis in 1980 led to its 

present status as a permanent community (ADF&G 1994). 

Viking Lumber, one of the larger sawmills presently operating in the region, is 

located nearby between Craig and Klawock. According to the 2006 mill survey 

conducted for the USDA Forest Service, this mill, which has an installed production 

capacity of 80 MMBF, processed approximately 19 MMBF in 2006 and employed 42 

people (Juneau Economic Development Council 2007). 

The population of Hollis increased by 28 people or 25 percent between 1990 and 2000. 

The estimated total population stayed essentially constant between 2000 and 2005, 

with an estimated 2 fewer people in 2005 than in 2000. Total estimated population 

was 156 in Hollis in 2006 (Alaska DOL 2007a). 

Year 1990 2000 2005 2006 

Population 111 139 137 156 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a 

Support services for the timber industry, the State Ferry, and the U.S. Forest 

Service provide the majority of employment to the residents of Hollis. While the 

timber industry is prevalent on the Prince of Wales Island, it does not occur directly 

in the Hollis Community (Alaska DCED 2002). 

Hollis 
3 Environment and Effects

Subregional Overview and Communities 3-608 Final EIS

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 3 percent of the labor force in 

Hollis was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $43,750, 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 12 19 

Construction 4 6 

Manufacturing 2 3 

Wholesale Trade 4 6 

Retail Trade 6 10 

Transportation, Warehousing & Utilities 11 17 

Information 0 0 

Finance, Insurance, Real Estate, Rental & Leasing 3 5 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

2 3 

Education, Health & Social Services 13 21 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

0 0 

Other Services (Except Public Admin) 0 0 

Public Administration 6 10 

Total Employment 63 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Hollis is part of the Central Prince of Wales community group (see Table 3.23-6). 

Detailed employment data are available for this community group by economic 

sector for 1990, 1995, and 2000 in the planning record for this EIS. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Hollis in 

their local day-to-day work, recreational, and subsistence activities is shown on 

Figure 3.23-9. This area contains 289,873 acres of National Forest System land 

(among other land ownerships). Table 3.23-23 shows how the land within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 53 percent of the total acreage within the 

Hollis community use area. Alternatives 5 and 6 would not have a significant effect 

on existing LUD allocations in the community use area because the acreage by LUD 

group would remain the same as under the existing Forest Plan. The acreage 

allocated to Wilderness/National Monument LUDs would remain constant under all 

alternatives. The amount of acreage allocated to Mostly Natural LUDs would 

increase under Alternatives 1 through 3. The largest increase would occur under 

Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing from 35 

percent under Alternative 5 (No Action) to 63 percent under Alternative 1, with a 

commensurate reduction in development LUDs (Table 3.23-23). Alternatives 4 and 7 

would increase the acreage in development LUDs. Development LUDs would 

account for 62 percent and 83 percent under Alternatives 4 and 7, respectively, 

compared to 53 percent under Alternative 5. 
 Environment and Effects 3 

Final EIS 3-609 Subregional Overview and Communities 

Figure 3.23-9 

Hollis’ Community Use Area 

Table 3.23-23 

LUD Groups in Hollis’ Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 29,180 33,571 40,718 57,431 46,863 46,893 85,742

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 34,253 34,253 34,253 34,253 34,253 34,253 34,253

Mostly Natural 181,869 155,362 122,186 74,504 101,416 100,486 15,833

Moderate Development 21,518 26,338 29,168 41,408 35,301 35,467 62,373

Intensive Development 52,233 73,920 104,265 139,708 118,903 119,667 177,413

Total 289,872 289,873 289,873 289,873 289,873 289,872 289,872 1

 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.
3 Environment and Effects

Subregional Overview and Communities 3-610 Final EIS

Total suitable acres would range from 10 percent under Alternative 1 to 30 percent 

under Alternative 7, compared to 16 percent of the total community use area under 

Alternative 5 (No Action) and Alternative 6 (Proposed Action). 

Economy 

Hollis is the site of the Alaska Marine Highway ferry terminal that provides access to 

the rest of Prince of Wales Island. As such, transportation is a major component of 

the community’s economy. Subsistence and timber also play important roles. 

Viking Lumber had 27 MMBF under contract in August 2006. Approximately 17 

percent (4.6 MMBF) of this volume could be potentially affected under Alternative 1, 

which would maintain all Inventoried Roadless Areas on the Tongass in a natural 

condition and not permit timber harvest in these areas. None of the other 

alternatives would affect this volume. These data provide an indication of potential 

impacts, actual impacts would depend on the volume that is under contract when 

the decision is implemented and whether potentially affected existing sales were 

cancelled as part of the decision. 

The ferry terminal would continue to provide important access to Prince of Wales 

Island under all alternatives. Ferry access has become increasingly important to 

Prince of Wales Island as its population continues to grow. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 65 

percent of the total edible pounds of subsistence resources harvested by Hollis 

households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for 73 percent of per capita subsistence harvest in Hollis in 

1998. 

The 1988 TRUCS study found that deer account for 23 percent of the total edible 

pounds of subsistence resources harvested by Hollis households (Kruse and Frazier 

1988). Deer accounted for 18 percent of the per capita subsistence harvest by 

Hollis residents in 1998 (ADF&G 2006). 

Data were not provided for Hollis in the ADF&G deer harvest reports for 1996 to 

2002. The majority of deer harvest by Hollis residents likely takes place in GMU 2—

Prince of Wales Island. Deer harvest and hunter effort in GMU 2 generally 

increased during 1997-2000 and subsequently declined during 2000-2004; however, 

no change has been noted in the average number of hunter-days required to 

harvest a deer (ADF&G 2005). As noted above, the human population of Hollis has 

been relatively constant since 1990. Hollis had an estimated population of 137 

residents in 2005. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, should be able to provide 

habitat capability for deer hunted in the Hollis community use area by Hollis 

residents and all rural hunters in both the short term and long term. Projected 

harvest by all hunters in the Hollis community use area would exceed 10 percent 

habitat capability; the level that the analysis assumed would provide a reasonably 

high level of hunter success for their effort, in both the short term and long term. 

The Final EIS analysis concluded that at some point a restriction in hunting might be 

necessary. 

In summary, use of most subsistence resources by Hollis residents (fish and marine 

invertebrates) is not expected to be affected by any of the alternatives. However, 

subsistence use of deer may be affected to the point that some restriction in hunting 
 Environment and Effects 3 

Final EIS 3-611 Subregional Overview and Communities 

might be necessary over the long term, even under Alternative 1. The risks of this 

occurring are greatest under Alternative 7, and second highest under Alternative 4 

because of its lower use of Non-Development LUDs than the other alternatives. 

Alternatives 1, 2, and 3 would have the lowest risk and Alternatives 5 and 6 would 

be intermediate. 

Hoonah is located on Port Frederick, along Icy Strait on the northeast shore of 

Chichagof Island, 40 air miles west of Juneau. Hoonah is predominantly a Native 

community and has been the principal village for the Hoonah Tlingit Clans since the 

late 1800s. According to the 2000 Census, Hoonah had a 2000 population of 501, 

with Alaska Natives comprising 61 percent of the total (U.S. Census Bureau 2001). 

Whitestone Logging Camp, with a population of 116 (U.S. Census Bureau 2001), is 

adjacent to Hoonah. The community of Game Creek, a religious ministry, is located 

2.6 miles southwest of Hoonah. 

The village of Hoonah has been occupied since prehistoric times by the Tlingit 

people. Groups of Huna Tlingit lived all or part of the year at seasonal camps and 

small winter settlements throughout the Huna territory. Dozens of camps and 

settlements have been documented through archaeological surveys. The Hoonah 

Tlingit have very close ties to the Glacier Bay area across Icy Strait.

In 1880, the Northwest Trading Company built a store in Hoonah. The following 

year, missionaries settled in the town and established the Presbyterian Home 

Mission church and school. By 1887, about 500 people were wintering in the 

village. When the post office was established in 1901, the village was officially 

named Hoonah, which means “village by the cliff” in Tlingit. In 1944, fire burned 

many homes in Hoonah and destroyed the traditional ceremonial costumes and 

keepsakes of the villagers. The town has since been rebuilt and has become a 

center for logging operations on northern Chichagof Island (ADF&G 1994). A sort 

yard and log transfer facility are located at Long Island. The community has a local 

Fish and Game Advisory Committee (ADF&G 1994). 

Icy Strait Point, an old cannery located approximately 1.5 miles from in Hoonah 

opened in 2004 as Alaska’s first cruise destination built specifically for tourists. 

Owned by the Hoonah Totem Corporation and operated by Pt. Sophia Development 

Corporation. A total of 67,620 cruise passengers visited Hoonah in 2004, 77,498 

visited in 2005, and 135,519 cruise visitors were projected for 2006 (Cruise Line 

Agencies of Alaska 2006). 

The Icy Straits Lumber Company and D&L Woodworks are both located in Hoonah. 

According to the 2006 mill survey conducted for the USDA Forest Service, the Icy 

Straits mill, which had an installed production capacity of 20 MMBF, processed 

approximately 0.7 MMBF in 2006 and employed 15 people (Juneau Economic 

Development Council 2007). D&L Woodworks had an installed production capacity 

of 1.8 MMBF and processed 0.1 MMBF in 2007, supporting approximately 1.5 years 

of full-time employment (Juneau Economic Development Council 2007). This 

processing total represented 3 percent and 6 percent of the existing capacity at the 

Icy Straits and D&L Woodworks facilities, respectively. 

The population of Hoonah increased by 65 people or 8 percent between 1990 and 

2000 and stayed essentially constant between 2000 and 2005. Total estimated 

population was 829 in Hoonah in 2006 (Alaska DOL 2007a). 

Hoonah 
3 Environment and Effects

Subregional Overview and Communities 3-612 Final EIS

Year 1970 1980 1990 2000 2005 2006 

Population 748 680 795 860 861 829 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a

Hoonah has a diverse economy with nearly full employment during the summer 

season. A total of 117 residents hold commercial fishing permits. Fishing, logging, 

and local government are the main employers. Estimated gross fishing earnings of 

local residents exceeded $1.5 million in 2000. Fish processing occurs at plants in 

Hoonah and nearby Excursion Inlet. Sealaska Timber Corporation employs a 

number of local residents through contracts with Whitestone Logging, Inc. and 

Southeast Stevedoring. The Huna Totem Corporation owns and operates a sort 

yard and timber transfer facility. The City of Hoonah and the school district are the 

major public sector employers (Alaska DCED 2002). Residents are also employed 

by the recently opened Icy Strait Point development. A total of 67,620 cruise 

passengers visited Hoonah in 2004, 77,498 visited in 2005, and 135,519 cruise 

visitors are projected for 2006 (Cruise Line Agencies of Alaska 2006). 

The economy of Hoonah has undergone a major transformation in recent years with 

the completion of Icy Strait Point (Dugan et al. 2006). Icy Strait Point is the largest 

single employer in Hoonah, with 124 employees, mostly Hoonah residents, working 

there three to four days a week. Icy Strait Point includes a museum and serves as a 

base for tours, including forest tours, whale watching, and fishing charters. These 

tours served an estimated 30,000 people in 2005 (Dugan et al. 2006). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 21 percent of the labor force in 

Hoonah was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $39,028, 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 75 24 

Construction 10 3 

Manufacturing 36 11 

Wholesale Trade 2 1 

Retail Trade 20 6 

Transportation, Warehousing & Utilities 42 13 

Information 0 0 

Finance, Insurance, Real Estate, Rental & Leasing 6 2 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

6 2 

Education, Health & Social Services 74 23 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

15 5 

Other Services (Except Public Admin) 2 1 

Public Administration 29 9 

Total Employment 317 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Hoonah is part of the North Chichagof community group (see Table 3.23-6). 

Detailed employment data are available for this community group by economic 

sector for 1990, 1995, and 2000 in the planning record for this EIS. Manufacturing 

and non-federal government were the major employers in the North Chichagof 

community group in 1999, accounting for 34 and 30 percent of total employment, 

respectively. Logging and seafood processing accounted for 24 and 10 percent of 

total employment, respectively. 
 Environment and Effects 3 

Final EIS 3-613 Subregional Overview and Communities 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Hoonah 

in their local day-to-day work, recreational, and subsistence activities is shown on 

Figure 3.23-10. This area contains 583,825 acres of National Forest System land 

(among other land ownerships). Table 3.23-24 shows how the land within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 46 percent of the total acreage within the 

Hoonah community use area. Alternatives 5 and 6 would not have a significant effect 

on existing LUD allocations in the community use area because the acreage by LUD 

group would remain the same as under the existing Forest Plan. The acreage 

allocated to Wilderness/National Monument LUDs would remain constant under all 

alternatives. The amount of acreage allocated to Mostly Natural LUDs would 

increase under Alternatives 1 through 3. The largest increase would occur under 

Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing from 51 

percent under Alternative 5 (No Action) to 87 percent under Alternative 1, with a 

commensurate reduction in development LUDs (Table 3.23-24). Alternatives 4 and 7 

would increase the acreage in development LUDs. Development LUDs would 

account for 58 percent and 69 percent under Alternatives 4 and 7, respectively, 

compared to 46 percent under Alternative 5. 

Total suitable acres would range from 3 percent under Alternative 1 to 19 percent 

under Alternative 7, compared to 10 percent of the total community use area under 

Alternative 5 (No Action). 

Economy 

Commercial fishing, logging, and subsistence use are important to Hoonah. The Icy 

Straits sawmill, which is located in Hoonah, employed 15 people in 2006. Hoonah 

residents are also employed by the recently opened Icy Strait Point development. 

Commercial fishing is not expected to be significantly affected under any of the 

alternatives. 

The Icy Straits sawmill had approximately 8 MMBF under contract in August 2006. 

Approximately 30 percent (2.5 MMBF) of this volume could be potentially affected 

under Alternative 1. None of the other alternatives would affect this volume. These 

data provide an indication of potential impacts, actual impacts would depend on the 

volume that is under contract when the decision is implemented and whether 

potentially affected existing sales were cancelled as part of the decision. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 59 

percent of the total edible pounds of subsistence resources harvested by Hoonah 

households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for 74 percent of per capita subsistence harvest in Hoonah 

in 1996. 

The 1988 TRUCS study found that deer accounted for 23 percent of the total edible 

pounds of subsistence resources harvested by Hoonah households (Kruse and 

Frazier 1988). Deer accounted for 14 percent of per capita subsistence harvest by 

Hoonah residents (ADF&G 2006). 
3 Environment and Effects

Subregional Overview and Communities 3-614 Final EIS

Figure 3.23-10 

Hoonah’s Community Use Area 

Table 3.23-24 

LUD Groups in Hoonah’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 20,211 51,358 53,071 86,596 56,811 54,540 109,951

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 23,113 23,113 23,113 23,113 23,113 23,113 23,113

Mostly Natural 508,614 381,703 347,870 219,502 294,907 329,917 159,977

Moderate Development 4,153 16,568 15,958 53,154 19,250 17,580 64,254

Intensive Development 47,945 162,441 196,884 288,053 246,555 213,215 336,482

Total 583,825 583,825 583,825 583,821 583,825 583,825 583,825 1

 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.
 Environment and Effects 3 

Final EIS 3-615 Subregional Overview and Communities 

Hoonah residents mainly harvest deer on Chichagof Island, which is included in 

GMU 4. Deer harvest in GMU 4 is considered very high relative to other areas of 

Southeast Alaska, which is indicative of relatively high deer populations (ADF&G 

2005). Over 1997-2004, there has been no significant trend in the number of deer 

harvested or in the number of hunters (ADF&G 2005). As noted above, the human 

population of Hoonah increased steadily from 1970 through 2000 and remained 

relatively constant from 2000 to 2005. Hoonah had an estimated population of 861 

in 2005. 

Four WAAs account for the majority (74 percent) of deer harvest by Hoonah 

residents (Table 3.23-25). The Hoonah portion represents from 78 percent to 93 

percent of the rural hunter harvest and from 49 percent to 70 percent of the total 

harvest in these WAAs. About 35 percent of the combined harvest in these WAAs is 

by non-rural hunters, suggesting that there is a harvest buffer that could be 

restricted, if necessary, before restrictions are placed on rural harvests. 

Table 3.23-25 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 1954 

Habitat Capability, for the WAAs where Hoonah Residents Obtain Approximately 75% of 

their Average Annual Deer Harvest* 

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA

Hoonah 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

3551 132 146 226 83 77 73 72 68 71 72 62 

3523 92 99 164 81 76 74 74 72 73 73 63 

3525 83 107 171 78 71 67 67 62 65 66 58 

3524 63 71 90 100 100 86 85 79 83 84 78 

*Calculated based on harvest where location is known 

Three of the WAAs identified in Table 3.23-26 are in areas with substantial past 

harvest and deer habitat capabilities are currently estimated to be considerably 

below 1954 levels. Under each of the alternatives, additional harvest would further 

reduce habitat capabilities. Reductions would be smallest under Alternatives 1 and 

2 and greatest under Alternative 7. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, should be able to provide 

sufficient habitat capability for deer hunted by Hoonah residents in the short term. 

Projected deer harvest in the Hoonah community use area for all rural hunters and 

all hunters would exceed 10 percent habitat capability, the level that the analysis 

assumed would provide a reasonably high level of hunter success for their effort, in 

the short term. Projected harvest for Hoonah residents was estimated to exceed 

this level in the long term. The Final EIS analysis concluded that at some point a 

restriction in hunting might be necessary. 

In summary, use of most subsistence resources by Hoonah residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. The 

risks of this occurring are greatest under Alternative 7 because of its general lack of 

Non-Development LUDs in Hoonah’s community use area, and second highest 

under Alternative 4 because of its lower use of Non-Development LUDs than the 

other alternatives (Table 3.23-25). Alternatives 1, 2, and 3 would have the lowest 

risk and Alternatives 5 and 6 would be intermediate. The risk of hunting restrictions 
3 Environment and Effects

Subregional Overview and Communities 3-616 Final EIS

would be reduced somewhat, through more intensive management (e.g., thinning) of 

the existing and future closed-canopy, young-growth forests in this area. Indirect 

effects associated with increased competition for deer within Hoonah’s subsistence 

use areas could also occur under all alternatives due to displacement of hunters 

from other communities due to timber harvest activity. Additional road development 

under the alternatives would improve access but may increase competition with 

other non-local hunters. The level of road development is already relatively high in 

these WAAs. Existing open road densities range from 0.4 to 2.1 miles per square 

mile and existing total road densities range from 0.8 to 2.1 miles per square mile (for 

all ownerships combined). Long-term (100+ years) road development would vary by 

alternative and would result in estimated maximum total road densities ranging from 

1.1 to 3.1 miles per square mile in these WAAs under Alternative 1, to 1.5 to 3.4 

miles per square mile in these WAAs under Alternative 7 (for all ownerships 

combined). 

Hydaburg is located on the southwest side of Prince of Wales Island, 45 air miles 

northwest of Ketchikan. According to the 2000 Census, Hydaburg had a 2000 

population of 382, with Alaska Natives comprising 85 percent of the total (U.S. 

Census Bureau 2001). 

The Haida Indians migrated to Prince of Wales Island, a predominantly Tlingit area, 

from Graham Island, Canada. After combining three villages, the present site was 

chosen initially as the Hydaburg Indian Reservation in 1912. It became a fishing 

village with the first fish processing plant opening in 1927, and three other canneries 

operating through the 1930s. Seafood processing was active until 1984 when a fire 

destroyed the cannery (ADF&G 1994). Hydaburg is connected by road to Craig, 

Klawock, Hollis, and northern parts of the Island. 

In 1936, Hydaburg became the first Alaskan Native village to form an Indian 

Reorganization Act Council. In 1972, Hydaburg incorporated as a first class city. 

The community has a local Fish and Game Advisory Committee (ADF&G 1994). 

Hydaburg’s population increased by 79 percent between 1970 and 1990, but 

remained fairly constant between 1990 and 2000, and decreased slightly (3 percent) 

between 2000 and 2005. Total estimated population was 352 in Hydaburg in 2006 

(Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 214 298 384 382 369 352 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a

Hydaburg’s economy is based primarily on the timber and fishing industries. A total 

of 39 residents hold commercial fishing permits. The Haida Corporation has a 

substantial timber holding, a log storage facility, and a sort yard. It suspended 

logging in 1985 due to a decline in the timber market and leases the storage facility 

and sort yard to Sealaska Corporation. The city of Hydaburg, Sealaska Corporation, 

Haida Corporation, and SEARHC are the leading employers. Potential development 

ideas for the community include a fish processing facility, a U.S. Forest Service 

Visitor Center, specialty woodworking, and some type of retail center (Alaska DCED 

2002). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 31 percent of the labor force in 

Hydaburg was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $31,625, 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Hydaburg 
 Environment and Effects 3 

Final EIS 3-617 Subregional Overview and Communities 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 5 6 

Construction 11 12 

Manufacturing 0 0 

Wholesale Trade 0 0 

Retail Trade 8 9 

Transportation, Warehousing & Utilities 7 8 

Information 0 0 

Finance, Insurance, Real Estate, Rental & Leasing 3 3 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

4 4 

Education, Health & Social Services 40 44 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

2 2 

Other Services (Except Public Admin) 3 3 

Public Administration 7 8 

Total Employment 90 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Hydaburg is part of the Hydaburg community group (see Table 3.23-6). Detailed 

employment data are available for this community group by economic sector for 

1990, 1995, and 2000 in the planning record for this EIS. Non-federal government 

and services were the main employers in the Hydaburg community group in 1999, 

accounting for 48 and 19 percent of total employment, respectively. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of 

Hydaburg in their local day-to-day work, recreational, and subsistence activities is 

shown on Figure 3.23-11. This area contains 764,430 acres of National Forest 

System land (among other land ownerships). Table 3.23-26 shows how the land 

within this community use area would be distributed among the LUD groups by 

alternative. The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 44 percent of the total acreage within the 

Hydaburg community use area. Alternatives 5 and 6 would not have a significant 

effect on existing LUD allocations in the community use area because the acreage 

by LUD group would remain the same as under the existing Forest Plan. The 

acreage allocated to Wilderness/National Monument LUDs would remain constant 

under all alternatives. The amount of acreage allocated to Mostly Natural LUDs 

would increase under Alternatives 1 through 3. The largest increase would occur 

under Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing 

from 44 percent under Alternative 5 (No Action) to 77 percent under Alternative 1, 

with a commensurate reduction in development LUDs (Table 3.23-26). Alternatives 

4 and 7 would increase the acreage in development LUDs. Development LUDs 

would account for 54 percent and 59 percent under Alternatives 4 and 7, 

respectively, compared to 44 percent under Alternative 5. 

Total suitable acres would range from 5 percent under Alternative 5 to 19 percent 

under Alternative 7, compared to 12 percent of the total community use area under 

Alternative 5 (No Action) and Alternative 6 (Proposed Action). 
3 Environment and Effects

Subregional Overview and Communities 3-618 Final EIS

Figure 3.23-11 

Hydaburg’s Community Use Area 

Table 3.23-26 

LUD Groups in Hydaburg’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 35,885 54,380 77,736 113,772 94,397 91,860 142,789

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 87,503 87,503 87,503 87,503 87,503 87,503 87,503

Mostly Natural 589,020 505,340 390,557 267,725 338,976 341,121 227,616

Moderate Development 27,692 49,387 54,131 109,515 68,704 62,074 114,791

Intensive Development 60,214 122,201 232,239 299,688 269,248 273,733 334,521

Total 764,430 764,430 764,430 764,431 764,431 764,430 764,431 1

 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.
 Environment and Effects 3 

Final EIS 3-619 Subregional Overview and Communities 

Economy 

Subsistence use and commercial fishing are the primary elements of Hydaburg’s 

economy. Commercial fisheries employment is not likely to be affected under any of 

the alternatives. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 80 

percent of the total edible pounds of subsistence resources harvested by Hydaburg 

households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for the majority (85 percent) of per capita subsistence 

harvest in Hydaburg in 1997. 

The 1988 TRUCS study found that deer accounted for 13 percent of the total edible 

pounds of subsistence resources harvested by Hydaburg households (Kruse and 

Frazier 1988). Deer accounted for 9 percent of per capita subsistence harvest by 

Hydaburg residents in 1997 (ADF&G 2006). 

Hydaburg residents primarily harvest deer on south Prince of Wales Island, which is 

included in GMU 2. Deer harvest and hunter effort in GMU 2 generally increased 

during 1997-2000 and subsequently declined during 2000-2004; however, no 

changehas been noted in the average number of hunter-days required to harvest a 

deer (ADF&G 2005). As noted above, Hydaburg’s human population increased 

steadily from 1970 through 1990 and decreased slightly from 2000 to 2005. 

Hydaburg had an estimated 2005 population of 861. 

Residents of Hydaburg harvest the majority (75 percent) of their deer from two 

WAAs in central Prince of Wales Island (1107 and 1214) (Table 3.23-27). The 

Hydaburg portion represents about 47 percent of the total harvest and 53 percent of 

rural hunter harvest in WAA 1107 and less than 10 percent of total and rural harvest 

in WAA 1214. Non-rural harvest comprises 10 percent of total harvest in WAA 1107 

and 42 percent in WAA 1214. This suggests that there is a limited harvest buffer 

that could be restricted, if necessary, before restrictions are placed on rural 

harvests. 

Table 3.23-27 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 1954 

Habitat Capability, for the WAAs where Hydaburg Residents Obtain Approximately 75% of 

their Average Annual Deer Harvest* 

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA

Hydaburg 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

1107 19 37 41 98 97 97 97 88 90 90 86 

1214 3 53 91 79 70 66 65 62 64 64 53 

*Calculated based on harvest where location is known 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are similar 

to the four highest harvest alternatives in this EIS, should be able to provide sufficient 

habitat capability for deer hunted by Hydaburg residents, as well as for all deer 

hunted within the WAAs of the Hydaburg community use area in the long term. 

In summary, use of most subsistence resources by Hydaburg residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 
3 Environment and Effects

Subregional Overview and Communities 3-620 Final EIS

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. The 

risks of this occurring are greatest under Alternative 7 because of its general lack of 

Non-Development LUDs throughout most of Prince of Wales Island, and second 

highest under Alternative 4 because of its lower use of Non-Development LUDs than 

the other alternatives. Alternatives 1, 2, and 3 would have the lowest risk and 

Alternatives 5 and 6 would be intermediate. The risk of hunting restrictions would be 

reduced somewhat, through more intensive management (e.g., thinning) of the 

existing and future closed-canopy, young-growth forests in this area. Indirect effects 

associated with increased competition for deer within Hydaburg’s subsistence use 

areas could also occur under all alternatives due to displacement of hunters from 

other communities due to timber harvest activity. Additional road development 

under the alternatives would improve access but may increase competition with 

other non-local hunters. The level of road development is already relatively high in 

these WAAs. Existing open road densities are 0.9 and 1.5 miles per square mile 

and existing total road densities are 0.9 and 1.6 miles per square mile in WAAs 

1107 and 1214, respectively (for all ownerships comined). Long-term (100+ years) 

road development would vary by alternative and would result in estimated maximum 

total road densities ranging from 1.5 to 2.3 miles per square mile in these WAAs 

under Alternative 1, to 1.5 to 2.7 miles per square mile in these WAAs under 

Alternative 7 (for all ownerships combined). 

Hyder is a small community located at the head of Portland Canal, a 70-mile-long fjord 

that forms part of the United States/Canadian border. Hyder is just 2 miles from 

Stewart, British Columbia, and 75 air miles from Ketchikan. Hyder is one of three 

Alaskan communities connected by road to Canada. According to the 2000 Census, 

Hyder had a 2000 population of 97, with no Alaska Native population (U.S. Census 

Bureau 2001). 

Nass River Tsimshians inhabited the area, which they called Skam-a-Kounst, “a 

safe place,” prior to the coming of white prospectors in the late 1890s. The first 

official exploration and building at the town site occurred in 1896 by the U.S. Army 

Corps of Engineers. Stewart also became settled at this time, as gold, silver, and 

other mineral mining operations developed. The two towns grew together with an 

initial economic base in mining (ADF&G 1994). 

The population of Hyder, which slightly more than doubled between 1970 and 1990, 

remained fairly constant between 1990 and 2005, decreasing by an estimated 6 

persons. Total estimated population was 92 in Hyder in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 49 77 99 97 91 92 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a

Hyder’s economy is primarily based on tourism and, as such, is seasonal. Four of 

the five largest employers are tourist related. Four residents hold commercial 

fishing permits. Many tourists enter Hyder from Canada. Stewart, British Columbia 

and Hyder are only 2 miles apart and share visitor services. A bottled water 

business opened in 1998 and employs several local residents (Alaska DCED 2002). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 47 percent of the labor force in 

Hyder was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $11,719 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Hyder 
 Environment and Effects 3 

Final EIS 3-621 Subregional Overview and Communities 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 0 0 

Construction 10 42 

Manufacturing 0 0 

Wholesale Trade 0 0 

Retail Trade 2 8 

Transportation, Warehousing & Utilities 4 17 

Information 0 0 

Finance, Insurance, Real Estate, Rental & Leasing 0 0 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

0 0 

Education, Health & Social Services 4 17 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

4 17 

Other Services (Except Public Admin) 0 0 

Public Administration 0 0 

Total Employment 24 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Hyder is part of the Hyder community group (see Table 3.23-6). Detailed 

employment data are available for this community group by economic sector for 

1990, 1995, and 2000 in the planning record for this EIS. The Federal government 

and services sectors were the main employers in the Hyder community group in 

1999, accounting for 69 and 25 percent of total employment, respectively. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Hyder in 

their local day-to-day work, recreational, and subsistence activities is shown on 

Figure 3.23-12. This area contains 108,809 acres of National Forest System land 

(among other land ownerships). Table 3.23-28 shows how the land within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 10 percent of the total acreage within the 

Hyder community use area. Alternatives 5 and 6 would not have a significant effect 

on existing LUD allocations in the community use area because the acreage by LUD 

group would remain the same as under the existing Forest Plan. The acreage 

allocated to Wilderness/National Monument LUDs would remain constant under all 

alternatives. The amount of acreage allocated to Mostly Natural LUDs would 

increase under Alternatives 1 through 3. The largest increase would occur under 

Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing from 90 

percent under Alternative 5 (No Action) to 100 percent under Alternative 1, with a 

commensurate reduction in development LUDs (Table 3.23-28). Alternatives 4 and 7 

would increase the acreage in development LUDs. Development LUDs would 

account for 31 percent under Alternatives 4 and 7 compared to 10 percent under 

Alternatives 5 and 6. 

Total suitable acres would range from 0 under Alternative 1 to 5 percent under 

Alternatives 4 and 7, compared to 3 percent of the total community use area under 

Alternative 5 (No Action) and Alternative 6 (Proposed Action). 
3 Environment and Effects

Subregional Overview and Communities 3-622 Final EIS

Figure 3.23-12 

Hyder’s Community Use Area 

Table 3.23-28 

LUD Groups in Hyder’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 0 3,011 3,011 5,543 3,054 3,054 5,788

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 71 71 71 71 71 71 71

Mostly Natural 108,738 99,539 99,539 75,530 98,275 98,275 75,530

Moderate Development 0 9,199 9,199 33,110 10,463 10,463 33,110

Intensive Development 0 0 0 98 0 0 98

Total 108,809 108,809 108,809 108,809 108,809 108,809 108,809 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.
 Environment and Effects 3 

Final EIS 3-623 Subregional Overview and Communities 

Economy 

Hyder is a small former mining town that now relies upon tourism and commercial 

fishing for the majority of its income. Tourism (especially bear viewing) has become 

increasingly important to the economy of Hyder. A number of organizations 

commenting on the Draft EIS pointed out that the area around Hyder is a well-known 

mining area (as noted above) and stated that several old mines in the area are 

being evaluated for further development and a number of new projects have been 

identified and are in various stages of development. These organizations requested 

that the LUD classification in this area be changed from Semi-remote Recreation to 

a Moderate Development LUD with a Minerals overlay. A Minerals overlay has 

been added to this area in the Final Proposed Plan under all of the action 

alternatives. The Minerals LUD overlay may have the effect of changing potential 

exploration and development costs from high to moderate in the affected area. This 

is discussed further in the Minerals section of this EIS. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 80 

percent of the total edible pounds of subsistence resources harvested by Hyder 

households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for the majority (85 percent) of per capita subsistence in 

Hyder in 1987. 

The 1988 TRUCS study found that deer accounted for only a fraction of the total 

edible pounds of subsistence resources harvested by Hyder households (Kruse and 

Frazier 1988). Deer accounted for a very small amount of per capita subsistence 

harvest by Hyder residents in 1987. 

Data were not provided for Hyder in the ADF&G deer harvest reports for 1996 to 

2002. The majority of deer harvest by Hyder residents likely takes place in GMU 

1A. Deer harvest in GMU 1A generally declined from 1997 to 2004, with the number 

of hunters and hunter effort also decreasing over this period (ADF&G 2005). As 

noted above, the population of Hyder increased from 1970 through 1990 and has 

remained fairly constant since. Hyder had an estimated population of 91 residents 

in 2005. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that 1997 Alternatives 2, 6, and 11, which are similar to 

the four highest harvest alternatives in this EIS, should be able to provide sufficient 

habitat capability for deer hunted in Hyder’s community use area by Hyder 

residents, all rural hunters, and all hunters in the short term. In the long term 

projected harvest for all rural hunters and all hunters in the Hyder community use 

area would exceed 10 percent habitat capability, the level that the analysis assumed 

would provide a reasonably high level of hunter success for their effort. 

In summary, use of most subsistence resources by Hyder residents (fish and marine 

invertebrates) is not expected to be affected by any of the alternatives. However, 

subsistence use of deer may be affected to the point that some restriction in hunting 

might be necessary over the long term, even under Alternative 1. The risks of this 

occurring are greatest under Alternative 7 and second highest under Alternative 4, 

because of their lower use of Non-Development LUDs compared with the other 

alternatives. Alternatives 1, 2, and 3 would have the lowest risk and Alternatives 5 

and 6 would be intermediate. It is unlikely that Hyder residents would be affected by 

increased competition or access in WAA 826, which surrounds their community, 

because of the limited access to this area. Existing road densities are also relatively 

low and total road density is not expected to increase to more than 0.6 mile per 

square mile even under Alternative 7 (for all lands combined). 
3 Environment and Effects

Subregional Overview and Communities 3-624 Final EIS

The city and Borough of Juneau surrounds the Gastineau Channel in Southeast 

Alaska. Juneau lies approximately 900 air miles northwest of Seattle and 600 air 

miles southeast of Anchorage. The City and Borough is comprised of three 

communities: Juneau, Auke Bay, and Douglas. According to the 2000 Census, the 

City and Borough of Juneau had a 2000 population of 30,711, accounting for 42 

percent of the population in Southeast Alaska. Alaska Natives comprised almost 11 

percent of the total population (U.S. Census Bureau 2001). 

Originally, Tlingit Indians made seasonal and permanent villages along the north and 

south coast near the present site of Juneau. Gold discovered in the Juneau area 

started the mining town in 1880 and the settlement grew rapidly. Two of the world’s 

largest lode gold mines produced over $180 million in gold before finally closing in 1944. 

The state capital was moved from Sitka to Juneau in 1906 while Alaska was still a 

territory. Alaska became the 49th State in 1959. Juneau has developed as a 

government and regional services center, with added economic contributions from 

fishing and tourism. 

The population of Juneau has grown steadily since 1970, almost doubling between 

1970 and 1990 and increasing a further 15 percent between 1990 and 2000. The 

population in Juneau has continued to growth, increasing by approximately 2 

percent (482 residents) between 2000 and 2005. Total estimated population was 

30,650 in Juneau in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 13,556 19,528 26,751 30,711 31,193 30,650 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a

The Juneau economy is primarily based on government, tourism, support services 

for logging, fish processing and mining. The State, city and Borough of Juneau, and 

federal agencies provide nearly 45% of the employment in the community. Juneau 

is the State capital and is the home of the State legislators and their staff during the 

legislative season (January to May). Tourism is a significant part of the economy 

during the summer months providing an estimated $130 million in income. Juneau 

is an important cruise ship docking location due to the local attractions: Mendenhall 

Glacier, Juneau Icefield, Tracy Arm Fjord Glacier, and the new Mount Roberts Tram. 

Estimated gross fishing earnings of local residents exceeded $10.4 million in 2000. 

Cold storage facilities in Juneau process over 2 million pounds of seafood annually 

and DIPAC, a private non-profit organization, operates a salmon hatchery. The 

Kennecott Green's Creek Mine, the largest silver mine in North America, produces 

gold, silver, lead and zinc (Alaska DCED 2002). In addition, the Forest Service 

approved a plan of operations for the Kensington Gold Mine north of Juneau in 2005 

and Coeur Alaska, Inc. subsequently began construction activities on the site. 

Construction and development was, however, halted by legal challenges and the 

Forest Service now anticipates the submittal of a revised plan of operations in 2008. 

Tourism in Juneau is dominated by cruise ships, but a recent study noted that a 

substantial number of independent unguided travelers also make their way through 

Juneau in pursuit of hiking, kayaking, boating, hunting, and other outdoor activities 

(Dugan et al. 2006). The six major cruise lines who dock at Juneau each offer 34 to 

37 shore excursions for purchase on the ship or before the cruise begins. 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 5 percent of the labor force in 

Juneau was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $62,034, 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Juneau and 

Vicinity 
 Environment and Effects 3 

Final EIS 3-625 Subregional Overview and Communities 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 854 5 

Construction 1,035 6 

Manufacturing 199 1 

Wholesale Trade 174 1 

Retail Trade 1,689 10 

Transportation, Warehousing & Utilities 1,072 6 

Information 417 3 

Finance, Insurance, Real Estate, Rental & Leasing 723 4 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

1,339 8 

Education, Health & Social Services 3,383 20 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

1,162 7 

Other Services (Except Public Admin) 755 5 

Public Administration 3,735 23 

Total Employment 16,537 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Juneau is part of the Juneau community group (see Table 3.23-6). Detailed 

employment data are available for this community group by economic sector for 

1990, 1995, and 2000 in the planning record for this EIS. Non-federal government, 

services, and retail trade were the main employers in the Juneau community group 

in 1999, accounting for 37, 21, and 15 percent of total employment, respectively. 

Recreation-related activities (lodging, restaurants, and recreation services) 

accounted for 11 percent of total employment. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Juneau 

in their local day-to-day work, recreational, and subsistence activities is shown on 

Figure 3.23-13. This area contains 2,013,397 acres of National Forest System land 

(among other land ownerships). Table 3.23-29 shows how the land within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 8 percent of the total acreage within the 

Juneau community use area. Alternatives 5 and 6 would not have a significant effect 

on existing LUD allocations in the community use area because the acreage by LUD 

group would remain the same as under the existing Forest Plan. The acreage 

allocated to Wilderness/National Monument LUDs would remain constant under all 

alternatives. The amount of acreage allocated to Mostly Natural LUDs would 

increase under Alternatives 1 through 3. The largest increase would occur under 

Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing from 73 

percent under Alternative 5 (No Action) to 80 percent under Alternative 1, with a 

commensurate reduction in development LUDs (Table 3.23-29). Alternatives 4 and 7 

would increase the acreage in development LUDs. Development LUDs would 

account for 10 and 11 percent under alternatives 4 and 7, respectively, compared to 

8 percent under Alternative 5. 

Total suitable acres would range from no acreage under Alternatives 1 through 3 to 

2.4 percent under Alternative 7, compared to 1.6 percent of the total community use 

area under Alternative 5 (No Action). 
3 Environment and Effects

Subregional Overview and Communities 3-626 Final EIS

Figure 3.23-13 

Juneau’s Community Use Area 

Table 3.23-29 

LUD Groups in Juneau’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 621 2,986 8,514 45,408 31,439 25,123 47,865

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 388,994 388,994 388,994 388,994 388,994 388,994 388,994

Mostly Natural 1,602,469 1,596,636 1,580,021 1,413,085 1,470,366 1,479,129 1,412,235

Moderate Development 21,934 24,203 40,818 175,434 131,124 122,472 176,382

Intensive Development 0 3,564 3,564 35,884 22,913 22,802 35,869

Total 2,013,397 2,013,397 2,013,397 2,013,398 2,013,397 2,013,397 2,013,480 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.
 Environment and Effects 3 

Final EIS 3-627 Subregional Overview and Communities 

Economy 

As the State capital, government is important to Juneau. Besides changes in 

government employment, Juneau is most likely to be affected by changes in mining, 

recreation and tourism, and commercial fishing. None of the alternatives are 

expected to affect these aspects of the local economy. 

Subsistence 

Juneau is not classified as a subsistence community; however, many residents use 

the surrounding Tongass for sport hunting and fishing. Juneau is the largest 

community in Southeast Alaska and accounted for 44 percent of the region’s 

population in 2005, with an estimated total of 31,193 residents. Given the nonsubsistence status of the community and its large size, no attempt is made here to 

summarize the WAAs that community residents use to hunt deer. The following 

paragraphs do, however, summarize the findings of the 1997 EIS and provide a 

general overview of the likely impacts of the current alternatives. 

The majority of deer harvest by Juneau residents likely takes place within the 

community’s identified use area (Figure 3.23-13), which is mainly located within 

GMU 1C. GMU 1C has been characterized from 1997-2004 by substantial annual 

variation in deer harvest, with no evident long-term trend in harvest levels (ADF&G 

2005). 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that 1997 Alternatives 2, 6, and 11, which are similar to 

the four highest harvest alternatives in this EIS, should be able to provide sufficient 

habitat capability for deer hunted by all rural hunters in the long term. Projected 

deer harvest in the Juneau community use area by all rural hunters and Juneau 

residents and all hunters was estimated to exceed 10 percent habitat capability; the 

level that the analysis assumed would provide a reasonably high level of hunter 

success for their effort in the short term and long term. The Final EIS analysis 

concluded that at some point a restriction in hunting might be necessary. 

In summary, use of most subsistence resources by Juneau residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. The 

risks of this occurring are greatest under Alternative 7, and second highest under 

Alternative 4 because of its lower use of Non-Development LUDs than the other 

alternatives. Alternatives 1, 2, and 3 would have the lowest risk and Alternatives 5 

and 6 would be intermediate. 

Kake is located on west Kupreanof Island, along Keku Strait, 38 air miles northwest 

of Petersburg. According to the 2000 Census, Kake had a 2000 population of 710, 

with Alaska Natives comprising 67 percent of the total (U.S. Census Bureau 2001). 

Tlingit Alaska Natives villages and fishing camps in the Kake area pre-date nonAlaska Native explorations of Southeast Alaska. During the 1800s these villages 

were consolidated at the present site of Kake. In the years following the American 

purchase of Alaska from Russia in 1867, there were several confrontations between 

the Keex’ Tlingit and the Russian and American military administrations culminating 

in the destruction of three Kake villages. For many years, the Keex’ people did not 

rebuild their villages. Eventually, they concentrated on Kupreanof Island at the 

present townsite along Keku Strait (ADF&G 1994). 

The period of 1880 through 1915 brought a territorial government, missionary 

activity, economic innovations, and a larger white population into Keex’ Tlingit 

territory. By the 1920s, Kake had become self-governing, with a mayor and police 

chief. In 1949, Kake formed an IRA Council under the Indian Reorganization Act of 

Kake 
3 Environment and Effects

Subregional Overview and Communities 3-628 Final EIS

1936. In 1952, Kake became incorporated as a first class city. In 1971, the 

passage of ANCSA resulted in the incorporation of the village and the selection of 

corporation lands (ADF&G 1994). 

The population of Kake, which increased by 56 percent between 1970 and 1990, 

remained fairly constant between 1990 and 2000, and decreased by an estimated 

112 people or 16 percent between 2000 and 2005. Total estimated population was 

536 in Kake in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 448 555 700 710 598 536 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a

The Kake economy is primarily based on timber and fishing industries. Sixty-seven 

residents hold commercial fishing permits. The city, including the school district, 

and the timber industry are the largest employers. Turn Mountain Timber, a joint 

venture between Whitestone logging and Kake Tribal Logging, and the log sort yard 

and transfer facility at Point McCarny employ a number of local residents. Kake 

Tribal Corporation, which owns a local cold storage plant and Ocean Fresh 

Seafoods, is the largest individual employer. The Gunnock Creek Hatchery, a nonprofit organization, operates a salmon hatchery to assist in sustaining the salmon 

fishery in the area (Alaska DCED 2002). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 25 percent of the labor force in 

Kake was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $39,643, 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 34 14 

Construction 34 14 

Manufacturing 10 4 

Wholesale Trade 0 0 

Retail Trade 22 9 

Transportation, Warehousing & Utilities 19 8 

Information 0 0 

Finance, Insurance, Real Estate, Rental & Leasing 3 1 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

0 0 

Education, Health & Social Services 57 23 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

17 7 

Other Services (Except Public Admin) 20 8 

Public Administration 32 13 

Total Employment 248 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Kake is located in the Petersburg Ranger District and part of the Kake community 

group (see Table 3.23-6). Detailed employment data are available for this 

community group by economic sector for 1990, 1995, and 2000 in the planning 

record for this EIS. 

The non-federal government, finance, insurance, and real estate (F.I.R.E), and 

manufacturing sector were the major employers in the Kake community group in 

1999, accounting for 28, 22, and 21 percent of total employment, respectively. 

Wood products (logging) employment decreased by 57 percent between 1990 and 

1999, declining from 123 to 53 jobs. Wood products employment accounted for 21 

percent of total employment in the Kake community group in 1999. 
 Environment and Effects 3 

Final EIS 3-629 Subregional Overview and Communities 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Kake in 

their local day-to-day work, recreational, and subsistence activities is shown on 

Figure 3.23-14. This area contains 454,186 acres of National Forest System land 

(among other land ownerships). Table 3.23-30 shows how the land within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Figure 3.23-14 

Kake’s Community Use Area 
3 Environment and Effects

Subregional Overview and Communities 3-630 Final EIS

Table 3.23-30 

LUD Groups in Kake’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 16,662 62,758 65,251 78,711 73,014 70,998 87,801

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 105,149 105,149 105,149 105,149 105,149 105,149 105,149

Mostly Natural 313,278 203,252 191,676 110,747 151,246 170,011 91,839

Moderate Development 5,806 8,035 10,242 18,292 13,885 15,480 23,345

Intensive Development 29,953 137,749 147,144 220,001 183,905 163,545 233,853

Total 454,187 454,185 454,210 454,188 454,186 454,185 454,186 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.

Development LUDs presently account for 44 percent of the total acreage within the 

Kake community use area. Alternatives 5 and 6 would not have a significant effect 

on existing LUD allocations in the community use area because the acreage by LUD 

group would remain the same as under the existing Forest Plan. The acreage 

allocated to Wilderness/National Monument LUDs would remain constant under all 

alternatives. The amount of acreage allocated to Mostly Natural LUDs would 

increase under Alternatives 1 through 3. The largest increase would occur under 

Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing from 33 

percent under Alternative 5 (No Action) to 69 percent under Alternative 1, with a 

commensurate reduction in development LUDs (Table 3.23-30). Alternatives 4 and 

7 would increase the acreage in development LUDs. Development LUDs would 

account for 52 percent and 57 percent under Alternatives 4 and 7, respectively, 

compared to 44 percent under Alternatives 5. 

Total suitable acres would range from 4 percent under Alternative 1 to 19 percent 

under Alternative 7, compared to 16 percent of the total community use area under 

Alternative 5 (No Action). 

Economy 

Kake is a traditional native community where commercial fishing, timber harvesting, 

and subsistence use are important. For subsistence use, west Kupreanof and north 

Kuiu Islands are some of the most important areas. 

Timber harvest has been an important contributor to the Kake economy for 

approximately 20 years. During that period, both private and National Forest 

System lands have been harvested. Recently, timber harvest has diminished on 

both ownerships. Logging employment in the Kake community group declined by 70 

jobs or 57 percent between 1990 and 1999, but still comprised 21 percent of total 

employment in 1999 (Table 3.23-7). 

A total of 20.6 MMBF is presently under contract in the Petersburg Ranger District. 

Approximately 22 percent or 4.6 MMBF of this volume would be affected under 

Alternative 1, which would maintain all Inventoried Roadless Areas on the Tongass 

in a natural condition and not permit timber harvest in these areas. None of the 

other alternatives would affect this volume. These data provide an indication of 

potential impacts, actual impacts would depend on the volume that is under contract 

when the decision is implemented and whether potentially affected existing sales 

were cancelled as part of the decision. 

Commercial fishing is not expected to be significantly affected under any of the 

alternatives. 
 Environment and Effects 3 

Final EIS 3-631 Subregional Overview and Communities 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 52 

percent of the total edible pounds of subsistence resources harvested by Kake 

households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for 60 percent of per capita subsistence harvest in Kake in 

1996. 

The 1988 TRUCS study found that deer accounted for 24 percent of the total edible 

pounds of subsistence resources harvested by Kake households (Kruse and Frazier 

1988). Deer accounted for 28 percent of per capita subsistence harvest by Kake 

residents in 1996 (ADF&G 2006). 

Kake residents harvest deer on Admiralty Island and Kupreanof Island, which are 

included in GMU 4 and GMU 3, respectively. Deer harvest in GMU 4 is considered 

very high relative to other areas of Southeast Alaska, which is indicative of relatively 

high deer populations. Over 1997-2004, there has been no significant trend in the 

number of deer harvested or in the number of hunters (ADF&G 2005). Deer harvest 

in GMU 3 declined between 1998-2002 and increased between 2002-2004. The 

number of deer hunters declined between 2000-2002 and slightly increased 

between 2002-2004 (ADF&G 2005). As noted above, Kake’s human population 

increased from 1970 to 1990, stayed relatively constant between 1990 and 2000, 

and decreased from 2000 to 2005. Kake had an estimated 2005 population of 598. 

Five WAAs account for the majority (76 percent) of deer harvest by Kake Residents 

(Table 3.23-31). The Kake portion ranges from about 19 percent (WAA 3939) to 91 

percent (WAA 5131) of the total harvest and from 21 percent to 100 percent of the 

rural hunter harvest in these WAAs. About 7 percent of the combined harvest in 

these WAAs is by non-rural hunters, suggesting that there is a small harvest buffer 

that could be restricted, if necessary, before restrictions are placed on rural 

harvests. 

Table 3.23-31 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 1954 

Habitat Capability, for the WAAs where Kake Residents Obtain Approximately 75% of their 

Average Annual Deer Harvest* 

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA

Kake 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

3940 35 75 77 92 92 92 92 92 92 92 92 

3939 24 114 125 100 100 100 100 100 100 100 100 

5132 18 21 21 73 71 68 67 64 65 67 62 

5131 15 15 17 90 86 83 83 80 81 82 79 

4041 14 24 29 90 90 90 90 90 90 90 90 

*Calculated based on harvest where location is known 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, should be able to provide 

sufficient habitat capability for deer hunted in the Kake community use area by Kake 

residents, all rural hunters, and all hunters in the short term. In the long term, the 

selected alternative (Alternative 11 in the 1997 Forest Plan EIS) should be able to 

provide sufficient habitat capability for deer hunted in the Kake community use area 

by Kake residents and all rural hunters. Projected harvest for all hunters in the Kake 

community use area would, however, exceed 10 percent habitat capability; the level 
3 Environment and Effects

Subregional Overview and Communities 3-632 Final EIS

that the analysis assumed would provide a reasonably high level of hunter success 

for their effort. 

In summary, use of most subsistence resources by Kake residents (fish and marine 

invertebrates) is not expected to be affected by any of the alternatives. However, 

subsistence use of deer in some of the WAAs hunted by Kake residents may be 

affected to the point that some restriction in hunting might be necessary over the 

long term, even under Alternative 1. The risks of this occurring are greatest under 

Alternative 7 because of its general lack of Non-Development LUDs within the Kake 

use area, and lower under the other six alternatives. The risk of hunting restrictions 

would be reduced somewhat, through more intensive management (e.g., thinning) of 

the existing and future closed-canopy, young-growth forests in this area. Indirect 

effects associated with increased competition for deer within Kake’s subsistence 

use areas could also occur under all alternatives due to displacement of hunters 

from other communities due to timber harvest activity. The impacts are estimated to 

be relatively low based on the limited accessibility of these areas to non-local 

hunters. Three of the five WAAs of highest importance to Kake hunters (WAAs 

3939, 3940, and 4041) occur at the south end of Admiralty Island. They are 

currently unroaded and there are no plans for future road development in these 

areas. This is not the case for the other two WAAs of importance to Kake hunters 

(WAAs 5131 and 5132), which are located surrounding or adjacent to the 

community of Kake on Kupreanof Island. These WAAs, which currently have total 

road densities of 0.4 and 2.2 miles per square mile, respectively, are projected to 

have long-term maximum total road densities ranging from 0.6 and 3.2 miles per 

square mile under Alternative 1 to 1.0 and 3.3 miles per square mile under 

Alternative 7, respectively (all ownerships combined). 

Kasaan is a small village located on the eastern side of Prince of Wales Island 30 

miles northwest of Ketchikan. According to the 2000 Census, Kasaan had a 2000 

population of 39, with Alaska Natives comprising 38 percent of the total (U.S. 

Census Bureau 2001). 

Originally Tlingit territory, Kasaan gets its name from the Tlingit word meaning 

“pretty town.” Haidas migrated north from the Queen Charlotte Islands in the early 

1700s to the Island and established the village known as “Old Kasaan.” Between 

1892 and 1900, the Copper Queen mine, camp, sawmill, post office, and store were 

built on Kasaan Bay, and the Haida people relocated to this new village (Alaska 

DCED 2006). The Haida village of Kasaan was settled at its present site in 1904 

(ADF&G 1994). 

Kasaan’s population grew by 80 percent between 1970 and 1990. The population 

declined between 1990 and 2000, decreasing by 15 people or 28 percent. The 

population has increased since 2000, with an estimated 61 people living in Kasaan 

in 2005. Total estimated population was 59 in Kasaan in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 30 25 54 39 61 59 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a

Most villagers participate in subsistence for supplemental food sources (Alaska 

DCED 2002). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. This data is an extrapolation based on 

information from a sample of residents. Extrapolation of a small sample may have 

inaccuracies but should provide a general indication of distribution of employment. 

Approximately 20 percent of the labor force in Kasaan was identified as unemployed 

and seeking work in 2000, compared to 7 percent for Southeast Alaska as a whole. 

Median household income was $43,500, compared to a regional median of $44,118 

(Alaska DCED 2002). 

Kasaan 
 Environment and Effects 3 

Final EIS 3-633 Subregional Overview and Communities 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 2 13 

Construction 2 13 

Manufacturing 3 19 

Wholesale Trade 0 0 

Retail Trade 0 0 

Transportation, Warehousing & Utilities 2 13 

Information 0 0 

Finance, Insurance, Real Estate, Rental & Leasing 0 0 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

0 0 

Education, Health & Social Services 2 13 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

0 0 

Other Services (Except Public Admin) 0 0 

Public Administration 5 31 

Total Employment 16 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Kasaan is part of the North Prince of Wales community group (see Table 3.23-6). 

Detailed employment data are available for this community group by economic 

sector for 1990, 1995, and 2000 in the planning record for this EIS. Wood products 

employment in the North Prince of Wales community group declined by 186 jobs or 

69 percent between 1990 and 1999. Wood products employment accounted for 83 

jobs or 23 percent of total employment in this community group in 1999. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Kasaan 

in their local day-to-day work, recreational, and subsistence activities is shown on 

Figure 3.23-15. This area contains 540,324 acres of National Forest System land 

(among other land ownerships). Table 3.23-32 shows how the land within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for about 47 percent of the total acreage 

within the Kasaan community use area. Alternatives 5 and 6 would not have a 

significant effect on existing LUD allocations in the community use area because the 

acreage by LUD group would remain the same as under the existing Forest Plan. 

The acreage allocated to Wilderness/National Monument LUDs would remain 

constant under all alternatives. The amount of acreage allocated to Mostly Natural 

LUDs would increase under Alternatives 1 through 3. The largest increase would 

occur under Alternative 1, with the acreage allocated to Mostly Natural LUDs 

increasing from 45 percent under Alternative 5 (No Action) to 78 percent under 

Alternative 1, with a commensurate reduction in development LUDs (Table 3.23-32). 

Alternatives 4 and 7 would increase the acreage in development LUDs. 

Development LUDs would account for 61 percent and 72 percent under Alternatives 

4 and 7, respectively, compared to 47 percent under Alternative 5. 

Total suitable acres would range from 6 percent under Alternative 1 to 24 percent 

under Alternative 7, compared to 13 percent of the total community use area under 

Alternative 5 (No Action) and Alternative 6 (Proposed Action). 
3 Environment and Effects

Subregional Overview and Communities 3-634 Final EIS

Figure 3.23-15 

Kasaan’s Community Use Area 

Table 3.23-32 

LUD Groups in Kasaan’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 29,928 45,137 63,693 93,428 70,810 69,888 128,100

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 42,343 42,343 42,343 42,343 42,343 42,343 42,343

Mostly Natural 421,877 348,098 264,463 166,490 242,878 242,474 107,599

Moderate Development 22,156 42,265 45,291 85,178 53,098 51,591 106,158

Intensive Development 53,947 107,619 188,227 246,313 202,005 203,916 284,224

Total 540,324 540,324 540,324 540,325 540,325 540,324 540,324 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.
 Environment and Effects 3 

Final EIS 3-635 Subregional Overview and Communities 

Economy 

Subsistence use and commercial fishing are the primary elements of Kasaan’s 

economy. Commercial fisheries employment is not likely to be affected under any of 

the alternatives. Much of the timber harvest in the vicinity of Kasaan is on private 

land owned by the Kasaan Native Corporation. This land would not be affected 

under any of the alternatives. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 74 

percent of the total edible pounds of subsistence resources harvested by Kasaan 

households (Kruse and Frazier 1988) and 75 percent of per capita harvest in 1998 

(ADF&G 2006). 

The 1988 TRUCS survey found that deer account for 22 percent of the total edible 

pounds of subsistence resources harvested by Kasaan households (Kruse and 

Frazier 1988). Deer accounted for 15 percent of per capita subsistence harvest by 

Kasaan residents in 1998 (ADF&G 2006). 

The majority of deer harvest by Kasaan residents takes place near the community 

on north Prince of Wales Island, which is included in GMU 2. Deer harvest and 

hunter effort in GMU 2 generally increased during 1997-2000 and subsequently 

declined during 2000-2004; however, no change has been noted in the average 

number of hunter-days required to harvest a deer (ADF&G 2005). As noted above, 

the population of Kasaan fluctuated from 1970 to 2000. From 2000 to 2005 

Kasaan’s population increased by 56 percent, with an estimated population of 61 in 

2005. 

Residents of Kasaan harvest the majority (90 percent) of their deer from WAA 1315 

on north Prince of Wales Island (Table 3.23-33). The Kasaan portion makes up 1 

percent of the total harvest and 2 percent of the rural hunter harvest in this WAA. 

About 35 percent of the harvest in this WAA is by non-rural hunters, suggesting that 

there is a harvest buffer that could be restricted, if necessary, before restrictions are 

placed on rural harvests. 

Table 3.23-33 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 1954 

Habitat Capability, for the WAAs where Kasaan Residents Obtain Approximately 75% of 

their Average Annual Deer Harvest* 

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA

Kasaan 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

1315 4 175 270 55 50 49 47 44 47 47 41 

*Calculated based on harvest where location is known 

WAA 1315 occurs in an area with substantial past harvest and, therefore, deer 

habitat capabilities are currently estimated to be considerably below 1954 levels 

(Table 3.23-33). Under each of the alternatives, additional harvest would occur that 

would reduce habitat capabilities after 100+ years to 41-50 percent of 1954 levels 

(Table 3.23-33). 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, should be able to provide 
3 Environment and Effects

Subregional Overview and Communities 3-636 Final EIS

sufficient habitat capability for deer hunted in the Kasaan community use area by 

Kasaan residents in the short term and long term. This alternative was also 

estimated to provide sufficient habitat for all rural hunters in the short term. 

Projected deer harvest for all hunters in the Kasaan community use area exceeds 

the level that is both sustainable and provides a reasonably high level of hunter 

success for their effort in the short term and long term. Projected deer harvest for all 

rural hunters also exceeds this level in the long term. 

Kasaan is currently competing with other communities in their subsistence use 

areas and this is likely to continue to do so under all alternatives. Alternatives 

increasing access by road due to harvest activity may increase competition from 

other communities on Prince of Wales Island indirectly impacting Kasaan’s use. An 

increase in access may also allow Kasaan households to increase the range of their 

use. 

In summary, use of most subsistence resources by Kasaan residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. The 

risks of this occurring are greatest under Alternative 7 because of its general 

emphasis on Development LUDs, and lower under the other six alternatives. The 

risk of hunting restrictions would be reduced somewhat, through more intensive 

management (e.g., thinning) of the existing and future closed-canopy, young-growth 

forests in this area. Indirect effects associated with increased competition for deer 

within Port Protection’s subsistence use areas could also occur under all 

alternatives due to displacement of hunters from other communities due to timber 

harvest activity. Additional road development under the alternatives would improve 

access but may increase competition with other non-local hunters. The level of road 

development is already relatively high in this WAA. Existing open road densities are 

1.5 miles per square mile and existing total road densities are 2.0 miles per square 

mile, respectively (all ownerships combined). Long-term (100+ years) road 

development would vary by alternative and would result in estimated maximum total 

road densities ranging from 2.7 miles per square mile in these WAAs under 

Alternative 1, to 2.9 miles per square mile in these WAAs under Alternative 7 (for all 

ownerships combined). 

Ketchikan is located on Revillagigedo Island near the southernmost boundary of 

Alaska. Ketchikan lies approximately 679 miles north of Seattle and 235 miles south 

of Juneau. It is the first Alaska port-of-call for northbound ships. Ketchikan 

Gateway Borough includes Ketchikan, Saxman, Mountain Point, Clover Pass, Ward 

Cove and Herring Cove, which are located on the Ketchikan road system, and 

Pennock Island. 

According to the 2000 Census, Ketchikan Gateway Borough had a 2000 population 

of 14,070, with 56 percent of the population living in the city of Ketchikan. Alaska 

Natives make up 18 percent of the borough population (U.S. Census Bureau 2001). 

Native populations in 1990 varied from a high of 80 percent in Saxman to a low of 

less than 8 percent in the Ketchikan suburbs. Alaska Natives accounted for 66 

percent of total population in Saxman in 2000. Refer to the section on Saxman for 

information directly relating to that community. 

The Ketchikan area was a summer fishing camp for the Tlingit Alaska Natives. 

Their name for the area, “kitschk-him,” meant “thundering wings of an eagle.” Its 

abundant fish and timber resources eventually attracted non-Natives, with the first 

cannery opening in Ketchikan in 1886 and four more by 1912. Nearby gold and 

copper discoveries briefly brought activity to Ketchikan during the late 1890s, but 

timber and fishing became the chief economic forces at the turn of the century and 

have remained important. The 1954 construction of a pulp mill in Ward Cove 

continued a tradition begun by the 1903 opening of Ketchikan Spruce Mills, which 

Ketchikan 
 Environment and Effects 3 

Final EIS 3-637 Subregional Overview and Communities 

operated for more than 70 years. Ketchikan has also remained an important hub for 

fishing, both for fish processing and as home to those with commercial fishing 

permits (401 area residents). 

The population of Ketchikan increased by 14 percent between 1980 and 1990 and 

then decreased by 4 percent between 1990 and 2000. The population decreased 

by a further 3 percent (237 residents) between 2000 and 2005. Total estimated 

population was 7,662 in Ketchikan in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 6,994 7,198 8,263 7,922 7,685 7,662 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a

Ketchikan is an industrial center and a major port of entry in Southeast Alaska. It 

has a diverse economy, supported by a large fishing fleet, fish processing facilities, 

timber and tourism. The estimated gross fishing earnings of local residents neared 

$10 million in 2000. Four canneries, three cold storage facilities, and a fish 

processing plant support the fishing industry in summer months. Ketchikan is a 

cruise ship stop and receives over 650,000 annual visitors. While the timber 

industry is important to the economy with the home base for several timber 

companies, the Ketchikan Pulp Corporation’s pulp mill closed almost a decade ago, 

in March 1997. 

Ketchikan received approximately 887,000 cruise ship visitors in 2005 and has a 

well-developed network and system of shore-excursions, with 47 shore excursions 

advertised by the various cruise lines that dock there. Most nature-based activities 

that originate in Ketchikan fell into four general categories: flightseeing, marine 

charters, adventure experiences, and general sightseeing. In all cases, the majority 

of clients participating in these activities were cruise ship passengers (Dugan et al. 

2006). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 8 percent of the labor force in 

Ketchikan was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $45,802, 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 170 4 

Construction 276 7 

Manufacturing 219 6 

Wholesale Trade 85 2 

Retail Trade 427 11 

Transportation, Warehousing & Utilities 430 11 

Information 93 2 

Finance, Insurance, Real Estate, Rental & Leasing 229 6 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

238 6 

Education, Health & Social Services 731 19 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

414 11 

Other Services (Except Public Admin) 183 5 

Public Administration 393 10 

Total Employment 3,888 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Ketchikan Gateway Borough is comprised of the Ketchikan and Revillagigideo 

community groups (see Table 3.23-6). Detailed employment data are available for 
3 Environment and Effects

Subregional Overview and Communities 3-638 Final EIS

this community group by economic sector for 1990, 1995, and 2000 in the planning 

record for this EIS. 

Since completion of the 1997 Forest Plan EIS analysis, the Ketchikan pulp mill has 

closed. Closure of the mill, the community’s largest employer, resulted in the loss of 

500 direct jobs, many of which were high paying and year round. Employment data 

compiled by the Alaska DOL indicate that employment in the lumber and wood 

products sector declined from 11.8 percent of total wage and salary employment in 

1996 to 5.7 percent in 1999 (Baker 2001). A study by the Alaska DOL found that 3 

years after the mill closure about 45 percent of the laid-off workers were employed 

in other jobs in the Ketchikan/Prince of Wales area, about 15 percent were 

employed elsewhere in Alaska, and about 40 percent had left the state altogether 

(Landry 2001). 

Gateway Forest Products opened lumber and veneer facilities on the former site of 

the KPC Pulp Mill in Ketchikan in 2000. Gateway Forest Products filed for 

bankruptcy protection in February 2002. This application was dismissed by the U.S. 

Bankruptcy Court in April 2002. The Ketchikan veneer mill restarted in 2007 using 

timber imported from British Columbia. More recently, the mill has acquired timber 

from a logging contractor that purchased timber from several Southeast Alaska 

timber sales (Brackley and Haynes, in press; Damstedt 2007). 

The Pacific Log and Lumber sawmill, one of the larger remaining sawmills in 

Southeast Alaska is also located in Ketchikan. According to the 2006 mill survey 

conducted for the USDA Forest Service, this mill, which has an installed production 

capacity of 39.6 MMBF, processed approximately 4.2 MMBF in 2006 and employed 

20 people (Juneau Economic Development Council 2007). 

Approximately 21 percent of employment in the Ketchikan community group was in 

non-federal government. Services and retail trade accounted for 21 and 17 percent 

of total employment, respectively, with recreation-related activities comprising 10 

percent of total employment. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of 

Ketchikan in their local day-to-day work, recreational, and subsistence activities is 

shown on Figure 3.23-16. This area contains 1,975,122 acres of National Forest 

System land (among other land ownerships). Table 3.23-34 shows how the land 

within this community use area would be distributed among the LUD groups by 

alternative. The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for about 21 percent of the total acreage within 

the Ketchikan community use area. Alternatives 5 and 6 would not have a significant 

effect on existing LUD allocations in the community use area because the acreage 

by LUD group would remain the same as under the existing Forest Plan. The 

acreage allocated to Wilderness/National Monument LUDs would remain constant 

under all alternatives. The amount of acreage allocated to Mostly Natural LUDs 

would increase under Alternatives 1 through 3. The largest increase would occur 

under Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing 

from 31 percent under Alternative 5 (No Action) to 48 percent under Alternative 1, 

with a commensurate reduction in development LUDs (Table 3.23-34). Alternatives 

4 and 7 would increase the acreage in development LUDs. Development LUDs 

would account for 32 percent and 33 percent under Alternatives 4 and 7, 

respectively, compared to 21 percent under Alternative 5. 
 Environment and Effects 3 

Final EIS 3-639 Subregional Overview and Communities 

Figure 3.23-16 

Ketchikan’s Community Use Area 

Table 3.23-34 

LUD Groups in Ketchikan’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 47,897 90,739 111,299 176,699 127,271 124,987 204,834

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 934,620 934,619 934,619 934,616 934,620 934,619 934,619

Mostly Natural 943,733 764,232 665,107 417,910 618,698 615,905 396,436

Moderate Development 36,231 82,362 88,211 187,083 100,554 97,706 199,418

Intensive Development 60,538 193,909 287,185 435,514 321,252 326,892 444,655

Total 1,975,122 1,975,122 1,975,122 1,975,123 1,975,123 1,975,122 1,975,129 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.
3 Environment and Effects

Subregional Overview and Communities 3-640 Final EIS

Total suitable acres would range from 2 percent under Alternative 1 to 10 percent 

under Alternative 7, compared to 6 percent of the total community use area under 

Alternative 5 (No Action) and Alternative 6 (Proposed Action). 

Economy 

Ketchikan would be primarily influenced by changes in timber processing, recreation 

and tourism use, commercial fishing, and recreation opportunities, as well as 

potential restrictions on transportation and utility projects. 

Pacific Log and Lumber had approximately 43 MMBF under contract in August 

2006. In addition, 24.5 MMBF is presently under contract with Alcan Forest 

Products, who are located in Ketchikan, but do not operate a facility there. 

Approximately 75 percent (32.1 MMBF) of the volume under contract with Pacific 

Log and Lumber could potentially be affected under Alternative 1, which would 

maintain all Inventoried Roadless Areas on the Tongass in a natural condition and 

not permit timber harvest in these areas. Alternative 1 would also affect 62 percent 

(15.2 MMBF) of volume under contract with Alcan Forest Products. None of the 

other alternatives would affect this volume. These data provide an indication of 

potential impacts, actual impacts would depend on the volume that is under contract 

when the decision is implemented and whether potentially affected existing sales 

were cancelled as part of the decision. 

Recreation and tourism have become increasingly important to the economy of 

Ketchikan, with more than 650,000 cruise ship passengers visiting Ketchikan 

annually. Ketchikan is also the stopover point for visitors traveling to Misty Fiords 

and Prince of Wales Island. 

Commercial fisheries employment is not likely to be affected under any of the 

alternatives. 

Subsistence 

Ketchikan is not classified as a subsistence community; however, many residents 

use the surrounding Tongass for hunting and fishing. Ketchikan Gateway Borough 

is the second largest community in Southeast Alaska and accounted for 19 percent 

of the region’s population in 2005, with an estimated total of 13,125 residents. 

Given the non-subsistence status of the community and its large size, no attempt is 

made here to summarize the WAAs that community residents use to hunt deer. The 

following paragraphs do, however, summarize the findings of the 1997 EIS and 

provide a general overview of the likely impacts of the current alternatives. 

The majority of deer harvest by Ketchikan residents likely takes place within the 

community’s identified use area (Figure 3.23-16), which is mainly located within 

GMU 1A and GMU 2. Deer harvest in GMU 1A generally declined from 1997 to 

2004, with the number of hunters and hunter effort also decreasing over this period 

(ADF&G 2005). Deer harvest in GMU 2 generally increased between 1997 and 

2000 and subsequently declined between 2001 and 2004. The average number of 

days required to harvest a deer, however, remained constant across the entire 

period (ADF&G 2005). 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, should be able to provide 

sufficient habitat capability for deer hunted by all hunters in the short term. 

However, projected deer harvest in the long term by rural hunters and Ketchikan 

residents and all hunters exceeds the level that is both sustainable and provides a 

reasonably high level of hunter success for their effort. If a restriction were 

necessary, sport hunting by Ketchikan residents would be restricted before 

subsistence hunting by rural hunters is restricted. 
 Environment and Effects 3 

Final EIS 3-641 Subregional Overview and Communities 

In summary, use of most subsistence resources by Ketchikan residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. The 

risks of this occurring are greatest under Alternative 7, and second highest under 

Alternative 4 because of its lower use of Non-Development LUDs than the other 

alternatives. Alternatives 1, 2, and 3 would have the lowest risk and Alternatives 5 

and 6 would be intermediate. 

Klawock is located on the west coast of Prince of Wales Island, across from 

Klawock Island, approximately 56 air miles from Ketchikan. It is connected by road 

to Craig and to other communities on the Prince of Wales Island road system. 

According to the 2000 Census, Klawock had a 2000 population of 854, with Alaska 

Natives comprising 51 percent of the total (U.S. Census Bureau 2001). 

The mouth of the Klawock River, where the village of Klawock is now located, has 

been the site of Tlingit occupation for at least the past 600 years. According to oral 

history, some members of the Kuiu kwaan of Kuiu Island moved to Klawock as well 

(ADF&G 1994). Klawock is now the center of the Tlingit population on west Prince 

of Wales Island. 

The history of Klawock is closely tied to the fishing industry. A trading post and 

salmon saltery were established in 1868, and the first cannery in Alaska was built 

here by a San Francisco firm in 1878. A hatchery for red salmon operated at 

Klawock Lake between 1897 and 1917 (Alaska DCED 2006). In 1929, Klawock 

incorporated as a first class city. The community has a local Fish and Game 

Advisory Committee (ADF&G 1994). 

The community has been historically dependent on fishing and cannery operations. 

The timber industry increased in importance in recent years with a relatively large 

number of residents employed in logging and ship loading in the Klawock and Craig 

area (Alaska DCED, 2002). Viking Lumber, one of the larger sawmills presently 

operating in the region, is located between Klawock and Craig. According to the 

2006 mill survey conducted for the USDA Forest Service, this mill, which has an 

installed production capacity of 80 MMBF, processed approximately 19 MMBF in 

2006 and employed 42 people (Juneau Economic Development Council 2007). 

A total of 47 residents hold commercial fishing permits. 

Retail trade and services have become increasingly important to the economy of 

Klawock. Many residents of communities on northern Prince Wales, as well as 

recreationists and tourists shop at the shopping center located in Klawock. Klawock 

has a new airport that has the capacity to accommodate large jet aircraft. The new 

airport is currently not in commercial operation.

Klawock’s population, which more than tripled between 1970 and 1990, increased 

by 132 people or 18 percent between 1990 and 2000. The population decreased by 

74 people or 9 percent between 2000 and 2005. Total estimated population was 

776 in Klawock in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 213 318 722 854 780 776 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001.; Alaska DOL 2007a

Historically, the Klawock economy has been dependent on fishing and cannery 

operations. The cannery operations were closed in the late 1980’s and the timber 

industry has become increasingly important. Sealaska’s logging operation, through 

a contract with Shaan-Seet, Inc., is the largest employer. The City and school 

district are also significant employers. The state operates a salmon hatchery on 

Klawock Lake to maintain the local salmon fisheries (Alaska DCED 2002). 

Klawock 
3 Environment and Effects

Subregional Overview and Communities 3-642 Final EIS

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 16 percent of the labor force in 

Klawock was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $35,000, 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Klawock is part of the Central Prince of Wales community group (see Table 3.23-6). 

Detailed employment data are available for this community group by economic 

sector for 1990, 1995, and 2000 in the planning record for this EIS. 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 50 13 

Construction 41 11 

Manufacturing 24 6 

Wholesale Trade 13 3 

Retail Trade 75 20 

Transportation, Warehousing & Utilities 17 5 

Information 5 1 

Finance, Insurance, Real Estate, Rental & Leasing 6 2 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

4 1 

Education, Health & Social Services 53 14 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

28 8 

Other Services (Except Public Admin) 32 9 

Public Administration 24 6 

Total Employment 372 100 

Source: Alaska DCED 2002 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Klawock 

in their local day-to-day work, recreational, and subsistence activities is shown on 

Figure 3.23-17. This area contains 767,934 acres of National Forest System land 

(among other land ownerships). Table 3.23-35 shows how the land within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for about 55 percent of the total acreage within 

the Klawock community use area. Alternatives 5 and 6 would not have a significant 

effect on existing LUD allocations in the community use area because the acreage 

by LUD group would remain largely the same as under the existing Forest Plan. The 

acreage allocated to Wilderness/National Monument LUDs would remain constant 

under all alternatives. The amount of acreage allocated to Mostly Natural LUDs 

would increase under Alternatives 1 through 3. The largest increase would occur 

under Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing 

from 39 percent under Alternative 5 (No Action) to 63 percent under Alternative 1, 

with a commensurate reduction in development LUDs (Table 3.23-35). Alternatives 

4 and 7 would increase the acreage in development LUDs. Development LUDs 

would account for 64 percent and 72 percent under Alternatives 4 and 7, 

respectively, compared to 55 percent under Alternative 5. 

Total suitable acres would range from 15 percent under Alternative 1 to 28 percent 

under Alternative 7, compared to 20 percent of the total community use area under 

Alternative 5 (No Action). 
 Environment and Effects 3 

Final EIS 3-643 Subregional Overview and Communities 

Figure 3.23-17 

Klawock’s Community Use Area 

Table 3.23-35 

LUD Groups in Klawock’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 113,371 132,673 147,957 170,424 153,413 149,162 212,194

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 45,518 45,518 45,518 45,518 45,518 45,518 45,518

Mostly Natural 479,982 386,022 314,182 229,123 302,146 308,274 166,626

Moderate Development 42,759 59,597 71,035 86,288 76,686 74,907 100,174

Intensive Development 198,674 275,797 336,201 406,006 342,585 338,235 454,615

Total 766,933 766,933 766,935 766,935 766,934 766,933 766,934 1

 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.
3 Environment and Effects

Subregional Overview and Communities 3-644 Final EIS

Economy 

Klawock is a traditional native community. Timber employment, subsistence use, 

and retail services are most likely to be affected in this community. Viking Lumber 

one of the larger remaining sawmills in the region is located between Craig and 

Klawock. 

Viking Lumber had 27 MMBF under contract in August 2006. Approximately 17 

percent (4.6 MMBF) of this volume could be potentially affected under Alternative 1, 

which would maintain all Inventoried Roadless Areas on the Tongass in a natural 

condition and not permit timber harvest in these areas. None of the other 

alternatives would affect this volume. These data provide an indication of potential 

impacts, actual impacts would depend on the volume that is under contract when 

the decision is implemented and whether potentially affected existing sales were 

cancelled as part of the decision. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 75 

percent of the total edible pounds of subsistence resources harvested by Klawock 

households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for 69 percent of per capita subsistence harvest in 

Klawock in 1997. The 1988 TRUCS study found that deer accounted for 19 percent 

of the total edible pounds of subsistence resources harvested by Klawock 

households (Kruse and Frazier 1988). Deer accounted for 15 percent of per capita 

subsistence harvest by Klawock residents in 1997 (ADF&G 2006). 

Klawock residents mainly harvest deer on north Prince of Wales Island, which is 

included in GMU 2. Deer harvest and hunter effort in GMU 2 generally increased 

during 1997-2000 and subsequently declined during 2000-2004; however, no 

change has been noted in the average number of hunter-days required to harvest a 

deer (ADF&G 2005). As noted above, the human population of Klawock increased 

steadily from 1970 to 2000, but decreased by an estimated 9 percent between 2000 

and 2005. Klawock had an estimated population of 78 in 2005. 

Residents of Klawock harvest the majority (75 percent) of their deer from six WAAs 

in north Prince of Wales Island (Table 3.23-36). The Klawock portion represents 

from about 4 percent (WAA 1315) to 31 percent (WAA 1318) of the total harvest and 

about 6 percent to 37 percent of the rural hunter harvest in these WAAs. About 33 

percent of the combined harvest in these WAAs is by non-rural hunters, suggesting 

that there is a limited harvest buffer that could be restricted, if necessary, before 

restrictions are placed on rural harvests. 

Most of the WAAs identified in Table 3.23-36 occur in areas with substantial past 

harvest and, therefore, deer habitat capabilities are currently estimated to be below 

1954 levels. Under each of the alternatives, additional harvest would occur that 

would reduce habitat capabilities after 100+ years to 64-85 percent of 1954 levels in 

WAA 1318 and 41-50 percent in WAA 1315. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, should be able to provide 

sufficient habitat capability for deer hunted by Klawock residents in the short term 

and long term. Projected deer harvest for all rural and for all hunters was estimated 

to exceed the level that the analysis assumed would provide a reasonably high level 

of hunter success for their effort in both the short term and long term. At some point 

a restriction in hunting may be necessary. 
 Environment and Effects 3 

Final EIS 3-645 Subregional Overview and Communities 

Table 3.23-36 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 1954 

Habitat Capability, for the WAAs where Klawock Residents Obtain Approximately 75% of 

their Average Annual Deer Harvest* 

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA

Klawock 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

1318 73 198 234 92 85 78 76 66 72 75 64 

1422 50 209 300 60 50 48 47 46 47 47 43 

1529 25 122 226 73 63 61 60 56 59 59 50 

1420 14 151 231 52 43 42 40 39 40 40 36 

1315 11 175 270 55 50 49 47 44 47 47 41 

1214 10 53 91 79 70 66 65 62 64 64 53 

*Calculated based on harvest where location is known 

In summary, use of most subsistence resources by Klawock residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. The 

risks of this occurring are greatest under Alternative 7 because of its low level of 

Non-Development LUDs throughout most of Prince of Wales Island, and second 

highest under Alternative 4 because of its lower use of Non-Development LUDs than 

the other alternatives. Alternatives 1, 2, and 3 would have the lowest risk and 

Alternatives 5 and 6 would be intermediate. The risk of hunting restrictions would be 

reduced somewhat, through more intensive management (e.g., thinning) of the 

existing and future closed-canopy, young-growth forests in this area. Indirect effects 

associated with increased competition for deer within the Klawock subsistence use 

areas could also occur under all alternatives due to displacement of hunters from 

other communities due to timber harvest activity. Additional road development 

under the alternatives would improve access but may increase competition with 

other non-local hunters. The level of road development is already relatively high in 

these WAAs. For example, for the three WAAs with the highest deer harvest by 

Klawock residents, existing open road densities range from 0.9 to 1.9 miles per 

square mile and existing total road densities range from 1.5 to 1.9 miles per square 

mile (all ownerships combined). Long-term (100+ years) road development in these 

three WAAs would vary by alternative and would result in estimated maximum total 

road densities ranging from 1.7 to 2.8 miles per square mile under Alternative 1, to 

2.0 to 3.0 miles per square mile under Alternative 7 (for all ownerships combined). 

Metlakatla is located on Annette Island, 15 miles south of Ketchikan. According to 

the 2000 Census, Metlakatla had a 2000 population of 1,375, with Alaska Natives 

comprising 82 percent of the total (U.S. Census Bureau 2001). 

Metlakatla, which is believed to have been occupied at one time by Tlingit Indians, 

was settled in 1887 by Church of England minister William Duncan and about 830 

Tsimshian followers from northern British Columbia. In 1891, an Act of Congress 

declared Annette Island an Indian Reservation (the Annette Island Reserve), the 

only one in Alaska. This action set aside the reservation for the exclusive use and 

occupancy by “Metlakatla Indians and such other Natives of Alaska who might join 

them” (ADF&G 1994). 

Metlakatla is a traditional Tsimshian community with a subsistence lifestyle. The 

community was not part of ANCSA. The 86,000-acre Island reservation and 

Metlakatla 
3 Environment and Effects

Subregional Overview and Communities 3-646 Final EIS

surrounding 3,000 feet of coastal waters are not subject to State jurisdiction. The 

Annette Island Reserve regulates commercial fishing in these waters, and operates 

its own tribal court system (Alaska DCED 2006). The community participates in 

regional fish and game management issues (ADF&G 1994). 

Non-federal government was the largest employer in the Metlakatla community 

group in 1999, accounting for 322 jobs or 68 percent of total employment. Wood 

products employment, which decreased by 60 percent (56 jobs) between 1990 and 

1999, accounted for 40 jobs or 9 percent of total employment in 1999. These jobs 

were all in the sawmill sector. The two sawmills located in Metlakatla, Annette 

Island Sawmill and Metlakatla Forest Products, were both idle in 2005 and are not 

expected to reopen. A total of 49 residents hold commercial fishing permits. 

The population of Metlakatla, which increased by a third between the 1980 and 1990 

census, saw a 2 percent decline between 1990 and 2000. The population declined 

by an estimated 33 people—a further 2 percent—between 2000 and 2005. Total 

estimated population was 1,377 in Metlakatla in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 1,050 1,056 1,407 1,375 1,342 1,377 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a

Metlakatla is a federal Indian reservation with no local taxes. The economy is based 

primarily on the fishing and wood products industry. Metlakatla Indian Community, 

the largest employer, operates a salmon hatchery on Tamgas Creek, the tribal court, 

and all local services. Annette Island Packing Co. is a cold storage facility in 

Metlakatla owned by the community (Alaska DCED 2002). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 21 percent of the labor force in 

Metlakatla was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $43,516, 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 36 7 

Construction 54 11 

Manufacturing 41 8 

Wholesale Trade 3 1 

Retail Trade 44 9 

Transportation, Warehousing & Utilities 42 8 

Information 4 1 

Finance, Insurance, Real Estate, Rental & Leasing 13 3 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

12 2 

Education, Health & Social Services 149 30 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

19 4 

Other Services (Except Public Admin) 8 2 

Public Administration 76 15 

Total Employment 501 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Metlakatla is part of the Metlakatla community group (see Table 3.23-6). Detailed 

employment data are available for this community group by economic sector for 

1990, 1995, and 2000 in the planning record for this EIS. Non-federal government 

and retail trade were the main employers in the Metlakatla community group in 

1999, accounting for 68 and 10 percent of total employment, respectively. 
 Environment and Effects 3 

Final EIS 3-647 Subregional Overview and Communities 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of 

Metlakatla in their local day-to-day work, recreational, and subsistence activities is 

shown on Figure 3.23-18. This area contains 1,975,123 acres of National Forest 

System land (among other land ownerships). Table 3.23-37 shows how the land 

within this community use area would be distributed among the LUD groups by 

alternative. The LUD groups are explained in the introduction to Chapter 3. 

Figure 3.23-18 

Metlakatla’s Community Use Area 
3 Environment and Effects

Subregional Overview and Communities 3-648 Final EIS

Table 3.23-37 

LUD Groups in Metlakatla’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 47,897 90,739 111,299 176,699 127,271 124,987 204,834

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 934,620 934,619 934,619 934,616 934,620 934,619 934,619

Mostly Natural 943,733 764,232 665,107 417,910 618,698 615,905 396,436

Moderate Development 36,231 82,362 88,211 187,083 100,554 97,706 199,418

Intensive Development 60,538 193,909 287,185 435,514 321,252 326,892 444,655

Total 1,975,122 1,975,122 1,975,122 1,975,123 1,975,123 1,975,122 1,975,129 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.

Development LUDs presently account for about 21 percent of the total acreage 

within the Metlakatla community use area. Alternatives 5 and 6 would not have a 

significant effect on existing LUD allocations in the community use area because the 

acreage by LUD group would remain the same as under the existing Forest Plan. 

The acreage allocated to Wilderness/National Monument LUDs would remain 

constant under all alternatives. The amount of acreage allocated to Mostly Natural 

LUDs would increase under Alternatives 1 and 2. The largest increase would occur 

under Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing 

from 31 percent under Alternative 5 (No Action) to 48 percent under Alternative 1, 

with a commensurate reduction in development LUDs (Table 3.23-37). Alternatives 

4 and 7 would increase the acreage in development LUDs. Development LUDs 

would account for 32 percent and 33 percent under Alternatives 4 and 7, 

respectively, compared to 21 percent under Alternative 5. 

Total suitable acres would range from 2 percent under Alternative 1 to 10 percent 

under Alternative 7, compared to 6 percent of the total community use area under 

Alternative 5 (No Action) and Alternative 6 (Proposed Action). 

Economy 

Metlakatla could be affected primarily by changes in commercial fishing, timber 

processing, and subsistence opportunities. 

Commercial fisheries employment is not likely to be affected under any of the 

alternatives. As noted above, the two sawmills in Metlakatla are presently idle and 

not expected to re-open. Alternatives 1 and 2 would provide sufficient volume to 

support the existing Southeast Alaska sawmills operating at their current production 

levels. The sawmills in Metlakatla would be unlikely to re-open under these 

alternatives. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 75 

percent of the total edible pounds of subsistence resources harvested by Metlakatla 

households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for 75 percent of per capita subsistence harvest in 

Metlakatla in 1987. 

The 1988 TRUCS study found that deer account for 15 percent of the total edible 

pounds of subsistence resources harvested by Metlakatla households (Kruse and 

Frazier 1988). Deer accounted for 15 percent of per capita subsistence harvest by 

Metlakatla residents in 1987 (ADF&G 2006). 
 Environment and Effects 3 

Final EIS 3-649 Subregional Overview and Communities 

The majority of deer harvest by Metlakatla residents occurs in the vicinity of the 

community in GMU 1A and on north Prince of Wales Island in GMU 2. Deer harvest 

in GMU 1A generally declined from 1997 to 2004, with the number of hunters and 

hunter effort also decreasing over this period (ADF&G 2005). Deer harvest in GMU 

2 generally increased between 1997 and 2000 and subsequently declined between 

2001 and 2004. The average number of days required to harvest a deer, however, 

remained constant across the entire period (ADF&G 2005). As noted above, the 

human population of Metlakatla increased from 1970 to 1990, declined from 1990 to 

2000, and declined a further estimated 2 percent from 2000 to 2005. Metlakatla had 

an estimated population of 1,342 in 2005. 

The majority (70 percent) of deer harvest by Metlakatla residents takes place in 

three WAAs located in the vicinity of the community (WAAs 101, 202, and 405) 

(Table 3.23-38). Metlakatla residents account for 100 percent of rural harvest in 

these WAAs and from 33 percent to 90 percent of total harvest. The other WAA 

identified as important to Metlakatla residents in Table 3.23-38, is located on north 

Prince of Wales Island. Metlakatal residents account for just 2 percent of rural 

harvest in this area. About 60 percent of the combined harvest in these WAAs is by 

non-rural hunters, suggesting that there is a harvest buffer that could be restricted, if 

necessary, before restrictions are placed on rural harvests. 

Table 3.23-38 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 1954 

Habitat Capability, for the WAAs where Metlakatla Residents Obtain Approximately 75% of 

their Average Annual Deer Harvest* 

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA

Metlakatla 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

101 16 16 99 94 94 89 87 86 86 86 85 

202 8 8 12 0 0 0 0 0 0 0 0 

405 3 3 31 83 80 74 73 73 74 73 71 

1529 3 122 226 73 63 61 60 56 59 59 50 

*Calculated based on harvest where location is known 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, should be able to provide 

sufficient habitat capability for deer hunted in the Metlakatla community use area by 

Metlakatla residents, all rural hunters, and all hunters in both the long term and short 

term. 

In summary, use of most subsistence resources by Metlakatla residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. The 

risks of this occurring are greatest under Alternative 7 because of its overall 

emphasis on Development LUDs, and lower under the other six alternatives. The 

risk of hunting restrictions would be reduced somewhat, through more intensive 

management (e.g., thinning) of the existing and future closed-canopy, young-growth 

forests in this area. The two WAAs of highest importance to Metlakatla hunters 

have existing open and total road densities ranging from less than 0.1 to 0.8 mile 

per square mile (for all ownerships combined). Long-term (100+ years) road 

development would vary by alternative and would result in estimated maximum total 

road densities ranging from 0.2 to 2.3 miles per square mile in these WAAs under 
3 Environment and Effects

Subregional Overview and Communities 3-650 Final EIS

Alternative 1, to 0.5 to 2.3 miles per square mile in these WAAs under Alternative 7 

(for all ownerships combined); however, the contribution of Tongass lands to these 

projected road densities is relatively small. 

Meyers Chuck is a small fishing village on the northwest tip of Cleveland Peninsula, 

40 miles northwest of Ketchikan. According to the 2000 Census, Meyers Chuck had a 

2000 population of 21, none of whom were Alaska Native (U.S. Census Bureau 2001). 

Beginning as a protected anchorage for fishing vessels, Meyers Chuck grew with the 

building of a cannery in Union Bay in 1916. Postal service began in 1922. Fishing and 

fish processing, and support services sustained the community until the mid-1900s. 

Fishing and fish processing are still the basic sources of income in the community. 

Meyers Chuck’s population was the same in 1990 as it was in 1970, but declined by 

16 residents, or 43 percent, between 1990 and 2000. The population declined by a 

further 6 people or 29 percent between 2000 and 2005. Total estimated population 

was 11 in Meyers Chuck in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 37 50 37 21 15 11 

Source: USDA Forest Service, 1997a; U.S. Census Bureau, 2001; Alaska DOL, 2007a

The Meyers Chuck economy is primarily based on fishing with five residents (25 

percent of the population) holding commercial fishing licensees. Due to the 

relatively few cash opportunities, many residents depend on subsistence activities 

(Alaska DCED, 2002). 

Employment by industry data for Meyers Chuck is not included because it was 

based on a very small sample size and may not be a good indicator of the economy 

as a whole. The 2000 U.S. Census identified 3 people as employed in a potential 

workforce of 13 residents. While no adults in Meyers Chuck were identified as 

unemployed and seeking work in 2000, 77 percent of the population was identified 

as unemployed and not seeking work. Median household income was $64,375 

compared to a regional median of $44,118 (Alaska DCED, 2002). 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Meyers Chuck is part of the Cleveland Peninsula community group (see Table 3.23-

6). Detailed employment data are available for this community group by economic 

sector for 1990, 1995, and 2000 in the planning record. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Meyers 

Chuck in their local day-to-day work, recreational, and subsistence activities is 

shown on Figure 3.23-19. This area contains 380,308 acres of National Forest 

System land (among other land ownerships). Table 3.23-39 shows how the land 

within this community use area would be distributed among the LUD groups by 

alternative. The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 30 percent of the total acreage within the 

Meyers Chuck community use area. Alternatives 5 and 6 would not have a 

significant effect on existing LUD allocations in the community use area because the 

acreage by LUD group would remain the same as under the existing Forest Plan. 

The acreage allocated to Wilderness/National Monument LUDs would remain 

constant under all alternatives. The amount of acreage allocated to Mostly Natural 

LUDs would increase under Alternatives 1 through 3. The largest increase would 

Meyers Chuck 
 Environment and Effects 3 

Final EIS 3-651 Subregional Overview and Communities 

Figure 3.23-19 

Meyers Chuck’s Community Use Area 

Table 3.23-39 

LUD Groups in Meyers Chuck’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 0 2,222 11,711 56,183 31,849 31,259 78,597

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 48,596 48,596 48,596 48,596 48,596 48,596 48,596

Mostly Natural 329,712 324,174 281,769 134,504 214,661 212,167 89,166

Moderate Development 0 2,191 19,138 69,814 33,310 32,295 92,573

Intensive Development 0 3,348 28,805 125,413 81,742 85,251 147,974

Total 378,308 378,308 378,308 378,327 378,308 378,308 378,308 1

 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative. 
3 Environment and Effects

Subregional Overview and Communities 3-652 Final EIS

occur under Alternatives 1, with the acreage allocated to Mostly Natural LUDs 

increasing from 56 percent under Alternative 5 (No Action) to 87 percent, with a 

commensurate reduction in development LUDs (Table 3.23-39). Alternatives 4 and 

7 would increase the acreage in development LUDs. Development LUDs would 

account for 52 percent and 64 percent under Alternatives 4 and 7 compared to 30 

percent under Alternative 5. 

Total suitable acres would range from no acreage under Alternative 1 to 21 percent 

under Alternative 7, compared to 8 percent of the total community use area under 

Alternative 5 (No Action) and Alternative 6 (Proposed Action). 

Economy 

Meyers Chuck is primarily a fishing community and would be primarily influenced by 

changes in fishing. Commercial fishing is not likely to be affected under any of 

the alternatives. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 80 

percent of the total edible pounds of subsistence resources harvested by Meyers 

Chuck households (Kruse and Frazier, 1988). Marine resources (fish and marine 

invertebrates) accounted for the majority (83 percent) of per capita subsistence 

harvest in Meyers Chuck in 1987. 

The 1988 TRUCS study found that deer account for 5 percent of the total edible 

pounds of subsistence resources harvested by Meyers Chuck households (Kruse 

and Frazier, 1988). Deer accounted for 5 percent of per capita subsistence harvest 

by Meyers Chuck residents in 1987 (ADF&G 2006). 

The WAAs used by Meyers Chuck residents for hunting deer lie within GMUs 1A, 2, 

and 4. Meyers Chuck had an estimated population of 15 in 2005 and this is 

reflected in the small total number of deer harvested by community residents (Table 

3.23-40). Four WAAs accounted for more than 75 percent of the annual average 

harvest by Meyers Chuck residents from 1996 to 2002. The WAA located in GMU 4 

(3308) is located outside the Meyers Chuck community use area and was only 

hunted in one year. This WAA is not considered further in this analysis. 

Deer harvest in GMU 1A generally declined from 1997 to 2004, with the number of 

hunters and hunter effort also decreasing over this period (ADF&G 2005). Deer 

harvest in GMU 2 generally increased between 1997 and 2000 and subsequently 

declined between 2001 and 2004. The average number of days required to harvest 

a deer, however, remained constant across the entire period (ADF&G 2005). 

Meyers Chuck residents take almost half (49 percent) of their deer from three WAAs 

(1003, 614, and 1319). These WAAs would each be affected under the alternatives, 

with the greatest effects occurring under Alternatives 4 and 7 (Table 3.23-40). 

In summary, use of most subsistence resources (fish and marine invertebrates) by 

Meyers Chuck residents is not expected to be affected under any of the alternatives. 

Subsistence deer harvest patterns would be most likely to be affected under 

Alternative 7, which allocates the largest share of WAAs used by Meyers Chuck 

residents to development LUDs. 
 Environment and Effects 3 

Final EIS 3-653 Subregional Overview and Communities 

Table 3.23-40 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 

1954 Habitat Capability, for the WAAs where Meyers Chuck Residents Obtain 

Approximately 75% of their Average Annual Deer Harvest*

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed as 

a Percent of the 1954 Habitat Capability 

WAA

Meyers 

Chuck 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

1003 4 17 61 66 54 53 53 49 51 52 47 

614 2 4 8 98 98 98 98 72 98 98 70 

3308 2 98 158 66 64 59 57 53 56 57 51 

1319 2 177 220 74 69 67 66 59 64 64 54 

*Calculated based on harvest where location is known. 

Naukati Bay is a town, approximately 6.5 square miles in size, located on the 

northwest coast of Prince of Wales Island. According to the 2000 Census, Naukati 

Bay had a 2000 population of 135, with Alaska Natives comprising 10 percent of the 

total (U.S. Census Bureau 2001). 

The U.S. Coast and Geodetic Survey named the area “Naukatee Nay” in 1904 after 

the local Native name. Naukati Bay was first developed as a logging camp, but in 

1991 an area approximately a mile from the camp was opened by the State 

Department of Natural Resources as a land disposal site for homesteaders (Alaska 

DCED 2006). 

The population of Naukati Bay increased by 42 people or 45 percent between 1990 

and 2000. The population declined by 29 people or 21 percent between 2000 and 

2005. Total estimated population was 129 in Naukati Bay in 2006 (Alaska DOL 

2007a). 

Year 1990 2000 2005 2006 

Population 93 135 106 129 

Source: USDA Forest Service, 1997a; U.S. Census Bureau 2001; Alaska DOL, 2007a 

The Naukati Bay economy is heavily dependent on the timber industry and 

employment is primarily seasonal. The Naukati Logging camp provides log transfer 

services for several smaller camps on Prince of Wales Island (Alaska DCED 2002). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 29 percent of the labor force in 

Naukati Bay was identified as unemployed and seeking work in 2000, compared to 

7 percent for Southeast Alaska as a whole. Median household income was 

$27,500, compared to a regional median of $44,118 (Alaska DCED 2002). 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Naukati Bay is located in the Thorne Bay Ranger District and is part of the North 

Prince of Wales community group (see Table 3.23-6). Detailed employment data 

are available for this community group by economic sector for 1990, 1995, and 2000 

in the planning record. Wood products employment in the North Prince of Wales 

community group declined by 186 jobs or 69 percent between 1990 and 1999. 

Wood products employment accounted for 83 jobs or 23 percent of total 

employment in this community group in 1999. 

Naukati Bay 
3 Environment and Effects

Subregional Overview and Communities 3-654 Final EIS

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 17 44 

Construction 2 5 

Manufacturing 0 0 

Wholesale Trade 0 0 

Retail Trade 2 5 

Transportation, Warehousing & Utilities 0 0 

Information 2 5 

Finance, Insurance, Real Estate, Rental & Leasing 0 0 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

2 5 

Education, Health & Social Services 9 23 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

3 8 

Other Services (Except Public Admin) 0 0 

Public Administration 2 5 

Total Employment 39 100 

Source: Alaska DCED 2002 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Naukati 

Bay in their local day-to-day work, recreational, and subsistence activities is shown 

on Figure 3.23-20. This area contains 1,109,349 acres of National Forest System 

land (among other land ownerships). Table 3.23-41 shows how the lands within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 48 percent of the total acreage within the 

Naukati Bay community use area. Alternatives 5 and 6 would not have a significant 

effect on existing LUD allocations in the community use area because the acreage 

by LUD group would remain the same as under the existing Forest Plan. The 

acreage allocated to Wilderness/National Monument LUDs would remain constant 

under all alternatives. The amount of acreage allocated to Mostly Natural LUDs 

would increase under Alternatives 1 through 3. The largest increase would occur 

under Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing 

from 45 percent under Alternative 5 (No Action) to 63 percent under Alternative 1, 

with a commensurate reduction in development LUDs (Table 3.23-41). Alternatives 

4 and 7 would increase the acreage in development LUDs. Development LUDs 

would account for 55 percent and 69 percent under Alternatives 4 and 7, 

respectively, compared to 48 percent under Alternative 5. 

Total suitable acres would range from 15 percent under Alternative 1 to 28 percent 

under Alternative 7, compared to 19 percent of the total community use area under 

Alternative 5 (No Action). 

Economy 

Naukati Bay is primarily a logging community and as such will be directly affected by 

the amount of logging opportunities on north Prince of Wales Island. Approximately 

6.5 MMBF was under contract in the Thorne Bay Ranger District in August 2006. 

This volume would not be affected under any of the alternatives. These data 

provide an indication of potential impacts, actual impacts would depend on the 

volume that is under contract when the decision is implemented and whether 

potentially affected existing sales were cancelled as part of the decision. 
 Environment and Effects 3 

Final EIS 3-655 Subregional Overview and Communities 

Figure 3.23-20 

Naukati Bay’s Community Use Area 

Table 3.23-41 

LUD Groups in Naukati Bay’s Community Use Area by Alternative 

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 168,053 182,465 193,690 228,053 210,908 204,686 308,479

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 75,923 75,923 75,923 75,923 75,923 75,923 75,923

Mostly Natural 695,124 615,063 556,587 423,984 500,059 509,065 268,147

Moderate Development 95,904 112,411 139,346 168,888 160,274 159,214 265,623

Intensive Development 242,395 305,951 337,493 440,556 373,094 365,146 499,656

Total 1,109,347 1,109,348 1,109,350 1,109,351 1,109,350 1,109,348 1,109,349 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative. 
3 Environment and Effects

Subregional Overview and Communities 3-656 Final EIS

Subsistence 

Naukati Bay was not surveyed by the Tongass Resource Use Cooperative Survey, 

and there are no baseline subsistence data for this community. No significant effect 

on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. Marine resources (fish and marine invertebrates) 

accounted for 73 percent of per capita subsistence harvest in Naukati Bay in 1987. 

Deer accounted for 19 percent of per capita subsistence harvest by Naukati Bay 

residents in 1988 (ADF&G 2006). 

Naukati Bay residents harvest deer almost entirely on Prince of Wales Island, which 

is included in GMU 2. Deer harvest and hunter effort in GMU 2 generally increased 

during 1997-2000 and subsequently declined during 2000 to 2004; however, no 

change has been noted in the average number of hunter-days required to harvest a 

deer (ADF&G 2005). As noted above, Naukati Bay’s human population decreased 

by an estimated 21 percent between 2000 and 2005. 

Residents of Naukati Bay harvest the majority (78 percent) of their deer from three 

WAAs on north Prince of Wales Island (1422, 1527, and 1529). As shown in Table 

3.23-42, the Naukati Bay portion ranges from 4 percent to 28 percent of the total 

harvest and from 7 percent to 46 percent of the rural hunter harvest in these WAAs. 

About 37 percent of the combined harvest in these WAAs is by non-rural hunters, 

suggesting that there is a harvest buffer that could be restricted, if necessary, before 

restrictions are placed on rural harvests. 

Table 3.23-42 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and 

After 100+ Years of Full Implementation under Each Alternative, Expressed as a 

Percent of 1954 Habitat Capability, for the WAAs where Naukati Bay Residents Obtain 

Approximately 75% of their Average Annual Deer Harvest*

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, 

Expressed as a Percent of the 1954 Habitat Capability 

WAA

Naukati 

Bay 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

1422 53 209 300 60 50 48 47 46 47 47 43 

1527 14 31 50 73 65 61 60 60 59 59 55 

1529 8 122 226 73 63 61 60 56 59 59 50 

*Calculated based on harvest where location is known. 

WAAs 1422, 1527, and 1529 occur in an area with substantial past harvest and, 

therefore, deer habitat capabilities are currently estimated to be considerably below 

1954 levels (Table 3.23-42). Under each of the alternatives, additional harvest 

would occur that would reduce habitat capabilities after 100+ years to 43-50 percent 

of 1954 levels in WAA 1422, 55-65 percent in WAA 1527, and 50-63 percent in 

WAA 1529. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, should be able to provide 

sufficient habitat capability for deer hunted in the Naukati Bay community use area 

by Naukati residents, all rural hunters, and all hunters in the short term. Projected 

deer harvest for all rural hunters and all hunters would exceed 10 percent habitat 

capability, the level that the analysis assumed would provide a reasonably high level 

of hunter success for their effort in the long term. The Final EIS analysis concluded 

that at some point a restriction in hunting might be necessary. 
 Environment and Effects 3 

Final EIS 3-657 Subregional Overview and Communities 

In summary, use of most subsistence resources by Naukati Bay residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. The 

risks of this occurring are greatest under Alternative 7 because of its overall 

emphasis on Development LUDs within the Naukati Bay use area, and lower under 

the other six alternatives. The risk of hunting restrictions would be reduced 

somewhat, through more intensive management (e.g., thinning) of the existing and 

future closed-canopy, young-growth forests in this area. Indirect effects associated 

with increased competition for deer within Naukati Bay’s subsistence use areas 

could also occur under all alternatives due to displacement of hunters from other 

communities due to timber harvest activity. Additional road development under the 

alternatives would improve access but may increase competition with other nonlocal hunters. The level of road development is already relatively high in these 

WAAs. Existing open road densities are 1.0. 0.9, and 0.9 mile per square mile and 

existing total road densities are 1.9, 1.5, and 1.5 miles per square mile in WAAs 

1422, 1527, and 1529, respectively). Long-term (100+ years) road development 

would vary by alternative and would result in estimated maximum total road 

densities ranging from 1.7 to 2.1 mile per square mile in these WAAs under 

Alternative 1, to 1.9 to 2.5 miles per square mile in these WAAs under Alternative 7 

(for all ownerships combined). 

Pelican is a fishing village along Lisianski Inlet on the northwest corner of Chichagof 

Island, located approximately 70 air miles north of Sitka and 70 air miles west of 

Juneau. Part of the community is built on pilings over tideland. A boardwalk serves 

as the town’s main thoroughfare due to lack of flat land for roads. According to the 

2000 Census, Pelican had a 2000 population of 199, with Alaska Natives comprising 

21 percent of the total (U.S. Census Bureau 2001). 

Prior to its settlement in 1938, the Pelican area was used as a safe harbor by 

fishermen and as a hunting, fishing, trapping, and gathering site by Hoonah Tlingit 

groups, who claimed lands on either side of Cross Sound (ADF&G 1994). 

Pelican was incorporated as a second class city in 1943. Pelican employs a fulltime city manager and is governed by a mayor and city council. The community has 

a local Fish and Game Advisory Committee. The Native community, largely Tlingit, 

is represented by a local Tlingit and Haida Community Council. No Native land 

allotments or withdrawals occur in the immediate vicinity of Pelican. Pelican is 

accessible via the Alaska ferry system, as well as floatplane from Juneau or Sitka 

(ADF&G 1994). 

The population of Pelican, which grew by 67 percent between 1970 and 1990, 

decreased by 27 percent between 1990 and 2000. The population continued to 

decline in the first part of this decade, decreasing by 48 people or 29 percent 

between 2000 and 2005. Total estimated population was 106 in Pelican in 2006 

(Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 133 180 222 163 115 106 

Source: USDA Forest Service, 1997a; U.S. Census Bureau, 2001; Alaska DOL, 2007a

The Pelican economy is primarily based on commercial fishing (41 residents hold 

permits) and seafood processing. Pelican Seafoods, the largest employer, operates 

a seafood processing plant, the electric utility, a fuel company, and a store. It was 

purchased by Kaioh Suisan, a Japanese firm, in 1989 and then closed in 1996. It 

was subsequently purchased by Kake Tribal Corporation and re-opened during the 

same year. The plant processes salmon, halibut, sable fish, rockfish, and 

dungenesss crab (Alaska DCED 2002). 

Pelican 
3 Environment and Effects

Subregional Overview and Communities 3-658 Final EIS

There have been low levels of tourism in Pelican for some time but more recently 

with the decline in commercial fishing tourism has begun to play a more important 

role in the local economy (Dugan et al. 2006). Tourism in Pelican is primarily 

focused on sport fishing and marine wildlife viewing charters, with 12 marine 

charters operating out of the town in 2005. The town also serves as a jumping-off 

point for independent travelers accessing nearby wilderness. 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 8 percent of the labor force in 

Pelican was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $48,750, 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 21 26 

Construction 2 2 

Manufacturing 25 31 

Wholesale Trade 0 0 

Retail Trade 3 4 

Transportation, Warehousing & Utilities 7 9 

Information 0 0 

Finance, Insurance, Real Estate, Rental & Leasing 0 0 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

2 2 

Education, Health & Social Services 16 20 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

0 0 

Other Services (Except Public Admin) 0 0 

Public Administration 5 6 

Total Employment 81 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, and 

subsistence use of this community. 

Pelican is part of the North Chichagof community group, which also includes Elfin Cove 

and Hoonah (see Table 3.23-6). Detailed employment data are available for this 

community group by economic sector for 1990, 1995, and 2000 in the planning record. 

Manufacturing and non-federal government were the major employers in the North 

Chichagof community group in 1999, accounting for 34 and 30 percent of total 

employment, respectively. Logging and seafood processing accounted for 24 and 10 

percent of total employment, respectively. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Pelican 

in their local day-to-day work, recreational, and subsistence activities is shown on 

Figure 3.23-21. This area contains 488,851 acres of National Forest System land 

(among other land ownerships). Table 3.23-43 shows how the lands within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs account for less than one percent of the lands in the Pelican 

community use area under Alternative 5 (No Action). The acreage allocated to 

Wilderness/National Monument LUDs would remain constant under all alternatives. 

The main difference between the alternatives is the amount of acres allocated to 

development LUDs. Under Alternatives 4 and 7, approximately 5 percent of the area 

would be allocated to development LUDs, compared to less than 1 percent under 

Alternatives 2, 3, 5, and 6 and zero under Alternative 1. 
 Environment and Effects 3 

Final EIS 3-659 Subregional Overview and Communities 

Figure 3.23-21 

Pelican’s Community Use Area 

Table 3.23-43 

LUD Groups in Pelican’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 0 972 972 8,063 820 972 8,127

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 245,569 245,569 245,569 245,569 245,569 245,569 245,569

Mostly Natural 243,281 240,434 240,430 218,829 240,602 240,425 218,829

Moderate Development 0 0 0 1,729 0 0 1,729

Intensive Development 0 2,848 2,851 22,723 2,679 2,857 22,723

Total 488,851 488,851 488,851 488,851 488,851 488,851 488,851 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative. 
3 Environment and Effects

Subregional Overview and Communities 3-660 Final EIS

Economy 

Pelican is primarily a commercial fishing and seafood processing town. 

Employment within the community is expected to remain stable as long as the 

Pelican Seafoods plant continues to operate. Commercial fishing is not expected to 

be significantly affected under any of the alternatives. 

Subsistence 

In terms of subsistence use, Lisianski Inlet, Icy Strait, northwest Chichagof, and 

Yakobi Island are the most important areas to Pelican. These areas are presently 

legislatively withdrawn from timber harvest as either Wilderness or LUD II or 

allocated to the Mostly Natural LUDs. Therefore, it is unlikely that subsistence use 

in Pelican would be directly affected under any of the alternatives. 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 63 

percent of the total edible pounds of subsistence resources harvested by Pelican 

households (Kruse and Frazier, 1988). Marine resources (fish and marine 

invertebrates) accounted for 64 percent of per capita subsistence harvest in Pelican 

in 1987. 

The 1988 TRUCS study found that deer account for 30 percent of the total edible 

pounds of subsistence resources harvested by Pelican households (Kruse and 

Frazier, 1988). Deer accounted for 30 percent of per capita subsistence harvest by 

Pelican residents in 1987 (ADF&G 2006). 

The WAAs used by Pelican residents for hunting deer lie within Game Management 

Unit (GMU) 4. Deer harvest in GMU 4 is considered very high relative to other 

areas of Southeast Alaska, which is indicative of relatively high deer populations 

(ADF&G 2005). Over 1997-2004, there has been no significant trend in the number 

of deer harvested or in the number of hunters (ADF&G 2005). As noted above, the 

number of residents in Pelican decreased by 29 percent from 2000 to 2005. 

Pelican residents take the majority (94 percent) of their deer from three WAAs on 

northwestern Chichagof Island (3417, 3418, and 3419). As shown in Table 3.23-44, 

these WAAs would not be affected by any of the alternatives because they are in 

wilderness, LUD II areas, or are in other Non-development LUDs. 

Table 3.23-44 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 

1954 Habitat Capability, for the WAAs where Pelican Residents Obtain Approximately 

75% of their Average Annual Deer Harvest*

Average Deer Harvest 

from 1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA

Pelican 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

3418 37 62 70 100 100 100 100 100 100 100 100 

3419 35 35 47 100 100 100 100 100 100 100 100 

3417 28 100 159 100 100 100 100 100 100 100 100 

*Calculated based on harvest where location is known. 
 Environment and Effects 3 

Final EIS 3-661 Subregional Overview and Communities 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, should be able to provide 

sufficient habitat capability for deer hunted in the Pelican community use area by 

Pelican residents, all rural hunters, and all hunters in the short term and long term. 

In summary, use of most subsistence resfources (fish and marine invertebrates) by 

Pelican residents is not expected to be affected under any of the alternatives. In 

addition, subsistence use of deer by Pelican households would not be directly 

affected by any of the alternatives as the areas most heavily used by Pelican. 

Marine resources (fish and marine invertebrates) accounted for 64 percent of per 

capita subsistence harvest in Pelican in 1987. 

Petersburg is located on the northern tip of Mitkof Island across Wrangell Narrows 

from Kupreanof Island. It lies midway between Juneau and Ketchikan, about 120 

miles from either community. According to the 2000 Census, Petersburg had a 

2000 population of 3,224, with Alaska Natives comprising 7 percent of the total (U.S. 

Census Bureau 2001). The community of Kupreanof, with a population of 23 in 

2000, is located less than one mile from Petersburg, on Kupreanof Island. This 

settlement is economically tied to Petersburg, where most residents find 

employment, purchase goods, and attend school (ADF&G 1994). 

Prior to Petersburg’s development by homesteaders and fishermen around 1900, 

Tlingit use of the area occurred at many small settlements (ADF&G 1994). The 

community of Petersburg was founded by Norwegian Peter Buschmann in 1899 and 

incorporated in 1906. More Norwegians followed and settled into a Scandinavianstyle community. Petersburg has a local Fish and Game Advisory Committee, 

which takes an active interest in resource management issues (ADF&G 1994). 

The population of Petersburg, which increased by 57 percent between 1970 and 

1990, increased by less than 1 percent between 1990 and 2000. The population 

decreased by 69 people or 2 percent between 2000 and 2005. Total estimated 

population was 3,129 in Petersburg in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 2,042 2,821 3,207 3,224 3,155 3,129 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a

The Petersburg economy is primarily based on the commercial fishing (469 

residents have commercial fishing permits) and timber industries and, unlike the rest 

of Southeast Alaska, has escaped the severe swings in economic cycles. Estimated 

gross fishing revenues of local residents was almost $22 million in 2000. 

Petersburg is among the top-ranked ports in the United States for quality and value 

of fish landed. The city includes several processors operating cold storage, 

canneries, and custom packing services and the state-run Crystal Lake salmon 

hatchery. Petersburg also provides supplies and services for many of the area 

logging camps. While there is no deep water dock suitable for cruise ships, there is 

independent sportsmen and tourist visitation (Alaska DCED, 2002). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 10 percent of the labor force in 

Petersburg was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $49,028, 

compared to a regional median of $44,118 (Alaska DCED, 2002). 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Petersburg and 

Kupreanof 
3 Environment and Effects

Subregional Overview and Communities 3-662 Final EIS

Petersburg and Kupreanof are part of the Petersburg community group (see Table 

3.23-6). Detailed employment data are available for this community group by 

economic sector for 1990, 1995, and 2000 in the planning record. 

Non-federal government and seafood processing were the main employers in the 

Petersburg community group in 1999, accounting for 25 and 24 percent of total 

employment, respectively. Employment in the wood products sector declined by 93 

percent between 1990 and 1999, with just 5 people employed in this sector in 1999. 

Three sawmills, The Mill, Alaska Fibre, and Southeast Alaska Wood Products, were 

identified in Petersburg in the mill survey conducted for the Forest Service in 2006. 

The mill survey noted that Alaska Fibre sold its primary processing equipment in 

2005, but reportedly has plans to purchase and install new equipment (Juneau 

Economic Development Council 2007). According to the 2006 mill survey, The Mill 

and Southeast Alaska Wood Products had respective installed production capacities 

of 8.5 MMBF and 4.5 MMBF, and together processed approximately 250 MBF in 

2006 and employed 2 people (Juneau Economic Development Council 2007). 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 301 20 

Construction 75 5 

Manufacturing 136 9 

Wholesale Trade 6 0 

Retail Trade 165 11 

Transportation, Warehousing & Utilities 111 7 

Information 60 4 

Finance, Insurance, Real Estate, Rental & Leasing 25 2 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

39 3 

Education, Health & Social Services 268 18 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

128 8 

Other Services (Except Public Admin) 96 6 

Public Administration 118 8 

Total Employment 1,528 100 

Source: Alaska DCED 2002 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of 

Petersburg in their local day-to-day work, recreational, and subsistence activities is 

shown on Figure 3.23-22. This area contains 742,197 acres of National Forest 

System land (among other land ownerships). Table 3.23-45 shows how the lands 

within this community use area would be distributed among the LUD groups by 

alternative. The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for about 40 percent of the total acreage 

within the Petersburg community use area. Alternatives 5 and 6 would not have a 

significant effect on existing LUD allocations in the community use area because the 

acreage by LUD group would remain the same as under the existing Forest Plan. 

The acreage allocated to Wilderness/National Monument LUDs would remain 

constant under all alternatives. The amount of acreage allocated to Mostly Natural 

LUDs would increase under Alternatives 1 through 3. The largest increase would 

occur under Alternative 1, with the acreage allocated to Mostly Natural LUDs 

increasing from 30 percent under Alternative 5 (No Action) to 58 percent under 

Alternative 1, with a commensurate reduction in development LUDs (Table 3.23-45). 

Alternatives 4 and 7 would increase the acreage in development LUDs. 
 Environment and Effects 3 

Final EIS 3-663 Subregional Overview and Communities 

Figure 3.23-22 

Petersburg’s Community Use Area 

Table 3.23-45 

LUD Groups in Petersburg’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 37,346 64,756 80,848 99,068 86,229 86,177 115,610

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 223,285 223,285 223,285 223,285 223,285 223,285 223,285

Mostly Natural 432,243 336,442 251,709 170,174 223,095 233,287 125,381

Moderate Development 45,518 100,014 147,536 195,479 162,219 160,680 220,238

Intensive Development 41,151 82,456 119,667 153,259 133,598 124,946 173,300

Total 742,197 742,197 742,197 742,198 742,198 742,197 742,205 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative. 
3 Environment and Effects

Subregional Overview and Communities 3-664 Final EIS

Development LUDs would account for 47 percent and 53 percent under Alternatives 

4 and 7, respectively, compared to 40 percent under Alternative 5. 

Total suitable acres would range from 5 percent under Alternative 1 to 16 percent 

under Alternative 7, compared to 12 percent of the total community use area under 

Alternative 5 (No Action) and Alternative 6 (Proposed Action). 

Economy 

Commercial fishing is particularly important to Petersburg. Commercial fisheries 

employment is not likely to be affected under any of the alternatives. Southeast 

Alaska Wood Products had 1.7 MMBF under contract with the Forest Service in 

August 2006. This volume would not be affected under any of the alternatives. 

Approximately 20.6 MMBF is presently under contract in the Petersburg Ranger 

District in August 2006. About 4.6 MMBF of this volume would be affected under 

Alternative 1, which would maintain all Inventoried Roadless Areas on the Tongass 

in a natural condition and not permit timber harvest in these areas. None of the 

other alternatives would affect this volume. These data provide an indication of 

potential impacts, actual impacts would depend on the volume that is under contract 

when the decision is implemented and whether potentially affected existing sales 

were cancelled as part of the decision. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 52 

percent of the total edible pounds of subsistence resources harvested by Petersburg 

households (Kruse and Frazier, 1988). Marine resources (fish and marine 

invertebrates) accounted for 65 percent of per capita subsistence harvest in 

Petersburg in 1987. 

The 1988 TRUCS study found that deer accounted for 21 percent of the total edible 

pounds of subsistence resources harvested by Petersburg households (Kruse and 

Frazier 1988). Deer accounted for 22 percent of per capita subsistence harvest by 

Petersburg residents in 1987 (ADF&G 2006). 

Petersburg residents harvest deer on and around Mitkof and Kupreanof Islands, with 

the majority of harvest occurring within GMUs 3 and 4. Deer harvest in GMU 3 

declined between 1998-2002 and increased between 2002-2004. The number of 

deer hunters declined between 2000-2002 and slightly increased between 2002-

2004 (ADF&G 2005). Deer harvest in GMU 4 is considered very high relative to 

other areas of Southeast Alaska, which is indicative of relatively high deer 

populations (ADF&G 2005). Over 1997-2004, there has been no significant trend in 

the number of deer harvested or in the number of hunters (ADF&G 2005). As noted 

above, the human population of Petersburg declined by an estimated 2 percent 

between 2000 and 2005. Petersburg had an estimated human population of 3,155 

in 2005. 

Eight WAAs account for the majority (78 percent) of deer harvest by Petersburg 

residents. As shown in Table 3.23-46, the Petersburg portion represents about 

three-quarters of the total and rural hunter harvest in these WAAs. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, should be able to provide 

sufficient habitat capability for deer hunted by Petersburg residents in the short term 

and long term. There was also sufficient habitat capability for deer hunted in the 

Petersburg community use area by all rural hunters in both the short term and long 
 Environment and Effects 3 

Final EIS 3-665 Subregional Overview and Communities 

Table 3.23-46 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 

1954 Habitat Capability, for the WAAs where Petersburg Residents Obtain Approximately 

75% of their Average Annual Deer Harvest* 

Average Deer Harvest from 1996 

to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA

Petersburg 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

2007 143 143 143 79 74 68 67 62 66 65 58 

1905 115 400 400 77 72 67 67 59 66 65 57 

3939 88 114 125 100 100 100 100 100 100 100 100 

1605 52 54 42 76 76 71 64 57 63 63 56 

3938 44 52 102 100 100 100 100 100 100 100 100 

5138 40 47 49 88 79 70 69 64 68 68 59 

5133 36 38 38 98 97 97 96 82 84 85 80 

3940 34 75 77 92 92 92 92 92 92 92 92 

*Calculated based on harvest where location is known. 

term. Projected deer harvest for all hunters would exceed 10 percent habitat 

capability, the level that the analysis assumed would provide a reasonably high level 

of hunter success for their effort, in the long term. The Final EIS analysis concluded 

that at some point a restriction in hunting might be necessary. 

In summary, use of most subsistence resources by Petersburg residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer in some of the WAAs hunted by Petersburg 

residents may be affected to the point that some restriction in hunting might be 

necessary over the long term, even under Alternative 1. The risks of this occurring 

are greatest under Alternative 7 because of its general lack of Non-Development 

LUDs within the Petersburg use area, and lower under the other six alternatives. 

The risk of hunting restrictions would be reduced somewhat, through more intensive 

management (e.g., thinning) of the existing and future closed-canopy, young-growth 

forests in this area. Indirect effects associated with increased competition for deer 

within Petersburg’s subsistence use areas could also occur under all alternatives 

due to displacement of hunters from other communities due to timber harvest 

activity. Additional road development under the alternatives would improve access 

but may increase competition with other non-local hunters. 

Point Baker is located on the northern tip of Prince of Wales Island, 101 air miles 

northwest of Ketchikan. Point Baker received its name in 1793 from Captain 

George Vancouver. According to the 2000 Census, Point Baker had a 2000 

population of 35, with Alaska Natives comprising 3 percent of the total (U.S. Census 

Bureau 2001). 

Native settlement of the area was already established during Vancouver’s time. 

Tlingits used fish camps at Point Baker to participate in both customary trade and 

subsistence fishing. Commercial fishing at Point Baker began in the early 1900s, 

when the area was used as the site of a floating fish packer. Land sales in Point 

Baker accounted for part of an increase in year-round residents, the majority being 

non-Native (ADF&G 1994). 

Point Baker is accessible by floatplane and skiff. Point Baker is not an incorporated 

city, nor is it within any other local government jurisdiction. It is not part of any 

Point Baker 
3 Environment and Effects

Subregional Overview and Communities 3-666 Final EIS

Native organization and has no traditional council. The town is not recognized 

under the Alaska Native Claims Settlement Act. Residents of Point Baker are 

members of the Sumner Strait Fish and Game Advisory Committee (ADF&G 1994). 

The population of Point Baker, which decreased by about a half between 1970 and 

1990, was fairly constant between 1990 and 2000. The population decreased by an 

estimated 13 people or 37 percent between 2000 and 2005. Total estimated 

population was 16 in Point Baker in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 80 90 39 35 22 16 

Source: USDA Forest Service, 1997a; U.S. Census Bureau, 2001; Alaska DOL, 2007a

The Point Baker economy is heavily dependent on the fishing industry, with three 

quarters of the population holding commercial fishing permits (Alaska DCED 2002). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. These data are an extrapolation based on 

information from a sample of residents. An extrapolation of a small sample may 

have inaccuracies but should provide a general indication of the distribution of 

employment. The 2000 U.S. Census estimated that 15 residents are employed. 

While no adults in Point Baker were identified as unemployed and seeking work in 

2000, 58 percent of the population was identified as not employed and not seeking 

work. Median household income was $28,000, compared to a regional median of 

$44,118 (Alaska DCED 2002). 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 6 40 

Construction 0 0 

Manufacturing 0 0 

Wholesale Trade 0 0 

Retail Trade 2 13 

Transportation, Warehousing & Utilities 0 0 

Information 0 0 

Finance, Insurance, Real Estate, Rental & Leasing 0 0 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

0 0 

Education, Health & Social Services 5 33 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

0 0 

Other Services (Except Public Admin) 0 0 

Public Administration 2 13 

Total Employment 15 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Point Baker is part of the North Prince of Wales community group (see Table 3.23-

6). Detailed employment data are available for this community group by economic 

sector for 1990, 1995, and 2000 in the planning record. Wood products employment 

in the North Prince of Wales community group declined by 186 jobs or 69 percent 

between 1990 and 1999. Wood products employment accounted for 83 jobs or 23 

percent of total employment in this community group in 1999. 
 Environment and Effects 3 

Final EIS 3-667 Subregional Overview and Communities 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Point 

Baker in their local day-to-day work, recreational, and subsistence activities is 

shown on Figure 3.23-23. This area contains 842,636 acres of National Forest 

System land (among other land ownerships). Table 3.23-47 shows how the lands 

within this community use area would be distributed among the LUD groups by 

alternative. The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 43 percent of the total acreage within the 

Point Baker community use area. Alternatives 5 and 6 would not have a significant 

effect on existing LUD allocations in the community use area because the acreage 

by LUD group would remain the same as under the existing Forest Plan. The 

acreage allocated to Wilderness/National Monument LUDs would remain constant 

under all alternatives. The amount of acreage allocated to Mostly Natural LUDs 

would increase under Alternatives 1 through 3. The largest increase would occur 

under Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing 

from 48 percent under Alternative 5 (No Action) to 64 percent under Alternative 1, 

with a commensurate reduction in development LUDs (Table 3.23-47). Alternatives 

4 and 7 would increase the acreage in development LUDs. Development LUDs 

would account for 52 percent and 61 percent under Alternatives 4 and 7, 

respectively, compared to 43 percent under Alternative 5. 

Total suitable acres would range from 13 percent under Alternative 1 to 25 percent 

under Alternative 7, compared to 17 percent of the total community use area under 

Alternative 5 (No Action) and Alternative 6 (Proposed Action). 

Economy 

Commercial fisheries and subsistence use are important to Point Baker. 

Commercial fisheries employment is not likely to be affected under any of the 

alternatives. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 59 

percent of the total edible pounds of subsistence resources harvested by Point Baker 

households (Kruse and Frazier, 1988). Marine resources (fish and marine 

invertebrates) accounted for 79 percent of per capita subsistence harvest in Point 

Baker in 1996. 

The 1988 TRUCS study found that deer account for 27 percent of the total edible 

pounds of subsistence resources harvested by Point Baker households (Kruse and 

Frazier 1988). Deer accounted for 16 percent of per capita subsistence harvest by 

Point Baker residents in 1996 (ADF&G 2006). 

Point Baker residents harvest deer on north Prince of Wales Island and Kupreanof 

Island, which are included in GMUs 2 and 3, respectively. Deer harvest and hunter 

effort in GMU 2 generally increased during 1997-2000 and subsequently declined 

during 2000-2004; however, no change has been noted in the average number of 

hunter-days required to harvest a deer (ADF&G 2005). Deer harvest in GMU 3 

declined between 1998-2002 and increased between 2002-2004. The number of 

deer hunters declined between 2000-2002 and slightly increased between 2002-

2004 (ADF&G 2005). Point Baker had a total estimated population of 22 people in 

2005, 13 fewer people than in 2000. 
3 Environment and Effects

Subregional Overview and Communities 3-668 Final EIS

Figure 3.23-23 

Point Baker’s Community Use Area 

Table 3.23-47 

LUD Groups in Point Baker’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 112,293 123,969 130,724 161,202 146,330 141,600 211,416

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 78,757 78,757 78,757 78,757 78,757 78,757 78,757

Mostly Natural 542,684 481,817 446,696 322,317 404,971 411,024 247,568

Moderate Development 47,608 57,686 78,121 98,590 93,354 94,718 133,755

Intensive Development 173,586 224,376 239,064 342,975 265,556 258,138 382,556

Total 842,635 842,636 842,638 842,638 842,638 842,636 842,636 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.
 Environment and Effects 3 

Final EIS 3-669 Subregional Overview and Communities 

Residents of Point Baker harvest the majority (72 percent) of their deer from two 

WAAs on north Prince of Wales Island (1529) and Kupreanof Island (5134). As 

shown in Table 3.23-48, the Point Baker portion ranges from 6 percent to 19 percent 

of the total harvest and from 3 percent to 16 percent of the rural hunter harvest in 

these WAAs. About 41 percent of the combined harvest in these WAAs is by nonrural hunters, suggesting that there is a harvest buffer that could be restricted, if 

necessary, before restrictions are placed on rural harvests. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, selected alternative 

(Alternative 11 in the 1997 Forest Plan EIS) should be able to provide sufficient 

habitat capability for deer hunted by Point Baker residents in the short term and long 

term. There was also sufficient habitat capability for deer hunted in the Point Baker 

community use area by all rural hunters in both the short term and long term. 

Projected deer harvest for all hunters would exceed 10 percent habitat capability, 

the level that the analysis assumed would provide a reasonably high level of hunter 

success for their effort, in the long term. The Final EIS analysis concluded that at 

some point a restriction in hunting might be necessary. 

In summary, use of most subsistence resources by Point Baker residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer on Prince of Wales Island may be affected to the 

point that some restriction in hunting might be necessary over the long term, even 

under Alternative 1. The risks of this occurring are greatest under Alternative 7 

because of its general emphasis on Development LUDs within the Point Baker use 

area, and lower under the other six alternatives. The risk of hunting restrictions 

would be reduced somewhat, through more intensive management (e.g., thinning) of 

the existing and future closed-canopy, young-growth forests in this area. Indirect 

effects associated with increased competition for deer within Point Baker’s 

subsistence use areas on Prince of Wales Island could also occur under all 

alternatives due to displacement of hunters from other communities due to timber 

harvest activity. Additional road development under the alternatives would improve 

access but may increase competition with other non-local hunters. The level of road 

development is already relatively high in one of the WAAs most used by Point Baker 

residents (1529), with an existing open and total road densities of 0.9 and 1.5 miles 

per square mile, respectively. Road densities are very low in the other WAAs (5014 

and 5134) important to Point Baker subsistence deer hunters. Long-term (100+ 

years) road development would vary by alternative and would result in estimated 

Table 3.23-48 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 

1954 Habitat Capability, for the WAAs where Point Baker Residents Obtain Approximately 

75% of their Average Annual Deer Harvest*

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA 

Point 

Baker 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

1529 7 122 226 73 63 61 60 56 59 59 50 

5134 6 33 39 92 92 92 89 83 87 87 83 

5014 2 4 4 96 96 96 96 70 75 75 64 

*Calculated based on harvest where location is known.
3 Environment and Effects

Subregional Overview and Communities 3-670 Final EIS

maximum total road densities ranging from 0.1 to 1.7 mile per square mile in these 

three WAAs under Alternative 1, to 0.3 to 2.5 miles per square mile in these WAAs 

under Alternative 7 (for all ownerships combined). 

Port Alexander is located on the southern tip of Baranof Island about 85 miles south 

of Sitka. According to the 2000 Census, Port Alexander had a 2000 population of 

81, with Alaska Natives comprising 4 percent of the total (U.S. Census Bureau 

2001). 

Port Alexander was named in 1849 by the governor of the Russian American 

colonies. In 1913, salmon trollers discovered the rich fishing grounds in the area, 

and two floating processors arrived soon after. By 1916, there was a fishing supply 

store, a shore station, and a bakery at Port Alexander. During the 1920s and 1930s, 

a prosperous fishing fleet evolved, and houses, stores, restaurants, and a school 

were constructed. The 1940s and 1950s saw a steep decline in Port Alexander’s 

population. Today, people choose Port Alexander as a home because of its 

independent, subsistence lifestyle, and commercial fishing opportunities, as well as 

its remote setting. There are no roads in Port Alexander; travel within the 

community is by skiff, boardwalks, and footpaths (ADF&G 1994). The community 

has a local Fish and Game Advisory Committee. 

Port Alexander’s population, which was three times larger in 1990 than it was in 

1970, decreased by 32 percent (39 residents) between 1990 and 2000. The 

population stayed relatively constant between 2000 and 2005, decreasing by an 

estimated 6 people over this period. Total estimated population was 64 in Port 

Alexander in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 36 86 119 81 75 64 

Source: USDA Forest Service 1997a; U.S. Census Bureau 2001; Alaska DOL 2007a

The economy of Port Alexander is largely based on commercial fishing and 

subsistence use of marine and forest resources. More than 40 percent of the 

population hold commercial fishing permits (35 residents). The City, the school, and 

post office provide the only full time employment in the area (Alaska DCED 2002). 

Employment by industry data for Port Alexander is not included since it was based 

on a very small sample size and may not be a good indicator of the economy as a 

whole. The 2000 U.S. Census identified 29 residents of Port Alexander as being 

employed out of a potential work force (aAge 16+) of 48. Approximately 9 percent of 

the labor force in Port Alexander was identified as unemployed and seeking work in 

2000, compared to 7 percent for Southeast Alaska as a whole. Median household 

income was $31,563 compared to a regional median of $44,118 (Alaska DCED 

2002). 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Port Alexander is part of the Kuiu Island community group (see Table 3.23-6). 

Detailed employment data are available for this community group by economic 

sector for 1990, 1995, and 2000 in the planning record. Logging employment 

accounted for 91 percent of total employment (77 jobs) in this community group in 

1990. There was no logging employment in this community group in 1999, and the 

non-federal government sector accounted for 13 of the 14 recorded jobs. 

Port Alexander 
 Environment and Effects 3 

Final EIS 3-671 Subregional Overview and Communities 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Port 

Alexander in their local day-to-day work, recreational, and subsistence activities is 

shown on Figure 3.23-24. This area contains 86,828 acres of National Forest 

System land (among other land ownerships). Table 3.23-49 shows how the lands 

within this community use area would be distributed among the LUD groups by 

alternative. The LUD groups are explained in the introduction to Chapter 3. 

None of Port Alexander’s community use area is presently allocated to 

development LUDs and this would be the case under all the alternatives evaluated 

in this EIS. There would be no change in the LUD allocation for this community 

under any of the alternatives. 

Economy 

Port Alexander is primarily a commercial fishing town. Commercial fishing and 

subsistence use are important to the community. Commercial fishing is not 

expected to be significantly affected under any of the alternatives. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 

55 percent of the total edible pounds of subsistence resources harvested by Port 

Alexander households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for 55 percent of per capita subsistence harvest in Port 

Alexander in 1987. 

Deer account for 36 percent of the total edible pounds of subsistence resources 

harvested by Port Alexander households (Kruse and Frazier, 1988). Deer accounted 

for 35 percent of per capita subsistence harvest by Port Alexander residents in 1987 

(ADF&G 2006). 

Port Alexander residents take the majority (95 percent) of their deer from one WAA 

(3734) on the south end of Baranof Island. This WAA is located within GMU 4. 

Deer harvest in GMU 4 is considered very high relative to other areas of Southeast 

Alaska, which is indicative of relatively high deer populations (ADF&G 2005). Over 

1997-2004, there has been no significant trend in the number of deer harvested or in 

the number of hunters (ADF&G 2005). Port Alexander’s human population declined 

slightly between 2000 and 2005. 

As shown in Table 3.23-50, WAA 3734 would not be affected under any of the 

alternatives. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 Forest 

Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are similar to the 

four highest harvest alternatives in this EIS, should be able to provide sufficient 

habitat capability for deer hunted in the Port Alexander community use area by Port 

Alexander residents, all rural hunters, and all hunters in the short term and long term. 
3 Environment and Effects

Subregional Overview and Communities 3-672 Final EIS

Figure 3.23-24 

Port Alexander’s Community Use Area 

Table 3.23-49 

LUD Groups in Port Alexander’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 0 0 0 0 0 0 0 

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 17,972 17,972 17,972 17,972 17,972 17,972 17,972

Mostly Natural 68,856 68,856 68,856 68,793 68,856 68,856 68,856

Moderate Development 0 0 0 0 0 0 0

Intensive Development 0 0 0 63 0 0 0

Total 86,828 86,828 86,828 86,828 86,828 86,828 86,828 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative. 
 Environment and Effects 3 

Final EIS 3-673 Subregional Overview and Communities 

Table 3.23-50 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 

1954 Habitat Capability, for the WAAs where Port Alexander Residents Obtain 

Approximately 75% of their Average Annual Deer Harvest*

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA 

Port 

Alexander 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

3734 38 74 85 100 100 100 100 100 100 100 100 

*Calculated based on harvest where location is known. 

In summary, use of most subsistence resources (fish and marine invertebrates) by 

Port Alexander residents is not expected to be affected under any of the 

alternatives. In addition, subsistence use of deer by Port Alexander households 

would not be directly affected by any of the alternatives as the area most heavily 

used by Port Alexander residents is in Non-development LUDs. It is also unlikely 

that Port Alexander residents would be affected by increased competition or access 

because of the limited access and the lack of activities under the alternatives in this 

area. 

Port Protection, located on the northern end of Prince of Wales Island in a quiet bay 

facing Sumner Strait, is only accessible by air and water. The nearby logging camp 

site at Labouchere Bay, however, is a roaded port. The community’s setting along 

the waterfront of the cove requires skiff travel for most purposes (ADF&G 1994). 

Port Protection is not an incorporated city, nor is it within any local government 

jurisdiction. Residents of Port Protection are members of the Sumner Strait Fish 

and Game Advisory Committee (ADF&G 1994). According to the 2000 Census, 

Port Protection had a 2000 population of 63, none of whom were Alaska Natives 

(U.S. Census Bureau 2001). 

Port Protection was first reported to the western world by the English explorer 

George Vancouver in 1793. Signs of earlier indigenous occupation of the northern 

shoreline of Prince of Wales Island include stone and wooden stake fish weirs and 

traps, as well as shell middens of edible marine invertebrates (ADF&G 1994). 

A scow served as a fish-buying station until it was replaced in 1946 by a trading 

post. A long float dock accommodated many fishing boats at the post (ADF&G 

1994). 

The population of Port Protection, which increased by approximately 50 percent 

between 1980 and 1990, was approximately the same in 2000 as it was in 1990. 

The population decreased by an estimated 9 people or 14 percent between 2000 

and 2005. Total estimated population was 59 in Port Protection in 2006 (Alaska 

DOL 2007a). 

Year 1980 1990 2000 2005 2006 

Population 40 62 63 54 59 

Source: USDA Forest Service, 1997a; U.S. Census Bureau, 2001; Alaska DOL, 2007a 

The Port Protection economy peaks during the fishing season in summer and fall. 

Fourteen residents hold a commercial fishing permit and some residents provide 

Port Protection 
3 Environment and Effects

Subregional Overview and Communities 3-674 Final EIS

sport fishing charters. Local residents depend on subsistence for year-round support 

(Alaska DCED 2002; 2006). 

The 2000 U.S. Census identified a potential work force of 61 residents and total 

employment of 34. Employment by industry data compiled by the Alaska DCED 

from the 2000 Census are summarized in the table below. These data is 

extrapolated from a sample of the city population. Because the sample size was 

small, the extrapolation is not accurate in detail, but should provide a general 

indication of distribution of employment. While no adults in Port Protection were 

unemployed and seeking work in 2000, 44 percent were unemployed and not 

seeking work. Median household income was $10,938, compared to a regional 

median of $44,118 (Alaska DCED 2002). 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 5 5 

Construction 5 5 

Manufacturing 0 0 

Wholesale Trade 2 2 

Retail Trade 8 9 

Transportation, Warehousing & Utilities 5 5 

Information 4 4 

Finance, Insurance, Real Estate, Rental & Leasing 7 8 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

2 2 

Education, Health & Social Services 27 30 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

3 3 

Other Services (Except Public Admin) 7 8 

Public Administration 16 18 

Total Employment 91 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, and 

subsistence use of this community. 

Port Protection is part of the North Prince of Wales community group (see Table 3.23-

6). Detailed employment data are available for this community group by economic 

sector for 1990, 1995, and 2000 in the planning record. Wood products employment in 

the North Prince of Wales community group declined by 186 jobs or 69 percent 

between 1990 and 1999. Wood products employment accounted for 83 jobs or 23 

percent of total employment in this community group in 1999. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Port 

Protection in their local day-to-day work, recreational, and subsistence activities is 

shown on Figure 3.23-25. This area contains 706,627 acres of National Forest System 

land (among other land ownerships). Table 3.23-51 shows how the lands within this 

community use area would be distributed among the LUD groups by alternative. The 

LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 49 percent of the total acreage within the 

Port Protection community use area. Alternatives 5 and 6 would not have a 

significant effect on existing LUD allocations in the community use area because the 

acreage by LUD group would remain the same as under the existing Forest Plan. 
 Environment and Effects 3 

Final EIS 3-675 Subregional Overview and Communities 

Figure 3.23-25 

Port Protection’s Community Use Area 

Table 3.23-51 

LUD Groups in Port Protection’s Community Use Area by Alternative 

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 108,469 120,049 127,290 135,243 134,817 129,563 180,164

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 17,019 17,019 17,019 17,019 17,019 17,019 17,019

Mostly Natural 474,390 407,001 367,958 320,675 345,451 353,087 245,932

Moderate Development 48,236 58,268 78,759 81,614 81,785 82,807 116,805

Intensive Development 166,980 224,338 242,892 287,321 262,373 253,714 326,871

Total 706,625 706,626 706,628 706,629 706,628 706,626 706,627 1

 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative. 
3 Environment and Effects

Subregional Overview and Communities 3-676 Final EIS

The acreage allocated to Wilderness/National Monument LUDs would remain 

constant under all alternatives. The amount of acreage allocated to Mostly Natural 

LUDs would increase under Alternatives 1 through 3. The largest increase would 

occur under Alternative 1, with the acreage allocated to Mostly Natural LUDs 

increasing from 49 percent under Alternative 5 (No Action) to 64 percent under 

Alternative 1, with a commensurate reduction in development LUDs (Table 3.23-51). 

Alternatives 4 and 7 would increase the acreage in development LUDs. 

Development LUDs would account for 53 percent and 64 percent under Alternatives 

4 and 7 compared to 49 percent under Alternative 5. 

Total suitable acres would range from 17 percent under Alternative 1 to 25 percent 

under Alternative 7, compared to 19 percent under Alternative 5 (No Action). 

Economy 

Port Protection’s economy primarily depends upon commercial fishing. Subsistence 

use is also important in this community. Commercial fisheries employment is not 

likely to be affected under any of the alternatives. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. Marine resources (fish and marine 

invertebrates) accounted for 69 percent of per capita subsistence harvest in Port 

Protection in 1996. 

Deer accounted for 21 percent of per capita subsistence harvest by Port Protection 

residents in 1996 (ADF&G 2006). 

Port Protection residents take the majority (95 percent) of their deer from one WAA 

(1529) on the north end of Prince of Wales Island. This WAA is located within GMU 

2. Deer harvest and hunter effort in GMU 2 generally increased during 1997-2000 

and subsequently declined during 2000-2004; however, no change has been noted 

in the average number of hunter-days required to harvest a deer (ADF&G 2005). 

Port Protection’s population declined slightly between 2000 and 2005. 

As shown in Table 3.23-52, the Port Protection portion of harvest represents about 4 

percent of the total harvest and about 8 percent of the rural hunter harvest in WAA 

1529. About 46 percent of the harvest in this WAA is by non-rural hunters, 

suggesting that there is a harvest buffer that could be restricted, if necessary, before 

restrictions are placed on rural harvests. 

WAA 1529 occurs in an area with substantial past harvest and, therefore, deer habitat 

capabilities are currently estimated to be considerably below 1954 levels (Table 3.23-

52). Under each of the alternatives, additional harvest would occur that would reduce 

habitat capabilities after 100+ years to 50-63 percent of 1954 levels (Table 3.23-52). 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, should be able to provide 

sufficient habitat capability for deer hunted by Port Protection residents and by all 

hunters in the short-term. In the long-term, the affected WAAs may not be able to 

provide deer for all hunters. 
 Environment and Effects 3 

Final EIS 3-677 Subregional Overview and Communities 

Table 3.23-52 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 

1954 Habitat Capability, for the WAAs where Port Protection Residents Obtain 

Approximately 75% of their Average Annual Deer Harvest*

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA 

Port 

Protection 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

1529 10 122 226 73 63 61 60 56 59 59 50 

*Calculated based on harvest where location is known.

In summary, use of most subsistence resources by Port Protection residents (fish 

and marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. The 

risks of this occurring are greatest under Alternative 7 because of its general 

emphasis on Development LUDs within the Port Protection use area, and lower 

under the other six alternatives. The risk of hunting restrictions would be reduced 

somewhat, through more intensive management (e.g., thinning) of the existing and 

future closed-canopy, young-growth forests in this area. Indirect effects associated 

with increased competition for deer within Port Protection’s subsistence use areas 

could also occur under all alternatives due to displacement of hunters from other 

communities due to timber harvest activity. Additional road development under the 

alternatives would improve access but may increase competition with other nonlocal hunters. The level of road development is already relatively high in this WAA. 

Existing open road density is 0.9 mile per square mile and existing total road density 

is 1.5 miles per square mile, respectively (all ownerships combined). Long-term 

(100+ years) road development would vary by alternative and would result in an 

estimated maximum total road density of 1.7 mile per square mile under Alternative 

1, to 2.0 miles per square mile under Alternative 7 (for all ownerships combined). 

Saxman is located on west Revillagigedo Island on the Tongass Highway, about 

three miles south of Ketchikan. According to the 2000 Census, Saxman had a 2000 

population of 431, with Alaska Natives comprising 66 percent of the total (U.S. 

Census Bureau 2001). 

In 1894, Tlingits from the old Cape Fox and Tongass villages chose Saxman as the 

site for a new village in which to locate a government school and a new Presbyterian 

church. The Saxman people are also known as the Cape Fox people or Sanya in 

the earlier ethnographies. Saxman was incorporated in 1929 and was certified by 

the federal government as a second class municipal corporation. Three years later, 

the federal government issued a patent to 365 acres of land to the townsite trustee 

for Saxman (ADF&G 1994). 

When the Ketchikan Gateway Borough was formed in 1963, Saxman was included 

within its boundaries. In 1971 and 1973, respectively, Saxman was recognized and 

then certified as a Native village under the Alaska Native Claims Settlement Act. An 

elected mayor and six city council members constitute the governing body of the 

municipality as organized under state law. The community has a local Fish and 

Game Advisory Committee (ADF&G 1994). 

Saxman 
3 Environment and Effects

Subregional Overview and Communities 3-678 Final EIS

When the Tlingits left their old villages to move to Saxman, they abandoned houses, 

totems, carvings, and other cultural and ceremonial artifacts. In 1938, the Civilian 

Conservation Corps retrieved and brought to Saxman original totems from the 

abandoned villages and cemeteries of Tongass, Cat, and Pennock Islands, and 

Cape Fox. The Totem Park in Saxman has become a major attraction for Ketchikan 

area visitors (ADF&G 1994). 

The population of Saxman, which more than doubled between 1970 and 1990, 

increased by 17 percent between 1990 and 2000. The population decreased by 26 

people or 6 percent between 2000 and 2005. Total estimated population was 422 in 

Saxman in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 135 273 369 431 405 422 

Source: USDA Forest Service, 1997a; U.S. Census Bureau, 2001; Alaska DOL, 2007a

Most employment opportunities for Saxman residents are in the city of Ketchikan. 

The City of Saxman, the Saxman Seaport, and the Cape Fox Corporation provide 

employment for a number of local residents. The Saxman Totem Park with a tribal 

house, a carving center, and a cultural hall for traditional Tlingit dance, has become 

an attraction for Ketchikan area visitors (Alaska DCED 2002). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 26 percent of the labor force in 

Saxman was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $44,375, 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 8 5 

Construction 19 13 

Manufacturing 7 5 

Wholesale Trade 0 0 

Retail Trade 19 13 

Transportation, Warehousing & Utilities 13 9 

Information 3 2 

Finance, Insurance, Real Estate, Rental & Leasing 18 12 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

2 1 

Education, Health & Social Services 16 11 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

17 11 

Other Services (Except Public Admin) 8 5 

Public Administration 21 14 

Total Employment 151 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Saxman is located in the Ketchikan Ranger District and is part of the Ketchikan 

community group (see Table 3.23-6). Detailed employment data are available for 

this community group by economic sector for 1990, 1995, and 2000 in the planning 

record. 
 Environment and Effects 3 

Final EIS 3-679 Subregional Overview and Communities 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Saxman 

in their local day-to-day work, recreational, and subsistence activities is shown on 

Figure 3.23-26. This area contains 1,975,123 acres of National Forest System land 

(among other land ownerships). Table 3.23-53 shows how the lands within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 21 percent of the total acreage within the 

Saxman community use area. Alternatives 5 and 6 would not have a significant 

effect on existing LUD allocations in the community use area because the acreage 

by LUD group would remain the same as under the existing Forest Plan. The 

acreage allocated to Wilderness/National Monument LUDs would remain constant 

under all alternatives. The amount of acreage allocated to Mostly Natural LUDs 

would increase under Alternatives 1 and 2. The largest increase would occur under 

Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing from 31 

percent under Alternative 5 (No Action) to 48 percent under Alternative 1, with a 

commensurate reduction in development LUDs (Table 3.23-53). Alternatives 4 and 7 

would increase the acreage in development LUDs. Development LUDs would 

account for 32 percent and 33 percent under Alternatives 4 and 7, respectively, 

compared to 21 percent under Alternative 5. 

Total suitable acres would range from 2 percent under Alternative 1 to 10 percent 

under Alternative 7, compared to 6 percent of the total community use area under 

Alternative 5 (No Action) and Alternative 6 (Proposed Action). 

Economy 

Saxman, a traditional native community, could be affected primarily by changes in 

recreation and tourism use, commercial fishing, timber processing, and subsistence 

opportunities. 

Approximately 42.8 MMBF was under contract in the Ketchikan Ranger District in 

August 2006. About 75 percent (32.1 MMBF) of this volume could be potentially 

affected under Alternative 1, which would maintain all Inventoried Roadless Areas 

on the Tongass in a natural condition and not permit timber harvest in these areas. 

None of the other alternatives would affect this volume. These data provide an 

indication of potential impacts, actual impacts would depend on the volume that is 

under contract when the decision is implemented and whether potentially affected 

existing sales were cancelled as part of the decision. 

Commercial fisheries employment is not likely to be affected under any of the 

alternatives. Recreation and tourism in Saxman is also unlikely to be affected under 

any of the alternatives. 

Subsistence 

No significant decline in salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 68 

percent of the total edible pounds of subsistence resources harvested by Saxman 

households (Kruse and Frazier, 1988). Marine resources (fish and marine 

invertebrates) accounted for 71 percent of per capita subsistence harvest in Saxman 

in 1987. 
3 Environment and Effects

Subregional Overview and Communities 3-680 Final EIS

Figure 3.23-26 

Saxman’s Community Use Area 

Table 3.23-53 

LUD Groups in Saxman’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 47,897 90,739 111,299 176,699 127,271 124,987 204,834

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 934,620 934,619 934,619 934,616 934,620 934,619 934,619

Mostly Natural 943,733 764,232 665,107 417,910 618,698 615,905 396,436

Moderate Development 36,231 82,362 88,211 187,083 100,554 97,706 199,418

Intensive Development 60,538 193,909 287,185 435,514 321,252 326,892 444,655

Total 1,975,122 1,975,122 1,975,122 1,975,123 1,975,123 1,975,122 1,975,129 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative.
 Environment and Effects 3 

Final EIS 3-681 Subregional Overview and Communities 

The 1988 TRUCS study found that deer accounted for 19 percent of the total edible 

pounds of subsistence resources harvested by Saxman households (Kruse and 

Frazier 1988). Deer accounted for 18 percent of per capita subsistence harvest by 

Saxman residents in 1987 (ADF&G 2006). 

Data were not provided separately for Saxman in the ADF&G deer harvest reports 

for 1996 to 2002. The majority of deer harvest by Saxman residents likely takes 

place in GMU 1A. Deer harvest in GMU 1A generally declined from 1997 to 2004, 

with the number of hunters and hunter effort also decreasing over this period 

(ADF&G 2005). As noted above, the population of Saxman decreased by an 

estimated 6 percent between 2000 and 2005. Saxman had an estimated population 

of 405 residents in 2005. Marine resources (fish and marine invertebrates) 

accounted for 71 percent of per capita subsistence harvest in Saxman in 1987. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, should be able to provide 

habitat capability for deer hunted in the Saxman community use area by Saxman 

residents, all rural hunters, and all hunters in the short term. This alternative was 

also estimated to provide sufficient habitat capability for Saxman residents and all 

rural hunters in the long term. However, projected deer harvest for all hunters was 

estimated to exceed 10 percent habitat capability, the level that the analysis 

assumed would provide a reasonably high level of hunter success for their effort, in 

the long term. 

In summary, use of most subsistence resources by Saxman residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. The 

risks of this occurring are greatest under Alternative 7, and second highest under 

Alternative 4 because of their lower use of Non-Development LUDs compared with 

the other alternatives. Alternatives 1, 2, and 3 would have the lowest risk and 

Alternatives 5 and 6 would be intermediate. 

Located on the west side of Baranof Island, Sitka is the only community in 

Southeast Alaska that fronts the open sea. According to the 2000 Census, Sitka 

had a 2000 population of 8,835, with Alaska Natives comprising 19 percent of the 

total (U.S. Census Bureau 2001). 

Present-day Sitka was originally inhabited by a major tribe of Tlingits who called the 

village “Shee Atika.” Traditionally, the Tlingits used a wide area surrounding the 

community for hunting, fishing, and gathering wild resources. The site became 

“New Archangel” in 1799, the capital of Russian America (ADF&G 1994). 

Sitka became the focal point of Russian fur trade in North America beginning in 

1741. During the mid-1800s, Sitka was the major port on the north Pacific coast, 

with ships calling from many nations. After the purchase of Alaska by the United 

States in 1867, it remained the capital of the Territory until 1906, when the seat of 

government moved to Juneau. During the early 1900s gold mines contributed to its 

growth, and during World War II the town was fortified. After the war, the Bureau of 

Indian Affairs converted some of the buildings to a boarding school for Alaska 

Natives (ADF&G, 1994). The APC pulp mill operated in Sitka from 1959 through 

1993, employing almost 400 people at the time of closure. 

The population of Sitka, which grew by 41 percent between 1970 and 1990, 

increased by just 3 percent between 1990 and 2000, and 1 percent or an estimated 

112 residents between 2000 and 2005. Total estimated population was 8,833 in 

Sitka in 2006 (Alaska DOL 2007a). 

Sitka 
3 Environment and Effects

Subregional Overview and Communities 3-682 Final EIS

Year 1970 1980 1990 2000 2005 2006 

Population 6,109 7,803 8,588 8,835 8,947 8,833 

Source: USDA Forest Service, 1997a; U.S. Census Bureau, 2001; Alaska DOL, 2007a

Sitka has a diversified economy, with tourism, fishing, fish processing, government, 

health care services, transportation, and retail all contributing to its base. A total of 

586 residents hold commercial fishing permits. Cruise ships contribute an estimated 

$11 million dollars to the local economy and residents realized an estimated $20 

million in gross fishing revenue in 2002. Sound Seafood and Seafood Producers 

Co-op are major employers of local residents. Regional health care services and 

the U.S. Forest Service also employ a number of people (Alaska DCED 2002; 

2006). 

A study conducted by the Alaska DOL in 2003 suggested that Sitka’s economy 

appears to have survived the downturn in its economy caused by the pulp mill 

closure, in large part because it has a relatively diversified economy (Gilbertson 

2003). While the community of Sitka does not appear to have been as negatively 

affected by the closure of the pulp mill as some predicted, the effects have been felt 

by the workers who lost their jobs. By 2001, 57 percent of the former pulp mill labor 

force were no longer employed in Alaska, 43 percent had left the State, and 14 

percent were in the State but had left the workforce, most likely retired. Only 25 

percent of the former pulp mill workers were still living and working in Sitka 

(Gilbertson 2003). 

Nature-based tourism in Sitka is less dominated by large cruise ships than in the 

other coastal communities with independent travelers making up a larger share of 

total visitors (Dugan et al. 2006). Multi-day fishing packages and kayaking and 

hunting are popular nature-based tourist activities operating from Sitka. An 

estimated 267,000 cruise ship passengers were scheduled to visit Sitka in 2006. 

There is no deepwater dock in Sitka so cruise ships anchor offshore and transport 

passengers to Sitka on smaller vessels. 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 8 percent of the labor force in 

Sitka was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $51,901, 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 407 9 

Construction 253 6 

Manufacturing 189 4 

Wholesale Trade 54 1 

Retail Trade 476 11 

Transportation, Warehousing & Utilities 245 6 

Information 72 2 

Finance, Insurance, Real Estate, Rental & Leasing 148 3 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

191 4 

Education, Health & Social Services 1,414 32 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

354 8 

Other Services (Except Public Admin) 292 7 

Public Administration 257 6 

Total Employment 4,352 100 

Source: Alaska DCED 2002 
 Environment and Effects 3 

Final EIS 3-683 Subregional Overview and Communities 

Sitka is part of the Sitka community group (see Table 3.23-6). Detailed employment 

data are available for this community group by economic sector for 1990, 1995, and 

2000 in the planning record. 

Wood products employment declined from 404 in 1990 (10 percent of total 

employment) to 0 in 1999 in the Sitka community group. Services, non-federal 

government, and retail trade accounted for 31, 22, and 17 percent of total 

employment in 1999, with recreation-related activities accounting for 10 percent. A 

total of 206,279 cruise ship passengers visited Sitka in 2001, approximately 18 

percent less than the number of passengers in 1996. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Sitka in 

their local day-to-day work, recreational, and subsistence activities is shown on 

Figure 3.23-27. This area contains 425,121 acres of National Forest System land 

(among other land ownerships). Table 3.23-54 shows how the lands within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 22 percent of the total acreage within the 

Sitka community use area. Alternatives 5 and 6 would not have a significant effect 

on existing LUD allocations in the community use area because the acreage by LUD 

group would remain the same as under the existing Forest Plan. The acreage 

allocated to Wilderness/National Monument LUDs would remain constant under all 

alternatives. The amount of acreage allocated to Mostly Natural LUDs would 

increase under Alternatives 1 and 2. The largest increase would occur under 

Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing from 74 

percent under Alternative 5 (No Action) to 96 percent under Alternative 1, with a 

commensurate reduction in development LUDs (Table 3.23-54). Alternatives 4 and 7 

would increase the acreage in development LUDs. Development LUDs would 

account for 59 percent of community use area acres under both of these alternatives 

compared to 22 percent under Alternative 5. 

Total suitable acres would range from no acreage under Alternative 1 to 12 percent 

under Alternative 7, compared to 5 percent of the total community use area under 

Alternative 5 (No Action) and Alternative 6 (Proposed Action). 

Economy 

Commercial fishing, recreation and tourism, and subsistence are important to Sitka 

residents. Commercial fishing is not expected to be significantly affected under any 

of the alternatives. None of the alternatives are expected to affect recreation and 

tourism-related employment in Sitka. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 69 

percent of the total edible pounds of subsistence resources harvested by Sitka 

households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for 68 percent of per capita subsistence harvest in Sitka in 

1996. 
3 Environment and Effects

Subregional Overview and Communities 3-684 Final EIS

Figure 3.23-27 

Sitka’s Community Use Area 

Table 3.23-54 

LUD Groups in Sitka’s Community Use Area by Alternative 

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 0 14,966 21,677 48,130 22,339 21,691 51,992

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 16,471 16,471 16,471 16,471 16,471 16,471 16,471

Mostly Natural 408,650 339,984 317,611 156,419 315,416 317,453 156,221

Moderate Development 0 23,960 40,025 55,097 40,851 40,360 55,257

Intensive Development 0 44,706 51,014 197,133 52,383 50,837 197,172

Total 425,121 425,121 425,121 425,120 425,121 425,121 425,120 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative. 
 Environment and Effects 3 

Final EIS 3-685 Subregional Overview and Communities 

The 1988 TRUCS study found that deer accounted for 27 percent of the total edible 

pounds of subsistence resources harvested by Sitka households (Kruse and 

Frazier, 1988). Deer accounted for 22 percent of per capita subsistence harvest by 

Sitka residents in 1996 (ADF&G 2006). 

Sitka residents mainly harvest deer on Baranof Island, which is included in GMU 4. 

Deer harvest in GMU 4 is considered very high relative to other areas of Southeast 

Alaska, which is indicative of relatively high deer populations (ADF&G 2005). Over 

1997-2004, there has been no significant trend in the number of deer harvested or in 

the number of hunters (ADF&G 2005). As noted above, the human population of 

Sitka increased by an estimated 1 percent between 2000 and 2005. Sitka had an 

estimated population of 8,947 in 2005. 

Eleven WAAs account for the majority (76 percent) of deer harvest by Sitka 

residents. As shown in Table 3.23-55, the Sitka portion represents over 95 percent 

of the rural hunter harvest and almost 90 percent of the total harvest in these WAAs. 

About 6 percent of the combined harvest in these WAAs is by non-rural hunters, 

suggesting that there is very little harvest buffer that could be restricted, if 

necessary, before restrictions are placed on rural harvests. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, would not be able to 

provide sufficient habitat capability for deer hunted in the Sitka community use area 

by Sitka residents, all rural hunters, and all hunters in the short term. Sitka residents 

were identified as harvesting 15 percent of habitat capability a year, which exceeds 

10 percent habitat capability, the level that the analysis assumed would provide a 

reasonably high level of hunter success for their effort. The Final EIS analysis 

concluded that at some point a restriction in hunting might be necessary. 

In summary, use of most subsistence resources by Sitka residents (fish and marine 

invertebrates) is not expected to be affected by any of the alternatives. However, 

subsistence use of deer in some of the WAAs hunted by Sitka residents may be 

affected to the point that some restriction in hunting might be necessary over the 

Table 3.23-55 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 

1954 Habitat Capability, for the WAAs where Sitka Residents Obtain Approximately 75% 

of their Average Annual Deer Harvest*

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA 

Sitka 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

3001 414 422 431 81 81 79 79 72 78 79 71 

3002 314 318 329 69 69 68 68 67 68 68 67 

3104 166 177 193 73 73 69 68 65 68 68 64 

3003 121 121 129 85 84 83 80 73 79 80 72 

3313 120 130 141 65 64 57 56 50 52 53 48 

3310 118 127 140 93 93 93 93 93 93 93 93 

3207 118 120 130 100 100 100 100 100 100 100 100 

3733 118 145 158 100 100 100 100 100 100 100 100 

3314 110 110 124 88 88 87 87 73 87 87 73 

3105 97 97 103 99 99 99 98 97 97 97 97 

3311 97 99 103 97 97 97 97 88 89 91 86 

*Calculated based on harvest where location is known.
3 Environment and Effects

Subregional Overview and Communities 3-686 Final EIS

long term, even under Alternative 1. The risks of this occurring are greatest under 

Alternative 7 because of its general lack of Non-Development LUDs within the Sitka 

use area, and lower under the other six alternatives. The risk of hunting restrictions 

would be reduced somewhat, through more intensive management (e.g., thinning) of 

the existing and future closed-canopy, young-growth forests in this area. Indirect 

effects associated with increased competition for deer within Sitka’s subsistence, 

use areas could also occur under all alternatives due to displacement of hunters 

from other communities due to timber harvest activity. Additional road development 

under the alternatives would improve access but may increase competition with 

other non-local hunters. 

Skagway is located in northern Southeast Alaska at the head of Taiya Inlet, 95 air 

miles north of Juneau. It is the end-of-the line for the Alaska Marine ferry and the 

entrance to the Klondike Highway. According to the 2000 Census, Skagway had a 

2000 population of 862, with Alaska Natives comprising 3 percent of the total (U.S. 

Census Bureau 2001). 

Prior to the founding of the community, the area was settled by Chilkoot Tlingit who 

called it “Skagua,” or “the place where the north wind blows.” The Chilkoots 

controlled access into the interior along what has become known as the Chilkoot 

Trail, which follows along the Taiya River and over the Chilkoot Pass. The Chilkoot 

Trail was a major trade route for the Chilkoot Tlingit, interior Tlingit, and 

Athabaskans (ADF&G 1994). 

Settlement began in Skagway in 1887 when a seafarer named William Moore 

decided to develop a trading and mining route into the Yukon Territory using the 

Chilkoot Trail. As the Klondike gold rush hit the area in 1896, the Chilkoot and White 

Pass trails became the major routes into the Interior. Within a few years, the trails 

were superseded by the adjacent White Pass and Yukon Railway. The railway 

continued to function as a supply and shipping route between Skagway and 

Whitehorse until 1982 (ADF&G 1994). The railway currently operates as a tourist 

attraction. 

Skagway is incorporated as a first class city. The community participates in the Upper 

Lynn Canal Fish and Game Advisory Committee (ADF&G 1994). A total of 610,145 

cruise ship passengers visited Skagway in 2001, more than double the number in 1996. 

The population of Skagway, which declined between 1980 and 1990, increased by 

170 people or 25 percent between 1990 and 2000. The population decreased by an 

estimated 28 residents or 3 percent between 2000 and 2005. Total estimated 

population was 854 in Skagway in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 675 814 692 862 834 854 

Source: USDA Forest Service, 1997a; U.S. Census Bureau, 2001; Alaska DOL, 2007a

Skagway has a strong base in the tourism industry. It is a port of call for cruise 

ships and a transfer site for interior rail and bus tours. The State ferry also connects 

travelers to the rest of Southeast Alaska. More than 600,000 cruise ship 

passengers and numerous State ferry travelers visit Skagway each year. Skagway 

is also the site of trans-shipment of lead/zinc ore, fuel, and freight via the Port and 

Klondike Highway to and from Canada (Alaska DCED 2002; 2006). 

Skagway 
 Environment and Effects 3 

Final EIS 3-687 Subregional Overview and Communities 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 2 0 

Construction 69 15 

Manufacturing 0 0 

Wholesale Trade 5 1 

Retail Trade 68 14 

Transportation, Warehousing & Utilities 114 24 

Information 6 1 

Finance, Insurance, Real Estate, Rental & Leasing 14 3 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

26 5 

Education, Health & Social Services 52 11 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

74 16 

Other Services (Except Public Admin) 13 3 

Public Administration 32 7 

Total Employment 475 100 

Source: Alaska DCED 2002 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 14 percent of the labor force in 

Skagway was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $49,375 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Skagway is part of the Skagway community group (see Table 3.23-6). Detailed 

employment data are available for this community group by economic sector for 

1990, 1995, and 2000 in the planning record. The retail trade, services, and nonfederal government sectors were the major employers in the Skagway community 

group in 1999, accounting for 32, 20, and 17 percent of total employment, 

respectively. Recreation-related activities (lodging, restaurants, and recreation 

services) accounted for 25 percent of total employment, illustrating the importance 

of recreation and tourism for this area. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Skagway 

in their local day-to-day work, recreational, and subsistence activities is shown on 

Figure 3.23-28. This area contains 199,938 acres of National Forest System land 

(among other land ownerships). Table 3.23-56 shows how the lands within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. Only 4 percent of 

the acres in the Skagway community use area would be allocated to development 

LUDs under Alternative 5 (No Action) and Alternative 6 (Proposed Action). There 

would be no acres allocated to development LUDs under Alternatives 1 and 2, and 

approximately 5 percent under Alternatives 4 and 7, with approximately 4 percent 

under Alternative 3. There would be no suitable acres under any of the alternatives. 
3 Environment and Effects

Subregional Overview and Communities 3-688 Final EIS

Figure 3.23-28 

Skagway’s Community Use Area 

Table 3.23-56 

LUD Groups in Skagway’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 0 0 168 386 171 168 511

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 0 0 0 0 0 0 0

Mostly Natural 199,938 199,938 192,699 190,804 192,402 192,699 190,804

Moderate Development 0 0 7,239 9,135 7,537 7,239 9,135

Intensive Development 0 0 0 0 0 0 0

Total 199,938 199,938 199,938 199,939 199,938 199,938 199,939 1

 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative. 
 Environment and Effects 3 

Final EIS 3-689 Subregional Overview and Communities 

There are no acres within the Skagway Community Use Area allocated to 

Wilderness/National Monument LUDs under any of the alternatives. 

Economy 

Recreation, tourism, and subsistence use are important to the community of 

Skagway. None of the alternatives are expected to affect recreation and tourismrelated employment in Skagway. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 88 

percent of the total edible pounds of subsistence resources harvested by Skagway 

households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for 88 percent of per capita subsistence harvest in 

Skagway in 1987. 

The 1988 TRUCS study found that deer account for only a small fraction of the total 

edible pounds of subsistence resources harvested by Skagway households (Kruse 

and Frazier, 1988). Deer accounted for 7 percent of per capita subsistence harvest 

by Skagway residents in 1987 (ADF&G 2006). 

Skagway residents harvested very few deer from 1996-2002 (Table 3.23-57). 

Residents harvested an annual average of more than one deer in just four WAAs 

over this period. Three of these WAAs are located in GMU 4; the other is located in 

GMU 1C. Deer harvest in GMU 4 is considered very high relative to other areas of 

Southeast Alaska, which is indicative of relatively high deer populations (ADF&G 

2005). Over 1997-2004, there has been no significant trend in the number of deer 

harvested or in the number of hunters (ADF&G 2005). GMU 1C has been 

characterized from 1997-2004 by substantial annual variation in deer harvest, with 

no evident long-term trend in harvest levels (ADF&G 2005). 

Skagway residents take the majority (68 percent) of their deer from four WAAs: two 

on Baranof Island, one on south Chichagof Island, and one on Douglas Island 

(Table 3.23-57). These numbers are, however, somewhat misleading due to the 

overall low deer harvest levels. 

Table 3.23-57 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 1954 

Habitat Capability, for the WAAs where Skagway Residents Obtain Approximately 75% of 

their Average Annual Deer Harvest*

Average Deer Harvest from 1996 to 

2002 

Deer Habitat Capability in 2005 and after 100+ Years of Full 

Implementation Under Each Alternative, Expressed as a 

Percent of the 1954 Habitat Capability 

WAA 

Skagway 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

2722 3 5 261 100 100 100 100 88 100 100 100 

3001 2 422 431 81 81 79 79 72 78 79 71 

3002 2 318 329 69 69 68 68 67 68 68 67 

3308 2 98 158 66 64 59 57 53 56 57 51 

*Calculated based on harvest where location is known.
3 Environment and Effects

Subregional Overview and Communities 3-690 Final EIS

Three of the WAAs identified in Table 3.23-57 are in areas with substantial past 

harvest and deer habitat capabilities are currently estimated to be considerably 

below 1954 levels. Under each of the alternatives, additional harvest would further 

reduce habitat capabilities. Reductions would be smallest under Alternatives 1 and 

2 and greatest under Alternative 7 in WAAs 3001, 3002, and 3308. There would 

only be a reduction in habitat capability under Alternative 4 in the other WAA (2722), 

used relatively heavily by Skagway residents.Marine resources (fish and marine 

invertebrates) accounted for 88 percent of per capita subsistence harvest in 

Skagway in 1987. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that 1997 Alternatives 2, 6, and 11, which are similar to 

the four highest harvest alternatives in this EIS, should be able to provide sufficient 

habitat capability for deer hunted by Skagway residents and all rural hunters in the 

short term. However, it concluded that demand would exceed the capability of the 

habitat to produce deer populations sufficient to avoid effects on hunter success for 

all hunters in the long term. 

In summary, use of most subsistence resources by Skagway residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. 

Tenakee Springs is located 50 miles northeast of Sitka on the north shore of 

Tenakee Inlet (east Chichagof Island). According to the 2000 Census, Tenakee 

Springs had a 2000 population of 104, with Alaska Natives comprising 3 percent of 

the total (U.S. Census Bureau 2001). Tenakee Springs, accessible only by 

floatplane or boat, is a stop on the Alaska Marine Highway ferry system. 

A Tlingit winter village site was located in the vicinity of the present-day harbor and a 

summer village was located across the Inlet at Kadashan Bay (ADF&G 1994). Early 

prospectors and fishermen came to the site to wait out the winters and enjoy the 

natural hot springs in Tenakee. Around 1895, a large tub and building were 

constructed to provide a warm bathing place. The 108-degree sulfur springs is the 

social focus of the community, with bathing times scheduled for men and women. 

In 1904, E. Snyder bought a tract of land from a Tlingit resident, including a house 

located near the public bathhouse. The post office, established in 1903, used the 

name Tenakee. In 1928, the community’s name was changed to Tenakee Springs. 

The community has a local Fish and Game Advisory Committee, and many 

residents practice a subsistence lifestyle, actively exchanging resources with 

neighbors (ADF&G 1994). 

Tenakee Springs’ population increased slightly between 1990 and 2000, and 

decreased slightly between 2000 and 2005. Total estimated population was 109 in 

Tenakee Springs in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 86 138 94 104 98 109 

Source: USDA Forest Service, 1997a; U.S. Census Bureau, 2001; Alaska DOL, 2007a

While Tenakee Springs is often considered a retirement community, commercial 

fishing (18 residents have permits), and tourism are important sources of income. 

The City and local store are the primary employers (Alaska DCED 2002). 

An estimated 25 percent of the homes in Tenakee Springs are second homes. 

Tourism activities are limited to two family-run marine charters and Tenakee Springs 

residents have been vocal in their opposition to tourism development (Dugan et al. 

2006). The Chichagof Conservation Council commenting on the Draft EIS noted 

Tenakee Springs 
 Environment and Effects 3 

Final EIS 3-691 Subregional Overview and Communities 

that small-scale, locally-owned businesses catering to independent travelers are a 

large part of the Tenakee Springs economy. Local residents opposed cruise ship 

development, not all tourism development. 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 14 percent of the labor force in 

Tenakee Springs was identified as unemployed and seeking work in 2000, 

compared to 7 percent for Southeast Alaska as a whole. Median household income 

was $33,125, compared to a regional median of $44,118 (Alaska DCED 2002). 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Tenakee Springs is part of the Chatham Strait community group (see Table 3.23-6). 

Detailed employment data are available for this community group by economic 

sector for 1990, 1995, and 2000 in the planning record. The non-federal 

government, wood products, and services sectors were the major employers in the 

Chatham Strait community group in 1999, accounting for 49, 18, and 17 percent of 

total employment, respectively. The wood products employment was entirely in the 

logging sector. 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 5 11 

Construction 2 5 

Manufacturing 0 0 

Wholesale Trade 0 0 

Retail Trade 5 11 

Transportation, Warehousing & Utilities 8 18 

Information 0 0 

Finance, Insurance, Real Estate, Rental & Leasing 0 0 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

4 9 

Education, Health & Social Services 4 9 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

2 5 

Other Services (Except Public Admin) 3 7 

Public Administration 11 25 

Total Employment 44 100 

Source: Alaska DCED 2002 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Tenakee 

Springs in their local day-to-day work, recreational, and subsistence activities is shown 

on Figure 3.23-29. This area contains 196,031 acres of National Forest the System 

land (among other land ownerships). Table 3.23-58 shows how the lands within this 

community use area would be distributed among the LUD groups by alternative. The 

LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 60 percent of the total acreage within the 

Tenakee Springs community use area. Alternatives 5 and 6 would not have a 

significant effect on existing LUD allocations in the community use area because the 

acreage by LUD group would remain the same as under the existing Forest Plan. 

The acreage allocated to Wilderness/National Monument LUDs would remain 

constant under all alternatives. The amount of acreage allocated to Mostly Natural 

LUDs would increase under Alternatives 1 through 3. The largest increase would 

occur under Alternative 1, with the acreage allocated to Mostly Natural LUDs 

increasing from 40 percent under Alternative 5 (No Action) to 93 percent under 
3 Environment and Effects

Subregional Overview and Communities 3-692 Final EIS

Figure 3.23-29 

Tenakee Springs’ Community Use Area 

Table 3.23-58 

LUD Groups in Tenakee Springs’ Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 5,693 14,034 20,040 34,158 26,547 25,726 40,971

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 0 0 0 0 0 0 0

Mostly Natural 181,878 153,699 126,906 57,489 78,488 94,892 45,536

Moderate Development 1,369 3,803 4,604 10,039 4,457 5,152 13,096

Intensive Development 12,784 38,528 64,520 128,503 113,085 95,987 137,398

Total 196,031 196,031 196,031 196,031 196,031 196,031 196,031 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative. 
 Environment and Effects 3 

Final EIS 3-693 Subregional Overview and Communities 

Alternative 1, with a commensurate reduction in development LUDs (Table 3.23-58). 

Alternatives 4 and 7 would increase the acreage in development LUDs. 

Development LUDs would account for 71 percent and 77 percent under Alternatives 

4 and 7, respectively, compared to 60 percent under Alternative 5. 

Total suitable acres would range from 3 percent under Alternative 1 to 21 percent 

under Alternative 7, compared to 14 percent of the total community use area under 

Alternative 5 (No Action) and 13 percent under Alternative 6 (Proposed Action). 

Economy 

Tenakee Springs is primarily a commercial fishing, subsistence, and retirement 

community. The lands along Tenakee Inlet are some of the most important to the 

community. Kadashan and Trap Bay watersheds are legislated LUD II areas. 

These areas were designated in the Tongass Timber Reform Act, in part, because 

of their high value for subsistence use for Tenakee Springs residents. 

Commercial fishing is not expected to be significantly affected by Forest Service 

activities during the next 10 years. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 55 

percent of the total edible pounds of subsistence resources harvested by Tenakee 

Springs households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for 53 percent of per capita subsistence harvest in 

Tenakee Springs in 1987. 

The 1988 TRUCS study found that deer accounted for 39 percent of the total edible 

pounds of subsistence resources harvested by Tenakee Springs households (Kruse 

and Frazier, 1988). Deer accounted for 41 percent of per capita subsistence 

harvest by Tenakee Springs residents in 1987 (ADF&G 2006). The WAAs used by 

Tenakee Springs residents for hunting deer lie within GMU 4. Deer harvest in GMU 

4 is considered very high relative to other areas of Southeast Alaska, which is 

indicative of relatively high deer populations (ADF&G 2005). Over 1997-2004, there 

has been no significant trend in the number of deer harvested or in the number of 

hunters (ADF&G 2005). However, as shown above, Tenakee Springs’ human 

population decreased slightly from 2000 to 2005, with an estimated 98 residents 

identified in 2005. 

Tenakee Springs residents take the majority (67 percent) of their deer from two 

WAAs on Chichagof Island (3627 and 3526). As shown in Table 3.23-59, the 

Tenakee Springs portion represents about 35 percent and 20 percent of the total 

harvest and about 72 percent and 74 percent of the rural hunter harvest in these 

WAAs, respectively. About 64 percent of the combined harvest in these WAAs is by 

non-rural hunters, suggesting that there is a harvest buffer that could be restricted, if 

necessary, before restrictions are placed on rural harvests. 

WAAs 3627 and 3526 occur in an area with substantial past harvest and, therefore, 

deer habitat capabilities are currently estimated to be below 1954 levels (Table 3.23-

59). Under each of the alternatives, additional harvest would occur that would 

reduce habitat capabilities after 100+ years to 61-70 percent of 1954 levels in WAA 

3627 and 60-77 percent in WAA 3526. 
3 Environment and Effects

Subregional Overview and Communities 3-694 Final EIS

Table 3.23-59 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 

1954 Habitat Capability, for the WAAs where Tenakee Springs Residents Obtain 

Approximately 75% of their Average Annual Deer Harvest*

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA 

Tenakee 

Springs 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

3627 25 35 72 76 70 67 65 62 64 65 61 

3526 23 31 115 81 77 73 72 69 72 72 60 

3629 11 16 43 91 91 89 85 75 79 80 73 

*Calculated based on harvest where location is known. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that 1997 Alternatives 2, 6, and 11, which are similar to 

the four highest harvest alternatives in this EIS, should be able to provide sufficient 

habitat capability over the short term for deer hunted by Tenakee Springs residents, 

all rural hunters, and all hunters. However, it concluded that all alternatives may 

have future inadequate habitat capability for the total deer hunter and at some point 

a restriction in hunting may be necessary. 

In summary, use of most subsistence resources by Tenakee Springs residents (fish 

and marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. The 

risks of this occurring are greatest under Alternative 7, and lower under the other six 

alternatives. The risk of hunting restrictions would be reduced somewhat, through 

more intensive management (e.g., thinning) of the existing and future closedcanopy, young-growth forests in this area. 

Thorne Bay is located at the head of Thorne Bay on eastern Prince of Wales Island, 

approximately 40 air miles northwest of Ketchikan. According to the 2000 Census, 

Thorne Bay had a 2000 population of 557, with Alaska Natives comprising 16 

percent of the total (U.S. Census Bureau 2001). 

Petroglyphs and other archaeological remains indicate occupation and use of the 

area by Alaska Natives dating back at least 3,000 years. Post-contact development 

began in the early 1900s with construction of a saltery on the south shore of Thorne 

Bay (ADF&G 1994). 

In 1960, a floating logging camp was built in Thorne Bay, and, in 1962, a shop, 

barge terminal, log sort yard, and camp were built to replace facilities at Hollis. 

Thorne Bay was incorporated as a second class city in 1982, making it one of 

Alaska’s newest cities. Thorne Bay is accessible by road, water, or floatplane. 

Three air carriers serve the community with six to ten flights daily, and the Alaska 

Marine Highway system is accessed by the road system to Hollis (ADF&G 1994). 

Thorne Bay’s population decreased by 4 percent between 1990 and 2000. 

Population in Thorne Bay decreased further between 2000 and 2005, with an 

estimated net loss of 71 residents or 13 percent of the community’s population in 

2000. Total estimated population was 482 in Thorne Bay in 2006 (Alaska DOL 

2007a). 

Thorne Bay 
 Environment and Effects 3 

Final EIS 3-695 Subregional Overview and Communities 

Year 1970 1980 1990 2000 2005 2006 

Population 443 377 581 557 486 482 

Source: USDA Forest Service, 1997a; U.S. Census Bureau, 2001; Alaska DOL, 2007a

The Thorne Bay economy is primarily based on the timber industry and the U.S. 

Forest Service management of the National Forest. Logging operations in the area 

are generally seasonal (March to November) and include a major log transfer site for 

Prince of Wales Island. The 2006 mill survey conducted for the USDA Forest 

Service identified three active timber processors in Thorne Bay: Porter Lumber 

Company, Thuja Plicata Lumber Company, and Thorne Bay Wood Products. These 

mills had a combined installed production capacity of 25 MMBF and together 

processed approximately 1.2 MMBF in 2006 and employed about 8 people (Juneau 

Economic Development Council 2007). Northern Star Cedar Products, also located 

in Thorne Bay, was recently subdivided and sold as three separate operations, with 

each part now under new ownership. 

Commercial fishing (22 residents hold permits), tourism, and government also 

provide employment (Alaska DCED 2002). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 15 percent of the labor force in 

Thorne Bay was identified as unemployed and seeking work in 2000, compared to 

7 percent for Southeast Alaska as a whole. Median household income was 

$45,625, compared to a regional median of $44,118 (Alaska DCED 2002). 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 53 20 

Construction 33 12 

Manufacturing 16 6 

Wholesale Trade 3 1 

Retail Trade 25 9 

Transportation, Warehousing & Utilities 15 6 

Information 3 1 

Finance, Insurance, Real Estate, Rental & Leasing 2 1 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

13 5 

Education, Health & Social Services 61 23 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

8 3 

Other Services (Except Public Admin) 6 2 

Public Administration 31 12 

Total Employment 269 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Thorne Bay is part of the North Prince of Wales community group (see Table 3.23-

6). Detailed employment data are available for this community group by economic 

sector for 1990, 1995, and 2000 in the planning record. Wood products employment 

in the North Prince of Wales community group declined by 186 jobs or 69 percent 

between 1990 and 1999. Wood products employment accounted for 83 jobs or 23 

percent of total employment in this community group in 1999. 
3 Environment and Effects

Subregional Overview and Communities 3-696 Final EIS

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Thorne 

Bay in their local day-to-day work, recreational, and subsistence activities is shown 

on Figure 3.23-30. This area contains 1,000,251 acres of National Forest System 

land (among other land ownerships). Table 3.23-60 shows how the lands within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 54 percent of the total acreage within the 

Thorne Bay community use area. Alternatives 5 and 6 would not have a significant 

effect on existing LUD allocations in the community use area because the acreage 

by LUD group would remain the same as under the existing Forest Plan. The 

acreage allocated to Wilderness/National Monument LUDs would remain constant 

under all alternatives. The amount of acreage allocated to Mostly Natural LUDs 

would increase under Alternatives 1 through 3. The largest increase would occur 

under Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing 

from 40 percent under Alternative 5 (No Action) to 61 percent under Alternative 1, 

with a commensurate reduction in development LUDs (Table 3.23-60). Alternatives 

4 and 7 would increase the acreage in development LUDs. Development LUDs 

would account for 62 percent and 78 percent under Alternatives 4 and 7, 

respectively, compared to 55 percent under Alternative 5. 

Total suitable acres would range from 17 percent under Alternative 1 to 31 percent 

under Alternative 7, compared to 21 percent of the total community use area under 

Alternative 5 (No Action) and Alternative 6 (Proposed Action). 

Economy 

Thorne Bay is primarily a logging community and as such would be directly affected 

by the amount of logging opportunities on north Prince of Wales Island, as well as 

elsewhere on the Tongass. The mill survey conducted by the Forest Service in 

2000 identified four sawmills operating in Thorne Bay. Three of these mills were 

also identified in the survey conducted for 2006 (Juneau Economic Development 

Council 2007). Approximately 6.5 MMBF was under contract in the Thorne Bay 

Ranger District in August 2006. This volume would not be affected under any of the 

alternatives. These data provide an indication of potential impacts, actual impacts 

would depend on the volume that is under contract when the decision is 

implemented and whether potentially affected existing sales were cancelled as part 

of the decision. 

The 1997 Forest Plan EIS indicated that several small timber operators produce 

value-added products in Thorne Bay. These value added products include music 

wood, cabinets, and other products. They need relatively low volumes of timber, but 

of specific species and grades to meet their needs. All alternatives should meet 

these needs. 

The lodges located near the community would not be affected under any of the 

alternatives. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 75 

percent of the total edible pounds of subsistence resources harvested by Thorne 

Bay households (Kruse and Frazier 1988). Marine resources (fish and marine 
 Environment and Effects 3 

Final EIS 3-697 Subregional Overview and Communities 

Figure 3.23-30 

Thorne Bay’s Community Use Area 

Table 3.23-60 

LUD Groups in Thorne Bay’s Community Use Area by Alternative

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 168,118 183,297 194,535 229,341 212,196 205,531 309,814

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 51,176 51,176 51,176 51,176 51,176 51,176 51,176

Mostly Natural 610,703 521,333 462,782 328,739 404,829 415,260 172,901

Moderate Development 95,974 112,481 139,418 168,888 160,346 159,286 265,649

Intensive Development 242,395 315,259 346,875 451,449 383,900 374,528 510,523

Total 1,000,248 1,000,249 1,000,251 1,000,252 1,000,251 1,000,249 1,000,249 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative. 
3 Environment and Effects

Subregional Overview and Communities 3-698 Final EIS

invertebrates) accounted for 54 percent of per capita subsistence harvest in Thorne 

Bay in 1998. 

The 1988 TRUCS study found that deer accounted for 20 percent of the total edible 

pounds of subsistence resources harvested by Thorne Bay (Kruse and Frazier 

1988). Deer accounted for 27 percent of per capita subsistence harvest by Throne 

Bay residents in 1998 (ADF&G 2006). 

Thorne Bay residents harvest deer almost entirely on Prince of Wales Island, which 

is included in GMU 2. Deer harvest and hunter effort in GMU 2 generally increased 

during 1997-2000 and subsequently declined during 2000-2004; however, no 

change has been noted in the average number of hunter-days required to harvest a 

deer (ADF&G 2005). As noted above, Thorne Bay’s human population declined by 

an estimated 13 percent between 2000 and 2005, with an estimated 2005 

population of 486. 

Residents of Thorne Bay harvest the majority (79 percent) of their deer from two 

WAAs in north-central Prince of Wales Island (1319 and 1315). As shown in Table 

3.23-61, the Thorne Bay portion represents about 56 percent and 42 percent of the 

total harvest and about 70 percent and 65 percent of the rural hunter harvest in 

these WAAs, respectively. About 28 percent of the combined harvest in these 

WAAs is by non-rural hunters, suggesting that there is a limited harvest buffer that 

could be restricted, if necessary, before restrictions are placed on rural harvests. 

WAAs 1319 and 1315 occur in an area with substantial past harvest and, therefore, 

deer habitat capabilities are currently estimated to be below 1954 levels (Table 3.23-

61). Under each of the alternatives, additional harvest would occur that would 

reduce habitat capabilities after 100+ years to 54-69 percent of 1954 levels in WAA 

1319 and 41-50 percent in WAA 1315. 

Table 3.23-61 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 

1954 Habitat Capability, for the WAAs where Thorne Bay Residents Obtain 

Approximately 75% of their Average Annual Deer Harvest*

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA 

Thorne 

Bay 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

1319 123 177 220 74 69 67 66 59 64 64 54 

1315 115 175 270 55 50 49 47 44 47 47 41 

*Calculated based on harvest where location is known. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that 1997 Alternatives 2, 6, and 11, which are similar to 

the four highest harvest alternatives in this EIS, should be able to provide sufficient 

habitat capability over the long term for deer hunted by Thorne Bay residents. 

Projected deer harvest in the Thorne Bay community use area by all rural hunters 

and all hunters is estimated to exceed 10 percent habitat capability, the level that 

the analysis is assumed would provide a reasonably high level of hunter success for 

their effort, in the short and long term. 

In summary, use of most subsistence resources by Thorne Bay residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 
 Environment and Effects 3 

Final EIS 3-699 Subregional Overview and Communities 

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. The 

risks of this occurring are greatest under Alternative 7 because of its general lack of 

Non-Development LUDs throughout most of Prince of Wales Island, and second 

highest under Alternative 4 because of its lower use of Non-Development LUDs than 

the other alternatives. Alternatives 1, 2, and 3 would have the lowest risk and 

Alternatives 5 and 6 would be intermediate. The risk of hunting restrictions would be 

reduced somewhat, through more intensive management (e.g., thinning) of the 

existing and future closed-canopy, young-growth forests in this area. Indirect effects 

associated with increased competition for deer within Thorne Bay’s subsistence use 

areas could also occur under all alternatives due to displacement of hunters from 

other communities due to timber harvest activity. Additional road development 

under the alternatives would improve access but may increase competition with 

other non-local hunters. The level of road development is already relatively high in 

these WAAs. Existing open road densities are 0.6 and 1.5 miles per square mile 

and existing total road densities are 1.2 and 2.0 miles per square mile in WAAs 

1319 and 1315, respectively (all ownerships combined). Long-term (100+ years) 

road development would vary by alternative and would result in estimated maximum 

total road densities of 1.3 and 2.7 miles per square mile in these two WAAs under 

Alternative 1, to 1.7 and 2.9 miles per square mile in these two WAAs under 

Alternative 7 (for all ownerships combined). 

Whale Pass is a dispersed unincorporated community located on the northeast 

coast of Prince of Wales Island. According to the 2000 Census, Whale Pass had a 

2000 population of 58, with Alaska Natives comprising one percent of the total (U.S. 

Census Bureau 2001). 

Whale Pass was originally established as a logging camp by Ketchikan Pulp 

Company in the early 1960s. According to local residents, a float camp housed 

loggers and their families in this location for almost 30 years. In 1982, the float 

camp was removed and many of the logging families left. Others moved to trailer 

pads on land at the head of the cove. That same year, Whale Pass became the site 

of a State land sale, which brought renewed population growth and the founding of a 

homeowners association. The community has been connected to the road system 

on Prince of Wales Island since 1981. A log transfer station remains on the 

southwest side of the bay (ADF&G, 1994). 

The population of Whale Pass decreased by 17 residents between 1990 and 2000. 

Population has increased by an estimated 18 residents or 31 percent since 2000. 

Total estimated population was 61 in Whale Pass in 2006 (Alaska DOL 2007a). 

Year 1980 1990 2000 2005 2006 

Population 90 75 58 76 61 

Source: USDA Forest Service, 1997a; U.S. Census Bureau, 2001; Alaska DOL, 2007a 

Whale Pass is primarily dependent on the timber industry, with logging operations 

and the local school being the only employers in the area (Alaska DCED 2002). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. These data are extrapolated from a sample of 

the city population. Since the sample size was small, the extrapolation may not be 

exact but should provide a general indication of the distribution of employment. The 

2000 U.S. Census identified a potential work force of 37 residents and total 

employment of 14. While no adults in Whale Pass were identified as unemployed 

and looking for work in 2000, 62 percent were identified as unemployed and not 

looking for work. Median household income was $62,083, compared to a regional 

median of $44,118 (Alaska DCED 2002). 

Whale Pass 
3 Environment and Effects

Subregional Overview and Communities 3-700 Final EIS

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 9 64 

Construction 0 0 

Manufacturing 0 0 

Wholesale Trade 0 0 

Retail Trade 3 21 

Transportation, Warehousing & Utilities 0 0 

Information 0 0 

Finance, Insurance, Real Estate, Rental & Leasing 0 0 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

2 14 

Education, Health & Social Services 0 0 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

0 0 

Other Services (Except Public Admin) 0 0 

Public Administration 0 0 

Total Employment 14 100 

Source: Alaska DCED 2002 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Whale Pass is located in the Thorne Bay Ranger District and is part of the North 

Prince of Wales community group (see Table 3.23-6). Detailed employment data 

are available for this community group by economic sector for 1990, 1995, and 2000 

in the planning record. Wood products employment in the North Prince of Wales 

community group declined by 186 jobs or 69 percent between 1990 and 1999. 

Wood products employment accounted for 83 jobs or 23 percent of total 

employment in this community group in 1999. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Whale 

Pass in their local day-to-day work, recreational, and subsistence activities is shown 

on Figure 3.23-31. This area contains 1,000,251 acres of National Forest System 

land (among other land ownerships). Table 3.23-62 shows how the lands within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for 54 percent of the total acreage within the 

Whale Pass community use area. Alternatives 5 and 6 would not have a significant 

effect on existing LUD allocations in the community use area because the acreage 

by LUD group would remain the same as under the existing Forest Plan. The 

acreage allocated to Wilderness/National Monument LUDs would remain constant 

under all alternatives. The amount of acreage allocated to Mostly Natural LUDs 

would increase under Alternatives 1 through 3. The largest increase would occur 

under Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing 

from 40 percent under Alternative 5 (No Action) to 61 percent under Alternative 1, 

with a commensurate reduction in development LUDs (Table 3.23-62). Alternatives 

4 and 7 would increase the acreage in development LUDs. Development LUDs 

would account for 62 percent and 78 percent under Alternatives 4 and 7, 

respectively, compared to 54 percent under Alternative 5. 
 Environment and Effects 3 

Final EIS 3-701 Subregional Overview and Communities 

Figure 3.23-31 

Whale Pass’ Community Use Area 

Table 3.23-62 

LUD Groups in Whale Pass’ Community Use Area by Alternative 

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 168,118 183,297 194,535 229,341 212,196 205,531 309,814

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 51,176 51,176 51,176 51,176 51,176 51,176 51,176

Mostly Natural 610,703 521,333 462,782 328,739 404,829 415,260 172,901

Moderate Development 95,974 112,481 139,418 168,888 160,346 159,286 265,649

Intensive Development 242,395 315,259 346,875 451,449 383,900 374,528 510,523

Total 1,000,248 1,000,249 1,000,251 1,000,252 1,000,251 1,000,249 1,000,249 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative. 
3 Environment and Effects

Subregional Overview and Communities 3-702 Final EIS

Total suitable acres would range from 17 percent under Alternative 1 to 31 percent 

under Alternative 7, compared to 21 percent of the total community use area under 

Alternative 5 (No Action) and Alternative 6 (Proposed Action). 

Economy 

Residents of Whale Pass could be potentially affected by changes in timber harvest, 

karst protection, recreation and tourism, and subsistence opportunities. Members of 

several speliological societies derive a portion of their income from cave and karst 

analysis and exploration in the vicinity. The Whale Pass Resort and a retail store 

are located in Whale Pass. 

Approximately 6.5 MMBF was under contract in the Thorne Bay Ranger District in 

August 2006. This volume would not be affected under any of the alternatives. 

These data provide an indication of potential impacts, actual impacts would depend 

on the volume that is under contract when the decision is implemented and whether 

potentially affected existing sales were cancelled as part of the decision. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 60 

percent of the total edible pounds of subsistence resources harvested by Whale 

Pass households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for 65 percent of per capita subsistence harvest in Whale 

Pass in 1998. 

The 1988 TRUCS study found that deer account for 27 percent of the total edible 

pounds of subsistence resources harvested by Whale Pass households (Kruse and 

Frazier, 1988). Deer accounted for 27 percent of per capita subsistence harvest by 

Whale Pass residents in 1998 (ADF&G 2006). 

The majority of deer harvest by Whale Pass residents occurs on Prince of Wales 

Island, which is included in GMU 2. Deer harvest and hunter effort in GMU 2 

generally increased during 1997-2000 and subsequently declined during 2000-2004; 

however, no change has been noted in the average number of hunter-days required 

to harvest a deer (ADF&G 2005). As noted above, the human population of Whale 

Pass increased by and estimated 31 percent from 2000 to 2005, with an estimated 

2005 population of 76, which roughly matches the community’s 1990 population 

level. 

Residents of Whale Pass harvest the majority (83 percent) of their deer from two 

WAAs in north Prince of Wales Island (1530 and 1529). As shown in Table 3.23-63, 

the Whale Pass portion represents about 12 percent and 2 percent of the total 

harvest and about 21 percent and 3 percent of the rural hunter harvest in these 

WAAs, respectively. About 46 percent of the combined harvest in these WAAs is by 

non-rural hunters, suggesting that there is a harvest buffer that could be restricted, if 

necessary, before restrictions are placed on rural harvests. 

WAAs 1530 and 1529 occur in an area with substantial past harvest and, therefore, 

deer habitat capabilities are currently estimated to be below 1954 levels (Table 3.23-

63). Under each of the alternatives, additional harvest would occur that would 

reduce habitat capabilities after 100+ years to 50-58 percent of 1954 levels in WAA 

1530 and 50-63 percent in WAA 1529. 
 Environment and Effects 3 

Final EIS 3-703 Subregional Overview and Communities 

Table 3.23-63 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 

1954 Habitat Capability, for the WAAs where Whale Pass Residents Obtain Approximately 

75% of their Average Annual Deer Harvest*

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA 

Whale Pass 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

1530 17 80 147 62 58 57 55 54 55 55 50 

1529 4 122 226 73 63 61 60 56 59 59 50 

*Calculated based on harvest where location is known. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that 1997 Alternatives 2, 6, and 11, which are similar to 

the four highest harvest alternatives in this EIS, should be able to provide sufficient 

habitat capability over the long term for deer hunted by Whale Pass residents. 

Projected deer harvest in the Whale Pass community use area by all rural hunters 

and all hunters is estimated to exceed 10 percent habitat capability, the level that 

the analysis assumed would provide a reasonably high level of hunter success for 

their effort, in the short term and long term. 

In summary, use of most subsistence resources by Whale Pass residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. The 

risks of this occurring are greatest under Alternative 7 because of its general lack of 

Non-Development LUDs throughout most of Prince of Wales Island, and second 

highest under Alternative 4 because of its lower use of Non-Development LUDs than 

the other alternatives. Alternatives 1, 2, and 3 would have the lowest risk and 

Alternatives 5 and 6 would be intermediate. The risk of hunting restrictions would be 

reduced somewhat, through more intensive management (e.g., thinning) of the 

existing and future closed-canopy, young-growth forests in this area. Indirect effects 

associated with increased competition for deer within the Whale Pass subsistence 

use areas could also occur under all alternatives due to displacement of hunters 

from other communities due to timber harvest activity. Additional road development 

under the alternatives would improve access but may increase competition with 

other non-local hunters. The level of road development is already relatively high in 

these WAAs. Existing open road densities are 1.1 and 0.9 miles per square mile 

and existing total road densities are 1.7 and 1.5 miles per square mile in WAAs 

1530 and 1529, respectively (all ownerships combined). Long-term (100+ years) 

road development would vary by alternative and would result in estimated maximum 

total road densities of 1.9 and 1.7 miles per square mile in these two WAAs under 

Alternative 1, to 2.0 miles per square mile in both WAAs under Alternative 7 (for all 

ownerships combined). 

Wrangell is located on the north end of Wrangell Island, near the mouth of the 

Stikine River, an historic trade route to the Canadian interior. According to the 2000 

Census, Wrangell had a 2000 population of 2,308, with Alaska Natives comprising 

16 percent of the total (U.S. Census Bureau 2001). 

Wrangell began as an important Tlingit site primarily because of its proximity to the 

Stikine River. Wrangell clans held a monopoly of trading rights along the Stikine. In 

1811, the Russians began fur trading with area Tlingits and built a stockade named 

Wrangell 
3 Environment and Effects

Subregional Overview and Communities 3-704 Final EIS

Redoubt Saint Dionysius in 1834. In 1867, a military post named Fort Wrangell was 

established as part of the Alaska Territory. The community continued to grow 

because of its strategic location as a military fur trading center, and as an outfitter 

for gold prospectors between 1861 and the 1930s (ADF&G 1994; Alaska DCED 

2006). 

Wrangell is incorporated as a home rule municipality and has maintained its historic 

cultural diversity. The community has a local Fish and Game Advisory Committee. 

In a move to emphasize the importance of subsistence, the Wrangell Indian 

Reorganization Act Council has formed its own local Fish and Game Advisory 

Committee (ADF&G 1994). 

The Silver Bay sawmill is located in Wrangell. According to the 2006 mill survey 

conducted for the USDA Forest Service, this mill, which has an installed production 

capacity of 65 MMBF, processed approximately 6 MMBF in 2006 and employed 30 

people (Juneau Economic Development Council 2007). 

Wrangell’s population, which increased 22 percent between 1970 and 1990, 

decreased by 171 residents or 7 percent between 1990 and 2000. The population 

decreased by a further estimated 334 residents or 14 percent from 2000 to 2005. 

Total estimated population was 1,911 in Wrangell in 2006 (Alaska DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 2,029 2,184 2,479 2,308 1,974 1,911 

Source: USDA Forest Service, 1997a; U.S. Census Bureau, 2001; Alaska DOL, 2007a

The Wrangell economy is primarily based on commercial fishing (250 residents hold 

permits), fish processing, and the timber industry. Estimated gross fishing earnings 

of local residents approached $5 million in 2000. A dive fishery, including for 

urchins, sea cucumbers, and geoducks, is developing. The Alaska Pulp Corp. 

sawmill, closed in 1994, was sold to Silver Bay Logging and reopened in April 1998. 

Wrangell also has a tourist business attracted by sportfishing in Stikine River and by 

a deep-water port for docking large and small cruise ships (Alaska DCED 2002; 

2006). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 9 percent of the labor force in 

Wrangell was identified as unemployed and seeking work in 2000, compared to 

7 percent for Southeast Alaska as a whole. Median household income was 

$43,250, compared to a regional median of $44,118 (Alaska DCED 2002). 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 176 16 

Construction 98 9 

Manufacturing 78 7 

Wholesale Trade 7 1 

Retail Trade 89 8 

Transportation, Warehousing & Utilities 77 7 

Information 27 3 

Finance, Insurance, Real Estate, Rental & Leasing 23 2 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

51 5 

Education, Health & Social Services 238 22 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

69 6 

Other Services (Except Public Admin) 38 4 

Public Administration 108 10 

Total Employment 1,079 100 

Source: Alaska DCED 2002 
 Environment and Effects 3 

Final EIS 3-705 Subregional Overview and Communities 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Wrangell is part of the Wrangell City community group (see Table 3.23-6). Detailed 

employment data are available for this community group by economic sector for 

1990, 1995, and 2000 in the planning record. 

Sawmill employment decreased by 62 percent in the Wrangell City community group 

between 1990 and 1999, a reduction from 162 to 62 jobs. The wood products 

sector accounted for 9 percent of total employment in the Wrangell City community 

group in 1999. The main employers in 1999 were the non-federal government and 

retail trade sectors, which accounted for 24 and 18 percent of total employment, 

respectively. 

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Wrangell 

in their local day-to-day work, recreational, and subsistence activities is shown on 

Figure 3.23-32. This area contains 819,240 acres of National Forest System land 

(among other land ownerships). Table 3.23-64 shows how the lands within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for about 36 percent of the total acreage within 

the Wrangell community use area. Alternatives 5 and 6 would not have a significant 

effect on existing LUD allocations in the community use area because the acreage 

by LUD group would remain the same as under the existing Forest Plan. The 

acreage allocated to Wilderness/National Monument LUDs would remain constant 

under all alternatives. The amount of acreage allocated to Mostly Natural LUDs 

would increase under Alternatives 1 and 2. The largest increase would occur under 

Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing from 20 

percent under Alternative 5 (No Action) to 45 percent under Alternative 1, with a 

commensurate reduction in development LUDs (Table 3.23-64). Alternatives 4 and 7 

would increase the acreage in development LUDs. Development LUDs would 

account for 48 percent under both of these alternatives compared to 36 percent 

under Alternative 5. 

Total suitable acres would range from 5 percent under Alternative 1 to 16 percent 

under Alternative 7, compared to 11 percent of the total community use area under 

Alternative 5 (No Action) and Alternative 6 (Proposed Action). 

Economy 

Commercial fishing, timber processing, recreation and tourism, and subsistence 

opportunities are particularly important to Wrangell. Wrangell is one of the stop-over 

points for visitors traveling to the Stikine River and the Stikine-LeConte Wilderness. 

Commercial fisheries employment and recreation and tourism activities are not likely 

to be affected under any of the alternatives. 

Approximately 26.2 MMBF of timber was under contract in the Wrangell Ranger 

District in August 2006. About 58 percent (15.2 MMBF) of this volume could be 

potentially affected under Alternative 1, which would maintain all Inventoried 

Roadless Areas on the Tongass in a natural condition and not permit timber harvest 

in these areas. None of the other alternatives would affect this volume. These data 
3 Environment and Effects

Subregional Overview and Communities 3-706 Final EIS

Figure 3.23-32 

Wrangell’s Community Use Area 

Table 3.23-64 

LUD Groups in Wrangell’s Community Use Area by Alternative 

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 38,268 65,753 87,283 116,010 87,266 87,628 128,413

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 363,146 363,146 363,146 363,146 363,146 363,146 363,146

Mostly Natural 367,625 254,848 162,305 61,076 161,015 161,265 60,538

Moderate Development 36,970 76,979 149,387 228,846 150,577 149,950 229,418

Intensive Development 51,498 124,268 144,403 166,173 144,503 144,880 166,139

Total 819,240 819,240 819,240 819,241 819,241 819,240 819,240 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative. 
 Environment and Effects 3 

Final EIS 3-707 Subregional Overview and Communities 

provide an indication of potential impacts, actual impacts would depend on the 

volume that is under contract when the decision is implemented and whether 

potentially affected existing sales were cancelled as part of the decision. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 52 

percent of the total edible pounds of subsistence resources harvested by Wrangell 

households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for 84 percent of per capita subsistence harvest in 

Wrangell in 1987. 

The 1988 study found that deer account for 21 percent of the total edible pounds of 

subsistence resources harvested by Wrangell households (Kruse and Frazier 1988). 

Deer accounted for a small amount of per capita subsistence harvest by Wrangell 

residents in 1987 (ADF&G 2006). 

Wrangell residents mainly harvest deer on Wrangell and surrounding islands, with 

the majority of harvest occurring in GMU 3. Deer harvest in GMU 3 declined 

between 1998-2002 and increased between 2002-2004. The number of deer 

hunters declined between 2000-2002 and slightly increased between 2002-2004 

(ADF&G 2005). As noted above, the human population of Wrangell decreased by 

an estimated 14 percent between 2000 and 2005. Wrangell had an estimated 

population of 1,974 in 2005. 

Deer harvest by Wrangell residents is spread over many WAAs, but the majority (76 

percent) of their deer are from five WAAs located on Wrangell and surrounding 

islands. Zarembo Island (WAA 1905) alone accounts for about half (51 percent) of 

Wrangell deer harvest. The Wrangell portion of the harvest in these five WAAs 

represents about 72 percent of the total harvest and about 80 percent of the rural 

hunter harvest (Table 3.23-65). 

The majority of the WAAs used heavily by Wrangell residents are in areas with 

substantial past harvest and deer habitat capabilities are currently estimated to be 

considerably below 1954 levels (Table 3.23-65). Under each of the alternatives, 

additional harvest would further reduce habitat capabilities after 100+ years. 

Reductions would be smallest under Alternative 1 and highest under Alternative 7. 

Table 3.23-65 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 

1954 Habitat Capability, for the WAAs where Wrangell Residents Obtain Approximately 

75% of their Average Annual Deer Harvest*

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA 

Wrangell 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

1905 283 400 400 77 72 67 67 59 66 65 57 

1903 60 60 60 86 80 73 72 63 71 71 60 

1901 30 31 38 91 87 80 78 70 77 77 64 

1530 26 80 147 62 58 57 55 54 55 55 50 

1906 17 17 20 59 55 55 55 55 55 55 53 

*Calculated based on harvest where location is known. 
3 Environment and Effects

Subregional Overview and Communities 3-708 Final EIS

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, should be able to provide 

sufficient habitat capability for deer hunted in the Wrangell community use area by 

Wrangell residents, all rural hunters, and all hunters in the short term. This is also 

estimated to be the case for Wrangell residents and all rural hunters in the long 

term. Projected deer harvest by all hunters is, however, estimated to exceed 10 

percent habitat capability, the level that the analysis assumed would provide a 

reasonably high level of hunter success for their effort, in the long term. 

In summary, use of most subsistence resources by Wrangell residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. The 

risks of this occurring are greatest under Alternative 7, and second highest under 

Alternative 4. Alternatives 1, 2, and 3 would have the lowest risk and Alternatives 5 

and 6 would be intermediate. The risk of hunting restrictions would be reduced 

somewhat, through more intensive management (e.g., thinning) of the existing and 

future closed-canopy, young-growth forests in this area. Indirect effects associated 

with increased competition for deer within Wrangell’s subsistence use areas could 

also occur under all alternatives due to displacement of hunters from other 

communities due to timber harvest activity. Additional road development under the 

alternatives would improve access but may increase competition with other nonlocal hunters. The level of road development is already relatively high in most of 

these WAAs. Existing open road densities range from 0.3 to 1.1 miles per square 

mile and existing total road densities range from 0.3 to 1.7 miles per square mile in 

the five most important WAAs for Wrangell deer harvest). Long-term (100+ years) 

road development would vary by alternative and would result in estimated maximum 

total road densities ranging from 0.4 to 1.9 miles per square mile in these WAAs 

under Alternative 1, to 1.1 to 2.0 miles per square mile under Alternative 7 (for all 

ownerships combined). 

Yakutat is located in the lowlands along the northern Gulf of Alaska, 212 miles 

northwest of Juneau at the mouth of Yakutat Bay. According to the 2000 Census, 

Yakutat had a 2000 population of 680, with Alaska Natives comprising 47 percent of 

the total (U.S. Census Bureau 2001). 

Yakutat, which means “the place where the canoes rest,” has a diverse cultural 

history. The original settlers, believed to have been Eyak people from the Copper 

River area, were later conquered by the Tlingits. Intensive contact with European 

explorers came in the late 1700s when a Russian fur trading company moved into 

the Yakutat area. By the mid-1800s, foreign traders were well established along the 

coast. The contemporary town grew up around “the old village,” which was 

established in 1889 by missionaries (ADF&G 1994). 

Incorporated as a first-class city in 1948, Yakutat is governed by a mayor and a city 

council. Yakutat Borough, incorporated in 1992, expanded the original city 

boundaries to include a large section of the Gulf Coast north of Cape Fairweather. 

Yakutat has a local Fish and Game Advisory Committee. Yakutat is accessible by 

jet service from Juneau and Anchorage. Wrangell-Saint Elias National Park, Russell 

Fiords Wilderness, and Glacier Bay National Park are located northwest, northeast, 

and southeast of Yakutat, respectively. 

The population of Yakutat, which almost tripled between 1970 and 1990, increased 

by 27 percent between 1990 and 2000. Population in Yakutat has, however, 

decreased since 2000, with an estimated net loss of 62 residents or 9 percent of the 

Yakutat 
 Environment and Effects 3 

Final EIS 3-709 Subregional Overview and Communities 

2000 population. Total estimated population was 609 in Yakutat in 2006 (Alaska 

DOL 2007a). 

Year 1970 1980 1990 2000 2005 2006 

Population 190 449 534 680 618 609 

Source: USDA Forest Service, 1997a; U.S. Census Bureau, 2001; Alaska DOL, 2007a

The Yakutat economy is primarily dependent on fishing, fish processing, and 

government. A total of 162 residents hold commercial fishing permits. Fishing 

opportunities in the area, both freshwater in the Situk River and saltwater, are 

considered world class, and 25 percent of the local residents have commercial 

fishing licenses. North Pacific Processors is the major private employer (Alaska 

DCED 2002; 2006). 

Employment by industry data compiled by the Alaska DCED from the 2000 Census 

are summarized in the table below. Approximately 8 percent of the labor force in 

Yakutat was identified as unemployed and seeking work in 2000, compared to 7 

percent for Southeast Alaska as a whole. Median household income was $46,786, 

compared to a regional median of $44,118 (Alaska DCED 2002). 

Please refer to the 1997 Forest Plan EIS for further details on the history, economy, 

and subsistence use of this community. 

Yakutat is part of the Yakutat community group (see Table 3.23-6). Detailed 

employment data are available for this community group by economic sector for 

1990, 1995, and 2000 in the planning record. 

Employment by Industry Number Percent of Total

Agriculture, Forestry, Fishing & Hunting, Mining 136 31 

Construction 32 7 

Manufacturing 25 6 

Wholesale Trade 0 0 

Retail Trade 21 5 

Transportation, Warehousing & Utilities 64 15 

Information 5 1 

Finance, Insurance, Real Estate, Rental & Leasing 9 2 

Professional, Scientific, Management, Administrative & Waste 

Mgmt 

0 0 

Education, Health & Social Services 62 14 

Arts, Entertainment, Recreation, Accommodation & Food 

Services 

43 10 

Other Services (Except Public Admin) 13 3 

Public Administration 30 7 

Total Employment 440 100 

Source: Alaska DCED 2002 

The services and non-federal government sectors were the main employers in the 

Yakutat community group in 1999, accounting for 24 and 21 percent of total 

employment, respectively. Seafood processing accounted for 17 percent and 

recreation and tourism-related activities (lodging, restaurants, and recreation 

services) accounted for 19 percent of total employment. Wood products (logging) 

employment decreased by 65 percent between 1990 and 1999 and accounted for 

just 3 percent of total employment in 1999. 
3 Environment and Effects

Subregional Overview and Communities 3-710 Final EIS

Potential Effects 

Community Use Area 

The general area commonly used or related to by many of the residents of Yakutat 

in their local day-to-day work, recreational, and subsistence activities is shown on 

Figure 3.23-33. This area contains 250,271 acres of National Forest System land 

(among other land ownerships). Table 3.23-66 shows how the lands within this 

community use area would be distributed among the LUD groups by alternative. 

The LUD groups are explained in the introduction to Chapter 3. 

Development LUDs presently account for just 15 percent of the acreage in the 

Yakutat community use area. Alternatives 5 and 6 would not have a significant effect 

on existing LUD allocations in this community use area because the acreage by LUD 

group would remain the same as under the existing Forest Plan. The acreage 

allocated to Wilderness/National Monument LUDs would remain constant under all 

alternatives. The amount of acreage allocated to Mostly Natural LUDs would 

increase under Alternatives 1 and 2. The largest increase would occur under 

Alternative 1, with the acreage allocated to Mostly Natural LUDs increasing from 47 

percent under Alternative 5 (No Action) to 62 percent under Alternative 1, with a 

commensurate reduction in development LUDs (Table 3.23-66). Alternatives 4 and 7 

would increase the acreage in development LUDs. Development LUDs would 

account for 18 percent of the Yakutat Community Use Area under both of these 

alternatives compared to 15 percent under Alternative 5. 

Total suitable acres would range from no acreage under Alternative 1 to 8 percent 

under Alternatives 4 and 7, compared to 7 percent of the total community use area 

under Alternative 5 (No Action). 

Economy 

Commercial fishing and subsistence are important to Yakutat. Oil exploration may 

begin again in the Pacific Ocean close to Yakutat. The Yakutat Forelands are some 

of the community’s most important subsistence use areas. Commercial fishing is 

not expected to be affected under any of the alternatives. 

Subsistence 

No significant effect on salmon, other finfish, or invertebrate habitat capability is 

expected from implementation of any alternative. These resources account for 82 

percent of the total edible pounds of subsistence resources harvested by Yakutat 

households (Kruse and Frazier 1988). Marine resources (fish and marine 

invertebrates) accounted for 74 percent of per capita subsistence harvest in Yakutat 

in 2000. 

Moose are more important than deer as a subsistence meat source for Yakutat 

residents. Moose availability would not be significantly affected under any of the 

alternatives. 

The 1988 TRUCS study found that deer account for only a small fraction of the total 

edible pounds of subsistence resources harvested by Yakutat households (Kruse 

and Frazier, 1988). Deer accounted for 1 percent of per capita subsistence harvest 

by Yakutat residents in 2000 (ADF&G 2006). 
 Environment and Effects 3 

Final EIS 3-711 Subregional Overview and Communities 

Figure 3.23-33 

Yakutat’s Community Use Area 

Table 3.23-66 

LUD Groups in Yakutat’s Community Use Area by Alternative 

 Alternative 

 1 2 3 4 5 6 7 

Suitable National Forest System Acres for Timber Management 

Suitable Acres 0 9,089 18,548 20,170 18,548 18,548 20,267

LUD Groups Acres of National Forest System Land per LUD Group 

Wilderness/National Monument 95,871 95,871 95,871 95,871 95,871 95,871 95,871

Mostly Natural 154,401 138,784 117,169 108,175 117,168 117,168 108,893

Moderate Development 0 13,514 20,667 19,029 20,668 20,668 18,077

Intensive Development 0 2,103 16,565 27,195 16,565 16,565 27,431

Total 250,271 250,271 250,271 250,270 250,271 250,271 250,272 1 See the accompanying large LUD map for the distribution of existing LUDs and the Alternative Maps for the distribution of LUDs by 

alternative. 
3 Environment and Effects

Subregional Overview and Communities 3-712 Final EIS

Yakutat residents harvested very few deer from 1996-2002, harvesting an annual 

average of more than one deer in just two WAAs over this period (Table 3.23-67). 

One of these WAAs is located in GMU 4; the other is located in GMU 5A. Deer 

harvest in GMU 4 is considered very high relative to other areas of Southeast 

Alaska, which is indicative of relatively high deer populations (ADF&G 2005). Over 

1997-2004, there has been no significant trend in the number of deer harvested or in 

the number of hunters (ADF&G 2005). The human population of Yakutat declined 

by an estimated 9 percent between 2000 and 2005, with an estimated 2005 

population of 618 residents. 

Yakutat residents take the majority (78 percent) of their deer from two WAAs (Table 

3.23-67). These numbers are, however, somewhat misleading due to the overall 

low deer harvest levels. In addition, deer harvest only occurred in WAA 4252, which 

is some distance from Yakutat near Hoonah, during one year. 

Table 3.23-67 

Deer Harvest (1996 to 2002) and Deer Habitat Capability on NFS Lands in 2005 and After 

100+ Years of Full Implementation under Each Alternative, Expressed as a Percent of 

1954 Habitat Capability, for the WAAs where Yakutat Residents Obtain Approximately 

75% of their Average Annual Deer Harvest*

Average Deer Harvest from 

1996 to 2002 

Deer Habitat Capability in 2005 and after 100+ Years of 

Full Implementation Under Each Alternative, Expressed 

as a Percent of the 1954 Habitat Capability 

WAA 

Yakutat 

Residents 

All Rural 

Hunters 

All 

Hunters 2005 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6 Alt 7 

4252 4 75 99 92 92 78 78 70 77 76 69 

4504 3 3 4 100 100 100 100 100 100 100 100 

3835 1 4 218 100 100 100 100 100 100 100 100 

*Calculated based on harvest where location is known. 

The Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS determined that the 1997 Alternatives 2, 6, and 11, which are 

similar to the four highest harvest alternatives in this EIS, should be able to provide 

sufficient habitat capability for deer hunted in the Yakutat community use area by 

Yakutat residents, all rural hunters, and all hunters in the short term. This is also 

estimated to be the case for Yakutat residents and all rural hunters in the long term. 

Projected deer harvest by all hunters is, however, estimated to exceed 10 percent 

habitat capability, the level that the analysis assumed would provide a reasonably 

high level of hunter success for their effort, in the long term. 

In summary, use of most subsistence resources by Yakutat residents (fish and 

marine invertebrates) is not expected to be affected by any of the alternatives. 

However, subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, even under Alternative 1. With 

the exception of WAA 4252, the highest use areas for Yakutat households are within 

Wilderness and LUD II designations that will not change by alternative. 

Environmental Justice 

Executive Order 12898, Federal Actions to Address Environmental Justice in 

Minority Populations and Low-Income Populations, requires each federal agency to 

make the achievement of environmental justice part of its mission by identifying and 

addressing disproportionately high and adverse human health or environmental 

effects of its programs, policies, and activities on minority and low-income 
 Environment and Effects 3 

Final EIS 3-713 Subregional Overview and Communities 

populations. The Order further stipulates that the agencies conduct their programs 

and activities in a manner that does not have the effect of excluding persons from 

participating in, denying persons the benefits of, or subjecting persons to 

discrimination under such programs, policies, and activities because of their race, 

color, or national origin. 

Race and ethnicity are shown by borough in Table 3.23-68. These data show that 

68 percent of the population of Southeast Alaska identified as White in the 2000 

census. American Indian and Alaska Native was the largest minority group, 

accounting for 17 percent of the total Southeast Alaska population. Table 3.23-68 

indicates that there are relatively large proportions of Alaska Natives in the Yakutat 

Borough and Prince of Wales-Outer Ketchikan and Skagway-Hoonah-Angoon 

Census Areas. The populations of Haines and Juneau, in contrast, have relatively 

low proportions of Alaska Natives, below the Southeast Alaska average of 17 

percent. 

Alaska Native populations are identified as a percentage of total population by 

community in Table 3.23-8. This information is presented graphically in Figure 3.17-

1 (in the Subsistence section). These data indicate that 13 of Southeast Alaska’s 32 

communities have Alaska Native populations that comprise a larger share of total 

population than the regional average (17 percent). Alaska natives comprised a 

particularly large share of total population in Angoon (82 percent), Hoonah (61 

percent), Hydaburg (85 percent), Kake (67 percent), Klawock (51 percent), 

Metlakatla (82 percent), and Saxman (66 percent), all considered traditional Native 

communities.

Table 3.23-68 

Race/Ethnicity by Borough/Census Area, 2000 

2000 

Population

Percent 

White 

Percent 

American 

Indian and 

Alaska 

Native 

Percent 

Two or 

More Races 

Percent 

Other1 

Percent 

Hispanic or 

Latino2 

Northern Boroughs 

Haines Borough 2,392 83 12 5 1 1 

Juneau Borough 30,711 75 11 7 7 3 

Sitka Borough 8,835 69 19 8 5 3 

Skagaway-Hoonah-Angoon CA 3,436 57 36 6 2 2 

Yakutat Borough 808 50 40 8 2 1 

Southern Boroughs 

Ketchikan Gateway Borough 14,070 74 15 5 5 3 

Prince of Wales-Outer Ketchikan CA 6,146 53 39 7 1 2 

Wrangell-Petersburg CA 6,684 73 16 8 3 2 

Southeast Alaska 73,082 68 17 7 8 3 

Alaska 626,932 69 16 5 10 4 

1 The “Other” category presented here includes respondents identifying as Black or African American, Asian, Native Hawaiian and Other 

Pacific Islander, and Other. These categories have been combined for ease of presentation and because they comprise small 

percentages of local populations. 

2 “Hispanic” can be of any race. 

Source: U.S. Census Bureau, 2001.

The percent of households below the poverty line and the median household income 

in 2000 are also identified by community in Table 3.23-8. The percent of 

households below the poverty line in Alaska as a whole was 7 percent in 2000. 

Median household income was approximately $51,571. The U.S. Census identified 

14 communities in Southeast Alaska with a larger percent of households below the 

poverty line than the state average. These communities include Klawock, Hoonah, 

Edna Bay, Hydaburg, Port Alexander, and Angoon, as well as Hyder and Port 
3 Environment and Effects

Subregional Overview and Communities 3-714 Final EIS

Protection. Median household incomes ranged from $36,048 in Haines Borough to 

$49,924 in the City and Borough of Juneau (U.S. Census Bureau 2001). All but four 

of the communities identified in Table 3.23-8 had median household incomes below 

the state average. Communities with median household income below the regional 

average included Port Protection, Hyder, Point Baker, Edna Bay, Angoon, and 

Hydaburg. 

The potential effects of the alternatives on the economic and social environment of 

Southeast Alaska are discussed in the Economic and Social Environment section of 

this document. The principal regional effects would be those associated with 

changes in the timber industry and recreation and tourism. There could also be 

potential effects upon subsistence use and heritage resources that have particular 

significance for Alaska Native populations. 

The effects of the alternatives on communities are discussed by community in the 

preceding part of this section. These community assessments include a discussion 

of potential timber harvesting within each community’s use area and the potential 

effects to the subsistence resources and the land base used by each community. 

Wood products employment is projected to be higher than current levels under all of 

the alternatives, except Alternative 1. Projected increases for the other alternatives 

ranging from 1.8 times the 2005 harvest level under Alternative 2 to 3.9 times under 

Alternative 7. The slight increases in projected employment under Alternative 2 when 

compared to 2005 harvest levels is still a decrease when compared to projected 

employment levels under Alternative 5 (No Action). Further, it could be argued that the 

alternatives that do not emphasize timber production represent a possible foregone 

opportunity for increased employment in the wood products sector. Even viewed in 

terms of a comparison of alternative projections, relative reductions in employment 

would be unlikely to have a disproportionately high effect on low-income and minority 

communities or groups. Relative reductions in sawmill employment would be 

concentrated in Ketchikan, Wrangell, and Craig. Reductions in logging employment 

would likely be distributed throughout Southeast Alaska, depending upon the 

alternative. 

The mix of available recreation opportunities would vary by alternative based on the 

allocation of the Forest to different LUD groups. However, viewed in terms of 

projected recreation and tourism employment over the next decade, there would be 

very little difference between the alternatives. Recreation and tourism-related 

economic impacts are not expected to disproportionately affect minority or lowincome populations. 

Subsistence issues are discussed for the region as a whole in the Subsistence

section and for each of Southeast Alaska’s 32 communities in the preceding part of 

this section. The deer analysis presented in the 1997 Tongass Forest Plan Final 

EIS indicated that deer habitat capabilities in several portions of the Tongass may 

not be adequate to sustain the current levels of deer harvests, which may result in 

restrictions on subsistence use at some point in the future. 

The potential effects of the alternatives upon heritage resources are expected to be 

the same or lower than under the current Forest Plan. Because of the protection 

offered by Forest-wide standards and guidelines, effects on heritage resources are 

expected to be low under all the alternatives. 
CHAPTER 4 

LIST OF PREPARERS 
List of Preparers 4 

Final EIS 4-1 List of Preparers 

List of Preparers 

Provided below are brief biosketches of the preparers from Tetra Tech and the primary reviewers and 

contributors from the Forest Service. Other Forest Service, Tetra Tech, and other agency staff, who 

contributed to various sections through an extensive internal review process, or in other ways, are also 

listed. 

Lee Kramer, Forest Service Project Manager 

Education 

B.S., Forest Management, Auburn University, 1979 

A.A., Degree from Eastern Wyoming College, 1975 

Experience 

Thirty years of Forest Service experience, including various Ranger District staff positions in 

Alabama, Virginia, Oklahoma, and New Mexico. 

Forest Planning or Forest Staff positions in Colorado, Wyoming, and Montana. 

Larry Lunde, Tongass Planning Staff Officer – Forest Service 

Education 

B.S., Forest Management, Washington State University, 1973 

Experience 

Twenty-eight years of Forest Service experience. 

Tongass National Forest, Environmental Coordinator and Planner. 

Previous experience in forest and multiple-use management positions as District Resource 

Staff and District Ranger, including Nez Perce National Forest in Idaho, Eldorado National 

Forest in California, Gifford Pinchot National Forest in Washington, and Mount Hood and 

Fremont National Forests in Oregon. 

Patricia O’Connor – Tongass Wildlife and Subsistence Staff Officer 

 Education 

M.S., Natural Resource Management, Humboldt State University, 1988 

B.S., Biology, Cornell University, 1983 

Experience 

Nineteen years of Forest Service experience, including several years as a staff wildlife 

biologist on the Mt. Hood National Forest in Oregon and on the Lolo National Forest in 

Montana. Five years as the Yukatat District Ranger on the Tongass National Forest. 

Randal Fairbanks, Interdisciplinary Team Leader, Project Manager – TtEC 

 Education 

M.S., Forest Resources, University of Washington, 1979 

B.S., Wildlife Science, University of Washington, 1972 

 Experience 

Thirty-three years of experience in design, conduct, and management of ecological and 

forest inventory and research, impact assessments, and mitigation plans. 
4 List of Preparers 

List of Preparers 4-2 Final EIS 

Project manager or interdisciplinary team leader for 11 major forest management-related 

EIS/EA efforts. 

Major contributor to dozens of other EISs, EAs, and Environmental Reports. 

Joe Iozzi, Silviculturist/Forester, Asst. Project Manager – TtEC 

 Education 

Silviculture Institute, University of Washington, 1984 to 1985 

B.S., Forest Management, Rutgers University, 1977 

 Experience 

Twenty-seven years of experience in silviculture and natural resource management, primarily 

on Forest Service and NEPA projects. 

Thirteen years as a certified silviculturist for the Forest Service. 

Nine years of experience working on timber sale and transportation management projects on 

the Tongass National Forest, project manager for the Forest-wide roads analysis and 

several NEPA projects. 

Matt Dadswell, Senior Social Scientist/Economist – TtEC 

 Education 

Ph.D., Candidate, Geography, University of Washington 

M.A., Geography, University of Cincinnati, 1990 

B.A., Economics and Geography, Portsmouth Polytechnic, 1988 

 Experience 

Fifteen years of experience conducting economic, social, and environmental regulatory 

analysis on a variety of natural resource projects, including Forest Service and NEPA 

projects. 

Ten years of experience working on Forest Service projects, including projects on the 

Tongass National Forest. 

John Knutzen, Senior Fisheries Biologist/Aquatic Ecologist – TtEC 

 Education 

M.S., Fisheries, University of Washington, 1977 

B.A., Biology, Western Washington State College, 1972 

 Experience 

Twenty-nine years of experience evaluating developmental activity impacts to lakes, rivers, 

and stream water quality and aquatic resources in the Pacific Northwest, with 

emphasis on salmonids. 

Experience working on more than 60 projects in the Pacific Northwest, including assessing 

effects of federal actions on endangered fish species. 

Provided scientific evaluation on more than 25 NEPA documents, including Forest Service 

EISs for the Tongass National Forest. 

Steve Negri, Wildlife Biologist – TtEC 

 Education 

M.S., Wildlife Ecology, Michigan State University, 1995 

B.S., Business Finance, University of Missouri, 1985 
List of Preparers 4 

Final EIS 4-3 List of Preparers 

 Experience 

Thirteen years of experience as a wildlife biologist, including work on three EISs for the 

Tongass National Forest and more than a dozen Forest Service-related projects. 

Experience working on approximately 15 EISs and other NEPA documents in the Pacific 

Northwest and Alaska. 

Previous experience includes working 5 years as threatened and endangered species 

biologist for the Washington Department of Fish and Wildlife. 

Brita Woeck, Wildlife Biologist – TtEC 

 Education 

M.S., Wildlife Ecology and Management, University of Missouri, Columbia, 2003 

BS, Wildlife Science, University of Washington, 1999 

 Experience 

Seven years of experience conducting all phases of ecological research. 

Experience includes ecological study development and coordination, data collection and 

analysis, results interpretation and presentation, and NEPA analysis. 

Work experience focuses on population dynamics, resource selection and space use 

patterns, and community ecology; with responsibility for vegetation and wildlife 

population surveys, radiotelemetry, and wildlife capture and immobilization. 

Mary Jo Russell, GIS Analyst – TtEC 

 Education 

B.S., Computer Information Systems, Menlo College 

 Experience 

Fourteen years of experience as a GIS analyst specializing in creating complex riparian 

models, surface models, habitat models, perspective scene analysis, aerial photo 

interpretation of logging units, preparation of field maps, and final production of maps 

for numerous timber sale EISs. 

Experience includes serving as lead GIS analyst on more than a dozen Forest Service 

projects, including four EIS projects specific to Southeast Alaska and the Tongass 

National Forest. 

Mary Clare Schroeder, Wetland Scientist /Botanist – TtEC 

 Education 

B.A., Botany, University of Washington, 2000 

MBA, University of Chicago, 1993 

Experience 

 Six years of experience working on EIS and NEPA documents. 

Field experience performing wetland delineation; wetland mitigation; planning and monitoring; 

and national, state, and local project permitting. 

Experience conducting wetland and plant surveys on the Tongass National Forest. 

Stephanie Phippen, PG, Geoscientist – TtEC 

 Education 

M.S., Geology/Watershed Science, Colorado State University, 2000 

B.A., Geology, Carleton College, 1996 

Professional Geologist, UT, Number 5557302-2250 
4 List of Preparers 

List of Preparers 4-4 Final EIS 

 Experience 

Seven years of experience in siting, environmental assessment of impacts to watersheds and 

water resources. 

Field of expertise is geomorphology (fluvial, colluvial, and glacial), with supporting strengths 

in hydrology (surface and groundwater), soil science, and statistics. 

Experience completing analyses of water quality, road networks, geomorphology, soils, 

hydrology, geology, and cumulative effects for EIS, EA, landscape and watershed 

assessment, geologic risk assessment, and geomorphic mapping projects. Published 

original research that quantifies the impacts of roads and other forms of land 

management on stream-channel equilibrium, sediment movement, and watershed 

stability. 

Dave Cox, Hydrologist/Minerals Specialist – TtEC 

 Education 

B.S., Geology, Western Washington University, 2000 

 Experience 

Six years of experience in hydrology, geomorphology, and natural resource management, 

primarily on Forest Service and NEPA projects. 

Field of expertise is hydrology, geomorphology, and regulatory compliance with supporting 

strengths in soil science. 

Previous experience working on three National Forests, including four years on the Tongass 

National Forest as project manager, hydrologist, and minerals administrator for projects 

including mine development, hydropower, transportation, and recreation. 

Susan Corser, Landscape Architect/Recreation Planner – Ernst Corser Associates 

 Education 

M.U.P., Urban Planning, University of Washington, 1989 

M.A., Landscape Design, Conway School of Landscape Design, 1983 

B.A., Geography and Environmental Studies, Macalester College, 1977 

 Experience 

Twenty-one years of experience conducting visual analyses, recreation demand studies, 

urban planning, and public meeting facilitation. Conducted visual, recreation, and land 

use impact analyses for hydropower, mine, landfill, ski area, and water supply projects. 

Ten years of experience working on environmental analyses on Forest Service or BLM lands, 

including two years experience working on NEPA projects within the Tongass National 

Forest. 

Marcy Rand, Public Involvement Coordinator – TtEC 

 Education 

B.A., Journalism and Mass Communications, Washington and Lee University, 1992 

 Experience 

Thirteen years of writing/editing/public involvement experience. 

Extensive writing/editing/public involvement experience with NEPA and Forest Service 

documents, including 10 EISs/EAs. 
List of Preparers 4 

Final EIS 4-5 List of Preparers 

Experience includes developing, writing, and producing factsheets, brochures, newsletters, 

news releases and advertisements; public outreach plan development and 

implementation; scoping and public comment coordination; and public meeting 

assistance. 

Maggie Huffer, Technical Editor/Public Involvement Coordinator – TtEC 

 Education 

B.A., Journalism/Public Relations, Western Washington University, 2000 

 Experience 

Seven years of experience writing, editing, and coordinating numerous environmental 

reports, including multi-volume EISs and other NEPA documents. 

Experience working on four Forest Service EISs specific to Southeast Alaska and the 

Tongass National Forest. 

T. Weber Greiser, Heritage Resource Specialist/Archaeologist 

 Education 

M.A., Anthropology, University of New Mexico, 1972 

B.A., Anthropology, University of New Mexico, 1969 

 Experience 

Twenty-seven years of experience as Project Manager and/or Principal Investigator on 

heritage resource projects in Alaska and throughout the Western U.S. Experience 

includes prehistoric and historic archaeological predictive modeling; heritage resource 

surveys, testing projects, and excavations; laboratory analysis of artifacts and faunal 

remains; and ethnographic investigations and oral interviews of native inhabitants 

regarding land use, water use, and sacred lands. 

Heritage resource Principal Investigator for background research, cultural resource survey, 

preparation of specialist report, and/or preparation of EA or EIS cultural resource 

sections for nine projects since 1993 on the Tongass. 

Eric Henderson, SPECTRUM Model Analyst – USDS Forest Service, Region 9 

Education 

M.S., Forest Management (2003), University of Minnesota 

B.B.A., Business Administration (2000), University of Iowa 

Experience 

Four years of experience as Forest Service Analyst/Planner, specializing in landscape 

planning models, growth and yield models, historic vegetation analysis, and computer 

programming languages. 

Other Contributors

Forest Service 

Rick Abt – Land Management Planner 

Richard Aho – Forest Fisheries Biologist 

Susan J. Alexander – Regional Economist 

John Autrey – Tribal Government Relations Specialist 

Jim Baichtal – Karst Specialist 

Gabriele Bosch – GIS Database Manager 

Jeff Defreest – Minerals 

Karen Dillman – Ecologist 
4 List of Preparers 

List of Preparers 4-6 Final EIS 

Pam Fletcher – Invasive Species Coordinator 

Colleen Grundy – Regional Silviculturist 

Bob Housley – Timber Valuation – Regional Office 

John Inman – Tongass Contracting Officer 

Karen Iwamoto – Land Management Planner 

Susan Jennings – Tongass Document Coordinator 

Steve Kessler – Regional Subsistence – Program Manager 

Patti Krosse – Forest Ecologist 

Dennis Landwehr – Soil Scientist 

Jan Lerum – Regional Planner 

Mark McCallum – Archaeologist 

Dom Monaco – Forest Landscape Architect 

Dennis Neill – Partnership and Public Affairs Staff Officer 

Jack Oien – Supervisory Engineer 

Eric Ouderkirk – Forest Plan Adjustment COR 

Steve Paustian – Hydrology Program Manager 

Betsy Rickards – Alaska Region Environmental Coordinator 

Jim Russell – Silviculture Program Manager 

Jim Schramek – Senior GIS Analyst 

Carol Seitz – Warmuth, Monitoring 

Cynthia Sever – Timber Planning 

JT Stangl – Wildlife Biologist 

Barbara Stanley – Lands 

Julianne Thompson – Hydrologist 

Bill Tremblay – Wilderness/Developed Rec/Rec Special Uses 

Erin Uloth – Ecosystem Services 

Betty Wilt – Highway Engineer 

Office of General Council 

Tim Obst 

Jim Ustasiewski 

State of Alaska 

Chris Maisch – Alaska State Forester 

Linda Hay – Office of the Governor 

Jack E. Phelps – Office of Economic Development 

Ed Fogels – Department of Natural Resources 

Marty Freeman – Department of Natural Resources 

Mike Curran – Department of Natural Resources 

Andy Hughes – Department of Transportation 

Doug Larsen – Department of Fish and Game 

Kim Titus – Department of Fish and Game 

Dale Rabe – Department of Fish and Game 

Tina Cunning – Department of Fish and Game 

Tom Brookover – Department of Fish and Game 

Tetra Tech EC, Inc. 

Matt Kozleski – GIS Analyst 

Chris Spagnuolo – GIS Analyst 

Wayne Watson – GIS Analyst 

Andrea Slusser – Project Record 
List of Preparers 4 

Final EIS 4-7 List of Preparers 

Judy Brown – Desktop Publishing 

Dawn Stuart – Desktop Publishing 

Steve Flegel – Desktop Publishing 

Josh Breen – Desktop Publishing 

Consultants 

John Hendee – Technical Review: Wilderness 

Tom Aley – Technical Review: Karst Resources 
4 List of Preparers 

List of Preparers 4-8 Final EIS 

This page is intentionally left blank. 
CHAPTER 5 

LIST OF DOCUMENT RECIPIENTS 
List of Document Recipients 5

Final EIS 5-1 List of Document Recipients

List of Document Recipients 

Federal Agencies 

Bureau of Land Management, Alaska State Office 

Bureau of Land Management, Juneau Minerals Information Center 

Department of Transportation, Western Federal Lands Highway Division 

Federal Aviation Administration, Office of the Regional Administrator 

Federal Energy Regulatory Commission, Environmental Compliance Branch 

Federal Highway Administration, Division Administrator 

Federal Highway Administration, Regional Administrator - Western Region 

Federal Railroad Administration, Office of Transportation and Regulatory Affairs 

Housing and Urban Development, Alaska Office of Housing and Urban Development 

Library of Congress 

National Marine Fisheries Service, Alaska Region 

National Marine Fisheries Service, Protected Resources Management Division 

National Oceanic and Atmospheric Administration, Office of Policy and Strategic Planning 

National Park Service, Glacier Bay National Park 

National Park Service, Wild and Scenic Rivers Program 

Office of Federal Register, National Archives and Records Administration 

Point Baker Post Office 

Tongass National Forest, Admiralty National Monument 

Tongass National Forest, Assistant Forest Supervisor, Alaska Region 

Tongass National Forest, Craig Ranger District 

Tongass National Forest, Hoonah Ranger District 

Tongass National Forest, Juneau Ranger District 

Tongass National Forest, Ketchikan Ranger District 

Tongass National Forest, Ketchikan Supervisor's Office 

Tongass National Forest, Pacific Northwest Research Station 

Tongass National Forest, Petersburg Ranger District 

Tongass National Forest, Petersburg Supervisor's Office 

Tongass National Forest, Rocky Mountain Research Station 

Tongass National Forest, Sitka Ranger District 

Tongass National Forest, Thorne Bay Ranger District 

Tongass National Forest, Wrangell Ranger District 

Tongass National Forest, Yakutat Ranger District 

US Advisory Council on Historic Preservation, Planning and Review 

US Army Corps of Engineers, Field Office Manager 

US Army Corps of Engineers, Juneau Regulatory Field Office 

US Army Corps of Engineers, Northwestern Division 

US Army Corps of Engineers, Pacific Ocean Division 

US Army Corps of Engineers, Regulatory Office 

US Army Engineer District, East Section 

US Bureau of Mines 

US Coast Guard, Environmental Management CG-443 

US Coast Guard, Seventeenth Coast Guard District 

US Department of Agriculture, APHIS PPD/EAD 
5 List of Document Recipients 

List of Document Recipients 5-2 Final EIS

US Department of Agriculture, National Agricultural Library 

US Department of Agriculture, Natural Resources Conservation Service 

US Department of Agriculture, OPA Publications Stockroom 

US Department of Agriculture, Rural Utilities Service 

US Department of Commerce, Ecology and Conservation Office 

US Department of Energy, Office of NEPA Policy and Compliance 

US Department of the Interior, Office of Environmental Policy and Compliance 

US Department of the Interior, Office of the Secretary 

US Department of the Interior, US Geological Survey 

US Department of Transportation, Environmental Division 

US Environmental Protection Agency, Alaska Operations 

US Environmental Protection Agency, Geo. Imp. Unit 

US Environmental Protection Agency, Office of Federal Activities 

US Environmental Protection Agency, Region 10 

US Fish and Wildlife Service, Office of Subsistence Management 

US Fish and Wildlife Service, Refuge Planning 

US Navy, Environmental Protection Division 

US Navy, Naval Oceanography Division 

US Navy, Office of Chief of Navy Operations 

US Navy, US Naval Air Systems Command 

US Senate, Public Land and Forest Subcommittee 

US Small Business Administration 

USDA Forest Service, Alaska Region 

USDA Forest Service, Chugach National Forest 

USDA Forest Service, Director of Ecosystem Planning and Budget 

USDA Forest Service, Division of Forest Management 

USDA Forest Service, Ecosystem Management Coord. Staff 

USDA Forest Service, Forestry Sciences Laboratory 

USDA Forest Service, Forestry Services Library 

USDA Forest Service, Hiawatha National Forest 

USDA Forest Service, Office of the Chief 

USDA Forest Service, Region 10, Regional Office 

USDA Forest Service, Region 9, Regional Office 

USDA Forest Service, SE Regional Subsistence Advisory Council 

USDA Forest Service, Supervisor’s Office 

State and Federal Congressional Representatives 

John Larson, U.S. Representative Mike Doyle, U.S. Representative 

Rush Holt, U.S. Representative Frank Pallone, Jr. , U.S. Representative 

Zoe Lofgren, U.S. Representative Allyson Schwartz, U.S. Representative 

Tammy Baldwin, U.S. Representative Steve Israel, U.S. Representative 

Betty McCollum, U.S. Representative Shelley Berkley, U.S. Representative 

Brad Sherman, U.S. Representative Nita M Lowey, U.S. Representative 

Ellen Tauscher, U.S. Representative Carolyn B Maloney, U.S. Representative 

Jim McDermott, U.S. Representative Don Young, U.S. Representative 

Carolyn McCarthy, U.S. Representative Pete Stark, U.S. Representative 

John Olver, U.S. Representative Mark Udall, U.S. Representative 

Anthony D Weiner, U.S. Representative Jane Harman, U.S. Representative 

Christopher Shays, U.S. Representative Tom Lantos, U.S. Representative 

Sam Farr, U.S. Representative Maurice Hinchey, U.S. Representative 
List of Document Recipients 5

Final EIS 5-3 List of Document Recipients

Rahm Emanuel, U.S. Representative Shelia Jackson Lee, U.S. Representative 

Ron Kind, U.S. Representative Robert Andrews, U.S. Representative 

Chris Van Hollen, U.S. Representative Corrine Brown, U.S. Representative 

Raul Grijalva, U.S. Representative Earl Blumenauer, U.S. Representative 

Ben Chandler, U.S. Representative Louise Slaughter, U.S. Representative 

Eddie Bernice Johnson, U.S. Representative Joseph Crowley, U.S. Representative 

Grace Napolitano, U.S. Representative Stephen Lynch, U.S. Representative 

Carolyn C Kilpatrick, U.S. Representative Jose E Serrano, U.S. Representative 

Gregory W Meeks, U.S. Representative Jim Moran, U.S. Representative 

Michael Honda, U.S. Representative Nydia M Velazquez, U.S. Representative 

Barbara Lee, U.S. Representative Gary Ackerman, U.S. Representative 

Dennis J Kucinich, U.S. Representative Barney Frank, U.S. Representative 

Lloyd Doggett, U.S. Representative Rosa DeLauro, U.S. Representative 

Anna Eshoo, U.S. Representative Lynn Woolsey, U.S. Representative 

Dale E Kildee, U.S. Representative Sander Levin, U.S. Representative 

Ed Markey, U.S. Representative Steven Rothman, U.S. Representative 

Roberty Wexler, U.S. Representative Michael McNulty, U.S. Representative 

Peter DeFazio, U.S. Representative Jim Marshall, U.S. Representative 

Eliot L Engel, U.S. Representative Richard J Durbin, U.S. Senator 

David Price, U.S. Representative Lisa Murkowski, U.S. Senator 

Rick Boucher, U.S. Representative Ted Stevens, U.S. Senator 

George Miller, U.S. Representative Albert Kookesh, State Senator 

Donald M Payne, U.S. Representative Peggy Wilson, State Representative 

Tim Ryan, U.S. Representative 

Alaska Native Tribes and Corporations 

Aboriginal Rights Committee 

Alaska Federation of Natives 

Alaska Native Brotherhood 

Alaska Native Brotherhood, Camp #01 

Alaska Native Brotherhood, Camp #03 

Alaska Native Brotherhood, Camp #04 

Alaska Native Brotherhood, Camp #05 

Alaska Native Brotherhood, Camp #06 

Alaska Native Brotherhood, Camp #07 

Alaska Native Brotherhood, Camp #08 

Alaska Native Brotherhood, Camp #13 

Alaska Native Brotherhood, Camp #14 

Alaska Native Brotherhood, Camp #15 

Alaska Native Brotherhood, Camp #16 

Alaska Native Brotherhood, Camp #19 

Alaska Native Brotherhood, Camp #36 

Alaska Native Brotherhood, Camp #70 

Alaska Native Brotherhood, Camp #91 

Alaska Native Brotherhood, Camp #92 

Alaska Native Sisterhood 

Alaska Native Sisterhood, Camp #01 

Alaska Native Sisterhood, Camp #02 

Alaska Native Sisterhood, Camp #03 

Alaska Native Sisterhood, Camp #04 

Alaska Native Sisterhood, Camp #05 

Alaska Native Sisterhood, Camp #06 

Alaska Native Sisterhood, Camp #07 

Alaska Native Sisterhood, Camp #08 

Alaska Native Sisterhood, Camp #09 

Alaska Native Sisterhood, Camp #10 

Alaska Native Sisterhood, Camp #12 

Alaska Native Sisterhood, Camp #13 

Alaska Native Sisterhood, Camp #15 

Alaska Native Sisterhood, Camp #19 

Alaska Native Sisterhood, Camp #36 

Alaska Native Sisterhood, Camp #70 

Alaska Native Sisterhood, Camp #76 

Alaska Native Sisterhood, Camp #83 

Alaska Native Sisterhood, Camp #90 

Angoon Advisory Committee 

Angoon Tlingit and Haida Community Council 

Angoon Traditional Council 

Cape Fox Corporation 

Central Council Tlingit and Haid Tribes of Alaska 

Chilkat Indian Village (Klukwan) 

Chilkoot Indian Association IRA 
5 List of Document Recipients 

List of Document Recipients 5-4 Final EIS

Chugach Alaska Corporation 

Craig Advisory Committee 

Craig Tlingit and Haida Community Council 

Douglas Indian Association 

Edna Bay Advisory Committee 

Elfin Cove Community, Chairperson 

Gathering Council of Kake 

Gustavus Community Association 

Haida Corporation 

Haida Society 

Haida Tribe 

Hollis Community Action Council 

Hoonah Tlingit and Haida Community Council 

Huna Totem Corporation 

Hydaburg Cooperative Association 

Kadin Corporation 

Kake Tribal Corporation 

Ketchikan Advisory Committee 

Ketchikan Indian Community 

Klawock Cooperative Association 

Klawock Heenya Corporation 

Klawock Tlingit and Haida Community Council 

Klawock Tribal Government 

Klukwan Tlingit and Haida Community Council 

Kootznoowoo Inc. 

Kuiu Thlingit Nation 

Metlakatla Indian Community 

Metlakatla Tlingit and Haida Community Council 

Meyers Chuck Community Association 

Native American Fish and Wildlife Society 

Native Forest Network 

Native Subsistence Commission 

Native Village of Kasaan 

Organized Village of Kake IRA 

Organized Village of Kasaan 

Organized Village of Saxman 

Pelican Tlingit and Haida Community Council 

Petersburg Indian Association 

Point Baker Community Council 

Port Tongass Village Association 

Saanya Kwan -– Tei Kweidi 

Saxman Advisory Committee 

SE AK Regional Subsistence Council 

Sitka Advisory Committee 

Sitka Tlingit and Haida Community Council 

Sitka Tribe of Alaska 

Skagua Traditional Council 

Skagway Village IRA 

Southeast Alaska Conservation Council 

Southeast Native Subsistence Commission 

Southeast Regional Advisory Council 

Sumner Strait Advisory Committee 

Tanana Chiefs Council 

Tlingit and Haida Community Council 

Tlingit and Haida Indians, CBJ 

Tongass Tribe 

Tsimpshian 

Tsimpshian Tribal Council 

Wrangell Advisory Committee 

Wrangell Cooperative Association 

Wrangell Resource Council 

Yak-Tat Kwaan, Inc. 

Yakutat Native Association 

Yakutat Tlingit Tribe 

State Agencies 

Alaska Coastal Management Program, OPMP 

Alaska Department of Commerce and Economic Development 

Alaska Department of Environmental Conservation 

Alaska Department of Fish and Game, Alaska Board of Game 

Alaska Department of Fish and Game, ANILCA 

Alaska Department of Fish and Game, Boards Support 

Alaska Department of Fish and Game, Division of Commercial Fisheries 

Alaska Department of Fish and Game, Division of Habitat and Restoration 

Alaska Department of Fish and Game, Division of Subsistence 

Alaska Department of Fish and Game, Division of Wildlife Conservation 

Alaska Department of Fish and Game, Special Areas Planner 

Alaska Department of Fish and Game, Sport Fish Division 

Alaska Department of Fish and Game, Wildlife Division 

Alaska Department of Labor 

Alaska Department of Natural Resources, Office of Habitat Management and Planning 
List of Document Recipients 5

Final EIS 5-5 List of Document Recipients

Alaska Department of Natural Resources, State Preservation Office 

Alaska Department of Natural Resources, Division of Forestry 

Alaska Department of Natural Resources, Division of Mining, Land and Water 

Alaska Department of Natural Resources, Office of Program Management 

Alaska Department of Transportation and Public Facilities 

Alaska Division of Telecommunication Operations 

Alaska Energy Authority 

Alaska Mental Health Trust 

Alaska Natural Heritage Program 

Alaska State Department of Labor 

Alaska State Parks Advisory Board 

Office of the Governor, State of Alaska 

Resource Development Council of Alaska 

City and Borough Agencies, Libraries, and Schools 

Alaska Court System, Juneau Law Library 

Alaska Court System, Ketchikan Law Library 

Alaska State Library 

Angoon Public School Library 

Bruce Hill School 

City and Borough of Juneau 

City and Borough of Sitka 

City and Borough of Yakutat 

City of Angoon 

City of Coffman Cove 

City of Craig 

City of Hoonah 

City of Hydaburg 

City of Kake 

City of Kasaan 

City of Ketchikan 

City of Klawock 

City of Kupreanof 

City of Pelican 

City of Petersburg 

City of Point Baker 

City of Port Alexander 

City of Saxman 

City of Tenakee Springs 

City of Thorne Bay 

City of Wrangell 

Colorado State University, Morgan Library 

Community of Naukati West 

Community of Whale Pass 

Craig Public Library 

Douglas Public Library 

Edna Bay School Library 

Elfin Cove Public Library 

Esther Greenwald Library 

Greater Ketchikan Chamber of Commerce 

Haines Public Library 

Hollis Public Library 

Hoonah Public Library 

Howard Valentine School 

Hydaburg School Library 

Hyder Public Library 

Juneau Chamber of Commerce 

Juneau City Clerk 

Juneau Public Library 

Kake Community Library 

Kasaan Community Library 

Ketchikan Chamber of Commerce 

Ketchikan Gateway Borough 

Ketchikan High School Library 

Ketchikan Public Library 

Ketchikan Visitors Bureau 

Kettleson Memorial Library 

Klawock Public Library 

Legislative Reference Library 

Mendenhall Valley Public Library 

Metlakatla Centennial Library 

Montana State University, Department of Biology 

Northwestern University, Urban Affairs and Policy 

Research 

Pelican Public Library 

Petersburg Chamber of Commerce 

Petersburg Public Library 

Point Baker Public Library 

Port Commission Wrangell 

Port Protection School 

Prince of Wales Chamber of Commerce 

Prince of Wales Community Advisory Council 
5 List of Document Recipients 

List of Document Recipients 5-6 Final EIS

Sheldon Jackson Library 

Skagway City Council 

Skagway Public Library 

Tenakee Springs Public Library 

Thorne Bay Community Library 

Transylvania Cooperative Extension Service 

University of Alaska - Southeast, Coop Extension 

Service 

University of Alaska - Southeast, Ketchikan College 

Library 

University of Alaska - Southeast, William A. Egan 

Library 

University of Alaska at Fairbanks 

University of Alaska at Fairbanks, School of Natural 

Resources and Agricultural Sciences, Palmer 

Research Center 

University of Alaska Land Management 

University of Minnesota, Forestry Library 

USDA National Agriculture Library 

Utah State University, College of Natural Resources 

Virginia Polytechnic Inst. and State Univ, Dept Fish 

and Wildlife 

Whale Pass School 

Wrangell Chamber of Commerce 

Wrangell Public Library 

Yakutat School District Library 

Other Organizations 

3-D Logging 

Adam Baskett’s Equip. Repair 

Adams Alaskan Safari 

Admiralty Bears Association 

Admiralty Tours 

Adventure Alaska Southeast 

Age Cedar Products 

Ahtna Incorporated 

Alaska Quiet Rights Coalition 

Alaska Angling 

Alaska Association for Historic Preservation 

Alaska Biological Research 

Alaska Board of Fish 

Alaska Center for the Environment 

Alaska Chapter Sierra Club, Auke Bay Group 

Alaska Charter & Adventures 

Alaska Charter Service 

Alaska Coalition 

Alaska Coastal Adventures 

Alaska Coastal Guiding 

Alaska Coastal Hunting 

Alaska Coastal Outfitters 

Alaska Conservation Alliance 

Alaska Conservation Foundation 

Alaska Discovery 

Alaska Environmental Lobby 

Alaska Fibre 

Alaska Fish Tales 

Alaska Fly N Fish Charters 

Alaska Forest Association 

Alaska Forest Products 

Alaska Island Adventures 

Alaska Loggers Association 

Alaska Longline Fishermen’s Association 

Alaska Miners Association 

Alaska Natural History Association 

Alaska Outdoor Adventures 

Alaska Pacific Logging, Inc. 

Alaska Pacific Powder Co. 

Alaska Pacific Trading Company 

Alaska Passages 

Alaska Peak & Seas 

Alaska Power & Telephone Co. 

Alaska Public Radio Network 

Alaska Rainforest Campaign 

Alaska Scenic Charters 

Alaska Scenic Waterways 

Alaska Ship & Drydock, Inc. 

Alaska Society of Forest Dwellers 

Alaska Timber Wolf 

Alaska Timberland Corporation 

Alaska Travel Adventures 

Alaska Travel Industry Association 

Alaska Trollers Association 

Alaska Tugboat Tours 

Alaska Vistas 

Alaska Waters, Inc / Leslie Cutters, Inc 

Alaska Wilderness League 

Alaska Wildlife Alliance 

Alaska Women in Timber 

Alaska Woods Service Company 

Alaska Wyldewind 

Alaska Yacht Adventures 

Alaskan Natural Mystic 

Alaskan Star Charters 

Alaskan Yacht Charters 

Alaskans for Responsible Resource 

Alcan Forest Products 

All Aboard Yacht Charters 

Allweather Industries / The Roadhouse Lodge 
List of Document Recipients 5

Final EIS 5-7 List of Document Recipients

Alpine Communications 

Alsek River Lodge 

American Forest & Paper Association 

American Safari Cruises, Inc. 

American Society of American Foresters 

American Society of American Foresters Juneau 

Chapter 

Anahootz Alaskan Adventure 

Anderson & Associates 

Annette Natural Resource Center 

AP&T 

Applied Sociocultural Research 

Aqua Sports Enterprises 

Associates in Pathology 

Atelier PS 

Atterbury Consultants, Inc. 

Audubon Alaska 

Aurora Films 

Baja Alaskan Experience 

Baltar Consulting 

Baranof Expeditions 

Baranof Wilderness Lodge 

Bear Creek Outfitters 

Bear Valley Lodge 

BearDown Adventures 

Big “R” Manufacturing 

Blackwell Log 

Blue Heron Inn 

Bluewater Adventures, Ltd. 

Bluewater Outfitter 

Boardwalk Wilderness Lodge 

Brabazon Expeditions 

Bravo Venture Group, Inc. 

Breakaway Adventures 

Buchanan General Contracting Co. 

Burgess Logging, Inc. 

California Forestry Association 

California Women in Timber 

Campbell Towing 

Campion Foundation 

Cape Decision Lighthouse Society 

Cape Fox Corporation 

Carlin Air 

Cascade Culvert, Inc. 

Cascade Sand & Gravel 

Cascadia Wildlands Project 

Cedar Bite Trading Post 

Center for Biological Diversity 

Center for Science in Public Participation 

CEO Expeditions 

CH2M Hill 

Chatham Cannery, Ltd. 

Chichagof Conservation Council 

Chilkat Valley Newss 

Citizens Advisory Commission 

Classic Alaska Charters 

Clover Bay Lodge 

Coast Alaska Engineering Support Group 

Coastal Island Adventures 

Coastal Wilderness Charters 

Columbia Helicopter 

Concerned Alaskans for Resource and Environment 

Concerned Citizens for Wise Use 

Construction Machinery, Inc. 

Cook Inlet Regional Incorporated 

Craig Community Association 

Cross Sound Seafoods 

Crossings 

Cruise West 

Crystal Lake Hatchery 

CT Sierra Club 

Customs Charters 

D & L Woodworks 

Daily Sitka Sentinel 

Deer Creek Cottages 

Defenders of Wildlife 

Discovery Southeast 

Dolphin Charters 

Doug Price Partners 

Durette Construction 

EA Engineering 

Earth Justice Legal Defense Fund 

Ecology Center of Southern California 

Ecosystem Management Research Institute 

Edna Bay Fish and Game Advisory Committee 

Elfin Cove Community Association 

Ellis Law Office 

Ellis, Inc. 

ENSR Information Center 

Erickson Air-Crane Co LLC 

Evergreen Helicopters 

Evergreen Timber LLC 

Expeditions, LLC 

Eyak Adventures 

Family Air 

Family Charters 

Family Partnership, Inc. 

Federation of Fly Fishers 
5 List of Document Recipients 

List of Document Recipients 5-8 Final EIS

First Alaskans Institute 

First Bank 

Flywater Adventures 

Forest Conservation Council 

Forest Service Employees for Environmental Ethics 

Friends of Admiralty 

Friends of Glacier Bay 

Friends of Southeast’s Future 

Friends of the Earth 

Friends of the Tongass 

Glacier Bay Cruiseline 

Glacier Energy Limited 

Glacier Grotto 

Glacier Guides, Inc. 

Goldbelt, Inc. 

Grady Lex, Inc. 

Great Alaska Cedar Works, Inc. 

Great Land Consultants 

Greenpeace 

Greg’s EZ Limit Guide Service 

Gregg Scheff & Associates 

Guitar Wood Supply 

H.I.C. Tours 

Harris & Associates 

Harza Engineering 

Haynes Research Group 

Hayward Lumber 

HDR, Inc. 

High Drive Drillins & Blastins Inc 

Hook & Eye Charters 

Hyder Fish and Game Advisory Board 

Icy Strait Lumber & Milling Inc 

Independence Mining Co. 

Information Insights 

Inside Passages 

International Society of Tropical Foresters 

Island News 

Island Point Lodge, Inc. 

Island Voyages, Inc 

Island Wings 

Italio River Adventures 

Italio Sport Camp 

Izaak Walton League 

J&J Forest Products Inc 

Jim’s Alaskan Adventures 

Juneau Audubon Society 

Juneau Empire 

Kake Area Conservation Council 

Kaleidoscope Cruises 

Kavilco Business Office 

Kavilco Inc. 

Kay C Charters 

KB Home 

KCAW-FM Raven Radio 

Ken & Bens Lumber Milling 

Kennecott Minerals 

Keslick and Son Modern Aboriculture 

Ketchikan Air Service 

Ketchikan Charter Boats, Incorporated 

Ketchikan Cutting Co. 

Ketchikan Daily News 

Ketchikan Homebuilders Association 

Ketchikan Outdoor Recreation and Trails Coalition 

Ketchikan Snowmobile Club 

Ketchikan Sportfishing 

Kettle Range Conservation Group 

KFSK Public Radio 

KHNS – FM 

Kilinsnoo Wood & Lumber 

KINY – AM, KSUP – FM, Juneau 

KJNO – AM, KTKU – FM, Juneau 

Klamath-Siskyou Wildlands Center 

Klawock IRA 

Klukwan Inc. 

Koncor Forest Products 

K-Ply 

KRBD Radio 

KRSA Radio 

KSTK – FM 

KTKN Radio 

KTOO 

KTOO TV 

Kupreanof Guides 

Landau Associates 

Lassen Forest Preservation Group 

Laughing Raven Lodge 

LEI Engineering 

Leonard’s Landing 

Lindblad Expeditions 

Log Cabin Resort & RV 

Lynn Canal Conservation, Inc. 

Maple Leaf Adventures 

Mariner, Inc. 

Marlin’s Flyfishing 

Mason Bruce and Girard 

McFarland’s Floatel 

Meridian Environmental 

Midnight Sun Charters 

Mirror Lake Fishing Club 

Montana Multiple Use Association 
List of Document Recipients 5

Final EIS 5-9 List of Document Recipients

Montgomery, Watson, Harza 

Monti Bay Foods 

MSM Resource 

Muskeg Excursions 

Nana Corporation 

Narrows Conservation Coalition 

National Association of Counties (NACo) 

National Association of Forest Service Retirees 

National Association of Home Builders 

National Audubon Society 

National Bank of Alaska 

National Forest Foundation 

National Outdoor Leadership School 

National Parks & Conservation Association 

National Wildlife Federation 

Natural Resources Conservation Svc 

Natural Resources Defence Council 

Natural Resources Management Corporation 

Naukati Adventures 

Naukati West Inc., Homeowners Assc. 

New World Ship Management 

Niblack Mining Company 

Nordic Air 

North Alaska Expeditions 

North American Bear Foundation 

North Arm Expediting 

North Star Equipment Services 

Northern Land Use Research, Inc. 

Northern Star Cedar 

Northland Services, Inc 

Northwest Mining Association (NWMA) 

NSWC/SEAFAC 

Ocean Ranger Charters 

OHV Rough Riders 

Olive Cove Homeowner’s Association 

Olsen & Sons Logging Company 

Olympic Mine, Land Owners 

Olympic Resources 

Outdoor Industries 

Pacific Legal Foundation 

Pacific Log & Lumber, Ltd. 

Pacific North West Capitol Group 

Pacific Rim Log Scaling Bureau, Inc. 

Pacific Salmon Commission 

Paden Timber Services 

Parametrix, Inc. 

Patterson River Guide Service 

Pence Contracting 

Petersburg Fishing Adventures 

Petersburg Pilot 

Petersburg Vessel Owners Association 

Peterson’s Guide & Charter Service 

Petro Alaska, Inc. 

Pew Charitable Trust 

Port Protection Community Association 

Portac Inc 

Porter Lumber 

Prince of Wales Loggers League 

Prince of Wales Conservation League 

Princess Tours 

Promech Air / Yes Bay Lodge 

Rain Walker Expeditions 

Raven Guide Service 

Raven’s Fire, Inc. 

Reid Brothers Logging and Construction Inc. 

Reinhart, Employee Affairs & Public Relations 

Manager 

Renaissance Ketchikan Group 

Resource Development Council 

Roanan Corporation 

Robertson, Monagle & Eastaugh 

Rocky Bay Lodge 

Rocky Pass Resort 

Rocky Point Resort 

Rogue Charters 

Ron’s Alaska Charters 

Ross Family Ltd. 

Salmon Enhancement Board 

Salmon Falls Resort 

Saltery Cove Charters 

Saltery Cove Homeowners Association 

Schmolck Mechanical Contractors 

Sitka State Parks Citizen Advisory Board 

Southeast Alaska Regional Advisory Committee 

Southeast Alaska Regional Subsistence Council 

Southeast Alaska Regional Health Corporation 

Southeast Alaska Wood Products 

Sea Buggy Charters 

Sealaska Corporation 

Sealaska Cruises, Inc. 

Sealaska Heritage Institute 

Sealaska Timber Corporation 

Seawind Charters 

See Alaska Tours & Charters 

Shaan-Seet, Inc. 

Sharp Lumber 

Shee Atika, Inc. 

Sierra Club 
5 List of Document Recipients 

List of Document Recipients 5-10 Final EIS

Sierra Club / Guadalupe Regional Group 

Sierra Club Legal Defense Fund/Earth Justice 

Silver Bay Logging 

Silver King Marine 

Sitka Charter Boat Operators Association 

Sitka Conservation Society 

Sitka Recreational Riders, Inc. 

Sitkans for a Sound Economy 

Skagway News 

Smart Construction 

Smayda Environmental Associates, Inc. 

Society of American Foresters 

Sound Sailing, Inc. 

Southeast Alaska Conservation Council 

Southeast Alaska Fishermen’s Alliance 

Southeast Alaska Flyfishing 

Southeast Alaska Guidance Association 

Southeast Alaska Guiding 

Southeast Alaska Land Acquisition Coalition 

Southeast Alaska Outdoor Recreation 

Southeast Alaska Regional Advisory Council 

Southeast Alaska Regional Dive Fisheries Association 

Southeast Alaska Resources 

Southeast Alaska Wood Products 

Southeast Conference 

Southeast Exposure 

Southeast Guide Service 

Southeast Hunts 

Southeast Stevedoring Corp. 

Southern SE Regional Aquaculture Association 

Sportsman’s Alliance for Alaska and Others 

Stikine Guide Service 

Stikine River Song Charters 

SUMDUM Yacht Charters 

Sumner Strait Fish and Game Advisory Committee 

Sunnyside School Library 

Sunrise Aviation 

Susquehanna River Basins Commission 

Taku Conservation Society 

Taquan Air Service 

Tech Cominco 

Temsco Helicopters, Inc. 

Tenacious Charters 

Tenakee Hot Springs Lodge 

Territorial Sportsmen 

Thayer Lake Lodge 

The Boat Company 

The Camp Fire Club of America / Committee on 

Conservation of Forests and Wildlife 

The Fishermen’s Inn 

The Louisiana Forestry Association 

The Mill Inc 

The Nature Conservancy of Alaska 

The Presidio of San Francisco 

The Wilderness Society 

The Yakutat Lodge 

Thorne Bay Wood Products 

Timber Data Co 

Timber Fallers, Incorporated 

Timbersource.com 

Timberwolf Charters 

Tolko Industries Ltd. 

Tongass Cave Project 

Tongass Community Alliance 

Tongass Conservation Society 

Tongass Futures Roundtable 

Tongass Kayak Adventures 

Trout Unlimited 

TRUCO 

Tuxekan Logging 

Tuxekan Logging 

UAF – Sitka Forest Products 

Unforgettable Charters 

United Fishermen of Alaska 

URS Corporation 

Van Os Nature Tours 

Vanguard Research 

Venture Pacific Marine, Inc. 

Viking Lumber Co. 

W.R. Tonsgard Logging & Lumber 

Walt Sheridan & Associates 

Washington Wilderness Coalition 

Water Ouzel Outtings 

Waterfall Resort 

Wesley Richard, Inc. 

Western Audubon Society 

Western Gold Cedar Products 

Whalers Cove Lodge 

Wild Rockies Field Institute 

Wilderness Enterprises 

Wilderness Watch 

Wildlands Center for Preventing Roads 

Wildlife Federation of Alaska 

Wildlife Forever 

Wilks Logging 

WO Development 

Wood Product Committee 

WR Jones & Son Lumber Co. 

Wrangell Historical Society 

Wrangell Research Associates 
List of Document Recipients 5

Final EIS 5-11 List of Document Recipients

Wrangell Sentinel 

Yakutat Bay & River Charters 

Yakutat Marine & Supply, Inc. 

Yakutat Outfitters 

Yakutat Salmon Board 

Ziegler, Cloudy, King & Petersen Attorneys at Law 

Individuals 

The Final Environmental Impact Statement was also sent to approximately 2,700 individuals. 

 
5 List of Document Recipients 

List of Document Recipients 5-12 Final EIS

This page is intentionally left blank. 
CHAPTER 6 

REFERENCES 
 References 6 

Final EIS 6-1 References 

References 

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USDA Forest Service. 2007b. Tongass Land and Resource Management Plan 

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January 
 References 6 

Final EIS 6-35 References 

USDA Forest Service. 2007c. Draft Alaska National Interest Lands Conservation 

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USDA Forest Service. 2007d. Draft Alaska National Interest Lands Conservation 

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USDA Forest Service. 2007g. The State of the Forest. Tongass National Forest. 

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References 6 

References 6-36 Final EIS

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February. 
 References 6 

Final EIS 6-37 References 

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USDA Forest Service. 2002a. Timber Supply and Demand 2000. Alaska National 

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USDA Forest Service. 1993a. Status of the Tongass National Forest 1991 Report. 

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Pp. 299-305. 
References 6 

References 6-38 Final EIS

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16. 

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Weckworth, B., S. Talbot, G. Sage, D. Person, and J. Cook. 2005. A signal for 

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 References 6 

Final EIS 6-39 References 

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Representation within Differing Planning Objectives for the Central Coast of 

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Wiggins, D.A. 2005. Brown Creeper (Certhia americana): a Technical Conservation 

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Wilcove, D. 1993. Getting Ahead of the Extinction Curve. Ecological Applications 

3. 

Wilcove, D.S., C.H. McLelloan and A.P. Dobson. 1986. Habitat Fragmentation in 

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Wing, M.G. 2000. Landslide and Debris Flow Influences on Aquatic Habitat 

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30. 

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References 6 

References 6-40 Final EIS

Zaborski, R. R., M. H. McClellan, and T.A. Handley. 2002. Understory vegetation 

development following commercial thinning in southeast Alaska: preliminary 

results from the Second-growth management Area Demonstration Project. 

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ecosystems – proceedings of the national Silviculture workshop, May 6-10, 

Hood River OR. USDA Forest Service, PNW Portland, OR. pp 74-82. 

Zaborski, R. R., M. H. McClellan, J. Barbour, T. L. Laufenberg, and C.G. Shaw III. 

2000. The Southeast Alaska Timber Resource and Industry: What Might the 

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Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of 

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http://bna.birds.cornell.edu/bna/species/015 
CHAPTER 7 

GLOSSARY 
Glossary 7

Final EIS Glossary 7-1 

Glossary 

The Glossary for the Final EIS is located in Chapter 7 of the Final Land and Resource Management Plan 

volume. 
7 Glossary 

Glossary Final EIS 7-2 

This page is intentionally left blank. 
CHAPTER 8 

INDEX 
Index 8

Final EIS Index 8-1 

Index 

Air 3-11 to 3-20 

Allowable Sale Quantity (ASQ) 2-5 to 2-10, 3-343 to 3-348 

Alternative Comparisons 2-43 to 2-63 

Alternative Development Process 2-1 to 2-6 

Alternatives 2-1 to 2-63 

Alternatives Considered in Detail 2-9 to 2-42 

Alternatives Eliminated from Detailed Study 2-6 to 2-9 

Angoon 3-576 to 3-580 

ASQ – See Allowable Sale Quantity 

Bald Eagle 3-166, 3-238 to 3-239, 3-285 

Bear, Black 3-8, 3-24, 3-233, 3-268 

Bear, Brown 2-56 to 2-57, 3-24, 3-235 to 3-236, 3-280 to 3-

281, 3-295 

Biodiversity 1-6 to 1-8, 2-10, 2-49 to 2-50, 3-127 to 3-218 

Biogeographic Provinces 3-5, 3-129 to 3-133, 3-461 to 3-462 

Birds, migratory 3-244 to 3-248, 3-288 to 3-299 

Brown Creeper 3-240 to 3-241, 3-285-3-286 

Caves – See Karst and Caves 

Coffman Cove 3-580 to 3-584 

Commercial Fishing and Seafood Processing 

Industry 

3-518 to 3-520, 3-542, 3-550 

Communities 3-571 to 3-712 

Comparison of Alternatives 2-43 to 2-63 

Craig 3-584 to 3-589 

Cumulative Effects 3-3 to 3-4, 3-17 to 3-20, 3-29, 3-30, 3-38 to 3-

40, 3-48 to 3-51, 3-58 to 3-61, 3-90 to 3-93, 3-

114 to 3-117, 3-124 to 3-126, 3-198 to 3-217, 

3-292 to 3-297, 3-307, 3-316 to 3-317, 3-350 

to 3-351, 3-364, 3-399 to 3-400, 3-432 to 3-

433, 3-453 to 3-454, 3-467 to 3-468, 3-487, 3-

558 to 3-560 

Deer, Sitka Black-tailed (also see 

Communities) 

3-8, 3-230 to 3-232, 3-251, 3-265 to 3-268, 

3-428 

Ecological Section/Subsection 3-129, 3-132 to 3-133 

Economic and Social Environment 3-489 to 3-560 

Economic Efficiency Analysis 3-544 to 3-557 

Economic Impact Analysis 3-526 to 3-544 

Ecosystem Services 1-7, 2-10, 3-551 to 3-556 

Edna Bay 3-589 to 3-593 

Elfin Cove 3-594 to 3-598 

Employment and Income – See Economy, 

Regional

Endemics 3-170 to 3-171, 3-196 to 3-197, 3-248 to 3-

250, 3-289 to 3-290 

Endemism – See Endemics 

Environmental Justice 3-712 to 3-714 
8 Index 

Index Final EIS 8-2 

Essential Fish Habitat 3,76, 3-88 

Experimental Forests 2-4, 2-9 to 2-40, 3-469 to 3-470, 3-479 to 3-

480 

Fire 3-12, 3-15 to 3-20, 3-121, 3-124 to 3-126 

Fish 2-11, 3-63 to 3-94 

Fish Habitat 3-41 to 3-42, 3-66 to 3-74, 3,76, 3-88 

Fisheries Enhancement 3-72 to 3,74 

Fishing, Sport 3-63, 3-66, 3-74 

Flying Squirrel 3-243 to 3-244, 3-287 to 3-288 

Forest Budget 3-557 to 3-558 

Forest Health 3-119 to 3-126 

Fragmentation 3-167 to 3-168, 3-173 to 3-174, 3-221 to 3-

223, 3-259 to 3-261 

Geology 3-21 to 3-22, 3-26 

Goshawk, Northern (Queen Charlotte) 3-226 to 3-229, 3-262 to 3-265 

Gustavus 3-598 to 3-601 

Habitat Connectivity – See Fragmentation 

Haines 3-602 to 3-607 

Hairy Woodpecker 3-204, 3-285 to 3-286 

Heritage Resources and Sacred Sites 3-437 to 3-442 

Hollis 3-607 to 3-611 

Hoonah 3-611 to 3-616 

Hydaburg 3-616 to 3-620 

Hyder 3-620 to 3-623 

Invasive Species 3-77 to 3-78, 3-89, 3-101 to 3-104, 3-113 to 3-

114, 3-171 to 3-172, 3-197 to 3-198, 3-250 to 

3-252, 3-290 

Issues 1-3 to 1-8 

Juneau 3-624 to 3-627 

Kake 3-627 to 3-632 

Karst and Caves 3-22 to 3-29 

Kasaan 3-632 to 3-636 

Ketchikan 3-636 to 3-641 

Klawock 3-641 to 3-645 

Kupreanof 3-661 to 3-665 

Land Divisions 3-5 to 3-6 

Land Use Designation Groups 2-1 to 2-4, 2-44, 3-1, 3-5 to 3-6 

Land Use Designations 2-1 to 2-4, 3-1 

Lands 3-299 to 3-307 

Leasable Minerals 3-354 to 3-355, 3-364 

Locatable Minerals 3-353 to 3-354, 3-360 to 3-363 

Log Transfer Facilities 3-47, 3-55, 3-309 to 3-316 

LUD – See Land Use Designation 

Mammals, Terrestrial (Other) 3-224, 3-261 

Management Indicator Species 3-74, 3-230 to 3-241, 3-265 to 3-286 

Marten 3-234 to 3-235, 3-278 to 3-279 

Metlakatla 3-645 to 3-650 

Meyers Chuck 3-650 to 3-653 

Minerals 3-353 to 3-634 

Mountain Goat 3-232 to 3-234, 3-268 to 3-277 

Murrelet, Marbled 3-241 to 3-243, 3-286 

Natural Amenities and Quality of Life 3-521 to 3-524, 3-542 to 3-543, 3-556 to 3-557
Index 8

Final EIS Index 8-3 

Naukati Bay 3-653 to 3-657 

NIC – See Non-interchangeable Components 

Non-interchangeable Components (NIC) 

(defined) 

2-10 

Non-use (Passive Use) Values 2-10, 3-551 to 3-556 

Old-Growth Forest (see also Timber) 2-55, 3-137 to 3-138, 3-142 to 3-150, 3-168, 

3-173, 3-220, 3-256 to 3-259 

Old-Growth Reserves 2-14, 3-254 to 3-260 

Osprey 3-229, 3-265 

Outfitter/Guides 3-382 to 3-386 

Pelican 3-657 to 3-661 

Peregrine Falcon 3-229, 3-265 

Petersburg 3-661 to 3-665 

Plants 3-95 to 3-117 

Point Baker 3-665 to 3-670 

Port Alexander 3-670 to 3-673 

Port Protection 3-673 to 3-677 

Public Involvement 1-3 to 1-5 

Purpose and Need 1-1 to 1-10 

Recreation and Tourism 3-365 to 3-401, 3-511 to 3-517, 3-539 to 3-

541, 3-543, 3-548 to 3-549, 3-575 

Recreation Opportunity Spectrum (ROS) 3-367 to 3-370, 3-386 to 3-387, 3-514 to 3-

517 

Recreation Places 3-370 to 3-372, 3-387 to 3-394 

Red Squirrel 3-239, 3-285 to 3-286, 

Red-breasted Sapsucker 3-239 to 3-240, 3-285 to 3-286 

Research Natural Areas 3-470 to 3-472, 3-480 to 3-482 

Riparian Areas – Also see Fish Habitat 3-45 to 3-46, 

River Otter 3-233, 3-277 to 3-278 

Roadless Areas 1-1 to 1-7, 2-44 to 2-45, 3-443 to 3-454 

Roads – See Transportation 

ROS – See Recreation Opportunity Spectrum 

Sacred Sites – See Heritage Resources 

Salable Minerals 3-355, 3-364 

Salmon Harvesting and Processing – See 

Fishing and Seafood Processing

Saxman 3-677 to 3-681 

Scenery 3-403 to 3-418 

Sensitive Species 3-76 to 3-77, 3-88 to 3-89, 3-105 to 3-113, 3-

114 to 3-116, 3-226 to 3-229, 3-262 to 3-265 

Silvicultural Systems and Practices 3-338 to 3-343 

Sitka 3-681 to 3-686 

Skagway 3-686 to 3-690 

Soils 3-31 to 3-40 

Special Interest Areas 3-472 to 3-474, 3-482 to 3-483 

Special Land Use Designations, Other 3-469 to 3-488 

Spruce Grouse 3-243, 3-287 

Subsistence – Abundance and Distribution 3-420, 3-427 to 3-429 

Subsistence – Access 3-420 to 3-421, 3-429 to 3-431 

Subsistence – ANILCA 3-433 to 3-435 

Subsistence – Competition 3-421, 3-431 3-432 

Subsistence – Use areas 3-426 to 3-427 
8 Index 

Index Final EIS 8-4 

Subsistence (see also Communities) 2-11, 3-419 to 3-436 

Suitable Timber Lands – see Timber 

Suitability

Tenakee Springs 3-690 to 3-694 

Thorne Bay 3-694 to 3-669 

Threatened and Endangered Species 3-75, 3-87 to 3-88, 3-223 to 3-225, 

Timber 3-319 to 3-352 

Timber Demand 2-5, 3-504 to 3-511, 3-526 to 3-539 

Timber Employment – See Timber Industry 

Timber Industry 1-7, 3-499 to 3-504, 3-527 to 3-538 

Timber Management – See Timber 

Timber Sale Program 3-331 to 3-336 

Timber Suitability 3-336 to 3-338 

Tourism 3-374 to 3-385, 3-393 to 3-397 

Transmission Lines, Power 3-17, 3-313 

Transportation and Utilities 3-309 to 3-318, 3-542 

Trumpeter Swan 3-229, 3-265 

Utilities – See Transportation and Utilities 

Vancouver Canada Goose 3-241, 3-286 

Viability – See Wildlife Viability 

Viewsheds 3-410 to 3-418 

Visual Management System 3-403 

Visual Quality – See Scenery 

Water 3-41 to 3-52 

Water Quality 3-42 to 3-45 

Watershed 3-46 to 3-47 

Wetlands 3-53 to 3-62 

Whale Pass 3-699 to 3-703 

Wild and Scenic Rivers 3-474 to 3-479, 3-483 to 3-487 

Wilderness 3-445 to 3-468 

Wildlife 3-219 to 3-298 

Wildlife Habitat 1-7 to 1-8 

Wildlife Viability 2-44, 2-50 to 2-53 

Wolf, Alexander Archipelago 3-236 to 3-238, 3-281 to 3-285 

Wrangell 3-703 to 3-708 

Yakutat 3-708 to 3-712 
APPENDICES
Appendices 

The following appendices are included in Volume II: 

APPENDIX A ISSUE IDENTIFICATION 

APPENDIX B MODELING AND ANALYSIS 

APPENDIX C POTENTIAL LAND ADJUSTMENTS 

APPENDIX D OLD-GROWTH HABITAT CONSERVATION 

STRATEGY, WILDLIFE STANDARDS AND 

GUIDELINES, AND WILDLIFE VIABILITY 

APPENDIX E CATALOGUE OF PAST HARVEST 

APPENDIX F BIOLOGICAL ASSESSMENT 

APPENDIX G TIMBER DEMAND AND SUPPLY 

APPENDIX H COMMENTS AND RESPONSES 
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Photograph taken looking northeast with Lindenberg Peninsula on Kupreanof Island and 

the mouth of Petersburg Creek (front cover) in the foreground, Petersburg Mountain (front 

cover) in the middleground, and Frederick Sound and the mainland in the background.
Tongass Land and

Resource Management Plan

Final Environmental

Impact Statement

Plan Amendment

United States

Department of

Agriculture

Forest Service

R10-MB-603d

January 2008

Volume II - Appendices 
Tongass National Forest 

Land and Resource Management Plan 

Final Environmental Impact 

Statement 

Plan Amendment 

Volume II - Appendices 

2008 

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 Contents 

Final EIS Contents iii 

Volume II 

EIS Appendices 

CONTENTS 

APPENDIX A ISSUE IDENTIFICATION ............................................................................................... A-1 

APPENDIX B MODELING AND ANALYSIS......................................................................................... B-1 

APPENDIX C POTENTIAL LAND ADJUSTMENTS............................................................................. C-1 

APPENDIX D OLD-GROWTH HABITAT CONSERVATION STRATEGY, WILDLIFE 

STANDARDS AND GUIDELINES, AND WILDLIFE VIABILITY................................... D-1 

APPENDIX E CATALOGUE OF PAST HARVEST ...............................................................................E-1 

APPENDIX F BIOLOGICAL ASSESSMENT.........................................................................................F-1 

APPENDIX G TIMBER DEMAND AND SUPPLY ................................................................................. G-1 

APPENDIX H COMMENTS AND RESPONSES................................................................................... H-1 
APPENDIX A 

ISSUE IDENTIFICATION 
Appendix A 

Final EIS A-i Issue Identification 

Appendix A 

Issue Identification 

CONTENTS 

Introduction ................................................................................................................................................A-1

Past Planning Efforts..................................................................................................................................A-1

Tongass Forest Plan Revision.........................................................................................................A-1

Tongass Forest Plan Revision Appeals...........................................................................................A-2

National Roadless Area Conservation Rule ....................................................................................A-2

Project-Level EIS Analyses .............................................................................................................A-2

National Forest Transportation Rule and Policy..............................................................................A-2

Supplemental EIS, Roadless Area Evaluation for Wilderness Recommendations.........................A-2

Public Issues ..............................................................................................................................................A-3

Public Input for this EIS..............................................................................................................................A-3

Key Issues..................................................................................................................................................A-4

 
Appendix A 

Final EIS A-1 Issue Identification 

Appendix A 

Issue Identification 

Introduction 

This Environmental Impact Statement (EIS) responds to the August 2005 U.S. Ninth Circuit Court 

Decision that found inadequacies primarily relating to the National Environmental Policy Act (NEPA) 

process for the 1997 Land and Resource Management Plan (Forest Plan or Plan). The Court directed 

the Forest Service to prepare an EIS that evaluates and considers timber demand, the range of 

alternatives related to the timber demand, and the cumulative analysis related to activities on nonNational Forest System (NFS) lands. This is discussed further in Chapter 1 of the EIS. This EIS 

responds to the Court and the 5-Year Review by analyzing six alternatives for amending the Plan in 

addition to the No-Action alternative. Appendix A of the 1997 Final EIS discusses the issue identification 

process used in the Tongass National Forest planning process. 

Identification of issues helps define or predict what resources or uses could be most affected by the 

planning alternatives under consideration. These issues are then used as a basis to formulate 

alternatives or to measure differences between alternatives. The following sections describe the process 

used to identify the issues for this EIS and the key issues identified. 

The scope of this EIS was initially determined by the Court in its 2005 ruling, and by the 5-Year Plan 

Review (completed in January 2005) that indicated the need to amend the current Tongass Forest Plan. 

Additional information was considered to help clearly define the issues and for use in the development 

and analysis of alternatives. For this EIS, comments and information from a wide variety of public inputs 

that were related to amending the Forest Plan were considered. This information included: 

♦ Public comments generated during the 1997 Tongass Forest Plan Revision process; 

♦ Tongass Forest Plan Revision appeals; 

♦ Public input specific to the Tongass National Forest on the Forest Service’s 2001 National 

Roadless Area Conservation Rule; 

♦ Public comments generated relative to the 2003 Supplemental EIS, Roadless Area Evaluation for 

Wilderness Recommendations; 

♦ Public input expressed during project-level NEPA analyses over approximately the past 10 years; 

and 

♦ Public input received in response to the Notice of Intent and the Web site for this EIS. 

This record of public input on the management of the Tongass covers a period of almost 2 decades.. Of 

special note are the extensive public meetings held in Southeast Alaska for the 1997 Forest Plan 

Revision, the 2001 National Roadless Area Conservation Rule, and the 2003 Supplemental EIS. 

Past Planning Efforts 

Tongass Forest Plan Revision 

Appendix L of the 1997 Final EIS presents summaries of all substantive comments received during the 

three public comment periods for the Tongass Forest Plan Revision, as well as presents Forest Service 

responses to these comment summaries. All public comment periods held during the Tongass Forest 

Plan Revision were announced in the Federal Register, by news release, in local newspapers, and 
Appendix A 

Issue Identification A-2 Final EIS 

through newsletters. Informational meetings and open houses, followed by hearings, were held in most 

Southeast Alaska communities during each comment period. More than 3,000 individuals, organizations, 

interest groups, and agencies provided written or oral input on the 1990 Draft EIS, and more than 7,000 

and 21,000 responses were received on the 1991 Supplement and the 1996 Revised Supplement, 

respectively. 

Comments summarized in Appendix L were identified by location and issue and entered into a database 

that had more than 850 entries. Information developed through this review was used to help identify 

public interest in specific roadless areas, as well as in the issue identification process. 

Tongass Forest Plan Revision Appeals 

A total of 23 appeals were received on the 1997 Tongass Land Management Plan Revision Record of 

Decision (ROD). These appeals were reviewed and comments were summarized by location and issue 

and entered into a database. Information developed through this review was used to help identify public 

interest in specific roadless areas, as well as in the issue identification process. 

National Roadless Area Conservation Rule 

More than 1.1 million separate pieces of public input were received on the National Roadless Area 

Conservation Rule Draft EIS. The results of the Forest Service’s content analysis of these comments are 

presented in Volume 3 of the Roadless Area Conservation Final EIS along with the Forest Service’s 

responses to the identified comment summaries (USDA Forest Service 2000). A portion of these 

comments specifically pertained to the Tongass. Some of these comments were in support of, and some 

were against, roadless area conservation on the Tongass. Some stated that roadless areas were 

important for wildlife and endangered and threatened species, some were concerned about effects on the 

regional economy, recreation, and subsistence (some indicated that limiting road construction would limit 

access for subsistence, while others stated that there are already sufficient roads on the Tongass to meet 

subsistence needs). 

Project-Level EIS Analyses 

Public input related to timber management, recreation, roadless areas, and other issues that has been 

expressed during project-level EIS analyses over approximately the past 10 years was considered. This 

included many recent project-level EISs and EAs completed since 1997, as well as several landscapelevel plans. Many of the comments that addressed timber demand, economics, wildlife, subsistence, 

scenery, tourism, and roadless area issues were made in response to proposals to harvest timber and to 

build roads. 

National Forest Transportation Rule and Policy 

Public input on the National Forest Transportation Rule and Policy that pertained specifically to the 

Tongass was also reviewed as part of this issue identification process. 

Supplemental EIS, Roadless Area Evaluation for Wilderness Recommendations 

Public input on the Supplemental EIS, Roadless Area Evaluation for Wilderness Recommendations was 

also reviewed as part of this issue identification process. Approximately 177,000 separate pieces of input 

were received during the public comment period. Eighteen public hearings were held, 16 in Southeast 

Alaska, one in Anchorage, and one electronic public hearing (via the internet). Comments were received 

from all 50 states and at least 11 foreign countries. Comments generally focused on how much roadless 

area to retain and how this would effect recreation, tourism, timber, wildlife, subsistence, and the local 

economy. Comment summaries and Forest Service responses are presented in Volume IV of the Final 

Supplemental EIS, along with letters from agencies, elected officials, and tribal governments. 
Appendix A 

Final EIS A-3 Issue Identification 

Public Issues 

Identification of issues helps define or predict the resources or uses that could be most affected by the 

management of NFS lands. These issues are then used as a basis to formulate alternatives or to 

measure differences between alternatives. 

Ten public issues were originally identified in 1988 for the Forest Plan Revision. These original issues 

included scenic quality, recreation, fish habitat, wildlife habitat, subsistence, timber harvest, roads, 

minerals, roadless areas, and local economy. The 1991 Forest Plan Revision Supplemental Draft EIS 

(SDEIS) added an additional concern, identifying and considering rivers for recommendation as Wild, 

Scenic, and Recreational rivers. 

After the release of the 1991 SDEIS, considerable new information pertaining to the Tongass Forest Plan 

Revision became available. Out of this information emerged five additional issues, determined by the 

Regional Forester to need more study and evaluation before a final revised Forest Plan could be adopted. 

Some of these issues were aspects or extensions of the ten public issues previously considered; others 

were new as issues or had not been considered as issues in themselves. The five issues were wildlife 

viability, fish habitat, karst and caves, alternatives to clearcutting, and socioeconomic considerations. 

These issues were assessed in the 1996 Revised SDEIS and the 1997 Tongass Forest Plan Revision 

Final EIS. 

The 2003 Supplemental EIS reviewed and evaluated roadless areas and analyzed alternative groupings 

of roadless areas for wilderness recommendations. Two broad issue categories, referred to as key 

issues, were identified as the major issues driving the alternatives and the analysis. They included 1) the 

long-term protection of roadless areas and associated values, and 2) the social and economic well-being 

of the communities of Southeast Alaska. 

Public Input for this EIS 

In addition to the above, extensive public involvement has occurred during the development of this EIS. 

All public input received has been reviewed and is maintained in the planning record. Comments and 

responses on the Draft EIS are also included in Appendix H. Public involvement activities have included 

the following items. 

♦ The Notice of Intent was published in the Federal Register in March 2006. 

♦ A Forest Plan Adjustment Web site was developed in January 2006 and has been maintained to 

inform and engage the public since then. It is updated as new information is developed or 

published and provides a mechanism for public input. Several hundred comments and questions 

were received through the Web site or via emails associated with the Web site in the first few 

months of operation. 

♦ A Weblog regarding the Forest Plan adjustment effort was established in July 2006 and was 

continually maintained as another method of public communication. 

♦ In response to the above items, a number of letters were received containing comments 

regarding the issues and alternatives. These included letters from environmental organizations, 

the timber industry, Southeast Alaska community organizations, and a number of individuals from 

Southeast Alaska and across the nation. 

♦ Government-to-government consultation has been conducted throughout the process, and is 

ongoing, with federally recognized Tribes. 

♦ A number of group-specific meetings have also occurred with various organizations (including 

Alaska Native groups). 

♦ A variety of news releases were issued relative to the Forest Plan adjustment throughout the 

process. 
Appendix A 

Issue Identification A-4 Final EIS 

♦ A series of ongoing meetings, hosted by the National Forest Foundation and The Nature 

Conservancy, known as the Tongass Futures Roundtable, have resulted in considerable 

discussion of Tongass management issues among a broad spectrum of individuals and groups 

interested in the future of Southeast Alaska since May 2006. 

♦ The input received prior to issuance of the Draft EIS was reviewed and a summary of this 

synthesis is presented as Appendix A (Issue Identification) to the Final EIS. 

♦ A Draft EIS and Proposed Forest Plan were released on January 12, 2007. This began a 90-day 

comment period, which was later extended to 108 days. The comment period closed on April 30, 

2007. 

♦ During the comment period, open houses and public hearings were held in 24 Alaska 

communities. In addition to comments on the Draft EIS, the hearings provided opportunity to 

hear concerns related to subsistence and Alaska Native issues. 

♦ On March 22, 2007, an open house and public hearing was held on the internet, to solicit public 

comment in an open forum from individuals living anywhere in the world. 

♦ Over 84,000 comment documents were received, including individual letters, form letters, emails, 

hearing testimony, and comments submitted directly via the Forest Plan Adjustment Web site. 

Slightly more than 2,000 of these were classified as individual comment documents and the 

others were classified as form letters and emails. The individual comment documents were 

subdivided into approximately 5,500 individual comments. Responses were received from all 50 

states and 89 foreign countries. A summary of the substantive comments and Forest Service 

responses to those comments can be found in Appendix H. 

Key Issues 

Any alternative that proposes to change the Forest Plan could affect resources and/or outputs relative to 

the current Forest Plan. Therefore, Chapter 3 of the EIS shows the effects of the various alternatives on 

all relevant resources and evaluates their effects relative to all of the issues and concerns previously 

identified during the 1997 plan revision process. However, based on the purpose and need of this EIS 

and the public input received during the current EIS process, some issues are more likely to influence the 

comparison among alternatives and represent the major issues to be evaluated. These issues were 

grouped into three broad issue categories, referred to as the key issues. These key issues are the major 

issues driving the alternatives and analyses. 

Key Issue 1 – Protection of high value roadless areas from road development and timber harvest 

activity on the Tongass National Forest is of local and national importance, particularly for wildlife 

and biodiversity, recreation, and tourism. 

Many people believe roadless areas should be allowed to evolve naturally through their own dynamic 

processes and should be afforded protection that ensures this will occur. The Tongass includes very 

large undeveloped land areas with several portions of the Forest consisting of contiguous roadless areas 

that exceed 1 million acres and represent large, unfragmented blocks of wildlife habitat. This large scale 

of roadless lands does not exist on any other National Forest, except the Chugach National Forest in 

Southcentral Alaska. 

Roadless areas are considered important because of their wildlife habitat and recreation values and their 

importance for tourism. They are also important because of the passive-use and ecosystem services 

values they provide. 

Passive-use values represent values that individuals assign to a resource independent of their use of that 

resource. Typically this includes existence, option, and bequest values, and represents the value 

individuals obtain from knowing that expansive roadless areas exist, knowing that they are available to 

visit in the future should they choose to do so, and knowing that they are available for future generations 

to inherit. There is interest in preserving large portions of the Tongass because so much of it is in a 
Appendix A 

Final EIS A-5 Issue Identification 

natural condition, unlike most other national forests, and because the Forest represents a significant 

portion of the world’s remaining temperate rainforests. 

Ecosystem services represent the services provided to society by healthy ecosystems. These services 

and benefits include what some consider to be long-term life support benefits to society as a whole. 

Examples of ecosystem services include watershed services, soil stabilization and erosion control, 

improved air quality, climate regulation and carbon sequestration, and biological diversity. 

Indicators: Analysis relative to this issue compares the amount and proportion of land protected in nondevelopment Land Use Designations (LUDs); the amount of inventoried roadless areas that would be 

protected under each alternative; and the amount of productive old-growth forest that would be protected 

under each alternative. Also, the values of the lands protected are considered. Non-use or passive-use 

values are discussed qualitatively and with examples provided from other studies. 

Key Issue 2 – The Tongass National Forest needs to seek to provide a sufficient timber supply to 

meet the market demand and help maintain a vibrant economy in Southeast Alaska. 

TTRA (Section 101) requires the Forest Service to seek to provide a supply of timber from the Tongass 

National Forest that meets the annual market demand and the market demand for each planning cycle, 

consistent with providing for the multiple-use and sustained yield of all renewable resources. With the 

cancellation of long-term timber contracts and the closure of two Southeast Alaska pulp mills in the 1990s 

(discussed in detail in Chapter 3 Environment and Effects), current demand for Alaska’s National Forest 

timber depends on markets for sawn wood and the option of exporting manufacturing residues and lower 

grade logs. Future or planning cycle demand scenarios cover a wide range of issues and depend on 

rates of economic growth in key markets, conditions faced by competitors, and the rate of investment and 

innovation in Alaskan manufacturing. 

Over the past half a century, the timber industry has been a major component of the economy of 

Southeast Alaska. However, with the closure of two Southeast Alaska pulp mills and the growth of 

tourism, timber has played a lesser role. Because the economy of Southeast Alaska is based on 

relatively few industries, maintaining an active timber industry is important for maintaining a welldiversified economy. 

Indicators: Analysis relative to this issue compares the likely demand for timber based on capacity of the 

local industry and the amount of harvest made available to meet that demand. It also considers the type 

of wood (sawlogs and utility wood) made available and the usefulness of that wood type to the local 

industry, as well as the amount of timber that would be available from state and private sources. Finally, 

it considers the effects on the regional and national economies and the effects on the local communities. 

Key Issue 3 – Protection of the wildlife habitat and biodiversity of the Tongass National Forest is 

of local and national significance and is affected by road development and timber harvest 

activities. 

The Tongass National Forest supports a unique and important assemblage of wildlife including the largest 

population of brown bears and breeding bald eagles in the world, species of high importance for 

subsistence (e.g., Sitka black-tailed deer), an extensive array of endemic mammals and other species, 

and a large number of species that are at least partially dependent on old-growth habitats (e.g., marten 

and goshawk). Populations of many of these species and the biodiversity of Southeast Alaska are 

affected by timber harvest and the development of roads. 

Although less than 10 percent of the productive old-growth habitat on the Tongass has been converted to 

young growth, the percentage is much higher for certain types of old growth, such as lowland and largetree old growth. In addition, a high percentage of non-NFS lands have been harvested at a much higher 

rate. Therefore, the cumulative effects of harvest and road building on wildlife in Southeast Alaska are 

greater than the effects for the Tongass by itself. 

Indicators: Analysis relative to this issue compares the amount of productive old- growth forest that would 

be protected under each alternative, as well as the percentages of biogeographic provinces that would be 

protected in reserves. It also considers the role of the managed lands (development LUDs) in providing 
Appendix A 

Issue Identification A-6 Final EIS 

wildlife habitat. It rates the alternatives in terms of the expert panel ratings conducted for the 1997 Forest 

Plan Revision EIS. Habitat changes, as documented by habitat amounts, changes in road densities, and 

habitat models are also used as indicators. Finally, cumulative harvest and road development on nonNFS lands is quantified and evaluated in conjunction with harvest and road development on NFS lands. 
APPENDIX B 

MODELING AND ANALYSIS 
Appendix B

Final EIS B-i Modeling and Analysis

Appendix B 

Modeling and Analysis 

CONTENTS 

Planning Situation ..................................................................................................................................... B-1

Spectrum Modeling ................................................................................................................................... B-1

Analysis-related Changes between the 1997 and 2008 Final EISs ................................................B-1

The Forest Planning Model (Spectrum)...........................................................................................B-3

The Tongass Spectrum Models.......................................................................................................B-4

Spectrum Model Components .........................................................................................................B-4

Land Base Analysis Areas ....................................................................................................B-4

Management Prescriptions ...................................................................................................B-8

Activities and Outputs............................................................................................................B-9

Spectrum Constraints......................................................................................................... B-14

Spectrum Solution Process..................................................................................................................... B-18

Objective Functions ...................................................................................................................... B-18

Iterative Process........................................................................................................................... B-19

Economic Efficiency...................................................................................................................... B-19

Supplemental Information on Other Model Assumptions ....................................................................... B-20

Stage II Suitability Analysis .......................................................................................................... B-20

The Regulation Class Process ..................................................................................................... B-22

Model Implementation Reduction Factors (MIRF)........................................................................ B-24

Estimation of Past and Future Harvest and Road Construction for Effects Analysis ............................. B-29

Estimation of Past and Future Harvest......................................................................................... B-29

Vegetation Inventory .......................................................................................................... B-29

Original POG by Category ................................................................................................. B-30

Future Harvest.................................................................................................................... B-30

Estimation of Past and Future Road Construction ....................................................................... B-30

Road Inventory................................................................................................................... B-31

Future Road Construction .................................................................................................. B-31

Deer Model Assumptions and Application .............................................................................................. B-31

LIST OF TABLES 

Table B-1 Spectrum Level Identifiers.....................................................................................................B-6

Table B-2 Timber Policy and Operational Constraints Used for Spectrum Modeling......................... B-15

Table B-3 Discounted Average Net Revenues by Land Category ..................................................... B-21

Table B-4 SIO for Distance Zone/LUD from Scenery Standards and Guidelines .............................. B-22

Table B-5 Maximum Unit Size based on Visual Absorption Capability .............................................. B-23

Table B-6 Percent Allowable Visual Disturbance ............................................................................... B-23

Table B-7 Regulation Class Allocation ............................................................................................... B-24

Table B-8 Generalized Visual Constraints Regulation Class Visual Disturbance Adjacency ............ B-24
Appendix B

Final EIS B-1 Modeling and Analysis

Appendix B 

Modeling and Analysis 

Planning Situation 

The National Forest Management Act of 1976 (NFMA) directs each National Forest to prepare a 

comprehensive land and resource management plan. The Tongass National Forest produced its first 

comprehensive Plan in April 1979. The NFMA also directs that these management plans be revised at 

least every 15 years. The Tongass began the Revision process in 1987, published a Draft Environmental 

Impact Statement (DEIS) in June 1990, and prepared the Supplement to the DEIS (SDEIS) as a result of 

the November 1990 Tongass Timber Reform Act (TTRA). The SDEIS was published in August 1991 and 

the Revised SDEIS (RSDEIS) was published in April 1996. The Final EIS for the Forest Plan Revision 

was published in 1997 along with a comprehensive Appendix B that detailed the analytical process 

followed. In 2002 a Draft Supplemental EIS (SEIS) was published and in 2003 a Final SEIS was 

developed; an Appendix B for modeling and analysis also accompanied the Final SEIS. The purpose of 

the 2008 Tongass Appendix B is to present a discussion of the major analytical processes and models 

used in this 2008 Forest Plan Amendment EIS. Due to the magnitude (17 million acres) and complexity 

(19 land use designations) of the planning process, a number of analytical methods are used. This 

discussion includes basic assumptions, modeling components and inputs, rules, methods, and 

constraints. The information supplements the broader, less technical descriptions included in the body of 

Chapters 2 and 3 of the EIS. Additional information and documents used in the analysis process are 

contained in the planning record. The planning record in its entirety is incorporated here by reference. 

Spectrum Modeling 

Analysis-related Changes between the 1997 and 2008 Final EISs 

As the assessment, development, and analysis of geographic information is a continuous process, 

aspects and attributes of existing databases are continually changing. These improvements and additions 

to the databases often have direct results on models, model results, and the assumptions used within the 

models themselves. The years between the 1997 FEIS and this EIS saw a number of changes to 

resource inventories, coefficient development, and model assumptions, all of which played a role in the 

recalculation of alternative outputs. These changes are: 

Development of a Forest-wide Logging System and Transportation Analysis (LSTA)—A complete 

and consistent Forest-wide LSTA and Integrated Timber Operability analysis were developed. These 

products resulted in geographic information system (GIS) layers for all potential harvest units and the 

roads needed to access them under the current Forest Plan. The harvest units were identified within the 

mapped suitable land base, as defined by the latest GIS layers. The harvest units and roads were 

mapped by logging engineers and foresters with knowledge and training in the standards and guidelines. 

Mapping included identification of the most appropriate logging systems, so that the suitable land base 

could be apportioned into operability classes. Risk factors were also identified that will be used for 

refinements to the estimated suitable land base. 

Recalculation of the Tentatively Suitable Land Base—More accurate information about the landscape 

has been captured in the Forest’s GIS resource layers (e.g., streams, slopes, karst). This information 

was used to update the tentatively suitable and the suitable land bases. See Appendix A of the Forest 

Plan and Chapter 3 of this EIS for more detailed information on how more current information was 

included in the suitability analysis. 
Appendix B 

Modeling and Analysis B-2 Final EIS

Geographic Zone Recognition—Due to recent analysis that showed significant volume differences 

between five physical geographic zones on the Forest, the decision was made to recognize cost, price, 

and volume differences according to these zones. The zones recognized were North Islands, South 

Islands, North Mainland, South Mainland, and Yakutat. This is distinct from past analyses in which three 

administrative area differences were recognized. 

Commercial Thinning—The interdisciplinary team recognized the option of commercially thinning younggrowth stands to achieve volume and/or wildlife goals. This prescription was included in the Spectrum 

model along with thinning volume estimates derived from the Forest Vegetation Simulator (FVS). 

Goshawk and Marten and Legacy Standards and Guidelines—For modeling the current Plan, 

Goshawk and Marten standards and guidelines were included in the Spectrum analysis. In some of the 

other alternatives, legacy standards and guidelines were incorporated as a way to leave forest structure 

after harvests. 

Changes to Visual Management System—The Forest completely changed over from the Visual 

Management System (VMS) to the Scenery Management System (SMS). At the same time, all of the 

scenery GIS layers were updated. This updating began with the mapping and development of a GIS 

layer for the Visual Priority Routes and Use Areas (see Appendix F in the Forest Plan). Next Seen Areas, 

based on these Visual Priority Routes and Use Areas, were modeled using digital elevation models 

(DEMs) and Distance Zones (foreground, middleground, and background) were mapped based on 

established criteria. Scenic Integrity Objectives were then mapped for each alternative, based on Seen 

Areas, Distance Zones, and Land Use Designations (LUDs). The Visual Absorption Capability was 

remodeled and mapped and based on all of these sources. Regulation Class layers (see below) were 

developed for use in Spectrum modeling. 

Land Adjustments—Since 1997, a variety of land adjustments have occurred. These adjustments have 

been incorporated into the current analysis as they have affected the total National Forest System (NFS) 

land base as well as the tentatively suitable and suitable forest land bases. 

Modeling Implementation Reduction Factors (MIRF)—These factors, used to adjust model results to 

account for missing and known data inaccuracies, have been recalculated for each alternative. The MIRF 

changes have occurred as a result of improved information derived from upgraded GIS layers, including 

streams, slopes, and karst, a reduction in the lands identified as encumbered, and other factors. This 

calculation is explained in detail later in this appendix. 

Inventory and Data—The inventory step of the planning process consists of the collection, development, 

and documentation of data to address the public issues, management concerns and resource 

opportunities, and planning criteria. Two basic types of information are needed to facilitate the analysis 

and development of alternatives. The first consists of information related to the classification of land into 

categories with unique properties. This classification can be based on any attribute significant to planning 

issues. This type of information is tied directly to the map base. In the case of the Tongass National 

Forest, this map base is its GIS database. The second type of information is not directly tied to a map 

base, but has more to do with the estimation of how land will respond to certain management activities. 

This type of information comes from many sources: Regional procedural handbooks, research studies, 

available literature, etc. The most up-to-date and verifiable information available was used for the EIS. 

Several Forest-wide inventory data sources have been updated and improved for the 2008 EIS. The 

primary changes and updates to the inventory, data, and modeling include: 

♦ The timber harvest map was updated to reflect timber harvested through 2006. 

♦ A new coverage was created to better estimate timber volumes. The cover was based on the 

value and degree of operational difficulty of the timber across the forest. Five unique geographic 

zones were identified; Yakutat, North Island, North Mainland, South Island, and South Mainland. 

Additionally, a size-density model (SDM) cover was created based on several landscape features 

incorporating the Common Land Unit (CLU), National Wetlands Inventory, aspect, and existing 

vegetation map to stratify old growth into seven unique size density classifications for productive 

old growth (POG). For modeling and yield estimation purposes, the old-growth stratum was 

derived from a generalization of the SDM into three volume strata (High, Medium, and Low). 
Appendix B

Final EIS B-3 Modeling and Analysis

These attributes stratified the Forest Inventory and Analysis (FIA) plots on the forest used in oldgrowth volume estimates. 

♦ Forest Vegetation Simulator (FVS) model runs were conducted to estimate young-growth yields, 

including commercial thins. These runs were based off of a combination of FIA and forest-level 

data collected on young-growth stands. 

♦ Forest-wide LSTA and timber operability analysis were developed (noted above). 

♦ Inventoried roadless area boundaries were changed to reflect new road construction and timber 

harvest that occurred through 2006. 

♦ New roads were added to the roads data base. 

♦ Changes in land ownership due to conveyances to the state and Native corporations and other 

adjustments have been addressed in the data base (noted above). 

♦ Improvements and updates have been made to most other resource databases, including 

tentatively suitable lands, streams, slopes, karst, and other data. 

♦ Development of a completely new set of Scenery Management System GIS layers (noted above). 

Modeling Changes—Some of the newly derived and updated information required updates to the 

Spectrum model formulation (see below for more detailed information on Spectrum modeling). The major 

modeling changes were: 

♦ Analysis Areas were refined and recalculated for alternatives. See “Land Base Analysis Areas” 

below for further discussion. 

♦ Young-growth stands were classified into 10-year age categories and by whether they had been 

precommercially thinned. 

♦ All timber values were recalculated to reflect current information. 

♦ Cost information was updated to reflect current information. 

♦ Management intensity regimes (Regulation Classes – see below) were recalculated for each 

alternative. 

♦ Watershed constraints were recalculated based on the suitable lands in each alternative. 

♦ Model implementation reduction factors (MIRFs – see below) were updated. 

♦ Incorporation of Goshawk/marten standards and/or legacy standards and guidelines into the 

Spectrum model. 

♦ Addition of new treatment options including commercial thinning and partial cutting. 

♦ Cost, price, and yield differences recognized by geographic zone rather than by administration 

area. 

The Forest Planning Model (Spectrum) 

Spectrum is a vegetation management model developed by the Forest Service Ecosystem Management 

staff in cooperation with the Rocky Mountain Experiment Station to assist in Plan Revision alternative 

evaluation. It was designed to fulfill the requirements outlined in the 1982 National Forest System Land 

and Resource Management Planning Act (36 CFR), most importantly Section 219.12(f)(8): “Each 

alternative shall represent to the extent practicable the most cost efficient combination of management 

prescriptions examined that can meet the objectives established in each alternative.” Spectrum is the 

primary modeling tool used to ensure that land allocations and output schedules for alternatives are 

realistic and meet standards and guidelines in a cost-efficient manner. Spectrum enables planners to 

create a sufficiently detailed linear model with fairly simplistic data entries. 

Spectrum is a derivative of the FORPLAN model used for analysis in the 1986 Forest Plan. Spectrum 

assumes that relationships between outputs and the land base are linear (e.g., twice the number of 

similar acres yields twice the timber volume). A management objective is specified (e.g., maximize net 

revenues from harvesting activity) as well as any constraints that may affect that objective (for example, 

produce a steady supply of timber over time). 
Appendix B 

Modeling and Analysis B-4 Final EIS

The Spectrum solution process involves three steps: 1) create a linear programming (LP) model, 2) find 

the optimal solution to the LP model, and 3) put the model solution into a more readable form (i.e., 

interprets the linear programming results). Spectrum’s matrix generator portion translates the 

management objective, constraints and assumptions about the land base into a matrix of numbers that 

can be solved with a linear programming (LP) solver software package. The Tongass used the C-WHIZ 

LP solver software package to solve the matrix generated by the Spectrum model. The solver software 

determines a system of management prescriptions that results in the highest possible management 

objective value (e.g., Present Net Value) within the constraint parameters (meeting desired conditions 

and appropriate standards and guidelines). Spectrum’s report writer portion then translates the LP output 

into reports, such as costs, revenues, landscape condition, and long-term sustained yield capacity. 

Results from the modeling process are only approximations of what to expect when any given alternative 

is implemented. The main purpose of modeling is to aid planners in estimating likely future 

consequences of management prescriptions. A choice between alternatives can be made even though 

the model may lack precision in describing specific attributes of a given alternative. 

An in-depth technical discussion of linear programming and its use in forest management applications 

can be found in Davis et al. (2001). 

The Tongass Spectrum Models 

Large Linear Programming models can be difficult or impossible to solve. Initial size estimates of the 

Tongass model, given the desired level of detail, made it clear that for each alternative, three Spectrum 

models would be needed; one model for each of the three old Administrative Areas of the Tongass 

National Forest (Chatham, Ketchikan, Stikine). To further mitigate model size, Spectrum models for the 

Tongass only analyze land classified as suitable for timber harvest. Those lands considered "unsuitable" 

for timber harvest were omitted from the models. The process for determining suitability can be found in 

Appendix A, "Timber Suitability Classification," of the Forest Plan. Results of each of the Administrative 

Area models were then aggregated to determine Forest-level quantities and impacts presented in the 

chapters of this EIS. 

Spectrum Model Components 

A Spectrum model has five main components: 1) the objective function, 2) land base analysis areas, 3) 

management prescriptions, 4) activities and outputs, and 5) constraints. The objective function is the 

overall management strategy objective of the model. Examples of typical objective functions are 

“maximize present net value,” “maximize timber volume,” and “minimize cost.” Only one objective 

function can be used for each model run; however, forests typically find it beneficial to use the results of 

one objective function learn about the specific nature of their management problem or to formulate 

desired conditions used with another objective function. Detailed information on objective functions used 

by the Tongass is found in the solution process section of this appendix. The last three components of 

the Spectrum model greatly influence how the second (the land base) will be defined. The Tongass 

models are designed to analyze the activities and outputs associated with timber harvest scheduling; 

therefore, the land base is defined by those characteristics significant to the timber resource. Other 

resources are dealt with through the LUD allocation process and model constraints. The management 

prescriptions applied to the Forest differ mostly by rotation age and dispersion amount (portion of the 

trees removed from the stand). The activities (costs) associated with timber harvesting are well 

documented as are the outputs (benefits) obtained from the wood fiber. The constraints differ by 

alternative but often refer to a particular timber classification, specific geographic area, activity or output 

volumes allowed, and management allocation. Constraints are used to ensure desired condition 

achievement, compliance with appropriate standards and guidelines, and that the resultant management 

strategy is feasible. 

Land Base Analysis Areas 

Analysis Areas represent unique combinations of the different Identifiers used to stratify the mapped 

suitable land base. The mapped suitable land base is different for each alternative and is derived in 
Appendix B

Final EIS B-5 Modeling and Analysis

Table 3.13-8 of this EIS. Analysis Areas represent between 378,000 and 1.5 million acres, depending on 

the alternative. It is important to note that they include the unmapped unsuitable lands accommodated for 

by the Model Implementation Reduction Factor (MIRF – see below for detailed discussion). If information 

was perfect, and all unsuitable lands could be mapped, the actual suitable would be somewhat less than 

the land base represented by the Analysis Areas (similar to figures found in line 13 of Table 3.13-8). 

An analysis area is an operational aggregation of land resource polygons that have the same 

characteristics, are expected to have similar responses management prescriptions, and have similar 

costs and benefits associated with management prescriptions. By an extension of this logic, analysis 

areas differ from each other in management prescription response and the costs and benefits associated 

with those prescriptions. Analysis Areas are unique combinations of the Analysis Area Identifies 

described below. 

Analysis Area Identifiers. The 1996 modeling process determined analysis area identifiers that provided 

a categorization of the timber base consistent with the timber management analysis nature of the harvest 

scheduling model used for plan revision. These identifiers were re-evaluated for the 2008 EIS and 

determined to still be relevant for classifying the land base into areas where the land within an area had 

similar logging costs and timber values. However, the identifiers were updated and expanded when 

appropriate to reflect new information or additional levels of detail that are relevant to the 2008 EIS 

process. Six identifiers were used for input into the Spectrum models: 1) Value Comparison Units, 2) 

logging operability, 3) productivity group, 4) roaded/unroaded classification, 5) timber strata/volume class, 

and 6) Regulation Class. A summary of each identifier and why it was selected follows. The identifiers 

are presented by name in Table B-1. 

Value Comparison Unit (VCU). In the current Plan, there are 946 unique VCUs. Each of the 

VCUs provides Spectrum with a level of spatiality the other identifiers cannot. In previous 

FORPLAN models, the main spatial identifier was Management Area (MA). Moving to VCU as the 

spatial identifier increased the resolution of mapping by six times. VCUs can be used to recognize 

spatially-variable costs such as hauling costs to the appropriate mill, road construction costs, and 

construction of log transfer facilities. VCUs are also used to formulate management constraints 

such as old growth retention, goshawk/marten, and legacy constraints, watershed constraints, 

and dispersion constraints (see constraints section of this appendix for further explanation). 

Timber Harvest Operability. Operability, or logging system, was a direct product from the LSTA 

developed for the Tongass National Forest. Suitable acres on the Tongass National Forest were 

classified into six operability classifications used in Spectrum; ground-based/shovel, short-span 

cable, long-span cable, short-distance helicopter, mid-distance helicopter, and long-distance 

helicopter. Slope was a factor in determining the logging system appropriate for each stand. 

Lands with a slope > 72% were eliminated from the suitable land base and, therefore, cannot be 

logged. Lands with slope > 67% are generally to be left unroaded (and are mostly harvested by 

helicopter) unless no practical alternatives exist. Lands between 35% and 67% slope generally 

cannot use the ground-based/shovel system, and must use the helicopter or cable system. 

Lands with < 35% slope can generally be harvested with the ground-based/shovel system. It is 

easy to see how slope has an indirect effect on the cost of removing the timber from the land; 

generally, ground-based/shovel systems are the least expensive, followed by cable, with 

helicopter harvests as the most expensive. Therefore, steeper-sloped areas incur a higher timber 

harvest cost. Operability also correlates quite strongly with elevation and general accessibility. 

Productivity Groups. This land classification is based on the site productivity as categorized in 

the Soil Mapping Unit (SMU) data base. There are three basic groups that indicate the 

regeneration potential for future timber stands. Group 1 is the highest productivity class with a 

minimum site index (SI) of 75. Group 2 is lands with an SI less than 75 that are not Group 3. 

Group 3 is all lands in the following wetland soil types: Karheen, Kaikli, Maybeso, Kitkum, or lithic 

Cryosaprist. Group 3 ranges from an SI of 40 (Chatham) to 50 (Ketchikan). 

Roaded Classification. This identifier specifies whether an area is presently roaded or 

unroaded. The road/roadless condition of an area influences the cost of harvesting the timber. 
Appendix B 

Modeling and Analysis B-6 Final EIS

Unroaded areas require more costly road construction; roaded areas require less costly road 

maintenance and repair when harvesting activities are conducted. 

Volume Class/Strata. This attribute was used as an identifier due to its relevance to many forest 

management considerations. Wildlife habitat and most recreational settings correlate with the 

vegetation types described by this feature. This attribute was relevant in then Spectrum model to 

distinguish the logging costs and timber benefits associated with the volumes generated from the 

different volume classes. There are 12 second-growth strata and three old-growth strata used as 

Spectrum identifiers. Young growth (or “second growth”) stands are categorized into 10-year age 

classes between 0 to 80 years old and also by whether they have been precommercially thinned. 

Old-growth strata include low-volume, medium-volume, and high-volume stocking levels. The 

strata used for this identifier are obtained from a GIS dataset derived from the Tongass National 

Forest’s recently derived size density model (SDM). 

Regulation Class. This identifier distinguishes the three regulation classes recognized in the 

model. Regulation class is determined by the combination of Scenic Integrity Objective, LUD 

designation, Distance Zone and Visual Absorption Capacity. Regulation class affects the intensity 

of potential harvesting activities. See below in this Appendix for a detailed explanation the 

Regulation Class process. 

Table B-1 

Spectrum Level Identifiers 

Identifier Possible Attributes 

Value Comparison Unit (VCU) 00 through 3950 (Chatham) 

5270 through 8670 (Ketchikan) 

3980 through 5260 (Stikine) 

Logging Operability Ground-based/Shovel 

Short-span cable 

Short-distance helicopter 

Long-span cable 

Mid-distance helicopter 

Long-distance helicopter 

Roaded Condition Roaded 

Unroaded 

Volume Class/Strata Young Growth Age 0-9 

Young Growth Age 10-19 

Young Growth Age 20-29 

Young Growth Age 30-39 

Young Growth Age 40-49 

Young Growth Age 50-59 

Young Growth Age 60-69 

Young Growth Age 70+ 

Young Gr. w/ Precomm. Thin Age 20-29 

Young Gr. w/ Precomm. Thin Age 30-39 

Young Gr. w/ Precomm. Thin Age 40-49 

Young Gr. w/ Precomm. Thin Age 50+ 

Low Volume Old growth 

Medium Volume Old growth 

High Volume Old growth 

Regulation Class Regulation Class 1 

Regulation Class 2 

Regulation Class 3 
Appendix B

Final EIS B-7 Modeling and Analysis

Modeled Analysis Areas. Once the Analysis Area Identifiers were determined, the next step was to 

estimate the number of possible analysis area combinations. The maximum number possible is the 

product of the number of unique elements in each identifier: 

946 VCUs x 6 Operability Classes x 2 road/unroaded x 3 productivity groups x 12 volume strata x 

3 regulation classes = 1,226,016 potential Analysis Areas 

The Tongass GIS layers of Analysis Area Identifiers were intersected to result in a Forest-wide total of 

about 87,500 unique polygons (Alternative 6). However, more than 86,000 of these polygons were less 

than 100 acres in size. Due to size considerations of the Spectrum model and the fact that, on an 

operational level, very small areas of land would not be independently managed, it was necessary to 

generalize smaller polygons and lump them with similar larger ones. Through a process of trial-and-error, 

an 80-acre threshold was used to create a manageable model size, while still preserving model integrity 

at a strategic planning level. In other words, all polygons less than 80 acres and within certain guidelines 

were aggregated into a larger analysis area. 

A four-step algorithm was used to take small polygons and lump them with larger ones to create a 

manageable number of analysis areas. Step 1 combined polygons regardless of size. Steps 2 through 4 

generalized only polygons less than 80 acres in size (they could be lumped into an analysis area larger or 

smaller than 80 acres). 

Step 1: Match on all attributes 

Some polygons were geographically distinct but not distinct based upon analysis area identifiers. 

Therefore, the first generalization was that if all identifiers matched between two or more polygons (initial 

analysis areas), they were combined into one for analysis purposes. 

Step 2: Ignore the roaded/unroaded classification 

If two Analysis Areas were in the same VCU, had the same operability, regulation class, volume strata, 

and productivity class, the smaller one was lumped with the larger one. 

Step 3: Ignore roaded/unroaded classification and operability classification 

After step 2, if two Analysis Areas were in the same VCU, had the same regulation class, volume strata, 

and productivity class, the smaller one was lumped with the larger one. 

Step 4: Ignore volume strata 

After step 3, if two Analysis Areas were in the same VCU, had the same operability, roaded/unroaded 

classification, regulation class, and productivity class, but different volume strata classification, the smaller 

one was lumped with the larger one. The exception was that old growth was not lumped with young 

growth and young growth was not lumped with old growth. 

Finally, if the analysis area could not be generalized and it was less than 5 acres in size, it was left out of 

the model. The final number of analysis areas for the Tongass was 5403 (Alternative 6). 

A note on the effects of model generalization 

As with any model, the Spectrum model is a landscape planning model that relies heavily on 

generalizations and assumptions. There are many generalizations used in the Spectrum model that 

affect exactness of the outcome. These factors include generalizations in the GIS maps used to create 

the analysis areas, aggregation and averaging of FIA stand inventories used to calculate per-acre yields, 

statistical inference used in calculating the value of harvested logs, statistical inference and 

generalizations in determining costs of logging, road construction, miles of roads to construct, etc., and 

simplifying assumptions about the uncertainty of future costs and commodity prices. Analysis Area 

aggregation is simply another generalization technique used to make the model a manageable size. It is 

simply not possible without further detailed study to isolate the effect of Analysis Area aggregation on the 

true value for any given land area/prescription or for the Forest as a whole. It is assumed that the level of 

detail maintained in the model is accurate enough to give managers enough information to make 

informed decisions about the alternatives evaluated in this Forest Plan.
Appendix B 

Modeling and Analysis B-8 Final EIS

Management Prescriptions 

A prescription is a management practice or group of management practices applied to a specific land 

area. The planning process involves assignment of the land base to the available prescriptions. This is 

facilitated by the Spectrum model. The solution process of Spectrum assigns land to prescriptions based 

on forest constraints, the given management alternative, and the objective function. 

Prescriptions were developed by the interdisciplinary team to represent the full range of possible 

management activities and outputs. Since the Tongass models are concerned primarily with timber 

harvest scheduling, only prescriptions related to timber harvest were modeled. The interdisciplinary team 

quantified the outputs, costs, and benefits that would occur when these timber prescriptions were applied 

to a given analysis area. This quantification process produced the output, cost, and benefit coefficients 

that are used in Spectrum yield and economic tables. The interdisciplinary team, during its development 

of standards and guidelines for all prescriptions, ensured that the specific management requirements set 

forth in 36 CFR 219.27 would be met in accomplishing the goals and objectives for the Tongass. 

Spectrum prescriptions were developed to allow consideration of a full range of management activities in 

the analysis areas. A minimum level or no-harvest prescription was created for each analysis area as 

well as several different harvest options. The only criterion used to eliminate timber options from the 

models was technical feasibility. For example, ground-based/shovel logging was not considered on 

slopes greater than 35 percent. Consideration of timber prescriptions for any given Analysis Area was 

not directly limited by economic efficiency, in order to allow they may be chosen in efficient fulfillment of a 

forest-wide desired condition (CFR 219.14(f)(8)). Available timber options were not eliminated from 

consideration because they produced a negative Present Net Value (PNV) or even a lesser PNV than 

some other timber option. A full range of timber options with varying levels of economic efficiency was 

available to the model, and the Spectrum model was able to consider the economic efficiency of each 

prescription during the solution process. The Spectrum prescriptions analyzed are briefly described 

below. 

Minimum Level/Maintenance. Applies minimum custodial direction for the timber resource. 

There is no commercial timber harvest and no production of outputs related to timber harvest. 

This is the prescription assigned to lands not scheduled for timber harvest 

Clearcut. Removal of all merchantable commercial trees within a stand in one operation. The 

regenerated stand receives no thinning activities before the next clearcut. 

Clearcut with precommercial thinning. Removal of all merchantable commercial trees within a 

stand in one operation. The regenerated stand receives a subsequent precommercial thin at 20 

years of age. 

Clearcut with commercial thinning. Commercial thin at age 70, 80, or 90. Clearcut at choice of 

rotation ages. Applies to Productivity Class 1 lands, Regulation Classes 1 and 2. 

Clearcut with precommercial and commercial thinning: Precommercial thin at age 20. 

Commercial thin at age 60, 70, or 80. Clearcut at choice of rotation ages. Applies to Productivity 

Class 1 lands, Regulation Classes 1 and 2. 

Small-group selection and uneven-aged harvesting. The objective of this prescription is to 

create uneven-aged stands with regeneration of desirable species. Trees are harvested 

individually or in small groups normally from 0.5 to 5 acres in size. Timber production is not the 

primary management emphasis in these areas (emphasis is recreation, scenery, fisheries, and/or 

wildlife). Applies to Regulation Class 3. 

This prescription is modeled as a series of removals that occur every 50 years and remove 25% 

of the volume at every entry. For old-growth stands, accounting rows (reflecting standing volume) 

in these yield tables show the combination of remaining old growth plus assumed regrowth of the 

small patch. Green-up interval is implied by the regulated scheduled entries (50 years); rotation 
Appendix B

Final EIS B-9 Modeling and Analysis

age will be 200 years. Existing young-growth stands in Regulation Class 3 are modeled in a 

similar manner as the old growth; 25% of the volume is removed upon first entry (starting age 80) 

and 25% is removed at second entry, etc. 

Old Growth Two-Aged Management (Partial Cut). This prescription was developed for areas 

where goshawk and marten standards apply. On first entry into old-growth stands, 75% of the 

land area is harvested (75% of the standing volume). The stand is then considered “regenerated” 

and second-growth activities are allowed on the cut portions of the stand starting at age 80. 

Standing volume is a function of remaining old growth plus assumed regeneration. Regeneration 

volume is approximately 10% less than full young-growth volume, due to the increased shading 

from reserve trees. This prescription is available to Regulation Class 1 and 2, Productivity 

Classes 1 and 2 Old-Growth High volume strata only. This prescription is applied to Alternative 5 

VCUs with goshawk/marten standards when more than 33% of the POG within a VCU has been 

regenerated. 

Activities and Outputs 

Activities are the costs associated with Spectrum-assigned timber harvests. Outputs are the timber 

volumes and prices associated with the same harvests. Each Activity and Output used in the model is 

described below. 

Activities (Costs). All costs and values used in the Spectrum analysis are based on collected values 

(2004). In order to reduce the number of numeric tables in this appendix, only average and summarized 

values are used in this section. The actual cost figures used in the analyses are available in the planning 

records. 

Coefficient Development and Estimation of Effects. The GIS enables identification and stratification 

of land into logical groupings. The response of these groups to management activities was determined 

from a wide variety of existing data. All coefficients and assumptions made in the modeling process have 

been developed from the following information sources. 

Sale Preparation and Administration 

Information Sources: Tongass National Forest, historic actual expenditures and accomplishment 

data, declaration of Forrest Cole, July 2004. 

Occurs With: Thousand board feet of net sawlogs removed from the stand. 

Assumptions: This is the cost to the Forest Service of administering and laying out timber sale 

areas. A single coefficient was used to estimate timber sale preparation and administration costs: 

$32/MBF. 

Log Transfer Facility (LTF) 

Information Source: The forest GIS coverage of existing and proposed LTFs. Costs and 

construction levels are based on historic costs experienced in the past 5 years of construction 

contracts and adjusted with Region 10 construction cost guide information. 

Occurs With or Varies By: Acres harvested. 

Assumptions: Using the LTF map and database, each LTF, existing or proposed, was assigned to 

the appropriate VCU. Appropriate mathematical adjustments were made for VCUs that access 

more than one LTF, or LTFs that service more than one VCU. LTF costs used in Spectrum are an 

average of total cost of the LTF to be constructed divided by the number of suitable acres in that 

VCU. The cost is incurred at time of harvest. LTF Construction costs are classified by 4 different 

categories to reflect the total cost of constructing the LTF. 

Category 1: Existing LTF constructed/used within last 10 years = $50,000 

Category 2: Existing LTF constructed/used more than 10 years ago = $125,000 
Appendix B 

Modeling and Analysis B-10 Final EIS

Category 3: New Construction (large) (>30 MMBF total volume) = $175,000 

Category 4: New Construction (small) (<30 MMBF total volume) = $125,000 

LTF Camp/Commute

Information Source: Based on most recent published collected costs, Region 10 Forest 

Management (2004). 

Occurs With or Varies By: Acres harvested. Varies by VCU. 

Assumptions: The cost is incurred at the time of harvest. Each LTF used by a VCU was identified 

as either needing to maintain a camp, pay for a significant commute, or be free of this cost. 

Average camp cost per MBF is $15. Average commute cost is $7 per MBF. Weighted averages 

assigned to all acres of a VCU were used when not all acres of a VCU require LTFs to incur 

camp or commute costs. 

Road, Raft, and Barge Haul

Information Source: Road haul costs are an average for the forest based on most recent 

published collected costs (2004). Raft and barge haul distances are based on a GIS analysis of 

LTFs and existing and/or potential mill locations. Barge and raft haul costs are calculated by a 

formula based on regional published costs. 

Occurs With or Varies By: Value Comparison Unit (VCU). Costs are based on the volume 

(thousand board feet) removed from the stand. 

Assumptions: Hauling cost includes all anticipated modes of transport likely used to transport logs 

from the landing to the mill. This may include road, barge, and/or log raft. Road haul is the cost of 

transporting logs by truck to either the closest LTF or mill. Road haul costs represent the forestwide average haul cost per MBF volume removed based on average haul time. The average 

Road Haul cost is $24 per MBF. Barge haul is the cost of barging logs from the site or the LTF to 

the appropriate mill. Raft haul is the cost of building rafts out of the logs and hauling them to the 

appropriate mill. Raft haul cost may only be used in higher-demand alternatives, assuming the 

construction of new Medium Density Fiberboard (MDF) plants. Appropriate mathematical 

adjustments were made for calculating the haul costs for alternatives that incurred haul costs for 

utility wood vs. those Alternatives that left the utility wood at the site. 

The distance to the nearest sawmill was determined for each VCU as VCUs are geographically 

distinct. For alternatives that recognized the eventual existence of Medium Density Fiberboard 

(MDF) plants, there were potentially two distances calculated for each VCU – one from the VCU’s 

LTF to the sawmill and one from the LTF to the MDF plant. This distance was then used in a 

formula to calculate the total cost per thousand board feet (MBF) of the timber sale. 

Formula: ((((RTD/M)*C)/B) + F)/(1-SD) 

Where: 

RTD = Round trip distance (unique for each VCU – twice the distance from the LTF to the mill) 

SD = Scaling Defect (unique based upon age of the stand, volume strata, and geographic zone). 

C = Cost per hour of operation ($182.50) 

B = Average MBF on the barge or raft (238) 

M= Miles per Hour (6.9) 

F = Fixed costs ($33.72) 

By inspection, one can see that when all other factors are held constant, logs traveling a greater 

distance to the mill incur a higher per-MBF transportation cost. This relationship is not exact, 

however, in that different VCUs were determined to have different Scaling Defects (SD) which 

may mitigate or exacerbate the transportation costs due to proximity to the mills. 
Appendix B

Final EIS B-11 Modeling and Analysis

Road Construction, Maintenance, and Repair 

Information Source: The extent of Road construction and maintenance and repair needs are 

based on total projected road miles and the total suitable land base. Costs required for different 

regulation class lands are derived from the linear grading road construction calculations within the 

Construction Cost Guide. Road construction and maintenance and repair costs are obtained 

from the Construction Cost Guide calculations, compared to the costs for construction of roads, 

over the past 5 years, for public works and timbersale contracts. Road maintenance that occurs 

during logging operations is included in logging costs. 

Occurs With or Varies By: Cost varies by Regulation Class. Miles of Road Construction and/or 

Maintenance and Repair vary by Roaded status and Regulation Class within each VCU. 

Assumptions: All harvest requires some road construction and maintenance and repair. If the 

area is classified as roaded, then the majority of the activity is road maintenance and repair. 

Otherwise, road construction is the primary activity. The amount of road construction or 

maintenance and repair required depends on the geographic location of the harvest area. Each 

VCU has a distinct roading requirement coefficient. This coefficient is in the terms of miles of 

roads required to access 1 acre of timber land. The average construction and maintenance and 

repair for the Tongass is approximately seven miles of road per 1,000 acres (this does not include 

temporary roads). Maintenance and repair is the only activity necessary once timber harvest is 

comprised solely of regenerated timber stands because the roads were assumed to be built to the 

stands for the first harvest. 

The timing of construction and maintenance and repair activities and costs varied by 

management prescription: 

 Even-aged prescriptions without commercial thinning incur road construction and 

maintenance and repair costs as necessary upon first harvest. Upon subsequent harvests, 

these prescriptions incur the sum of the initial construction and maintenance and repair costs 

as maintenance and repair costs. 

 Even-aged prescriptions with commercial thinning incur road construction and maintenance 

and repair costs as necessary at the time of the thin. When the stand is regenerated, roads 

maintained and repaired at thin will be maintained and repaired and roads constructed at thin 

will be maintained and repaired. 

 The partial-cut prescription works as the even-aged prescription, except in that even though 

only a portion of the area is treated by this prescription, the full cost for the total area is 

incurred. 

 The Regulation Class 3 prescription works similar to the even-aged prescription; roads are 

constructed and maintained and repaired upon first entry and they are all maintained and 

repaired upon subsequent entries. 

Road construction and reconstruction costs are obtained from the Construction Cost Guide 

calculations, compared to the costs for construction of roads, over the past 5 years, for public 

works and timber sale contracts. Road construction costs are dependent on slope; steeper 

slopes have a higher road construction cost. Construction costs are exactly calculated for each 

Regulation Class and Roaded status type within each VCU in order to accommodate the different 

slopes in these classes between VCUs. The Forest-wide road construction cost is $185,000 per 

mile and maintenance and repair costs are $50,000 per mile. Road construction/maintenance 

and repair miles needed for harvests are exactly calculated for VCUs with 100 or more acres of 

suitable land. For VCUs with less than 100 acres, an average for the administration area was 

used to mitigate small mapping errors and miscalculations that may occur with small areas. 

Regeneration Certification 

Information Source: Tongass National Forest, average cost 

Occurs With or Varies By: Acres harvested with an even-aged prescription 
Appendix B 

Modeling and Analysis B-12 Final EIS

Assumptions: Occurs for every acre harvested and the cost is incurred at time of harvest. This 

activity usually takes place from 3 to 5 years after harvest, but because modeling is done on a 

decadal basis the cost is incurred at time of harvest. It also is assumed that all stands will be 

certified as regenerated by year five. According to the Tongass silviculturist, when planting 

occurs, it costs $200/acre. However, only about 3% of treated acres need to be planted. 

Therefore, the average planting cost of all treated acres is $6 per acre. Planting on Regulation 

Class 3 lands or in partial cuts is adjusted by the percentage removed (i.e., if a partial cut is 75% 

of the acre, 75% of the planting cost is incurred). In addition to planting costs, there is a 

regen/survey cost of $18 per acre that will be included with this cost. The total planting cost used 

in Spectrum was $24. 

Precommercial Thinning 

Information Source: Tongass National Forest, implementation cost data based on Region 10 

budget allocation 

Occurs With or Varies By: Acres receiving a timber prescription permitting this activity. 

Assumptions: The Tongass has an active program of precommercial thinning. This improves the 

health of the stand and permits greater understory development for wildlife. This thinning 

operation is termed "precommercial" because no revenues are derived from the sale of the 

harvested trees. The average cost for precommercial thinning on the Tongass is $550 per acre. 

This silvicultural activity is generally conducted when the stand is between 10 and 20 years old 

and modeled to occur at age 20. 

Yarding/Logging Costs 

Information Source: Calculated using procedures in FSH 2409.22 -- Timber Appraisal Handbook. 

Occurs With or Varies By: Varies by volume class, logging operability, geographic zone, 

productivity group, stand age, and prescription. This cost is incurred according to net sawlogs 

removed per acre and net utility volume removed per acre. 

Assumptions: These costs include road maintenance relative to logging, profit and risk relative to 

yarding, landing construction, and yarding. Logging costs increase as operability becomes more 

difficult. The logging operability classification of the area heavily influences the logging costs due 

primarily to the different harvest systems required. The size of the logs influences logging costs. 

Typically, larger logs result in less logging cost per 1,000 board feet. Volume class, productivity 

group, stand age, and the use of precommercial thinning is used to estimate the average log size 

and volume per acre for each unit. 

Logging systems include ground-based/shovel, short-span cable and long-span cable. Helicopter 

costs will also be determined by three categories of distance (0.5 mile, 1.25 mile, and 2+ mile). 

Helicopter costs are constant costs independent of volume strata and geographic zone, so they 

can be applied wherever helicopter logging must be used. Young-growth harvest costs were 

determined initially from FVS outputs at age 80. They were then adjusted for geographic zone, 

age, and prescription (i.e., clearcut or thin) using South Islands (POW, where the data was 

collected) as a reference point. Cost curves from 1996 were used as the basis of this adjustment. 

Felling and bucking coefficients 

Information Source: Based on most recent published collected costs, Region 10 Forest 

Management (2004). 

Occurs With or Varies By: Tracked on a per volume basis (MBF). Varies by Geographic zone and 

volume class. 
Appendix B

Final EIS B-13 Modeling and Analysis

Assumptions: Felling and bucking costs were split out separately from logging costs. Costs varied 

by Geographic zone and volume strata. The forest-wide average felling and bucking cost was $47 

per thousand board foot volume. 

Outputs(Benefits). The economic benefits associated with timber harvest are based on appraised value. 

Value is based on tree size, species composition, amount of defect, and other factors. Timber benefits 

are measured as pond log value. Pond log values used in the Spectrum model are the estimates of price 

a timber buyer would pay for a log at the mill site, less the markup charged by the logger (profit and risk). 

To get the stumpage value of this log, all estimated costs that are incurred to get the log to the mill must 

be subtracted from the pond log value. The resulting stumpage price is assumed to be the price the 

timber buyer pays for the log (bid price). Bid price represents money to the U.S. treasury. 

Sawtimber (board feet and cubic feet) 

Information Source: Timber values were determined using timber appraisal methodologies for 

Southeast Alaska (FSH 2409.22). Values were derived from historic cruise database based on 

actual collected values (2004). Merchantable volume of existing old-growth timber stands was 

based on FIA plot analysis by volume strata within each identified Geographic Zone. Yields for 

regenerated second growth timber stands were derived from permanent study plots and the FVS 

yield table generation program. 

Occurs With or Varies By: At harvest, the volume of merchantable timber produced generates a 

per mbf revenue that varies by Geographic Zone and volume class. Geographic zone affects this 

revenue due to differences in species composition and wood quality. 

Assumptions: For existing stands, piece size and species composition is determined from a treeby-tree analysis of the FIA plot summary data. For regenerated stands, piece size and species 

composition is based on a tree-by-tree analysis of the FVS model outputs. It is assumed that 

existing old-growth volumes are constant (i.e., through time, growth equals mortality). Younggrowth (regenerated) stands grow at a rate determined by the FVS model. The average oldgrowth pondlog value is $273 per mbf, which is adjusted for profit and risk (economic benefit, or 

profit, to the logger). Young-growth sawtimber pond log values are also adjusted for profit and 

risk. 

Utility Volume (board feet and cubic feet) 

Information Source: No value for utility wood is recognized for Alternatives 1, 2, and 3. Values 

for Alternatives 4, 5, 6 and 7 are based on Medium Density Fiberboard pond log calculations. 

Source: "Technical & Economic Feasibility of Constructing a Medium Density Fiberboard Plant in 

Southeast Alaska". Leonard Guss Associates, 31 May, 2005 and discussions with Dr. Allen 

Brackley, USDA Forest Service, Sitka Wood Utilization Center. Average percent utility volume 

was derived using timber measurements methodologies developed by the Region 10 

Measurements Specialist. Merchantable volume of existing stands is derived from an analysis of 

FIA plots located within the suitable land base of the forest. Volume of regenerated stands is 

obtained from the FVS. 

Occurs With or Varies By: At harvest, the volume of merchantable timber produced generates 

revenue that varies based on Geographic Zone and volume class. Geographic Zone affects this 

revenue due to differences in species composition and quality. 

Assumptions: For existing stands, piece size and species composition is determined from a tree 

by tree analysis of the FIA plot summary data. For regenerated stands, piece size and species 

composition is based on a tree-by-tree analysis of the FVS model outputs. It is assumed that 

existing old growth volumes are constant (i.e., through time, growth equals mortality). The utility 

volume from regenerated stands is assumed to be negligible and is therefore not counted, 

whereas the utility component of existing old growth stands averages 16 percent. This difference 

results from the mixed diameter distribution of old growth stands and the impact of defect to 
Appendix B 

Modeling and Analysis B-14 Final EIS

potential sawlogs. The average utility log pondlog value is $72 per mbf, which accounts for profit 

and risk. 

Spectrum Constraints 

Constraints in a linear programming model are the rules that must be followed when determining an 

optimal problem solution. Without constraints, the solution of a Spectrum model may represent a 

management strategy that is impractical, inconsistent with the forest plan, or in conflict with Forest 

Service policy. Thus, constraints are included in Spectrum models to ensure that their results are useful 

and meaningful.

There are two categories of constraints within a Spectrum linear matrix: implicit and explicit. Implicit 

constraints are common to all Spectrum models. For example, all acres in the model must be allocated to 

some prescription (even if it is the “no management” prescription), or the number of acres assigned to 

each prescription must not be negative. These types of constraints are exercises in logic and need not 

be discussed further. 

Explicit constraints are those constraints added to Spectrum models by planners. These constraints 

come in many forms and are applied to mimic regulations and laws such as NFMA, standards and 

guidelines set forth in the forest plan, and on-the-ground operating conditions. An example is the nondeclining yield constraint. Proven ability to maintain a constant flow (non-declining yield) of harvested 

timber volume in perpetuity is Forest Service policy. A constraint is added to the Spectrum data set that 

forces all timber harvest volumes to be at least as great as the previous decade's harvest volume (see 

below for further discussion). Another example may be a constraint that forces a certain area to be 

managed specifically for wildlife habitat. There are many explicit constraints in the Tongass models. They 

vary by land attributes, geographic area, and by management alternative. The explicit constraints used in 

the Spectrum models fall into two categories: timber policy constraints and operational constraints. A 

detailed discussion of the intent of these constraints follows. They are summarized in Table B-2 for 

comparison of their application across the alternatives. 

Timber policy constraints. These constraints are included in the Spectrum models to represent legal or 

policy requirements of national forest timber management. The primary requirements regarding timber 

management incorporated into Tongass Spectrum models are: 

Non-declining Yield. The Tongass models have a constraint that ensures harvest volume (in 

board feet) will not decline in any decade over the 160-year planning horizon per national policy. 

Harvest volumes may increase, but all subsequent harvests must be at least as much as the 

previous decade’s harvest. 

Sustained Yield. The harvest in any decade of the planning horizon must not exceed the LongTerm Sustained Yield that can be maintained on the forest. Long-term sustained yield is 

measured in cubic feet. It is calculated as the average yearly volume yielded from a chosen 

management action, summed across all management actions for all stands chosen by the model. 

For instance, if a management action yields 50 cubic feet every 100 years, the Long-Term 

Sustained Yield for that management action is 0.5 cubic feet per year. 

Culmination of Mean Annual Increment. The age at which a managed stand is harvested is 

called the rotation age. Agency policy is that rotation age can be no earlier than the age at which 

95% of culmination of mean annual increment (CMAI) occurs. CMAI is the age at which the 

stand achieves its highest average volume. The Spectrum models have constraints that allow 

timber harvest only when a stand has reached 95 percent of this CMAI age. On the Tongass, this 

translates to a range of rotation ages of about 60 to 170 years. CMAI varies by stand productivity, 

management prescription, and administrative area and is calculated using merchantable cubic 

foot volume. 
Appendix B

Final EIS B-15 Modeling and Analysis

Table B-2 

Timber Policy and Operational Constraints Used for Spectrum Modeling 

Variation Among Alternatives 

Constraint Description 1 2 3 4 5 6 7 

Non-declining Yield Ensures that a Decade's total harvest 

volume is at least as much as the 

previous decade 

These constraints are identical between the 

Alternatives 

Sustained Yield Prevents the model from harvesting 

all available timber in the last 

planning period - limits it to LongTerm Sustained Yield or less 

Calculated for each Alternative - Applied the 

same way* 

Culmination Mean 

Annual Increment 

Prevents the model from harvesting a 

stand before 95% CMAI is reached 

These constraints are identical between the 

Alternatives 

Strata Harvest Control Limits the harvest of Old Growth High 

Volume to their proportion of the total 

Calculated for each Alternative - Applied the 

same way* 

Logging Operability Limits harvest in Normal Operability 

(NIC I) to its proportion of the total 

Calculated for each Alternative - Applied the 

same way* 

Watershed Entry Limit the model to 20% of any 

watershed less than 30 years old 

Calculated for each Alternative - Applied the 

same way* 

Precommercial Thinning Limits the total amount of 

precommercial thinning to a feasible 

level - 6300 acres per year 

This constraint is identical between the 

Alternatives 

Minimum Timber 

Constraint 

Sets the minimum amount of volume 

to harvest in certain decades; this is a 

desired condition of the Alternative 

Calculated for each Alternative - Applied the 

same way* 

Regulation Class 3 

Harvest 

Limits harvest in Regulation Class 3 

to historic proportion of the total 

This constraint is identical between the 

Alternatives 

Cause the model to accommodate 

the appropriate standards and 

guidelines of the Alternative 

Goshawk/Marten No No No No Yes No No 

Legacy Yes Yes Yes No No Yes No 

Goshawk/Marten, 

Legacy, Retention 

Standards and 

Guidelines 

Old Growth Retention No No No Yes No No No 

Regulation Class 

Management Intensity 

Cause the model to implement the 

correct management scheme for each 

Regulation Class 

These constraints are identical between the 

Alternatives 

Modeled Implementation 

Reduction Factor (MIRF) 

Accounts for unmappable unsuitable 

lands 

These constraints are identical between the 

Alternatives 

Dispersion and 

Adjacency 

Controls on management intensity in 

the different Regulation Classes 

Calculated for each Alternative - Applied the 

same way1

1 The constraint level is unique for each alternative but it takes the same form (e.g., High Volume Strata < X, 

where “X” is unique for each alternative) 

Operational Constraints. These constraints are added to Spectrum models to ensure that the results fall 

within certain Forest-derived guidelines and objectives. Many of these constraints are included to ensure 

the Forest Plan standards and guidelines are followed. Others are included to make sure the model is 

“well-behaved.” The term well-behaved means that Spectrum results are reviewed for any operationally 

impossible solutions and constraints are added to deal with these. An example may be the harvest of all 

of the high-volume strata in the first two decades of the planning horizon. The “strata harvest control 

constraints” are then added to address this problem (see below). The operational constraints used in the 

Tongass Spectrum models vary slightly by alternative but are used primarily to control the spatial and 

volume components of timber management. These constraints are summarized below. 

Strata Harvest Control Constraints. In order to ensure that the model does not cut all of the 

most valuable timber early in the planning horizon, each model is constrained so that the 

proportion of harvest in the highest volume strata does not exceed the proportion of that stratum 
Appendix B 

Modeling and Analysis B-16 Final EIS

in each administration area. This prevents the model from harvesting all of the most desirable 

timber in an unsustainable way. This constraint is adjusted to account for the type of land 

(volume class mix) available in each alternative. For Alternative 5, this constraint limits the 

harvest of the high-volume strata acres to less than 43 percent of the total harvest of all oldgrowth acres.

Logging Operability Constraints. The forest has three general classes of logging operability 

derived from six specific classes of operability. The general classes are normal, difficult, and 

isolated, and the six specific classes are ground based/shovel, short span cable, long span cable, 

short distance helicopter, medium distance helicopter and long distance helicopter. Shovel, short 

span cable and short distance helicopter were considered “normal” operability, long span cable 

and medium distance helicopter were “difficult” and the long distance helicopter was “isolated.” 

To ensure that the model does not cut all of the cheapest, most accessible acres early in the 

planning horizon, constraints were added to disperse harvest to the difficult and isolated 

operability areas in proportion to their occurrence within each Administrative Area. These 

constraints vary by alternative due to different LUD applications but, in general, limit harvest from 

normal operability areas to no more than about 90 percent of total harvest acreage per decade. 

Watershed Entry Constraints. In order to minimize cumulative watershed impacts from harvest 

operations, constraints are included to restrict the number of acres that are in an open state in 

any time period. In general, these constraints limit total harvest acres in any 30-year period to 

less than 20 percent of the total watershed land area. Because the Tongass models use VCU as 

the primary land attribute, these constraints are entered for each VCU. Coefficients had to be 

calculated in each VCU in order to accommodate the fact that only suitable acres are included in 

the Spectrum model and are only a portion of the total area of most VCUs. In instances where 

suitable acres are less than 20% of the total acres in the VCU, the constraint will never be 

violated—even if all suitable acres are harvested. Therefore, these constraints are constructed 

based on total acres [ownership] in the VCU relative to suitable acres with the following formula: 

C = .2 * T / s 

Where C = constraint percentage, .2 is the 20% limit, T is total acres in the VCU, and “s” is the 

number of suitable acres. 

As an example, consider a VCU with 100 total acres, but only 50 suitable acres. C = .2 * 100/50, 

or 40%. The constraint added to the model would be 40% of the 50 acres, which is the same as 

20% of the 100 acres. Only constraints where C is less than 50% will be applied in order to 

mitigate model size, based on the assumption that Dispersion and other constraints will cause 

these constraints to be redundant where C is greater than 50%. 

Precommercial Thinning Constraint. All alternatives are limited to a maximum precommercial 

thinning of 6,300 acres per year. This is the amount that Region 10 considers feasible given 

budget and personnel limitations. A recent Region 10 report shows that the Forest has treated 

between 3,500 to 5,500 acres per year (2003-2006). It is recognized that this is not a maximum 

feasible amount, but suggests that 6,300 is a reasonable estimate of the maximum amount 

possible. 

Minimum Timber Constraint. All alternatives are constrained to meet at least the timber 

demand associated with the alternative being modeled. This helps to ensure that a full range of 

ASQs are explored during the decision-making process. These constraints are formulated on the 

basis that alternatives have been developed to evaluate different possible timber demand 

scenarios. Therefore, the level of timber demand in an alternative is viewed as a desired 

condition of that alternative. 

Regulation Class 3 Constraints. Of the acres clearcut during the planning horizon, no more 

than 7% of them can be from lands in Regulation Class 3. This constraint is based on the historic 
Appendix B

Final EIS B-17 Modeling and Analysis

level of harvest on marginally economically viable lands adjacent to normal timber sales. This 

constraint prevents the model from scheduling impractical amounts of Regulation Class 3 lands in 

later decades. 

Goshawk/Marten Constraints. These constraints apply to Alternative 5 at the VCU level. The 

amount of POG that can be harvested before these guidelines are enforced is used to constrain 

the number of acres that can be clearcut in each applicable VCU. Once that threshold is reached, 

lands may only receive a less intensive treatment (Old-Growth two-aged management – see 

“Management Prescriptions” above) 

Legacy Constraints. Alternatives 1, 2, 3, 5, and 6 incorporate the legacy constraint instead of 

the goshawk/marten constraints. This constraint requires 30% of the stand to be left unharvested 

in 49 VCUs on the Forest that have experienced high rates of past harvest. It is modeled in 

Spectrum using volume. This simulates leaving the appropriate number of legacy trees at the 

time of harvest. The constraints apply in perpetuity; if the regenerated stand is harvested later in 

the planning horizon, it is assumed that the same trees (or appropriate substitutes) will be left 

living at the site. 

Old Growth Retention Constraints. These constraints are applied to Alternative 4. Alternative 

4 includes old-growth reserves in four biogeographic provinces and an old-growth retention 

strategy in the others. Reserve areas are excluded from the model, and the retention strategy is 

modeled with a series of constraints. 

 

The alternative framework says that within each VCU where timber harvest is scheduled, the 

following constraints should apply: 

1) Harvest no more than 50% of the POG during any 50-year period 

2) Retain a minimum of 33% of the VCU in an old-growth forest condition 

Constraint 1 is formulated based on the amount of 2006 suitable POG relative to the amount of 

POG present in 1954 (represents the “original” amount of POG present). If the amount of suitable 

POG in 2006 is less than 50% of the total amount of 1954 POG, there is no danger of violating 

Constraint 1, and therefore the VCU is not constrained. In the remaining VCUs, the constraint 

was formulated so that no more than 50% of the 2006 suitable POG could be harvested in any 

50-year period. 

Constraint 2 was formulated based on how much of the remaining suitable POG could be 

harvested before 67% of the 1954 POG was harvested. If it was possible to harvest enough 

suitable POG to cross the 67% threshold, the constraint was set so that harvest would stop once 

67% of the POG was removed. Otherwise, the constraint was not necessary as one could 

harvest 100% of the remaining suitable POG and still leave 33% or more of the 1954 POG in the 

VCU. 

Model Implementation Reduction Factor Constraints (MIRF). These constraints are designed 

to accommodate for unmapped unsuitable lands that were missed during the suitability 

determination. It is assumed that when harvest activities occur, a certain percentage of the 

assumed suitable land will be off-limits for management due to several economic or ecological 

considerations. These constraints are applied to each old-growth volume strata of each of the six 

operability harvest systems as well as to young-growth stands. The constraint is implemented by 

forcing the model to never harvest a certain percentage of the acres in the model. The effect is to 

control the maximum amount of acres from the suitable land base that are actually harvested. 

See below for a discussion of how MIRF factors were determined. 

Dispersion and Adjacency Constraints. To meet visual quality and Regulation Class 

objectives, dispersion and adjacency constraints were incorporated into the models. “Dispersion” 
Appendix B 

Modeling and Analysis B-18 Final EIS

refers to spreading harvests across the landscape rather than focusing all activities in a 

concentrated area. The dispersion limits are taken from proxies developed by Tongass 

landscape architects for each LUD. These visual guidelines estimate how much of a viewshed 

can be "disturbed" at any one time and still meet the adopted scenic integrity objectives of the 

area. They also specify length of time before harvest of adjacent units is permissible and the 

maximum size of these harvest units. Table B-7 (below) shows the constraints that were used for 

each Regulation Class. The “Visual Disturbance” factors were used in the constraints section of 

the model and the “Adjacency” definitions were defined in the outputs section of the model. 

Together, these two definitions (as well as treatment options available to each regulation class) 

distinguish the regulation classes in the model. Detailed information about these constraints is 

found in the “Regulation Class” section of this appendix (below). 

Spectrum Solution Process 

The following sections describe some of the steps involved in solving the Spectrum models. The concept 

of “objective function” is discussed as the final model component. Following that is a brief discussion of 

how the Tongass evaluated economic efficiency of the alternatives. Last is a discussion of how the 

Spectrum model was used to gain insight into the management situation of each alternative and make 

more informed decisions. 

Objective Functions 

The objective function of a linear programming model defines the overall management objective of the 

forest quantitatively. It is generally expressed as a “minimize” or “maximize” function. The LP solution 

software finds the largest (or smallest) value possible of the objective function within the boundaries of 

the model constraints. Linear programming principles guarantee that the solution is optimal; that is, the 

best answer possible. Several different objective functions were used to explore the nature of the 

Tongass management problem. While only the “maximize present net value” objective function was used 

for the final results, the other ones may have been used at intermediate steps in the analysis process. 

Some of the objective functions used in the modeling process include: 

Maximize Present Net Value. Present Net Value (PNV) is defined as the benefits less the costs of a 

management prescription, discounted at 4% annually to the present day, summed over all management 

prescriptions of all Analysis Areas. Because the model is formulated in 10-year time periods, discounting 

is done from the middle of each period. This is the objective function that was used for all final model 

runs presented in this Final EIS. 

Maximize Timber Volume. Timber volume is tracked for each management action of each Analysis 

Area and the total amount is maximized. Several forms of this objective function were used; maximize 

timber volume in a given period or span of periods, maximize the sawlog component of the total timber 

volume in a given period or over a span of periods, or maximize the volume from an operability class in a 

period or span of periods. This objective function was used to ensure that desired levels of timber could 

be achieved. These runs were also used to proportionally allocate the Alternative demand level across 

the three Administrative Areas based on each area’s potential. However, the maximize timber runs were 

not used as the final models evaluated in this EIS. 

Minimize Harvest from the Unroaded Areas. This objective function was used to determine a 

management strategy that would meet the desired timber demand level by building as few roads as 

possible. It was used to help determine appropriate levels of suitable lands in some alternatives. 

Minimize Old-Growth Harvest. This objective function was used to determine the minimum amount of 

old-growth harvest that would sustain the desired timber demand level of an alternative. This information 

was not used in the final analysis of any alternative, but rather was an intermediate step. 
Appendix B

Final EIS B-19 Modeling and Analysis

Iterative Process 

The Spectrum model was used to test the assumptions and problem formulation strategies used in this 

analysis. Model outputs were generated and assessed to strengthen the validity of the model. For 

instance, if it was noticed the model was capitalizing on a certain commodity early in the planning horizon 

that was out of proportion with a likely feasible implementation (for instance, the model tends to high 

grade when given the opportunity), the model could be constrained appropriately. Additionally, the 

Spectrum model was used to formulate feasible constraints in the model. An objective function of 

“minimize harvest from unroaded areas” can be used to determine the minimum number of unroaded 

acres that need to be kept in the model to meet the desired demand level. If desired, excess acres could 

then be constrained to no management or removed from the suitable land base. Timber maximization in 

later decades can be evaluated to explore trade-offs between harvesting the timber early vs. saving 

inventory for later decades. If a model solution was infeasible (there is no management strategy that does 

not violate at least one constraint), the limiting constraints were identified and adjusted appropriately. 

One of the strengths of Spectrum or any Linear Programming model is the ability to analyze marginal 

costs associated with the different constraints. If a solution space is very narrow (there are very few 

decisions that result in a feasible management strategy), the marginal costs of the constraints can be 

analyzed to determine which are the “bottlenecks,” or constraints that have the largest impacts on 

meeting the objective. The problem can then be reformulated by relaxing these constraints if desired. 

Economic Efficiency 

The Spectrum model was used to help measure the economic efficiency of the timber management 

activities of each alternative. Timber management activities can be thought of as a portion of the net 

public benefits associated with each alternative. Net public benefits are the "overall long-term value, to 

the nation, of all outputs and positive effects (benefits) less all associated Forest inputs and negative 

effects (costs) whether they can be quantitatively valued or not" (36 CFR 219.3). Net public benefit 

represents the sum of the net value of priced outputs plus the net value of non-priced outputs. The EIS 

Chapter 3 explains and describes the elements of public benefits that may be a function of Forest 

planning and management activities. In the Tongass Spectrum analyses, the only economic efficiency 

directly considered was related to timber management. 

Present Net Value Formulation. Economic benefits from the Spectrum model were calculated as 

Present Net Value, or PNV, of the scheduled timber management activities. This calculation was done by 

the Spectrum model using pond log values, costs to the logger, and costs to the agency for administering 

the sale. The formula used to calculate the PNV of each potential management prescription is: 

PNV = [PLV – LC – AC]/(1 + d )t

PLV = pond log value (adjusted to exclude logger profit and risk) 

LC = Logging costs (operability, haul, LTF, camp/commute, felling and bucking, road building) 

AC = Agency costs (regeneration certification, sale preparation and administration) 

t = time (year) of harvest into the future 

d = discount rate (4% annually) 

The dollar values of outputs used to calculate PNV in the Spectrum model are pond log values measured 

at mill sites less the profit and risk to the seller. The costs weighed against these values included all of the 

expenses incurred from removing the timber from the site to the mill (logging costs, haul costs, LTF costs, 

road building costs, etc. – see above). This is a more detailed approach than a typical Spectrum 

application, but is done so to account for the variability in stumpage values that occur over such a large 

land area that is the Tongass National Forest. Stumpage value is the value of the timber at the site and is 

considered receipts to the federal government for a timber sale. In other words, it is what a purchaser will 

pay for the timber after considering all of the expenses (LC in the equation above) that are incurred in 

removing it to the mill. Stumpage, while not explicitly calculated before it is entered into the Spectrum 

model, it is an inherent part of the above equation [PLV – LC] that is calculated by Spectrum for all 

potential management prescriptions. 
Appendix B 

Modeling and Analysis B-20 Final EIS

See the above section on “Activities and Outputs” for more detailed information on each of the costs and 

timber values used in the Spectrum model. 

Supplemental Information on Other Model 

Assumptions 

Stage II Suitability Analysis 

Each acre classified as suitable for timber harvest was analyzed to determine the costs and benefits for a 

range or management intensities (36 CFR 219.14(b)). For the purpose of this analysis, the planning area 

was stratified into categories of land with similar costs and returns according to the Analysis Area 

Identifiers described above. The stratification also took into account those factors that influence costs and 

returns such as physical and biological conditions of the site (affecting logging system) and transportation 

requirements (by VCU). 

Stage II analysis is used to identify management intensities of timber production for each category of land 

that results in the largest amount of discounted net revenues. Stage II analysis provides insight into the 

overall economic condition of the suitable land base and what types of land are most cost efficient for 

management. The costs and benefits used for this analysis are described above and include pond log 

value, the cost of logging, removing, and transporting the timber to the mill as well as the agency-incurred 

costs of management. This analysis does not account for the utility volume costs or revenues, as the 

current market conditions do not favor its removal. 

Stage II analysis was conducted for all applicable management intensities: Intensive even-aged 

management with thinning regimes to very small clearcuts and group selection prescriptions (regulation 

class 3 areas). Table B-3 shows per-acre weighted average net revenue by category. These figures are 

representative of the highest value of the earliest treatment available to each land type. 

The current economic situation in Southeast Alaska creates some confusion in the interpretation of Table 

B-3. At an initial glance, it may appear there are no economically viable areas for timber harvest. It is 

important to realize that within each category of land there can be large differences in economics. For 

instance, the Regulation Class 1 Ketchikan High Volume Class Normal Operability category (-$478/acre) 

contains a range of economics from acres of short-span helicopter harvest with a large negative net 

revenue (-$6,917/acre) to acres of shovel harvest in a roaded area with a large per acre net revenue 

($3,257/acre). Therefore, a summary of the positive values in each category is also provided in the final 

two columns of the table. These figures represent the weighted average net value per acre of only those 

acres that have positive value. Again, some caution in interpretation must be used; the $1,461/acre of 

Regulation Class 1 Chatham High Volume Class Normal represents 3,600 acres, whereas the Regulation 

Class 1 Ketchikan High Volume Class Normal Operability ($488/acre) represents nearly 53,000 acres. A 

complete economic analysis for each Analysis Area is too lengthy for this appendix and is included in the 

planning record. 

Another potentially confusing aspect of these tables occurs due to the decreasing value of more highly 

stocked stands. An example of this can be seen in the Regulation Class 1 Chatham Normal Operability, 

where a “Low” stand is valued at -$1,736 and a “High” stand is at -$2,529. Here is a case where on 

average, the additional cost of removing the volume from the woods is more than the revenues received 

for that volume. The Chatham is susceptible to this phenomenon likely due to its average distance from 

the nearest processing mill. The additional cost incurred from shipping more volume from a “High” stand 

is cumulatively more than the cost of shipping less volume from a “Low” stand. This same relationship 

generally holds true when comparing Regulation Classes 1 or 2 with Regulation Class 3. In Regulation 

Class 3, there is generally less volume removed per acre, and therefore the overall costs per acre are 

lower. Otherwise, the table generally shows lower economic desirability in more expensive harvest 

systems and lower volumes per acre. Regulation Classes 1 and 2 numbers are predictably similar due to 

their difference only in allowable clearcut size, green-up intervals, and adjacency constraints, none of 

which factor into this economic feasibility study. 
Appendix B

Final EIS B-21 Modeling and Analysis

Table B-3 

Discounted Average Net Revenues by Land Category 

Regulation Class 1 

Reg. Class 1 - 

Positive Values Only 

Admin 

Area 

Volume 

Class 

Normal 

(net$/acre) 

Difficult 

(net$/acre) 

Isolated 

(net$/acre) 

Normal 

(net$/acre) 

Difficult 

(net$/acre) 

Chatham Low -1,736 -3,242 -4,567 90 

Medium -1,842 -5,437 -8,927 585 

High -2,529 -7,557 -12,948 1461 

Young Gr -184 -5,095 -7,094 873 

Ketchikan Low -1,532 -4,474 -6,809 247 

 Medium -589 -4,381 -9,702 856 318

 High -478 -5,191 -13,994 1,288 819

 Young Gr -28 -1,550 -4,270 349 

Stikine Low -1,577 -4,492 -7,134 140 

Medium -554 -4,466 -9,386 755 343

High -396 -3,503 -13,985 1,177 230

Young Gr -193 -939 -3,763 144 

 

Regulation Class 2 

Reg. Class 2 – 

Positive Values Only 

Admin 

Area 

Volume 

Class 

Normal 

(net$/acre) 

Difficult 

(net$/acre) 

Isolated 

(net$/acre) 

Normal 

(net$/acre) 

Difficult 

(net$/acre) 

Chatham Low -1,657 -3,102 -4,727

Medium -1,865 -5,867 -9,342 505 

High -1,913 -7,153 -13,207 1,302 505

Young Gr -175 -4,642 -6,934 708 

Ketchikan Low -1,388 -4,005 -7,309 171 

 Medium -607 -4,678 -9,437 967 671

 High -675 -3,675 -13,923 1,508 438

 Young Gr -43 -3,133 -8,637 213 

Stikine Low -1,679 -4,078 -6,910 228 

Medium -1,004 -4,539 -9,542 913 24

High -402 -3,739 -13,879 1,095 325

Young Gr -165 -2,518 -8,286 277 

 

Regulation Class 3 

Reg. Class 3 – 

Positive Value Only 

Admin 

Area 

Volume 

Class 

Normal 

(net$/acre) 

Difficult 

(net$/acre) 

Isolated 

(net$/acre) 

Normal 

(net$/acre) 

Difficult 

(net$/acre) 

Chatham Low -949 -1,480 -1,801

Medium -1,080 -2,032 -3,040 115 

High -1,012 -2,596 -4,071 163 

Young Gr -78 -924 -2,414 293 

Ketchikan Low -1,093 -1,607 -2,785 141 

 Medium -858 -1,950 -3,915 306 

 High -1,015 -2,751 -4,771 229 

 Young Gr -49 -548 -3,223 121 

Stikine Low -1,119 -1,423 -2,389 36 

Medium -947 -2,010 -3,099 223 

High -899 -2,204 -4,414 241 

Young Gr -16 -279 -1,731 112 
Appendix B 

Modeling and Analysis B-22 Final EIS

The Regulation Class Process 

To recognize the varying intensities of timber harvests that may occur on the landscape, the regulation 

class concept was developed. Regulation Class is a methodology developed to distill the unique 

combinations of Land Use Designation (LUD), Distance Zone (DZ), Scenic Integrity Objective (SIO), and 

Visual Absorption Capacity (VAC) into four management categories, or Regulation Classes. These 

classes group lands that allow similar allowable harvest unit size, visual disturbance, and re-entry times 

(adjacency). Regulation Classes are numbered 0 to 3, with 0 being ineligible for management. Most of the 

following discussion is focused on Regulation Classes 1-3. 

Land Use Designation (LUD) For each alternative, a unique assignment and map of Land Use 

Designations was developed. Every Land Use Designation, or LUD, delineates a unique set of standards 

and guidelines that apply to that area. For each Alternative, up to 19 LUDs were recognized, but only 

three were allowed to produce timber counted towards Allowable Sale Quantity (ASQ): Scenic Viewshed, 

Modified Landscape, and Timber Production. These three LUDs were evaluated in the Regulation Class 

process. See the supplemental Alternative LUD maps and Chapter 3 of the Forest Plan for more specific 

information on LUDs. 

Distance Zone (DZ) The amount of allowable timber harvesting also is affected by distance zone (DZ). 

Distance zone is the proximity of an area to a view-point. Distance zone varies from Foreground (within a 

0.25 mile), Middle Ground, Background, to Not-Seen, which is completely out-of-view from selected 

viewing points. Again, available treatment intensity is usually greater on lands with more hidden Distance 

Zones. 

Scenic Integrity Objectives (SIO) Scenic Integrity Objectives are a function of LUD and Distance Zone 

and describe the desired quality of the scenery to be maintained in each classification. The categories 

include “High,” “Moderate,” “Low,” and “Very Low” objectives. Further description of SIOs is found in the 

“Scenery” section of Chapter 4 in the Forest Plan. SIOs for each of the LUD/Distance Zone combinations 

are shown in Table B-4. 

Visual Absorption Capability (VAC) The VAC is a measure of an area's ability to "absorb" (make 

visually less noticeable) ground disturbing activities (i.e., timber harvesting). VAC is simplified to three 

categories: Low, Interim, and High. VAC is used to define the intensity of management treatments that 

can be used to maintain each SIO. Generally, areas with greater VAC can sustain a more intensive 

treatment while still maintaining the desired SIO. Table B-5 shows the management unit size allowed for 

each SIO/VAC combination. 

Tongass landscape architects developed some general timber harvesting guidelines, or proxies, for 

various VACs, SIOs, and LUDs. Although the exact harvest intensity an area receives is determined 

during the timber sale layout stages, estimates of allowable disturbance were needed in order to facilitate 

modeling. Each LUD has a series of adopted SIO and VAC objectives. Associated with these objectives 

are the estimated allowable disturbance factors. The proxies for each LUD and SIO/VAC setting were 

grouped by similar harvest method and unit size, cumulative visual disturbance, and height to adjacent 

stand criteria. Grouping the proxies of similar standards resulted in the creation of four distinct 

categories. These groups became the four regulation classes used in Spectrum modeling. These groups 

range from no harvest allowed to large clearcutting with minimal visual concerns. The GIS is then used to 

provide Spectrum with the regulation class allocations by alternative for each Analysis Area. Table B-6 

summarizes the approximate disturbance factors by LUD, Distance Zone, SIO, and VAC. 

Table B-4 

SIO for Distance Zone/LUD from Scenery Standards and Guidelines 

LUD Foreground Middle Ground Background Not Seen 

Scenic Viewshed Retention Partial Retention Partial Retention Max Modification 

Modified Landscape Partial Retention Modification Modification Max Modification 

Timber Production Modification Max Modification Max Modification Max Modification 
Appendix B

Final EIS B-23 Modeling and Analysis

Table B-5 

Maximum Unit Size based on Visual Absorption Capability 

SIO Low VAC Interm. VAC High VAC 

Retention < 2 5-15 15-30 

Partial Retention 5-10 15-40 40-60 

Modification 15-40 40-60 80-100 

Max Modification 50-75 80-100 80-100 

R = Retention, PR = Partial Retention, M = Modification, MM= Maximum Modification 

The percentages in Table B-6 are rough estimates intended to depict the possible level of disturbance 

one may encounter when viewing these areas. For modeling purposes, these visual disturbance zones 

were aggregated into groups with similar standards and economic response (e.g., logging costs). 

Because the percent of visual disturbance includes all visible terrain, tests had to be conducted to 

“recalculate” disturbance thresholds since only suitable lands are being modeled. These tests involved a 

series of iterative mapping exercises where varying levels disturbance factors were applied to the 

separate groups. The feasibility of the harvest level was then compared to the standards and guidelines 

and reviewed by Tongass National Forest landscape architects. This work was conducted under the 

following assumptions: 

1. The items in the database (e.g., distance zone, visual absorption capability) were correct, 

2. The standards and guidelines are modeled to their limits, and 

3. The “viewshed” was a large area (e.g., as viewed from a boat). 

This work indicated a need to further review the scenery components of the database but in general the 

process worked well in terms of modeling the intent of the standards and guidelines. This work resulted 

in three distinct regulation classes that permit timber harvest activities. The final allocation of regulation 

classes to the various disturbance zones is shown in Table B-7. 

Table B-6 

Percent Allowable Visual Disturbance 

Land Use 

Designation 

Distance 

Zone 

SIO Low 

VAC 

Interm 

VAC 

High 

VAC 

Scenic Viewshed Foreground R 8 10 10 

 Mid. Ground PR 8 15 20 

 Background PR 20 20 20 

 Not Seen MM 20 20 20 

Modified Landscape Foreground PR 8 15 20 

Mid. Ground M 15 20 25 

Background M 25 25 25 

Not Seen MM 25 25 25 

Timber Production Foreground M 15 20 25 

 Mid. Ground MM 50 50 50 

 Background MM 50 50 50 

 Not Seen MM 50 50 50 
Appendix B 

Modeling and Analysis B-24 Final EIS

Table B-7 

Regulation Class Allocation 

Land Use 

Designation 

Distance 

Zone 

SIO Low 

VAC 

Intermediate 

VAC 

High 

VAC 

Scenic Viewshed Foreground R 3 3 2 

 Mid. Ground PR 3 3 2 

 Background PR 3 2 1 

 Not Seen MM 1 1 1 

Modified Landscape Foreground PR 3 3 1 

Mid. Ground M 2 2 1 

Background M 2 1 1 

Not Seen MM 1 1 1 

Timber Production Foreground M 2 2 1 

 Mid. Ground MM 2 1 1 

 Background MM 1 1 1 

 Not Seen MM 1 1 1 

R = Retention, PR = Partial Retention, M = Modification, MM= Maximum Modification 

There are two main components of scenery constraints applied to the Regulation Classes in each VCU: 

the total visual disturbance and adjacency considerations. Total visual disturbance is the percent of land 

within a viewshed (VCU) that is classified as disturbed (Table B-8). Adjacency refers to the amount of 

time required before a harvest unit can be placed immediately next to an existing harvest unit (often 

referred to as the “green-up” period). These constraints are shown in Table B-8. 

There are several important things to remember regarding the above table: 

1. Disturbance percent is applied to suitable lands only, not the entire viewshed. 

2. These values are entered into the models as constraints for each VCU. 

3. The disturbance and adjacency factors for Regulation Class 3 are based on the use of small 

patch cutting (less than 2 acres). Optimally, disturbance and adjacency would not be an issue 

with carefully planned uneven-aged management (i.e., partial stand removal). 

Variation by Alternative. Because LUD is one factor in determining Regulation Class, the breakdown of 

each of the seven alternatives into regulation class was recalculated for each alternative. A GIS map of 

Regulation Class was developed and used to intersect with the other layers used in Analysis Area 

development. Regulation Class was then used as an attribute to help define Analysis Areas. 

Table B-8 

Generalized Visual Constraints 

Regulation Class Visual Disturbance Adjacency

Regulation Class Visual Disturbance Adjacency 

1 40% 20 Years 

2 30% 35 Years 

3 20% 50 Years 

Model Implementation Reduction Factors (MIRF) 

To reiterate what was stated in the “Constraints” section (above), the use of MIRF is designed to 

accommodate for unmapped unsuitable lands that cannot be directly eliminated from the suitable land 

base but should be. It is known that when harvest activities occur, a certain percentage of the assumed 

suitable land will be ineligible for management (unsuitable) due to a number of physical, biological, or 

economic considerations. However, reasonable assumptions can be made to estimate the average 
Appendix B

Final EIS B-25 Modeling and Analysis

amounts of these elements on the ground. Their effect on actual suitable land can be incorporated into 

the Spectrum model as constraints. Constraints are applied to each old-growth volume strata of each of 

the six operability harvest systems as well as to young-growth stands. The constraints are implemented 

by forcing the model to never harvest a certain percentage of the acres in the model. The effect is to 

control the maximum amount of acres from the “pre-MIRF” suitable land base that are actually harvested. 

A discussion of these elements and their estimated amounts follows. 

MIRF Elements. Each of the nine MIRF subfactors used in the 1997 FEIS (Riparian Habitat was actually 

divided into two subfactors so there were 10 identified in 1997) was re-evaluated for the 2008 Final EIS. 

These subfactors are listed below and described in the following paragraphs. 

♦ Land Selections – reduction due to the conveyance of selected lands to the State of Alaska and 

Native interests 

♦ TTRA Stream Buffers – reduction due to unmapped Class I and II stream buffers 

♦ Non-Commercial Forest – reduction due to volume class mapping errors 

♦ Slope/Soil Hazard – reduction due to unmapped steep slopes 

♦ Cost Efficiency – excludes stands with the lowest economic potential from the suitable base 

♦ Riparian Habitat (Class III streams) – reduction due to unmapped Class III stream buffers 

♦ Karst/Caves – reduction due to upgrading of the karst classification to high vulnerability on some 

areas 

♦ Deer Habitat – reduction due to implementation of deer habitat standards and guidelines (some 

1997 alternatives included these) 

♦ Remaining Standards and Guidelines – reduction due to unmapped raptor and murrelet nests, 

wolf dens, mountain goat habitat, and habitat linkages 

Land Selections. This subfactor estimates the reduction in the suitable land base as a result of 

conveyance of land to the State of Alaska and Native interests. In 1997, it was assumed that past land 

selections were representative of future land selections. It was also recognized that the subfactor may be 

overestimating the suitable lands lost because Native Corporations may select townsites near shore and 

within the 1,000-foot beach fringe. 

In 1997, this subfactor was estimated by determining (with GIS) that there was 638,737 acres of 

encumbered lands and that 186,980 acres remained to be conveyed. This indicated that 29% of the 

encumbered lands would be transferred out of Forest Service ownership. Then, the amount of 

encumbered suitable lands was estimated and 29% was applied to those lands, producing the estimated 

suitable lands likely to be conveyed. This acreage was divided by the total suitable lands to estimate 

MIRF for this subfactor, which was rounded to be 2%. 

In 2006, the following estimates are made using GIS and other knowledge of lands remaining to be 

conveyed (see the planning record for calculations): 

♦ Total encumbered lands = 260,487 acres (not including encumbered lands in Misty Fiords) 

♦ Current suitable (Alt 5) encumbered lands = 33,589 acres 

♦ Remaining lands to be conveyed (40,000 State and 65,000 Native interests) = 105,000 acres 

♦ Percent of encumbered to be conveyed (105,000/260,487) = 40% 

♦ 40% of current suitable encumbered lands = 13,436 acres 

♦ Total current suitable = 1,044,587 acres 

♦ MIRF subfactor (13,436/1,044,587) = 1% 

Therefore, 1% was used for this MIRF subfactor. This percent was applied to all alternatives. 

Tongass Timber Reform Act (TTRA) Stream Buffers. This subfactor estimates the reduction in the 

suitable land base due to unmapped Class I and II stream buffers. In 1997, it was assumed that the loss 
Appendix B 

Modeling and Analysis B-26 Final EIS

of suitable timber was proportional to its occurrence and that streams were randomly distributed across 

the landscape. 

In 1997, this subfactor was estimated using the Forest Service response to the Irland Group report, 

Chatham data, Central Prince of Wales Island data, and Stikine field reviews. The following TTRA buffer 

MIRF estimates were made based on each of these studies: 

♦ Irland Study (1992) – 2.50% 

♦ Chatham (1995) – 3.91% 

♦ Central Prince of Wales Island (1995) – 3.62% 

♦ Stikine Field Visit – 2.32% 

Based on these estimates, the 1997 MIRF for this subfactor was 2.5%. 

For 2006 it was assumed that this percentage is reduced to 2%. This is because of the significant 

amount of field survey work and the amount of updating of the streams GIS layer that has occurred in the 

10 to 15 years since these studies were done. 

Non-Commercial Forest. This subfactor estimates the reduction in the suitable land base due to volume 

class mapping errors. In 1997, it was assumed that reduction in suitable land due to mis-mapping was 

the same for all three Administration Areas. 

In 1997, a statistician at the Pacific Northwest Research Station used the Forest Inventory plot data 

(1970s) and the revised TIMTYPE volume strata to identify plots designated as high/medium/low volume 

that actually had less than 8,000 board feet of volume per acre. The 8,000 board feet per acre figure was 

used as the definition of productive old growth, or POG. This analysis indicated that 2% of the medium 

volume strata plots and 18% of the low volume strata plots were stocked at less than 8,000 board feet per 

acre. The reduction for the medium plots was not used because it was judged too small and would 

overlap with other reduction factors, so 18% MIRF was used for this subfactor only for the low volume 

strata. 

In 2006, 10% MIRF was used for low volume strata for this subfactor. Recent consultation with the Pacific 

Northwest Research Station statistician concluded that the 18% figure the low volume strata is still 

reasonable, even with the new inventory data. However, it was decided that there should be recognition 

of “fall-up” or the determination that areas of Unproductive Forest are misclassified and should actually be 

POG. It was estimated, based on detailed experience with the inventory data, that 5 to 10% of the 

Unproductive Forest is POG (> 8,000 board feet/acre). So the following steps were followed: 

♦ The Tongass has 4.22 million acres of Unproductive Forest, 4.95 million acres of POG, and 0.98 

million acres of low volume strata POG. 

♦ If 5% of the Unproductive Forest is low volume strata POG, then there are 0.21 million additional 

acres of low volume strata POG. 

♦ 0.21 million acres represents a 21% increase in the amount of low volume strata. 

♦ If the Forested Muskeg type of Unproductive Forest is not included in Unproductive Forest, then 

there are 3.15 million acres and 5% of 3.15 million acres is 0.16 million acres. Assuming only half 

of these acres are actually identified and incorporated into units, this results in 0.08 million acres 

represents an 8% increase in the amount of low volume strata. 

Therefore, being conservative and using only half of the 5% of the “other” Unproductive Forest as “fallup,” in 2006 an 8% “fall-up” and an 18% fall-down were assumed. Therefore, the MIRF for this subfactor 

is the net difference, which produces a 10% reduction in low volume strata. 

Slope/Soil Hazard. This subfactor estimates the reduction in the suitable land base due to unmapped 

steep slopes. It represents the additional acreage of steep slopes identified during project 

implementation that is not already mapped, divided by the mapped suitable acres. 

In 1997, this subfactor was based on a draft Baranof MIRF analysis (1996), the Forest Service response 

to the Irland Group report (1995), Chatham data, Central Prince of Wales Island data, and the Ketchikan 
Appendix B

Final EIS B-27 Modeling and Analysis

cumulative effects contract study (on suitable and fall-down by project area). Based on these sources, 

the 1997 MIRF for this subfactor was defined as 32% for Chatham and 3.1% for the Stikine and 

Ketchikan Areas. 

For 2006, the slope data that was developed to produce the suitability layer for the new Tongass LSTA 

was reviewed. This new layer (which removes slopes >72% and includes more detailed information, 

including LIDAR) already removes many of the steep slopes that were not accounted for in 1997. A GIS 

query examined the acres in steep slopes that are not in MMI4. This amounted to 6% of the suitable in 

the Chatham Area and 3% of the suitable in the Ketchikan and Stikine. In addition, there are two other 

factors that affect the MIRF for this subfactor: First, there is a certain amount of “fall-up” for areas 

mapped as MMI4 and areas mapped as >72% slope. These positive factors were not considered in the 

1997 MIRF. Second, there is a large amount of area removed due to being mapped as Site Index = 1 

and it appears that more areas are added back in (due to “fall-up”) than are taken out due to site index. 

Therefore, for 2006, the Chatham MIRF was reduced for this subfactor to 26% and the Ketchikan and 

Stikine MIRFs to 1%. 

Cost Efficiency. This subfactor excludes the stands with the lowest economic potential from the suitable 

land base. In 1997, 36 CFR 219.14[c][3] was applied and it was assumed that future economic potential 

could be estimated using past harvest experience. 

In 1997, the subfactor was estimated using the best professional judgment of Bill Wilson and Don 

Golnick. They assumed that no harvest would be conducted in low volume strata if it was in the Difficult 

or Isolated Operability Class. In addition, they assumed the same for medium volume strata in the 

Isolated Operability Class. Therefore, lands with these characteristics had a 100% MIRF subfactor. 

In 2006, it was decided that economics should be factored in differently because the Spectrum modeling 

extends over a 150-year period. It was decided to make the MIRF for this subfactor equal to 25% for 

Difficult/Low Volume and Isolated/Medium Volume and 50% for Isolated/Low Volume. These subfactors 

are additive with the other subfactors; therefore, the combined MIRF for these low economic categories 

ranges from 44 to 79% in Ketchikan, 38 to 73% in the Stikine, and 64 to 99% in the Chatham Area (see 

attached Excel file). 

It should be noted that by design the Spectrum model will tend to harvest the most economically 

challenging areas only as a means to achieve a desired condition. Even without these subfactors the 

model is unlikely to schedule these lands for harvest. 

Riparian Habitat (Class III Streams). This subfactor estimates the reduction in the suitable land base 

due to unmapped Class III stream buffers. In 1997, it was assumed that 50% of the Class III streams 

would need to be buffered and that 50% of the Class III streams were unmapped. 

In 1997, the subfactor was estimated to be 14% based on estimating 50% of unmapped Class III stream 

acreage and then relating it to the suitable. It appears that the amount of suitable used in the calculation 

was incorrect, making the percentage higher than it should have been. 

In 2006, it was decided to be more conservative (although a lower MIRF was estimated). The MIRF for 

this subfactor was calculated as follows: 

♦ GIS analysis showed 7,557 miles of Class III streams in the development LUDs of the No-Action 

alternative. 

♦ Since 29% of these development LUDs is suitable forest land, it was estimated that there are 

2,191 miles of Class III streams on suitable forest land. 

♦ Assuming all are buffered and the buffers are 100 feet on each side, these stream miles would 

produce 53,114 acres of buffers. 

♦ Assuming an equal amount will be established in the future: 53,114 divided by 1,044,588 gives a 

MIRF of 7.6%. 

♦ To be conservative, we rounded this MIRF to 8%. 
Appendix B 

Modeling and Analysis B-28 Final EIS

Karst/Caves. This subfactor estimates the reduction in the suitable land base due to a change in karst 

classification from low – moderate to high vulnerability. In 1997, it was assumed (based on the 

professional judgement of J. Baichtal (1996) and others) that 30% of low-moderate lands in Ketchikan 

should be high vulnerability; similarly, the percentages for the Stikine and Chatham are 10% and 20%. 

In 1997, the subfactor was estimated based on professional judgement and GIS queries. For Alternative 

11, the MIRF values for this subfactor were: 0.5% for the Chatham Area, 0.3% for the Stikine Area, and 

5.9% for the Ketchikan Area. 

In 2006, GIS queries were made again, using the new karst rock layer (tkarst06). The MIRF for this 

subfactor were calculated as follows: 

♦ It was determined there are 100,743 acres of karst rock on suitable lands on the Forest. 

♦ GIS analysis showed these were apportioned among the Administrative Areas as follows: 18.5% 

(18,637 acres) to the Chatham; 5.2% (5,239 acres) to the Stikine; and 76.3% (76,867 acres) to 

Ketchikan. 

♦ Applying the 30%, 10%, and 20% factors defined in 1997 for the Administrative Areas produces 

the following: 3,727 acres of low-moderate should be high vulnerability for the Chatham, 524 

acres for the Stikine, and 23,060 acres for the Ketchikan Areas. 

♦ Dividing these by the amount of suitable for these areas (277,016, 354,362, and 413,210, 

respectively) produces the final MIRFs for this subfactor: 

− Chatham = 1.3%; rounded to 1% 

− Stikine = 0.1%; rounded to 0% 

− Ketchikan = 5.6%; rounded to 6% 

Deer Habitat. This subfactor estimates the reduction in the suitable land base due to implementation of 

the deer standards and guidelines. In 1997, these applied to the high and medium volume strata for 

Alternatives 3, 4, 5, and 6 of the 1997 Final EIS. 

In 2006, this subfactor is not used, because none of the 2006 alternatives include these deer habitat 

standards and guidelines. 

Remaining Standards and Guidelines. This subfactor estimates the reduction in the suitable land base 

due to unmapped eagle/osprey nests, goshawk nests, murrelet nests, wolf dens, goat habitat, and 600-

foot habitat linkages. In 1997, this subfactor was estimated at 1% based on the best professional 

judgement of Bill Wilson and Don Golnick. 

In 2006, it was decided to maintain the MIRF of 1% for this subfactor. 

Overall Results. The sum of these subfactors produces the overall MIRF for each category 

(Administrative Area, volume strata, operability class, alternative). To date, we have identified one MIRF 

for all alternatives. Specific calculated MIRF values are in the planning record. The range of MIRFs 

(varying with operability class) for the different volume strata and Administrative Areas are as follows: 

Low Volume Medium Volume High Volume 

Chatham 49% – 99% 39% – 64% 39% 

Stikine 23% – 73% 13% – 38% 13% 

Ketchikan 29% – 79% 19% – 44% 19% 
Appendix B

Final EIS B-29 Modeling and Analysis

Estimation of Past and Future Harvest and Road 

Construction for Effects Analysis 

The quantification of the direct, indirect, and cumulative effects of the alternatives on fish, wildlife, plants, 

and other resources was based heavily on the estimation of past and future harvest of old growth and 

young growth and the amount of road construction. These tasks were conducted for both National Forest 

System (NFS) and non-NFS lands. This section describes the process followed and the major 

assumptions. 

Estimation of Past and Future Harvest 

The estimation of the direct, indirect, and cumulative effects of the alternatives on POG habitats and the 

fish, wildlife, and plants that use these habitats required three major steps. First, it was necessary to 

assemble the inventory of existing vegetation on both NFS and non-NFS lands. The second step was the 

estimation of the original POG on NFS and non-NFS lands and the classification of this original POG into 

POG types for the purpose of evaluating the level of disproportionate past harvest. The third step was 

the estimation of future harvest and the amount of POG in various POG categories that would be 

remaining after future harvest on NFS lands under each alternative, and for all lands combined, including 

factors for harvest of future harvest on non-NFS lands. 

Vegetation Inventory 

For NFS lands, the existing vegetation information from the Tongass Geographic Information System 

(GIS) library was used. Specifically, the recently developed Size Density Model (SDM) (see Affected 

Environment in the Biodiversity section) was used for the classification of existing vegetation on the 

Tongass. Using this model, POG is defined by seven old-growth types: SD67, SD5N, SD5S, SD5H, 

SD4N, SD4S, and SD4H. Young growth is defined by six types, depending on the approximate age and 

origin of the stand; natural young growth (e.g., young growth originating from blowdown) is divided into 

three types (S1, S2, and S3) and young growth that originated from timber harvest is classified into three 

types (HS1, HS2, and HS3). 

For non-NFS lands, a number of sources of information were used to produce the most updated and 

accurate mapping available for non-NFS lands in Southeast Alaska. These sources included: 

• Sealaska Regional Corporation provided recently updated GIS layers for vegetation and harvest 

on their lands throughout Southeast Alaska; these layers were used for mapping all Sealaska 

lands. 

• The State of Alaska provided GIS layers for harvesting on state lands in Southeast Alaska. 

These layers were used for most state lands. 

• Audubon Alaska and The Nature Conservancy recently completed a conservation assessment for 

Southeast Alaska (Albert and Schoen 2007) that included the development of a reasonably 

accurate vegetation map of the entire region based on Tongass GIS vegetation data (SDM 

mapping), augmented with timber inventory data from Haines State Forest and with classified 

Landsat Multi-spectral Scanner (MSS) imagery from the Interim Landcover Mapping Program of 

the U.S. Geological Survey, and 1997 aerial photography. This mapping was used for most of 

the remainder of Southeast Alaska. 

• Forest Service orthophotography and aerial photography was interpreted in some areas to fill in 

gaps in the above layers. 

Based on all of the above information, a Catalogue of Past Harvest for all of Southeast Alaska was 

developed that itemizes the acres harvested for each land ownership category, landowner, and 

biogeographic province, and breaks this harvest down by approximate decade, where the decade of 

harvest is known or can be reasonably estimated. In addition to the spatial information described above, 
Appendix B 

Modeling and Analysis B-30 Final EIS

statistics on the implementation of the Alaska Forest Resources and Practices Act and information on 

State timber sales in Southeast Alaska were collected from the Alaska Department of Natural Resources, 

Division of Forestry. This information is presented in Appendix E. 

Original POG by Category 

Next, the original POG was estimated on NFS and non-NFS lands in each biogeographic province and 

ecological subsection by category. This was done for the purpose of evaluating the level of 

disproportionate past harvest. 

Original POG is defined in this EIS as the POG that existed, outside of the developed areas associated 

with towns, prior to all mapped timber harvest. Therefore, all young growth originating from timber 

harvest (mapped as HS1, HS2, and HS3 on NFS lands) was assumed to be original POG. Natural young 

growth (mapped as S1, S2, and S3 on NFS lands) was assumed to be in a steady state of succession 

and replacement; therefore, it was not assumed to be original POG. On the Tongass, about 300 acres of 

young growth were mapped as having been harvested in the 1700s and 1800s and about 16,000 acres 

are from the first half of the 1900s. The vast majority (about 438,000 acres on the Tongass) of the 

harvest occurred since 1950. 

In addition to total POG (represented by the seven SDM types), two other categories of POG were used 

to represent the larger tree types: high-volume POG, which includes the three types with the largest trees 

(SD5S, SD5N, SD67), and large-tree POG, which is defined as SD67 by itself. To estimate original high 

volume- and large-tree POG, an estimate was first made of the percentage of past harvest in these 

categories using timber type mapping from the mid-1980s. The archived tim86 GIS layer from the 

Tongass GIS library was used and lands that had been harvested since this mapping was done were 

examined. For NFS lands, these areas were divided into older harvests done prior to the TTRA and 

harvests after the Act was implemented. 

The following compositions of harvest were determined for NFS and non-NFS lands: 

• For NFS lands, prior harvest was estimated to have been 29 percent large-tree POG and 64 

percent high-volume POG. 

• For non-NFS lands, prior harvest was estimated to have been 37 percent large-tree POG and 62 

percent high-volume POG. 

Future Harvest 

Future harvest on NFS lands was estimated based on the acreage of POG scheduled for harvest by the 

Spectrum model under each alternative assuming the maximum harvest allowed by the ASQ is harvested 

each decade. The estimate assumes all scheduled suitable POG is harvested (calculated by subtracting 

alternative-specific reduction factors for MIRF and scheduling from the mapped suitable acreage under 

each alternative [see the Timber section]). Factors are applied separately to each biogeographic 

province and ecological subsection to develop province- and subsection-specific acreages. 

The estimation of future harvest on non-NFS lands was made by examining the amount of POG 

remaining on these lands and making reasonable assumptions regarding the percentage of that POG that 

would be harvested in the future. Estimates were conservatively high, in general. 

Estimation of Past and Future Road Construction 

The estimation of the direct, indirect, and cumulative effects of the alternatives associated with road 

construction required two major steps. First, it was necessary to assemble the inventory of existing roads 

on both NFS and non-NFS lands. The second step was the estimation of future road development for 

NFS lands under each alternative, and for all lands combined, including factors for future road 

development on non-NFS lands. 
Appendix B

Final EIS B-31 Modeling and Analysis

Road Inventory 

For NFS lands, the existing road information from the Tongass GIS library was used. The infra roads 

layer was used for the inventory of system roads and the definition of maintenance levels to determine 

whether they were open or closed. The allroads layer was used to estimate additional unauthorized 

roads. For non-NFS lands, existing roads were inventoried using the following sources: 

♦ Tongass GIS library layers contain many roads on non-NFS lands. 

♦ Sealaska Regional Native Corporation provided mapping of roads on Sealaska lands. 

♦ The State of Alaska provided GIS layers for roads on many non-NFS lands in Southeast Alaska. 

♦ Other available GIS layers (e.g., ESRI’s StreetMap) was used for urban and rural areas around 

towns and settlements. 

♦ The sources above were supplemented by orthophoto and aerial photograph interpretation to “fill 

in holes.” 

Future Road Construction 

Future road construction on NFS lands was estimated based on the recently completed logging system 

and transportation analysis (LSTA) for the Tongass. In areas that the LSTA did not cover, future roads 

were extrapolated based on the road miles per harvest acreage in the portions of each Value Comparison 

Unit (VCU) or Wildlife Analysis Area (WAA) that were covered by the LSTA. Projections were made for 

each VCU and WAA and under each alternative, so that road densities could be calculated for each of 

these land divisions. 

On non-NFS lands, future increases in road density were projected after examining existing road 

densities and making reasonable assumptions regarding the additional road density that would be 

developed in the future. Estimates were conservatively high, in general. All non-NFS roads were 

assumed to be open roads. 

Deer Model Assumptions and Application 

The TLMP or DeGayner Deer Model was used in the EIS to (1) evaluate reductions in winter habitat 

capability under each alternative, as indicated by changes in the DeGayner Deer Model habitat suitability 

index (HSI) scores, (2) estimate the percentage of high value deer winter range that could be harvested 

under each alternative, and 3) estimate the number of WAAs across the Tongass that exceed the 18 deer 

per square mile index in the wolf standards and guidelines. Changes in winter habitat capability and 

harvest of high-value winter range were based on projected 1954 (point at which large-scale timber 

harvest began) conditions, to be consistent with past analyses done at the Forest planning level. 

Analyses were run at the WAA level, as this is the land division used by the ADF&G for deer inventories 

and planning. A cross-walk was developed to reclassify the new Forest-wide vegetation model (the SDM) 

into the deer model vegetation categories (high, medium, low volume old-growth). High-volume stands 

included SDM vegetation categories SD5N, SD5S, and SD67; medium volume stands include SD4N, 

SD4S, and SD5H; and low volume stands include SD4H. HSI scores from this model range from 0 to 1.3 

but were standardized to range from 0 to 1.0 by dividing all values by 1.3, because outputs from such 

models represent a range from 0 to 100 percent habitat suitability, with higher values indicating higher 

habitat capability. Greater details are documented in the project planning record. 

To estimate 1954 habitat suitability, it was necessary to “grow back” the vegetation in previously 

harvested units. Previously harvested units were assumed to have been stands of POG. The variable for 

volume class (VolClass) in the Existing Veg layer, which exists for most stands that have recently been 

harvested, was used as an indicator of their 1954 VolStratum categories. Stands with an Existing Veg 

VolClass of 4 or 5 were assumed to have been medium volume POG in 1954, following the assumption 

that few low VolStrata stands were harvested; stands with a VolClass of Null, 3, 6, or 7 were assumed to 

have been high VolStratum POG. VolStratum 6 and 7 were obviously in high VolStratum and it was 

assumed that the remainder of the stands that were harvested many years ago were in the high 

VolStratum also. All stands with a date of origin prior to 1954 were not modified. 
Appendix B 

Modeling and Analysis B-32 Final EIS

Future habitat suitability was based on maximum timber harvest after full implementation of the Forest 

Plan under each alternative. It was assumed that 25 percent of the harvestable acreage would be in the 

stand initiation stage (I) and 75 percent of harvestable acreage would be in the stem exclusion stage (E) 

of stand development after full implementation. In addition, the MIRF, or the percent of the mapped 

suitable acres not actually harvested due to factors identified during implementation (e.g., karst, unstable 

slopes and other issues that preclude harvest during timber sale layout), and a scheduling factor was 

taken into account as they are for the timber volume estimation, the Spectrum ASQ modeling, and other 

future harvest and road construction estimation. 

Accordingly, future WAA-level HSI scores were based on a weighted average of three scenarios, or 

model runs, which assumes that all harvestable lands are harvested. This approach produces an 

unbiased estimate of future HSI scores under the assumption that 25% of all suitable forest land is in the I 

stage, 75% is in the E stage, the remaining harvested young growth (unsuitable) is in the E stage, and all 

old growth and natural young growth remains the same. No-Harvest Scenario weights account for the 

area represented by MIRF and scheduling and which is not harvested. 

To estimate the percentage of 1954 winter range habitat capability that currently remains, and would 

remain under each alternative after full implementation of the Forest Plan, the1954 HSI score was divided 

by the current and future HSI score for each WAA, respectively. This illustrates the cumulative effect of 

timber harvest on estimated deer habitat capability, from the beginning of large-scale timber harvest on 

NFS lands in 1954 to the present and to the year 2105. 

To take into account effects on deer across the Tongass inhabiting areas that vary naturally in their 

habitat quality, high quality habitat was defined as the quartile of the current land base with the highest 

HSI scores within each WAA. This was defined by using the following process: 

♦ Sorting HSI scores within each WAA from highest to lowest by polygon; 

♦ Filtering out all polygons with HSI scores = 0 (this area was not included when identifying the 

area percentages); 

♦ Identifying the polygons that are in the highest 25% based on the WAA acreage, by accumulating 

the acreages starting with the polygons with the highest HSI scores and working down until 25% 

of the area was included; and 

♦ Determining the percentage of these acres (which represent the highest quality deer winter range 

within each WAA) that are harvested under each alternative. 

Deer per square mile were calculated to develop an index of the effects of the alternatives on the wolf 

standard and guideline that deals with deer habitat capability. For this analysis, habitat capability in terms 

of deer density was calculated by assuming a density of 100 deer per square mile for an HSI of 1.0. 

Only WAAs where wolves potentially occur (GMUs 1, 2, 3, and 5) were included and WAAs with naturally 

very low deer densities (WAAs 4302-4607) were excluded from the analysis. 
APPENDIX C 

POTENTIAL LAND ADJUSTMENTS CHAPTER 1 PURPOSE AND NEED
Appendix C 

Final EIS C-i Potential Land Adjustments

Appendix C 

Potential Land Adjustments 

CONTENTS 

Introduction ............................................................................................................................................... C-1

Legislated Alaska Conveyances............................................................................................................... C-1

Potential Future Conveyances.................................................................................................................. C-2

Southeast Alaska Native Land Entitlement Finalization Act........................................................... C-2

Proposal and Current Status .................................................................................................. C-2

Forest Management Implications ........................................................................................... C-3

University of Alaska Lands ............................................................................................................. C-4

Proposal and Current Status .................................................................................................. C-4

Forest Management Implications ........................................................................................... C-4

Unrecognized Southeast Alaska Native Communities................................................................... C-5

Proposal and Current Status .................................................................................................. C-5

Forest Management Implications ........................................................................................... C-5

Alaska Native Veterans .................................................................................................................. C-6

Proposal and Current Status .................................................................................................. C-6

Forest Management Implications ........................................................................................... C-6

Alaska State Forest ........................................................................................................................ C-7

Proposal and Current Status .................................................................................................. C-7

Forest Management Implications ........................................................................................... C-7

Potential Land Exchanges ........................................................................................................................ C-8

Shee Atika Cube Cove Proposed Land Exchange ........................................................................ C-8

Proposal and Current Status .................................................................................................. C-8

Forest Management Implications ........................................................................................... C-9

Mental Health Trust Land Exchange .............................................................................................. C-9

Proposal and Current Status .................................................................................................. C-9

Forest Management Implications .........................................................................................C-10

Sealaska Proposed Comprehensive Tongass-wide Land Exchange .......................................... C-10

Proposal and Current Status ................................................................................................ C-11

Forest Management Implications .........................................................................................C-12

Cape Fox Land Entitlement Adjustment....................................................................................... C-12

Proposal and Current Status ................................................................................................ C-13

Forest Management Implications .........................................................................................C-14

Summary Discussion .............................................................................................................................. C-14

LIST OF TABLES 

Table C-1 Summary of Potential Land Adjustments........................................................................... C-15
Appendix C 

Final EIS C-1 Potential Land Adjustments

Appendix C 

Potential Land Adjustments 

Introduction 

This appendix addresses certain types of land ownership adjustments involving Tongass National Forest 

lands that could potentially occur during the period of the Forest Plan Amendment. Adjustment of land 

ownership within the Tongass boundaries can occur through Congressionally-mandated conveyances, 

exchanges, and acquisitions or through Forest Service administrative activities. The latter two types of 

adjustments typically involve small acreages and specific, localized property circumstances, and have 

little impact on management of the Tongass. Land conveyance processes and land exchanges can 

involve larger acreages and can be relatively wide-ranging in geographic scope. Because these types of 

adjustments could have more substantial implications for Forest management, this appendix provides 

more detailed information about specific potential actions that have been proposed by parties other than 

the Forest Service in recent years. The discussion of the possible ramifications of potential conveyances 

or exchanges is an overview and is intended for informational purposes only. It does not represent a 

National Environmental Policy Act (NEPA)-type analysis of the potential environmental impacts of such 

actions. If the Forest Service were to propose such a land adjustment action or accept for review a 

proposal from another entity, the Forest Service would evaluate the proposal under NEPA and standard 

Forest Service processes for land adjustments. 

Legislated Alaska Conveyances 

Land ownership status within the Tongass is complicated by several ongoing Alaska land conveyances 

created under various federal legislation (USDA Forest Service 2003b). The Alaska Native Allotment Act 

of 1906 provided for Native individuals who had occupied lands prior to their designation as National 

Forest to apply for conveyance of up to 160 acres, under conditions prescribed by the Act and federal 

regulations. As of August 2006, approximately 4,500 acres in 44 Native allotments had been conveyed, 

with an additional 3,500 acres pending adjudication by the Bureau of Land Management (BLM). 

The 1958 Alaska Statehood Act authorized the State of Alaska to select 400,000 acres of vacant and 

unappropriated land from within the Tongass and Chugach National Forests in Alaska, to further the 

development and expansion of Alaskan communities. To date, under this provision of the Statehood Act, 

the state has received title to approximately 258,600 acres located in the Tongass National Forest. 

Approximately 37,400 acres remain to be conveyed to the state from the Chugach and Tongass National 

Forests. 

The Alaska Native Claims Settlement Act (ANCSA) established processes for transfer of federal land to 

Alaska Native village corporations and regional corporations, and to Native individuals. ANCSA provided 

for the conveyance of 23,040 acres of surface estate lands (a full township, 36 square miles) to each of 

the 10 Native village corporations and 2 urban corporations located in Southeast Alaska. ANCSA 

provided that the subsurface estate under the village and urban corporation land would be conveyed to 

the Native regional corporation. ANCSA also included other provisions addressing land conveyances to 

Native regional corporations. Under Section 12c of ANCSA, 11 regional corporations were to share in the 

selection of 16 million acres. Section 14(h)(8) set aside a pool of 2 million acres to be transferred to the 

Native regional corporations in the State after certain other conveyances are completed. After the 

specified conveyances have been implemented, the remaining land in the pool will be divided among the 

regional corporations based on population, with approximately 22 percent of the balance going to 

Sealaska Corporation, the regional corporation for Southeast Alaska. Finally, ANCSA provided for 

selection and transfer of up to 160 acres to Native individuals who had occupied that land as a primary 

place of residence on August 31, 1971. 
Appendix C 

Potential Land Adjustments C-2 Final EIS

To date, approximately 571,000 acres within the Tongass have been conveyed under ANCSA. Each of 

the 10 Native village corporations and 2 urban corporations in Southeast Alaska has selected its 

authorized acreage; virtually all of that land has been conveyed, amounting to a total of approximately 

279,000 acres. Approximately 292,000 acres have been conveyed to date to Sealaska Corporation, in 

addition to the subsurface estate under the lands owned by the village and urban corporations. Sealaska 

has selected about 171,000 additional acres. It is expected that approximately 64,000 acres of these 

lands will be conveyed to Sealaska. 

Potential Future Conveyances 

The major Alaska land conveyances described above (those occurring under the Alaska Statehood Act 

and ANCSA) have been authorized by Acts of Congress and implemented through additional legislation 

and regulations. In recent years there have been a number of other formal and informal proposals that, if 

authorized, might result in the transfer of Tongass National Forest System (NFS) lands out of federal 

ownership. Information currently available to the Forest Service about these conveyance proposals is 

provided below. For each proposal, the text includes background information, a description of the 

conveyance proposal, and a discussion of the potential implications for land ownership and management 

of the Tongass. Because the proposed legislation for the respective conveyances does not generally 

specify where land selections would be made, it is not possible at this time to identify the types of 

Tongass lands and resources that would likely be affected by the proposals. Consequently, the 

discussion of forest management implications for the potential conveyances is necessarily quite general. 

Southeast Alaska Native Land Entitlement Finalization Act 

A proposal was identified in the Draft EIS entitled Sealaska Proposed Comprehensive Tongass-wide 

Land Exchange. Since the Draft EIS was published, the potential land exchange has evolved into a 

legislative proposal entitled Southeast Alaska Native Land Entitlement Finalization Act, which was 

subsequently introduced into Congress as H.R. 3560. This bill, as introduced, more closely resembles a 

conveyance rather than a land exchange as earlier described. The text describing the original proposal 

has been maintained under the Potential Land Exchange section of this appendix so readers can 

compare the current proposal to the original proposal identified in the Draft EIS. 

H.R. 3560 is to provide for the completion of certain land selections under ANCSA, and for other reasons. 

H.R. 3560 defines its purpose as the vehicle to redress the inequitable treatment of the regional 

corporation for Southeast Alaska by allowing Sealaska to select its remaining entitlement under section 

14 of the ANCSA (43 U.S.C.1613). These selections are to come from designated Federal land in 

Southeast Alaska, outside the ten Southeast Alaska village withdrawal areas. In general, H.R. 3560 

authorizes Sealaska to select and receive conveyance of its remaining land entitlement from three 

categories including economic development lands; sites with sacred, cultural, traditional, or historic 

significance; and Native enterprise sites. 

Proposal and Current Status 

H.R. 3560 was referred to the House Committee on Natural Resources, U.S. House of Representatives, 

in Washington D.C. on September 18, 2007. A hearing was held by the same Committee on November 

14, 2007. Testimony was presented by officials from the Departments of the Interior and Agriculture for 

the Executive branch, along with representatives of the Sealaska Corporation and Southeast Alaska 

Conservation Council. At this time no additional hearings or committee assignments have been identified 

and it is not clear whether or not this proposal will move further through the legislative process. 

The goal of the H.R. 3560 is to finalize Sealaska’s entitlement equitably; secure ownership of places of 

sacred, cultural, traditional, and historic importance; maintain its existing resource development and 

management operations; and continue economic opportunities for the Native people in Southeast Alaska. 

While not clearly defined in the Act, those lands identified as entitlement are assumed to be similar to 

those described in the Potential Land Exchange section of this appendix. For brevity, this section will not 

repeat the information described in that section. Maps (Sealaska ANSCA Land Entitlement 
Appendix C 

Final EIS C-3 Potential Land Adjustments

Rationalization Pool, dated May 17, 2007) have been made available that define the locations of the 

potential land acquisitions, which further refine what was presented in the Draft EIS. Upon completion of 

the land conveyance from the Tongass to Sealaska, all encumbrances (327,000 acres according to the 

Bill) currently held by the regional corporation would be removed. 

Two new items presented by H.R. 3560, were not addressed in the Draft EIS. These include sites with 

sacred, cultural, traditional, or historic significance (sacred sites) and Native enterprise sites. The sacred 

sites encompass no more than 2,400 acres of known locations (identified on maps entitled “Places of 

Sacred, Cultural, Traditional, and Historic Significance, dated May 17, 2007” and “Traditional and 

Customary Trade and Migration Routes, dated May 17, 2007”). An additional 1,200 acres is set aside 

and may be used by Sealaska to acquire new discoveries. The known sites are depicted across the 

extent of the Tongass National Forest and prohibit commercial timber harvest; shall not be subject to 

additional covenants; and provide for varying uses of the sites by Sealaska. 

Native enterprise sites encompass no more than 5,000 acres and are identified on a map entitled “Native 

Enterprise Sites dated May 17, 2007.” These sites are identified across the extent of the Tongass 

National Forest and prohibit commercial timber harvest; shall not be subject to restrictive covenants; 

provide for access from the site to NFS lands 15 miles away from the exterior boundary of the site; and 

provide for varying uses by Sealaska. 

Forest Management Implications 

The Forest Service conducted preliminary analysis of the economic development lands in the Draft EIS. 

Based on how these lands are described in H.R. 3560, it is likely that the effects of the Act would be 

similar to what is presented for the Sealaska Proposed Comprehensive Tongass-wide Land Exchange in 

the Potential Land Exchange section of this appendix. Rather than repeat that analysis here, readers are 

directed to that text for reference. 

Sites with sacred, cultural, traditional, or historic significance as well as Native enterprise sites could 

potentially affect management of many resources and issues on public lands, including subsistence, 

recreation, wildlife and fish, timber (including second growth), karst, travel management, and heritage 

resources. These potential effects are difficult to determine from the proposed legislation due to the 

vagueness of its language. More information, than what can be derived from the bill and testimony, 

would be necessary in order to adequately address this issue. 

From the review the Forest Service conducted in the Draft EIS only on economic development lands, it 

was determined that implementation of the Sealaska proposal would require a Forest Plan Revision 

based on the magnitude of the changes in land use designations. With the addition of the sacred and 

Native enterprise sites, this determination is still warranted as a result of net losses in the Conservation 

Strategy, the lack of ability in making up key lands associated with the old-growth reserves, effects on the 

Allowable Sale Quantity, and impacts associated with other existing uses. Additionally, the lands to be 

exchanged to the federal government generally do not have existing road systems, and costs for 

developing roads on these lands would likely constrain the ability to supply timber economically. The 

combined impacts on the availability of timber from the Tongass could have a significant adverse effect 

on the supply of timber to mills on Prince of Wales Island and surrounding areas. 

Table C-1 (at the end of this appendix) has been updated to reflect the acreages included in the 

legislative proposal and assumes like acreages for the economic development lands as described in the 

Draft EIS. It indicates the acreage of the NFS lands that could be transferred to Sealaska via the 

entitlement and conveyance components of the proposal, and the acreages of the current Sealaska lands 

that could be conveyed to the U.S. This table displays the acreages of the entire pool of parcels. The 

actual acreage conveyed would likely be less than listed. 

Additionally, the U.S. Fish and Wildlife Service recently published a determination not warranting the 

listing of the Queen Charlotte Goshawk (Accipitier gentilis laingi) in Alaska (Federal Register on 

November 8, 2007). This determination was made, in part, based on the habitat protection measures on 

federal lands. Should the proposed legislation be implemented a high probability exists that this 
Appendix C 

Potential Land Adjustments C-4 Final EIS

determination would be revisited, given the current harvest level that has taken place on Prince of Wales 

Island, where the legislation would give emphasis to lands being acquired by Sealaska. 

University of Alaska Lands 

The following discussion is based on information obtained from the University of Alaska and Senate Bill 

293. 

By separate acts passed in 1915 and 1929, Congress granted approximately 360,000 acres of surveyed 

land to the University of Alaska to be used to generate revenue to support the University’s educational 

mission (University of Alaska 2005). Only about 100,000 acres had been surveyed and conveyed to the 

University by the time of statehood in 1959, and the Statehood Act extinguished the University’s right to 

receive the balance of its federal land grants. At that time the State of Alaska also took on management 

responsibility for the University lands, and allowed several municipalities to select University grant lands 

for their municipal entitlements without compensating the University. Through multiple settlements of 

lawsuits filed by the University, the University subsequently gained title to additional lands and timber 

harvest rights. The University of Alaska now owns and manages approximately 183,000 acres of land, of 

which approximately 170,000 acres are managed for investment purposes. Because the University 

received only a portion of the acreage total granted it by Congress, and that figure was smaller than the 

university land grant for virtually all other states, the University has sought additional grant lands through 

proposed state and federal legislation. 

Proposal and Current Status 

Under the terms of Senate Bill 293, introduced in Congress on February 3, 2005, the University of Alaska 

will be allowed to select up to an additional 250,000 acres of federal land that would be managed to 

provide income for the university system. If enacted, the university would not be allowed to select lands 

within a federal conservation system area (e.g., a national park or a wilderness area) or Tongass NFS 

lands other than those within development Land Use Designations (LUDs), and their selections would be 

limited to areas of second-growth timber where timber harvest occurred after January 1, 1952. Senate

Bill 293 was not passed by Congress. As of September 2007, the bill has not been re-introduced. 

Forest Management Implications 

The proposal to allow conveyance of federal lands to the state to provide income to support the University 

of Alaska exists in concept only at this time. The Forest Service is aware of no maps indicating areas of 

interest for selection for such purpose, or statements from policy makers identifying areas that might be of 

interest. Therefore, it is not possible to determine specifically how enactment of such a conveyance 

process might affect management of the Tongass. 

Based on the purpose of the University of Alaska Lands Bill, however, it is possible to identify the broad 

outlines of possible implications for the Forest. Because the purpose of the program is to generate 

income, lands with relatively high timber production capability and accessibility are a logical focus of land 

selection under such an act. Areas known or suspected to have high mineral resource potential will also 

be of interest. While some areas of the Chugach National Forest and some lands under the jurisdiction of 

the BLM will also be of interest, it is reasonable to assume that a substantial portion of any lands selected 

under such a conveyance program will be located on the Tongass. 

Under the current Forest Plan, there are approximately 3.6 million acres within development LUDs and 

nominally available for selection, based on the language of Senate Bill 293. The Biodiversity section of 

this EIS indicates approximately 453,000 acres of the Tongass are second growth resulting from timber 

harvest (about 234,000 additional acres are in natural young growth). About 240,000 of these acres are 

in the 0-70 year age category and are on lands suitable for timber harvest. Therefore, this latter figure 

represents the lands that could be taken as the approximate area eligible for selection. Therefore, it is 

conceivable that land selection for the University of Alaska could absorb essentially all second-growth 

land in development LUDs on the Tongass. While this is possible, the Forest Service does not consider 

that to be a realistic possibility, given the availability of large areas of federal lands with incomegenerating potential elsewhere in the state. 
Appendix C 

Final EIS C-5 Potential Land Adjustments

If the University of Alaska Lands Bill is enacted, it is evident that any lands within the Tongass selected 

by the University would be productive timber lands currently supporting second-growth timber of varying 

ages. Because little, if any, of that timber is ready for harvest relatively soon, there would likely be 

minimal direct effect on near-term sales and harvest volumes for the Tongass. Nevertheless, removal of 

productive forest land from the development LUD land base would necessarily cause a commensurate 

reduction in the ASQ for the Forest, and therefore indirectly result in reduced harvest volumes from the 

Tongass in the relatively near term. Conversely, it can reasonably be assumed that any Tongass lands 

selected by the University under such a program will be open for timber harvest by the University and will 

provide a supply of wood as soon as that is economically viable. Therefore, over the long term it appears 

likely that the total harvest volume would not be much different with enactment of the University lands 

legislation, although the mix of sources would change somewhat. Timber from University lands would 

presumably be available for export, however, in which case the supply of wood to processors in 

Southeast Alaska could be reduced somewhat. 

Unrecognized Southeast Alaska Native Communities 

Under the Alaska Native Claims Settlement Act (ANCSA), corporations representing Native residents of 

10 Southeast Alaska communities were each allowed to select 23,040 acres of surface estate for 

conveyance from the U.S. to those village corporations. ANCSA also provided the same conveyance 

rights to two Native urban corporations in Southeast Alaska. Native residents of Haines, Ketchikan, 

Petersburg, Tenakee Springs, and Wrangell were not addressed in those ANCSA provisions presumably 

because they did not meet the eligibility requirements. For a number of years there have been legislative 

proposals to extend land conveyance rights to the Native residents of these five communities to place 

them on an equal footing with other Southeast Alaska communities. 

Proposal and Current Status 

The Unrecognized Southeast Alaska Native Communities Recognition and Compensation Act (Senate 

Bill 1746), introduced most recently on June 29, 2007, proposes to allow Alaska Native residents of 

Haines, Ketchikan, Petersburg, Tenakee Springs, and Wrangell to organize as five Urban Corporations 

and to each receive 23,040 acres of surface estate lands and other compensation. Sealaska Corporation 

would receive the subsurface estate to these lands. The language in the bill does not identify the specific 

areas that would be available for selection and conveyance. 

Forest Management Implications 

If enacted, Senate Bill 1746 would presumably result in the transfer of up to 115,200 acres of current NFS 

lands out of federal ownership. Such an action would represent a reduction of approximately 0.7 percent 

in the total Forest land base. Given the limited existing information about how the proposal might be 

implemented, it is difficult to speculate as to which types and acreages of NFS lands would be affected. It 

is also unknown if selections would be allowed within congressionally designated areas such as 

Wilderness and LUD II areas. If it is assumed that selections would occur from available lands in areas 

close to the respective communities, selections under such a program could affect LUDs as follows: 

Haines – Semi-Remote Recreation and Remote Recreation, with some Modified Landscape on either 

side of Lynn Canal 

Ketchikan – Semi-Remote Recreation, Scenic Viewshed and Timber Production 

Petersburg – Modified Landscape, Scenic Viewshed, Timber Production and Old-Growth Habitat 

Tenakee Springs – Modified Landscape and Timber Production 

Wrangell – Modified Landscape, Scenic Viewshed, Timber Production and Old-Growth Habitat 

Based on the distribution of Tongass lands near the subject communities, it appears that Native 

selections under such a program could be concentrated within moderate development and intensive 

development LUDs. Alternatively, newly-formed village corporations might choose to select productive 

timberlands, to maximize the revenue potential from their lands. In either case, it appears likely that a 
Appendix C 

Potential Land Adjustments C-6 Final EIS

large majority of the total selected acreage would occur in development LUDs. Consequently, a 

conveyance program such as outlined in Senate Bill 1746 would likely result in forest management 

implications similar to those discussed above for the proposed University of Alaska conveyances. Based 

on the respective potential acreage figures (up to approximately 250,000 acres vs. about 115,000 acres), 

passage of Senate Bill 1746 or similar legislation could affect approximately half as much land on the 

Tongass as the University land proposal. Adoption of such a proposal would likely result in a minor 

reduction in the land base of suitable timber and a small corresponding decrease in the ASQ. 

Alaska Native Veterans 

The 1906 Native Allotment Act established a conveyance process under which individual Alaska Natives 

could select and receive title to up to a 160-acre parcel of vacant, unappropriated, and unreserved 

nonmineral federal land. Allotments may be made in national forests if founded on occupancy and use of 

the land prior to the establishment of the forest. In 1971, ANCSA repealed the Native Allotment Act and 

extinguished this right for Alaska Natives to claim allotments. The 1998 Alaska Native Veterans 

Allotment Act (Public Law 105-276) amended ANCSA to provide Alaska Native veterans another 

opportunity to apply for a Native allotment of up to 160 acres of land. This act was intended to 

compensate for the fact that Natives serving in Vietnam may not have been able to apply for their 

allotments prior to closure of the allotment program. This situation applies to approximately 2,800 Alaska 

Natives who served in the military during the Vietnam conflict. The 1998 legislation contained several 

provisions regarding federal land status, prior use of the claimed land and eligible military service dates 

that may be viewed by some as barriers to Native veterans obtaining their allotments. 

Proposal and Current Status 

The Alaska Native Veterans Land Allotment Equity Act, introduced most recently on August 2, 2007, as 

House Bill 3350, proposes to redress certain obstacles created by the 1998 Alaska Native Veterans 

Allotment Act. The Bill allows Alaska Natives who served in the military between August 5, 1964 and May 

7, 1975 (the starting and ending dates of the entire Vietnam conflict) to each claim 160 acres of vacant 

federal land. Unlike the 1998 legislation, Alaska Natives filing under this program would not have to 

demonstrate substantially continuous use or occupancy of the subject land for at least five years that is 

potentially exclusive of others. Based on the estimated number of eligible Alaska Natives and the 

allotment size, this legislation could, if passed, result in the conveyance of up to approximately 448,000 

acres of federal land in Alaska. 

As of November 2006, the current Congress had not taken action on Senate Bill 2000 and passage is not 

likely to occur before this Congress adjourns. Future action would require reintroduction of the bill in the 

next Congress, which will convene in 2007. 

Forest Management Implications 

♦ The Forest Service is not aware of any information indicating how much Tongass land might be 

selected for Native allotments if this legislation is passed. It is unknown how many of the 

approximately 2,800 Alaska Native Vietnam veterans addressed by Senate Bill 2000 would 

actually select and claim land for allotments. In addition, many of those veterans no doubt live 

elsewhere in the state and would be inclined to select allotments in regions other than Southeast 

Alaska. Alaska population statistics indicate that Native Alaskans living in Southeast Alaska 

comprise about 12 percent of the total statewide Native population (Alaska Department of Labor 

and Workforce Development 2006). If Alaska Native Vietnam veterans are distributed 

geographically in the same proportion and selected allotment lands within their home region, the 

maximum area of Tongass lands potentially subject to selection under such an allotment program 

would appear to be in the range of 50,000 to 55,000 acres. 

♦ It is not known what type of lands Alaska Native Vietnam veterans would be inclined to select 

under such an allotment program. Because the individual parcels would be small, many 

claimants might be inclined to select parcels that would be desirable for homesites or locations 

for hunting and fishing camps. Alternatively, some might select lands with income potential from 

timber resources. An allotment program such as proposed in House Bill 3350 could have 
Appendix C 

Final EIS C-7 Potential Land Adjustments

implications similar to those described above for the proposed Unrecognized Southeast Alaska 

Native Communities Recognition and Compensation Act, including a reduction in the suitable 

timber land base and ASQ on the Tongass. To the extent such effects would occur, they would 

be considerably less extensive based on the respective acreages involves, and would be minor 

from a Forest-wide perspective. Because an Alaska Native Vietnam veteran allotment program 

could result in a relatively large number of small, scattered private inholdings around the 

Tongass, perhaps a more important forest management effect would be to complicate land 

ownership administration by the Forest Service in areas where allotments were selected. 

Alaska State Forest 

The Alaska Department of Natural Resources, Division of Forestry manages extensive areas of current 

State-owned lands that are forested. Those lands include two designated state forests, the Haines State 

Forest and the Tanana Valley State Forest, which together comprise over 2 million acres and about 2 

percent of all State-owned land (Alaska Department of Natural Resources 2006). The two state forests 

are managed to provide a sustained yield of many resources, primarily timber, while allowing other 

beneficial uses of the public land and resources. The state forests also provide fish and wildlife habitat, 

clean water, opportunities for recreation and tourism, and minerals. The Haines State Forest contains 

approximately 286,000 acres of land north of Haines in Southeast Alaska, generally in the Chilkat River 

watershed and surrounding the Chilkat Bald Eagle Preserve. 

Various State of Alaska officials or interests have at times advocated for the establishment of an 

additional Alaska State Forest, to be managed to provide income for state government programs. A new 

state forest conceivably could be created through state legislation creating a new management unit on 

existing state-owned lands, or through federal legislation establishing a new conveyance process to 

transfer additional federal lands to state ownership for management as a state forest. If such a proposal 

were ever implemented through federal legislation, it would presumably include conveyance of existing 

Tongass and/or Chugach National Forest lands with timber production capability to the State of Alaska. 

Proposal and Current Status 

♦ The Forest Service is aware of no formal, public proposal to create an Alaska State Forest. To 

date, no federal legislation to implement such a proposal has been introduced in Congress, and 

State documents do not indicate the size and location envisioned for a state forest. The Forest 

Service is aware of public discussion of one concept for such a management unit, which involved 

a 2-million-acre area on or near Prince of Wales Island. Creation of a state forest in such a 

location would require transfer of extensive areas of current Tongass NFS lands to the state. 

Because there has been no formal proposal or action on a proposal, establishment of an Alaska 

State Forest in Southeast Alaska should be considered a speculative possibility. 

Forest Management Implications 

With respect to the types of potential changes, the implications for future management of the Tongass 

from establishment of a new, large-scale state forest would be similar to those described for the proposed 

University of Alaska Lands bill, although the affected area would likely be much larger. Consistent with 

Alaska State Senate Bill 149 that was signed into law on August 8, 2003; a new Alaska state forest would 

presumably be managed for timber resources while allowing for other beneficial uses of public land and 

resources. Therefore, future management and human uses of Tongass lands conveyed to the state 

under such a proposal might be managed more intensively for timber production than under current 

management and uses. The state would likely be inclined to select productive timber lands for inclusion 

in a new state forest, and would emphasize timber production as a primary uses of those lands. Based 

on current Alaska state forest management policies, the new state forest lands would also presumably 

continue to support other resource values such as water, fish and wildlife habitat and recreation, but to a 

lesser extent than for timber. To the extent that future state forest management paralleled current 

Tongass management under Forest Service administration, the available multiple resource values from 

those lands could change significantly under such a proposal. The prospects for such a change cannot 

be predicted at this time. 
Appendix C 

Potential Land Adjustments C-8 Final EIS

Potential Land Exchanges 

Administrative land exchanges, in which NFS lands can be conveyed to another entity in exchange for 

lands of equal value, are another form of land ownership adjustment. Complex land exchanges are 

sometimes authorized by Congress through special legislation. The Forest Service has completed 

several land exchanges involving relatively small acreages of Tongass NFS lands. These adjustments 

are summarized in Chapter 3 of the EIS and include exchanges involving the Kake Tribal Corporation, the 

Alaska Pulp Corporation and the Kennecott Greens Creek Mining Company, Inc. 

There have also been discussions regarding potential future land exchanges between the Forest Service 

and a number of Native Corporations and other entities that could influence land ownership on the 

Tongass. As before, for each potential exchange the text includes background information, a description 

of the conveyance proposal, and a discussion of the potential implications for land ownership and 

management of the Tongass. In one case, a land adjustment package proposed by the Sealaska 

Corporation, the Forest Service has received a specific proposal identifying the NFS lands proposed for 

inclusion in the land adjustment. For that case, the level of available information allows a more specific 

discussion of the types of lands that would be affected and how their conveyance or exchange might 

influence forest management. 

Shee Atika Cube Cove Proposed Land Exchange 

Shee Atika, Incorporated, is an Alaska Native Village Corporation established under ANSCA, 

representing the historical Native interests of Sitka, Alaska. Through ANSCA, Shee Atika received 

approximately 23,040 acres in the vicinity of Cube Cove on Admiralty Island. Admiralty Island, for the 

most part, represents the Admiralty National Monument and surrounds Shee Atika in-holdings. Over the 

period of enactment of ANSCA to the mid 1990’s, Shee Atika harvested the vast majority of the oldgrowth forests on these lands and at present has no active management taking place. An extensive road 

system is in place beginning at a log transfer facility in Cube Cove and extending throughout the limits of 

their lands primarily in the lower reaches of the valleys. The conditions of the roads are unknown. 

Proposal and Current Status 

Shee Atika formally approached the Forest Service on September 20, 2007, after the Draft EIS was 

published, proposing a mutual interest agreement to explore the possible exchange of certain NFS lands 

for Shee Atika surface estate located at Cube Cove. In exchange, Shee Atika is interested in acquiring 

lands (both surface and subsurface estate) within the Tongass National Forest located on West and 

North Yakobi Island and on western Chichagof Island. A map depicting the lands they wish to acquire in 

whole or in part was presented as a general description. 

Sealaska, the Alaska Native regional corporation, owns the subsurface estate under the Shee Atika 

inholdings at Cube Cove. Shee Atika has informed Sealaska of its intent to enter into discussions with 

the Forest Service. At this time, Shee Atika and the Forest Service have met once to discuss the land 

exchange concept in general terms only and neither party has made any binding commitments on 

proceeding further. 

Shee Atika’s goal for the proposal is to maintain a viable resource and land base for its shareholders. 

Lands Shee Atika has identified an interest in acquiring are in the Semi-Remote Recreation LUD with a 

small portion of congressionally designated LUD II within the boundaries. 

Table C-1 (at the end of this appendix) has been updated to reflect the acreages included in the proposed 

land exchange. It indicates the acreage of the NFS lands that could be transferred to Shee Atika via the 

land exchange components of the proposal, and the acreages of the current Shee Atika lands that could 

be conveyed to the U.S. This table displays the acreages of the entire pool of parcels. The actual 

acreage exchanged would likely vary depending on the final lands pool identified, values determined 

through appraisal, and site-pecific issues raised by the public. 
Appendix C 

Final EIS C-9 Potential Land Adjustments

Forest Management Implications 

The Forest Service has conducted a cursory evaluation of how the Shee Atika proposal, if implemented 

as presented, would affect the Tongass Land Management Plan. The evaluation was based on the 

assumed existing character and resource condition of the respective lands that would be conveyed from 

Shee Atika to the U.S. and vice versa. It focused on the potential effects on the ability to implement the 

Old-Growth Conservation Strategy and on necessary changes to the Allowable Sale Quantity for the 

Tongass. The evaluation also considered subsequent effects on sawmills, karst and cave resources, 

heritage resources, subsistence hunting and fishing, and public access. 

From the limited review, the preliminary determination by the Forest Service is that implementation of the 

proposal would not require a revision but may require an amendment to the Forest Plan, based on the 

magnitude of the changes in land base designations. The evaluation assumed that, if all lands in the 

proposal were transferred, there would be no significant loss of old-growth reserves, no effect on 

sawmills, no effect on known karst and cave resources, potential effect on heritage resources, no 

significant effect on subsistence hunting and fishing, and limited effect on public access. This analysis is 

premised on the limited knowledge given the nature of the proposal and the limited understanding by the 

Forest Service of what Shee Atika interests are in the lands acquired. 

Mental Health Trust Land Exchange 

The Trust Land Office (State of Alaska, Department of Natural Resources) manages about one million 

acres for the Alaska Mental Health Trust land on behalf of the Alaska Mental Health Trust Authority. 

Resource categories managed by the Trust Land Office include coal, gas, materials, minerals, oil, real 

estate and timber. The Trust Land Office generates revenues from the Trust land through a variety of 

methods including sales, long-term leases and short-term land use licenses. Revenues generated from 

Trust land management are used by the Trust Authority to improve the lives and circumstances of Trust 

beneficiaries throughout the State of Alaska. 

Proposal and Current Status 

The Trust Land Office (State of Alaska, Department of Natural Resources) representing the Mental 

Health Trust Authority, presented a conceptual proposal to the Forest Service on November 20, 2007, 

after the Draft EIS was published. This proposal offers to exchange approximately 20,000 acres of lands 

managed by the Trust Land Office in Southeast Alaska for an equal value of Tongass National Forest 

lands on Prince of Wales Island. The parcels the Trust has offered for exchange are adjacent to or in the 

immediate vicinities of Skagway, Juneau, Petersburg, Wrangell, Sitka, and Ketchikan. The lands being 

offered for exchange for the most part are adjacent to NFS lands and, in many cases, form the 

backdrops, in whole or in part, to the communities identified. Maps depicting these parcels have been 

provided to the Forest Service for further review and consideration. The lands the Trust has interest in 

acquiring from the Forest Service are located on Prince of Wales Island and have generally been 

identified as lands containing the majority of their timber base in young-growth stands. These lands are 

identified in concept on a map showing areas around Coffman Cove, Staney Creek, Thorne Bay North, 

Kasaan, Hollis, Twelve Mile Arm, and Polk Inlet. 

The Trust has identified two interests as the primary uses of the lands considered for acquisition. These 

interests include sustained harvest of young-growth timber stands and small parcel developments. The 

Trust has identified an interest in discussing the possibilities of making all or a portion of the timber 

volume harvested available to Southeast Alaska processors; allowing access to continue subsistence 

harvesting by rural residents; and either maintaining or avoiding the Conservation Strategy which the 

Tongass Forest Plan uses as a foundation for wildlife habitat management. 

This proposal, while new, was presented to the Tongass Futures Roundtable for information on 

December 3, 2007. The Forest Service at this point is considering the concepts of the proposal and has 

made no agreements on whether or not it will pursue this exchange further. 
Appendix C 

Potential Land Adjustments C-10 Final EIS

Forest Management Implications 

Given that only preliminary discussions of the proposal have taken place and specific details of the 

exchange are not available, only general considerations can be made regarding effects. The Forest 

Service has conducted a cursory evaluation of how the Trust proposal, if implemented as presented, 

would affect the Tongass Land Management Plan. The evaluation was based on the assumed existing 

character and resource condition of the respective lands that would be conveyed from the Trust to the 

U.S. and vice versa. It focused on the potential impacts on the ability to implement the Old-Growth 

Conservation Strategy and on necessary changes to the Allowable Sale Quantity for the Tongass. The 

evaluation also considered subsequent effects on sawmills, karst and cave resources, heritage 

resources, subsistence hunting and fishing, and public access. 

From the limited review, the Forest Service preliminary determination is that implementation of the 

proposal would not require a revision but may require an amendment to the Forest Plan, based on the 

magnitude of the changes in land base designations. The evaluation indicated that, if all lands in the 

proposal were transferred, there may not be a significant loss of old-growth reserves; there may not be an 

effect on sawmills; a potential exists to affect karst and cave resources; a potential effect could occur to 

heritage resources; there may be an effect on subsistence hunting and fishing; and there is potential for a 

limited effect on public access. This evaluation is premised on the limited knowledge given the nature of 

the proposal and the limited understanding by the Forest Service of what the Trust’s interests are in the 

lands acquired. 

Table C-1 (at the end of this appendix) has been updated to reflect the acreages included in the proposed 

land exchange. It indicates the acreage of the NFS lands that could be transferred to the Trust via the 

land exchange components of the proposal, and the acreages of the current Trust lands offered for 

consideration that could be conveyed to the U.S. This table displays the acreages of the entire pool of 

parcels. The actual acreage exchanged would likely vary depending on final lands identified, values 

determined through appraisal, and site-specific issues raised by the public. 

Sealaska Proposed Comprehensive Tongass-wide Land Exchange 

The potential exchange that has received the most attention and discussion is known as the Sealaska 

Proposed Comprehensive Tongass-wide Land Exchange (USDA Forest Service 2005b). This land 

adjustment package was proposed by the Sealaska Corporation, the Native regional corporation for 

Southeast Alaska. The package includes two components; one involves an exchange of existing lands 

owned by Sealaska for existing NFS lands, and the other involves adjustments to Sealaska’s land 

conveyance rights under ANCSA. 

ANCSA established processes for transfer of federal land to Alaska Native village corporations and 

regional corporations, and to Native individuals. ANCSA included two separate provisions addressing 

land conveyances to Native regional corporations. Under Section 12(c) of ANCSA, 11 regional 

corporations were to share in the selection of 16 million acres. Section 14(h)(8) set aside a pool of 2 

million acres to be transferred to the Native regional corporations in the State after certain other 

conveyances are completed. After the specified conveyances have been implemented, the remaining 

land in the pool will be divided among the regional corporations based on population, with approximately 

22 percent of the balance going to Sealaska. 

Under the applicable ANCSA provisions Sealaska selected approximately 463,000 acres for potential 

conveyance to the corporation. To date, the U.S. has conveyed approximately 293,000 acres to 

Sealaska. Sealaska has selected about 171,000 additional acres, which are distributed among nine 

withdrawal areas defined by ANCSA for Native selections. Based on current information from the Bureau 

of Land Management, approximately 64,000 of those acres will eventually be conveyed to Sealaska to 

complete the corporation’s land entitlement under ANCSA. (Native corporations were allowed and 

encouraged to select lands in excess of their entitlements, and the final amount of the Sealaska 

entitlement has not yet been determined.) Sealaska has approximately 20,000 acres of unconveyed 

ANCSA entitlement under Section 14(h)(8), in addition to approximately 44,000 acres of 14(h)(8) lands 

resulting from the 2004 Alaska Land Transfer Acceleration Act, P.L. 108-452. 
Appendix C 

Final EIS C-11 Potential Land Adjustments

Proposal and Current Status 

In August 2002 Sealaska Corporation submitted a proposal to the Forest Service to exchange 

approximately 100,000 acres of NFS lands for Sealaska Corporation lands and selection rights under 

ANCSA. As noted above, Sealaska has approximately 20,000 acres of remaining entitlement under 

Section 14(h)(8), plus approximately 44,000 acres from P.L. 108-452. The Tongass-wide exchange 

proposed by Sealaska involves lands throughout Southeast Alaska. 

The goals of the proposed exchange are to consolidate NFS lands and Sealaska lands and to finalize 

Sealaska’s remaining land selection rights under ANCSA. Approximately 171,000 acres of the Tongass 

are encumbered by Sealaska land selections. Resolution of Sealaska’s remaining ANCSA land 

entitlement would remove these selection rights in existing ANCSA withdrawal areas as part of the 

exchange. 

The proposed land exchange package would enable Sealaska to acquire other lands outside of the 

ANCSA withdrawal areas, in addition to the selected Native heritage 14(h)(1) parcels. This is not 

authorized under ANCSA except through a land exchange. Land exchanges are discretionary, voluntary 

real estate transactions between Federal and non-Federal parties. At present there is no binding land 

exchange agreement signed by the Forest Service and Sealaska that would enable Sealaska to receive 

lands outside of the withdrawal areas. In the most recent version of its proposal, Sealaska defined what it 

termed an “entitlement pool” of approximately 123,000 acres, all of which are located outside of the 

ANCSA withdrawal areas. Sealaska consciously defined the entitlement pool to include substantially 

more acres than its maximum entitlement amount, to allow flexibility in resolving the proposal. Under the 

proposal, lands from this entitlement pool of current NFS lands would be conveyed to Sealaska as a 

substitute for its current entitlement rights. The affected acreage occurs in approximately eight blocks 

located on Prince of Wales Island (northern, central and southern portions) and on Kosciusko, Tuxekan 

and Heceta Islands. In addition, Sealaska would transfer to the U.S. lands from a pool of approximately 

68,000 acres of existing corporation lands distributed among five withdrawal areas in exchange for lands 

from a pool of 74,000 acres of current NFS lands. Those lands occur in five blocks located on Kuiu, 

Kosciusko, Heceta and central Prince of Wales Islands and on the Cleveland Peninsula, and are 

generally adjacent to areas Sealaska would receive from the entitlement pool. Sealaska would also 

relinquish claim to the 171,000 acres of lands it has selected within the ANCSA withdrawal areas. 

Without an appraisal, it is difficult to determine how many acres would be transferred or exchanged under 

this proposal. Federal law requires that lands or interests to be exchanged must generally be of equal 

value, based on market value as determined through an appraisal. Both Section 22(f) of ANCSA and 

Section 1302(h) of ANILCA provide that exchanges shall be based on equal value and contain provisions 

for cash payments to equalize land values. If the parties agree to an exchange and the Secretary of 

Agriculture determines it is in the public interest, exchanges may be made for other than equal value. 

The Forest Service completed a draft feasibility report on a similar version of this proposal in 2003. After 

lengthy discussions and several modifications to the proposal, in 2005 the Forest Supervisor informed 

Sealaska that he was not willing to move forward with the exchange because of a lack of substantial 

agreement on the parcels to be exchanged, concerns over a variety of resource issues, and the need for 

a revision to the Forest Plan to accommodate the exchange due to the magnitude of the resulting 

changes in LUD designations. The response also indicated that the proposal lacked support from local 

communities and could result in a further decline in the current timber industry dependent on the Tongass 

for its supply. 

There has been no further formal action on the proposed exchange since 2005. The proposed Alaska 

Land Transfer Acceleration Act of 2003 (Senate Bill 1466) included provisions to implement Sealaska’s 

proposed land exchange, but Congress did not pass this bill. Congress subsequently approved the 

Alaska Land Transfer Acceleration Act (PL 108-452) in 2004, without the Sealaska exchange provisions. 

New legislation to authorize the proposed exchange has not been introduced to Congress, although such 

legislation remains a possibility. Sealaska has been working internally on refinements to the proposed 

exchange and has shared a variety of preliminary maps with the Forest Service, but to date has not 

submitted a revised formal exchange proposal for Forest Service review. 
Appendix C 

Potential Land Adjustments C-12 Final EIS

Forest Management Implications 

The Forest Service conducted a preliminary evaluation of how the Sealaska proposal, if implemented, 

would affect the Tongass Land Management Plan. The analysis was based on the existing character and 

resource condition of the respective lands that would be conveyed from Sealaska to the U.S. and vice 

versa. It focused on the potential impacts on the ability to implement the Old-Growth Conservation 

Strategy and on necessary changes to the allowable sale quantity for the Tongass. The analysis also 

considered subsequent effects on local sawmills, karst and cave resources, heritage resources, 

subsistence hunting and fishing, and public access. 

Table C-1 (at the end of this appendix) summarizes the acreages included in the most recent version of 

the proposed land adjustment and their general location. It indicates the acreage of the entire pool of 

NFS lands that could be transferred to Sealaska via the entitlement and conveyance (exchange) 

components of the proposal, and the acreages of the pool of current Sealaska lands that could be 

conveyed to the U.S. The actual acreage conveyed or exchanged would likely be much less than the 

listed acres. 

From the review the Forest Service determined that implementation of the Sealaska proposal would 

require a Forest Plan Revision, based on the magnitude of the changes in land use designations. Our 

analysis showed that, if all lands in the pools were to be transferred, there would be a significant loss of 

old-growth reserves on the Tongass. There would also be a significant reduction in the Tongass 

allowable sale quantity (ASQ). In order to make up for the loss of old growth reserve acres, some areas 

currently in development LUDs would likely be precluded from timber production. This would further 

reduce the ASQ. In addition, the lands to be exchanged to the U.S. generally do not have existing road 

systems, and costs for developing roads on these lands would likely constrain the ability to supply timber 

economically. The combined impacts on the availability of timber from the Tongass could have a 

significant adverse effect on the supply of timber to mills on Prince of Wales Island and surrounding 

areas. 

In addition, the Sealaska proposal presented to the Forest Service does not provide any assurances that 

important resources on the lands to be exchanged to Sealaska would be protected to the same degree as 

under national forest management. Specifically, the proposal does not ensure that the conditions and 

requirements of the National Historic Preservation Act would be met to protect heritage resources, nor 

are there assurances that karst and cave resources would be protected. The lands proposed for 

conveyance to Sealaska also include at least one Research Natural Area and a Special Interest Area. 

Finally, there are no provisions in the Sealaska proposal that would allow for continued access to lands 

for subsistence and community recreation purposes. Consequently, resource values to the public from 

the affected lands could be lost, and subsistence and recreation uses currently occurring on those lands 

could be shifted to other areas on the Tongass. 

Several of the Sealaska parcels that would potentially be exchanged to the United States have high 

recreation and scenic values and are along established highways or cruiseship and ferry travel routes. 

Several parcels are important to local communities for dispersed recreation and subsistence activities. 

Two parcels are noteworthy for heritage resources including one site that is eligible for listing on the 

National Register of Historic Places. Other of the parcels are known to have well developed karst and/or 

karst that has been determined to be of high vulnerability. Several of the Sealaska parcels have been 

harvested. Generally, the unharvested parcels are adjacent to Tongass National Forest lands that have 

been allocated to non-development LUDS. If acquired by the United States, these parcels might also be 

allocated to non-development LUDs and may not contribute to the Tongass allowable sale quantity. 

Cape Fox Land Entitlement Adjustment 

The Cape Fox Corporation is the Native corporation established under ANCSA for the Village of Saxman, 

which is located near Ketchikan. While Cape Fox was granted entitlement to 23,040 acres within a 

defined withdrawal area, as were all Native village corporations in Southeast Alaska, its ability to select 

lands was constrained by the proximity to Ketchikan (Bureau of Land Management 2003). While other 

village corporations were prevented from making selections within 2 miles of the boundary of home-rule 
Appendix C 

Final EIS C-13 Potential Land Adjustments

cities, Cape Fox was not allowed to select lands within 6 miles of Ketchikan. In addition, all villages were 

required to take title to all available land within the core township surrounding the village and were only 

allowed to select lands within the respective withdrawal areas defined by ANCSA. As a result of these 

multiple ANCSA restrictions, the only land within the core township available for conveyance to Cape Fox 

was a 160-acre parcel that Cape Fox did not want, but that the United States was required to transfer to 

Cape Fox. 

For some time there has been interest in legislative action to adjust the selections and conveyances 

available to Cape Fox. Under ANCSA, village corporations receive only the surface estate for the lands 

conveyed to them, while the subsurface estate to those lands was transferred to the respective Native 

regional corporation, which is Sealaska Corporation in the case of Cape Fox. Therefore, to avoid 

creation of a split estate condition between NFS surface lands and Sealaska subsurface rights, 

adjustment of Cape Fox selections and conveyances also requires adjustment of Sealaska selections 

and conveyances. 

Sealaska Corporation, Shee Atika, Inc. (the urban Native corporation for Sitka), and the Forest Service 

have conferred regarding a possible land exchange and purchase since November of 1999, when Shee 

Atika expressed interest in selling its surface estate to approximately 23,100 acres at Cube Cove, within 

the Admiralty Island National Monument and Kootznoowoo Wilderness. In April 2000 Sealaska proposed 

exchanging their subsurface estate to these Cube Cove lands, or other Sealaska subsurface lands or 

land interests, in exchange for the surface and subsurface of NFS lands of equal value at the Kensington 

and Jualin Mines near Berners Bay, north of Juneau. 

By the fall of 2001 it became clear that the non-federal lands at Cube Cove were no longer offered as part 

of the exchange proposal, apparently because their preliminary appraisal figures for fair market land 

values did not meet Shee Atika’s expectations. In March 2002 Sealaska revised its proposal to offer 

approximately 5,200 acres of Sealaska subsurface lands and land interests in exchange for NFS surface 

and subsurface lands at the Kensington and Jualin Mines. This proposal was captured in a 

Congressional bill, S. 2222, along with other proposals by Cape Fox Corporation. S. 2222 was passed by 

the Senate in the 107th Congress, but not by the House. 

Proposal and Current Status 

Several versions of a Cape Fox Land Entitlement Adjustment bill were introduced to both houses of the 

107th Congress in 2002, but were not passed. On April 30, 2003, Congressman Young introduced H.R. 

1899, the Cape Fox Land Entitlement Adjustment Act of 2003, in the 108th Congress. On June 26, 2003, 

Senator Murkowski introduced a similar bill in the Senate, as S. 1354. 

H.R. 1899 and S. 1354 provided for an additional 99 acres of ANCSA selection area at Clover Passage 

(on Revillagigedo Island), for selection by Cape Fox and Sealaska Corporations. The corporations would 

select these 99 acres from within their existing ANCSA entitlements. These bills also require the Forest 

Service to offer a land exchange and, if accepted by Cape Fox, to complete a land exchange with the 

Cape Fox and Sealaska Corporations. Through this land exchange: 

1. Cape Fox Corporation would receive the surface and subsurface estates to 2,663.9 acres of NFS 

lands at the Jualin Mine. 

2. Sealaska Corporation would receive the surface and subsurface of NFS lands to equalize values 

of Sealaska subsurface lands and land interests they convey to the United States. Sealaska 

Corporation would select NFS lands of equal value from within a 9,329-acre pool of NFS lands at 

the Kensington Mine. 

3. The Forest Service would receive lands and land interests of equal value from within: (a) a pool 

of approximately 2,900 acres and a public trail easement, offered by Cape Fox (surface) and 

Sealaska (subsurface) on Revillagigedo Island; (b) 2,506 acres of Sealaska split estate 

subsurface, located at Upper Harris River and Kitkun Bay (Group 2 Lands); and (c) approximately 

2,698 acres of Sealaska subsurface land interests at Kitkun Bay and Dora Lake West, which 

remain as Sealaska entitlement (Group 3 Lands). Lands in (b) and (c) above are located on 

Prince of Wales Island and are left over from the Haida Land Exchange Acts and the 
Appendix C 

Potential Land Adjustments C-14 Final EIS

Sealaska/Forest Service Split Estate Exchange Agreement of 1991. Cape Fox will choose the 

lands to be conveyed to the United States from the approximately 2,900-acre pool in (a) above. 

Senator Murkowski held a legislative field hearing in Anchorage August 6, 2003, to provide an opportunity 

for public input and comments on the proposal. She also held a public town meeting in Juneau on 

September 20, 2003, and an additional legislative hearing March 10, 2004, in Washington, D.C. The 

Administration supported the legislation, with some minor changes to clarify valuation standards, extend 

required time frames, and provide for environmental survey and remediation standards. The 108th

Congress did not pass the legislation, however. 

On April 7, 2006 Senator Murkowski introduced S. 2615, “to provide equitable treatment for the people of 

the Village Corporation established for the Native Village of Saxman, Alaska, and for other purposes,” in 

the 109th Congress. This bill waived the requirement under ANCSA Section 16(b) that the U.S. convey 

and Cape Fox receive the 160-acre parcel discussed above, and provided for conveyance of the surface 

estate for the 99 acres at Clover Passage to Cape Fox (with the subsurface estate going to Sealaska). 

This bill did not address the other land conveyances proposed in H.R. 1899/S. 1354 (see items 1-3 

above), although it did state that conveyance of the 99 acres identified in Section 3(a) of the bill would be 

considered to fulfill the entitlement of Cape Fox under ANCSA Section 16(b). This bill was not passed by 

the 109th Congress. The bill was mostly recently introduced on January 8, 2007 as Senate Bill 203 in 

the 110th Congress. 

Forest Management Implications 

The Cape Fox land entitlement adjustment proposal introduced in 2003 is a relatively complex package of 

selections, conveyances and exchange actions that could affect a number of NFS parcels and have a 

variety of effects on Tongass management. Under that proposal, Cape Fox and Sealaska would convey 

to the Forest Service the surface and subsurface rights to approximately 2,900 acres on Revialgigedo 

Island, and Sealaska would convey to the Forest Service the subsurface rights to approximately 5,200 

acres on Prince of Wales Island. Surface management of those lands on Revillagigedo Island would 

likely remain unchanged, while the Forest Service would need to administer a split-estate condition for 

the lands on Prince of Wales Island. In return, Cape Fox would receive surface and subsurface rights to 

nearly 2,700 acres of NFS lands and Sealaska would select up to 9,300 acres of NFS lands with a value 

equal to the 5,200 acres of subsurface rights. The Native corporations would presumably receive lands 

with high mineral values located near existing mineral resources (the Jualin and Kensington mines), 

which could change the jurisdiction over future mining activities. While these conveyances could 

ultimately be of note from a financial perspective, they would affect relatively small areas and probably 

would not change the likelihood of expanded future mineral development in the subject locations. 

Senate Bill 2615, introduced in 2006, and the current version, Senate Bill 203 would have a minor effect 

upon Tongass management. The 99-acre parcel to be conveyed to Cape Fox Corporation is adjacent to 

lands owned by Cape Fox, other private owners, and the State of Alaska. Currently this parcel is 

managed as scenic viewshed, a moderate development LUD. This bill would also complete Cape Fox 

Corporation’s ANCSA entitlement resulting in the removal of selection encumbrances on approximately 

800 acres of NFS lands. 

Summary Discussion 

Table C-1 summarizes the key parameters of the proposed land conveyance and exchange programs 

discussed in this appendix. For each proposal, the table indicates the maximum acreage of Tongass 

lands that could be transferred to other ownership, acreage that could be added to the Tongass land 

base, the general location of the action (if identified in the proposal), whether the proposal is intended to 

complete an existing entitlement, and the type of land involved (if known or inferred). 
Appendix C 

Final EIS C-15 Potential Land Adjustments

Table C-1 

Summary of Potential Land Adjustments 

Conveyance or 

Exchange Proposal 

Max. acres 

from NFS 

Max. Acres 

to NFS 

Likely Tongass 

Location 

Entitlement 

Completion? Type of Land 

University of Alaska Lands, 

Senate Bill 293 

250,000 0 Unknown No Second-growth 

cut since 1952 

Unrecognized SE AK Native 

Communities, Senate Bill 

1306 

115,200 0 Near Haines, 

Ketchikan, 

Petersburg, Tenakee 

Springs, Wrangell 

No Development 

LUDs? 

Alaska Native Veterans 

Land Allotment Equity Act, 

Senate Bill 2000 

55,000 est. 0 Unknown No Homesites, 

recreation lands? 

Alaska State Forest 

proposal 

2,000,000 0 Prince of Wales 

island 

No Timber 

Production 

Southeast Alaska Native 

Land Entitlement 

Finalization Act* or 

Sealaska Proposed 

Comprehensive Tongasswide Land Exchange 

203,000 68,000 Widely distributed Yes, outside of 

ANCSA 

withdrawal 

areas. Also 

exchange other 

lands 

Varied 

Shee Atika ±23,000 ±23,000 West and North 

Yakobi & Northwest 

Chichagof 

No Semi-Remote 

Recreation 

Mental Health Trust ±20,000 ±20,000 Prince of Wales 

Island 

No Timber 

Production (young 

growth) 

Cape Fox Entitlement 

Adjustment, Senate Bill 

2615 

99 0 North of Ketchikan Yes, outside of 

ANCSA 

withdrawal area 

Moderate 

Development 

LUD 

Total 2,666,000 111,000 

*Assumes economic development lands similar to what depicted in DEIS. An additional 3,600 acres are added for 

sacred, cultural, traditional, or historic significance, as well as 5,000 acres for Native enterprise sites. 

When considered as individual actions, several of the land adjustment proposals discussed above appear 

to be relatively minor in scope and potential effect, and/or the implications of the proposal for Tongass 

management are difficult to determine due to lack of specificity in the proposal. Conversely, some of the 

proposals could result in substantial changes to the NFS land base and prompt corresponding 

adjustments in Tongass management. 

The Forest Service believes that it is unlikely that all of the identified conveyance and exchange 

proposals would be enacted and/or implemented. Because some of the proposals involve larger 

acreages and it is conceivable that multiple proposals could be adopted; however, it is appropriate to 

consider the range of implications for management of the Forest. Pertinent observations based on 

considering the conveyance and exchange proposals collectively include the following: 

♦ These proposals generally target, or would be likely to focus interest on, Tongass lands that are 

currently managed for resource development activities. Conveyance of these lands out of federal 

ownership would decrease the acreage available for development activities on the Tongass. 

♦ If all of the proposals were enacted and implemented, it could conceivably result in 

transfer/exchange/conveyance of over 2 million acres from the Tongass, representing 

approximately 15 percent of the current NFS land base. 
Appendix C 

Potential Land Adjustments C-16 Final EIS

♦ Conveyance of large blocks of land under several of these proposals would consolidate certain 

other ownerships while likely further fragmenting the federal land ownership pattern within the 

Tongass. 

♦ While new owners of former Tongass National Forest lands would presumably pursue resource 

development objectives on much or most of the affected acreage, it is unlikely that all new 

owners would continue the currently applicable protection measures for cultural and ecological 

resources, or continue to supply timber to local mills at current rates. 

♦ It is unlikely that all new owners would allow public access to the affected lands for subsistence, 

recreation, and similar public uses, resulting in a reduction in the set of opportunities currently 

available for these purposes. 

As it has in the past, the Forest Service will evaluate any new or modified proposals for administrative 

land exchanges for their consistency with applicable NFS planning and management direction. The 

Forest Service will follow Congressional direction in implementing future land adjustments that might be 

enacted by Congress, and will modify Tongass National Forest planning and management as needed in 

response to such changes. 
APPENDIX D 

OLD-GROWTH HABITAT CONSERVATION STRATEGY, WILDLIFE STANDARDS AND GUIDELINES, AND WILDLIFE VIABILITY 
Appendix D

Final EIS Conservation Strategy, 

Wildlife S&Gs, and Viability 

D-iii 

Appendix D 

Old-Growth Habitat Conservation Strategy, Wildlife 

Standards and Guidelines, and Wildlife Viability 

CONTENTS 

1. INTRODUCTION............................................................................................................................... D-1

2. OLD-GROWTH HABITAT CONSERVATION STRATEGY .............................................................. D-2

2.1. Historical Background of the Conservation Strategy ........................................................... D-2

2.1.1. Overview................................................................................................................. D-2

2.1.2. Habitat Reserve Approach ..................................................................................... D-2

2.1.3. VPOP Strategy ....................................................................................................... D-3

2.1.4. Pacific Northwest Research Station Review.......................................................... D-3

2.1.5. VPOP Response .................................................................................................... D-5

2.2. The 1997 Old-Growth Conservation Strategy...................................................................... D-6

2.2.1. Forest-wide Habitat Reserve Network ................................................................... D-6

2.2.2. Matrix Management.............................................................................................. D-10

2.2.3. Analysis of the 1997 Old-Growth Strategy........................................................... D-13

2.3. Modifications to the Strategy between 1997 and 2007...................................................... D-17

2.4. New Relevant Science since 1997 .................................................................................... D-19

2.4.1. Conservation Strategies....................................................................................... D-19

2.4.2. Species-Specific Science..................................................................................... D-22

2.5. Modifications to the Strategy under 2008 Forest Plan Amendment .................................. D-26

2.5.1. Changes to Forest-wide Reserve Network (coarse-filter approach).................... D-27

2.5.2. Changes to Standards and Guidelines (fine-filter approach)............................... D-30

3. WILDLIFE VIABILITY RATINGS..................................................................................................... D-51

3.1. Historical Background for Tongass Viability Ratings ......................................................... D-51

3.2. Description of the 1995/1996 and 1997 Panel Assessment Process................................ D-52

3.2.1. Panel Process ...................................................................................................... D-52

3.2.2. Concepts of Viable and Well Distributed Populations.......................................... D-53

3.3. Summary of 1995/96 and 1997 Panel Assessment Results for Wildlife............................ D-55

3.3.1. Northern Goshawk ............................................................................................... D-55

3.3.2. American Marten .................................................................................................. D-58

3.3.3. Alexander Archipelago Wolf................................................................................. D-63

3.3.4. Brown Bear........................................................................................................... D-65

3.3.5. Other Terrestrial Mammals................................................................................... D-68

3.3.6. Marbled Murrelet .................................................................................................. D-73

3.4. New Science Relevant to Wildlife Viability Assessment Since 1997................................. D-77

3.5. Application of Panel Assessments to the 2008 FEIS Alternatives..................................... D-79

3.5.1. Northern Goshawk ............................................................................................... D-79

3.5.2. American Marten .................................................................................................. D-82

3.5.3. Alexander Archipelago Wolf................................................................................. D-83

3.5.4. Brown Bear........................................................................................................... D-83

3.5.5. Other Terrestrial Mammals................................................................................... D-84

3.5.6. Marbled Murrelet .................................................................................................. D-84

3.6. Alternative Approach to Viability Evaluation for Alternative Comparison .......................... D-85

4. CONCLUSIONS REGARDING THE 2008 FOREST PLAN AMENDMENT.................................. D-87

4.1. Introduction ........................................................................................................................ D-87

4.2. Forest-wide Reserve Changes .......................................................................................... D-87

4.3. Standards and Guidelines Changes .................................................................................. D-88

4.4. Summary and Conclusions................................................................................................ D-90

5. REFERENCES CITED.................................................................................................................... D-91
Appendix D

Conservation Strategy, Final EIS 

Wildlife S&Gs, and Viability

D-iv 

LIST OF TABLES 

Table D-1. Analysis of the Range of Island Sizes across the Tongass National Forest and the 

Amount of Productive Old-Growth at Potential Risk (in 1997)......................................... D-15

Table D-2. Summary of Changes in Suitable Acres due to Forest Plan Amendments that 

Produce the 2007 Forest Plan.......................................................................................................................................... D-18

Table D-3. Summary of Acreages in Reserves and Matrix under the 2007 and the 1997 versions 

of the Forest Plan............................................................................................................. D-18

Table D-4. Summary of Productive Old-Growth Acreage in Reserves, Protected in the Matrix, 

and Suitable for Timber Harvest in 2008.......................................................................... D-19

Table D-5. Summary of Acreages in Reserves and Matrix under the Alternatives compared with 

the Forest Plan in 1997 .................................................................................................... D-29

Table D-6. Estimated Acreage and Percentage of All Existing POG, High-Volume POG, and 

SD67 POG in Reserves and Matrix Lands (minimum protected vs. maximum 

harvested) by Alternative................................................................................................. D-30

Table D-7. Number of VCUs where the Proposed Legacy Standard applies, compared with the 

number of VCUs where the Goshawk and Marten Standards apply, by Biogeographic 

Province............................................................................................................................ D-41

Table D-8. Summary of POG Protection under Alternatives 5 and 6. ............................................... D-46

Table D-9. Northern Goshawk Panel Results .................................................................................... D-57

Table D-10. American Marten Panel Results....................................................................................... D-60

Table D-11. Alexander Archipelago Wolf Panel Results...................................................................... D-64

Table D-12. Brown Bear Panel Results ............................................................................................... D-67

Table D-13. Widely Distributed Mammals Panel Results .................................................................... D-70

Table D-14. Endemic Mammals Panel Results ................................................................................... D-71

Table D-15. Marbled Murrelet Panel Results....................................................................................... D-75

Table D-16. Relationship of 2008 Alternatives to 1997 Alternatives for Use in Rating 2008 

Alternatives in Terms of Panel Assessments................................................................... D-80

Table D-17. Viability Ratings (likelihood of maintaining habitat to support viable and well 

distributed populations) assigned to the 2008 Alternatives based on the Equivalent 

Panel Assessment Ratings from the 1995/1997 Panel Assessments ............................. D-81

Table D-18. Goshawk Viability Ratings for the 2008 Alternatives Relative to the 2007 Forest Plan... D-82

Table D-19. Risk Indices associated with the joint probability that any (i.e., at least one) wildlife 

species among those evaluated would become restricted to refugia or be extirpated .... D-86
Appendix D

January 2008 Conservation Strategy, 

Wildlife S&Gs, and Viability

D-1 

1. INTRODUCTION 

This appendix provides a description of the background, rationale, and assumptions, for the changes to 

the Tongass old-growth habitat conservation strategy, proposed by the alternatives evaluated in the 2008 

Forest Plan amendment Final Environmental Impact Statement (FEIS). In addition, it describes the 

assumptions and rationale for application of the wildlife viability ratings to the alternatives. This appendix 

brings forward and updates information contained in Appendix N to the 1997 FEIS. 

Chapter 2 addresses the old-growth habitat conservation strategy. It includes a summary of the historical 

background, a description of the 1997 strategy including modifications to the strategy between 1997 and 

2007, and an overview of the new science that is relevant to the strategy. Sections 2.1 and 2.2 begin by 

presenting the historical background of the strategy and describe the strategy, as it was proposed in 

1997. These two sections are largely summarized from Appendix N to the 1997 FEIS. Section 2.3 

summarizes the modifications to the strategy that have occurred through Forest Plan amendments and 

land adjustments from 1997 through 2007 and Section 2.4 summarizes new relevant science that has 

been developed since 1997. 

Modifications to the strategy proposed by the 2008 FEIS alternatives are described in Section 2.5. In this 

FEIS, Alternative 5 (No Action) incorporates the 1997 strategy, as modified between 1997 and 2007, 

while the six action alternatives propose modifications. Alternatives 1, 2, 3, and 6 propose the same 

refined network of Old-Growth Habitat Land Use Designations (LUDs) and incorporate the same changes 

to the wildlife standards and guidelines, but differ in the amount and distribution of some of the other nondevelopment LUDs that also comprise the reserve system. Section 2.5 describes the background, 

rationale, and modifications to the strategy proposed by these four alternatives. These modifications 

include changes to the old-growth reserve (OGR) network, changes in other non-development LUDs, and 

changes to species-specific standards and guidelines. Alternatives 4 and 7 propose more extensive 

changes to the conservation strategy and standards and guidelines. Section 2.5 also summarizes the 

rationale and changes to the strategy incorporated in these alternatives. The changes for all of the 

alternatives are compared to Alternative 5 (the 1997, as amended, Forest Plan). 

In 1995/1996 and 1997 a series of expert risk assessment panels were conducted to evaluate the various 

alternatives used in the 1997 FEIS and predecessor documents. The purpose of the panels was to 

evaluate various alternatives for the likelihood of maintaining sufficient, well distributed habitat to maintain 

viable populations of old-growth associated wildlife species over a 100-year horizon. These panel 

assessments, along with new information and an alternate method, were used as a tool to evaluate 

wildlife viability for the 2008 FEIS alternatives. Chapter 3 describes the panel assessments, summarizes 

results of the panel assessments that are relevant to the 2008 alternatives, discusses new relevant 

science, and then summarizes the application of the panel assessments to the 2008 alternatives, 

including rationale and assumptions. Section 3.1 presents historical background for the Tongass wildlife 

risk assessment panels and ratings, Section 3.2 describes the panel assessment process, and Section 

3.3 summarizes the 1995/1996 and 1997 panel assessment results. These first three sections of Chapter 

3 are largely summarized from the risk assessment panel reports and Appendix N to the 1997 FEIS. 

Section 3.4 summarizes new science related to wildlife viability assessment that has been developed 

since 1997. The application of the 1995/1996 and 1997 panel assessments to the 2008 FEIS 

alternatives is described in Section 3.5. Finally, Section 3.6 presents an alternative approach to 

assessing viability. 

Chapter 4 presents a summary of the major conclusions that are relevant to the 2008 Forest Plan 

amendment and the alternatives evaluated in the EIS. Finally, Chapter 5 lists the references cited. 
Appendix D

Conservation Strategy, Final EIS 

Wildlife S&Gs, and Viability

D-2 

2. OLD-GROWTH HABITAT CONSERVATION STRATEGY 

2.1. Historical Background of the Conservation Strategy 

2.1.1. Overview 

An integrated science-based old-growth forest habitat conservation strategy was developed and adopted 

during the 1997 Forest Plan Revision process. The old-growth strategy has two basic components. The 

first is a forest-wide reserve network that protects the integrity of the old-growth forest by retaining blocks 

of intact, largely undisturbed habitat. The OGRs include a system of large, medium, and small Habitat 

Conservation Areas (HCAs) allocated to the Old-Growth Habitat LUD, and full protection of all islands less 

than 1,000 acres in size. The reserve network also includes all other non-development LUDs. These 

include Wilderness, National Monument, Legislated LUD II, Wild River, Remote and Semi-Remote 

Recreation, Research Natural Area, Municipal Watershed, and all other LUDs that essentially maintain 

the integrity of the old-growth ecosystem. The second component of the old-growth habitat conservation 

strategy is management of the matrix, e.g., the lands with LUD allocations where commercial timber 

harvest may occur. Within the matrix, components of the old-growth ecosystem are maintained by 

standards and guidelines to protect important areas and provide old-growth forest habitat connectivity. 

The analysis presented in this section describes the rationale for the strategy and its specific 

components. 

Development of the old-growth strategy relied on several key scientific documents that provided the basic 

foundation for addressing wildlife viability. These included the Interagency Viable Population Committee 

(VPOP) Conservation Strategy (Suring et al. 1993), the Pacific Northwest Research Station Peer Review 

of the VPOP Strategy (Kiester and Echkardt 1994), and the VPOP Response to the Pacific Northwest 

Research Station Peer Review (Suring et al. 1994). In addition, the Alexander Archipelago Wolf (Person 

et al. 1996) and Northern Goshawk (Iverson et al. 1996) conservation assessments provided the basis for 

design of some components of the strategy as well as a basis for examining whether the old-growth 

strategy would sustain viable and well-distributed populations of these two species. This section provides 

a discussion of the major features, findings, and recommendations of each of the three conservation 

planning (VPOP-related) documents, a consideration of features and recommendations in each 

document, and the integration of features in the deliberative process to arrive at an overall strategy to 

address viability of old-growth associated species. As such, it represents a summary of much of the 

information presented in Appendix N to the 1997 Forest Plan. 

2.1.2. Habitat Reserve Approach 

There is a substantial science base for an old-growth habitat reserve approach for addressing wildlife 

viability. Habitat reserves have often been the focal point of conservation strategies since the pioneering 

work of MacArthur and Wilson (1967) on the theory of island biogeography: that the equilibrium number of 

species on an island generally depends on island size, and island distance from (usually mainland) 

source populations. Reserves are viewed as islands of undisturbed or natural habitat within a landscape 

of management-altered or dissimilar habitat. Reserves attempt to protect the integrity of an isolated 

landscape. From this theory, five general concepts of reserve design have evolved in conservation 

planning (Thomas et al. 1990): 

♦ Well-distributed species are less prone to extinction than species confined to small portions of their 

range; 

♦ Larger reserves supporting many pairs of individuals are superior to smaller reserves supporting only 

a few pairs; 

♦ Reserves that are close together are better than ones far apart; 

♦ Reserves should have the least amount of induced fragmentation possible; and 
Appendix D

Final EIS Conservation Strategy, 

Wildlife S&Gs, and Viability

D-3 

♦ Reserves should be connected, either through specific corridors (such as beach fringe or riparian 

areas) or through maintaining habitat characteristics similar to the reserves on the lands between 

them. 

A reserve-based strategy relies on blocks of intact, largely undisturbed habitats (such as old-growth 

forest) of the appropriate size, spacing, and composition to meet a desired design that will maintain 

viable, well-distributed populations of one or more species. The HCA network used for the conservation 

of spotted owl habitat in the Pacific Northwest is a classic example (Thomas et al. 1990). 

Potential drawbacks of a reserve approach are the failure to consider natural disturbance processes-the 

dynamic nature of ecosystems, and not being able to preserve landscape integrity (Irwin and Wigley 

1992). These can be overcome by combining a reserve system with some type of matrix management 

approach (Thomas et al. 1990, Franklin 1993). As a complement to reserves, matrix management can 

serve at least three important roles: 1) providing habitat at smaller spatial scales, 2) increasing the 

effectiveness of the reserves, and 3) improving landscape connectivity.

2.1.3. VPOP Strategy 

The Interagency Viable Population Committee (VPOP) performed pioneering work in designing a 

landscape conservation strategy to address wildlife viability. Their strategy and extensive supporting 

analysis are contained in A Proposed Strategy for Maintaining Well-Distributed, Viable Populations of 

Wildlife Associated With Old-Growth Forests in Southeast Alaska (Suring et al. 1993). VPOP was 

commissioned by the Tongass Land Management Plan (Forest Plan) Revision Team to provide 

recommendations for sustaining habitat to help ensure the maintenance of well-distributed viable 

populations of all old-growth associated wildlife species across the Tongass. VPOP systematically 

screened all wildlife species and identified those old-growth associated species they considered to be 

most sensitive to habitat loss and fragmentation of the old-growth ecosystem. Their ‘coarse filter’ 

landscape strategy designed to consider the entire complement of old-growth associated species, 

included a system of large (40,000-acre ) and medium (10,000-acre ) HCAs with spacing and habitat 

composition requirements well distributed across the Tongass. Small (1,600-acre) HCAs in each major 

watershed (>10,000 acres) and individual species-specific management guidelines also were 

recommended. 

Landscape connectivity was an integral feature of the original VPOP landscape conservation strategy 

(Suring et al. 1993). VPOP reviewed the available literature and concluded that there was limited 

empirical support for corridors but that this should not preclude their inclusion in landscape conservation 

planning. They reasoned that landscape habitat connectivity was an important component of 

conservation planning to facilitate animal dispersal and movement, whether specifically designed as 

corridors or through overall management of a habitat matrix. They recommended a 500-foot beach fringe 

buffer Forest-wide and 200-foot buffers on anadromous fish streams. Breaks in these buffer corridors 

should be less than 65 feet to facilitate flying squirrel dispersal. 

VPOP mapped the large and medium reserves and provided guidance for locating the small reserves, 

stating that their mapping effort represented only one possible application of the OGR system across the 

forest. VPOP concluded that their strategy represented “the minimum amount and distribution of habitat 

necessary to assure a high likelihood of maintaining viable, well-distributed populations of old-growth 

associated wildlife species across the Tongass National Forest” (p. 37). 

2.1.4. Pacific Northwest Research Station Review 

The Forest Service Pacific Northwest Research Station was requested by the Alaska Region to conduct 

an independent scientific peer review of the VPOP strategy. Kiester and Eckhardt (1994) obtained 

technical reviews from 18 scientists from North America with substantial knowledge and experience in 

species ecology or conservation biology. Kiester and Eckhardt (1994) synthesized these technical 

reviews and published all reports in the document Review of Wildlife Management and Conservation 

Biology on the Tongass National Forest: A Synthesis with Recommendations (Pacific Northwest 

Research Station Review). 
Appendix D

Conservation Strategy, Final EIS 

Wildlife S&Gs, and Viability

D-4 

The general concepts in VPOP’s multiscale habitat conservation strategy received positive support from 

the scientists involved in the Pacific Northwest Research Station Review: Beckman (p. 37): “The 

proposal of HCAs of three sizes somewhat uniformly scattered across the landscape seems like a 

reasonable strategy...”; Forsman (p. 48): “...proposed network of conservation areas is a reasonable start 

in combination with protection of known (goshawk) nest areas within the matrix.”; Hansen (p. 50): “The 

core approach of this report (strategy) is scientifically sound and generally consistent with modern 

conservation biology.”; Jarvis (p. 71): “The strategy is an innovative and bold attempt to apply species, 

community, and ecosystem concepts to applied management.”; Lande (p. 78): “...a good initial attempt to 

develop a strategy for maintaining biodiversity.”; Lidicker (p. 87): “The strategy outlined is a giant step in 

the right direction, but improvements are needed...”; Marcot (p. 101): “...the process and basis for the 

proposed conservation strategy is scientifically sound given our current knowledge base...”; and Walters 

(p.194): “...the overall management strategy that considers landscape level features is excellent. The 

approach is well-grounded in the best current information in conservation biology...”. Kiester and 

Eckhardt (p. 5) concluded in their summary review that “the Strategy (VPOP) receives high marks. It 

represents a solid attempt to integrate species viability concerns with the HCA approach.” 

The Pacific Northwest Research Station Review identified several weaknesses in the VPOP strategy. For 

example, corridors were considered inadequate, there was insufficient attention directed to the matrix 

lands, and HCAs were considered to be too small by many scientists. Kiester and Eckhardt (1994 p. 5) 

concluded that “the particular pattern of HCAs that it [the VPOP strategy] suggests will not ensure viability 

of all species”--although no individual species were specifically identified. Careful examination of all 

reports by the 18 scientists that participated in the Pacific Northwest Research Station Review revealed 

repeated concerns relative to brown bears and wolves (Lande p. 82; Lidicker p. 91; McLellan p. 132, 

Paquet p. 143; Pletscher p. 147; Powell p. 156, and in the summary by Kiester and Eckhardt, p. 16, 17) 

and that 40,000-acre large HCAs recommended by VPOP were too small to sustain populations of these 

wide-ranging species. Lande recommended that at least one very large HCA be maintained in each 

ecological province or island (p. 81); Lidicker recommended a “few large areas, one per island or island 

group” (p. 91); McCullough (p. 116) recommended fewer but larger HCAs to support continuous 

populations; and Pletscher (p. 147) suggested an “inverse HCA” concept of very large preserved 

landscapes with small areas allocated for timber harvest. 

Importantly, Kiester and Eckhardt (1994, p.3) noted that the Pacific Northwest Research Station Review 

only considered the network of mapped VPOP large and medium HCAs and Congressionally protected 

areas such as Wilderness, Monuments and Legislated LUD II areas. The VPOP reserve network was not 

examined in the context of the entire forest plan or a fully articulated planning alternative containing the 

strategy. The scientists were unable to consider other LUDs that effectively function as reserves and 

conserve the old-growth ecosystem—a very important component incorporated into the development of 

the old-growth habitat conservation strategy in the revised Forest Plan and this analysis. 

Corridors and landscape connectivity received considerable attention among the scientists involved in the 

Pacific Northwest Research Station Review, and somewhat differing opinions emerged regarding how to 

address landscape connectivity. Lidicker recommended 1,000-foot corridors (p. 91), while Lande (p. 82) 

recommended corridors of up to 4,000 feet wide. Other scientists questioned the value of explicitly 

designed corridors. McCullough (p. 116) noted that “corridors are of considerable debate” and 

recommended larger reserves to minimize reliance on dispersal corridors; Paquet (p. 137) stated “there 

are few controlled data with which to assess the conservation role of corridors, thus it is difficult to support 

or refute their value” but added “...maintenance or restoration of connectivity in the landscape is a 

prudent strategy”; Pletscher (p 147) stated “There are few empirical studies documenting the value of 

narrow corridors” and recommended more attention be focused on overall management of the matrix; and 

Powell (p. 154) agreed with VPOP regarding uncertainty of corridors and recommended more attention 

be given to the intervening landscape matrix to facilitate wildlife movement and dispersal. Kiester and 

Eckhardt (p. 17) stated that overall landscape connectivity was an essential component of an old-growth 

conservation strategy and wider corridors were necessary (especially for marten), particularly relative to 

ecological pinch points, but cautioned that corridors are “virtually untested in practice.” 
Appendix D

Final EIS Conservation Strategy, 

Wildlife S&Gs, and Viability

D-5 

In their summary chapter, Kiester and Eckhardt (1994) provided many recommendations that specifically 

relate to forest planning and features of landscape design: 

♦ Existing largest blocks of contiguous high-volume old-growth forest should not be further fragmented 

by timber harvesting or road building. 

♦ Incorporate larger reserves. 

♦ Incorporate wider corridors. 

♦ Do not differentially cut low altitude, high-volume old growth 

♦ Consider an inverse HCA concept. 

They provided many other sound management recommendations not directly related to landscape 

planning design, such as adaptive management, biological inventory, gap analysis, and population 

viability analyses. 

2.1.5. VPOP Response 

Suring et al. (1994) specifically responded to individual recommendations made in the Kiester and 

Eckhardt (1994) review of the VPOP Conservation Strategy in the document: Response to the Peer 

Review of: A Proposed Strategy for Maintaining Well-distributed, Viable Populations of Wildlife 

Associated with Old-Growth Forests in Southeast Alaska (VPOP Response). In this brief (11 pages with 

appendices) response, Suring et al. (1994) indicated that the document represented an “initial response” 

outlining additional elements that would be considered in their preparation of a final Conservation 

Strategy as provided for in the peer review process, stating “additional support will be needed by the 

Committee (VPOP) from the Forest Service to adequately incorporate the recommendations of the peer 

reviewers into our manuscript and to publish that manuscript” (Suring et al. 1994, p. 3). 

Within the VPOP Response, seven specific recommendations were made that were responsive to Pacific 

Northwest Research Station Review comments. All recommendations were considered during the 

Viability Synthesis Workshop (Iverson and Rene, 1997) to identify building block concepts for forest plan 

alternative development. All VPOP Response recommendations were analyzed spatially and 

quantitatively (Iverson 1996a). In doing so, the Forest Plan interdisciplinary team (IDT) concluded that 

the features described in the recommendations would not collectively represent a fundamentally different 

alternative than existed within the range for forest plan alternatives considered in the Revision planning 

process and that general concepts recommended (e.g., larger reserves and wider corridors) were already 

addressed. 

Specifically, from the Pacific Northwest Research Station Review recommendation to “keep landscape 

options open, and do not further fragment existing large blocks of high-volume old growth,” the VPOP 

Response generated the following recommendation: “it is important that the largest remaining patches not 

be fragmented. This may (emphasis added) be accomplished by restricting logging and road building to 

areas other than the three largest old-growth forest patches within each ecological province” (p.8). The 

Pacific Northwest Research Station Review referred to blocks of old growth while the VPOP response 

referenced “patches”; the Pacific Northwest Research Station Review recommendation specifically 

mentioned “high-volume” old growth—VPOP did not; the VPOP Response only recommended that the 

three largest old-growth forest patches be protected—the Pacific Northwest Research Station Review 

suggested all blocks. Despite slight but important differences between these two recommendations, the 

Forest Service concluded that minimizing additional fragmentation of large areas of old-growth forest with 

a focus on the high-volume class strata was the basic intent of the recommendations. 

Noting the limitations in their original conservation strategy identified by the Pacific Northwest Research 

Station Review, the VPOP Response considered the diversity of opinion among the scientists concerning 

corridors and provided a series of explicit corridor recommendations. They recommended that a beach 

fringe corridor of 3,300 feet be established Forest-wide within which only selective uneven-aged 

management could be applied. They also recommended that 1,000-foot and 1,600-foot no harvest 

corridors be designated to connect medium and large HCAs, respectively. These corridors should be 

located below 800 feet in elevation. 
Appendix D

Conservation Strategy, Final EIS 

Wildlife S&Gs, and Viability

D-6 

2.2. The 1997 Old-Growth Conservation Strategy 

The 1997 Forest Plan IDT carefully reviewed the landscape design recommendations contained in the 

documents discussed above. In consideration of all multiple-use issues and concerns, they designed a 

habitat strategy that was responsive to the recommendations contained in these documents. This 

strategy represents the integration of many elements, some of which are specific to addressing wildlife 

viability, others of which respond to other issues, such as Congressional legislation (Wilderness, National 

Monument, and Legislated LUD II), riparian habitat management from the Anadromous Fish Habitat 

Assessment, or the allocation of lands to Remote and Semi-Remote Recreation in recognition of 

recreation and tourism uses. 

After considering the Pacific Northwest Research Station Review by prominent scientists and considering 

all other available information, the IDT incorporated the VPOP HCA strategy as the cornerstone of the 

old-growth forest habitat strategy in the 1997 revised Forest Plan. This represents a fundamental ‘coarse 

filter’ approach to addressing wildlife viability and the conservation of biodiversity. In addition, a variety of 

other coarse filter standards and guidelines provided connectivity between the reserves. At the “fine filter” 

level, species-specific standards recommended by VPOP (e.g., brown bear, goshawk, wolf, great blue 

heron, etc.) were fully considered in light of additional information such as conservation assessments, 

panel assessment results, etc. and appropriate standards and guidelines were incorporated into the 

Threatened, Endangered, and Sensitive Species and Wildlife sections of the Forest Plan for species that 

needed additional protection measures to assure their viability and well-distributed status. 

The following sections describe the strategy. First, the Forest-wide reserve network is discussed. Next, 

the management of lands outside the reserve network (the “matrix”) is described with subsections on 

each category of standards and guidelines that affect this management. 

2.2.1. Forest-wide Habitat Reserve Network 

2.2.1.1. Introduction 

The coarse-filter approach was designed to maintain a functional and interconnected old-growth 

ecosystem, which in turn will maintain the component parts (composition and structure) and processes 

(function) of that ecosystem (p. 3-11, U.S.D.A. 1997c). In general, the home range and dispersal 

capabilities of old-growth associated species of concern were considered in determining the size, 

spacing, and number of reserves. 

The system of Forest-wide habitat reserves adopted by the Forest Plan consists of large, medium, and 

small reserves. Of the estimated 5 million acres of productive old growth (POG) in 1997, the reserve 

system sets aside 3.6 million acres, and nearly 1 million additional acres are protected through the 

various standards and guidelines prescribed for management of the lands outside the reserves (U.S.D.A. 

2003). The percentage of POG reserved within each of the 21 biogeographic provinces on the Tongass 

ranges from 38 to100 percent (Iverson and DeGayner 1997). The percent of the reserve system that is 

high-volume old growth (greater than 25,000 board feet per acre) is slightly higher than the Forest-wide 

average (44 percent and 43 percent, respectively) (U.S.D.A. 1997a). 

2.2.1.2. Description and Design Features of the Reserve Network 

A summary description of the reserve types, as they were defined in the 1997 Forest Plan, is provided 

below. In addition, details regarding the design features of the reserve network are presented following 

the description. 

Description and General Design of Each Reserve Type 

Large Reserves: 

♦ There are 38 large reserves on the Tongass. These are contiguous landscapes, typically at least 

40,000 acres in size and including at least 20,000 acres of POG forest. At least 10,000 acres of POG 

was intended to be in the high-volume stratum. Large reserves consist of a variety of nondevelopment LUDs including the Old-Growth Habitat LUD. 
Appendix D

Final EIS Conservation Strategy, 

Wildlife S&Gs, and Viability

D-7 

♦ Large reserves are intended to be no more than 20 miles apart and are distributed across the entire 

Forest. Large reserves within the range of brown bears were intended to have at least one Class I 

anadromous fish stream. 

Medium Reserves: 

♦ The Tongass includes 112 medium reserves. These are contiguous landscapes of approximately 

10,000 acres including at least 5,000 acres of POG forest. At least 2,500 acres of the POG was 

intended to be in the high-volume stratum. Medium reserves consist of a variety of non-development 

LUDs including the Old-Growth Habitat LUD. 

♦ Medium reserves are intended to be no more than 8 miles from the nearest large or medium reserve 

and are distributed across the entire Forest. 

Small Reserves: 

♦ The Tongass includes a network of 237 small reserves, which are defined by Old-Growth Habitat 

LUDs. They generally contain at least 16 percent of the area of a value comparison unit (VCU) in a 

contiguous landscape, with at least 50 percent of the area in POG forest. 

♦ They typically contain a minimum of 400 acres of POG. 

Small Islands: 

♦ The Tongass Forest Plan protects all islands less than 1,000 acres from additional harvest of oldgrowth forest. These areas are mapped as non-development LUDs, typically Semi-Remote 

Recreation. 

Additional Design Features and Assumptions of Reserve Network 

This section describes additional design criteria and assumptions used to design the OGRs system. A 

basic assumption was that future reviews of most individual medium and large OGRs or reviews of the 

entire conservation strategy would need to consider the total acres of old-growth habitat and other nondevelopment LUDs that maintain the integrity of the old-growth forest ecosystem and contribute to a 

Forest-wide system of reserves within National Forest System lands. Islands less than 1000 acres that 

are designated as non-development LUDs may be excluded from acreage calculations. 

General Design Criteria 

A. OGRs were located so that spacing is maintained in the four cardinal directions. 

B. Reserves are more circular rather than linear in shape to maximize the amount of interior 

(secure from the effects of forest edge) forest habitat. 

C. The amount of early seral habitat within mapped reserves was minimized to the extent 

feasible. In VCUs where managed stands constitute a high portion of the total acres, 

including seral habitat that previously supported high volume stands to the OGR was favored 

if it achieved a more circular shape, maintained connectivity or included rare habitats (e.g., 

karst). 

D. The amount of roads and log transfer facilities within mapped reserves were minimized to the 

extent feasible. 

E. Riparian, beach and estuary habitats were considered as contributing elements to OGRs. 

F. Site-specific factors in placing reserves were considered to help meet multiple biodiversity or 

wildlife habitat objectives. Factors included, but were not limited to: 

1. The largest remaining blocks of contiguous old growth within a watershed. Old-growth 

forest that constitutes scattered fragments of unsuitable timberland generally did not 

contribute to meeting small reserve design. 

2. Rare features such as underrepresented forest plant associations or stands with some 

of the Forest’s highest volume timber stands. 

3. Known or suspected goshawk nesting habitat. 

4. Known or suspected marbled murrelet nesting habitat. 
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5. Important deer winter range to maintain important deer habitat capability to meet 

public demand for use of the deer resource. 

There was no requirement to ensure connectivity among all small OGRs or between small OGRs and 

non-development LUDs (which form parts of large and medium OGRs). POG forest occurring within 

other features of the strategy (e.g., beach fringe, riparian, other non-development LUDs) contributes to 

overall landscape connectivity in the evaluation. It was anticipated that there would be a need to provide 

additional corridors only in rare situations. Medium and large OGRs were designed to provide 

connectivity between other old-growth LUDs and other non-development LUDs. The following 

parameters were used to ensure OGRs maintained connectivity. 

A. Only one connection in one direction was necessary. 

B. The beach fringe serves as a connector. 

C. The connection did not have to be the shortest distance. 

Additional Criteria for the Design of Small OGRs 

This subsection provides a summary of additional criteria that were used in the design and layout of small 

OGRs. 

A. Small OGRs were not required under the following circumstances: 

1. In VCUs where the total acres and acres of POG within non-development LUDs met 

or exceeded the minimum acreage criteria. 

2. In VCUs with a computational allocation of less than 800 acres of POG forest. An 

OGR may have been designed contiguous with old-growth acres in a nondevelopment LUD in an adjacent VCU. 

3. In VCUs that were partially designated as very large, large, or medium OGRs even if 

these did not meet the minimum acre criteria for a small OGRs. In some cases, 

small OGRs have been designated in these VCUs for specific purposes. 

B. Small OGRs may have been designated under the following circumstance: 

1. VCUs that have been separated may have been combined for computational 

purposes. These VCUs are denoted by an integer other than zero as the fourth digit 

of the VCU number (e.g., 5971, 5972, 5973). An OGR was located in at least one of 

these VCUs. In some cases, small OGRs were designated in more than one of these 

VCUs for specific purposes. 

2.2.1.3. Rationale for the Reserve Network 

The mapped system of 150 large and medium HCAs originally designed by VPOP as “one possible 

application of the proposed strategy” was integrated into the Forest Plan through allocation to the OldGrowth Habitat LUD and other non-development LUDs. Spatial modifications to the original VPOP large 

and medium HCAs were made; this is provided for in the VPOP report as long as HCA design criteria for 

size, spacing, and composition are maintained (Suring et al. 1993, p. 30). In their HCA composition 

analysis, Suring et al (1993) also identified limitations in their mapped strategy. Subsequent 

modifications were made to large and medium HCAs to correct limitations. Modifications were made for 

several reasons: 

♦ The original VPOP delineation did not meet minimum HCA criteria (e.g., St. James Bay Large HCA); 

♦ The original delineation incorporated large amounts of fragmented clearcut landscape (e.g., 

Couverden and Kelp Bay large HCAs); 

♦ The original VPOP delineation exceeded minimum criteria (Ratz Harbor, Aaron’s Creek medium 

HCAs); 

♦ The integrity of the original HCA was substantially compromised by recent timber harvest that was 

inconsistent with HCA objectives (Game Creek Large HCA); and 

♦ The reserve location was adjusted to achieve multiple-use objectives such as timber harvest. 
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Even after these modifications, all large and medium HCAs do not precisely match the specific VPOP 

size, spacing and habitat composition design criteria. Based on a detailed analysis of how well the 

original mapped VPOP reserves and the design criteria were integrated into the 1997 Forest Plan 

(Iverson 1997), VPOP found that over 90 percent of the 149 HCAs they mapped forest-wide met the 

minimum spacing criteria, and those that did not were generally isolated islands or within Wilderness 

(Suring et al. 1993, Table 8, 9). Very few HCAs were completely moved (Iverson, 1997); thus the current 

location of mapped reserves is considered in general compliance with the original VPOP design. While 

site-specific compliance is not always perfect, either exceeding or occasionally deficient in VPOP design 

criteria, fine-tuning application of the strategy would take many iterations. As VPOP concluded, “a 

‘perfect’ application of this conservation strategy does not exist” (Suring et al. 1993, p. 35). Furthermore, 

standards and guidelines in the Old-Growth LUD provide for the examination of the size, spacing, and 

composition criteria for each reserve at the project level and provide for necessary adjustments to ensure 

minimum design criteria are met.

Small (1,600-acre) HCAs in each 10,000-acre watershed were recommended by VPOP, to be mapped 

during project implementation. VPOP identified two objectives for small HCAs (Suring et al. 1993, p. 28): 

“to provide temporary functional habitat for animals dispersing between large and medium HCAs and to 

ensure that species of concern have a relatively high likelihood of occurring in each 10,000+ acre 

watershed.” The IDT identified and explicitly mapped the small reserves in the Forest Plan as part of the 

Old-Growth LUD. These small reserves also contribute to the overall landscape matrix outside large and 

medium HCAs (see Section 2.2.2 Matrix Management). Approximately 237 small reserves were mapped. 

These included nearly 267,000 acres of POG forest within a total of 480,000 acres (Appendix 1 to 

Appendix N of the 1997 Forest Plan Revision FEIS). These reserves represent an important component 

of the Forest-wide old-growth habitat conservation strategy. 

The need for larger habitat reserves (larger than provided by VPOP) and minimizing fragmentation, in 

general, and specifically for brown bears and wolves, was a consistent recommendation expressed by the 

Pacific Northwest Research Station Review scientists. The 1997 Forest Plan, in response to 

observations of the Pacific Northwest Research Station Review scientists and management 

considerations contained in the interagency wolf conservation assessment, contained at least one very 

large reserve within each of the 21 biogeographic provinces across the Tongass to address large-scale 

distribution of large OGRs (Appendix 5 to Appendix N of the 1997 Forest Plan Revision FEIS). This 

action was specifically responsive to Lande’s recommendation (p. 81, in Kiester and Eckhardt 1994) of 

one large reserve per province and to other scientist’s concerns that VPOP’s HCAs were too small. A 

quantitative definition of large was not provided in any reference; however, multiples in excess of the 

VPOP large HCAs of 40,000 acres may be considered as ‘large’ (1-2 times as large) or ‘very large’ (3 or 

more times as large). 

The VPOP Response also recommended the following: “it may (emphasis added) also be necessary to 

establish 0.5- to 1-mile buffers around all large and medium HCAs as a “special management zone” 

permitting removal of up to 25 percent of the standing volume in 5-acre units using uneven-aged timber 

management. This recommendation relates to the need for larger old-growth forest reserves. This 

feature has been incorporated into the Forest Plan in a different way than proposed in the VPOP 

Response. As discussed above, at least one very large reserve per province was allocated. 

Furthermore, the VPOP Response recommendation would have permitted substantial harvest (up to 25 

percent) of the expanded area. The Forest Plan protects entire reserves without selective harvest and 

associated additional reduction of old-growth forest. 

Both the Pacific Northwest Research Station Review and VPOP Response expressed concern for 

disproportionate harvest of higher volume old-growth stands. VPOP Response specifically recommended 

(p. 9) that “it is necessary to defer logging and road building in volume class 6 and 7 old-growth forest (as 

determined by field reconnaissance) below 800 feet elevation until a biological survey is completed.” The 

Forest Plan Revision IDT recognized the concern for higher volume stands and took a broader approach 

toward protecting larger reserves and intact landscapes, which necessarily include higher volume stands. 

The IDT did not believe that a focus on protecting small isolated stands of the former volume class 6 and 

7 that may be imbedded within a mosaic of clearcuts, susceptible to windthrow, was a prudent 

management approach to addressing conservation of old-growth associated species. 
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The final component of the reserve strategy addresses potentially endemic taxa (species or sub-species) 

that may exist on small islands. MacDonald and Cook (1994) reported 27 mammalian taxa endemic to 

Southeast Alaska. Many may have limited dispersal capabilities and are restricted to individual islands 

(e.g., Coronation Island vole); some may also be susceptible to loss and fragmentation of old-growth 

habitat. Populations existing on small islands (oceanic or habitat fragments) are more susceptible to local 

extinction (Wilcove et al. 1986, Burkey 1995). The archipelago of Southeast Alaska contains over 22,000 

islands (Iverson 1996b) and uncertain but likely high levels of biotic endemism (MacDonald and Cook 

1994). Lidicker (in Kiester and Eckhardt, 1994, p. 91) identified a concern for small island endemic taxa 

and recommended that no logging occur on islands of less than 1,000 acres to reduce risks to these taxa, 

and further recommended that at least one reserve be maintained on larger islands. The Other Mammal 

Assessment Panel expressed similar concerns relative to endemic taxa (Julin 1996). 

In response to these concerns about endemic taxa with possibly unique gene pools that may be restricted 

to small islands, the Forest Plan protected all islands less than 1,000 acres from additional harvest of oldgrowth forest, in direct response to the Lidicker recommendation and concern expressed by the Other 

Mammal Assessment Panel. 

2.2.2. Matrix Management 

The second component of the old-growth forest habitat conservation strategy is management of the area 

outside reserves (the “matrix”) that is subject to timber harvest. This topic was of notable concern to the 

Pacific Northwest Research Station Review scientists who suggested that more attention be directed to 

this component of landscape conservation planning. They particularly noted the need to provide 

enhanced landscape connectivity and to manage human disturbance of the land similar to natural 

disturbance regimes (Kiester and Eckhardt 1994: Hansen p. 52; Lande p. 82; Lidicker p. 87; McCullough 

p. 109; McClellan p. 133). 

Some management protections within the matrix are spatially explicit, such as the 1,000-foot beach and 

estuary fringe, and the riparian buffers for maintaining the integrity of the aquatic and riparian 

ecosystems. In addition, other forest-wide standards and guidelines preclude or significantly limit timber 

harvest in areas of high hazard soils, steep slopes, karst terrain, visually sensitive travel routes and use 

areas, and in timber stands technically not feasible to harvest. Finally, a number of species-specific 

standards and guidelines provide additional protection to old growth within the matrix. 

2.2.2.1. Beach/Estuary Fringe and Riparian Habitats 

Beach and estuary fringe, and riparian habitats, have special importance as components of old-growth 

forests, serving as wildlife travel corridors, providing unique wildlife habitats, and providing a forest 

interface with marine or riverine influences that may distinguish them as separate ecosystems within the 

larger old-growth forest ecosystem. Riparian areas are important for fisheries in providing, among other 

resources, the source of large woody debris that creates pools for rearing habitat, and in controlling 

stream temperatures and the amount of sediment reaching streams. Riparian areas provide habitat for 

terrestrial species associated with aquatic environments (amphibians, for instance, or mammals such as 

river otter and beaver), and for terrestrial species for which fish from streams are important food (brown 

and black bears). Considering the dendritic nature of riparian systems that begin high in watersheds, 

these riparian areas provide forested corridors connecting higher elevation regions in upper watersheds 

with lower elevation forests in valley bottoms. Riparian areas often contain plant species which can live 

only where water is available year-round. Riparian soils often support large spruce trees and some of the 

most highly-productive stands of old growth. 

The beach fringe, the forested area adjacent to salt-water shorelines, is thought to be an important wildlife 

travel corridor, a transition zone between interior forest and salt water influences, and a unique habitat (or 

micro-climate) in itself. The beach fringe is a very important feature on the Tongass given the extensive 

amount of shoreline (more than 13,000 miles) that exists on the more than 22,000 islands. The beach 

fringe provides horizontal or low-elevation connectivity between watersheds, many of which otherwise 

have very steep sides and/or non-forested ridgetops. In conjunction with riparian areas, which provide 

connectivity within watersheds, the beach fringe is thought to be a component of the major travel corridor 

system used by many resident wildlife species. 
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Interagency habitat capability models developed previously for management indicator species of the 

Tongass produced the highest habitat suitability value in POG forests within the 500-foot beach fringe 

zone for the bald eagle, marten, and river otter (Suring 1993). The beach fringe was rated second only to 

the 1,000-foot estuary fringe for brown and black bears in overall habitat quality, and higher deer habitat 

values generally occur in high-volume old growth below 800-foot elevation, much of which occurs in the 

beach zone with a moderating maritime-influenced microclimate. A revised marten habitat capability 

model rated the beach fringe old-growth forests highest among all habitat components (Flynn 1995). 

There are indications that the value of the beach zone habitat may extend beyond 500 feet. Gende et al. 

(1998) reported reduced bald eagle nesting densities and success in landscapes adjacent to clearcuts 

and recommended a beach buffer zone of at least 1,000 feet. The 1,000-foot beach fringe was also used 

frequently by radio-marked goshawks (Iverson et al. 1996). The importance of the beach fringe zone has 

long been recognized, and was a component of the Retention Factor Method used in the 1979 Tongass 

Plan, as amended (USDA Forest Service, 1986) (specifically recognizing the importance of the 1,000-foot 

beach fringe for brown/black bear, 600-foot for furbearers, and 0.25 mile inland from the beach for deer 

winter range). 

In developing the old-growth forest habitat strategy, the information described above and the available 

literature relative to Southeast Alaska were carefully examined. The Forest Plan Revision IDT concluded 

that explicit corridors should be a component of a landscape conservation strategy, that a 1,000-foot 

beach and estuary fringe corridor was clearly justified by the available information but that no evidence 

supported a 3,300-foot buffer recommended by the VPOP Response. The IDT further reasoned that a 

1,000-foot no-harvest beach and estuary fringe corridor was comparable or possibly superior to a 3,300-

foot corridor that permitted up to 25 percent volume removal in 5-acre patch cuts as recommended by the 

VPOP Response. Accordingly, the Forest Plan establishes a Beach and Estuary Fringe Forest-wide 

Standard and Guideline that prevents timber harvest within 1,000 feet inland from mean high tide. The 

1,000-foot beach fringe serves many functions: providing more effective landscape linkages between 

habitat reserves, protecting long-term bald eagle habitat capability, buffering the primary beach fringe 

zone (0 to 500 feet) from windthrow (Hodges 1982, Harris 1989), maintaining a functional interior forest 

condition within the entire primary beach fringe (Concannon 1995), and sustaining very important habitat 

for goshawks (Iverson et al. 1996). 

In addition, the Forest Plan incorporated, as a minimum, the riparian habitat recommendations in the 

Anadromous Fish Habitat Assessment (AFHA 1995). Riparian habitat buffers also provide elevational 

corridors within forested watersheds. Mapping the small old-growth habitat reserves (see above) also 

provides additional landscape connectivity. Together, the beach and riparian habitat management 

features and the mapping of small reserves represented a substantial response to the landscape linkage 

element of conservation planning and significantly contributed to management of the overall matrix 

among habitat reserves. 

2.2.2.2. Landscape Connectivity Standard and Guideline 

The Forest Plan contains a standard and guideline that provides for the maintenance of a contiguous 

forested corridor, where it exists, connecting each large or medium habitat reserve to at least one other 

reserve. This standard and guideline is to be implemented during the environmental analysis for projects 

proposing to harvest timber, construct roads, or otherwise significantly alter vegetative cover. In addition, 

young-growth treatments to accelerate old growth characteristics to help increase connectivity for wildlife 

are encouraged. 

2.2.2.3. Species-Specific Standards and Guidelines 

A variety of species-specific standards and guidelines were adopted to strengthen the conservation 

strategy for individual species and species groups. Many of these have positive effects for a variety of 

old-growth-associated species. For some species, like the northern goshawk and the American marten, 

additional habitat conservation measures were prescribed in areas of the Forest where intensive timber 

harvest had occurred. 
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Stand level habitat management objectives, that contributed to maintaining features of old-growth forest 

within the matrix, were established in the 1997 Forest Plan Revision to reduce the adverse effects of 

clearcut timber harvest on marten and goshawk habitat use by retaining important forest structure during 

harvest. These habitat management measures were added to the Forest Plan in response to panel 

assessments (see Section III.B). In the North and Central Prince of Wales Biogeographic province, 

where risks of sustaining habitat for goshawks was greatest (Iverson et al. 1996), the 1997 Forest Plan 

Revision standards and guidelines provide for the retention of forest structure during harvest in VCUs 

where over 33 percent of the original POG has been harvested and harvest units are over 2 acres. This 

management standard and guidelines maintains an average of at least 30 percent canopy closure after 

harvest and requires that an average of at least 8 large (20 to 30 inches diameter at breast height [DBH]) 

trees/acre are retained at harvest. The objective of this provision was to retain some foraging habitat 

value after harvest; silvicultural prescriptions that provide for retention were considered to be superior to 

clearcut harvest (Iverson et al. 1996). 

Similar stand level structural retention standards and guidelines in the Forest Plan were established to 

manage high value marten habitat. These standards and guidelines applied to the five higher risk 

biogeographic provinces identified by VPOP (Suring et al. 1993, p. 41) (East Chichagof, 

Kupreanof/Mitkof, Etolin Island and Vicinity (except Zarembo), Revilladagado Island and Vicinity, and 

North and Central Prince of Wales Island). In VCUs within these provinces where over 33 percent of the 

original POG had been harvested, including additional future harvest, high value marten habitat was to be 

managed to retain important forest structure for marten. Harvest units over 2 acres in size in high value 

marten habitat (e.g., high volume timber strata and below 1,500 feet in elevation) retained after harvest: 

an average of over 30 percent canopy closure, an average of at least 8 large trees/acre (20 to 30 inches 

DBH), an average of at least 3 large decadent (20 to 30 inches DBH dead or dying trees) trees/acre, and 

an average of at least 3 pieces/acres of large (20 to 30 inches DBH) down logs. For all other VCUs within 

these five provinces, the following structure was retained in harvest units in high-value marten habitat: 

approximately 10 to 20 percent of original stand structure will be retained with an average of 4 large 

trees/acre (20 to 30 inches DBH), an average of 3 large decadent trees/acre (20 to 30 inches DBH), and 

an average of at least 3 pieces/acres of large (20 to 30 inches DBH) down logs. 

For both the goshawk and marten stand management standards and guidelines above, harvest units 

under 2 acres did not need to maintain any of the prescribed amounts of forest stand structure. However, 

to provide for retention of important forest structure, the effective silvicultural rotation was increased to 

200 years. 

In addition, other fine-filter species-specific standards and guidelines contribute to the old-growth 

strategy. These include standards and guidelines for raptor nest habitat protection, wolf den protection, 

brown bear foraging habitat along certain streams, and others. The major species-specific standards and 

guidelines include: 

♦ Brown Bear Foraging Habitat: Establish forested buffers, where available, of approximately 500 feet 

from the stream at sites where additional protective measures are needed to provide cover among 

brown bears while feeding, or between brown bears and humans. 

♦ Heron and Raptor Nest Protection: Protect active rookeries and raptor nesting habitat with a forested 

600-foot windfirm buffer, where available. 

♦ Marbled Murrelet Nest Protection: Protect identified marbled murrelet nests with a 600-foot radius of 

undisturbed forest habitat. 

♦ Wolf Dens: Maintain a 1,200-foot forested buffer, where available, around known active wolf dens. 

♦ Mountain Goat Travel Corridors and Winter Habitat: Identify and maintain travel corridors between 

important seasonal sites. Where feasible, maintain important mountain goat winter habitat capability. 

2.2.2.4. Other Non-Wildlife Standards and Guidelines 

In addition, although the conservation strategy was designed without consideration of the contribution of 

standards and guidelines that restrict timber harvest to protect resources other than wildlife, there are 

many other standards and guidelines that restrict or limit timber harvest. These other Forest-wide 
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standards and guidelines preclude or significantly limit timber harvest in areas of high hazard soils, steep 

slopes, karst terrain, visually sensitive travel routes and use areas, and in timber stands technically not 

feasible to harvest. 

2.2.3. Analysis of the 1997 Old-Growth Strategy 

Appendix N to the 1997 FEIS presented an analysis of the 1997 Old-Growth Strategy. This analysis 

documented the amount of habitat protection produced by the Forest Plan and compared it with the 

recommendations of VPOP and other recommendations. The following section summarizes this analysis 

(see Section IV.A.6 of Appendix N to the 1997 FEIS for the details). 

2.2.3.1. Amount and Distribution of Old-Growth Forest 

The analysis presented in Appendix N to the 1997 FEIS noted that the first and most prominent feature of 

the old-growth habitat strategy in the 1997 Forest Plan was the substantial amount of POG forest that is 

protected forest-wide in both the reserves and in the matrix areas that are allocated to timber 

management (70.1 percent in reserves and 19.0 percent in the matrix). A total of 84 percent of the POG 

that was present in 1954 was estimated to be present in 100 years assuming the maximum timber 

harvest levels per decade allowed in the 1997 Forest Plan. This is equivalent to an estimated 90 percent 

of existing POG. 

Adequate distribution of old growth habitats, and not necessarily the forest-wide total amounts, was a 

principal element of the VPOP conservation strategy (Suring et al. 1993). The proportion of old-growth 

protected in reserves varied by biogeographic province, but ranged from 38 percent (Kupreanof/Mitkof 

Province) to 100 percent (Admiralty and West Chichagof Provinces). Within protected old-growth forests, 

all volume classes of POG were protected as well. High-volume old growth generally contains the largest 

trees and averages 35,000 board feet per acre (Julin and Caouette 1997). An average of 44 percent of 

the POG in reserves was estimated to be high volume, whereas 43 percent of the old growth forest-wide 

was high volume. The proportion of high-volume old growth in reserves in 18 of 21 provinces equaled or 

exceeded the proportion present in the province as a whole. 

The 1997 Forest Plan exceeded the minimum strategy recommended by VPOP relative to sustaining 

viable wildlife populations. While fully integrating the large and medium VPOP HCAs and the mapping of 

the small reserves, the 1997 Forest Plan protected substantial additional POG forest to further reduce 

risks to wildlife viability and enhance protection of biological diversity. For comparison, reserves allocated 

in the Forest Plan with at least 5,000 contiguous acres of POG (the minimum POG requirement for VPOP 

medium HCAs) exceeded the amount recommended by VPOP by 147 percent forest-wide (Appendix 2 of 

Appendix N to the 1997 FEIS). Old-growth allocated to reserves exceeded the amount recommended by 

VPOP in 20 of 21 biogeographic provinces, ranging from 9 to 460 percent over VPOP recommendations. 

This comparison was conservative: it did not include old-growth forest in contiguous reserves with less 

than 5,000 acres of POG, and did not include the substantial old-growth forest that would remain in the 

matrix. 

The old growth strategy was noted to contain at least one large contiguous reserve relative to the 

province size in each of the 21 biogeographic provinces across the Tongass to address large scale 

distribution of large OGRs (Appendix 5 of Appendix N to the 1997 FEIS). Seventeen of the 21 provinces 

have at least 1 very large reserve (e.g. over 180,000 contiguous acres). For example, in the North 

Central Prince of Wales Province, a contiguous reserve of 200,584 acres (Honker/Sarkar/Karta) was 

provided in the Forest Plan—5 times larger than a VPOP large HCA (40,000 acres). Two provinces had 

a large reserve exceeding 75,000 acres; the two remaining provinces were intermediate sized-islands or 

aggregates of smaller islands and had contiguous reserves of from 30 to 40,000 acres and virtually all 

federal lands within the province were in a reserve land allocation (Dall Island and Southern Outer 

Islands). 

High-quality old-growth forest was mapped in the largest reserves as well. The proportion of high-volume 

old growth (used as one indirect measure of old-growth habitat quality) in the largest reserves was equal 

to or greater than the proportion of high-volume old growth throughout the province in 16 of 21 provinces 

forest-wide (Appendix 5, of Appendix N to the 1997 FEIS). Many of these reserves previously existed 
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(e.g., Admiralty and Misty Fiords National Monuments), while others were explicitly created to achieve this 

objective (South and Central Prince of Wales Island, Kupreanof/Miktof and East Chichagof Island). 

The comprehensive old-growth habitat strategy in the Forest Plan was also responsive to the Pacific 

Northwest Research Station Review recommendation to not further fragment existing blocks of highvolume old growth by incorporating many existing roadless areas in reserves. An average of 89 percent 

(range 55 to 100 percent in each of 21 biogeographic provinces) of the Tongass was roadless (Appendix 

4), an indirect measure of unfragmented (from clearcut harvest) landscapes. An average of 84 percent of 

the roadless acreage on the Tongass was allocated to “non-development” LUDs in the 1997 Forest Plan 

and would, thus, retain the roadless and unfragmented character of the landscape. A substantial portion 

of the Tongass would remain roadless and unfragmented in the Forest Plan 

Additional concerns regarding habitat fragmentation were expressed by the VPOP Response that 

recommended that the three largest old-growth forest patches within each ecological province should be 

protected from logging and roadbuilding. An examination of how well the old-growth strategy in the 

Forest Plan responded to these general recommendations to maintain large blocks of old-growth forest 

was conducted. However, it was noted that there are various ways to define forest blocks or “patches”. 

Without some patch definition restrictions, virtually all old-growth forest on any island could be considered 

one contiguous and interconnected patch. 

Two analyses were conducted to examine the recommendation regarding preservation of large blocks of 

old-growth forest. The first examined the concept of contiguous blocks of interior old-growth forest. 

Interior forest was defined as greater than 300 feet into the forest from the productive/nonproductive 

forest edge. The resulting five largest interior forest blocks in each biogeographic province were 

compared to the Forest Plan land allocations to determine the proportion of these blocks protected in a 

reserve. Forest-wide, 73 percent of the area of these five largest interior old-growth blocks was protected 

for a total of 476,000 acres (Appendix 6 to Appendix N of the 1997 FEIS). A small portion of these acres 

may no longer meet the definition of interior forest acres after the maximum timber harvest levels allowed 

in of the Forest Plan for 100 years are harvested. The proportion varied by province, from 38 percent 

protected in the East Baranof Biogeographic Province to 100 percent on West Chichagof, Admiralty, and 

North and South Misty Fiords Biogeographic Provinces. 

A second analysis examined the largest contiguous blocks of only high volume old-growth forest and the 

proportion protected in reserves in the Forest Plan. Overall, within a biogeographic province, these highvolume blocks were much smaller than the interior forest blocks of all POG (Appendix 6 and Appendix 7 

to Appendix N of the 1997 FEIS). Forest-wide, an average of 83 percent (province range: 36 to 100 

percent) of the five largest contiguous high-volume blocks in each province was protected in reserves for 

a total of 225,000 acres (Appendix 6 to Appendix N of the 1997 FEIS). These first two methods of many 

possible delineations of “large blocks” provided somewhat different results. There was no analysis to 

support the “three largest old-growth forest patches” recommendation—certainly nothing compared to the 

in-depth analysis VPOP contributed in their initial conservation strategy (278 pp.) or the scientific reviews 

provided by the Pacific Northwest Research Station Review 18 scientists (282 pp.). Nonetheless, the 

Forest Plan provides substantial (73 to 83 percent) protection to old-growth blocks considered in this 

analysis. 

Regarding the matrix, it was noted that the allocation of forest stands and landscapes to some form of 

timber harvest did not mean that all trees and stands would be harvested leaving only a continuous “sea 

of second growth.” There are numerous standards and guidelines limiting timber harvest in these matrix 

lands to protect specific resource and landscape components. An average of at least 57 percent 

(Appendix 8 to Appendix N of the 1997 FEIS) of the original (pre-1954) POG in these landscapes (the 

three timber harvest LUDs) would not be harvested and would remain standing throughout the planning 

horizon of 100 years, even with application of the maximum allowable timber harvest under the Forest 

Plan. A total of 69 percent of all existing POG in the matrix would remain after full plan implementation.

The relative quality of habitat within the three principal features of the matrix, the beach and estuary 

fringe, riparian habitat management areas, and other lands not available for timber harvest, are identified 

at both the province and VCU spatial scales. The beach and estuary fringe accounted for 15 percent of 

the POG protected in the matrix; riparian habitat accounted for about 24 percent, and the “other lands” 
Appendix D

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accounted for the remaining 61 percent. As discussed earlier, the proportion of high-volume old growth 

was one measure of habitat quality: the beach fringe averaged 45 percent and the riparian areas 

averaged 43 percent high-volume old-growth forest. 

2.2.3.2. Island Effects 

The potential risk to island endemic species that may be closely associated with old-growth forests was 

evaluated by conducting an analysis of islands of varying sizes (Iverson 1996b). This evaluation revealed 

a very low risk to islands ranging in size from 1,000 to 10,000-acres in Southeast Alaska. It was noted 

that there are 58 islands of this size range, but only 8 had POG forest that was suitable for timber harvest 

in the Forest Plan representing only 2.2 percent of the POG on these islands (Table D-1). However, longterm risk may be elevated on some of these 8 islands considering past as well as potential additional 

harvest (e.g., Shelikof, Sokolof, Marble, and Orr Islands). 

Risks were slightly higher for islands ranging from 10,000 to 100,000 acres, with 7 of 19 having suitable 

POG potentially available for harvest. Heceta Island was identified as the largest island in this category 

(41,000 acres of federal land) with POG suitable for timber harvest. Several of these islands could also 

have elevated risks due to the cumulative effects of past as well as potential additional harvest (e.g., 

Tuxekan, Catherine, Suemez, and Heceta Islands. However, most POG (92 percent) and most 

scheduled for timber harvest (95 percent) occurs on the largest islands exceeding 100,000 acres. The 

Forest Plan wouldl not add additional risk to islands under 1,000 acres and would minimize risks to 

islands under 50,000 acres, with a cumulative maximum of 2,100 acres of old-growth forest that may be 

harvested over the next 100 years. This analysis assumed maximum allowable harvest every decade for 

100 years under the Forest Plan. Furthermore, the analysis assumed a potential harvest of nearly 

600,000 acres of POG, whereas only 474,000 acres are actually scheduled for potential harvest. 

In recognition of the uncertainty about island endemic species and their vulnerability, the Forest Plan 

contained a “survey and manage” standard and guideline designed to substantially reduce the risk to 

endemic mammals on these islands. If surveys indicate the presence of these taxa, proposed projects 

would be designed to ensure their long-term persistence on the island. 

Table D-1. 

Analysis of the Range of Island Sizes across the Tongass National Forest and the Amount 

of Productive Old-Growth at Potential Risk (in 1997)1,2

Island Size3

(acres) 

No. of 

Islands 

Total 

Area 

Total 

POG 

No. Islands 

w/POG Suitable 

for Harvest 

Acres 

POG 

% 

POG 

1995 

Second 

Growth 

1 to 1,000 461 68,807 43,201 0 0 0 3,660 

1,001 to 10,000 58 196,503 95,647 8 2,105 2.2 13,659 

10,001 to 100,000 19 502,271 272,552 7 25,759 9.5 29,710 

Over 100,000 19 16,018,366 4,652,201 18 579,064 12.4 356,440 

Total 557 16,785,947 5,063,601 33 606,928(4) 12.0 403,469 1 From Table 7 in Appendix N to the 1997 Forest Plan FEIS. 2

 The proportion of the POG that is suitable for timber harvest over the next 100 years in the Forest Plan is a measure of relative 

risk to potential island endemic taxa that may be associated with old-growth forests. 3

 Includes only federal lands. 

4

 Only 474,000 (80 percent) of these suitable acres are scheduled for harvest over the 100-year planning period. 

2.2.3.3. Habitat Connectivity 

The analysis in Appendix N of the 1997 FEIS noted that there is general agreement among scientists that 

habitat connectivity is an important component of a landscape conservation strategy (Kiester and 

Eckhardt 1994, Lidicker 1995). There is, however, uncertainty regarding how connectivity should be 

achieved in an integrated conservation strategy: through explicitly designed corridors; by designing larger 

reserves thereby decreasing dispersal distances and facilitating population interchange; or by using an 

overall matrix management design (e.g., the “50-40-11” matrix prescription designed to provide marginal 

foraging habitat between reserves for dispersing northern spotted owls [Thomas et al. 1990]). 
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In light of the uncertainty regarding a variety of approaches to provide landscape connectivity, a further 

review and analysis was conducted by the 1997 Forest Plan IDT. Thus, the 1997 Forest Plan 

incorporated a combination of all three landscape conservation design approaches to address landscape 

connectivity. It has not relied on a single strategy. Beach and riparian corridors of specific widths were 

established that provide significant within-island habitat connectivity; habitat reserves were enlarged (see 

Old-Growth Habitat Reserves above) often minimizing dispersal distances between many reserves; and 

standards and guidelines that govern management of the matrix outside reserves (including beach and 

riparian buffers) were partially designed to contribute to retaining a substantial old-growth forest 

component to provide connectivity. If site-specific project analyses identify deficiencies in landscape 

connectivity, the Forest Plan Old Growth Habitat LUD provided the opportunity to re-examine small 

habitat reserves, which may be adjusted to provide the necessary connectivity (see Small Old-Growth 

Habitat Reserves, below). 

An additional approach to achieve landscape connectivity is to use timber harvest practices that retain 

some forest structure within the stand after harvest. Application of the marten and goshawk stand level 

management standard and guidelines was anticipated to contribute to maintenance of potentially 

important stand structure in landscapes with substantial amounts of even-aged clearcut harvest with little 

within-stand residual structure. The goshawk management standard and guideline was to be applied to 

the most heavily harvested and fragmented VCUs on Prince of Wales Island. The marten standard and 

guideline was to apply in the same VCUs plus additional VCUs in the North Central Prince of Wales, 

Revilla/Cleveland and Vicinity, East Chichagof, Mitkof/Kupreanof, and Etolin and Vicinity provinces. 

Since the marten standard and guideline applied to VCUs that currently exceeded 33 percent of POG 

harvested, as well as VCUs that would exceed that amount through future projects, this standard and 

guideline was anticipated to apply to additional VCUs in the future. Retention of these substantial 

amounts of within-stand structure served to minimize the adverse impacts of additional timber harvest. 

Another feature of connectivity identified by the Pacific Northwest Research Station Review were critical 

links or “pinchpoints” connecting major landscapes within islands (Marcot in Kiester and Eckhardt 1994, 

p. 103). Such pinchpoints must be carefully protected (Kiester and Eckhardt 1994, p. 17). The 1997 

Forest Plan IDT identified six such landscape pinchpoints, all relatively narrow areas between larger land 

units where future alterations in habitat could significantly reduce natural connectivity and limit the ability 

of land-based species to disperse or migrate. These areas and the degree of protection afforded by the 

1997 Forest Plan at the time of its adoption include: 

1. The portage between Tenakee Inlet and West Port Frederick on Chichagof Island is a narrow 

neck of land connecting northeast Chichagof Island to the main body of the rest of the island. 

This is in the East Chichagof biogeographic province. This area is completely protected with a 

large old-growth habitat reserve using the Old-Growth Habitat LUD. 

2. The area connecting Lisianski Inlet with the North Arm of Peril Strait is a narrow region that 

connects two major portions of Chichagof Island. This area is fully protected as a Legislated LUD 

II area. 

3. The area between Port Camden, Bay of Pillars, and Three-Mile Arm on Kuiu Island (Kuiu Island 

biogeographic province), a narrow neck of land connecting the northern and eastern part of the 

island to the rest of Kuiu Island. This area is protected with the Old-Growth Habitat LUD through 

a combination of several adjacent small old-growth habitat reserves. 

4. The narrow area between Lindenburg Peninsula and the remainder of Kupreanof Island is largely 

protected by the Petersburg Creek Duncan Salt Chuck Wilderness. The remaining small area not 

included in the Wilderness between Portage Bay and Duncan Salt Chuck is primarily peatland; 

the 1,000-foot beach fringe provides additional connectivity. 

5. The Neck Lake area between Whale Passage and El Capitan Passage on Prince of Wales Island 

(North Central Prince of Wales biogeographic province) has had significant past and on-going 

forest management activities. It also is a relatively narrow piece of land connecting the extreme 

northern end of Prince of Wales Island to the remainder of the island. A cross-island connection 

is nearly protected with a small reserve around Neck Lake and fully protected further south with 
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the very large natural setting reserve around Sarkar Lakes. Connectivity is also provided on both 

sides of the narrow pinchpoint with the 1,000-foot beach fringe corridor. 

6. Sulzer Portage is between West Arm Cholmondeley Sound and Portage Bay at the head of Hetta 

Inlet on Prince of Wales Island. This relatively narrow neck of land joins the southeast part of 

Prince of Wales Island to the remainder of the island, connecting North Central and South Prince 

of Wales biogeographic provinces. This area has had considerable timber harvesting on both 

national forest and adjacent private lands. Due to a recent transfer of land ownership the area is 

now all private land, dividing the northcentral and south portions of Prince of Wales Island with a 

non-national forest strip 1 to 2 miles wide. Continued timber harvesting is anticipated on these 

private lands, with the potential of creating dispersal barriers. However, clearcuts and advanced 

second growth forests (50 to 100 years old) are unlikely to create complete barriers to movement 

for deer, wolves, marten and squirrels or other species of concern. 

2.2.3.4. Summary 

In summary, the Appendix N analysis noted that the 1997 Forest Plan IDT concluded that the original 

VPOP strategy was a sound and effective landscape approach to address the long-term conservation of 

old-growth associated wildlife species. VPOP used a coarse filter conservation planning approach to 

develop a comprehensive, multi-scale landscape conservation strategy. They incorporated the entire 

community of old-growth associated species into their analysis and focused on those species with the 

greatest viability or distribution concerns in the development of their strategy. Additional scientific 

information, such as conservation assessments and recommendations contained in the Pacific Northwest 

Research Station Review, were incorporated into the Forest Plan to further strengthen the original VPOP 

strategy. The VPOP Response was considered as a brief “initial response” of some possible 

considerations that may have been integrated into a final report. While VPOP Response 

recommendations were not explicitly incorporated, many of the elements of the VPOP Response were 

addressed in concept in the Forest Plan (wider corridors, larger reserves, protection of high-volume oldgrowth, etc.). 

The old-growth habitat conservation strategy in the 1997 Forest Plan was carefully crafted in response to 

these fundamental conservation planning documents. Based upon consideration of the best available 

information related to conservation planning, the Appendix N analysis concluded that the 1997 Forest 

Plan provided a sufficient amount and distribution of habitat to maintain viable populations of old-growth 

associated species after 100 years of Plan implementation. Due largely to uncertainty, the 1997 Forest 

Plan did not, however, represent a “no risk” conservation strategy; rather it represented a balance of 

wildlife conservation measures that consider the best available scientific information and reflect an 

acceptable level of risk for continued species viability. 

2.3. Modifications to the Strategy between 1997 and 2007 

Since 1997, there have been 24 project analyses that have modified small or medium OGR boundaries 

and adjacent LUDs (Table D-2). Overall, these changes have resulted in an increase in reserve area and 

an increase in the amount of POG included within reserves. The net result of these amendments is that 

the acres suitable for timber harvest have been reduced by approximately 16,000 (Table D-2). The 2007 

Forest Plan (defined as the 1997 Forest Plan, as amended through 2007) reflects these changes. 

In addition to these changes in OGR boundaries, a number of ownership adjustments and other slight 

LUD modifications have been made. The combined effect of these changes on the areas within reserves 

and the matrix is shown in Table D-3. This table shows that while the total area of the Forest decreased 

by about 110,000 acres, primarily due to land adjustments, the acreage of development LUDs decreased 

by 112,000 acres and the acreage within reserves increased by about 2,000 acres over the period 1997 

through 2007. 
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Table D-2. 

Summary of Changes in Suitable Acres due to Forest Plan Amendments that Produce the 

2007 Forest Plan1

Project Name (acres) 

Small or 

Medium OGR 

Project 

Year 

Non-dev to 

Dev LUD 

Suitable 

Acres 

Dev to Nondev LUD 

Suitable 

Acres 

Net Change 

in Suitable 

Acres 

Canal Hoya Small 1998 0 151 -151 

Chasina Small 1998 0 78 -78 

Cholmondeley Small/Medium 2003 894 6,873 -5,979 

Control Lake Small 1998 446 142 +304 

Couverden Small 2005 0 790 -790 

Crystal Creek Small 1998 481 1,153 -672 

Doughnut Small 2000 0 19 -19 

Finger Mountain Small 2003 0 593 -593 

Fire Cove Salvage Small 2002 186 633 -447 

Kensington Mine Small 2004 0 1,615 -1,615 

Kuakan Small 2000 416 542 -126 

Luck Lake Small 2000 257 794 -537 

Madan Small 2003 377 1,501 -1,124 

Nemo Loop (Thoms Lake) Small 1998 177 932 -755 

Niblack Small 1998 252 0 +252 

Overlook Small 2006 354 578 -224 

Polk Small Sales Small 2000 0 153 -153 

Salty Small 2000 99 126 -27 

Scott Peak Small 2006 1,089 1,962 -879 

Sea Level Small 1999 185 500 -315 

Threemile Small 2004 458 826 -368 

Todahl Backline Small 1998 2 363 -361 

Tuxekan Small 2006 431 1,614 -1,183 

Woodpecker Small 2003 180 130 +50 

Total 6,284 22,068 -15,784 

1 The 2007 Forest Plan is defined as the 1997 Forest Plan, as amended through 2007. 

 Source: Non-significant Forest Plan Amendment for Tuxekan Project, October 2006 

Table D-3. 

Summary of Acreages in Reserves and Matrix under the 2007 and the 1997 versions of the 

Forest Plan 

Reserves 

Alternative 

Old-Growth 

Habitat LUD 

Other NonDevelopment 

LUDs 

Total in NonDevelopment 

LUDs Matrix Total 

Percent of 

Forest in 

Reserves 

2007 Forest 

Plan1/ 1,182,424 11,985,410 13,167,834 3,605,974 16,773,808 78.5% 

1997 Forest 

Plan2/ 1,131,059 12,034,860 13,165,919 3,717,081 16,883,000 78.0% 

1/ Based on the 2007 Forest Plan (defined as the 1997 Forest Plan, as amended through 2007) and Tongass GIS. 2/ Based on 1997 Forest Plan table on p. 4-2 and Table 3-77 of 1997 FEIS. 

Table D-4 summarizes the POG acreage in reserves and the matrix for the 2007 and 1997 versions of the 

Forest Plan. The 2007 acreage of POG within OGRs, including all non-development LUDs is 3,518,425, 

which represents 71.1 percent of all POG on the Forest (Table D-4). Within the matrix, there is an 

additional 925,051 acres of old growth (18.7 percent) that is protected within the Beach and Estuary 

Fringe, Riparian Management Areas, and other unsuitable areas. This estimate includes unsuitable 

areas that are not yet mapped (e.g., Riparian Management Areas along unmapped streams, unmapped 

unstable slopes, unmapped high vulnerability karst lands). Finally, there is an estimated 28,598 acres of 
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D-19

POG that is suitable, but would not be scheduled due to economics and other factors. As a result, the 

2007 Forest Plan results in the protection of 90.3 percent of all existing POG on the Forest, assuming the 

full Allowable Sale Quantity (ASQ) is harvested each decade. Table D-4 also compares these acreages 

and percentages with the same acreage categories in 1997, at the time that the Forest Plan Revision was 

adopted. 

The maximum percentages that could be harvested are similar between the 1997 Forest Plan and the 

2007 Forest Plan when one looks at only the larger POG types. Under the 2008 Forest Plan, a total of 

71.3 percent of the high-volume POG (SD Model types 5N, 5S, and 67) and 67.8 percent of the big-tree 

POG (SD Model type 67) would be included within reserves. Overall, 88.9 percent of the existing highvolume POG and 88.6 percent of the big-tree POG would not be harvested. 

Table D-4. 

Summary of Productive Old-Growth Acreage in Reserves, Protected in the Matrix, and 

Suitable for Timber Harvest in 2008 

Year 

POG Area in 

Reserves 

Matrix POG 

Protected or Not 

Scheduled for 

Harvest 

Matrix POG Suitable and 

Scheduled for Harvest 

(represents the maximum 

POG to be harvested) 

Total 

Existing 

POG1/

2007 Forest 

Plan2/ (acres) 3,518,425 970,176 462,556 4,951,156 

2007 Forest 

Plan2/ (percent) 71.1% 19.6% 9.3% 100.0% 

1997 Forest 

Plan (acres) 3,551,482 1,038,492 473,597 5,063,5712/

1997 Forest 

Plan (percent) 70.1% 20.5% 9.4% 100.0% 

1/ Note that the Tongass land base has changed since 1997 due to land adjustments and harvest has occurred. 2/ The 2007 Forest Plan is defined as the 1997 Forest Plan, as amended through 2007. 

Sources: Table 3.9-12 in Biodiversity Section for 2008 numbers; Appendix N to the 1997 Tongass FEIS and Appendices to 

Appendix N for 1997 numbers.

2.4. New Relevant Science since 1997 

This section describes new information related to conservation planning and science developed since 

1997. It summarizes general information on conservation strategies, as well as species-specific 

information that are particularly relevant to the Tongass Conservation Strategy. 

2.4.1. Conservation Strategies 

2.4.1.1. General 

Haufler (2006) conducted a comprehensive review of conservation science produced since 1997 and its 

relationship to the Tongass Forest Plan. In his review, he described major types of conservation 

strategies, as well as concepts that form the basis for those strategies (e.g., landscape ecology, corridors 

and landscape linkages, and habitat loss and fragmentation) and related new science (new science 

related to population viability was also addressed but is summarized in Section 3.0), and related these to 

the science behind the Tongass Conservation Strategy. This effort included a review of recent literature 

as well as recently completed and on-going conservation initiatives to identify approaches and strategies 

used by agencies and other organizations in their conservation planning efforts. This section provides a 

summary of that review. 

The term “conservation strategy” refers to the framework and the underlying basis and assumptions used 

in planning to maintain or enhance biological diversity (Haufler 2006). Most conservation strategies share 

the common objective of conserving biodiversity, which has been succinctly defined by the United Nations 

Environment Programme (1991) as: “the variety of and variability within and among living organisms and 

the ecological complexes of which they are part; this includes diversity within species, between species, 

and of ecosystems.” To do so, the concepts of representation (i.e., addressing the range of 
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environmental conditions in the planning area), resiliency (i.e., being capable of withstanding natural and 

human-caused changes in the environment), and redundancy (i.e., consisting of a sufficient number of 

areas to withstand larger scale stochastic events) have been emphasized as being important in 

delineating effective reserve designs (Shaffer and Stein 2000). 

Conservation strategies can be distinguished based on whether they take a coarse filter or fine filter 

approach to conserving biodiversity. Coarse filter strategies focus on ecological communities or 

functional ecosystems where planning incorporates an appropriate mix of ecosystems that will maintain or 

enhance biological diversity and ecosystem integrity within a landscape (Haufler 2006). Recent 

approaches that form the basis of coarse filter strategies include the habitat diversity approach (i.e., 

maintaining or restoring adequate amounts of existing vegetation communities; Groves (2003), the 

historical reference approach (i.e., prioritizing conservation efforts based on a comparison of existing and 

historical conditions; Haufler 2000, Poiani et al. 2000), and the historic range of variability approach (i.e., 

maintaining the landscape within the historic ranges of variability; Aplet and Keeton 1999). However, 

there is little agreement on how to apply coarse filter approaches, with few examples of well designed 

coarse filter initiatives. 

In contrast, fine filter conservation strategies focuses on species or groupings of species to address the 

ecological objective of maintaining the species or groupings of species within a landscape. Fine filter 

approaches include the use of umbrella species, indicator species, keystone species, flagship species, 

ecological engineers, focal species, declining species, at-risk species to represent other, co-occurring 

species. Groves (2003) and Noon and Dale (2002) provide an overview of these species-specific 

approaches. Under a fine filter strategy conservation areas are often identified using indices such as 

species richness, species diversity, or are based on biological hotspots, with the objective of protecting 

the maximum number of species (Chaplin et al. 2000). However, there is generally poor support in the 

literature for the fine filter approach because of the difficulty in identifying appropriate species to serve as 

surrogates, or whether this is even possible (Carignan and Villard 2002), and the inability of this approach 

to adequately represent all levels of biodiversity (e.g., landscape and ecosystem levels; Schwartz 1999, 

Chaplin et al. 2000, Groves 2003). 

A central element in conservation planning, as indicated above under the two basic frameworks for 

conservation strategies, is the identification of conservation areas such as reserves or reserve networks. 

Conservation strategies may differ in their view of conservation areas, with some placing priority on their 

protected status (e.g., wilderness) such that they are kept separate from human influence (i.e., a 

compositionalism viewpoint; Callicott et al. 1999), with others emphasizing the functional capabilities of 

protected areas which may include working landscapes (the functionalism view; Callicott et al. 1999; 

Haufler et al. 1990, 2000). Though the latter view recognizes that reserves are an important tool for 

conserving biodiversity, it strives to balance human and conservation needs and focuses on providing 

functional ecosystems. 

Another element that distinguishes conservation strategies is their primary focus. That is, whether they 

are concerned with rare or declining species or ecosystems or with representation of all species or 

ecosystems (Haufler 2006). A rarity focus typically devotes funding and effort to the identification of rare 

or declining elements (e.g., old-growth forest) and the protection of these elements in reserves. A 

representation focus strives to maintain the full spectrum of ecosystem elements (i.e., all forest structural 

stages) in adequate amounts and distribution across the planning landscape. 

Haufler (2006) noted that most conservation strategies combine many of the approaches described. This 

more comprehensive approach to conservation planning enables the testing of the effectiveness of each 

plan element (e.g., implementing a fine filter approach to test the effectiveness of the coarse filter 

approach; Haufler 1999, 2000) and also addresses the shortcomings of any one strategy or view point. 

2.4.1.2. Landscape Ecology 

Landscape ecology and the associated concepts of scale, landscape effects, and habitat networks, have 

also received considerable attention in recent literature and have become a fundamental part of 

conservation planning. At the landscape scale, the influence of spatial arrangements, amounts, and sizes 

of habitat patches in landscapes, and the relationships of these factors with ecological processes are 
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important advances (Turner 2005, Freemark et al. 2002). Both the grain (patch-based versus landscapebased) and extent (delineation of planning areas) of landscape analyses have been identified as critical 

elements in conservation planning, as they influence the results and implications of modeling efforts 

(Bassett and Edwards 2003). 

2.4.1.3. Landscape Linkages and Corridors 

Since the 1990s, a common element of conservation planning has been to ensure that adequate 

connectivity between habitat reserves is maintained to facilitate movement across the landscape and thus 

exchange between populations. Traditionally, connectivity has been viewed in the form of structural, 

often linear, elements of the landscape (i.e., riparian buffers) that literally act as corridors through which 

species move between larger habitat patches within the surrounding matrix. However knowledge of 

species ecology and dispersal capabilities, coupled with new understanding of landscape ecology, has 

broadened this view to include linkage zones, or areas within the landscape that may not physically 

connected but include appropriate habitat elements that provide functional connectivity (Tischendorf and 

Fahrig 2000). Landscape linkages address movement capabilities, habitat patches, landscape 

configurations, matrix conditions, barriers, and their ability to maintain continuous populations (Haufler 

2006). 

2.4.1.4. Habitat Loss and Fragmentation 

Numerous recent empirical studies have evaluated the effects of habitat loss and fragmentation on a 

variety of species. Results of these studies indicated that 1) habitat and fragmentation are not 

independent, with the degree of habitat fragmentation influencing the magnitude of direct effects from 

habitat loss (Goodsell and Connell 2002); 2) fragmentation and resulting distribution of remaining habitat 

is of primary concern in managed landscapes where there has already been substantial habitat 

loss/conversion (Freemark et al. 2002); 3) interior and specialist species, as well as those that are rare or 

isolated will be the most affected by habitat loss and fragmentation (Bender et al. 1998, Davies et al. 

2000), 4) habitat conversion may benefit some species (McGarigal and McComb 1999); 5) the amount 

and configuration of remaining habitat were influential in the landscape occupancy (Villard et al. 1998, 

McIntyre and Wiens 1999, Radford 2005); 6) the quality of remaining habitat may be more important than 

the quantity (Braden et al. 1997). Notably, studies evaluating the effects of fragmentation in various 

landscapes indicated that some of the negative effects of fragmentation on vertebrates observed where 

ecosystems have been converted to urban or agricultural uses have not been found in landscapes where 

timber harvest is the primary land use (Freemark 2002) 

Theoretical studies have also been conducted that provide some insight on how the effects of habitat loss 

may operate. With (1999) described two perspectives that have resulted from these efforts. One is 

based on the theory of island biogeography where the objective is to identify the appropriate distribution 

of habitat patches which are compared to island surrounded by a matrix of non-habitat. The other is 

based on landscape permeability and the ability of species to move through the landscape (dispersal 

abilities), and views that landscape as a mosaic consisting of a spatially complex variety of habitat 

conditions. 

The issue of habitat adequacy, or the threshold at which the amount of remaining habitat is insufficient to 

facilitate species persistence, has also been the subject of recent research. Risks of extinction tend to 

display non-linear responses as the effects of habitat fragmentation increase (With and King 1999, 

Flather et al. 2002). Under theoretical studies, threshold effects of habitat loss have been noted at 60 to 

80 percent (Flather et al. 2002, Fahrig 1997). However, empirical studies have found the adequacy 

question difficult to isolate because of complexities in landscape mosaics, matrix conditions, temporal 

changes, and the various habitat needs of different species. Empirical studies note species losses 

typically above a 90 percent threshold (Radford and Bennett 2004, Virkkala and Toivnen 1999). 

2.4.1.5. Relationship to the Tongass Conservation Plan 

The conservation strategy was described as a “habitat-based wildlife conservation strategy that employed 

old-growth associated umbrella species to design a coarse filter/fine filter approach for species 
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D-22

conservation” (Haufler 2006). Based on Haufler’s (2006) review, the science underpinning the Tongass 

conservation strategy is supported by recent literature. New information suggests that additional 

consideration of windthrow effects, which may occur at greater magnitudes than once thought (Kramer et 

al. 2001) and have farther reaching effects on habitat selection of some species (DeGayner et al. 2005), 

and a finer scale analysis of the distribution of plant associations (e.g., VanHees and Mead 2005) may be 

warranted to enhance the existing coarse filter component of the conservation strategy (Haufler 2006). At 

this time, plant association mapping for the Tongass does not exist, and the development of such 

mapping would be an enormously expensive undertaking. In lieu of evaluating how representative are 

the reserves based on plant associations, ecological subsection and biogeographic province mapping 

was used in conjunction with old-growth types as a surrogate. Likewise, a finer-scale assessment of 

viability for some species, particularly endemics (see Wildlife section for discussion of new science 

related to endemism on the Tongass) may be warranted to ensure the coarse filter component of the 

conservation strategy is meeting the needs of all species, including those that are rare or occupy limited 

distributions (Haufler 2006). However, Haufler (2006) concluded that “the developments in the field of 

conservation science produced since 1996 indicate that the conservation strategies used in the plan are 

still valid at the present.” 

In April 2006, an Interagency Conservation Strategy Review workshop was held to review the Tongass 

Land Management Plan conservation strategy in light of new information since 1997 (USDA Forest 

Service 2007). The objectives of the workshop were to: 

1. Facilitate robust discussion between an interagency workgroup and invited scientific and 

technical experts regarding new information attained since 1997 that may be relevant to the 

conservation strategy; and 

2. Generate and discuss science-informed “Considerations” relative to the strategy.“ 

Considerations included identification of the need to attain additional information or conduct additional 

analysis regarding a scientific question or issue, the need for change to the conservation strategy, or 

other investments or work. The workshop included technical presentations regarding recent and current 

studies on species and species groups of concern on the Tongass. A broad conclusion of the workshop 

was that the conservation strategy continues to be supported by science (USDA Forest Service 2007). 

Although the information presented emphasized that there is still uncertainty associated with managing 

wildlife habitat on the Tongass, the new information presented has increased our knowledge of 

species/habitat relationships, reinforced the idea that retaining old growth in a system of Forest-wide 

reserves is appropriate for many species, and reiterated that having a very conservative approach to 

conservation of old-growth-associated species is still warranted and supported by science. 

2.4.2. Species-Specific Science 

This section presents a summary of the new information for individual species that is relevant to the 

Tongass Conservation Strategy, with focus on those species that are directly relevant to proposed 

changes to the Conservation Strategy. The majority of this information was presented at the April 2006 

Interagency Conservation Strategy Review workshop and is summarized in a report (USDA Forest 

Service 2007). Reference to this information, as well as more complete discussion of this new 

information, can be found throughout the Wildlife section in Chapter 3 of the FEIS. This section 

summarizes the key highlights of information with particular focus on goshawk and marten, since these 

two species have specific standards and guidelines amended. 

2.4.2.1. Northern Goshawk (including the Queen Charlotte goshawk subspecies) 

The results of 10 years of research on the Queen Charlotte goshawk in Southeast Alaska were 

summarized at the Conservation Strategy workshop (Flatten et al. 2001,2002; Lewis 2005; Lewis et al. 

2001, 2006 ). This research was in various studies, some of which is published and some of which is 

available in agency reports. A total of 69 adult goshawks (37 females and 32 males) were radiotagged 

from 1992 to 2001. Using 2-year and 1-year tags on females and males, respectively, greater than 2,800 

relocations were recorded over approximately 500 km2

 of the Tongass National Forest. 
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Nest trees are typically found in the largest trees available relative to the nest stand. Basal area was 

higher at the nest tree (> 60 percent) than the surrounding stand (< 60 percent). Aerial photo analysis 

also showed a difference between the amount of forest, productive forest, and canopy cover at the nest 

site versus random sites; however, although it was statistically significant, it may not be biologically 

significant. Eighty-nine percent of the 63 nest sites evaluated had multi-storied canopies. 

Two large spatial scales (816 ha and 2,088 ha) were used to provide a summary of the vegetation 

surrounding 78 known nest sites based on GIS analyses. POG on NFS land represented 37 to 40 

percent of the circular areas around these nest sites on average, followed by unproductive forest on NFS 

land at 24 percent, and NFS young growth at 9 to 10 percent. Nonforest on NFS land made up 5 percent 

and non-NFS land and saltwater made up the remaining 23 to 25 percent (see EIS planning record). 

Sixty-eight to 70 percent of the POG on NFS land inside the circles was protected in reserves or in the 

matrix. Use by adult males and females during the nesting and non-nesting season showed a 

consistently higher use of POG forest in proportion to availability. Habitat use of the 1,000-foot beach 

and estuary buffer was higher for females than for males during nesting and non-nesting seasons and 

peaked again at approximately 3,000, and 4,000 feet from the beach fringe. 

Using the same approach discussed above, a hypothetical post-fledging area (PFA) was developed using 

a radius centered on a nest site and determined by the mean distance moved by northern goshawk 

juveniles (approximately 1,500 m) from the nest. Based on habitat categories of suitable (medium- and 

high-volume old growth), low-volume old growth, harvested, and nonproductive forest, approximately 45 

percent of the mean PFA was in nonproductive forest, followed by suitable habitat (39 percent), lowvolume old growth (8 percent), and harvested (4 percent). Results of this hypothetical PFA analysis 

indicate that about 40 percent of the PFA on average will be medium- or high-volume POG, of which 55 

percent was in a Timber LUD or non-NFS lands. 

Adult goshawk home ranges were large, much larger than most other home ranges documented in North 

America. Median home range sizes ranged from 3,900 ha to 11,800 ha for adult females during the 

nesting and non-nesting season, respectively. Male home ranges were slightly larger in size ranging from 

4,300 ha to 11,900 ha during the nesting and non-nesting seasons, respectively. 

Movements by nesting pairs within a territory between year 1 and year 2 ranged from 0.1 to 3.2 km with 

the majority (67 percent) moving less than 0.4 km. Female goshawks tend to move much greater 

distances between nests in sequential years than males with approximately 35 percent of females leaving 

their nesting area, re-pair, and nest in a new area the next year. However, of 24 nesting territories, 54 

percent remained within 0.36 km radius of the previous years nest and all movements were within 3.2 km 

of the nest site. Nesting pairs split up more often and between-year nesting dispersal of adult female 

goshawks is much higher than anywhere else they have been studied in detail in North America. 

The diet of goshawks in Southeast Alaska is dominated by a few key prey (grouse, medium-sized birds, 

and red squirrels, where present). Prey rich areas include the northern half of the Tongass National 

Forest, where blue grouse and red squirrel are the dominant prey items taken. On Prince of Wales Island 

(POW) and other islands where sooty grouse and red squirrel are not present, spruce grouse, Steller’s 

jay, and ptarmigan are the dominant prey items taken. Small mammals make up a small portion of the 

overall diet in this area. Ten nests were monitored as part of the study and of all food deliveries to the 

nest, 78 percent of the goshawk diet in Southeast Alaska consisted of bird species, with grouse the most 

commonly delivered prey item. From a broader diet pattern using stable isotope and prey associations, 

forest-dwelling prey items are, not surprisingly, dominant, but there is also a component of tidal and 

wetland prey species in their diet. 

Recent studies confirm the importance of management for prey in relation to goshawk productivity 

(Kenward 2007). Salafsky et al. (2007) recommend that goshawk management strategies incorporate 

forest management practices that increase the abundance and diversity of available prey resources. The 

differences in prey species abundance and distribution across the Tongass may help explain some of the 

variation in productivity, territory size and nest site selection (Lewis et al. 2006, see also compiled 

information in U.S. Fish and Wildlife Service 2007). 
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In a review of over 180 publications on goshawk habitat relationships, Reynolds (2004) reported that, 

although goshawks predominantly nest in mature and old-growth forest characterized by closed-canopy 

stands of large, dense trees, there is considerable variation in nest sites among populations, with 

goshawks in Oregon and Nevada nesting in stands with canopy cover as low as 31 percent. Reynolds 

(2004) also reported that outside of the nesting season, the variation in habitats used by goshawks is 

even greater (multiple forest age classes, edges, and openings) and is apparently related to differences 

among habitat in prey abundance and availability (i.e., goshawks may nest or forage more often in habitat 

where prey is more abundant). Reynolds (2004) concluded that the main factors limiting goshawks were 

habitat structure for both nesting and foraging (rather than composition) and prey. This idea was also 

demonstrated by Reynolds et al (1992) who used a food web-based, ecological approach to develop 

forest management recommendations for goshawks in the Southwest United States. Taking into account 

both goshawk habitat requirements and the habitat requirements of 14 of their prey species, Reynolds et 

al. (1992) recommended that no more than 60 percent of a desired landscape of goshawk and prey 

habitats consist of mature to old-growth forests, and that post-fledging family areas (i.e., the area 

immediately surrounding the nesting area) should include habitat attributes important to prey species, 

including snags, downed logs, woody debris, large trees, openings with herbaceous and shrubby 

understories, and an intermixing of forest vegetative stages. Reynolds et al. (2006) concluded that 

management prescriptions based on the ecology (e.g., composition, structure, pattern, and dynamics) of 

a forest ecosystem, is a more appropriate basis for developing desired forest conditions that support 

goshawks and their prey. 

Management recommendations for goshawks have been incorporated into multiple Forest Plans across 

the United States. Many of these are based on Reynolds et al. (1992), which includes recommendations 

for goshawk habitat for a variety of spatial scales, including nest sites and post-fledging family areas. 

These recommendations are specific to habitats in the southwestern United States, though they have 

been used in other geographic areas. While information from these studies regarding goshawk habitat 

relationships is useful across a broad geographic areas, specific recommendations for standards and 

guidelines is less useful. Because of significant differences in habitat and the extent of human influences 

on natural processes between Alaska and the Southwest, specific management prescriptions have limited 

applicability to Southeast Alaska. 

In addition to these findings, limited new research has shown goshawk use of young-growth stands. 

Although POG is still considered the optimal nesting habitat for this species, non-productive forest types 

and second-growth stands are also used by goshawks for movement and foraging (and sometimes 

nesting), emphasizing the importance of matrix lands in goshawk management (McClaren 2004, Boyce et 

al. 2006, Reynolds et al. 2006). Some nests have been found in maturing second-growth (previously 

harvested) stands (Bosakowski et al. 1999, McClaren 2003). On Vancouver Island, most second-growth 

stands supporting nests were 60 to 80 years old, and suitable structure was apparently achieved in as 

little as 50 years (McClaren 2003). Additionally, Doyle (2004b) found that blue grouse, an important prey 

species for goshawks on the Queen Charlotte Islands, selected stands with more open canopies 

indicating that there may be a threshold below which timber harvest would not adversely affect grouse, or 

goshawks as their predators. On Douglas Island in Southeast Alaska, goshawks have been observed to 

nest in 80-90 year old stands (Kim Titus, Alaska Department of Fish and Game. pers. comm., 2007). 

Management of the nest stands around known goshawk nests continues to be an important factor in 

goshawk conservation; some Forest Plans incorporate management of an area around the nest for 

fledglings (USDA Forest Service 2006). With respect to nest site management, Reynolds et al. (1992) 

recommended nest buffers of 30 acres, with maintenance of at least 3 known nests and 3 replacement 

nests (totaling 180 acres) within a 600 acre post-fledging family area. Thus, they recommend that 30 

percent of the post-fledging family area should be retained for nesting habitat, with rest in a variety of 

successional stages. Management for goshawk nests is complicated by the difficulty in finding nests, 

particularly in the remote terrain of Southeast Alaska, where detection rates appear to be lower than in 

other areas (U.S. Fish and Wildlife Service 2007). Goshawks often have multiple alternate nests within a 

territory, which further complicates management of nest sites (USDA Forest Service 2007). Recent 

research in the southwestern U.S. confirms the difficultly in managing for goshawks only at the nest scale 

because detectability of goshawks is highly variable among individuals as a result of extensive year-toyear and spatial variation in breeding. Goshawks do not always nest every year, often skipping nesting 
Appendix D

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D-25

for one or more years; this behavior is most likely due to prey abundance and availability (Reynolds et al. 

2005). 

2.4.2.2. American marten 

Several new studies and concerns related to the conservation of marten were presented at the 

Interagency Conservation Strategy Review: An Assessment of New Information Since 1997 in April 2006 

(USDA Forest Service 2007). Marten experts reviewed and summarized new information relevant to 

Tongass management issues. New information was presented relative to the level of endemism in 

marten on the Tongass. Preliminary molecular analyses distinguish two lineages of marten and indicate 

that they have very different evolutionary histories (Stone and Cook 2002, Small et al. 2003, Cook et al. 

2006). The two lineages (americana and caurina) are considered by some to be two species, but have 

not been formally identified as such. The caurina lineage is known to inhabit only two islands within the 

archipelago (Admiralty and Kuiu Islands; Cook et al. 2006). There are two contact zones (i.e., zones 

where the lineages coincide) in North America, one in Southeast Alaska and one in Montana (Cook et al. 

2006). In addition, there are records that marten were introduced on many islands in Southeast Alaska in 

including Prince of Wales, Baranof, Chichagof and nearby smaller islands (MacDonald and Cook 2007). 

The authors speculate that the endemic lineage of marten (caurina) may have occurred on more islands 

than Kuiu and Admirality and may have been extripated by introductions of americana. 

Between 1990 and 1998, studies were conducted on Chichagof Island to assess marten habitat selection 

at multiple scales, demographics, diet, and prey availability. Results indicated that marten numbers 

fluctuated greatly over time in response to food availability and trapping mortality (Flynn et al. 2004). 

Habitat requirements reflect a strong interaction between food, cover, climate, and predation, with forest 

cover being particularly important for travel, dens and resting sites, hunting and avoiding predation, and 

staying dry. Martens selected forest stands with increasing amounts of structure (e.g., selected stands 

with a greater number of large trees and multiple stories); with stronger selection occurring in winter. 

Important habitat features included large logs and stumps in decay classes 4 and 5 and the bases of 

large live trees, which they use for dens and resting sites. Habitat data were consistent with the Forest 

Plan definition of high value marten habitat. 

Several studies have indicated that marten are sensitive to fragmentation (Hargis et al. 1999, Flynn et al. 

2004). Based on metapopulation theory, spatially isolated populations will persist in suitable habitats if 

regularly recolonized (Ruggiero et al. 1994). 

To determine whether the results of the Chichagof Island studies were applicable across the Tongass, 

eight study areas in Southeast Alaska were established between 2001 and 2003, representing different 

marten populations (Flynn et al. 2004). Hypotheses include 1) marten abundance is greater than or equal 

to 25 marten per large OGR (which was an assumption for the Forest Plan Conservation Strategy) and 2) 

marten densities would be greater on areas with habitat composition similar to OGRs, but with more 

diverse and abundant food resources. 

This study indicated that only the Chichagof Island site had abundance estimates of greater than 25 

females per OGR and only the Point Couverden and Thomas Bay sites had upper confidence intervals 

greater than 25 females per OGR. A large variation in small mammal abundance was observed, with 

long-tailed voles only abundant on Chichagof Island, Keen’s mice common except on the mainland, and 

red-backed voles occupying a limited distribution but numerous where they occurred (e.g., Etolin Island, 

Point Couverden, Thomas Bay, and Yakutat). Marten fed on long-tailed voles when they were available, 

and generally avoided Keen’s mice and red-backed voles. However, when vole numbers were low, 

marten switched to salmon. Marten numbers were best predicted by long-tailed vole abundance (positive 

correlation) and Keen’s mice abundance (negative correlation); red-backed voles were not a significant 

factor. The ungulate index was marginally significant and fragmentation indices were correlated with 

marten density. 

Based on these results, marten experts at the Conservation Strategy Review concluded that the OGR 

system appears to be an appropriate model for marten conservation, though they felt that management 

needed to be tailored to specific island populations (Cook and McDonald 2001, Cook et al. 2001). They 

believe that OGRs may not provide enough habitat in themselves to maintain healthy populations and 
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D-26

additional conservation measures may be necessary, such as managing matrix lands as productive 

habitat and maintaining corridors between OGRs (Flynn et al. 2004). Studies of marten home ranges 

have shown that they encompass areas of timber harvest and roads, elevating the importance of matrix 

management in providing functional connectivity across the landscape for marten (Flynn et al. 2004). 

Studies on Mitkof Island indicated that martens selected for POG and used a wide variety of POG types 

but used some clearcuts 26 to 40 years of age; on Mitkof these clearcuts where characterized by 

abundant understory forage and small mammals (Flynn et al. 2004). Home ranges of marten were well 

distributed across the landscape and included areas with timber harvest and roads. Although they 

selected against it, they seemed to readily travel across areas of noncommercial forest as well as POG 

and clearcuts with established conifer cover. Prey quality and quantity appear to be very important in 

predicting marten abundance and distribution. 

2.4.2.3. Other Species 

Research has also identified new endemic species, and refuted species thought to be endemic. 

Regardless, changing the list of endemic species considered by the panel assessment would not change 

the fact that they occupy limited distributions and some are sensitive to habitat conversion related to 

timber harvest. However, new science is continuing to emphasize the importance of the Alexander 

Archipelago as a center for endemism from a global perspective (Cook and MacDonald 2001, Cook et al. 

2006). 

Recent research on small endemic mammals in Southeast Alaska has focused on documenting 

distribution and increasing information regarding genetic variation. There has been little work, except for 

marten and flying squirrel, directed at habitat relationships. Therefore, while we know more about 

endemic mammalian abundance and distribution across the Tongass, there is not much additional 

information to support significant changes to the Conservation Strategy for endemic mammals. 

Recent analyses presented at the Tongass Conservation Strategy Review Workshop (2006) updated the 

relationship between road density and wolf mortality related to legal and illegal hunting and trapping. This 

analysis was based on a regression analysis of average wolf harvest by Wildlife Analysis Area (WAA) 

between 1990 and 1995 against total road density for lands below 370 m elevation. Results presented 

the probability of an overkill (average harvest of greater than 30 percent of the population) or destructive 

harvest (harvest greater than 90 percent of the population occurring once between 1985 and 1999) of the 

wolf population on Prince of Wales Island, taking into account road density and whether the road system 

was connected to a main road system with access to a ferry. Results indicated that the probability of 

overkill for WAAs with road density greater than 0.7 miles per square mile at 40 percent, if the WAA is 

connected to a main road system and 13 percent if not. Results also indicated that 32 percent of WAAs 

on Prince of Wales Island had road densities indicative of a high probability of overkill and 52 percent had 

road densities indicating a high probability of having had at least one destructive harvest between 1985 

and 1999. These results indicated that roads exerted a strong influence on wolf mortality, particularly 

when connected to main road systems. However, it is important to note that roads themselves do not 

decrease habitat capability for wolves, but increased density of roads may lead to higher hunting and 

trapping mortality through improved human access. There are other methods available to address 

unsustainable hunting and trapping mortality including changes to both State and Federal hunting and 

trapping regulations and increased enforcement. 

2.5. Modifications to the Strategy under 2008 Forest Plan 

Amendment 

The comprehensive science-based conservation strategy included in the 1997 Forest Plan is a 

scientifically sound foundation from which to base management decisions. Its system of large, medium 

and small OGRs across the Forest was implicitly designed to assure well distributed, viable wildlife 

populations. Alternative 5 of the 2008 Forest Plan Amendment Final EIS maintains the 2007 Forest Plan 

(1997 Forest Plan, as amended through 2007) old-growth conservation strategy, as described in Sections 

2.2 and 2.3. Alternatives 1, 2, 3, and 6 of the 2008 Forest Plan Amendment Final EIS retain the main 

components of the conservation strategy (i.e., the OGR system and non-development LUDs, the beach 
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D-27

fringe, riparian buffers); in addition, they expand the areas within the Forest-wide reserve network and 

incorporate some modifications to the standards and guidelines. This section describes the differences 

between the 2007 Forest Plan’s conservation strategy, as represented by Alternative 5, and the 

conservation strategy proposed under Alternatives 1, 2, 3, and 6. 

Alternatives 4 and 7 differ from the other five alternatives in that they eliminate or modify significant 

portions of the conservation strategy and these are also addressed in this section and compared with 

Alternative 5 as well as the 1997 Forest Plan. Alternative 4 modifies the coarse filter component by 

identifying Old-Growth Habitat LUDs in only four of the most heavily modified biogeographic provinces 

(North Central Prince of Wales, Kupreanof/Mitkof Islands, Dall Island and Vicinity, and East Chichagof 

Island) in addition to maintaining two individual reserves including the Wright Lake (mainland southeast of 

Wrangell), and Myers Chuck (Cleveland Peninsula northwest of Ketchikan) reserves and creating one 

near Eva Lake (northeast Baranoff Island) in an area currently designated as Semi-Remote Recreation. 

In addition, all VCUs outside of these biogeographic provinces would be required to retain 33 percent of 

their old growth with no requirement to consider spacing, location, size, shape, or composition in the 

design of the retained acres, as is provided by the 2007 Forest Plan Old-Growth Habitat Reserve Criteria 

(see Section 2.2.1.2, Description and Design Features of the Reserve Network). As under all other 

alternatives, OGRs are also provided by other non-development LUDs, although, with the exception of 

Alternative 7, the acreage is less under Alternative 4 than under all other alternatives. Alternative 7 

maintains substantial area in non-development LUDs, but entirely eliminates the Old-Growth Habitat LUD 

and would not have a specific retention requirement. 

Of the other alternatives, Alternatives 1, 2 and 3 all have significantly less old-growth harvest as 

compared to Alternative 6. This Appendix therefore focuses on effects to Alternative 6 because this is the 

benchmark by which to measure effects to these three other alternatives. Adverse effects to wildlife 

would be less under Alternatives 1, 2 and 3 based on the volume of old growth projected to be harvested 

and this is fully discussed in the Wildlife Section of the FEIS. 

2.5.1. Changes to Forest-wide Reserve Network (coarse-filter approach) 

The Forest-wide Reserve network is expanded under Alternatives 1, 2, 3, and 6, relative to Alternative 5 

(the 1997 Forest Plan Revision as amended). This expansion includes additional acreage in the OldGrowth Habitat LUDs relative to Alternative 5 and relative to the original 1997 Forest Plan. The 

expansion of the Old-Growth Habitat LUDs is the same for all four alternatives. In addition, the acreage 

in non-development LUDs is expanded for each of the four alternatives, with the amount of the expansion 

varying by alternative. As noted above, Alternative 4 identifies a smaller area than Alternative 1, 2, 3, 5, 

or 6 in Old-Growth Habitat LUDs and Alternative 7 does not identify any area. 

2.5.1.1. Changes to Old-Growth Habitat LUDs 

The original 1997 Plan noted that small OGRs had received less analysis and mapping precision than 

was necessary to meet the Plan standards. Large and medium OGRs received a rigorous review to be 

sure that they achieved the conservation strategy objectives (1997 Forest Plan, p. 3-82). However, the 

small OGRs received differing levels of reviews. Therefore, the Forest Plan and the Tongass National 

Forest Land and Resource Plan Implementation Policy Clarification (referred to as TPIT; USDA Forest 

Service 1998;) provided for the further evaluation and possible adjustment of the locations of small OGRs 

(USDA Forest Service 1997, Forest Plan, p. 3-82). 

The 1997 Forest Plan standards and guidelines for OGRs state that during project level environmental 

analyses for project areas that include or are adjacent to a mapped OGR, the size, spacing and habitat 

composition of mapped reserves may be further evaluated (USDA Forest Service 1997, Forest Plan, p. 3-

82). TPIT (USDA Forest Service 1998, p. 1) stated that an interagency team of biologists (referred to as 

the interagency team) would jointly evaluate the location and composition of the small OGR as mapped in 

the Forest Plan using criteria in Forest Plan Appendix K. The objective of the interagency team review 

described above was to develop a consensus biological recommendation on small reserve locations that 

was consistent with the Forest Plan. The Forest Service line officer retained decision authority to 

implement recommended changes or modify them. Because changes in OGRs resulted in a change in 

LUD, a Forest Plan amendment was required to implement changes. 
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As described in Section 2.3, analysis and mapping refinement of OGRs associated with 24 project areas 

has been conducted since 1997 (Table D-2). These adjustments were incorporated into the Forest Plan 

via non-significant Forest Plan amendments. Efforts to complete this higher level of analysis and 

mapping on all other small reserves have been ongoing since 1997. As part of the current Forest Plan 

Amendment process, the Forest worked with the Alaska Department of Fish and Game (hereafter 

referred to as ADFG) and the U. S. Fish and Wildlife Service (hereafter referred to as FWS) to complete a 

more comprehensive review and mapping effort. This process was conducted in 2006 and 2007 and 

included the development of a biological recommendation for adjustment of OGR boundaries, a 

refinement of that proposal with Forest Service Ranger District staff, and a further refinement by the 

Forest Supervisor. This refinement process was conducted in order to consider multiple-use objectives in 

addition to pure biological ones. The final proposal is included in Alternatives 1, 2, 3, and 6 of the Final 

EIS. Alternative 5 retains the 1997 Plan (as amended) reserve network and the reserves of Alternatives 4 

and 7 are not affected by this proposal. 

The final proposal for modifying small OGR boundaries was based on reviewing all small OGRs and a 

few medium reserves. As a result, OGR locations were generally finalized for all but 13 small OGRs. 

OGR locations are expected to change in the future only if a project occurs near these 13 reserves or 

under other limited circumstances (see Appendix K to the Final EIS). The net result of the review was an 

increase of 39,000 acres in the Old-Growth Habitat LUD, from 1,182,000 to 1,221,000. In addition to this 

expansion, some areas containing Old-Growth Habitat LUDs were converted to other non-development 

LUDs (e.g., Special Interest Area and Semi-Remote Recreation) and remain a part of the OGR network. 

These areas are discussed in the next subsection and the net result of all these changes is summarized 

in Section 2.5.1.3. 

Not only was the total acres in the Old-Growth Habitat LUD increased, but the quality of the small OGRs 

was also improved. Updated local information was used, in many cases, to increase the protection of key 

old-growth species habitat, including known goshawk nests, important black bear, mountain goat and 

brown bear habitat, riparian habitat, anadromous streams and beach fringe. In addition, connectivity was 

another consideration in updated small OGRd locations. Rationale for making these adjustments were 

documented in an OGR tracking table for the refinement effort (located in the planning record). 

2.5.1.2. Changes in Other Non-Development LUDs 

The Old-Growth Habitat LUDs discussed in the previous subsection are a critical piece of the OGR 

network, but many other non-development LUDs represent important parts as well. Although the area in 

Old-Growth Habitat LUDs is the same for Alternatives 1, 2, 3, and 6, the total area in other nondevelopment LUD categories varies. Alternatives 4, 5, and 7 vary in both their Old-Growth Habitat LUD 

and their other non-development LUD acreage. The acreage in many individual non-development LUD 

categories is constant regardless of the alternative (e.g., wilderness, LUD II, research natural area); 

however, the acreage in three non-development LUD categories (other than Old-Growth Habitat) differs 

among alternatives. These categories include: Special Interest Area, Semi-Remote Recreation, and 

Remote Recreation. Special Interest Area acreage was expanded by 47,000 acres relative to Alternative 

5 (the 1997 Forest Plan, as amended), under Alternatives 1, 2, 3, 4, 6, and 7. The change in SemiRemote and Remote Recreation acreages varies by alternative. For Alternative 6, the area in these two 

LUDs increased by 63,000 acres compared with Alternative 5. For Alternatives 1, 2, and 3, these LUD 

acreages increased by 2,681,000, 1,591,000, and 717,000 acres, respectively, while for Alternatives 4 

and 7 the LUD acreages decreased by 379,000 and 308,000 acres, respectively. 

The net increase in non-development LUD acreage (not counting the Old-Growth Habitat LUD) relative to 

Alternative 5, would be 110,000 acres for Alternative 6 and would range from 763,000 to 2,728,000 acres 

for Alternative 3, 2, and 1 in that order, respectively. Under Alternatives 4 and 7, non-development LUDs 

other than Old-Growth, would decrease by 333,000 and 261,000 acres, respectively. While it is 

recognized that not all acres within these LUDs are old growth, there would be a net increase in the 

reserve system under Alternatives 1, 2, 3, and 6 that is proportional to the increase in non-development 

LUD acres and a proportional decrease under Alternatives 4 and 7. 
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2.5.1.3. Net Changes to the Forest-wide Reserve Network 

The acreage in reserves, given the above changes in the Old-Growth Habitat LUD and other nondevelopment LUDs, is compared with the acreage in the matrix for the alternatives and compared with the 

1997 version of the Forest Plan in Table D-5. This comparison shows that the 1997 version of the Plan 

included 78.0 percent of the Forest in reserves. As a result of land adjustments and OGR changes 

between 1997 and 2007, the 2007 Forest Plan (equivalent to Alternative 5) now has 78.5 percent of the 

Forest in reserves. Alternatives 1, 2, 3, and 6 would each result in a higher percentage yet, ranging from 

79.4 percent in reserves under Alternative 6 to 95.0 percent in reserves under Alternative 1. Under 

Alternative 4, the percentage in reserves would be reduced to 71.8 percent, and under Alternative 7 this 

percentage would be reduced to 69.9 percent. 

Table D-5. 

Summary of Acreages in Reserves and Matrix under the Alternatives compared with the 

Forest Plan in 1997 

Reserves 

Alternative 

OldGrowth 

Habitat 

LUD 

Other NonDev. LUDs Total in NonDev. LUDs Matrix Total 

Percent 

of Forest 

in 

Reserves 

Alternative 1 1,221,173 14,712,270 15,933,443 840,359 16,773,802 95.0%

Alternative 2 1,221,173 13,623,148 14,844,321 1,929,485 16,773,806 88.5%

Alternative 3 1,221,173 12,748,685 13,969,858 2,803,945 16,773,803 83.3%

Alternative 4 393,360 11,652,756 12,046,116 4,727,686 16,773,802 71.8%

Alternative 5 

(1997 Forest 

Plan) 

1,182,424 11,985,410 13,167,834 3,605,974 16,773,808 78.5%

Alternative 6 1,221,173 12,095,212 13,316,385 3,457,420 16,773,805 79.4%

Alternative 7 0 11,724,107 11,724,107 5,049,695 16,773,802 69.9%

1997 Forest 

Plan 

1,131,059 12,034,860 13,165,919 3,717,081 16,883,000 78.0%

Sources: Final EIS Chapter 2 for the Alternative numbers; Appendix N to the 1997 Tongass FEIS and Appendices to 

Appendix N for 1997 numbers. 

A summary of POG acres in reserves and in various matrix categories is provided in Table D-6. This 

table presents POG acreages for the Forest-wide reserve network under Alternatives 1, 2, 3, and 6, given 

the above changes in the Old-Growth Habitat LUD and other non-development LUDs, as well as under 

Alternatives 4, 5, and 7, which do not include the above changes in the Old-Growth Habitat LUD. The 

table also compares these alternatives with the 1997 version of the Forest Plan. Based on these 

numbers, the 1997 version of the Forest Plan included 70.1 percent of the existing POG in reserves; 

combined with the protected and unscheduled POG in the matrix, 90.6 percent of the current POG was 

protected or not scheduled to be harvested. Again, Alternatives 1, 2, 3, and 6 would each result in higher 

percentages for both of these categories, with 72.0 percent of the POG in reserves and 91.0 percent of 

the existing POG protected or not scheduled for harvest under Alternative 6. 

Under Alternative 5 (the 2007 Forest Plan), 71 percent of the existing high-volume POG (SD Model types 

5N, 5S, and 67) and 68 percent of the existing large-tree POG (SD Model type 67) would be included 

within reserves (Table D-6). Overall, 90 percent of the existing high-volume POG and 89 percent of the 

large-tree POG would not be harvested. These percentages would all remain the same or increase under 

Alternatives 1, 2, 3, or 6 because of the changes made to OGRs and other LUDs, which resulted in a 

greater portion of the forest types consisting of larger trees being included within reserves. Under 

Alternative 6, for example, 73 percent of the high-volume POG and 70 percent of the large-tree POG 

would be included within reserves. Overall, 90 percent of the existing high-volume POG and 89 percent 

of the large-tree POG would not be harvested. Alternatives 1, 2, and 3 would protect higher percentages 

of high-volume and large-tree POG in reserves and in the matrix. Under Alternatives 4 and 7, on the 
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other hand, lower percentages would be protected. Approximately 57 to 60 percent of the high-volume 

POG and 53 to 57 percent of the large-tree POG would be in reserves under Alternatives 7 and 4, 

respectively. Overall, 82 to 85 percent of the high-volume POG and 80 to 84 percent of the large-tree 

POG would be protected from harvest. 

Table D-6. 

Estimated Acreage and Percentage of All Existing POG, High-Volume POG, and SD67 POG 

in Reserves1

 and Matrix Lands (minimum protected vs. maximum harvested) 2 by Alternative

Amount in Matrix2 Amount in 

Reserves1 Minimum Protected Maximum Harvested Total Existing POG3

Alt. POG Category Acres Percent Acres Percent Acres Percent Acres Percent 

All POG 4,615,995 93% 249,182 5% 85,972 2% 4,951,148 100% 

High-Volume 

POG 1,862,441 93% 104,444 5% 41,460 2% 2,008,345 100% 1 

SD67 POG 477,813 89% 43,253 8% 16,385 3% 537,451 100% 

All POG 4,167,367 84% 569,270 11% 214,511 4% 4,951,149 100% 

High-Volume 

POG 2 1,674,500 83% 232,318 12% 101,529 5% 2,008,346 100% 

SD67 POG 425,744 79% 77,417 14% 34,291 6% 537,451 100% 

All POG 3,866,467 78% 771,255 16% 313,426 6% 4,951,148 100% 

High-Volume 

POG 3 1,572,277 78% 294,628 15% 141,440 7% 2,008,345 100% 

SD67 POG 401,011 75% 90,844 17% 45,596 8% 537,451 100% 

All POG 2,965,670 60% 1,329,005 27% 656,473 13% 4,951,148 100% 

High-Volume 

POG 4 1,203,702 60% 511,928 25% 292,714 15% 2,008,345 100% 

SD67 POG 307,863 57% 145,418 27% 84,169 16% 537,451 100% 

All POG 3,518,425 71% 970,176 20% 462,556 9% 4,951,156 100% 

High-Volume 

POG 1,431,634 71% 378,068 19% 198,647 10% 2,008,349 100% 5 

SD67 POG 364,183 68% 113,501 21% 59,767 11% 537,451 100% 

All POG 3,563,600 72% 942,410 19% 445,103 9% 4,951,114 100% 

High-Volume 

POG 6 1,458,202 73% 352,379 18% 197,760 10% 2,008,342 100% 

SD67 POG 375,671 70% 103,085 19% 58,696 11% 537,451 100% 

All POG 2,807,478 57% 1,336,275 27% 807,396 16% 4,951,148 100% 

High-Volume 

POG 7 1,143,122 57% 502,283 25% 362,940 18% 2,008,345 100% 

SD67 POG 287,295 53% 144,188 27% 105,968 20% 537,451 100% 

All POG 3,551,482 70% 1,038,492 21% 473,597 9% 5,063,571 100% 

High-Volume 

POG4 1,562,652 72% 373,857 17% 219,268 10% 2,155,788 100% 

1997 

Forest 

Plan SD67 POG4 -- -- -- -- -- -- -- -- 1 Reserves include all non-development LUDs (e.g., Old-Growth Habitat, Semi-Remote Recreation, Remote Recreation, Wilderness, 

National Monument, etc.). 

2

 Matrix includes all development LUDs (Timber Production, Modified Landscape, Scenic Viewshed, and Experimental Forest). 

Maximum harvested assumes the maximum acreage permitted by the Allowable Sale Quantity is harvested each decade. 

3 Note that the Tongass land base has changed since 1997 due to land adjustments and harvest has occurred. 4 High-volume POG numbers were derived from percentages given in Appendices 3 and 8 to Appendix N of the 1997 Tongass FEIS; 

numbers were not available for SD67 POG. There are differences in the method of calculation for high-volume POG between 1997 and 

2008, so the absolute numbers should not be compared – only the percentages. 

Sources: Table 3.9-12 in Biodiversity Section for the 2008 alternative numbers; Appendix N to the 1997 Tongass FEIS and Appendices 

to Appendix N for 1997 numbers. 

2.5.2. Changes to Standards and Guidelines (fine-filter approach) 

This section describes and provides background/rationale for the changes to standards and guidelines 

proposed under the seven alternatives. The first section provides a summary listing of the primary 
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changes in standards and guidelines from the 1997 Forest Plan. Following this section, a series of 

sections provide background and rationale for the most important individual changes. 

2.5.2.1. Overview of Changes to Standards and Guidelines by Alternative 

Most of the standards and guidelines identified in the 1997 Forest Plan remain the same for all of the 

alternatives. The standards and guidelines for Alternative 5 would be exactly the same and most 

standards and guidelines related to the conservation strategy do not change under Alternatives 1, 2, 3, 

and 6. This includes key supporting standards, like the 1,000-foot beach buffer and riparian buffers that 

were deemed critically important for wildlife connectivity; these are brought forward into the amended 

Plan under these alternatives. However, there are four primary changes, four additional important but 

non-substantive changes, and some minor editorial changes to standards and guidelines that relate to 

Alternatives 1, 2, 3, and 6. The four primary changes associated with these alternatives are listed in a 

subsection below, followed by the important non-substantive changes (minor changes are not listed). 

In addition, many of the changes associated with Alternatives 1, 2, 3, and 6 and several additional 

important changes are associated with Alternatives 4 and 7. These changes are identified in separate 

subsections below. 

Primary Changes Associated with Alternatives 1, 2, 3, and 6 

1. Added a new Forest-wide Legacy Forest Structure (hereafter referred to as Legacy) standard and 

guideline that requires retention of 30 percent of the acreage in harvest units greater than 20 

acres in size for VCUs with high amounts of past and/or anticipated future timber harvest. This 

replaced the goshawk foraging standard and guideline and the marten standard and guideline 

that required varying degrees of retention of old growth trees in harvest units. 

2. Changed the goshawk nesting habitat standard and guideline for confirmed and probable nests to 

allow timber harvest or other activities if, based on annual monitoring, the nest site is found to be 

inactive for 2 consecutive years. (note – active nest sites include sites that are occupied, whether 

or not there is actual nesting documented). 

3. Added a stipulation to allow for alternative goshawk nest site management with projects under 

contract. If a new nest is located within an area that is under a timber sale or other contract, the 

activity may proceed if at least 300 acres of POG, including at least one contiguous block of 100 

acres, remains within a 0.75-mile circular radius of the nest. Timing restrictions would apply to 

allow that year’s brood to successfully fledge from the nest. 

4. Clarified that the landscape connectivity standard was to provide connectivity between large and 

medium reserves only. Also, given the assessment of small OGRs done for the amendment (see 

below), no additional areas were determined to need additional assessment at the project level 

and this is reflected in the amended standard. 

Other Important Clarifying Changes Associated with Alternatives 1, 2, 3, and 6 

1. The endemic terrestrial mammal standard was changed to allow for use of existing data on 

endemic mammal distribution. Surveys would only be necessary where existing information is 

not adequate to assess project level effects. 

2. Edited the marten road standard to clarify that road management would be considered only 

where road access and associated human caused mortality has been determined to be the 

significant contributing factor to unsustainable marten mortality and this would be done in 

collaboration with the Alaska Department of Fish and Game (ADF&G). 

3. Edited the wolf road standard to clarify that road management would be considered only where 

road access and associated human caused mortality has been determined to be the significant 

contributing factor to unsustainable wolf mortality, and this would be done in collaboration with 

ADF&G. It also directs an assessment of both total and open road density when human access 

considerations are necessary. The wolf standard was changed so that both access management 

on National Forest System lands and hunter/trapper harvest regulations are considered. 
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4. Edited the wolf standard to clarify the use of the deer habitat capability model and standardized 

this to a habitat capability of 18 deer/square mile. The wolf standard was also changed to direct 

biologists to consider local knowledge of habitat conditions, spatial location of habitat and other 

factors rather than solely relying upon model results. 

Changes Associated with Alternative 4 

All of the changes associated with Alternatives 1, 2, 3, and 6 also apply to Alternative 4, except the 

Legacy standard and guideline. Neither the Legacy nor the goshawk foraging standard and guideline and 

marten standards and guidelines apply to Alternative 4. In addition, as noted in the introduction to 

Section 2.5, Alternative 4 has a standard that requires a minimum of 33 percent of POG be retained in 

VCUs outside of the four biogeographic provinces that include areas with designated Old-Growth Habitat 

LUDs. 

Changes Associated with Alternative 7 

All of the changes associated with Alternatives 1, 2, 3, and 6 also apply to Alternative 7, except for the 

Legacy standard and guideline and the goshawk nest buffer standard and guideline. Neither the Legacy 

nor the goshawk foraging and marten standards and guidelines apply to Alternative 7 and there would be 

no nest buffer standard and guideline that is specific to goshawks; only the general heron and raptor nest 

protection standard and guideline would apply. In addition, riparian buffers along Class III streams are 

not required under Alternative 7 and the beach and estuary fringe is reduced to 500 feet. 

2.5.2.2. Legacy Standard and Guideline – Alternatives 1, 2, 3, & 6 

Background from 1997 Tongass Land and Resource Management Plan 

The Legacy Forest-wide standard and guideline is an ecological, rather than single-species approach, 

that retains old-growth forest structure within harvest openings greater than 20 acres in areas that have 

had or are anticipated to have high timber harvest. The legacy standard and guideline evolved from 

considerations presented at the Interagency Conservation Strategy Review workshop (summarized in 

USDA Forest Service 2007). This standard and guideline was developed after discussions with ADFG 

and FWS at several interagency meetings in 1997. It replaces the species-specific goshawk foraging and 

marten standards and guidelines from the 1997 Forest Plan Revision to provide protection for goshawk, 

marten and other wildlife species across a broader landscape. Goshawk foraging and marten standards 

and guidelines, that prescribed retaining canopy cover in high risk biogeographic provinces, were 

conservation measures added to the Forest Plan in the Record of Decision to provide additional 

protections and to increase the already high likelihood that implementing the Forest Plan would maintain 

habitat to provide for viable populations of goshawks and moderate likelihood that implementing the 

Forest Plan would maintain habitat to provide for viable populations of marten. This subsection provides 

a summary of the background for the new Legacy standard and guideline by describing the history of the 

goshawk foraging and marten standards and guidelines. 

American Marten 

The risk assessment panel convened in 1997 indicated that there was a better than equal likelihood that 

implementation of Alternative 11 for 100 years would result in significant gaps in marten habitat 

distribution on the Tongass (DeGayner 1997). Alternative 11, with modifications, was the Alternative 

selected in the Record of Decision for the 1997 FEIS. Their interpretation of the outcomes that were used 

as the basis for risk assessment is as follows (a complete description of the panel assessments with the 5 

outcomes is described later in this document in the Wildlife Viability Ratings section). Outcome III, defined 

as providing habitat to maintain breeding populations but with significant gaps in historic distribution, was 

interpreted by the panelists as an array of potential conditions. At one end of this array were gaps in 

habitat as small as the territory of a single marten. At the other end this array was conditions with broad 

gaps in habitat distribution and significant limitations on population interactions. The panelists considered 

some part of this array of conditions as meeting the definition of viable and well-distributed. The panelists 

assigned a total of 91 likelihood outcome points to the sum of Outcomes 1 + II + III. This included 38 

likelihood points in Outcomes I and II, which they considered to represent a viable and well distributed 
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condition. It also includes 55 likelihood points in Outcome III, some portion of which represents a viable 

and well distributed condition. The panelists indicated there was a very low likelihood that marten would 

exist only in refugia or be extirpated from the Tongass after 100 years of Forest Plan implementation with 

a combined Outcome IV and V score of 9. The panelists indicated that matrix management was the 

feature of the 1997 Alternative 11, as rated, that contributed to the assignment of likelihood points to 

outcomes that were not well-distributed. They indicated that clearcut silviculture on a 100-year rotation 

would result in further fragmentation of marten habitat. 

The panel evaluators defined the spatial scale of a gap to be one vacant marten territory. A marten 

territory was considered to be from one to three square miles. The consequence of a gap is some 

measure of reduced gene flow within the population. Panel evaluators indicated that a population can 

accommodate a certain, but unknown, level of gaps and still remain viable. The greater the size and 

number of gaps, however, the higher the risk of reducing gene flow. To avoid creation of gaps by forest 

management practices, panel evaluators recommended uneven aged harvest, in contrast to clear cutting 

in blocks, be coupled with a reduced level of timber harvest in the matrix lands. The panel recognized the 

high degree of natural fragmentation on the Tongass National Forest. The panel could not, however, 

identify the threshold of POG remaining at which a landscape or a territory would not be suitable for 

marten reproduction (DeGayner 1997). 

The panel was very conservative in their assessment of the definition of a gap, which lead to the 

assignment of most points in Outcome III. The overall assessment of a moderate likelihood of 

maintaining viable marten hinged on the 55 likelihood points in Outcome III and the fact that some 

undetermined portion of this outcome likelihood represented a viable and well distributed condition. It is 

also important to note that the panel assessed the 1997 Alternative 11 without the additional conservation 

measures that were added at the decision stage. Even without these additional measures, the panel 

projected no likelihood that marten would be extirpated from the entire forest under this alternative. 

Forest Plan was strengthened at the decision stage subsequent to the panel assessment, primarily due to 

the level of concern about the likelihood of marten populations remaining well-distributed across the 

Tongass for at least 100 years. 

The measures used to strengthen the alternative were based on comments provided by the panelists, 

information drawn from past studies on marten, and information on existing habitat conditions on the 

Tongass. Three different measures were applied to Alternative 11 to improve the likelihood of maintaining 

habitat to support well-distributed populations of marten. 

1. Within the five higher risk biogeographic provinces, stands would be managed under practices 

other than clearcutting. 

2. Access management would be used to reduce marten mortality in areas where mortality rates 

due to trapping/hunting have been identified as a serious risk to marten populations. 

3. Additional assurance of maintaining connections between habitat blocks throughout the Tongass 

would be considered. 

Implementation of the above strategy increased the likelihood of maintaining habitat that supports welldistributed marten populations. While it was anticipated that there would likely be gaps in this distribution, 

there was a low likelihood that there would be significant isolation among marten populations resulting 

from implementation of the 1997 Forest Plan. 

Goshawk 

Alternative 11 of the 1997 Forest Plan was rated as having very low likelihood of goshawks existing in 

refugia or being extirpated from the Tongass after 100 years of Forest Plan implementation. However, 

because the goshawk was considered for listing under the Endangered Species Act, Alternative 11 was 

reviewed at the decision stage to determine if features of the alternative could be modified to improve the 

projected outcome. An additional measure for goshawk habitat was prescribed for Prince of Wales Island 

where POG was fragmented by past management actions. In VCUs, where over 33 percent of POG has 

been converted to young stands by past management, any additional management of POG was restricted 

to 2-acre clearcuts or managed to leave significant structure in harvested stands. Taken in combination 
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with other measures already in place in the Forest Plan, these additional measures increased the already 

high likelihood of providing habitat sufficient to maintain viable and well-distributed goshawk populations. 

New information Since 1997 

Scientific Literature: A considerable number of new studies on goshawks and marten relevant to the 

Tongass situation have been conducted since 1997. Many new studies and concerns related to the 

conservation of marten and goshawk were presented at the Interagency Conservation Strategy Review: 

An Assessment of New Information Since 1997 in April 2006 (USDA Forest Service 2007). This 

information is summarized along with other studies in Section 2.4.2. 

Implementation of Goshawk Foraging and Marten Standards and Guidelines and Forest Plan since 1997: 

The 1997 goshawk foraging and marten standards and guidelines, coupled with the associated Tongass 

Plan Implementation Team (TPIT) Clarifications, are lengthy and complex. This complexity has lead to 

inconsistent interpretation and application across the Tongass (Conservation Strategy Review 2007). In 

addition, translating canopy cover to standard silviculture terminology has been problematic. The TPIT 

worked collaboratively to attempt to clarify these standards and guidelines in 1998 and allowed flexibility 

in the implementation of these standards. Unfortunately, this clarification was lengthier than the original 

standard and guideline and did not necessarily result in increased clarity. One result of the TPIT 

clarification was to allow flexibility to clump leave trees when operability concerns or ecological reasons 

made uniform placement difficult or impossible. 

There have also been issues during the implementation of goshawk foraging and marten standards and 

guidelines. Recent compiled information indicates the lack of consistency in their Forest-wide application, 

despite the TPIT clarifications. A survey of Tongass District wildlife biologists done in 2007 indicates a 

high degree of inconsistency and uncertainty in the application of goshawk foraging and marten standard 

and guidelines (Fadden 2007a). Biologists were not consistent in their interpretation of the standards and 

guidelines and believed that there was not consistent interpretation Forest-wide. In addition, it was not 

necessarily clear to biologists how these standards and guidelines actually benefited marten and 

goshawk. 

Review of a sample of planned timber sales since 1997 also demonstrates the inconsistency in 

application on the ground, with the goshawk foraging and marten standards being implemented using a 

simple percentage of the stand on some timber sales, using basal area on others, and using trees per 

acre on others (Fadden 2007b). All of the measures resulted in different effects on the ground, ranging 

from a clumped leave patches to partial harvest scattered across the unit. Within most timber sales 

reviewed, implementation of both marten and goshawk standards did take into account other leave areas 

(stream buffers, karst, etc.), which counted towards the final target (Fadden 2007b). Recommendations in 

this report included the need to simplify these standards to provide for more consistent application. 

Monitoring of timber harvest implemented since 1997 indicates that, overall, timber harvest is occurring at 

a scale much less than was anticipated in the 1997 Forest Plan EIS. Annual timber harvest has been 

much less than the Forest Plan Allowable Sale Quantity (ASQ) of 267 mmbf. In 2004, actual harvest was 

17 percent of the ASQ and in 2005, harvest was 24 percent of the ASQ. In addition, there is trend toward 

a decrease in size of traditional clearcuts and a decrease in opening size. Since 1997, the average 

clearcut harvest size is 11 acres (Conservation Strategy Review 2007). As a consequence, the effects on 

wildlife have been considerably lower than the level predicted by the 1997 Forest Plan FEIS. 

The trend toward smaller opening sizes coupled with the increased use of partial harvest are factors that 

make timber sales less economical, as well as more difficult to log. A combination of factors including 

market issues and increased fuel and logging costs are also factors in timber sale economics; however, 

when coupled with less volume per acre and higher logging costs due to partial harvest, it has 

exacerbated the economic issues, particularly at the scale of an individual timber sale (as presented at 

the Interagency Conservation Strategy Review: An Assessment of New Information Since 1997 in April 

2006; USDA Forest Service 2007). 

The 1997 Forest Plan sought to provide for economic considerations while implementing conservation 

measures for species of concern. Monitoring of timber sale economics indicates that this approach, 
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which has resulted in significantly smaller timber harvest unit size and more partial harvest, is likely 

contributing to significant difficulties in implementing economic timber sales. More information regarding 

timber sale economics can be found in the Economic and Social section of the Final EIS. 

While this information indicates the challenge in providing for economic timber sales, the trends 

discussed above represent several positive consequences for wildlife. The main positive consequence is 

that more habitat for old-growth associated species is retained as old growth. The second consequence 

is the ameliorating effects of forest succession. Negative effects to goshawk and marten are strongly 

associated with the effects of past large-scale timber harvest on the Tongass. Past harvest resulted in 

much larger openings than are allowed under the 1997 Forest Plan, often occurring within riparian areas 

and beach buffers, which are high value wildlife habitats. Neither riparian areas nor beach buffers are 

harvested under the 1997 Forest Plan, nor would they be harvested under 2008 FEIS Alternatives 1, 2, 3, 

or 6. As young forests mature, they gradually become more suitable for goshawks and marten. 

Previously, little emphasis was given to the young second-growth component of the matrix in terms of its 

ability to contribute structure, function, or value to wildlife. However, there appears to be a growing 

perception that, with active management, young stands can contribute at least some of the values 

commonly associated with old-growth (Barbour et al. 2005). Key features of old-growth forest include 

large, old decadent trees, multiple canopy layers, standing snags, down woody debris, and a diverse and 

abundant herb layer. These features can be maintained or created by retaining structures and organisms 

at the time of regeneration harvest of old-growth forest and through active management of young, evenaged stands. Some potential approaches to even-aged management involve thinning of older, 

“commercial”-aged young-growth stands (Deal 2001, Deal and Tappeiner 2002, Deal et al. 2002), 

including red alder (Alnus rubra) in the reforestation of harvested areas to expedite the production of 

large-diameter conifers (Deal 1997, Deal et al. 2004, Hanley et al. 2006), and the initial use of alternatives 

to clearcutting (McClellan et al. 2000). It should be emphasized that additional research on the 

implementation of these techniques is needed. 

For example, both pre-commercial and commercial thinning of young-growth stands have beneficial 

impacts to black-tailed deer by opening up the forest and promoting the growth of understory vegetation. 

Likewise, active young-growth management has the potential to benefit both marten and goshawk 

through an increase in small mammal populations (red squirrels and red-backed voles, major prey items 

of these species, benefit from more open forests with abundant understory vegetation) and by speeding 

the succession of older young-growth stands toward old-growth condition (Hanley 1996, 2005). Thinning 

also may benefit forest-dwelling birds, some of which are prey for goshawk (Dellasala et al. 1996). 

Although the time frame in which young-growth stands become suitable habitat for some old growth 

associated species is beyond the lifespan of the 10-15 years of this Forest Plan, it is something to be 

considered as part of a long-term vision for management of the Tongass. It must be noted however that 

their research on the effectiveness of young-growth management is on going and peer-reviewed results 

are not yet available. The evidence in support of the potential short and long term benefits of younggrowth management for multiple values is derived from a series of demonstration projects that have 

tested various second-growth management methods (e.g., Zaborske et al. 2002; Deal et al. 2004; 

McClellan 2004, 2005; McClellan et al. 2005; Wipfli et al. 2003), retrospective assessments (Hanley and 

Barnard 1998), and other observations. Thus, there remains uncertainty about the true benefits of 

second-growth management to wildlife. Although active management will likely improve habitat 

conditions in young conifer stands, significant questions remain regarding the types of treatments, 

treatment timing, and cost/benefit tradeoffs. 

This does not imply that young growth is the same quality habitat as old growth, nor does it ignore the 

negative consequences of the stem-exclusion phase, which is characterized by dense young trees that 

shade out most of the understory and thus, provide low habitat value for most wildlife species. But once 

stands transition out of this stage, they gradually begin to provide the components of good quality wildlife 

habitat, including larger trees, small canopy gaps, a diverse understory, snags and downed logs. Stands 

typically do not begin to take on the characteristics of old growth until they reach at least 150 years of age 

(Alaback 1982). However there is some evidence that some species associated with older forests may in 

fact use much younger stands (for example, goshawks - see Section 2.4.2.1). 
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Besides the benefits of succession, another benefit of aging young-growth stands is the increased 

potential value of these stands for commercial forest products and their ability to replace old growth trees 

for a significant portion of the supply of timber in Southeast Alaska in the future. Managing young-growth 

forests in Southeast Alaska is likely to become an increasingly important component of forest 

management on the Tongass in the coming years. Young-growth stands can be treated through thinning 

and other intermediate treatments to concentrate growth in fewer, larger trees, improve lumber quality, 

and/or to enhance habitat conditions for wildlife. Treatments applied to young stands may have a 

profound effect on the types of materials available in the future, including log diameter, knot size, and 

wood strength (see Timber section of Final EIS for more discussion). 

Overall the consequence of substantially less harvest of old growth in the past decade coupled with the 

increased growth and potential value of young growth for wildlife is beneficial and supports that 

assumptions made regarding risks to species viability made in the 1997 Plan were conservative. This 

conclusion is supported by observations that some old growth associated species use younger forests 

that anticipated in the 1997 Forest Plan (for example, goshawks), that a shift to more commercial forest 

products coming from young growth forests is occurring and is likely to accelerate over the next two to 

three decades, and that the beneficial effects to wildlife by less harvest of old growth over the past 

decade than is greater than was anticipated under the 1997 Forest Plan. This is particularly significant in 

places with the oldest young growth, which includes some portions of Prince of Wales Island. Of the 

187,000 acres of past harvest on Prince of Wales Island, 8,000 acres are now age 50 or older, 42,000 

acres are now age 40 to 49, and 54,000 acres are now age 30 to 39. Within 20-30 years, much of the 

young growth on Prince of Wales Island may be approaching suitable nest habitat for goshawks. 

Annual Monitoring and ADFG Reports: According to the 2006 Tongass National Forest Annual 

Monitoring and Evaluation Report, habitat capability for marten was expected to decrease slightly 

because of timber harvest activities and road construction across the Tongass. However since timber 

harvest levels have been substantially less than anticipated, this report documents that effects anticipated 

to marten under the Forest Plan have been less than anticipated. The most recent ADF&G Furbearer 

Report (Alaska Department of Fish and Game 2004) suggests that marten populations are stable or 

increasing across most of the Tongass; the exception potentially being near Juneau. In 2003, over 2700 

marten were trapped in Southeast Alaska and both trappers and agency personal reported stable or 

increasing marten populations in most Game Management Units (GMUs). The two areas with the highest 

harvest levels are GMUs 2 and 4, which include Prince of Wales Island and Chichigof Island, areas with 

some of the highest past timber harvest on the Tongass. The link, if any, between habitat changes on the 

Tongass National Forest and changes in the marten population is difficult to determine. Fluctuations in 

prey abundance or spatially different trapping pressure are confounding factors. Areas on the Tongass 

with the most timber harvest continue to have stable or increasing marten populations and trapping 

regulations have not changed significantly on the Tongass. 

Queen Charlotte Goshawk Status Review and Findings: The U.S. Fish and Wildlife Service was 

petitioned to list the Queen Charlotte goshawk as endangered in May 1994. In June 1995, the Service 

published a 12-month finding that listing was not warranted. The finding was challenged in U.S. District 

Court, which remanded the finding to the FWS with instructions to base the finding on the existing 

management plan for the Tongass National Forest, rather than one in development at the time. The FWS 

released a new finding (also “not warranted”) in August 1997, which was also challenged in April 1998, 

and which the court remanded again to the FWS in July 1999, with instructions to provide a reliable 

population estimate for the subspecies The government appealed this decision in the U. S. Court of 

Appeals, which overturned the requirement for a population estimate, but remanded the case to the 

District Court for further consideration of the remainder of the finding. In May 2004, the District Court 

remanded the finding to the FWS with instructions to evaluate whether Vancouver Island in British 

Columbia is a “significant portion” of the subspecies’ range and, if so, to determine whether the bird 

should be listed (U. S Fish and Wildlife Service 2007) 

In order to reach an informed decision with respect to the court’s remaining questions on the significance 

of Vancouver Island and whether the subspecies should be listed, the FWS recently updated the status of 

the subspecies range-wide. In addition, the FWS published a new finding in November 2007 regarding 

the status of the Queen Charlotte goshawk. In this report, they concluded that Vancouver Island is a 
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significant portion of the Queen Charlotte goshawk’s range and that listing the subspecies on Vancouver 

Island is warranted. In addition to addressing the court’s remand, they assessed whether listing was 

warranted for the Queen Charlotte goshawk beyond Vancouver Island. Their review indicated that the 

subspecies’ populations in British Columbia and Alaska each constitute distinct population segments 

(DPSs) of the Queen Charlotte goshawk. Based on differences in forest management, with substantially 

greater habitat loss in British Columbia, they found that they had sufficient information about biological 

vulnerability and threats to the goshawk to determine that the entire British Columbia DPS warrants listing 

as threatened or endangered. They also found that the best available information on biological 

vulnerability and threats to the goshawk does not support listing the Alaska DPS as threatened or 

endangered at this time. Of note are the following key items from the FWS review: 

♦ The majority of POG that existed in Southeast Alaska prior to large-scale logging would remain over 

time. Most (77 percent) of this habitat is on the Tongass. 

♦ There is no data to indicate how much goshawk populations have declined as a result of timber 

harvest. Based on one approach, the FWS believes that populations may have declined by 15 

percent in Southeast Alaska and as much as 45 percent in British Columbia. 

♦ The most important factor related to goshawk demographics is adult survival. Adult survival is a 

function of prey abundance and availability. 

♦ Southeast Alaska is relatively prey-poor for goshawks, especially on the islands of the south 

Tongass. For example, Prince of Wales Island lacks red squirrels and sooty grouse, which are 

important prey for goshawks on the mainland and islands in the north Tongass. Many studies from 

across the range of the goshawk suggest that prey availability is one of the most important factors 

regulating goshawk population size in Southeast Alaska. 

♦ Studies from across the range of the goshawk suggest they select nest stands that have a higher 

proportion of mature and old forests than random sites. 

♦ Goshawks use a wide range of habitats for foraging within the matrix, including non-forest, young 

forest, low-volume forests, and clearcuts. 

♦ Goshawks, even juveniles, can travel relatively long distances across salt water, indicating that there 

are not likely to be barriers to goshawk movement among the islands in Southeast Alaska. 

Importance of Retention of Forest Structure After timber harvest and Spatial 

Considerations 

While the benefits of leaving old growth structure after timber harvest are well documented in the 

scientific literature, the need to leave it after timber harvest on the Tongass is not as clear, given the 

conservation strategy, the fact that slightly over 90 percent of the existing POG is protected under the 

2007 Forest Plan and that there are economic consequences of leaving structure post timber harvest 

(see Section 2.3). However, past timber harvest has been concentrated in certain portions of the 

Tongass. While it is true that Forest-wide, the vast majority of old growth would be retained, there are 

biogeographic provinces and watersheds that have and are predicted to have much higher reductions in 

old growth than the average. For example, as reported in the 2008 FEIS, the North Central Prince of 

Wales biogeographic province currently has 74 percent of the original POG and it is anticipated that this 

would be reduced to 63 percent of the original POG after 100 years of timber harvest at maximum levels 

allowed by the Forest Plan under Alternative 6. Considering only large tree POG, North Central Prince of 

Wales province would retain 57 percent of original large-tree POG; however, the East Baranof province 

would retain only 31 percent. In these and similar areas, there would be elevated risk that there could be 

gaps in distribution of some species and reduction in connectivity between old-growth patches after 100 

years of timber harvest at maximum levels allowed by the Forest Plan. 

Many studies validate the importance of retention of legacy trees and patches of old growth after timber 

harvest for many forest associated species (Masurek and Zielinski 2004, Carey 2000). Retention of this 

old growth structure affects forest developmental pathways, indirectly affecting wildlife abundance by 

retaining necessary structural features in both mature and young forests (Deal 2007). In Southeast 

Alaska, many bird species utilize legacy trees as nesting, foraging, perching, and roosting sites (Sidle and 
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Suring 1986). The lack of these structural features within forests can negatively impact many old growth 

associated species (Bunnell et al. 1999, 2002, Aubry et al. 1999, Bevis et al. 2002, Deal 2001, 2007). 

Work on flying squirrels in Southeast Alaska indicates the importance of the matrix in providing adequate 

dispersal habitat in order to maintain connectivity between OGRs. Flying squirrels, being arboreal, 

require these structural components and are found primarily in mature and old growth forests but are also 

found at lower densities in peatland –scrub forests (Smith and Person 2007). 

While numerous studies validate the importance of retention of this structure, research is not available, 

especially for Southeast Alaska, to guide specific silvicultural prescriptions or to help prescribe specific 

amounts of leave trees for individual wildlife species. Most Forest Plans in other parts of the United 

States have incorporated various retention prescriptions. The closest plan ecologically to Southeast 

Alaska is the Northwest Forest Plan that covers Oregon and Washington. The Northwest Forest Plan 

requires green-tree retention in at least 15 percent of the area within logging units. It is recommended that 

at least 70 percent of this retention be implemented in patches or clumps of up to one hectare (about 2.5 

acres). In addition to this green-tree retention, the retention of snags and large decadent trees within 

these green-tree retention clumps is recommended. These prescriptions were developed based on the 

professional judgment and collective biological knowledge of individuals who have studied the ecological 

processes characterizing the forests of the Pacific Northwest (Aubry et al. 1999). A large-scale and longterm experiment (the Demonstration of Ecosystem Management Options (DEMO) study) to evaluate the 

ecological effects and public perception of green-tree retention in western Washington and Oregon is 

underway. Among the key findings to date are that the pattern of retention is not as important as the 

amount of retention; however, the retention of 2.5-acre clumps can provide refuges with ecological and 

mircroclimatic conditions that enable many sensitive species to persist, at least in the short term (USDA 

Forest Service 2007). 

In Southeast Alaska, research has described the characteristics of wind-created openings (Nowacki and 

Kramer 1998). Understanding the range of natural wind disturbance gaps can help in the development of 

management prescriptions. Within the four areas studied by Nowacki and Kramer (1998), mean gap size 

sustaining large-scale wind events ranged from 10 to 39 acres in four study areas, with the range in size 

of individual gaps from 1 to 1,000 acres. Within gaps, there was also a range in the amount of remnant 

trees remaining after a windthrow event, with some remnant structure in most gaps. Most gaps had a 

range from 0 to 50 percent of the stand remaining post wind event. 

The 1997 Forest Plan used a harvest unit threshold of 2 acres, for the implementation of goshawk 

foraging and marten standards and guidelines. No documentation of why this acre threshold was used 

can be found in the 1997 FEIS; however, there is reference to the practice of group selection in the timber 

section of the 1997 FEIS. The group selection method prescribes the removal of small groups of trees to 

create openings in the stand. The forest created, using this method, is a mosaic of small groups of trees 

of uniform age and height with the goal of regenerating an uneven-aged stand structure across the 

landscape. Group sizes range from 0.1 acre to approximately 2 acres in size. Research and experience 

with this method is extremely limited in Southeast Alaska. The ideas behind using this method in 

Southeast Alaska are to protect excessively steep or unstable soils and reduce the impacts to scenic and 

wildlife resources. 

Rationale for Legacy Standard and Guideline 

The legacy standard and guideline as a replacement for the species-specific goshawk foraging and 

marten standard and guidelines is proposed for the following reasons: 

1. It provides a science-based measure of retention of old-growth habitat characteristics (large 

trees, down logs, snags) Forest-wide rather than only in places where there were concerns 

related to goshawk and marten. This will provide habitat protections in high risk biogeographic 

provinces across the forest for more species of concern (including endemic small mammals and 

forest birds) than the goshawk and marten standards and guidelines in the 2007 Forest Plan. 

2. It provides an alternate method for retaining connectivity and prey base for marten and goshawk 

at the watershed scale. Legacy would apply in 49 VCUs Forest-wide in 7 biogeographic 

provinces. Goshawk foraging standards under the 2007 Forest Plan apply in 22 VCUs on Prince 
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of Wales Island only (1 province). Marten standards for high risk provinces under the 2007 Forest 

Plan apply in 12 VCUs in 2 provinces. Marten standards for moderate risk provinces in the 2007 

Forest Plan apply in 107 VCUs in 6 provinces. These standards for low risk provinces apply in 

112 VCUs in 6 provinces. 

3. Overall, considered in combination with other improvements to the Conservation Strategy, 

including increased quality of small OGRs, increased old-growth protection in key areas, and 

increased quantity (acreage) of OGRs, habitat for viable populations of goshawk and marten 

across the Tongass would be maintained. 

4. The Legacy standard and guideline is simpler to implement and will likely have more consistent 

implementation Forest wide than the previous goshawk foraging and marten standards and 

guidelines. 

These four reasons are explained in detail below. 

1. Providing a science-based measure of retention of old-growth habitat characteristics (large 

trees, down logs, snags) Forest-wide and the value to multiple species. 

A review of current science, as described previously, supports both the value of the retention of old 

growth structure to a wide range of species and the value of taking a broader approach, rather than taking 

a single-species approach as did the goshawk foraging and marten standards. While the value of 

retaining old-growth forest components within landscapes managed for timber production has a sound 

basis in science, there is no scienific basis to support specific prescriptive standards for marten, goshawk 

or most individual species. In other words, while there may be a scientific basis that supports that partial 

harvest has less impact to goshawk or marten habitat than clearcutting, there is no scientific basis to 

support any specific management prescription. Clearly, there is a gradient of the value of habitat 

conditions for many species, with large contiguous blocks of old growth being most beneficial for many 

old growth associated species in Southeast Alaska and large expanses of clearcut forest being the least 

beneficial. But without specific studies indicating what specific prescriptions are of most value, the 

management decision for these prescriptions are made by considering the risk to the resource (in this 

case wildlife habitat needs) with the feasibility requirements for other management (in this case, 

economic timber harvest). 

Furthermore, while 1997 Forest Plan prescribed retention of 10 to 30 percent canopy cover as a measure 

to help maintain connectivity for marten and to maintain foraging habitat for goshawk, there is no scientific 

basis to support that this relatively low amount of retained canopy cover in a stand provides measurable 

protection specific to goshawk or marten or their prey. Also there is no scientific basis to support that this 

degree of retention of canopy cover is effective for maintaining connectivity in fragmented landscapes. 

The studies summarized previously indicate that more than significantly more than 30 percent canopy 

cover would need to be retained to meet these objectives. While increased amounts of retention post 

timber harvest may benefit old growth associated species, including marten and goshawk, they present 

conflicts in providing for economical timber harvest. 

Based on current science, leaving old growth structure post timber harvest in clumps is preferable to 

leaving the structure in a more uniform configuration across a clearcut because clumps of trees are more 

likely to be used by a variety of wildlife species, they may benefit other organisms in the forest, and they 

are more windfirm than scattered trees. As noted above, the DEMO study in western Washington and 

Oregon has found that many plant and animal species that are sensitive to timber harvest were able to 

persist in retention clumps of 2.5 acres, indicating that such patches may serve as local sources of 

recolonization into adjacent harvested areas as the new stand develops (USDA Forest Service 2007). 

Leaving structure in clumps rather than scattered is also more efficient for logging with the consequence 

of reduced logging costs in cable-yarding harvest units. The recently completed logging system and 

transportation analysis (LSTA) for the Tongass indicates that only 35 percent of the remaining suitable old 

growth is planned for cable yarding (see Table 3.13-2 in the Timber section of the Final EIS). The 

remaining 65 percent is planned for ground-based logging systems, such as shovel logging, or helicopter. 

With ground-based or helicopter logging, there is substantial flexibility in terms of how retention trees 

could be left without significantly affecting logging costs. If only the normal operability ground is 

considered (excluding the difficult and isolated operability classes), the percentage of ground-based and 
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helicopter yarding would still be 61 percent. Therefore, there is considerable flexibility available to project 

IDTs for the majority of future old-growth harvest units, to design retention spatial patterns in a way that is 

beneficial to wildlife and does not negatively affect timber sale economics. 

The legacy standard and guideline addresses the high degree of endemism within the islands of the 

Tongass and a degree of uncertainty in managing for endemic species because of gaps in information 

about species distribution and habitat needs. While recent science addresses concerns regarding 

endemic mammals related to risks of extinction due to island factors and small population sizes and 

connectivity within islands, there remains a lack of a scientific basis to help managers develop speciesspecific conservation measures. Therefore, taking an ecological approach to leaving legacy that spans 

the entire Tongass and focuses on watersheds with a high degree of past timber harvest (harvest that 

occurred prior to the 1997 Forest Plan) is an approach that, in the absence of science to support other 

measures, will most likely help ensure connectivity for a wide range of species. 

2. Providing an alternate method for retaining connectivity and prey base for marten and goshawk 

at the watershed scale. 

The objectives of the 1997 Forest Plan goshawk foraging and marten standards and guidelines were to 

improve connectivity for marten by reducing fragmentation, improve habitat conditions to provide for 

dispersal for goshawks between OGRs and to maintain foraging habitat for both goshawks and marten in 

the matrix in biogeographic provinces with a high degree of past timber harvest. This was done through 

the retention of forest stand structure important to these species and their prey (large trees, snags, and 

down logs) through several standards and guidelines, including those specific to goshawk foraging and 

marten habitat. 

The legacy standard and guideline would apply under Alternatives 1, 2, 3, and 6 for the 2008 Forest Plan 

Amendment Final EIS within seven high-risk biogeographic provinces, as compared to the 1997 goshawk 

foraging standard and guideline, which applied one biogeographic province on Prince of Wales Island, 

and the marten standards and guidelines, which applied in two high-risk biogeographic provinces and 

three additional moderate-risk biogeographic provinces (Table D-7). 

One of the factors contributing to the high likelihood of maintaining sufficient habitat for viable populations 

of goshawks in the 1997 Forest Plan was the application of a 300-year ‘ecological’ rotation. While not a 

rotation as defined in traditional silvicultural terminology, the concept is applied at larger, landscape scale. 

Application of a 300-year ‘ecological’ rotation generally results in 1/3 of the productive forest landscape in 

0-100 year-old stands (low value to goshawks or most of their prey), 1/3 in 100-200 year old stands 

(moderate value to goshawks and their prey), and 1/3 in 200-300 or older (old growth) stands (highest 

value to goshawks and their prey). These proportions of habitat within the scale of goshawk use areas 

(i.e., median home range of approximately 10,000 acres) across a large landscape would provide habitats 

with a high likelihood of sustaining well distributed populations. Both extended traditional rotations and 

the concept of a 300-year ‘ecological’ rotation were viewed favorably by members of the Goshawk 

Assessment Panel for sustaining long-term goshawk habitat (Iverson, 1996). Panel members, as did 

authors of the Goshawk Assessment, concluded that maintaining conifer stands in intermediate age stand 

structure from 100 to 200 years would, in part, supply stand structure for goshawk prey production, and 

thus, goshawk foraging opportunities. 

Alternatives 1, 2, 3, and 6 for the 2008 Forest Plan Amendment FEIS include the Legacy standard, which 

requires 30 percent of a stand to be retained in higher risk VCUs for even-aged harvest units over 20 

acres in size. Most (over 80 percent) of VCUs within the suitable land base are categorized as low or 

medium risk because these VCUs currently have more than 67 percent of their historical old growth 

remaining and will not have more than 67 percent harvested after 100 years of harvesting at the 

maximum ASQ level.. Because these VCUs will continue to be managed on at least an ecological 300-

year rotation, these VCUs have a high probability of maintaining adequate wildlife habitat for many 

species, including marten and goshawk. 

This approach addresses the potential cumulative effects from previous harvest and provides for the 

retention of a representation of old-growth components across all VCUs managed for timber production. 

In low and moderate risk VCUs, the representation of old-growth components is provided for by the mix of 

non-development LUDs, OGRs, and other standards and guidelines. In high risk VCUs, this is provided 
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for by the legacy standard plus the mix of non-development LUDs, OGRs and other standards and 

guidelines. 

Implementing the legacy standard and guideline in high risk VCUs will help ensure connectivity between 

OGRs within the matrix where connectivity may have been affected by past harvest practices. There is a 

high likelihood that VCUs with little past harvest will have a high degree of connectivity even after 100 

years of implementing the Forest Plan because of the suite of protective measures that are in place under 

Alternatives 1, 2, 3, 5, and 6. 

Table D-7 provides a summary of the number of VCUs where the legacy, goshawk, and marten standard 

and guidelines apply. There are two scenarios within which the legacy standard and guideline differs 

from the goshawk foraging and the marten standards and guidelines. First, there is no requirement to 

leave 30 percent legacy in harvest units 20 acres or smaller in size. Legacy would only be left in harvest 

units that are greater than 20 acres and this number was selected because it represents a typical harvest 

unit, based on analysis of the Logging System Transportation Analysis (LSTA). This typical harvest unit 

Table D-7. 

Number of VCUs where the Proposed Legacy Standard applies, compared with the 

number of VCUs where the Goshawk and Marten Standards apply, by Biogeographic 

Province

Marten Standard & Guideline1/

Biogeographic Province 

Legacy 

Standard & 

Guideline 

Goshawk 

Standard & 

Guideline 

Currently 

>33% 

Harvested2/

>33% 

Harvested 

in the 

Future 

<33% 

Harvested 

Now & in the 

Future 

Yakutat Forelands 3 - - - - 

Yakutat/Glacier Bay 

Upland - - - - - 

East Chichagof Island - - - 16 30 

West Chichagof Island - - - - - 

East Baranof Island 1 - - - - 

West Baranof Island 4 - - - - 

Admiralty Island - - - - - 

Lynn Canal - - - - - 

Northern Coast Range - - - - - 

Kupreanof/ Mitkof Islands - - - 22 13 

Kuiu Island - - - - - 

Central Coast Range - - - - - 

Etolin Island and Vicinity 2 - - 12 10 

North Central Prince of 

Wales Island 31 22 9 30 31 

Revilla Island/Cleveland 

Peninsula 3 - 3 23 19 

Southern Outer Islands 5 - - - - 

Dall Island and Vicinity - - - - - 

South Prince of Wales 

Island - - - - 1 

North Misty Fiords - - - - - 

South Misty Fiords - - - - - 

Ice Fields - - - - - 

TOTAL 49 22 12 103 104 1/ Marten standards and guidelines include one level of retention in VCUs with >33 percent harvest and one level for VCUs with <33 

percent harvest. The VCUs listed in the first column under marten will always follow the >33 percent harvest retention rules and 

the VCUs in the third column under marten will always follow the <33 percent harvest retention rules. The VCUs in the middle 

column start out under the <33 percent harvest retention rules and switch after the 33 percent harvest threshold is reached. 2/ The VCUs listed in this column under marten are additional to VCUs that are counted under the Goshawk standard and guideline. 
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is what is available for harvest after considering landforms, land suitability, Tongass Timber Reform Act 

riparian buffers and other resource considerations mapped for the LSTA. For wildlife species sensitive to 

forest fragmentation, smaller clearcuts are better than larger clearcuts. Legacy was retained only in units 

greater than 20 acres in response to the challenge of providing economic timber sales while conserving 

wildlife habitat. This was chosen because of the lack a clear scientific basis for determining what sized 

clearcuts are absolute barriers to wildlife, because there is no clear scientific basis to support that 10 to 

30 percent canopy cover retention mitigates the effects of clearcutting on wildlife and in order to address 

timber harvest logistical and economic considerations. 

Because legacy only applies in openings greater than 20 acres in size, there is a risk of increased 

negative consequences for goshawks and marten at the stand scale than was anticipated in the 1997 

Record of Decision (but not in the 1997 FEIS, see discussion in 3 below). However, considering that 

wildlife encounter both natural and human caused fragmentation on the Tongass, opening sizes from 

natural wind events range up to 1,000 acres, but are typically less than 40 acres, and there are few actual 

barriers (except saltwater) for many species on the Tongass, wildlife movements will continue to be 

facilitated through managed landscapes. While there would be openings as large as 20 acres without 

retention of legacy, a typical timber sale layout will have a mix of unit sizes and configurations. The 

combination of all the protective measures specific in the Forest Plan, including riparian buffers and 

implementation of other standards and guidelines, will result in timber sale layout that has significant 

more leave as compared to pre 1997 Forest Plan timber harvest practices. 

The second scenario where legacy differs is that marten standards require two additional measures of 

retention that are not prescribed with the legacy standard and guideline. First, marten standards under 

the 2007 Forest Plan require 30 percent canopy cover retention in VCUs that would, in the future, have > 

33 percent of the VCU harvested in what are considered high risk biogeographic provinces for marten. 

Alternatives that adopt the legacy standard and guideline would not require this additional measure; 

however, these VCUs are considered to be moderate risk overall, because a higher percentage of their 

harvest will have occurred under more protective standards and guidelines and a higher percentage of 

retention will be present, compared with VCUs that are rated as high risk by the legacy standard and 

guideline. Second, marten standards require a smaller level of retention (10-20 percent) in VCUs that 

would never exceed 33 percent harvest. Again, alternatives that adopt the legacy standard and guideline 

would not require this additional measure; these are considered to be low risk VCUs, which will have an 

even higher percentage of retention within the matrix due to the fact that the harvest percentage is low 

and/or a greater percentage of the harvest will have occurred under more protective standards and 

guidelines (which require more retention). 

Observations from implementing the Forest Plan since 1997 indicates that there are multiple standards 

and guidelines that provide residual forest structure (trees, snags, down logs) that are retained within 

timber harvest units. Besides marten and goshawk standards, these include scenery, riparian buffers 

(including class III streams), soils, and karst standards. In addition, logging system limitations (such as 

blind leads) also result in portions of stands being retained that are often unreachable with cable logging 

systems. Partial harvest has also occurred more frequently than anticipated, due to a variety of factors, 

not just marten and goshawk standards and guidelines. These observations indicate that there is 

significant structure being retained within watersheds as a result of the Forest Plan standards and 

guidelines and this structure will provide habitat for many wildlife species, including marten and goshawk. 

3. Overall, considered in combination with other improvements to the Conservation Strategy, 

including increased quality of small OGRs, increased old-growth protection in key areas, and 

increased quantity (acreage) of OGRs, habitat for viable populations of goshawk and marten 

across the Tongass would be maintained. 

Under the 1997 Plan, the viability assessment for marten (with the assumption of the maximum timber 

harvest levels allowed over 100 years) of the selected Alternative indicated a moderate likelihood of 

maintaining viable and well distributed populations of marten across the Tongass. The viability 

assessment for goshawk indicated a high likelihood of maintaining viable and well distributed populations 

of goshawks across the Tongass. These determinations were made prior to additional conservation 

measures added in the Decision. The 1997 Forest Plan and the 2008 Forest Plan EIS both assume that 

matrix lands would be somewhat fragmented by timber harvest and recognized the risks to wildlife within 
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a fragmented landscape. It was assumed that a consequence of implementation of timber harvest at 

maximum levels allowed in the Forest Plan over 100 years was that there would be a reduction in wildlife 

habitat capability in those watersheds that had significant amounts of fragmentation due to timber 

harvest, hence the importance of the reserve system. Research focused on the conservation strategy 

since 1997 has confirmed an assumption of the 1997 Forest Plan that for some species, the OGR system 

alone may not retain viable populations. This was why the Forest Plan approach of both a reserve 

system and matrix management was adopted in 1997. Under Alternative 6, total reserve area (nondevelopment LUDs) has been increased by over 150,000 acres and protections are even greater under 

Alternatives 1, 2 and 3, when considering all additions to non-developments LUDs including small OGRs, 

increases to geologic special interest areas for karst and increases for other resources. A substantial 

portion of these additions is POG. 

The potential effects to marten described for Alternative 6 in the Final EIS for the 2008 Tongass Forest 

Plan Amendment are within the range of effects predicted in 1997. These effects would be less under 

Alternatives 1, 2, and 3. The 1997 Tongass Forest Plan EIS estimated there would be a moderate 

likelihood that marten populations would remain viable with the selected Alternative throughout the 

Tongass, before the marten standard and guideline was added in the 1997 ROD to further reduce risk. 

Alternatives 1, 2, 3, and 6 also reduce risks to marten viability through increased protective measures for 

marten above and beyond what the viability panels assessed. These additional measures include 

increased old growth acres retained in both OGRs and other non-developments LUDs; retention of the 

marten road density and landscape connectivity standards and guidelines; and the addition of the legacy 

standard and guideline. 

Furthermore, the level of risk to goshawk and marten viability described in the 1997 FEIS would be 

realized only under a certain set of conditions, as follows. 

♦ Timber is harvested continually at the maximum level allowed under the Plan (the ASQ level 

annually) for 100 consecutive years, with no change in applicable standards and guidelines during 

that entire period. In essence, the panels did not assess the risks associated with a 10- to 15-year 

decision, but with a 100-year decision. This risk is relatively low because timber has not been 

harvested on the Tongass at or near the maximum ASQ level throughout a single planning cycle, let 

alone several. The first Tongass Forest Plan was adopted in 1979, and was in effect through May of 

1997. It had an annual average ASQ of 549 MMBF of total volume. Total volume harvested from 

1980 through 1996 averaged 327 MMBF annually, only 60 percent of the ASQ. Since adoption of the 

1997 Forest Plan, total volume harvested has averaged 84 MMBF annually, only 32 percent of the 

annual average ASQ of 267 MMBF. 

♦ If timber harvest rises to the ASQ annually over the next 10-15 years the planning process ensures 

that any issues that may emerge regarding sustaining viable populations of wildlife species on the 

Tongass will be addressed. Plans must be revisited through a public process every 10-15 years. 

Each time, the latest scientific information is examined to determine what changes may be needed. 

The Forest Service and other State and Federal agencies will continue to monitor implementation of 

the Forest Plan and its results. If a viability-related problem were to develop, it would be addressed. 

♦ Standards currently in effect are far more protective than those of 20 or 40 years ago. It is highly 

likely that standards will continue to become more effective over the next several decades through 

adaptive management as the scientific understanding of how to minimize the adverse environmental 

effects of human activities continues to improve. 

In addition, consideration of the increasing value of aging young-growth stands is crucial when assessing 

habitat values in the matrix. As young growth matures, habitat becomes more suitable for a variety of 

forest-dwelling prey. The matrix also increases in value for foraging goshawks, for providing nest sites for 

goshawks and to provide a variety of habitat conditions beneficial to marten. In addition, not all existing 

young growth will be managed in the future on an 80 to 100 year rotation. Of the approximately 440,000 

acres of harvested lands on the Tongass, 45 percent is within non-developments LUDs and will be 

managed to enhance future old-growth habitat. 

Overall, implementing the legacy standard and guideline increases the likelihood that the matrix will 

provide many more functions than just connectivity and will help ensure the persistence of all species on 
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the Tongass. While adoption of this standard and guideline a degree of increased risk with respect of the 

conservation of goshawk and marten specifically because the legacy standard applies in less VCUs that 

the 1997 marten standards and guidelines applied and because it applies only in openings greater than 

20 acres, this risk does not change the overall conclusion that there is a moderate to high degree of 

likelihood that sufficient habitat will be maintained to provide for viable populations of marten and 

goshawk. 

4. The Legacy standard and guideline is simpler to implement and will likely have more consistent 

implementation Forest wide than the previous goshawk foraging and marten standards and 

guidelines. 

The legacy standard and guideline is simpler and clearer than the goshawk and marten standards. The 

intent is similar – retain forest structure in units after timber harvest. The standard is clear that this 

structure is meant to be within the harvest units, not on the edge, though it does provide for exceptions 

when logging systems preclude this. The Forest Plan monitoring plan requires monitoring for a variety of 

wildlife questions. Adjustments can be made through this adaptive management process if it is 

determined that our objectives are not being met. 

In addition, the goshawk foraging and marten standards and guidelines, with the TPIT clarifications, have 

often been implemented very similarly to how we expect the legacy standard and guideline to be 

implemented. Particularly in units harvested with cable yarding systems, patches of old growth have 

been left as a proportion of the unit, rather than as dispersed trees or as by retention of canopy cover. 

Observations indicate that canopy cover is difficult to measure and implement and, therefore, a portion of 

the stand has been left to meet the standards and guidelines. Therefore in high risk VCUs, 

implementation of the legacy standard and guideline will be the same on many Ranger Districts as was 

done using goshawk foraging and marten standards and guidelines. 

2.5.2.3. Goshawk Nest Buffer Standard and Guideline – Alternatives 1, 2, 3, 4, & 6 

Background 

Under Alternatives 1, 2, 3, 4, and 6, the goshawk nest buffer standards and guidelines were modified to 

read as follows: 

1. Preserve nesting habitat around all confirmed and probable goshawk nests. If, based on annual 

monitoring, a previously active nest is found to be inactive for 2 consecutive years, protection 

measures for the site may be removed. 

2. When a new nest is located within an area that is under a timber sale or other contract, the 

activity may proceed if at least 300 acres of POG, including at least one contiguous block of 100 

acres, will remain within a 0.75-mile circular radius of the nest. Timing restrictions on some 

activities will be applied to allow that year’s brood to successfully fledge from the nest. 

The purpose of change 1 was to allow for future tiimber harvest in areas if evidence indicates goshawks 

have discontinued use of the nest stand. Note that this considers active nest sites very conservatively 

and include sites that are occupied, whether or not there is actual nesting documented. 

The purpose of change 2 was to allow a measure of flexibility when goshawk nests are found during 

implementation of a timber sale or other contract. This is of particular concern during timber sale 

contracts, but also could occur during implementation of other contracts. Goshawks predominately have 

alternate nests within a territory. When found, active nest sites are protected with a 100-acre nest buffer, 

but there is a high likelihood that the pair will move to an alternate nest site in subsequent years. Since 

timber sales are planned several years in advance of actual harvest, the likelihood of this happening 

before harvest, when a timber sale is under contract, is compounded. When goshawks move to an 

alternate nest, it is particularly problematic for management if they move into a timber sale unit or within a 

road location after a contract has been awarded. In this case, unless the purchaser and Forest Service 

can come to a mutual contract agreement, the government becomes liable to claims when the nest is 
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buffered and the unit or portion of unit is dropped from the contract. Therefore, it is desirable to have 

flexibility to address these contract issues on a case-by-case basis. 

New science relevant to goshawks and the conservation strategy is summarized in Section 2.4.2.1. 

Rationale 

The use of alternate nest sites within a territory coupled with the year-to-year variation in actual nesting 

makes it difficult to determine if goshawks are actively nesting within a nest stand or territory. Research 

indicates that goshawks commonly have multiple alternate nests within a territory. Alternate nests may 

occur within the 100 acre nest buffer or could elsewhere within the territory. Within one study in 

Southeast Alaska, only 54 percent of alternate nests occurred within 100 acres of known nests, indicating 

that goshawks commonly move nests outside known nest stands (USDA Forest Service 2007). This, 

coupled with the difficulty in finding nests in Southeast Alaska means there is some risk that observers 

will fail to detect an active nest within the territory. In addition, because goshawks do not necessarily nest 

every year and may go several years between successful nesting attempts, there is some risk that 

managers will not be absolutely certain a nest site is abandoned after inventorying for only 2 years. It is 

labor intensive to find goshawk nests and verify actual reproduction in a territory. This is even more 

costly in the remote, inaccessible terrain of Southeast Alaska. Since goshawks may not attempt to nest 

for 2 or more years and individual goshawks are highly variable in the number of years between 

successful nesting attempts, the only method for managers to be absolutely assured that goshawks are 

no longer using a territory would be cost prohibitive. Using 2 years allows some measure of assurance 

that managers will not inadvertently harvest an active nest stand, but this is not without risk. There is 

some risk that a once active nest stand will be logged because not all nesting goshawks are detected and 

because some goshawks pairs may return to nest in a stand after two or more years absence. In 

addition, there is some risk that the nest stand may become unsuitable for future nesting. 

Standards and guidelines outline relatively conservative criteria for what constitutes confirmed and 

probable nests. Observers do not need to actually find the nest to confirm a stand as a nest stand 

requiring a 100 acre buffer. A confirmed stand is one where evidence suggests nesting is highly likely 

and mangers can be relatively assured that they have identified the actual nest tree. Characteristics of 

confirmed nests include goshawks observed on or near a nest; nestlings or branchers (young not able to 

fly) observed on or near a nest; goshawk feathers or eggs obtained from the nest or one or more nest 

structures indicative of goshawk were found with goshawk prey remains, but without positive identified 

goshawk on the nest and without positive identified feathers from nest. A probable nest is one where 

evidence suggests nesting is likely nearby, but there is less assurance that managers know where the 

actual nest tree is. Characteristics of probable nests include aggressive, territorial breeding season 

adults vocalizing or attacking an observer (without locating a nest); or adults observed during the 

breeding season in a territory and recently fledged young were observed (without locating a nest). 

The fact that timber harvest occurs at all within a goshawk nest territory presents some risk that the 

goshawk pair will not successfully nest and may ultimately abandon the territory. However, most 

goshawk nesting habitat on the Tongass will not be affected by timber harvest. Assuming goshawks 

occupy suitable habitat across the entire the Tongass, most goshawk territories would be protected by 

virtue of the fact that the majority (71 to 72 percent) of existing POG is protected in reserves (Table D-8). 

Providing protection for goshawk nest stands continues to be an important component of goshawk 

conservation measures in the Amended Forest Plan under Alternatives 1, 2, 3, 5 and 6. Goshawk nests 

and nest territories are protected in a variety of ways, including the implementation of 100-acre nest 

buffers within timber harvest areas. Within the matrix, an additional 17 to 18 percent of the existing POG 

would be protected within the matrix by a suite of buffers and standards and guidelines. Finally, at least 

an additional 1 percent of existing POG would not be scheduled and would not be harvested primarily 

because of economics; however, based on the recent history of harvest levels on the Tongass, this 

percentage could be substantially higher. In total, over 90 percent of the existing POG would be 

protected over the life of the Forest Plan under Alternatives 5 and 6. 
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Table D-8. 

Summary of POG Protection under Alternatives 5 and 6. 

 Alternative 

Protected in 

Reserves (OGRs, 

Wilderness, Nat. 

Mon., LUD II, and 

other Natural 

Setting LUDs 

Protected in Matrix 

(beach fringe, 

riparian and other 

areas protected 

from harvest by 

standards and 

guidelines) 

Minimum 

POG Not 

Scheduled 

for Harvest 

Total 

protected 

Alternative 5 65.3% 16.9% 0.8% 83.0% 

% of 1954 POG * 

Alternative 6 66.2% 15.9% 1.1% 83.2% 

Alternative 5 71.0% 18.4% 0.9% 90.3% 

% of 2006 POG 

Alternative 6 72.0% 17.3% 1.2% 90.5% 

* The % of 1954 POG is the % of POG that was present in 2005 compared to the amount of POG that was estimated to be present 

prior at the onset of large-scale timber harvest. 

It is not possible to estimate how many goshawk nests will be found in the future within units in active 

timber sales under contract. However, it is likely to be a relatively rare circumstance; since 1997, this 

issue of has occurred only once, where the nest moved multiple times within the timber sale contract 

area. 

There is no scientific basis in Southeast Alaska to support a management strategy for goshawks that 

relies on retaining a prescribed threshold of suitable habitat in matrix lands instead of having perpetual 

nest buffer protections, as was done for management of goshawks in the southwest. While such a 

strategy would ideally provide flexibility to address timber harvest and goshawk nest conflicts, there are 

no studies that guide development of a habitat threshold. Science supports that the retention of old 

growth in matrix lands is an important component of goshawk conservation, especially within 

biogeographic provinces that are anticipated to be at higher risk for goshawks because they do not 

maintain a 300-year ecological rotation (Iverson et al.1996). But there are no known thresholds for how 

much old growth can be harvested before goshawks will abandon a territory. However, as described in 

Iverson et al. (1996), one estimate of the minimum proportion of old growth in breeding use areas in 

Southeast Alaska was 23 percent for males and 28 percent for females, respectively. It is instructive to 

assess the quality and protection status of habitat around known nest sites on the Tongass. Such 

information supports that known goshawk nests, many of which have been found during timber sale 

planning and thus are in matrix lands, have a high degree of habitat protection. 

During the 1997 Forest Plan process, stand-level analysis was conducted to examine past timber harvest 

at various spatial scales around known goshawk nests. It also examined additional future risk to known 

goshawk nesting areas compared to land allocations and standards and guidelines in the Forest Plan. A 

sample of 36 known goshawk nest areas in Southeast Alaska was used for this analysis. This sample of 

nests is biased towards goshawks discovered in landscapes predominantly allocated to timber 

management and may not necessarily be representative of the entire goshawk population in Southeast 

Alaska. Within this sample, relatively little POG had been harvested around known goshawk nests. The 

proportion harvested increased with distance from the nest, with 3 percent (range: 0 to 50 percent) within 

the 0.25 mile radius (radius area = 140 acres), 12 percent (range: 0 to 57 percent) within a 1-mile radius 

(radius area = 2,040 acres), and 14 percent (range: 0 to 61 percent) within a 3-mile radius (radius area = 

18,000 acres). Only 2 of 36 nests (6 percent) had any harvest within the 140-acre area around the nest 

and only 60 acres within the 0.25 mile radius had been harvested after the nest was discovered. Similarly, 

only 160 acres at three nests had been harvested within a 1-mile radius once the nest was located. 

In addition, this analysis indicated that a total of 20 of 36 (56 percent) goshawk nest sites known at that 

time occurred in a protected natural setting LUD. Nearly 40 percent of the entire area of all three spatial 

analysis areas (0.25-, 1-, and 3-mile radii from the nest) would be protected in a reserve in the Forest 

Plan, despite potentially being a biased sample toward landscapes predominantly allocated to timber 
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harvest. This reiterates the importance of the non-development LUDs in the overall protection of 

goshawk nest sites. 

A summary of recent research given at the Conservation Strategy Review Workshop (US Forest Service 

2007) looked at hypothetical post-fledging areas (PFAs) around 78 known goshawk nests, which 

indicated that these contained, on average, 39 percent medium- and high-volume old growth, 45 percent 

productive forest, 8 percent low-volume forest and 4 percent clearcuts. Results of this hypothetical PFA 

analysis indicated that an average of about 40 percent of the PFAs were medium- or high-volume POG, 

of which 55 percent was in the development LUDs or non-National Forest System lands. 

More detailed analysis was done for the Forest Plan amendment looking at the same issue of protection 

of habitat around known goshawk nests but included an assessment of two different sized hypothetical 

PFAs. Both measurements have similar results and therefore, the issue of the actual size or shape of the 

circle is probably not biologically meaningful. For a 1-mile radius circle, 27 percent of circle was protected 

POG, 13 percent was POG mapped as suitable for harvest, 10 percent was young growth, 24 percent 

was unproductive forest, 5 percent was non-forest, non-NFS lands was 14 percent (this land contains 

POG, young growth, unproductive forest, and non forest), and saltwater was 9 percent. However, this 

analysis was done using the mapped suitable POG. If the difference between as the mapped suitable 

and what is actually suitable on the ground (due to a variety of factors, such as steep slopes, new 

streams, and other standards and guidelines) and scheduled for harvest, the acres of POG protected 

would increase to about 31 percent of the circle and the acreage of POG not protected would decrease to 

about 9 percent of the circle. 

All of these analyses indicate that goshawk nests on the Tongass are afforded a relatively high level of 

protection, including both nests that occur within non-development LUDs and those in the matrix lands of 

development LUDs. In most cases there would be other potential nesting habitat within the goshawk’s 

territory if nest stand was inadvertently logged. The analysis described above is a potential future 

monitoring tool to see whether newly found goshawk nests in the matrix have similar conditions. 

There is the risk that timber harvest will occur within an occupied or historic goshawk nest stand, given 

that goshawks do not always respond during surveys and thus, there is some risk of overlooking 

goshawks during timber sale planning. This risk exists with or without changing this standard. However, 

the risk is reduced during the entire process from planning to layout to contract implementation since 

stands are visited multiple times and, therefore, it is less likely that a truly occupied stand would be 

overlooked. In addition, the Tongass will continue to do goshawk surveys for timber sale planning prior to 

NEPA decisions. 

Overall, at least 90 percent of existing POG would be protected or not be scheduled for harvest under 

either Alternative 5 or 6 after 100 years (assuming the maximum timber harvest levels allowed in these 

Alternatives). While there is some uncertainty in how many nest stands would be affected by this change 

in standard and guideline, given the degree of POG retention within goshawk territories in the matrix that 

provide potential habitat for both alternate nest sites and foraging habitat and that the vast majority of 

nesting habitat is protected over the life of the Plan, implementation of this standard may affect nest 

occupation by individual pairs but not substantially affect goshawk populations across the Tongass. 

Overall, nest protection within the matrix, while an important component of the conservation strategy, is a 

relatively small component of the overall conservation strategy because timber harvest will occur within a 

small portion of suitable goshawk habitat. The U.S. Fish and Wildlife Service, in their 2007 finding 

(Federal Register 2007. Vol. 72 no. 216 pp. 63123-63140) acknowledged this issue of goshawk nest 

protections and concluded the following, which confirms the value of the key components of the 

conservation strategy for goshawks: 

“Nest buffers of 100 ac (40 ha) of POG, as specified in the Forest Plan, are intended to protect 

individual nests from disturbance. Larger buffers would likely enhance goshawk conservation by 

providing better habitat for fledglings in the immediate vicinity of the nest, but lack of larger buffers 

is not expected to reduce fecundity or survival to an unsustainable level because OGRs, which 

typically protect much larger patches of old growth forest, and other retained forest patches are 

reserved in each watershed, and we expect goshawks to nest in these reserves as the forest 
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D-48

around them is increasingly harvested. In some cases, suitable nesting habitat in nearby reserves 

may already be occupied by nesting pairs, but the territoriality of goshawks is likely to prevent this 

in most cases.” 

They also discuss concerns that have been raised about the adequacy of the conservation strategy to 

maintain goshawk populations and conclude that: 

“In spite of the shortcomings discussed above, we find that the full suite of standards, guidelines, 

and land designations contained in the 1997 Forest Plan are likely to provide adequate habitat 

protection to sustain goshawks in Southeast Alaska into the foreseeable future, largely because 

adequate amounts of old and mature productive forest will be protected in reserves, retention 

areas, and inoperable stands, in large and small patches, throughout the harvested matrix. “ 

2.5.2.4. Landscape Connectivity – Alternatives 1, 2, 3, 4 (partially), & 6 

The Forest-wide Landscape Connectivity standard and guideline was changed to clarify when the issue of 

connectivity was important to assess during project implementation. It was also changed given that 

changes in the small OGR boundaries have improved connectivity between all medium and large OGRs 

and no areas will need specific consideration during project implementation (see Biodiversity and Wildlife

sections of the Final EIS). 

The conservation strategy did not assume that there was connectivity between small OGRs and the 

mediums and large OGRs. Connectivity would be provided for by beach fringe, riparian buffers, other 

standards and guidelines, other unsuitable POG, and unscheduled POG. While it may be desirable to 

consider local connectivity issues within a project area during NEPA analysis, this is not necessary in 

order to provide for viable and well distributed populations – this was provided by the Forest-wide reserve 

network of old growth in non-development LUDs. 

The other portion of this standard that was added was to consider young-growth treatments that 

accelerate old growth conditions on unsuitable acres. There are significant acres of young growth in nondevelopment LUDs that could provide connectivity quicker with active management. 

Under Alternative 4, this standard and guideline would only apply within the four biogeographic provinces 

that include small OGRs (see Biodiversity and Wildlife sections of the Final EIS). 

2.5.2.5. Endemic Mammals – Alternatives 1, 2, 3, 4, 6, and 7 

The Forest-wide Endemic Terrestrial Mammal standard and guideline was changed to clarify what kinds 

of information should be used for assessing endemic mammals during NEPA analysis. The standard 

allows for use of existing information on endemic mammals to be used for project planning where 

available. The Forest has invested significant funds into numerous cooperative projects with several 

universities as well as with the Pacific Northwest Research Station. The result of this investment is a 

significantly better understanding about mammalian distribution in Southeast Alaska, than existed prior to 

the 1997 Forest Plan (for example, MacDonald and Cook 2007). This is not to imply that we have 

information on species distributions on all islands of Southeast Alaska. However, on many islands, 

particularly the larger islands, there is adequate presence/absence data for NEPA analysis. There is 

some inherent risk to endemic mammals under all alternatives because of their inherent endemism, their 

distribution amongst islands, and the lack of complete knowledge of their distribution and habitat 

relationships. 

Other guidelines added to the 1997 Plan in response to the panel assessments would also benefit both 

the endemic and widely-distributed mammals. The connectivity guideline will provide additional measures 

to maintain connectivity of large and small reserves and other non-development LUDs in places where 

beach fringe and riparian habitat management areas do not provide adequate connectivity. Guidelines for 

structural retention for goshawk and marten habitat as well as the legacy standard and guideline will also 

benefit other mammal species. The increased quality and quantity of the OGR system under Alternatives 

1, 2, 3, and 6 will also benefit many endemic mammals, particularly those as most risk, which includes the 

Prince of Wales flying squirrel. 
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2.5.2.6. Marten – Alternatives 1, 2, 3, 4, 6, and 7 

The American marten Forest-wide standard and guideline was changed to clarify when to consider road 

density management. The standard clarifies that consideration of access as an issue for marten 

management should only occur when it is demonstrated that mortality is exceeding sustainable levels and 

that the most significant factor causing this human access on roads. 

This change does not change the intent of the standard; however, it clarifies when it should be 

implemented. Other minor edits were also done to this standard and guideline that do not change the 

intent of the standard, but clarify it for more consistent implementation. 

2.5.2.7. Wolf – Alternatives 1, 2, 3, 4, 6, and 7 

The Alexander Archipelago Wolf Forest-wide standard and guideline was changed to clarify when to 

consider road density management. It also incorporated information from the Conservation Strategy 

Review that indicated that both open and total road density were important factors to consider when 

assessing road effects on wolves. The standard clarifies that consideration of access as an issue for wolf 

management should only occur when it is demonstrated that mortality is exceeding sustainable levels and 

that the most significant factor causing this human access is roads. 

This change does not change the intent of the standard; however, it clarifies when it should be 

implemented. Other minor edits were also done to this standard and guideline that do not change the 

intent of the standard, but clarify it for more consistent implementation. It continues to outline the need for 

a cooperative interagency analysis to identify regions where wolf mortality is apparently excessive. In 

such areas we would attempt to determine if the mortality is unsustainable and identify the probable 

causal factors of the excessive mortality. If road access and specific roads are identified as contributing to 

excessive mortality, then road closures or access management recommendations can be made and 

actions taken. In addition, seasons, harvest methods and bag limits need to be considered as population 

management tools by the ADF&G and Federal Subsistence Board as a cooperative approach to 

managing wolf mortality at a sustainable level. 

The 1997 Forest Plan did not prescribe a rigid open road density limit and one is not proposed in this 

amendment. The Wolf Assessment Panel recommended not using a specific road density “rule of thumb.” 

This was contrary to recommendations in Suring et al (1993) where a road density limits from 1 to 1.25 

mile of open road per square mile were recommended, depending on geographic location. Establishing a 

rigid road density level was not done because the resulting arbitrary closure roads to meet this density 

was determined to provide no management assurance that wolf conservation objectives would be 

achieved. Furthermore, it could unnecessarily limit overall public use of an established road system that 

may otherwise have no specific adverse impact on wolf mortality. Management recommendations for road 

and access management, if necessary, would result from the site-specific analysis discussed above that 

would identify a problem requiring a local and cooperative management resolution. Road densities above 

or indeed below these referenced densities may be appropriate to effectively manage road-access related 

wolf mortality. This approach is also taken by the amended Forest Plan. 

Changing the standard and guideline to consider total rather than just open road density takes into 

account updated science supporting the relationship between wolf mortality and both open and closed 

roads. The standard and guideline also retains a range of road densities, based on research from several 

locations, including Alaska, Minnesota, and other states, that guide managers to determine the need to 

take action to address wolf mortality concerns. Based on research described in Section 2.4.2.3, the risk 

of unsustainable wolf mortality is higher on islands with roads that connect to communities than islands 

with no roads or roads that do not connect to a community. Given this variability in risk, adopting a range 

instead of one number allows better consideration of more site specific management that directly 

addresses actual human use. 

2.5.2.8. Elimination of Legacy and Goshawk/Marten Standards and Guidelines – 

Alternatives 4 & 7 

Alternatives 4 and 7 were developed because of the need to evaluate alternatives that satisfied higher 

timber volume demand levels than the 2007 Forest Plan. As such, methods of increasing timber volume 
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levels were evaluated that caused the least impact to the conservation strategy. The elimination of the 

requirement to leave legacy or reserve trees within harvest units, as prescribed by the Legacy and the 

Goshawk and Marten standards and guidelines, was one of the key methods identified. As noted above 

and in Section 3, neither of these standards and guidelines were assumed for the viability panel ratings. 

2.5.2.9. Minimum 33 Percent POG Retention – Alternative 4 

Alternative 4 is different from the other alternatives in that it identifies Old-Growth Habitat LUDs in only 

four biogeographic provinces (North Prince of Wales Island, Kupreanof/Mitkof, Dall Island, and Northeast 

Chichagof), in addition to several individual reserves (Myers Chuck, Lake Eva, Wright Lake) in other 

provinces. This concept was first analyzed under Alternative 6 in the 1997 FEIS. Overall, Alternative 4 

includes only 393,360 acres of Old-Growth Habitat LUDs, compared with 1,182,424 acres for Alternative 

5. In order to provide for a minimum level of POG in VCUs outside of these four provinces, a new 

standard would require that a minimum of 33 percent of POG be retained in each VCU that occurs 

outside of the four biogeographic provinces. However, this requirement would not have a major effect on 

POG retention because few VCUs would result in less than 33 percent POG retention and the majority of 

those that would occur within the four biogeographic provinces. 

2.5.2.10. Reduction of Beach Fringe – Alternative 7 

Additional modifications were made to the standards and guidelines under Alternative 7 to respond to 

public comments so that this alternative could provide a higher level of timber volume and improve timber 

sale economics, while minimizing effects on the conservation strategy. This item and the next two items 

fall into this category; however, the reduction of the beach fringe is the most significant. Under Alternative 

7, the beach fringe buffer would be reduced from 1,000 feet to 500 feet from the shoreline. This concept 

was first analyzed under Alternative 2 in the 1997 FEIS. Because this low-elevation band typically 

contains larger trees, is more easily accessible, and adds a substantial amount of suitable forest land, this 

modification has a large effect on available timber volume and average timber sale economics. On the 

other hand, it would negatively affect many wildlife and plant species that use or inhabit beach fringe 

habitats more extensively than most other Tongass habitats, and would negatively affect old-growth 

connectivity. 

2.5.2.11. Elimination of Class III Stream Buffers – Alternative 7 

As noted in Section 2.5.2.10, additional modifications were made to the standards and guidelines under 

Alternative 7 to respond to public comments so that this alternative could provide a higher level of timber 

volume and improve timber sale economics, while minimizing effects on the conservation strategy. The 

elimination of the requirement to leave riparian buffers along Class III streams is one of these 

modifications. It would not produce a substantial additional timber volume, but could result in more 

economic timber sales, since Class III stream buffers are thought, by many, to be a key factor in timber 

sale economics. 

2.5.2.12. Elimination of Goshawk-Specific Nest Buffer Standard and Guideline – 

Alternative 7 

As noted in Section 2.5.2.10, additional modifications were made to the standards and guidelines under 

Alternative 7 to respond to public comments so that this alternative could provide a higher level of timber 

volume and improve timber sale economics, while minimizing effects on the conservation strategy. 

Elimination of the goshawk-specific nest buffer standard and guideline is another modification that 

contributes to this goal. Only the general heron and raptor nest protection standard and guideline would 

apply to confirmed or probable goshawk nests. This means that active nests would receive forested 600-

foot wind-firm buffers, where available, and that road construction through the buffer would be 

discouraged. Disturbance during the active nesting season would be prevented and protection measures 

could be removed if the nest is inactive after 2 consecutive years of monitoring. 
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3. WILDLIFE VIABILITY RATINGS 

3.1. Historical Background for Tongass Viability Ratings 

Direction under the National Forest Management Act (36 CFR 219.19:43048) states that “fish and wildlife 

habitat shall be managed to maintain viable populations of existing native and desired non-native 

vertebrate species in the planning area.” For planning purposes, a viable population is defined as “one 

which has the estimated numbers and distribution of reproductive individuals to insure its continued 

existence is well distributed in the planning area.” Furthermore, “habitat must be provided to support, at 

least, a minimum number of reproductive individuals and that habitat must be well distributed so that 

individuals can interact with others in the planning area.” 

To meet these requirements, decision-makers for the 1997 Forest Plan revision effort relied in part on the 

findings of structured risk assessment panels, consisting of subject matter experts. The panels were 

charged with the task of providing unbiased scientific information on the relative risk associated with 

implementing each plan alternative to the continued persistence across the landscape of selected species 

or species groups. These risk assessment panels consisted of four evaluators (drawn from various 

Federal agencies and Alaska state government), a local subject matter expert available as a resource 

person, a facilitator, a scribe, and a silent observer (Shaw 1999). 

The approach of using professional judgment to assess viability risk had been used in the Pacific 

Northwest for the development of the Northwest Forest Plan (FEMAT 1993, Starkey 1998). In addition, 

this approach was selected for the Tongass because of the considerable uncertainty regarding the 

ecology and distribution of many wildlife species and there was generally inadequate information on 

which to base predictive models. In addition, the timeframe for the planning process was too short to 

facilitate the collection of additional data on which to base predictive models (Shaw 1999). 

Thus, seven wildlife panel assessments were conducted: one for goshawk, marten, brown bear, wolf, 

marbled murrelet, "other terrestrial mammals," which included both endemics and widely distributed 

species, and black-tailed deer. These old-growth associated species and species groups were selected 

because collectively their ecologies incorporated the breadth of forest habitat features and other attributes 

of environmental variation represented across the Forest (Shaw 1999)., and because they were thought 

to be representative of a subset of species that are sensitive to disturbance and potentially at risk of either 

becoming locally extirpated or jeopardizing cultural or subsistence uses. Risk assessment panels were 

also conducted for sustainability of the fisheries resource, old-growth forest ecosystems, the social and 

economic values of forest resources to residents of southeast Alaska, and subsistence use of forest 

resources (e.g., black-tailed deer and salmon), but these are not discussed further in this appendix. 

Panel assessments were initially conducted in fall 1995 and winter 1995-96 to evaluate the risks of nine 

draft Forest Plan alternatives. Following public comment, and taking into account results of these panel 

assessments, some plan alternatives were modified and additional plan alternatives were developed that 

were not subject to the panel assessment process. Consequently, a second set of risk assessment 

panels was convened in the spring of 1997, which evaluated seven alternatives including a modified 

version of Alternative 2 (equivalent to 2008 Alternative 7) and a new Alternative 11 (equivalent to 2008 

Alternative 5); Alternative 6 (similar to 2008 Alternative 4) was not reevaluated. Evaluators were the 

same during both panel assessments for the marten and the other terrestrial mammals group, but one or 

more evaluators changed for the other panel assessments. 

In the 1997 FEIS, which was developed before the second set of panels was conducted, Alternatives 10 

and 11 were not subjected to risk assessment panels as were the full array of draft alternatives. In the 

description and analysis of panel results in the 1997 FEIS (Chapter 3, Biodiversity and Wildlife sections), 

there was a strong correlation between the acres of POG scheduled for harvest in an alternative and the 

mean outcome scores for that alternative. As the number of acres harvested increased among 

alternatives, the mean outcome scores also increased, resulting in greater risk that habitat may not be 

sufficient to maintain viable and well distributed populations. 
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Based upon this strong relationship that emerged, the likely effects of Alternatives 10 and 11 were 

inferred from the acres of old-growth forest scheduled for harvest in these two alternatives, the features of 

these alternatives as compared to the paneled alternatives, and the relative importance of these features 

as judged from panel discussions for individual species. Using this approach the likely effects of 

Alternatives 10 and 11 were discussed in the Biodiversity and Wildlife sections of the FEIS. Because this 

strong relationship facilitated development of an effects analysis and time and expense of reconvening all 

panels was a consideration, alternatives 10 and 11 were not originally subjected to panel risk 

assessment. 

To examine if these inferences were appropriate and presented an accurate analysis of likely effects of 

implementing Alternatives 10 and 11. This second set of six risk assessment panels included the 

northern goshawk, Alexander Archipelago wolf, brown bear, American marten, fisheries resources, and 

other terrestrial mammals. These panels followed the same process as the panels conducted in late 

1995 and early 1996. The conclusions from this second set of panels were consistent with the inferences 

made based on the strong relationship between acres harvested and viability scores (see Appendix N to 

the 1997 FEIS). 

Therefore, this same approach for making inferences is being used in the 2008 Forest Plan Amendment 

FEIS. Additional factors which solidify the accuracy and reasonableness of this approach are that all of 

the 2008 alternative harvest levels are within the range of harvest levels analyzed by the panels and four 

of the seven 2008 alternatives are similar to alternatives directly evaluated by the panel assessments. 

Section 3.2 describes the 1995/1996 and 1997 panel assessment process and Section 3.3 summarizes 

the wildlife panel assessment results. Section 3.3 reviews recent science related to viability analysis and 

Section 3.4 describes the application of the 1995/1996 and 1997 panel assessments to the 2008 

alternatives. Finally, Section 3.5 presents an alternative approach to addressing viability. 

3.2. Description of the 1995/1996 and 1997 Panel Assessment 

Process 

3.2.1. Panel Process 

The panel assessments evaluated alternatives in terms of their ability to maintain habitat sufficient to 

support the continued existence of well-distributed, viable wildlife populations across the Tongass over a 

100-year planning horizon (10 decades of implementation). The panels were conducted with a 

modification of the Delphi process that was used, tested, and judged effective in the President’s 

Northwest Forest Plan. 

To assess relative levels of risk to wildlife species or species groups, a likelihood approach was used 

where evaluators individually assigned 100 “likelihood” points by alternative to five potential outcomes, 

based on the available scientific information. Outcomes included: 

♦ Outcome I: Habitat is of sufficient quality, distribution, and abundance to allow the species to 

maintain well-distributed breeding populations across the Tongass. The concept of well distributed 

must be based on knowledge of the species’ distributional range and life history. 

♦ Outcome II: Habitat is of sufficient quality, distribution, and abundance to allow the species to 

maintain breeding populations distributed across the Tongass. However, some local populations are 

more ephemeral because of reduced population levels and increased susceptibility to environmental 

extremes and stochastic events associated with reduced habitat abundance and distribution. 

Vacated habitats may become recolonized in the future. 

♦ Outcome III: Habitat is of sufficient quality, distribution, and abundance to allow the species to 

maintain some breeding populations, but with significant gaps in the historic distribution in the Forest. 

These gaps are likely permanent and will result in some limitation of interactions among local 

populations. The significance of gaps must be judged relative to the species’ distributional range and 

life history. 
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♦ Outcome IV: Habitat only allows continued species existence in refugia, with strong limitations on 

interactions among local populations. The significance of extirpations across islands or regional 

landscapes must be evaluated relative to the species’ distribution, range, and life history. 

♦ Outcome V: Habitat conditions result in species extirpation from Federal land. 

Likelihood points assigned to these outcomes do not represent absolute probabilities per se, rather they 

represent a relative measure of how likely future outcomes are, based on reasoned professional 

judgment (Shaw 1999). Thus they can be used to compare alternatives, and serve as a measure of the 

evaluators’ certainty about a particular outcome, but by themselves do not represent the percent 

probability of a given outcome. 

For each species, evaluators independently assigned outcome scores to each alternative. For the 

endemic and widely distributed groups, evaluators selected what they determined to be the most 

vulnerable species or group of species, which varied by alternative due to the location of activities 

proposed under each alternative and the geographic distribution of many island endemics (Shaw 1999). 

However, like the single-species panels, each group was assigned only 100 points per alternative. The 

only species for which likelihood ratings were not used was the Sitka black-tailed deer, for which the 

panel assessment relied on the deer habitat capability model to predict potential outcomes (See Wildlife 

section in Chapter 3 for a description). 

Panel evaluators were instructed to evaluate the effect that implementation of the alternatives for 100 

years would have on the abundance and distribution of habitats suitable to support well distributed and 

persistent populations of species assessed. One hundred likelihood outcome points were distributed 

among five possible outcomes. In addition, panel evaluators were asked to appraise features used to 

construct alternatives (e.g., reserves, beach buffers) as to their contribution to maintaining habitat for 

species assessed. These qualitative appraisals of specific features and the panel discussions were used 

by the authors of the written summaries prepared for each panel, to interpret the quantitative evaluation of 

alternatives as indicated by the assignment of likelihood points by outcome and to identify important 

ecological considerations. (Summary reports for each panel were developed and are included in the 

planning record and at http://www.fs.fed.us/pnw/tlmp_app/.) 

In the presentation of panel assignment of likelihood outcome points in each table below, the ‘after’ 

likelihood outcome ratings are used to compare among alternatives since these second ratings benefit 

from professional interaction and a likely greater understanding of differences among features in 

alternatives. The ‘before’ ratings occurred following presentations on alternatives and local information 

on each species, but before the merits of individual alternatives were discussed among panel evaluators. 

The average rating for all panelists also is used, rather than focusing on differences among individual 

evaluators. 

3.2.2. Concepts of Viable and Well Distributed Populations 

In the discussion and analysis of the first set of panel results in the 1997 FEIS, Outcomes I and II were 

often combined as an expression of likelihood of sustaining habitat sufficient to support viable and well 

distributed populations. Conversely, Outcomes III, IV, and V were often combined in effects analysis as 

representing increased risks of not maintaining the habitat necessary to sustain viable and well distributed 

populations. By virtue of its description, Outcome III was difficult to interpret due to the statement that 

“significant gaps” would be created and the “significance of gaps must be judged relative to the species 

distributional range, and life history.” There was considerable variability in the interpretation of this 

concept by individual panelists. The original panelists convened in late 1995 and early 1996 were not 

specifically queried about the relationship between outcomes and the maintenance of viable welldistributed populations. These conclusions were generally inferred, based largely upon whatever 

discussion occurred during panel deliberations. In general, the IDT inferred that Outcome III represented 

a condition where gaps were significant enough to substantially preclude interaction among populations 

of the species. In this condition, a species would not be well distributed, and continued existence of the 

species across the planning area would be at risk. 
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Because of the difficulty the IDT encountered in interpreting the first set of panel results relative to the 

maintenance of well distributed and viable populations, the second set of panelists were provided an 

opportunity to directly and explicitly discuss these issues. The same five outcomes were used in the 

second panels conducted in 1997. However, focused discussion provided additional information relative 

to Outcome III and the panelists’ interpretation of gaps in distribution, well distributed populations, and 

viability. 

Outcome III, defined as providing habitat to maintain breeding populations but with significant gaps in 

historic distribution, was interpreted as an array of conditions. For some of the panels, one end of this 

array was any condition where gaps in habitat existed as small as the territory of a single animal or single 

pair of animals of the species being assessed. At the other end, this array could include conditions with 

broad gaps in habitat distribution and significant limitations on population interactions. The panelists 

considered some part of this array of conditions as meeting their concept of viable and well distributed. 

They indicated that the concepts of well distributed and viable, as they used them for the purposes of 

assessing risk, were not necessarily synonymous. Their views on well distributed habitat dealt primarily 

with the likelihood that modified habitat would, because of gaps, no longer be able to support a 

continuous territory-to-territory distribution of resident individuals or groups. That is, some previously 

occupied territories might become permanently vacant within a 100-year timeframe. 

The panelists interpreted viability as a condition in which populations could continue to interact and 

interbreed within their historic distribution across the Tongass National Forest. They felt that a distribution 

that included some gaps could still be considered viable as long as there was still interaction among the 

population segments on the forest and those population segments were distributed across the species 

range. For example, the marten panel understood that their concept of a habitat gap being as wide as a 

previously occupied home range likely had little if any effect on species interaction or interbreeding. 

Thus, in the panelists’ interpretation, the criterion of well distributed was more restrictive than the criterion 

of viable. 

The panelists were not providing a legal interpretation of the requirement in the National Forest 

Management Act of 1976 (NFMA) regulations to provide for viable populations. In the discussion of 

population viability in the NFMA regulations, the concept of “well-distributed” is tied to the ability to 

continue interactions among individuals of a species, not necessarily to the maintenance of a territory-toterritory distribution of the species. The interpretation of well distributed is expressed most clearly in the 

stipulation that maintenance of a viable population requires providing habitat to support “at least a 

minimum number of reproductive individuals and that habitat must be well distributed so that those 

individuals can interact with others in the planning area” (36 CFR 219.19). This has been interpreted to 

mean that the condition of viable and well distributed allows for gaps within a species distribution as long 

as the population segments of the species continue to interact and are distributed throughout the planning 

area. Thus, the concept of well distributed used by the panelists was more stringent than the concept as 

applied in the NFMA regulations. 

It is difficult to determine how many likelihood points were assigned to the outcome of a viable population 

since the panelists considered that only some part of the array of conditions under Outcome III met their 

definition of viable. Thus, the likelihood of maintaining habitat sufficient to support well distributed and 

viable populations is appropriately presented as being within the span of scores that bracket Outcome III. 

Consequently, in some of the tables in the following discussions, ratings are expressed as being greater 

than the sum of likelihood scores for Outcomes I and II, but less than the sum of likelihood scores for 

Outcomes I, II and III. Expression of data as a range also illustrates the uncertainty in the process and 

the variability in the professional judgments regarding the concepts of viable and well distributed 

populations. Use of a range also avoids presenting a single absolute value that might suggest a level of 

precision that does not exist in this assessment process. 

Finally, in some of the following tables, 1995/1996 panel outcome scores are expressed in the same 

manner of bracketing scores as for the 1997 scores discussed above. Expression of the first panel 

information in this manner is for comparative purposes only. These combinations do not infer any 

conclusions on behalf of the 1995/1996 panels because they did not specifically discuss viable and well 

distributed populations relative to the specific outcomes. 
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3.3. Summary of 1995/96 and 1997 Panel Assessment Results for 

Wildlife 

3.3.1. Northern Goshawk 

3.3.1.1. General Observations on the Goshawk Panels 

Panelists noted the apparent low relative density of nesting goshawks in Southeast Alaska. Less than 40 

total nest sites had been identified by the time of the assessments after nearly 5 years of inventory effort 

across the Forest (Iverson 1996a). Low prey diversity compared to other goshawk populations across 

North America was considered a principle factor, resulting in a higher sensitivity to habitat modifications 

which may reduce prey diversity and abundance. 

The primary factor used by panelists in rating the likelihood of alternatives to support a viable and welldistributed goshawk population was net proportion of all old growth on the Tongass that would be 

harvested in 100 years (Iverson 1996a, 1997a). This was based on science current at the time of the 

panel assessments that indicated the strong selection by goshawks for POG forest and the avoidance of 

all other habitat types (especially early and mid seral conifer forests), though panelists noted that the 

reliance on this factor was somewhat general due to the lack of more specific information on goshawks in 

Southeast Alaska and what specific old-growth acres would be harvested. 

The 1995 panel assessment used 20 percent of the POG harvested as a threshold level beyond which 

local persistence and viability were concerns (Iverson 1996a). Most notable was north Prince of Wales 

Island where in excess of 20 percent of the POG had been harvested. Significant concern arose over this 

and increased proportions of unsuitable early seral forest on the landscape. This concern was generated 

from the relatively low density of nesting goshawks discovered relative to the inventory effort in those 

landscapes. In addition, potential signs of ecological stress was indicated by large home ranges, 

nonbreeding, and differential winter and breeding use areas. Thus, qualitative judgments concluded that 

alternatives resulting in this or a greater percentage of the net POG harvested could result in negative 

overall landscape consequences to sustaining resilient, adaptable, and well distributed goshawk 

populations in Southeast Alaska. While such thresholds were considered by the 1997 panel, they did not 

make any conclusions regarding harvest thresholds due to the lack of information and other uncertainty 

(Iverson 1997a). They suggested that to draw conclusions relative to harvest thresholds, further 

information was needed on the demographic performance of goshawks under different situations. 

In addition, alternatives that proposed standards and guidelines to maintain important landscape 

components such as riparian, beach and estuary buffers were rated as having higher likelihoods of 

supporting well-distributed goshawk populations. These habitats are used by goshawks when old-growth 

forest is present and they also generally support greater prey diversity and net prey productivity. The 

ability of stands to provide structure adequate to support prey populations and goshawk foraging 

opportunities was also considered important and related to the length of rotation and harvest method 

proposed under the alternatives. 

The concept of habitat reserves was seen as a less important landscape design feature, since 

management of the landscape matrix as a whole was felt to have a greater net influence on goshawk 

habitat suitability, distribution and persistence. Large (40,000 acre) and medium (10,000 acre) habitat 

reserves as proposed were generally considered too small to sustain more than one or two pairs of 

goshawks. Roads were not considered an adverse element, thus roadless features of reserves did not 

generally contribute to overall habitat suitability. 

Panelists concluded that at some, albeit low, minimum level, forest management was not considered 

adverse to overall goshawk habitat suitability and likely contributed to stand diversity. 

Given the wide ranging nature of goshawks, the panels emphasized the importance of matrix 

management to providing habitat capable of supporting viable and well-distributed goshawk populations. 

However, elements of the reserve system (i.e., large and medium habitat reserves and legislated 
Appendix D

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D-56

conservation areas) were deemed important because by default they reduced the net acreage of oldgrowth harvested. 

3.3.1.2. Goshawk Panel Results 

The final average panel ratings for northern goshawk are displayed in Table D-9. Alternative 1 in 1997 

essentially represents a no-harvest alternative. Nearly two-thirds of all likelihood points were assigned to 

Outcome I, which indicates that well distributed goshawk breeding populations would be maintained 

across the Tongass. However, Outcome II received nearly a third of likelihood scores, suggesting that 

even with no further reduction in old-growth forest, goshawk populations would likely experience 

reductions and local persistence may be more ephemeral or irregular as a result of the local 

concentration of habitat loss from past timber harvest. Implied in this conclusion is that additional harvest 

would be additive to an existing effect. 

Because of the significant amount of legislatively reserved lands and the net amount of POG that would 

likely remain under even the most aggressive timber harvest alternatives, panelists believed there was 

little chance for total extirpation of the goshawk population from Southeast Alaska. The highest rating for 

Outcome V (extirpation) was only 8 (for 1997 Alternative 7). Moderately high net scores for Outcomes I 

and II occurred for 1997 Alternatives 4 and 5 (65 and 74-85, respectively). These alternatives had in 

common the use of extended 200-year rotations. Panelists generally believed that forest structure 

resulting from mid-seral mature forest developmental stages (100 to 200 years old) was more beneficial 

to goshawks and their prey than a combination of reserves and shorter, 100-year rotations. 

The 1997 panel assigned 71 likelihood points to 1997 Alternative 11 for the sum of Outcomes I and II, 

and 97 likelihood points to the sum of Outcomes I, II and III. Even though this alternative was based on a 

100-year rotation, its ratings were second highest of all alternatives that proposed to continue timber 

harvest, only slightly lower than the rating given to Alternative 5. In addition, Alternative 11 was rated as 

having very low likelihood of goshawks existing in refugia or being extirpated from the Tongass after 100 

years of Forest Plan implementation with a combined Outcome IV and V score of 3. 

Alternatives 3, 6, and 10 (1997) had intermediate combined Outcome I and II scores of 52, 50, and 48, 

respectively. In spite of partial or complete application of habitat reserves, the higher overall old-growth 

harvest levels, coupled with the 100-year rotation perpetuated a less suitable early seral forest stand 

structure and was a drawback for these alternatives. Conversely, panelists attributed moderate 

uncertainty that either of these two alternatives would maintain well distributed populations, with a 

combined score of Outcomes III, IV and V of 48 (1997 Alternative 3), 50 (1997 Alternative 6), and 53 

(1997 Alternative 10). This suggested there was a nearly even chance that either permanent gaps in the 

distribution would occur or goshawks may exist only in refugia under these three alternatives in 100 

years; and in either case interaction between individuals would likely diminish. The forest-wide system of 

old-growth habitat reserves proposed in 1997 Alternatives 3 and 10 alone imbedded in a matrix of early 

seral forest structure managed on a 100-year rotation were rated by the panelists to be of insufficient size 

to support goshawk populations without gaps in distribution or refugia populations occurring. 

Alternatives 2, 7 and 9’ (1997) were rated by panelists as having a relatively high likelihood (76-80, 88, 

and 77-92, respectively) that in 100 years gaps in distribution would be likely to occur or populations 

would exist only in isolated refugia or be extirpated (Outcomes III, IV, or V). When Alternative 9 was 

analyzed in 1997 with a lower harvest, results were nearly the same producing a likelihood of 90. 

Variation in ratings for alternatives assessed in both 1995 and 1997 ranged up to 18 points based on the 

sum of likelihood points assigned to Outcomes I, II and III (Table D-9). Of those alternatives reviewed in 

both 1995 and 1997, 1997 Alternatives 1, 5, 2, and 9' were ranked in order (based on average weighted 

outcomes) from least to highest risk to goshawk habitat in both of the assessments. The 1997 panels 

also confirmed the judgment in Chapter 3 of the 1997 FEIS, based on a detailed analysis of VCUs, that 

1997 Alternatives 5 and 11 had the highest likelihood of sustaining goshawk habitat across the forest of 

all alternatives that proposed to continue timber harvest. However, the analysis in Chapter 3 resulted in a 

conclusion that 1997 Alternative 11 had a slightly higher likelihood of maintaining goshawk habitat than 

1997 Alternative 5. 
Final EIS C

Wildl

D-57

Table D-9. Northern Goshawk Panel Results1

1997 Forest Plan Revision FEIS Alternatives 

Outcomes Pre 1954 1 5 11 4 10 3 6 8 2 9 9’ 

1997 Panel 

I 89 63 35 23 8 1 0 0 

II 11 38 50 48 40 19 10 8 

III 0 0 15 28 48 61 61 61 

IV 0 0 0 3 5 16 26 29 

V 0 0 0 0 0 5 3 3 

Potential POG Harvest 

(1,000s of acres) - 414 0 463 475 495 670 571 732 -- 853 1,042 1,40

1995 Panel 

I 66 23 23 17 6 0 0 0 

II 31 51 42 35 44 27 24 23 

III 3 25 29 34 33 41 40 42 

IV 0 1 6 14 17 29 33 32 

V 0 0 0 0 0 3 4 3 

Potential POG Harvest 

(1,000s of acres) -- 0 572 -- 618 -- 736 954 955 1,107 -- 1,40

Range Between Outcomes I + II and I + II + III 

1997 Panel 100 100 85-100 71-97 -- 48-96 -- -- -- 20-61 10-61 8-61 1995 Panel -- 97-100 74-99 -- 65-94 -- 52-86 50-83 27-68 24-64 -- 23-6

1 Mean likelihood outcome scores by evaluators in 1997 are shown at the top of the table. Scores from the 1995 panel are shown in the middle of the ta

were assigned by both panels for Alternatives 1, 2, 5, and 9’. Alternatives 1 and 9’ are identical between panels in both features and acres of POG harAlternatives 2 and 5 are identical in features but with fewer acres of POG harvested in 1997 relative to 1995. A range for all alternatives is shown at ththe table for the likelihood of maintaining habitat to support viable and well distributed goshawk populations. Only ‘after’ scores are shown. The - 414,

POG harvest under Historic represents the acreage harvested since 1954. 
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3.3.1.3. Effects of Added Habitat Management Measures 

Even though 1997 Alternative 11 was rated second highest in terms of viability among all alternatives that 

proposed to continue timber harvest and had a very low likelihood of goshawks existing in refugia or 

being extirpated from the Tongass after 100 years of Forest Plan implementation, because it was the 

selected alternative and because the goshawk had been considered for listing under the Endangered 

Species Act, 1997 Alternative 11 was reviewed to determine if features of the alternative could be 

modified to improve the projected outcome. 

The conservation assessment for northern goshawk (Iverson et al. 1996) evaluated the effect of various 

management practices on goshawk nesting and foraging habitat, and also identified specific geographic 

locations where goshawk habitat had been highly fragmented. Based on this information, an additional 

measure for goshawk habitat was prescribed for Prince of Wales Island where POG had been 

fragmented by past management actions. This measure applied in VCUs where over 33 percent of POG 

had been converted to young stands by past management. In those VCUs, any additional management 

of POG was to be either restricted to 2-acre clearcuts or be managed to leave significant structure in 

harvested stands. 

This standard and guideline applied to management activities in VCUs on Prince of Wales Island with a 

high percentage of past harvest. Approximately 55 percent of the total original POG had been converted 

to young forest in these VCUs. For any additional harvest of POG in these VCUs, the standard and 

guideline had the effect of either implementing a 200-year uneven-aged management regime or leaving 

structure equivalent to 30 percent of the cover of the original stand. Neither of these practices was 

expected to produce high-value nesting habitat, but they were expected to result in moderate to high 

value foraging habitat (Iverson et al. 1996). This structure, in combination with matrix management 

provisions for beach fringe and riparian management areas, was believed to facilitate goshawk dispersal 

among large and medium reserves on Prince of Wales Island. Goshawks were also considered to benefit 

in other provinces by the measures put in place for marten and for connectivity. Again, these had the 

effect of facilitating dispersal among goshawk populations in reserves. Taken in combination with other 

measures already in place in 1997 Alternative 11, these increased the already high likelihood of providing 

habitat sufficient to maintain viable and well-distributed goshawk populations and, had they been added 

prior to the panel assessments, may have increased the likelihood points. 

3.3.2. American Marten 

3.3.2.1. General Observations on the Marten Panels 

Forest structure at the stand scale and integrated across the landscape was the most important factor in 

panel ratings and discussion due to the close association of marten with lower elevation and higher 

volume old growth and because these stands have also received a disproportionate amount of timber 

harvest (Iverson 1996b, 1997b). Structural complexity, associated with older forest stands, was also 

deemed important for providing habitat to support adequate prey populations of small mammals. The 

ability of alternatives to provide structural complexity was related to the proposed harvest rotation, which 

was a primary factor in the panel ratings. The panels considered 100 years an inadequate amount of 

time to produce structural elements such as large trees, snags, and downed logs that are used by marten 

and provide prey habitat. Maintaining the old-growth forest within the beach and riparian habitat zones 

was considered important by panelists, particularly for landscape connectivity and prey habitat diversity. 

Both marten panels agreed that large and medium reserves as designated by the VPOP provide 

important habitat features for marten (Iverson 1996b, 1997b). Both panels indicated, however, that the 

VPOP approach to establishing a system of well distributed OGRs was only minimally acceptable for 

marten. The approach was judged to be minimal primarily because its spatial distribution of reserves 

could allow for the creation of “gaps” in marten distribution within harvested matrix lands. 

Roads were a minor consideration in panel ratings in relation to their impact on human access. As with 

wolves, it was not the direct effect of the number of road miles or road density proposed under the 
Appendix D

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alternatives, but rather increased trapping pressure and related mortality resulting from increased access 

which could be mitigated through appropriate road management, seasons, and bag limits. 

3.3.2.2. Marten Panel Results 

The final average panel ratings for American marten are displayed in Table D-10. Alternative 1 (1997) 

provided the greatest likelihood of maintaining well distributed marten populations across their current 

range on the Tongass. It had a mean likelihood rating of 54 (in 1995) to 84 (in 1997) for Outcome I. The 

1995 panelists indicated that even with no further timber harvest and road construction, there was still a 

reasonable likelihood that local populations would be reduced or gaps that limit populations would be 

created with little interaction within the species range, as indicated by a combined score of 46 for 

Outcomes II and III. Concentration of past timber harvest in specific provinces and past harvest primarily 

in the high-volume classes which were concentrated at lower elevations contributed to this conclusion. In 

contrast, however, the much higher ratings given by the 1997 panel indicated they thought that past 

timber harvest would create few gaps in marten distribution (combined score of only 17 for Outcomes II 

and III). 

Panelists concluded that there was no likelihood of extirpation of marten from the entire Tongass National 

Forest under all alternatives in 1997 and under most alternatives in 1995. In 1995, Alternatives 2, 9, and 

7 were considered to have some chance of extirpation (likelihood scores of 15-25 for Outcome V). 

Anticipated timber harvest, especially in the remaining high-volume class stands at lower elevation, and 

road construction, contributed to this conclusion. 

The likelihood that in 100 years an alternative would result in either significant gaps in distribution, 

populations existing in relatively isolated refugia, or local extirpations, may be an indication that marten 

populations would not remain well distributed across the forest. This cumulative likelihood is the sum of 

Outcomes III, IV, and V. From this perspective, 1995-1997 Alternatives 2, 7, 8, 9 and 9’ were given 

cumulative ratings of 80 to 91, depending on the panel and the alternative. Alternative 6 (1995) also had 

a relatively high cumulative likelihood outcome of 72. Extensive planned roading, continued 

fragmentation of habitat, and most importantly, a significant reduction in the important high-volume oldgrowth forest component were factors cited by panelists that contributed to these conclusions. Even 

(1995-1997) Alternatives 3, 10, and 11, with their significant reserve components had combined Outcome 

III, VI, and V ratings of 56 to 70, suggesting a better-than-even chance that well distributed populations 

may not be maintained across the Tongass in 100 years. All of these alternatives had in common a 100-

year timber harvest rotation. 

Alternatives 4 and 5 (1995-1997) were rated intermediate by the panelists in their likelihood of 

maintaining persistent and well distributed marten breeding populations, with combined scores for 

Outcome I and II of 60 and 66-70, respectively. Extended 200-year timber harvest rotations was the most 

important design feature for sustainable approaches to providing marten habitat.

Alternative 10 (1997) was intermediate between 1997 Alternatives 2 and 3 in both design features and 

acres of old growth harvested; thus risks to maintaining viable marten populations were considered 

intermediate between these two alternatives. In spite of having a system of large, medium and 

unmapped small reserves that would reduce risks relative to 1997 Alternative 2, the 100 year rotation, 

only a 500-foot beach fringe, and smaller riparian buffers in 1997 Alternative 10 was considered as 

possible long-term risks to marten. 
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Table D-10. American Marten Panel Results1

1997 Forest Plan Revision FEIS Alternatives 

Outcomes Pre 1954 1 5 11 4 10 3 6 8 2 9 9’ 

1997 Panel 

I 90 84 1 0 0 0 0 0 

II 9 9 65 36 30 19 13 11 

III 1 8 29 55 59 64 53 50 

IV 0 0 5 9 11 18 35 39 

V 0 0 0 0 0 0 0 0 

Potential POG Harvest 

(1,000s of acres) - 414 0 463 475 495 670 571 732 -- 853 1,042 1,403 

1995 Panel 

I 54 17 15 4 3 3 3 3 

II 25 53 45 40 25 17 6 6 

III 21 24 37 41 42 42 55 46 

IV 0 6 3 15 30 35 21 24 

V 0 0 0 0 0 3 15 21 

Potential POG Harvest 

(1,000s of acres) -- 0 572 -- 618 -- 736 954 955 1,107 -- 1,403 

Range Between Outcomes I + II and I + II + III 

1997 Panel 99-100 93-100 66-95 36-91 -- 30-89 -- -- -- 19-83 13-66 11-61 1995 Panel -- 79-100 71-95 -- 60-97 -- 44-85 28-70 20-62 8-64 -- 9-55 

1 Mean likelihood outcome scores by evaluators in 1997 are shown at the top of the table. Scores from the 1995 panel are shown in the middle of the ta

were assigned by both panels for Alternatives 1, 2, 5, and 9’. Alternatives 1 and 9’ are identical between panels in both features and acres of POG harAlternatives 2 and 5 are identical in features but with fewer acres of POG harvested in 1997 relative to 1995. A range for all alternatives is shown at ththe table for the likelihood of maintaining habitat to support viable and well distributed goshawk populations. Only ‘after’ scores are shown. The - 414

for POG harvest under Historic represents the acreage harvested since 1954. 
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Alternative 11 (1997) had additional features that further increased the likelihood of maintaining viable 

goshawk populations relative to 1997 Alternative 3, such as mapped small reserves in all watersheds, 

and allocation of four additional medium and small reserves. The 1,000-foot beach and riparian 

protection were similar among 1997 Alternatives 11 and 3, but 1997 Alternative 11 had substantially 

fewer old growth acres scheduled for harvest (475,000) and thus lower risk than 1997 Alternative 3 

(571,440). Total acres harvested in 1997 Alternative 11 was even fewer than 1997 Alternative 4 

(495,000), in spite of the 200-year rotation. Alternative 11 (1997) did not have a two-aged silvicultural 

prescription that maintained forest structure considered important by panelists, but the net acres old 

growth disturbed might have offset either the potential advantage of two-aged management in 1997 

Alternative 3 or two-aged management and a 200-year rotation in 1997 Alternative 4. 

Of those alternatives reviewed in both 1995 and 1997, Alternatives 1, 5, 2, and 9' were ranked in order 

from least to highest risk to marten habitat in both assessments (Table D-10). The 1997 panel results 

also were consistent with conclusions drawn concerning the relative ranking of all alternatives based on 

other evidence in Chapter 3 of the 1997 FEIS and other information in the planning record. This includes 

the conclusion that outcomes of 1997 Alternative 11 would be similar to those of 1997 Alternative 3. 

3.3.2.3. Effects of Added Habitat Management Measures 

American martens were one of the primary species considered in the design of the original VPOP 

strategy. By design, each large HCA was intended to support at least 25 female martens, medium HCAs 

to support at least 5 female martens, and small HCAs at least 1 female. Each large HCA was designed 

to support a population with high likelihood of at least short-term persistence. The design distance 

between large HCAs was 25 miles, approximating the maximum dispersal distance recorded for marten, 

and medium and small HCAs were spaced more closely. Forested corridors were to provide for dispersal 

among HCAs. All corridors were to be at least 330 feet wide, and riparian and beach fringe habitats were 

considered appropriate corridors where they provided connections among the HCAs. This network of 

interconnected HCAs was intended to support a number of local populations that could interact as a 

metapopulation, thus providing for long-term viability. 

Three of the scientists involved in the Kiester and Eckhardt (1994) review identified limitations in this 

strategy for marten. Benkman, Lidicker, and Powell questioned the use of the maximum marten dispersal 

distance to establish spacing among HCAs. Benkman cautioned that this strategy would only work if the 

medium and small HCAs provided connections among the large HCAs. Lidicker added that the condition 

of the matrix ought to be considered when establishing distances among HCAs. Powell indicated that 

marten would generally not travel directly between HCAs, so the actual distances they would have to 

cover would exceed the design distance. None of these reviewers commented directly on the size of 

large or medium HCAs, but both Benkman and Powell noted that the small HCAs would be unlikely to 

support even one pair of marten by themselves. A number of the reviewers in Kiester and Eckhardt 

(1994) commented in general that the utility of corridors for wildlife dispersal had not been demonstrated. 

None of these comments were specific to marten, possibly because marten are known to make extensive 

use of riparian zones (Bissonette et al. 1989, Clark et al. 1987). 

The VPOP strategy is most fully represented in 1995-1997 Alternative 3. The risk assessment panel 

convened in 1995 rated this alternative intermediate between 1995 Alternative 1 (no further harvest) and 

1995 Alternative 9 (continuation of the existing plan). They indicated that there was a better than equal 

likelihood that implementation of this alternative for 100 years would result in significant gaps in marten 

habitat distribution on the Tongass. They projected no likelihood that marten would be extirpated from 

the entire forest under this alternative. 

The risk assessment panel convened in 1997 gave Alternative 11 a similar risk rating to that given to 

Alternative 3 in 1995. Alternative 11 (1997), as rated by the panel, provides for a wider beach fringe 

buffer than 1997 Alternative 3, but it also relies more heavily on even-aged management in the matrix. 

Panelists noted that the projected matrix conditions had a significant influence on their ratings. The 

panelists convened in 1997 also clarified their interpretation of the outcomes that were used as the basis 

for risk assessment. Outcome III, defined as providing habitat to maintain breeding populations but with 

significant gaps in historic distribution, was interpreted as an array of conditions. At one end of this array 

was any condition where gaps in habitat existed as small as the territory of a single marten. At the other 
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D-62

end, this array could include conditions with broad gaps in habitat distribution and significant limitations 

on population interactions. The panelists considered some part of this array of conditions as meeting the 

definition of viable and well-distributed. The panelists assigned a total of 91 likelihood outcome points to 

the sum of Outcomes 1 + II + III. This included 36 likelihood points in Outcomes I and II, which they 

considered to represent a viable and well distributed condition. It also included 55 likelihood points in 

Outcome III, some portion of which represents a viable and well distributed condition. The panelists 

indicated there was a very low likelihood that marten would exist only in refugia or be extirpated from the 

Tongass after 100 years of Forest Plan implementation with a combined Outcome IV and V score of 9. 

The panelists indicated that matrix management was the feature of 1997 Alternative 11, as rated, that 

contributed to the assignment of likelihood points to outcomes that were not well-distributed. They 

indicated that clearcut silviculture on a 100-year rotation would result in further fragmentation of marten 

habitat. 

Alternative 11 (1997) was strengthened subsequent to the panel assessment because that assessment 

indicated a level of concern about the likelihood of marten populations remaining well-distributed across 

the Tongass for at least 100 years. The measures used to strengthen the alternative were based on 

comments provided by the panelists, information drawn from past studies on marten, and information on 

existing habitat conditions on the Tongass. Three different measures were applied to 1997 Alternative 11 

to improve the likelihood of maintaining habitat to support well-distributed populations of marten. 

The first directs the management of high quality marten habitat in five biogeographic provinces where 

marten habitat was considered to be at higher risk. These five biogeographic provinces were identified by 

the VPOP risk assessment as the highest risk provinces of the 21 provinces across the Tongass National 

Forest (Suring et al. 1993). High value habitat is defined in the Interagency Marten Habitat Capability 

Model (Suring et al. 1993) as consisting of high-volume old-growth stands at elevations below 1,500 feet. 

Within the high-risk provinces, these stands were to be managed under practices other than clearcutting. 

In VCUs where 33 percent or more of the POG had been or was projected to be harvested, further 

harvest in any high-value marten habitat would retain at least 30 percent canopy closure, 8 large live 

trees per acre, 3 large decadent trees per acre and 3 logs per acre. Where less than 33 percent of POG 

had been harvested, further harvest in high-value marten habitat would retain 10-20 percent canopy 

closure, 4 large live trees per acre, 3 large decadent trees per acre, and 3 logs per acre. These habitat 

management measures were based on studies showing marten use higher in partially logged areas than 

clearcut areas (Soutiere 1979); a study reported by Hargis and Bissonette (1997) and Hargis et al. (1999) 

indicating that the proportion of clearcut harvesting at a landscape scale is a key determinant of marten 

success; and numerous studies showing the importance of large wood structure to marten (Baker 1992, 

Buskirk et al. 1989, Corn and Raphael 1992, Raphael and Jones (1997). 

The second measure provided for access management to reduce marten mortality in areas where 

mortality rates due to trapping/hunting had been identified as a serious risk to marten populations. The 

third measure provides additional assurance of maintaining connections between habitat blocks 

throughout the Tongass. It required an analysis of the effectiveness of features such as small reserves, 

beach fringe and riparian buffers in providing for connection between old-growth blocks in medium and 

large reserves and other natural setting LUDs. Where these measures do not provide for full connectivity, 

additional habitat was to be allocated to provide for connectivity of old-growth habitats. 

With all measures in place, 1997 Alternative 11 was modified to provide for a network of large and 

medium-sized HCAs, capable of supporting 25 and 5 female marten each, respectively. Connection 

between HCAs was provided by protected habitats in riparian and beach fringes, small HCAs, and 

additional old-growth habitat designated for connectivity where these protected habitats were not 

adequate. Connections through the riparian and beach fringe were believed to be effective for marten 

based on studies that have shown preferential use by marten of riparian zones (Buskirk et al. 1989, 

Raphael and Jones (1997), Spencer and Zielinski 1983). The matrix between the reserves also 

contained significant, although fragmented, old-growth habitat. An average of 57 percent of the pre-1954 

POG was estimated to remain unharvested in the matrix areas through the planning horizon of 100 years. 

The percent of old growth remaining in the matrix varies by province, but in those provinces considered at 

highest risk the additional habitat measures described above were to be applied in the matrix. In addition 
Appendix D

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D-63

to all of the above habitat measures, road access was to be managed to reduce marten mortality where 

mortality had been identified as a significant risk. 

Full implementation of the above strategy was believed to increase the likelihood of maintaining habitat 

that would support well-distributed marten populations. While there would likely be gaps in this 

distribution, it was estimated that there was low likelihood that there would be significant isolation among 

marten populations resulting from implementation of 1997 Alternative 11. 

3.3.3. Alexander Archipelago Wolf 

3.3.3.1. General Observations on the Wolf Panels 

Important assessment factors for wolves were deer habitat capability, wolf mortality, and wolf dispersal 

capabilities; genetic information indicating the existence of the Alexander Archipelago subspecies was 

new at the time of the panel assessments and was also considered, though not as a major factor. Deer 

habitat capability was ranked as the most important factor influencing panel evaluators’ ratings because 

of the close link between wolf persistence and deer habitat capability (Iverson 1996c, 1997c). Thus, 

alternatives that contributed to greater deer habitat capability, as determined by the deer habitat capability 

model (see Wildlife section of Chapter 3 for a description), and thus greater numbers of deer, were 

ranked as more likely to sustain viable and well-distributed wolf populations. Deer habitat capability can 

be reduced directly by timber harvest, which may increase deer vulnerability to predators, especially in 

winters of heavy snowfall. 

Roads were a primary factor associated with wolf mortality identified by the panels; however, the panels 

agreed that the main issues were related to human access and attitudes (i.e., issues of season and bag 

limits, proper access management, and human education), rather than the miles of road or road densities 

proposed by the alternatives. It was recognized that increased road densities contributed to increased 

legal and illegal mortality. Thus, the value of maintaining roadless refugia was identified as a means of 

providing deer habitat capability and controlling human access, and alternatives that maintained such 

areas were ranked as more likely to sustain viable and well-distributed wolf populations. 

Wolf population distribution and the interaction of populations with respect to gaps was also an issue 

discussed by the panel, given the dispersal capabilities of wolves. A gap in wolf distribution was defined 

as approximately 100 square miles between populations, or the estimated size of a wolf pack territory on 

Prince of Wales Island. The most current genetic information available at the time suggested that 

interchange among wolf populations was occurring across major island groups in Southeast Alaska. 

However, there was disagreement on this point between local experts and evaluators since direct 

ecological evidence suggested the existence of dispersal barriers or at least severe limitations to such 

dispersal, especially between Prince of Wales Island and neighboring islands and the mainland, as 

demonstrated by available radio-telemetry data (Iverson 1996c). The panel did highlight the potential 

ecological concerns associated with insular populations of wolves. 

3.3.3.2. Wolf Panel Results 

The final average panel ratings for Alexander Archipelago wolf are displayed in Table D-11. For all 1997 

alternatives, it was concluded that there was virtually no chance of extirpation of the wolf from the 

Tongass National Forest (Outcome V). All alternatives had only 1 of a possible 100 points assigned to 

this outcome, with the exception of Alternatives 9 and 9’ in the 1997 panel, which had 3 points assigned. 

This likely represents a chance catastrophic event that, in combination with normal Forest Service activity, 

would result in the complete extirpation of wolves. 

Alternative 1 (1997) provided the greatest relative likelihood of maintaining stable well distributed wolf 

populations across their current range on the Tongass. However, panelists indicated that even with no 

action, past management activity that reduced deer habitat capability on some portions of the forest 

(north and central Prince of Wales Island were specifically identified) would at least result in some 

likelihood of locally reduced population levels (the sums of Outcomes II, III, and IV were 12 – 19, 

depending on the panel). Outcome II for Alternative 1 was explained as the likely result of natural 

fluctuations in wolf populations in response to prey availability and other environmental factors.
Appendix D

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D-64

Table D-11. Alexander Archipelago Wolf Panel Results1

1997 Forest Plan Revision FEIS Alternatives 

Outcomes Pre 1954 1 5 11 4 10 3 6 8 2 9 9’ 

1997 Panel 

I 89 88 55 58 54 20 18 18 

II 8 6 29 25 26 43 30 30 

III 1 3 13 14 16 34 44 44 

IV 1 3 3 3 3 3 6 6 

V 1 1 1 1 1 1 3 3 

Potential POG Harvest 

(1,000s of acres) - 414 0 463 475 495 670 571 732 -- 853 1,042 1,40

1995 Panel 

I 80 48 34 59 26 7 35 3 

II 14 34 39 25 38 43 25 31 

III 3 16 24 14 31 40 30 48 

IV 2 1 2 1 4 9 9 18 

V 1 1 1 1 1 1 1 1 

Potential POG Harvest 

(1,000s of acres) -- 0 572 -- 618 -- 736 954 955 1,107 -- 1,40

Range Between Outcomes I + II and I + II + III 

1997 Panel 97-98 94-97 84-97 83-97 -- 80-96 -- -- -- 63-97 48-92 48-91995 Panel -- 94-97 82-98 -- 73-97 -- 84-98 64-95 50-90 60-90 -- 34-8

1 Mean likelihood outcome scores by evaluators in 1997 are shown at the top of the table. Scores from the 1995 panel are shown in the middle of the ta

were assigned by both panels for Alternatives 1, 2, 5, and 9’. Alternatives 1 and 9’ are identical between panels in both features and acres of POG harAlternatives 2 and 5 are identical in features but with fewer acres of POG harvested in 1997 relative to 1995. A range for all alternatives is shown at ththe table for the likelihood of maintaining habitat to support viable and well distributed goshawk populations. Only ‘after’ scores are shown. The - 414

for POG harvest under Historic represents the acreage harvested since 1954. 
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Because of the intensity of proposed harvest activity and anticipated significant regional reductions in 

deer habitat capability, Alternatives 2, 7 and 9 were rated by the 1995 panel to have some likelihood 

(range 9-19) of creating populations that would exist in refugia with severely restricted interaction 

between them (Outcome IV) (Iverson 1996c); the points for this outcome were dropped considerably by 

the 1997 panel, ranging from 3 to 6 for Alternatives 2, 9, and 9’ (Iverson 1997c). 

The likelihood of an alternative resulting in a situation in 100 years where either gaps in distribution occur, 

populations exist in refugia, or total extirpation may be a general indication that wolf populations would 

not remain well distributed across the Tongass compared to historical distributions. This cumulative 

likelihood is considered the sum of Outcomes III, IV, and V. The 1995 and 1997 versions of Alternatives 

7, 8, 9, and 9’ all had relatively high cumulative likelihood outcomes, ranging from 50 to 71. Moderate 

likelihoods existed for Alternatives 2 (40) and 6 (36). These cumulative outcomes are generally directly 

related to the total harvest levels and associated reductions in deer habitat capability and all have in 

common a 100-year timber harvest rotation timber management regime. 

Overall, the results of the 1995 and 1997 evaluations were consistent. Of those alternatives reviewed in 

both 1995 and 1997, Alternatives 1, 5, 2, and 9' were ranked in order from least to highest risk to wolf 

habitat in both assessments (Table D-11). In the 1997 evaluation, Alternatives 11, 10, and 5 were all 

given relatively high ratings, and these were similar to ratings given to Alternative 3 in 1995. These 

results are consistent with the discussion of alternatives in Chapter 3 of the 1997 FEIS, except that the 

analysis in Chapter 3 clearly distinguished Alternative 11 as the most favorable for wolves among the 

alternatives that propose to continue timber harvest, primarily due to the more extensive reserve system 

in Alternative 11. 

3.3.4. Brown Bear 

3.3.4.1. General Observations on the Brown Bear Panels 

Important assessment factors identified by the brown bear panel included acres harvested, roads and 

access management, large reserves and legislated conservation areas, and riparian habitat 

management. Alternatives that harvested more acres were given a lower likelihood of maintaining habitat 

sufficient to support a viable and well distributed brown bear population. The driving force behind this 

relationship were the cumulative effects of timber harvest (i.e., the combination of clearcuts, road 

construction, and risks to salmon populations on bears), though direct effects, such as the temporary 

displacement of bears due to their tendency to avoid recently clearcut areas, were also taken into account 

(Iverson 1996d, Meade 1997). Likewise, alternatives that did not include effective access management 

or proposed a greater number or road miles were rated as having a lower likelihood of supporting viable 

and well-distributed brown bear populations. This was related to the potential for direct effects such as 

the increased potential for brown bear mortality due to legal hunting, illegal killing, and defense of life and 

property, as well as the creation of either temporary or permanent gaps in the distribution of the brown 

bear population. Indirect effects associated with the extent of proposed road construction related to the 

risks posed to anadromous salmon, the primary food source of brown bears (the panels relied on the 

1996 fish and riparian panel results to assess this). 

Large OGRs and legislated conservation areas where timber harvest is not permitted were considered a 

critical factor in the rating of these alternatives due to their function in providing roadless refugia for brown 

bears. Thus, alternative that allocated a greater number of acres to these reserves were rated as having 

a higher likelihood of supporting viable and well-distributed brown bear populations. The spatial 

distribution of these areas was also taken into account, as was the likelihood that they would persist in a 

roadless state over time. 

Two aspects of riparian habitat management were identified as being important to brown bears: the 

maintenance of riparian habitat capable of sustaining salmon habitat and populations over time and 

providing sufficient forest cover to maintain important brown bear feeding and loafing areas. Alternatives 

that provided greater protection to riparian areas were considered more likely to provide adequate travel 

corridors to foraging areas, loafing areas, and vegetative cover capable of reducing adverse encounters 

among brown bears (i.e., sows with cubs) and between bears and humans. 
Appendix D

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Wildlife S&Gs, and Viability

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3.3.4.2. Brown Bear Panel Results 

Average panel ratings are shown in Table D-12. Panelists unanimously agreed that brown bears were 

not likely to be extirpated in 100 years from the Tongass National Forest under any alternative. All 

panelists rated Outcome V as 0 for all alternatives; wilderness and LUD II (legislated) areas essentially 

assured brown bear persistence somewhere in Southeast Alaska in 100 years. Alternative 1 was rated 

highest in total likelihood of maintaining brown bears in their current distribution, with combined scores of 

Outcomes I and II of 93, although certain populations would experience some reduction in overall density 

(a 76 score for Outcome II). The likelihood rating of 6 for Outcome III was due to the extent of past 

roading and an anticipated future growth in human use of existing roads, in spite of little or no additional 

timber harvest. 

Due to the planned extensive timber harvest and associated road construction, Alternatives 7 and 9’ had 

the highest likelihoods of limiting distribution of brown bears such that they might exist only in isolated 

refugia, with Outcome IV scores of 40 and 25-41, respectively. 

Panelists generally agreed that either Outcomes III, IV, or V would not represent well distributed 

populations based upon the assessment criteria they were provided. Alternatives 2, 7, 8, 9, and 9’ all had 

scores over 50 for Outcomes III, IV, and V combined. All of these alternatives had in common relatively 

extensive planned timber harvest and all were managed with a 100-year rotation. The panelists believed 

that these five alternatives presented the greatest relative long-term risk to the maintenance of well 

distributed brown bear populations in 100 years. 

Alternative 3 ratings did not appear to reflect the panelists’ conclusion that riparian habitat protection was 

a significant feature in brown bear management. Alternative 3 hds the widest riparian buffers on most 

channel types, yet was rated similarly to Alternatives 4, 5, 6, 10, and 11 with combined Outcome I and II 

scores of 60, 55, 65-67, 51, 56, and 68, respectively. The extended rotations in Alternatives 4 and 5 

inferred greater dispersion of future timber harvest into roadless watersheds and were rated similar to 

Alternatives 3 and 6 in spite of much less total planned harvest of old growth. Alternative 11 had the 

highest likelihood of maintaining viable long-term brown bear populations due the extensive reserve 

system that should significantly address the road issue that is adverse to bears. It also has strong 

riparian protection. Nonetheless, all these alternatives had a reasonable likelihood of maintaining brown 

bear populations at least in their current distribution in spite of the potential for development of temporary 

gaps in distribution. 

Subpopulations in Southeast Alaska were rated separately. Panelists generally had greater concerns for 

the mainland bear populations than the populations on Chichagof/Baranof and Admiralty Islands. The 

mainland population was rated consistently lower than Chichagof/Baranof for all alternatives in combined 

Outcomes I and II. These ratings supported discussion that focused significant concern on the low 

density population that may already exist in relatively isolated regions. Anticipated future roading and 

human access development would exacerbate this natural situation and place these populations at 

additional risk. 

Overall, the results of the 1995 and 1997 evaluations were consistent. Of those alternatives reviewed in 

both 1995 and 1997, Alternatives 1, 5, 2, and 9 were ranked in order from least to highest risk to brown 

bear habitat in both assessments (Table D-12). However, the panel results suggested that Alternatives 5 

and 11 would produce similar outcomes for brown bears, while analysis based on the components of the 

alternatives (Chapter 3 of the 1997 FEIS) indicated that Alternative 11 was more effective than Alternative 

5 in reducing risk to bears. Alternative 11 has a much greater reserve system than Alternative 5, 

including additional large reserves on Northeast Chichagof Island in a landscape that was identified as 

high risk by the 1995 panels. In addition, Alternative 11 provides more substantial riparian protection than 

Alternative 5, and this feature was identified as important for bears. 
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Table D-12. Brown Bear Panel Results1

1997 Forest Plan Revision FEIS Alternatives 

Outcomes Pre 1954 1 5 11 4 10 3 6 8 2 9 9’ 

1997 Panel 

I 81 16 0 0 0 0 0 0 

II 19 76 65 68 56 49 16 16 

III 0 6 33 25 33 41 63 59 

IV 0 0 3 8 11 10 21 25 

V 0 0 0 0 0 0 0 0 

Potential POG Harvest 

(1,000s of acres) - 414 0 463 475 495 670 571 732 -- 853 1,042 1,403 

1995 Panel 

I 40 8 8 10 6 1 4 0 

II 53 59 47 50 45 28 35 14 

III 8 34 37 36 38 50 38 45 

IV 0 0 8 4 11 21 24 41 

V 0 0 0 0 0 0 0 0 

Potential POG Harvest 

(1,000s of acres) -- 0 572 -- 618 -- 736 954 955 1,107 -- 1,403 

Range Between Outcomes I + II and I + II + III 

1997 Panel 100 93-100 65-98 68-93 -- 56-89 -- -- -- 49-90 16-79 16-75 1995 Panel -- 94-100 67-100 -- 55-92 -- 60-96 51-89 29-79 39-77 -- 14-59 

1 Mean likelihood outcome scores by evaluators in 1997 are shown at the top of the table. Scores from the 1995 panel are shown in the middle of the ta

Scores were assigned by both panels for Alternatives 1, 2, 5, and 9’. Alternatives 1 and 9’ are identical between panels in both features and acres of P

harvested. Alternatives 2 and 5 are identical in features but with fewer acres of POG harvested in 1997 relative to 1995. A range for all alternatives is 

the bottom of the table for the likelihood of maintaining habitat to support viable and well distributed goshawk populations. Only ‘after’ scores are show

414,000 value for POG harvest under Historic represents the acreage harvested since 1954. 
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Wildlife S&Gs, and Viability

D-68

3.3.5. Other Terrestrial Mammals 

3.3.5.1. General Observations on the Other Terrestrial Mammals Panels 

This panel identified two groups of mammals associated with POG for evaluation: widely distributed taxa 

(widely distributed group), and endemic taxa (endemic group). 

Widely distributed group included: 

♦ black bear (Ursus americanus) 

♦ Canada lynx (Lynx canadensis canadensis) 

♦ wolverine (Gulo gulo luscus) 

♦ fisher (Martes pennanti) 

♦ northern flying squirrel (Glaucomys sabrinus zaphaeus) 

♦ river otter (Lutra canadensis mira) 

♦ mountain goat (Oreamnos americanus columbiae) 

♦ silver-haired bat (Lasionycteris noctivagans) 

♦ California Myotis (Myotis caIifornicus caurinus) 

♦ Keen’s Myotis (Myotis keenii keenii) 

♦ little brown Myotis (Myotis lucifugus alascensis) 

♦ long-legged Myotis (Myotis volans longicrus). 

The endemic group included: 

♦ Prince of Wales Island flying squirrel (Glaucomys sabrinus griseifrons) 

♦ beaver (Castor canadensis phaeus) 

♦ Keen’s mouse (Peromyscus keeni sitkensis) 

♦ red-backed vole (Clethrionomys gapperi stikinensis) 

♦ red-backed vole (Clethrionomys gapperi solus) 

♦ red-backed vole (Clethrionomys gapperi wrangeli) 

♦ red-backed vole (Clethrionomys gapperi phaeus) 

♦ Admiralty Island meadow vole (Microtus pennsylvanicus admiraltiae) 

♦ Sitka meadow vole (Microtus oeconomus sitkensis) 

♦ ermine (Mustela erminea aiascensis) 

♦ ermine (Mustela erminea initis) 

♦ ermine (Mustela erminea celenda) 

♦ Admiralty Island ermine (Mustela erminea salva) 

♦ Suemez Island ermine (Mustela erminea seclusa) 

Because multiple species were considered by the panel, likelihood scores given to the most vulnerable or 

sensitive taxon within a group were applied to the entire group in 1995, thus these panel ratings result in 

conservative scores. The 1997 panel assessment rated the species as a group due to the underlying 

uncertainty level for the ratings of the endemic group due to the lack of ecological knowledge for many of 

the species. 
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Final EIS Conservation Strategy, 

Wildlife S&Gs, and Viability

D-69

The panel recognized that certain endemics may yet be discovered while other endemics may be more 

common than originally thought. The panel identified that the greatest concern for endemic species was 

their restricted ranges, which naturally increased their risk of extinction, and that being an endemic 

species equated to increased risk. Thus the panel predicted that all of the proposed alternatives had 

some likelihood of causing extirpation within the endemic group and likelihood increased with higher 

levels of timber harvest proposed. For the endemic group, Alternative 2 was determined to have a low 

likelihood of maintaining viable and well-distributed populations due to the absence of a reserve network 

and the amount of timber harvest proposed. Alternative 6 and 11 were both determined to have a 

moderate likelihood of maintaining viable and well-distributed endemic mammal populations, with 

Alternative 11 being the best, due to proposed harvest levels and rotation length (100 versus 200 years). 

3.3.5.2. Other Terrestrial Mammals Panel Results 

Average panel ratings are shown in Tables D-13 and D-14. Alternative 1 was generally considered by the 

panels as the alternative least likely to negatively impact taxa under consideration. The panels predicted 

a higher likelihood that the widely distributed group would experience ephemeral range distribution gaps 

(Outcome II) in both 1995 and 1997; the endemic group was predicted to occur more frequently in refugia 

(Outcome IV) in 1995, but the 1997 panel predicted a higher likelihood for Outcome II, as for the widely 

distributed group. Panelists assigned these outcomes based upon historical levels of timber-related 

activities. The panels suggested that Alternative 1 could be improved by restoring old growth in 

extensively harvested areas (northern Prince of Wales Island for example). 

Alternatives 5 and 11 were regarded by panelists as the second and third least likely alternatives to 

negatively impact taxa under consideration. The panels offered higher likelihoods that the widely 

distributed group would experience both ephemeral and permanent range distribution gaps (Outcomes II 

and III) that could affect viable populations well-distributed across the planning area. Little brown Myotis 

was cited as one animal whose local populations would be more ephemeral under this alternative; it was 

predicted that fisher could experience significant gaps in its historic range. The endemic group would 

more likely have range distribution gaps or be restricted to refugia under Alternatives 5 and 11 (Outcomes 

III and IV). These circumstances would increase the risk of extirpation as a result of isolation. Prince of 

Wales Island flying squirrel was noted as one animal that would likely only exist in refugia. Panelists 

stressed that reserves should be carefully located within the ranges of vulnerable wildlife and that 

corridors be truly functional. 

Panelists ranked Alternatives 3, 4, 6, and 10 as intermediate among the alternatives in terms of likelihood 

of negatively impacting taxa under consideration. For the widely distributed group, likelihood scores were 

fairly evenly distributed among Outcomes II, III, and IV; scores for outcome extremes (I and V) were 

consistently lower for these alternatives. Likelihood scores were similarly distributed for the endemic 

group, except scores were higher for Outcome V, particularly for Alternatives 3 and 6 in 1995. For most 

of these alternatives, local populations of Sitka mouse could become more ephemeral (Outcome II); 

northern flying squirrel could experience permanent gaps in its historic range or exist only in refugia 

(Outcome III or IV); fisher could exist only in refugia (Outcome IV). 

The panel considered Alternatives 2, 7, 8, 9, and 9’ to be most likely among alternatives to create wildlife 

viability problems. The panel predicted that implementation of these alternatives would result in high 

likelihoods that both the widely distributed and endemic groups would exist only in refugia (northern flying 

squirrel for example) or would become extirpated (Keen’s Myotis for example). It was suggested that 

these alternatives could be improved by incorporating longer rotations, uneven-aged management, and 

higher levels of riparian habitat protection. 

For the widely distributed group, it was determined that Alternative 2 had a very high likelihood of 

resulting in conditions of either refugia or extirpation in 100 years (not viable; combining Outcomes IV and 

V). Conversely Alternative 11 was rated as having a relatively high likelihood of not resulting in conditions 

of refugia or extirpation in 100 years because of its forest-wide reserve system. Alternative 6 was rated 

as being in between Alternatives 2 and 11 (Table D-13). 

There was general consistency in the 1995 and 1997 evaluations of other terrestrial mammals, although 

there was variation in the ratings assigned to alternatives by the two panels. Of those alternatives 
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Table D-13. Widely Distributed Mammals Panel Results1

1997 Forest Plan Revision FEIS Alternatives 

Outcomes 

Pre 

1954 1 5 11 4 10 3 6 8 2 9 9’ 7 

1997 Panel 

I 75 24 3 10 3 0 0 0 

II 17 45 36 28 23 3 0 0 

III 7 28 53 44 53 15 9 4 

IV 1 4 6 16 19 68 68 70 

V 0 0 3 3 4 15 24 26 

Potential 

POG 

Harvest 

(1,000s of 

acres) 

- 414 0 463 475 495 670 571 732 -- 853 1,042 1,403 1,200 

1995 Panel 

I 23 3 1 5 5 5 0 0 0 

II 44 38 34 31 19 10 9 3 3 

III 25 49 41 34 25 20 18 9 8 

IV 9 9 21 19 36 33 29 35 31 

V 0 3 3 11 15 33 45 54 59 

Potential 

POG 

Harvest 

(1,000s of 

acres) 

-- 0 572 -- 618 -- 736 954 955 1,107 -- 1,403 1,557 

Range Between Outcomes I + II and I + II + III 

1997 Panel 92-99 69-97 39-92 38-82 -- 26-79 -- -- -- 3-18 0-9 0-4 -- 1995 Panel -- 67-92 41-90 -- 35-76 -- 36-70 24-49 15-35 9-27 -- 3-12 3-11 

1 Mean likelihood outcome scores by evaluators in 1997 are shown at the top of the table. Scores from the 1995 panel are shown in the middle of 

the table. Scores were assigned by both panels for Alternatives 1, 2, 5, and 9’. Alternatives 1 and 9’ are identical between panels in both 

features and acres of POG harvested. Alternatives 2 and 5 are identical in features but with fewer acres of POG harvested in 1997 relative to 

1995. A range for all alternatives is shown at the bottom of the table for the likelihood of maintaining habitat to support viable and well distributed 

goshawk populations. Only ‘after’ scores are shown. The - 414,000 value for POG harvest under Historic represents the acreage harvested since 1954. 
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Table D-14. Endemic Mammals Panel Results1

1997 Forest Plan Revision FEIS Alternatives 

Outcomes Pre 1954 1 5 11 4 10 3 6 8 2 9 9

1997 Panel 

I 59 6 1 3 1 0 0 0 

II 26 34 9 16 13 0 0 0 

III 13 31 45 36 34 8 8 4 

IV 2 28 41 41 46 70 71 7

V 0 1 4 4 6 23 21 2

Potential POG Harvest 

(1,000s of acres) - 414 0 463 475 495 670 571 732 -- 853 1,042 1,4

1995 Panel 

I 13 5 4 8 8 6 0 0 

II 20 18 14 15 18 11 5 3 

III 18 16 19 21 18 16 11 9 

IV 43 51 50 36 28 28 30 2

V 8 10 14 20 30 39 54 6

Potential POG Harvest 

(1,000s of acres) -- 0 572 -- 618 -- 736 954 955 1,107 -- 1,4

Range Between Outcomes I + II and I + II + III 

1997 Panel 85-98 40-71 10-55 19-55 -- 14-48 -- -- -- 0-8 0-8 0-1995 Panel -- 33-51 23-39 -- 18-37 -- 23-44 26-44 17-33 5-16 -- 3-1

1 Mean likelihood outcome scores by evaluators in 1997 are shown at the top of the table. Scores from the 1995 panel are shown in the middle of the ta

were assigned by both panels for Alternatives 1, 2, 5, and 9’. Alternatives 1 and 9’ are identical between panels in both features and acres of POG harAlternatives 2 and 5 are identical in features but with fewer acres of POG harvested in 1997 relative to 1995. A range for all alternatives is shown at thtable for the likelihood of maintaining habitat to support viable and well distributed goshawk populations. Only ‘after’ scores are shown. The - 414,00POG harvest under Historic represents the acreage harvested since 1954. 
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D-72

reviewed in both 1995 and 1997, Alternatives 1, 5, 2, and 9' were ranked in order from least to highest 

risk to habitat of the widely-distributed group in both assessments (Table D-13). Differences between 

Alternatives 2 and 9' were slight in both assessments. Additionally, ratings of all these alternatives 

improved substantially from the 1995 to the 1997 assessment. The same pattern held true for the 

endemic mammal group (Table D-14). Relative rankings of the four alternatives reviewed by both panels 

remained constant, but the ratings for each of the alternatives improved from the first to the second panel. 

These results also generally support the conclusion drawn in Chapter 3 of the 1997 FEIS that, of the 

alternatives that propose to continue harvesting timber, Alternative 11 poses the least risk to these 

species groups. However, the difference for these species between Alternative 11, as evaluated by the 

panelists, and Alternative 5 is small. Subsequent to the assessment by the panelists, additional 

measures were added to Alternative 11 to benefit these species groups. 

3.3.5.3. Effects of Added Habitat Management Measures 

As noted above, the other terrestrial mammals associated with POG were broadly divided into two 

groups: widely-distributed species and endemic species. A total of 26 taxa within these two groups were 

explicitly considered by the panels asked to provide judgments for the other terrestrial mammals. Two of 

these 26 taxa, northern flying squirrel and river otter, were the focus of specific measures in the original 

VPOP strategy. Small HCAs were adopted by the VPOP committee to provide for distribution of northern 

flying squirrels in every major watershed (i.e., every 10,000 acres). The size of these HCAs was intended 

to allow them to support 20 to 40 squirrels. VPOP also recommended that travel corridors be maintained 

between patches of flying squirrel habitat. They considered beach fringe and riparian zone to be suitable 

corridors, and recommended that additional corridors be designated in areas where these did not provide 

adequate connectivity. 

The Prince of Wales river otter is strongly associated with saltwater beach fringe and freshwater riparian 

habitats (Larsen 1983, Noll 1988, Woolington 1984). VPOP’s conservation recommendation for river 

otter was maintenance of beach fringe, estuary fringe, and riparian habitat associated with streams and 

lakes. 

The review of Kiester and Eckhardt (1994) provided little comment on this aspect of the VPOP strategy. 

However, one of the common themes of many of the reviews was the lack of knowledge of all the taxa 

present on the Tongass and the distribution of species among islands. Kiester and Eckhardt (1994) 

recommended a thorough biological survey of the Tongass, and an evolutionary analysis of small 

mammals. Lidicker (in Kiester and Eckhardt 1994) recommended that no timber harvest take place on 

islands less than 1,000 acres or those that could be considered unique because of their isolation or 

known presence of endemics. 

In the 1995 evaluation, the VPOP strategy, most fully embodied in Alternative 3, was assessed as having 

the third highest likelihood, for those alternatives that propose continuing timber harvest, of maintaining 

both the widely-distributed and the endemic groups of mammals. In this assessment, substantial 

likelihoods of not maintaining species well-distributed were projected for all alternatives, including 

Alternative 1 which called for no further timber harvest. These results were based, at least in part, on 

effects of past harvest, lack of knowledge of many of the mammal species, and risks inherent to endemic 

species. Alternative 11, as evaluated in the 1997 panel assessments, differed in several important ways 

from Alternative 3. It eliminated all islands less than 1,000 acres from the timber base as recommended 

by Lidicker (in Kiester and Eckhardt 1994). It extended the beach fringe to 1,000 feet, but also relied 

more heavily on short-rotation clearcutting than did Alternative 3. Of the alternatives evaluated in 1997 

that propose continued timber harvest, it ranked second highest in likelihood of maintaining viable 

populations of the widely-distributed and endemic mammals. Despite its favorable ranking relative to the 

other alternatives, it still was projected to have substantial likelihood of not maintaining well-distributed 

populations. Alternative components that were viewed favorably by this panel included the presence of a 

reserve system, the amount of old growth that would be retained in the matrix, and a process for sitespecific analysis particularly related to endemic mammals. 

In response to the 1997 panel assessment, additional guidelines were added to Alternative 11 to increase 

the likelihood that viable populations of endemic mammals would be maintained. These guidelines 
Appendix D

Final EIS Conservation Strategy, 

Wildlife S&Gs, and Viability

D-73

require that surveys for endemic mammals be completed prior to projects that would substantially alter 

vegetation on islands of 50,000 acres or less. Surveys were also to be conducted on larger islands if an 

initial assessment indicates high likelihood that endemic mammals are present on the site. Where 

endemic taxa are detected by the surveys, projects were to be designed to provide for continued 

persistence of the taxa. As an additional measure, ongoing research of endemic taxa on the Tongass 

was to be accelerated. 

Other guidelines added to Alternative 11 in response to the panel assessments also benefited both the 

endemic and widely-distributed mammals. The connectivity guideline provided additional measures to 

maintain connectivity of large and small reserves and other non-development LUDs in places where 

beach fringe and riparian habitat management areas do not provide adequate connectivity. Guidelines 

for structural retention for goshawk and marten habitat also benefited other mammal species. 

The Prince of Wales flying squirrel may be considered the greatest viability concern among the endemic 

mammals that were specifically considered by the panels, and the northern flying squirrel may be of 

greatest concern among the widely-distributed mammals. According to Carey (1991), habitat factors 

important to northern flying squirrels include large, live trees; large snags; fallen trees; multilayered 

canopies; and connectedness of habitat either through large contiguous areas of habitat or through 

corridors of suitable habitat. Alternative 11 provided these features through its system of large and 

medium HCAs interconnected with small reserves and matrix habitats. Each large HCA should have the 

capability to support 100 or more northern flying squirrels, medium HCAs to support more than 50 

squirrels, and small HCAs to support 20 to 40 squirrels. These individual populations should have the 

capability to persist over short to intermediate periods of time. Interactions among these populations 

through the matrix would allow them to function as a metapopulation conferring high probability of longterm persistence. Dispersal through the matrix was facilitated by the beach fringe and riparian habitat 

management areas, by the overall amount of old forest remaining in the matrix, and by additional 

measures prescribed under Alternative 11 to provide for connectivity. These additional measures could 

include relocating small reserves to better serve a role as connectors, thus providing for small squirrel 

populations at locations intermediate between the larger populations. 

These same components of Alternative 11 also reduced risks to the endemic species and the Prince of 

Wales flying squirrel. In addition, the 200,000-acre reserve designated on Prince of Wales Island, by 

itself, was expected to support a moderately large population of squirrels. Another feature of Alternative 

11 that was to further reduce risk to Prince of Wales flying squirrels was the requirement to survey for 

endemic mammals on islands of 50,000 acres or less, or in other areas where there is a high likelihood of 

species presence. Application of this measure to Prince of Wales Island was expected to result in 

additional project-specific measures reducing risk to the squirrels. Finally, implementation of mitigation 

measures for goshawk and marten on Prince of Wales Island was expected to result in the retention of 

structural features important to flying squirrels such as snags, logs, and large live trees. 

Implementation of the survey requirement was expected to substantially reduce risks to other endemic 

species. This requirement, in combination with the ongoing research on endemic taxa, is responsive to 

Kiester and Eckhardt's (1994) recommendation to conduct a biological survey on the Tongass. 

3.3.6. Marbled Murrelet 

3.3.6.1. General Observations on the Marbled Murrelet Panel 

Only one panel was conducted for the marbled murrelet (Smith 1996). The panel noted the lack of 

distributional and ecological information about marbled murrelets, especially in Southeast Alaska. They 

appeared to make the following general assumptions about harvest practices and other components of 

the alternatives relative to marbled murrelets and in particular to nesting habitat. 

1. The best or most important habitat is found within large contiguous blocks of high-volume, 

low-elevation old-growth forest. In Yakutat and Glacier Bay this may include stands of large 

mature Sitka spruce. 
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2. The main concern with fragmenting or reducing such habitat is an increase in predation rates 

(more edge and less interior). 

3. Canopy cover above the nest (highest in the high-volume stands) is another critical factor in 

keeping predation rates lower. 

4. The maintenance of old-growth forest reserves, and extended rotations, are both seen as ways to 

retain suitable nesting habitat. Large reserves, and rotations greater than 200 years, are favored; 

an alternative that would provide both Forest-wide would be ideal (assuming timber harvesting is 

to continue). Rotations averaging 100 years are not long enough to provide suitable habitat. 

5. Riparian and beach fringe old growth, due to its linear nature (more edge, less interior), is 

considered less suitable nesting habitat than interior old growth. Alternatives with higher amounts 

of riparian and beach fringe protection may work against murrelets by pushing harvest into critical 

nesting habitat. Conversely, higher riparian protection could lead to improved habitats overall 

through a synergistic effect resulting from more interconnectivity. 

6. The retention of spatially-explicit small OGRs (as in the one/watershed in Alternatives 3) is 

favored over the "33 percent residual" concept of Alternatives 5 and 6. 

3.3.6.2. Marbled Murrelet Panel Results 

Average panel ratings are shown in Table D-15. Based on these ratings, the nine alternatives rated fell 

roughly into four groups. Alternative 1 was by itself with all of its outcome points assigned to Outcomes I 

or II. The very low level of timber harvest, all of it under a 200-year rotation, resulted in a rating 

considerably higher (in terms of ensuring viability) than the other alternatives. The assignment of points 

to Outcome II was primarily a result of the amount of low-elevation, high-volume old growth already 

harvested. 

Alternatives 3, 4 and 5 all rated fairly high, with at least 74 percent of the points in Outcomes I or II. 

Alternative 5, offering extended rotations and reserves in critical areas, had the highest viability scores of 

this group, although the panel would have preferred spatially-identified small reserves rather than the 33 

percent residual old growth concept. The full reserve system and greater riparian protection, combined 

with two-aged management, of Alternative 3 was favored somewhat over the Forest-wide uneven-aged 

management, but no reserves, of Alternative 4. 

Alternatives 2, 6, and 9 each had most of their points (67-74 percent) assigned to Outcomes II or III, and 

except for Alternative 9 have over 90 percent in Outcomes I-III, providing moderate to high viability ratings 

(although not all panelists felt Outcome III would meet viability requirements). The rationale for these 

scores varied by alternative. Alternatives 6 rated highest of this group due largely to their reserve 

systems, two-aged rather than even-aged timber harvesting, and watershed-specific residual old growth 

requirements. The 100-year rotations in each were a drawback. Alternatives 2 and 9 rated somewhat 

lower than Alternatives 6, neither of the former having a reserve system and both using even-aged 

harvest with 100-year rotations. 

Finally, Alternative 7, similar to Alternatives 2 and 9 and with a higher timber harvest level, had the lowest 

viability rating, assigning 2/3 of its points to Outcomes III or IV. 
Final EIS C

Wildl

D-75

Table D-15. Marbled Murrelet Panel Results1

1997 Forest Plan Revision FEIS Alternatives 

Outcomes Pre 1954 1 5 11 4 10 3 6 8 2 9 9’ 

1997 Panel 

I 

II 

III 

IV 

V 

Potential POG Harvest 

(1,000s of acres) - 414 0 463 475 495 670 571 732 -- 853 1,042 1,40

1995 Panel 

I 85 45 36 41 26 25 18 16 

II 15 46 38 40 33 38 34 29 

III 0 6 24 19 36 31 40 38 

IV 0 3 3 0 5 6 9 18 

V 0 0 0 0 0 0 0 0 

Potential POG Harvest 

(1,000s of acres) -- 0 572 -- 618 -- 736 954 955 1,107 -- 1,40

Range Between Outcomes I + II and I + II + III 

1997 Panel -- -- -- -- -- -- -- -- -- -- -- -- 1995 Panel -- 100 91-97 -- 74-97 -- 81-100 59-95 63-94 52-91 -- 45-8

1 Mean likelihood outcome scores by evaluators in 1997 are shown at the top of the table. Scores from the 1995 panel are shown in the middle of the ta

were assigned by both panels for Alternatives 1, 2, 5, and 9’. Alternatives 1 and 9’ are identical between panels in both features and acres of POG harAlternatives 2 and 5 are identical in features but with fewer acres of POG harvested in 1997 relative to 1995. A range for all alternatives is shown at ththe table for the likelihood of maintaining habitat to support viable and well distributed goshawk populations. Only ‘after’ scores are shown. The - 414

for POG harvest under Historic represents the acreage harvested since 1954. 
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Marbled murrelet likelihood outcome ratings were also highly correlated (0.98) with acres of POG planned 

for harvest over a 100 year rotation. Alternative 10 was very similar in design to Alternative 3, but did not 

have the extended beach nor option 1 and 2 riparian buffers, both features considered important by 

panelists, thus presented greater relative risks than Alternative 3. The system of large and medium and 

unmapped small old-growth habitat reserves in Alternative 10 was also an important feature, thus 

superior in design with lower relative risk that Alternative 2. 

Alternative 11 harvested almost the lowest amount of old growth (Table D-15), had the most extensive 

forest-wide reserve system with very large reserves in heavily harvested provinces, and had an extended 

beach and significant riparian protection. The only possible drawback of Alternative 11 was the 100-year 

timber harvest rotation in the matrix, viewed as unfavorable by panelists. However, an average of nearly 

57 percent of the original 1954 POG would remain in all watersheds under timber management 

contributing to a diversity of stands and habitat mosaics, clearly superior to extensive even-aged stands. 

Thus, Alternatives 1 and 11 were believed likely offer the highest likelihood of maintaining well distributed 

viable murrelet populations. 

Commentary on the Panel Ratings. The marbled murrelet is second only to the Other Terrestrial 

Mammals panel with respect to the lack of local information available to assess long-term viability. 

Viability concerns for the marbled murrelet in southeast Alaska intensified due to listing of this species as 

threatened under ESA in California, Oregon, and Washington and the very close habitat affinity with 

coastal old growth forests (Ralph et al. 1995). Information to substantiate this concern in southeast 

Alaska is only indirect relative to the loss of nearly one million acres of POG coastal temperate rainforests 

throughout southeast Alaska (including all ownerships). These are generally the more productive sites at 

low elevation, presumably some of the best murrelet nesting habitat (DeGange 1996). However the 

strength of the association between murrelet nesting habitat and highly POG forest has not been 

established; indeed two of the six nests located in Southeast Alaska to date have been on the ground. 

Short term (10-15 years) risks to murrelet viability are difficult to assess but are likely minor especially 

given the magnitude of recent conservative population estimates of over 365,000 marbled murrelets in 

southeast Alaska (DeGange 1996). Further, murrelets appear to be highly mobile traveling up to 50-60 

miles per day on foraging flights (DeGange 1996) suggesting at least the possibility of relatively high 

population interaction throughout southeast Alaska. Short term risks are likely proportional to the amount 

of additional old growth planned for harvest among alternatives (1, 11, 5, 4, 3, 10, 6, 2, 9 and 7 in order of 

increasing risk) within the planning period covered by the Forest Plan Revision. While large block 

reserves in general may be a preferable conservation strategy, the small (1,600 acre) block reserves 

(Alternatives 3, 10, 11 and parts of 5 and 6) in each watershed may significantly contribute to 

maintenance of nesting habitat and well distributed populations in the absence of additional information 

on nesting habitat relationships. Forest-wide Standards and Guidelines protect nesting habitat around 

any identified murrelet nests. However, only six murrelet nests have been found so this standard is not 

considered as a viable conservation strategy in itself. Rather it serves to protect habitat surrounding the 

few nests that may be located for long term monitoring and studies to understand murrelet habitat 

relationships. 

Under the assumption that POG habitat is the preferred murrelet nesting habitat, then the loss of an 

additional 1.5 million acres in some alternatives, in addition to the million acres already lost, could 

contribute to a long-term viability concern. This concern may become greater if future research reveals a 

significant murrelet selection for high volume low elevation forests that are sought for timber production, 

similar to the situation documented in the Pacific Northwest (Ralph et al. 1995). DeGange (1996) 

suggested that long rotations may be beneficial components to a murrelet conservation strategy, he 

concluded that a reserve system was more likely to present a viable conservation strategy for murrelets 

given significant unknowns about this elusive specie; protecting intact landscapes/ecosystems is a better 

hedge against uncertainty. 

The significant reserve system in Alternative 11, especially in at-risk landscapes with significant past 

timber harvest (reserves partially discussed under Wolf) may make this alternative superior to all others 

(except Alternative 1). The reserve system in additional to significant matrix protection should provide a 
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reasonably high likelihood of sustaining well-distributed viable murrelet populations throughout southeast 

Alaska. 

Even over long time periods, there is less relative concern for the marbled murrelet compared to other old 

growth associated vertebrates assessed by panels. Average murrelet scores for Outcome I and II rated 

higher than all other species in all alternatives except for the wolf in Alternatives 2 and 3. 

3.4. New Science Relevant to Wildlife Viability Assessment 

 Since 1997 

The process of assessing wildlife risk through a structured panel assessment process is one of a variety 

of methods for conducting a viability assessment. Beissinger and McCullough (2002) compiled a 

reference which consists of a set of review papers on population viability analysis. This section presents 

a summary of the science that is relevant to wildlife viability assessment since 1997. It is largely based 

on a review of recent science relative to population and species viability assessment conducted by 

Haufler (2006). 

Numerous factors influence the viability of any species. However, habitat is the greatest overall factor 

affecting viability of a species (Wilcove et al. 1998). Reed et al. (2006) identified four broad classes of 

factors influencing viability of a species; population size and structure, habitat, demography, and 

relationships between demographic rates and habitat and between demographic rates and population 

size. In addition, many other minor factors can play a role. Given this myriad of potential influences on 

the viability of a species, it is not surprising that quantification of species viability has been a difficult task. 

Consequently, most assessments of species viability in a planning or impact assessment context have 

been conducted qualitatively, usually with the use of expert opinion in relation to projected future 

conditions. 

Species viability assessment based on habitat has ranged from expert assessments of future population 

status based on projected habitat conditions to more complex analyses of individual home ranges and 

their contributions to species persistence in spatially-explicit individually-based population viability models 

(Noon et al. 1999). Individually-based spatially explicit models may be the most realistic (Breininger et al. 

2002), but these approaches also require many model parameters that may not be known with any 

accuracy, and include various assumptions that may be difficult to test. The spatial description of habitat 

quality produced from this approach can be used for a variety of habitat-based population viability 

assessments (Akcakaya and Atwood 1997, Akcakaya 2000). Lawler and Schumaker (2004) evaluated 

habitat surrogates for population parameters of red-shouldered hawks and goshawks, and found poor 

relationships between predicted habitat quality and observed habitat quality. 

Various models for population viability assessment (PVA) have been proposed and developed (see 

review by Akcakaya and Sjogren-Gulve 2000), most involving theoretical relationships of demographic 

data. The idea behind PVA has been to determine an estimate of the extinction risk to a species based 

on current demographic conditions and alternative future conditions. Given the complexities of species 

viability described above, it is not surprising that sufficient data generally do not exist to conduct a 

thorough population viability analysis. For example, Green and Hirons (1991) reported that data suitable 

for population modeling were available for only 2 percent of threatened bird species, taxa about which we 

know the greatest amount, while Samson (2002) reported that suitable data existed to conduct a PVA for 

only 3 of 119 species at risk in the Northern Great Plains. Beissinger and Westphall (1998) discussed 

use of PVAs in endangered species management. They suggested caution in use of predictions 

produced from such analyses because of the unreliability of data available for such models as well as the 

lack of understanding of both periodic fluctuations and density dependent factors, and varying model 

assumptions that can cause changes in results. They suggested that PVAs consider relative rather than 

absolute rates of extinction, be limited to short projections, and use models compatible with the available 

data. 

A number of different demographic-based approaches have been proposed for assessing species 

viability. As with habitat-based approaches, these range from relatively simple approaches to much more 

complex approaches (Haufler 2006). Incidence function models are relatively simple models designed to 
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provide an estimate of the risk of extinction (Hanski 1999). This approach requires the presence or 

absence of species of interest to be determined for various habitat patches in a landscape over a time. 

Appropriate time frames are difficult to estimate, as different populations have different generation times 

and vulnerability to extinction events. This approach assumes relatively static habitat conditions (Ralls et 

al. 2002), an unlikely condition for management planning or impact assessments. 

A second demographic-based approach is the use of population trend information (Morris et al. 1999). 

This approach requires the population of a species to be consistently monitored over time to determine 

any changes in the population size. Morris et al. (1999) recommended a minimum of 7 years of trend 

data for accurate analysis. Even with this information, the population trend applies only to that time 

interval and landscape studied. 

A number of population simulation models have been developed that address questions of productivity 

and survival rates of a population (Haufler 2006). These models require detailed information on the 

demographics of the population under evaluation, data that are seldom available (Bessinger and 

Westphal 1998). 

Certain populations may be limited by the spatial distribution of their habitat, where dispersal among 

patches is a relatively rare event, so that population demographics within a patch are largely independent 

of other habitat patches within the landscape. When this arrangement occurs, it is known as a 

metapopulation (McCullough 1996, Hanski and Gilpin 1997). A number of metapopulation models have 

been developed that attempt to address population persistence in patches as balanced by dispersal rates 

among patches. Such models, to be accurate, require information on the status of a population within a 

habitat patch, including the habitat quality, population size, and internal-patch demographic parameters. 

In addition, the distribution, and size of other patches in the landscape and rates of successful dispersal 

among the patches must be known. Dispersal data are one of the least known and most difficult 

parameters to assess for a population, and small errors in assessment of dispersal can cause large errors 

in projections of metapopulation models (Reed et al. 2002). In addition, even if these population 

parameters are collected, as with other demographic parameters, they are usually not transferable to 

other conditions than those in which they were collected. 

Concerns over habitat fragmentation have led many to assume that populations are regularly being 

converted to metapopulations, and to view any system with a patchy distribution as a metapopulation 

(Hanski and Simberloff 1997, Harrison and Taylor 1997). However, this is generally not correct, as actual 

metapopulations are rare (Harrison and Taylor 1997). Hanski (1999) discussed the basic parameters that 

need to be considered to conduct a metapopulation analysis. 

Smith and Zollner (2005) argue that using the most vulnerable species, or evaluating single species 

without reference to others, to assess impacts of land management likely underestimates the probability 

of extinction of wildlife species across the planning area because the risk of local extirpation increases 

with the number of extinction prone species considered. Additionally, the management alternative that 

poses the greatest risk to the most vulnerable wildlife species may not pose the greatest risk to the 

wildlife community as a whole (Smith and Zollner 2005). The authors present an alternative method for 

assessing risk to wildlife viability that considers the risk of “any” extinction among species at risk in the 

planning area. To accomplish this, an equation is used which calculates the joint probability of at least 

one extinction among the set of selected species (derived from panel assessment ratings or population 

viability analysis), which can then be used to conduct a relative comparison of alternatives. That is, it 

takes into account the marginal, or individual, extinction probability of each species. This approach is 

used here as an alternate method for comparing the effects of the alternatives on wildlife viability (see 

Section 3.6 and the Wildlife section of Chapter 3 for further discussion). 

Global climate change has been a subject of increasing interest and focus in the past 10 years. A 

number of publications have discussed biodiversity conservation in the face of global warming. Saxon 

(2003) presented a good discussion of this topic. He recommended that conservation planning occur 

across ecoregions, and that these ecoregions be identified based on abiotic factors including climate, but 

also based on other abiotic factors than climate as this factor is likely to change. With climate change 

expected to have a greater effect on more polar regions, incorporating the potential consequences of 

global warming relative to conservation planning in Alaska is warranted. 
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3.5. Application of Panel Assessments to the 2008 FEIS Alternatives 

The 1997 Forest Plan Revision Final EIS wildlife analysis relied in part on the expert panel evaluations of 

alternatives in terms of the estimated relative risks to a species or habitat of concern, as described in 

Sections 3.2 and 3.3. The 2008 Forest Plan Amendment FEIS also relies in part on these panel 

evaluations. Of the seven alternatives analyzed in the 2008 FEIS, four of them are very similar to or 

based on alternatives analyzed during the panel assessments. In addition, the harvest levels of all 2008 

alternatives are within the range of the 1997 alternative harvest levels, given that a no-harvest alternative 

was analyzed in 1997. As described in Section 3.1, there was a strong correlation between the acres of 

POG scheduled for harvest in an alternative and the mean outcome scores for that alternative resulting 

from the panel assessments (Section 3.3). As the number of acres harvested increased among 

alternatives, the mean outcome scores also increased, resulting in greater risk that habitat may not be 

sufficient to maintain viable and well distributed populations. Therefore, the panel evaluations can be 

used to make inferences about the 2008 alternatives. 

The accuracy of this approach was tested in 1997 (Section 3.1). The 1997 FEIS, which was developed 

prior to the 1997 panel assessments, evaluated two alternatives, which had not been assessed by the 

panels, by making inferences based on harvest acres; these inferences and the resulting alternative 

evaluations were generally confirmed based on the 1997 panel assessments (see Appendix N to the 

1997 FEIS). 

The relationship between the 2008 alternatives and the 1997 alternatives in terms of equivalency of 

features, land base, and acreage of POG potentially harvested is summarized in Table D-16, for use in 

rating the 2008 alternatives in terms of the panel assessments. 

Based on the equivalencies given in Table D-16 and supplemental information, viability ratings for the 

2008 alternatives were developed and are summarized in Table D-17. The ratings were based on the 

midpoint of the range between the sum of Outcomes I+II and the sum of Outcomes I+II+III for each 

alternative. The midpoint of the range between these sums was used as the index of viability because 

viability was generally assumed by panelists to lie between the sum of Outcomes I+II and the sum of 

Outcomes I+II+III (USDA Forest Service 1997(Appendix N, p.N-3). The 2008 alternatives were evaluated 

by applying the equivalencies or rankings in Table D-17 to the panel assessment midpoint values as 

shown in the tables in Section 3.3. The midpoint values were then transferred to ratings using the key 

provided in the footnote to Table D-17. Further explanation for these ratings is provided in the following 

subsections. 

3.5.1. Northern Goshawk 

Alternatives 1, 2, and 3 in 2008 would both have midpoint values above 91, based on applying Table 

D-16 equivalencies and rankings to Table D-9. Therefore, they are expected to have very high viability 

ratings for goshawks. Alternatives 5 and 6 in 2008 are both similar to 1997 Alternative 11, which had a 

midpoint value of 84. In addition, 2008 Alternatives 5 and 6 both include supplemental measures, which 

may have a positive effect on viability; 2008 Alternative 5 includes the goshawk and marten standards 

and guidelines and 2008 Alternative 6 includes the legacy forest structure standards and guidelines. 

Neither of these measures were evaluated by either of the panels, so their value for goshawks was not 

considered. As a result of this and the 84 midpoint value for 1997 Alternative 11, 2008 Alternatives 5 and 

6 are rated in the high category for goshawks. Alternative 4 in 2008 is rated as moderately high, because 

the midpoint value for 1997 Alternatives 10, 3, and 6, ranges from 66.5 to 74. Alternative 7 in 2008 is 

equivalent to 1997 Alternative 2, which had a midpoint value of 40.5. This value falls within the moderate 

range. 
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Table D-16. 

Relationship of 2008 Alternatives to 1997 Alternatives for Use in Rating 2008 

Alternatives in Terms of Panel Assessments 

2008 Alternatives Equivalency or Ranking in terms of 1997 Alternatives* 

Alternative 1 

84,000 acres of potential 

POG harvest 

2008 Alternative 1 has a lower POG harvest than any of the 1997 

alternatives with POG harvest. Ratings for this alternative should be 

between 1997 Alternative 1 with 0 harvest and 1997 Alternative 5 (with 

463,000 acres of harvest) or 1997 Alternative 11 (with 475,000 acres of 

harvest). Based on the low POG harvest levels, ratings would be closest to 

(but greater than) Alternative 1. 

Alternative 2 

223,000 acres of potential 

POG harvest 

2008 Alternative 2 has a lower POG harvest than any of the 1997 

alternatives with POG harvest. Ratings for this alternative should be 

between 1997 Alternative 1 with 0 harvest and 1997 Alternative 5 (with 

463,000 acres of harvest) or 1997 Alternative 11 (with 475,000 acres of 

harvest). Based on harvest levels, ratings would be in the middle of the 

range between Alternative 1 and Alternatives 5 or 11. 

Alternative 3 

325,000 acres of potential 

POG harvest 

2008 Alternative 3 has a lower POG harvest than any of the 1997 

alternatives with POG harvest. Ratings for this alternative should be 

between 1997 Alternative 1 with 0 harvest and 1997 Alternative 5 (with 

463,000 acres of harvest) or 1997 Alternative 11 (with 475,000 acres of 

harvest). Based on harvest levels, ratings would be closer to (but less than) 

Alternatives 5 or 11. 

Alternative 4 

644,000 acres of potential 

POG harvest 

2008 Alternative 4 is similar to 1997 Alternative 6 in terms of features and 

land base. The acres of POG harvest are lower for the 2008 Alternative 4 at 

644,000 compared with the 1997 Alternative 6 at 732,000. However, only 

the 1995 version of Alternative 6 was evaluated by the viability panels, and 

the acres of POG harvest are considerably lower in 2008 vs. 1995 (644,000 

vs. 954,000, respectively). The alternative that was reviewed by the viability 

panels and is the closest to the 2008 Alternative 4 is the 1997 Alternative 10 

(670,000 acres of harvest). So ratings for 2008 Alternative 4 are expected 

to be between 1995 Alternative 6 and 1997 Alternative 10; being closer to 

the latter alternative. 

Alternative 5 

479,000 acres of potential 

POG harvest 

2008 Alternative 5 is similar to 1997 Alternative 11 in terms of features, land 

base, and POG harvest (481,000 vs. 463,000 acres of harvest, 

respectively). Therefore, the ratings for this alternative would be similar to 

the ratings for 1997 Alternative 11. 

Alternative 6 

472,000 acres of potential 

POG harvest 

2008 Alternative 6 is similar to 1997 Alternative 11 in terms of features, land 

base, and POG harvest (472,000 vs. 463,000 acres of harvest, 

respectively). Therefore, the ratings for this alternative would be similar to 

the ratings for 1997 Alternative 11. 

Alternative 7 

826,000 acres of potential 

POG harvest 

2008 Alternative 7 is similar to 1997 Alternative 2 in terms of features, land 

base, and POG harvest (826,000 vs. 853,000 acres of harvest, 

respectively). Therefore, the ratings for this alternative would be similar to 

the ratings for 1997 Alternative 2. 

* POG harvest levels in 1997 are based on values given to the panels, which were different, in some cases from the final 

scheduled acres given in the 1997 FEIS. 
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Table D-17. 

Viability Ratings (likelihood of maintaining habitat to support viable and well distributed 

populations) assigned to the 2008 Alternatives based on the Equivalent Panel 

Assessment Ratings from the 1995/1997 Panel Assessments 

Alternatives 

Species 1 2 3 4 5 6 7 

Goshawk Very High Very High Very High Moderately 

High 

High High Moderate 

Marten Very High High High Moderate Moderate Moderate Moderate 

Wolf Very High Very High High High High High Moderately 

High 

Brown 

Bear 

Very High High High Moderately 

High 

High High Moderately 

High 

Widely 

Distributed 

Mammals 

High Moderately 

High 

Moderately 

High 

Moderate Moderate Moderate Moderately 

Low 

Endemic 

Mammals 

Moderate Moderate Moderate Moderately 

Low 

Moderate Moderate Very Low 

Marbled 

Murrelet 

Very High Very High Very High High Very 

High 

Very 

High 

Moderately 

High 1

 Ratings were based on the midpoint of the range between Outcomes I+II and Outcomes I+II+III for each 

alternative, as determined by applying the equivalencies or rankings in Table D-17 to the panel assessment results 

tables in Section 3.3. The midpoint values were then transferred to ratings using the following key: 

Very High: 91-100, High: 81-90, Moderately High: 66-80, Moderate: 35-65, Moderately Low: 20-34, 

Low: 10-19, Very Low: 0-9. 

In addition, these ratings may be conservatively low. Information from recent studies indicates that 

goshawks may make more use of second growth and other forest types than was assumed during the 

panel assessments (Bosakowski et al. 1999; McClaren 2003, 2004; Boyce et al. 2006, Reynolds et al. 

2006). As noted in Section 3.3.1.1, the primary factor used by panelists in their ratings was the proportion 

of POG that would be harvested in 100 years. The panels assumed a strong selection by goshawks for 

POG and the avoidance of all other habitat types. In addition, the level of old-growth harvest that was 

envisioned by the panels over the past 10 years has not materialized. As a result, nearly the same 

amount of old growth still exists on the Tongass and the large quantities of older second growth are now 

10 years closer to becoming useful goshawk habitat. Therefore, if the panels were repeated today, the 

ratings could be slightly higher. 

Given these factors, the rankings of the 2008 alternatives relative to the 1997 selected alternative 

(Alternative 11) would be as follows: Alternatives 4 and 7 in 2008 would have lower viability ratings than 

1997 Alternative 11, and 2008 Alternatives 1, 2, 3, 5, and 6 would have higher ratings. These higher 

ratings are because of a smaller managed land base, the addition of goshawk/marten (in the case of 

2008 Alternative 5) or legacy (in the case of 2008 Alternatives 1, 2, 3, and 6) standards and guidelines, 

and new science about goshawk habitat use in Southeast Alaska. The slight change in the goshawk nest 

standard and guideline (see Section XX), is not expected to affect viability. 

The same relative ratings are also expected to hold for the 1997 Forest Plan versus the 2008 alternatives 

(i.e., 2008 Alternatives 4 and 7 would have lower viability ratings and 2008 Alternatives 1, 2, 3, 5, and 6 

would have higher viability ratings than the 1997 Forest Plan). These conclusions follow the same 

reasoning as given in the above paragraph for most of the alternatives. Table D-18 summarizes this 

reasoning. 
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Table D-18. 

Goshawk Viability Ratings for the 2008 Alternatives Relative to the 2007 Forest Plan1/

Alternatives Comparison with 2007 Forest Plan1/ 

Viability for 

Alternative 

relative to 2007 

Forest Plan1/ 

Alternative 1 

Acreage in protected POG is considerably higher in Alt 1 due to 

expanded OGRs (i.e., more acreage in Old Growth Habitat, Special 

Interest Areas, Semi-Remote Recreation, and other nondevelopment LUDs). 2007 Forest Plan has goshawk S&G, marten 

S&G, and unmodified goshawk nest S&G, while Alt 1 has legacy 

S&G. 

Alt. 1 has higher 

viability rating 

Alternative 2 

Acreage in protected POG is considerably higher in Alt 2 due to 

expanded OGRs (i.e., more acreage in Old Growth Habitat, Special 

Interest Areas, Semi-Remote Recreation, and other nondevelopment LUDs). 2007 Forest Plan has goshawk S&G, marten 

S&G, and unmodified goshawk nest S&G, while Alt 2 has legacy 

S&G. 

Alt. 2 has higher 

viability rating 

Alternative 3 

Acreage in protected POG is considerably higher in Alt 3 due to 

expanded OGRs (i.e., more acreage in Old Growth Habitat, Special 

Interest Areas, Semi-Remote Recreation, and other nondevelopment LUDs). 2007 Forest Plan has goshawk S&G, marten 

S&G, and unmodified goshawk nest S&G, while Alt 3 has legacy 

S&G. 

Alt. 3 has higher 

viability rating 

Alternative 4 

Acreage in protected POG is considerably lower in Alt 4 due to 

OGRs in only four provinces and less acreage in non-development 

LUDs in general. 2007 Forest Plan has goshawk S&G, marten 

S&G, and unmodified goshawk nest S&G, while Alt 4 does not have 

goshawk/marten S&Gs or legacy S&Gs. 

Alt 4 has lower 

viability rating 

Alternative 5 Same as the 2007 Forest Plan Alt 5 has the same 

viability rating 

Alternative 6 

Acreage in protected POG is higher in Alt 6 due to expanded OGRs 

(i.e., more acreage in Old Growth Habitat, Special Interest Areas, 

and Semi-Remote Recreation). 2007 Forest Plan has goshawk 

S&G, marten S&G, and unmodified goshawk nest S&G, while Alt 6 

has legacy S&G. 

Alt. 6 has a similar 

viability rating 

Alternative 7 

Acreage in protected POG is considerably lower in Alt 7 due to 

OGRs in only four provinces and less acreage in non-development 

LUDs in general. 2007 Forest Plan has goshawk S&G, marten 

S&G, and unmodified goshawk nest S&G, while Alt 7 does not have 

goshawk/marten S&Gs or legacy S&Gs. 

Alt 7 has 

substantially lower 

viability rating 

1/ The 2007 Forest Plan is defined as the 1997 Forest Plan, as amended through 2007. It is represented by 

Alternative 5. 

3.5.2. American Marten 

Alternative 1 in 2008 would have a midpoint value suggesting a very high viability rating for marten, based 

on applying Table D-16 equivalencies and rankings to Table D-10. Based on the level of POG harvest, 

2008 Alternatives 2 and 3 are expected to have a high rating. Alternatives 5 and 6 in 2008 are both 

similar to 1997 Alternative 11, which had a midpoint value of 64. In addition, 2008 Alternatives 5 and 6 

both include supplemental measures, which were not considered in the panel assessments and these 

measures may have a positive effect on viability; 2008 Alternative 5 includes the goshawk and marten 

standards and guidelines and 2008 Alternative 6 includes the legacy forest structure standards and 

guidelines. As a result of this and the 64 midpoint value for 1997 Alternative 11, 2008 Alternatives 5 and 

6 are rated at the upper end of the moderate category for marten. Alternative 4 in 2008 is also rated as 
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moderate, because the midpoint value for 1997 Alternatives 10, 3, and 6, ranges from 49 to 64.5. 

Alternative 7 in 2008 is equivalent to 1997 Alternative 2 with a midpoint value of 51, which is also in the 

moderate range. 

Information from recent studies indicates that the marten in Southeast Alaska may represent two species, 

or at least, two different genetic lineages of one species. If there are actually two species, it could 

indicate a greater viability concern for some islands on the Tongass (e.g., Kuiu - the endemic lineage of 

marten is currently only documented on Kuiu and Admiralty Islands). However, there is no information 

indicating that there are ecologically meaningful differences (e.g., differences in habitat use) between the 

two lineages. 

Given these factors, the rankings of the 2008 alternatives relative to the 1997 selected alternative 

(Alternative 11) would be as follows: Alternatives 4 and 7 in 2008 would have lower viability ratings than 

1997 Alternative 11, and 2008 Alternatives 1, 2, 3, 5, and 6 would have higher ratings. These higher 

ratings are because of a smaller managed land base, the addition of goshawk/marten (in the case of 

2008 Alternative 5) or legacy (in the case of 2008 Alternatives 1, 2, 3, and 6) standards and guidelines. 

The same relative ratings are also expected to hold for the 2007 Forest Plan versus the 2008 alternatives 

(i.e., 2008 Alternatives 4 and 7 would have lower viability ratings and 2008 Alternatives 1, 2, 3, 5, and 6 

would have higher viability ratings than the 2007 Forest Plan). The moderate viability rating for marten in 

the 2007 Forest Plan was based on the 1997 plan without the additional conservation measures for 

marten added in the Decision. With those additional measures, the likelihood of maintaining habitat for 

viable populations of marten was strengthened. Similarly, Alternative 6 strengthens this likelihood by 

retaining the additional measures that were added for the 1997 Decision except for the replacement of 

the Legacy standard for one of the marten measures. This, plus the other additions described in Chapter 

2, is why both Alternatives 5 and 6 would have higher viability ratings than the 1997 Forest Plan These 

conclusions follow the same reasoning as given in the above paragraph for most of the alternatives and 

are similar to those given in Table D-18 for goshawks. 

3.5.3. Alexander Archipelago Wolf 

Alternatives 1 and 2 in 2008 would have midpoint values suggesting a very high viability rating for the wolf 

and Alternative 3 would have a high rating, based on applying Table D-16 equivalencies and rankings to 

Table D-11. Alternatives 5 and 6 in 2008 are both similar to 1997 Alternative 11, which had a midpoint 

value of 90. As a result, 2008 Alternatives 5 and 6 are rated at the high end of the high category. 

Alternative 4 in 2008 is also rated as high, because the midpoint value for 1997 Alternatives 10, 3, and 6, 

ranges from 79.5 to 91. Alternative 7 in 2008 is equivalent to 1997 Alternative 2 with a midpoint value of 

80, which is in the moderately high range. 

Given these factors, the rankings of the 2008 alternatives relative to the 1997 selected alternative 

(Alternative 11) would be as follows: Alternatives 4 and 7 in 2008 would have lower viability ratings than 

1997 Alternative 11, and 2008 Alternatives 1, 2, and 3 would have higher ratings. Alternatives 5 and 6 in 

2008 would have similar ratings, albeit slightly higher. The same relative ratings are also expected to 

hold for the 2007 Forest Plan versus the 2008 alternatives (i.e., 2008 Alternatives 4 and 7 would have 

lower viability ratings and 2008 Alternatives 1, 2, 3, 5, and 6 would have higher viability ratings than the 

2007 Forest Plan). 

3.5.4. Brown Bear 

Alternative 1 in 2008 would have a midpoint value suggesting a very high viability rating for the brown 

bear, based on applying Table D-16 equivalencies and rankings to Table D-12. Based on the level of 

POG harvest, 2008 Alternatives 2, 3, 5, and 6 are expected to have high ratings. Alternative 4 in 2008 

would be rated as moderately high, because the midpoint value for 1997 Alternatives 10, 3, and 6, ranges 

from 70 to 78 and averages below 76. Alternative 7 in 2008 is equivalent to 1997 Alternative 2 with a 

midpoint value of 69.5, which is also in the moderately high range. 

Given these factors, the rankings of the 2008 alternatives relative to the 1997 selected alternative 

(Alternative 11) would be as follows: Alternatives 4 and 7 in 2008 would have lower viability ratings than 
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1997 Alternative 11, and 2008 Alternatives 1, 2, and 3 would have higher ratings. Alternatives 5 and 6 in 

2008 would have similar ratings, albeit slightly higher. The same relative ratings are also expected to 

hold for the 2007 Forest Plan versus the 2008 alternatives (i.e., 2008 Alternatives 4 and 7 would have 

lower viability ratings and 2008 Alternatives 1, 2, 3, 5, and 6 would have higher viability ratings than the 

2007 Forest Plan). 

3.5.5. Other Terrestrial Mammals 

Alternative 1 in 2008 would have a midpoint value suggesting a high viability rating for widely distributed 

mammals and a moderate rating for endemic mammals, based on applying Table D-16 equivalencies and 

rankings to Tables D-13 and D-14. Based on the level of POG harvest, 2008 Alternatives 2 and 3 are 

expected to have moderately high ratings for widely distributed mammals and moderate ratings for 

endemic mammals, respectively. Alternatives 5 and 6 in 2008 are both similar to 1997 Alternative 11, 

which had a midpoint value of 60 for the widely distributed group and 37 for the endemic group. In 

addition, 2008 Alternatives 5 and 6 both include supplemental measures (see Section 3.3.2.3), which 

were not considered in the panel assessments and these measures may have a positive effect on 

viability; these measures include the survey requirement, connectivity guideline, and goshawk and marten 

standards and guidelines for 2008 Alternative 5 and the survey requirement, connectivity guideline, and 

legacy standards and guidelines for 2008 Alternative 6. As a result of this and the midpoint values for 

1997 Alternative 11, 2008 Alternatives 5 and 6 are rated at the high end of the moderate category for the 

widely distributed group and at the low end of the moderate category for endemics. Alternative 4 in 2008 

is also rated as moderate for the widely distributed group because the midpoint value for 1997 

Alternatives 10, 3, and 6, ranges from 36.5 to 54. This alternative is rated as moderately low for 

endemics (midpoint ranges from 31 to 35). Alternative 7 in 2008 is equivalent to 1997 Alternative 2 with 

midpoint values of 10.5 and 4 for the widely distributed and endemic groups, respectively. This places it 

in the moderately low and very low categories for the widely distributed and the endemic groups, 

respectively. 

Given these factors, the rankings of the 2008 alternatives relative to the 1997 selected alternative 

(Alternative 11) would be as follows: Alternatives 4 and 7 in 2008 would have lower viability ratings than 

1997 Alternative 11, and 2008 Alternatives 1, 2, 3, 5, and 6 would have higher ratings. The same relative 

ratings are also expected to hold for the 2007 Forest Plan versus the 2008 alternatives (i.e., 2008 

Alternatives 4 and 7 would have lower viability ratings and 2008 Alternatives 1, 2, 3, 5, and 6 would have 

higher viability ratings than the 1997 Forest Plan). 

3.5.6. Marbled Murrelet 

Alternatives 1, 2, and 3 in 2008 would have midpoint values suggesting a very high viability rating for the 

marbled murrelet, based on applying Table D-16 equivalencies and rankings to Table D-15. Alternatives 

5 and 6 in 2008 are both similar to 1997 Alternative 11, which was not rated by the panel; however, based 

on the values assigned to the 1995 versions of Alternatives 3, 4, and 5, the 2008 Alternatives 5 and 6 

would also fall into the very high viability category. Alternative 4 in 2008 is rated as high, because the 

midpoint value for the 1995 versions of Alternatives 3 and 6 range from 77 to 90.5. Alternative 7 in 2008 

is equivalent to the 1995 version of Alternative 2, but with less harvest. It is given a moderately high 

viability rating for the marbled murrelet because the midpoint value for the 1995 version of Alternative 2 

was 71.5. 

Given these factors, the rankings of the 2008 alternatives relative to the 1997 selected alternative 

(Alternative 11) would be as follows: Alternatives 4 and 7 in 2008 would have lower viability ratings than 

1997 Alternative 11, and 2008 Alternatives 1, 2, and 3 would have higher ratings. Alternatives 5 and 6 in 

2008 would have similar ratings, albeit slightly higher. The same relative ratings are also expected to 

hold for the 2007 Forest Plan versus the 2008 alternatives (i.e., 2008 Alternatives 4 and 7 would have 

lower viability ratings and 2008 Alternatives 1, 2, 3, 5, and 6 would have higher viability ratings than the 

2007 Forest Plan). 
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3.6. Alternative Approach to Viability Evaluation for Alternative 

Comparison 

To determine whether the alternatives provided sufficient habitat to sustain all indigenous wildlife across 

the planning area, and as a means to compare the alternatives, the 1997 Forest Plan FEIS relied, in part, 

on the findings of structured panel assessments. As described above, these panel assessments provided 

estimates of the relative risk, in the form likelihood points or scores for a certain outcome. Results from 

this assignment of likelihood points do not represent probabilities in the classic sense of frequencies; 

rather, they represent degrees of belief in future outcomes that are based on reasoned professional 

judgment and expressed in a probability-like scale (Shaw 1999). Scores from individual panel members 

were averaged to produce a likelihood score for five possible outcomes related to population distribution 

for each species: occupancy of historic range (Outcome I), temporary gaps in distribution (Outcome II), 

permanent gaps in distribution (Outcome III), existence in refugia (Outcome IV), and extirpation from 

Federal lands (Outcome V). 

Other considerations to assess viability were presented in Section 3.4. In order to increase the 

confidence in our viability assessment, an alternate method for alternative comparisons to address 

viability was used, The tool with the most applicability to the Tongass, given the lack of level of 

information required for most other tools, is the analysis presented by Smith and Zollner (2005). They 

argued that using the most vulnerable species to assess impacts of land management likely 

underestimates the probability of extinction of wildlife species across the planning area because the risk 

of local extirpation increases with the number of extinction prone species considered. Since the Tongass 

is an island archipelago with natural inherent risks of species extripation, this method presents a 

conservative method to further assess viability risks. The authors present an alternative method for 

assessing risk to wildlife viability that considers the risk of “any” extinction among species at risk in the 

planning area. To accomplish this, an equation is used which calculates the joint probability of at least 

one extinction among the set of selected species. That is, it takes into account the marginal, or individual, 

extinction probability of each species, as determined by population viability analysis or panel assessment, 

to compare the relative, rather than absolute, risk of extinction among land management alternatives (see 

Smith and Zollner (2005) for the equation and for statistical details). 

This method was used to rank the 2008 FEIS alternatives in terms of relative level of risk of any of the 

evaluated species existing in refugia or being extirpated using the 1997 FEIS panel assessment ratings. 

It is important to note that, since the panel scores for outcomes do not represent probabilities, this 

approach simply produces risk indices. Two risk indices were calculated: one is based on the likelihood 

that any species will exist in refugia or be extirpated after 100 years of Forest Plan implementation and 

the other is based on the likelihood that any species will be extirpated. 

This method (which applies the binomial theorem) requires that responses of species at risk to 

management alternatives be independent (i.e., they cannot respond identically to the management 

scenario or be ecologically dependent on each other as in predator/prey interactions; Smith and Zollner 

2005). The individual species and groups selected for risk assessment panel evaluation were chosen 

because their ecologies likely incorporate the breadth of forest habitat features and other attributes of 

environmental variation represented across the Forest (Shaw 1999) and are, therefore, assumed to be 

independent for this analysis; however, it is recognized that some degree of correlation between 

components is inherent in all ecological communities. 

Table D-19 presents the risk indices for 2008 Alternatives 4, 5/6, and 7, which are equivalent or similar to 

1997 Forest Plan FEIS Alternatives 6, 11, and 2 (which were evaluated by the panels), respectively. 

Applying this risk assessment method indicates that, when all evaluated species are considered jointly, 

Alternatives 4 and 7 would have the greatest risks. This difference is driven primarily by potential risks to 

the endemic and widely distributed mammals groups, which have the highest risks of any species or 

group evaluated (Table D-19). The risk index for extirpation was near 40 percent for both Alternatives 4 

and 7, but only 8 percent for Alternatives 5 and 6. The risk index for any species existing in refugia or 
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Table D-19. 

Risk Indices associated with the joint probability that any (i.e., at least one) wildlife 

species among those evaluated would become restricted to refugia or be extirpated

Outcome Scores and 

Risk Index1/

Species Risk Index for Alt 4* Alt 5 or 6 Alt 7 

Goshawk Species existence in refugia or extirpation 17 3 21 

Species extirpation from NFS lands 0 0 5 

Marten Species existence in refugia or extirpation 30 9 18 

Species extirpation from NFS lands 0 0 0 

Wolf Species existence in refugia or extirpation 5 4 4 

Species extirpation from NFS lands 1 1 1 

Brown bear Species existence in refugia or extirpation 11 8 10 

Species extirpation from NFS lands 0 0 0 

 Murrelet*** Species existence in refugia or extirpation 5 1 9 

Species extirpation from NFS lands 0 0 0 

Endemics Species existence in refugia or extirpation 58 45 93 2/, 3/ 

Species extirpation from NFS lands 30 4 23 

Widely Species existence in refugia or extirpation 51 19 83 

distributed2/, 3/. Species extirpation from NFS lands 15 3 15 

Combined Risk Index for a Species Being Restricted to Refugia 

or Being Extirpated 2/ 90 66 >99 

Combined Risk Index for a Species Being Extirpated2/ 41 8 38 

1/ Derived from the 1995 (Alternative 4) and 1997 (Alternatives 7 and 11) panel assessment ratings for Outcomes IV and V; 

Alternatives 4, 5, and 7 are equivalent to the 1997 Forest Plan FEIS Alternatives 6, 11, and 2, respectively. See Smith and Zollner 

(2005) for equation and further statistical discussion. Values are relative. 2. Endemic group includes small mammals whose known distribution in southeast Alaska (beaver, ermine, voles, etc); wide ranging 

group includes 3/ Within each guild, evaluators selected what they considered to be the most sensitive species or group of species to evaluate the 

effect of each alternative on the guild, sometimes consisting of a few or even one species, depending on geographic distribution of 

species or management actions (Shaw 1999). For the risk assessment these groups were treated similarly to the single species 

panels. 

being extirpated was greater than 99 percent for Alternative 7, 90 percent for Alternative 4, and 66 

percent for Alternatives 5 or 6. Again, it is important to understand that these numbers represent an 

index of relative risk that any species may exist in refugia or be extripated after 100 years of maximum 

levels of timber harvest allowed in each Alternative. This relative risk is used to compare alternatives and 

therefore, it is not accurate to consider these as absolute indicators of a degree of risk. 

Because 2008 Alternatives 1, 2, and 3 would harvest less timber than Alternative 5 or 6, but maintain 

equivalent or more protective conservation measures, it can be assumed that their risk indices would be 

lower than the corresponding indices for Alternatives 5 and 6. The lowest risk indices would be 

associated with Alternative 1. 

The fact that Alternative 4 had an overall probability of extirpation that was slightly higher than Alternative 

7, despite proposing less harvest, is likely due to the fact that risk assessment panels convened twice, 

once in 1995 and once in 1997, evaluating different alternatives each time. The 1997 FEIS Alternative 2 

(equivalent to the 2008 Alternative 7) was assessed both times, whereas 1997 FEIS Alternative 6 

(equivalent to the 2008 Alternative 4) was only assessed in 1995. In 1997, there was a consistent shift in 

outcome ratings for Outcome V, or local extirpation (points shifted to higher outcomes, generally IV), 

across all alternatives due to a clarification of the interpretation of extirpation within the 100-year 

evaluation period (Iverson 1997). Also, the acreage potentially harvested under the version of Alternative 

6 reviewed by the 1995 panel was higher than the level of harvest for the 1997 Alternative 6 and for the 

2008 Alternative 4. Thus, it is likely that if the 1995 version of Alternative 6 had been reevaluated in 

1997, its score for Outcome V would also have shifted down, lower than the 1997 version of Alternative 2 

(re-ordering the results to show that Alternative 7 considered here would in fact pose the greatest risk to 

the ecological community). Taking this factor into account, the overall outcomes confirm the relative 

rankings of the alternatives based on other comparisons. 
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4. CONCLUSIONS REGARDING THE 

2008 FOREST PLAN AMENDMENT 

4.1. Introduction 

The conservation strategy provides the scientific basis for an ecological approach to the Tongass Forest 

Plan. The strategy consists of a system of OGRs and matrix lands that are a mix of retention and active 

forest management. The Forest-wide reserve network provided by the non-development LUDs provides 

the backbone framework to ensure maintenance of habitat for species viability while the matrix provides a 

variety of functions and activities. Both are critical for the conservation strategy and to ensure species 

viability; however, they have different functions. 

The reserve network protects the integrity of the old-growth forest ecosystem by protecting the largest 

blocks of contiguous old growth, as well medium and smaller-sized blocks. These reserves are 

distributed across the Forest and serve as core areas for functioning old-growth ecological communities. 

The forests in the matrix provide a variety of functions, including connectivity between old growth in 

reserve areas and providing habitat for a variety of organisms associated with forests of a variety of 

successional stages, including old growth. Standards and guidelines within the matrix are designed to 

provide for important ecological functions such as dispersal of organisms, carryover of some species from 

one stand to the next and maintenance of ecologically valuable structural components such as down logs, 

snags and large trees. The expected condition for the matrix over time, given all Forest Plan 

expectations, is a mosaic of successional stages – from early seral to second growth forests to old-growth 

forests. The suite of ecological functions provided by the matrix, including connectivity and old-growth 

representation, is achieved through the combination of old growth retention in beach fringe, riparian and 

floodplain buffers, karst, soil, other no-harvest areas; aging young-growth stands; uneven-aged managed 

stands; and patches of forest left in managed stands. Matrix functions are enhanced, both in the short 

term and as the stand ages, by leaving individual reserve trees, snags and clumps of reserve trees within 

harvested units. 

4.2. Forest-wide Reserve Changes 

Changes to the conservation strategy under the alternatives fall into two broad categories (as described 

in Sections 2.5.1 and 2.5.2): changes to the Forest-wide reserve network and changes to standards and 

guidelines that affect management of the matrix. The overall effects of these changes need to be 

examined in combination to determine the net effects of the changes relative to the 2007 Forest Plan 

(modeled by Alternative 5). This section summarizes these overall effects. 

As noted in Section 2.5.1, the Forest-wide reserve network was modified in two ways: changes were 

made to the areas identified as Old-Growth Habitat LUDs and changes were made to other nondevelopment LUDs. Under Alternatives 1, 2, 3, and 6, the boundaries of a large portion of the OldGrowth Habitat LUDs that represent the small OGRs were modified using a process that started with an 

interagency biological proposal and ended with a refinement of that proposal in consideration of multipleuse objectives. The net result of these modifications was an increase in OGR acres by 39,000 relative to 

Alternative 5 (the 2007 Forest Plan). In contrast, Alternative 4 reduces the acreage in Old-Growth Habitat 

LUDs by 789,000 or 67 percent and Alterative 7 totally eliminates the Old-Growth Habitat LUD. 

The second way that the Forest-wide reserve network was modified was through the modification of other 

non-development LUDs, which also represent an important part of the network. Overall, the acreage in 

these other non-development LUDs was also enlarged under Alternatives 1, 2, 3, and 6 relative to 

Alternative 5, and reduced under Alternatives 4 and 7. 

Table D-5 provides a summary of these changes in reserve area relative to Alternative 5. This table 

demonstrates that the land area in reserves under Alternative 6 (proposed action) has increased by 

149,000 acres relative to Alternative 5. This represents an increase of approximately 1 percent of the 

Forest land area (i.e., reserve acreage represents 79.4 percent of the Forest under Alternative 6 and 78.5 
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percent under Alternative 5). An increasingly greater percentage of the Forest would be in reserves 

under Alternatives 3, 2, and 1 (83.3, 88.5, 95.0 percent, respectively). Under Alternatives 4 and 7, the 

acreage in reserves would be reduced to 71.8 and 69.9 percent of the Forest, respectively. 

Table D-6 summarizes these changes relative to POG. Under Alternative 6, the acreage of POG in 

reserves would be 45,000 acres greater than under Alternative 5, while the acreage of POG that is 

protected in the matrix would be 28,000 acres less than under Alternative 5, resulting in a net increase of 

17,000 acres. In addition, the percentage of high-volume and large-tree POG that is protected in 

reserves would increase under Alternative 6, relative to Alternative 5, primarily because of the changes 

made to OGRs and other LUDs; these changes resulted in a greater portion of the forest types consisting 

of larger trees being included within reserves. Under Alternative 6, for example, 72.6 percent of the highvolume POG and 69.9 percent of the large-tree POG would be included within reserves compared with 

71.3 and 67.8 percent under Alternative 5, respectively. Overall, 90.1 percent of the existing high-volume 

POG and 89.0 percent of the large-tree POG would not be harvested under Alternative 6, compared with 

88.9 and 88.6 percent under Alternative 5. Again, an increasingly greater percentage of total POG and 

the larger tree POG types would be protected in reserves and in overall under Alternatives 3, 2, and 1, in 

that order. In contrast, a significantly smaller percentage of total POG and the larger tree POG types 

would be protected in reserves and overall in Alternatives 4 and 7, in decreasing order. 

4.3. Standards and Guidelines Changes 

The other major factors to be considered in comparing the overall effects of changes to the conservation 

strategy are the changes to standards and guidelines. Most changes to the standards and guidelines 

under Alternatives 1, 2, 3, and 6 are minor and it was concluded in the previous subsections that they 

would not affect the strategy. The one change to the standards and guidelines that is more far-reaching 

and needs to be considered in combination with the LUD changes is the replacement of the goshawk and 

marten standards and guidelines with the legacy standard and guideline. The legacy standard provides 

an alternative, more ecological approach to conserving wildlife habitat at the project scale as compared to 

the more species-specific marten and goshawk standards. This approach simplifies the standard, allows 

equal to greater flexibility, and leaves representative components of old growth in high risk VCUs outside 

of the biogeographic provinces covered by the marten and goshawk standards. 

For marten, ADF&G harvest reports continue to indicate stable or increasing marten populations across 

the Tongass and trapping continues to occur across the entire Tongass under both State regulations and 

federal subsistence regulations. While there is increased knowledge regarding the distribution of two 

marten lineages (caurina and americana), there is no indication of differential life history requirements or 

habitat use between lineages. Therefore, maintaining one set of marten standards is still appropriate. 

The legacy standard would continue to retain additional forest structure in VCUs with the highest level of 

harvest in high risk marten provinces and this is still valid, based on concerns about the ability of marten 

to travel through landscapes that have large openings due to past timber harvest. 

No barriers to movement other than open salt water have been identified and marten travel through a 

variety of habitats including clearcuts, muskeg openings and roads. Marten will continue to move through 

the matrix using riparian and beach buffer routes, as well as crossing the mix of natural and humancaused openings. Since trapping access and trapping success can increase where there are roads, the 

standard requiring road management considerations is maintained, where marten mortality is directly 

attributed to road access. 

Considering the combination of the OGR network, non-development LUDs and retention of old growth via 

various standards and guidelines, there is significantly more high value marten habitat retained than just 

in OGRs. Recent studies indicating that OGRs may not be of sufficient sizes to maintain marten do not 

adequately take into account the amount of other old growth retained in the Forest Plan and, thus, do not 

reflect how much actual marten habitat would remain. Slightly more than two-thirds (68 percent) of all 

existing old growth within the matrix would remain unharvested after 100 years of Forest Plan 

implementation (at the maximum allowable harvest rate) under either Alternative 5 or Alternative 6. Thus, 

lands outside of the reserves will provide more than just connectivity for marten. Given timber harvest 

trends (smaller-sized openings coupled with decreased harvest levels), the continued succession of 
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young growth to mature forest, and the value and amount of old growth retained outside of OGRs, it 

appears that the assumptions of these studies were very conservative and do not reflect available marten 

habitat under actual Forest Plan implementation. Based upon this analysis, implementation of 

Alternatives 1, 2, 3, or 6 with the legacy standard would not reduce the likelihood of maintaining habitat 

that supports well-distributed marten populations, relative to Alternative 5. Based on the viability panel 

analysis (Section 3), there is at least a moderate likelihood that sufficient habitat would be maintained to 

support a viable and well distributed marten populations across the Tongass under these alternatives. 

While it is anticipated that there could be gaps in this distribution, there is a low likelihood that there would 

be significant isolation among marten populations resulting from implementation of the amended Forest 

Plan. 

For goshawks, based upon these analyses, Alternatives 1, 2, 3, and 6 would provide a sufficient amount 

and distribution of habitat to maintain viable and well distributed populations across the Tongass after 100 

years of Forest Plan implementation. The legacy standard and guideline would continue to retain 

additional forest structure in harvest units greater than 20 acres in all VCUs on Prince of Wales Island 

that were identified as concerns for goshawk, and this is still valid, based on concerns about goshawks 

specific to this island. In addition, the legacy standard would also retain forest structure in other VCUs 

forest-wide, which provides an additional measure of protection for goshawk habitat outside of Prince of 

Wales Island. 

These analyses assumed maximum allowable timber harvest every decade for 100 years of 

implementation of the Forest Plan. The interagency assessment called The Conservation Assessment 

for the Northern Goshawk in Southeast Alaska (Iverson et al. 1996) defined three categories of VCU 

harvest and related those categories to the likelihood of the VCU continuing to support goshawks. These 

categories were based on the concept of a 300-year ecological rotation. The three categories were: 1) 

<33 percent POG harvest = high likelihood that VCU supports goshawks; 2) 33-47 percent POG harvest 

= slightly increased risk that VCU will not support goshawks; and 3) >47 percent = increased risk that 

VCU will not support goshawks. 

The proportion of the Tongass acreage that falls into these categories was estimated for those VCUs that 

originally contained a significant amount of goshawk habitat (defined as a minimum of 2,300 acres of 

POG). For this appendix, the three categories were applied to Alternative 6 and the results are 

summarized below: 

♦ An estimated 95 percent of the goshawk range on the Tongass currently has a high likelihood of 

sustaining goshawk habitat (< 33 percent of old-growth harvested). 

♦ An estimated 95 percent of the goshawk range on the Tongass would have 47 percent or less of the 

POG harvested after 100 years of Forest Plan implementation, and would maintain a relatively high 

likelihood of sustaining goshawks. 

♦ An estimated 12 percent of the goshawk range on the Tongass would have a slightly elevated risk of 

not sustaining goshawks, with between 33 and 47 percent of the old growth harvested after 100 

years. 

♦ Most elevated risk landscapes (> 47 percent harvested) would be aggregated on North and Central 

Prince of Wales Island. This province only represents 9 percent of the acreage comprising goshawk 

range on the Tongass. 

♦ Where risks would be elevated by matrix management intensity, remaining very high quality goshawk 

habitats would be protected by forest-wide standards and guidelines 

These results, together with the viability panel analysis described in Section 3 and the other related 

analyses presented in Section 2.5, lead to the conclusion that implementation of Alternatives 1, 2, 3, or 6 

with the legacy standard would not reduce the likelihood of maintaining habitat that supports viable and 

well-distributed goshawk populations relative to Alternative 5. Based on the viability panel analysis 

(Section 3) there is at least a high likelihood that sufficient habitat would be maintained to support viable 

and well distributed goshawk populations across the Tongass under these alternatives. 
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D-90 

In contrast, the modifications to the standards and guidelines under Alternatives 4 and 7 (e.g., no legacy 

or goshawk/marten standards and guidelines under either alternative and reduced beach fringe and 

elimination of Class III stream buffers under Alternative 7), coupled with their significantly lower acreages 

of protected POG, particularly in reserves, leads to the conclusion that the likelihood of maintaining 

habitat that supports well-distributed marten and goshawk populations could be compromised. The 

potential effect would be substantially greater under Alternative 7. However, based on the viability panel 

analysis (Section 3) there is a moderate likelihood for marten and a moderate to moderately high 

likelihood for goshawks, that sufficient habitat would be maintained to support viable and well distributed 

populations across the Tongass under these alternatives. In addition, even under Alternative 4 or 7, the 

potential effect would not be realized unless harvest levels occurred and were maintained at a much 

higher rate than has occurred in the past 10 years. Given this, and given the 10 to 15-year timeframe 

until the Forest Plan is revised again, it is highly unlikely that these levels of harvest would occur before 

the next Forest Plan revision. 

4.4. Summary and Conclusions 

In summary, the numbers reviewed in Section 2.5 reflect the changes in reserves as well as the changes 

in standards and guidelines (including the replacement of the goshawk and marten standards and 

guidelines with the legacy standard and guideline). Although there is some shift of POG from the matrix 

to POG in reserves, the net effect of all LUD and standard and guideline changes is an increase in 

protected POG (including the larger tree POG types) under Alternatives 1, 2, 3, and 6, relative to 

Alternative 5. The 1997 Forest Plan FEIS analysis of Alternative 11 (without consideration of specific 

additional goshawk and marten standards and guidelines) stated that the 1997 Alternative 11 was 

explicitly designed to address issues related to wildlife viability conservation planning. It was projected to 

have a moderately high likelihood of maintaining viable, well distributed populations of old-growth 

associated species across the Tongass National Forest (USDA Forest Service 1997c). Alternatives 1, 2, 

3, and 6 of the 2008 Forest Plan Amendment FEIS do not negatively affect the conservation strategy that 

this conclusion was based on; in fact, the acreage in reserves and the acreage of old growth in reserves 

would be higher and the total protected POG would be slightly higher. These positive effects would occur 

under Alternatives 6, 3, 2, and 1, in increasing order. Alternatives 4 and 7, on the other hand, would 

negatively affect the conservation strategy and would reduce the likelihood of maintaining viable, welldistributed populations. Alternative 7 would have the greatest potential to negatively affect the strategy. 

Under any alternative, however, the maximum effects that these conclusions are based on depend on 

actual harvest levels occurring at a rate significantly higher than under the recent past. 
Appendix D

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Wildlife S&Gs, and Viability

D-91 

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APPENDIX E 

CATALOGUE OF PAST HARVEST 
Appendix E 

Final EIS E-i Catalogue of Past Harvest

Appendix E 

Catalogue of Past Harvest 

CONTENTS 

Introduction ................................................................................................................................................E-1

Part I – Acreage of Past Harvest by Ownership Category, by Landowner, by Biogeographic Province, 

by Approximate Decade.............................................................................................................................E-1

Part II – Statistics on the Alaska Forest Resources and Practices Act Implementation and State Timber 

Sales in Southeast Alaska ...................................................................................................................... E-12
Appendix E

Final EIS E-1 Catalogue of Past Harvest

Appendix E 

Catalogue of Past Harvest 

Introduction 

This appendix presents a catalogue of past harvest for Southeast Alaska. It is based on updated and 

extensive mapping of past harvest based on the Tongass GIS library, GIS data layers provided by 

Sealaska Regional Native Corporation, the State of Alaska, and Audubon Alaska/The Nature 

Conservancy, as well as supplemental interpretation of orthophotography and other aerial photography. 

It is also based on tabular information collected from the State of Alaska, Department of Natural 

Resources regarding state harvests and harvests under the Alaska Forest Resources and Practices Act. 

Appendix B provides more detailed information on the inventory methodology. 

Part I of this appendix provides a tabular catalogue of harvest acreage by ownership category, 

landowner, and biogeographic province. An approximate harvest period is listed by decade as well. Part 

II presents a tabular summary of information provided by the State of Alaska Department of Natural 

Resources, Division of Forestry. 

Part I – Acreage of Past Harvest by Ownership Category, by 

Landowner, by Biogeographic Province, by Approximate Decade 

Ownership Category Landowner 

Est. Approx. 

Harvest 

Decade 

Acres 

Harvested

Yakutat Forelands Biogeographic Province

Tongass National Forest Tongass National Forest 1950s 28

Tongass National Forest 1970s 553

Tongass National Forest 1980s 1,812

Tongass National Forest 1990s 229

Tongass National Forest 2000s 987

Tongass National Forest -- 18

Total NFS Lands 3,627

 

State of Alaska State of Alaska 1970s–1990s 1,315

Total State Lands 1,315

 

Yak-tat Kwaan Village Corporation 1980s 12,541

Other -- 134

Private & Other Lands Total Private/Other Lands 12,675

 

 

TOTAL PROVINCE HARVEST 17,618

 
Appendix E

Catalogue of Past Harvest E-2 Final EIS

Ownership Category Landowner 

Est. Approx. 

Harvest 

Decade 

Acres 

Harvested

Yakutat Uplands Biogeographic Province

Tongass National Forest Tongass National Forest 1980s 665

Tongass National Forest 1990s 173

Tongass National Forest 2000s 552

Tongass National Forest -- 21

Total NFS Lands 1,411

 

State of Alaska Total State Lands 0

Private & Other Lands Total Private/Other Lands 0

 

 

TOTAL PROVINCE HARVEST 1,411

 

East Chichagof Island Biogeographic Province

Tongass National Forest Tongass National Forest <1950 1,016

Tongass National Forest 1950s 1,527

Tongass National Forest 1960s 6,053

Tongass National Forest 1970s 13,232

Tongass National Forest 1980s 10,501

Tongass National Forest 1990s 11,713

Tongass National Forest 2000s 60

Tongass National Forest -- 105

Total NFS Lands 44,207

 

State of Alaska State of Alaska 1980s 200

State of Alaska 1990s 227

State of Alaska 2000s 70

Total State Lands 497

 

Private & Other Lands Hoonah -- 252

Huna Totem Village Corporation -- 11,449

Sealaska Regional Corporation 1970s 1,352

Sealaska Regional Corporation 1980s 7,670

Sealaska Regional Corporation 1990s 6,400

Sealaska Regional Corporation 2000s 6,825

Other Private Owners -- 81

Total Private/Other Lands 37,007

 

TOTAL PROVINCE HARVEST 81,711

 
Appendix E

Final EIS E-3 Catalogue of Past Harvest

Ownership Category Landowner 

Est. Approx. 

Harvest 

Decade 

Acres 

Harvested

West Chichagof Island Biogeographic Province

Tongass National Forest Total NFS Lands 0

 

State of Alaska Total State Lands 0

 

Private & Other Lands Total Private/Other Lands 0

 

 

TOTAL PROVINCE HARVEST 0

 

East Baranof Island Biogeographic Province

Tongass National Forest Tongass National Forest <1950 197

Tongass National Forest 1950s 223

Tongass National Forest 1960s 8,158

Tongass National Forest 1970s 2,725

Tongass National Forest 1990s 2,227

Total NFS Lands 13,530

 

State of Alaska Total State Lands 0

 

Private & Other Lands Other Private Land Owners -- 2

Total Private/Other Lands 2

 

TOTAL PROVINCE HARVEST 13,532

 

West Baranof Island Biogeographic Province

Tongass National Forest Tongass National Forest <1950 516

Tongass National Forest 1950s 1,085

Tongass National Forest 1960s 9,812

Tongass National Forest 1970s 5,556

Tongass National Forest 1980s 10

Total NFS Lands 16,978

 

State of Alaska State of Alaska 1980s 696

State of Alaska 1990s 204

Total State Lands 900

 
Appendix E

Catalogue of Past Harvest E-4 Final EIS

Ownership Category Landowner 

Est. Approx. 

Harvest 

Decade 

Acres 

Harvested

 

Private & Other Lands Shee Atika Village Corporation 1980s 1,184

Other Private Owners -- 271

Total Private/Other Lands 1,455

 

 

TOTAL PROVINCE HARVEST 19,332

Admiralty Island Biogeographic Province

Tongass National Forest Tongass National Forest Prior to 1950 3,202

Tongass National Forest 1950s 771

Tongass National Forest 1960s 3,305

Tongass National Forest 1970s 1,108

Tongass National Forest 1990s 17

Tongass National Forest 2000s 105

Tongass National Forest -- 88

Total NFS Lands 8,595

 

State of Alaska Total State Lands 0

 

Private & Other Lands Shee Atika Village Corporation 1980s–1990s 20,080

Other Private Owners -- 110

Total Private/Other Lands 20,190

 

 

TOTAL PROVINCE HARVEST 28,785

 

Lynn Canal Biogeographic Province

Tongass National Forest Tongass National Forest 1960s 2,129

Tongass National Forest 1970s 1,177

Tongass National Forest 1980s 545

Tongass National Forest 1990s 1,527

Total NFS Lands 5,377

 

State of Alaska State of Alaska 1980s 214

Total State Lands 214

 

Private & Other Lands Other Private Owners 1990s 335

Total Private/Other Lands 335

 

 

TOTAL PROVINCE HARVEST 5,926

 
Appendix E

Final EIS E-5 Catalogue of Past Harvest

Ownership Category Landowner 

Est. Approx. 

Harvest 

Decade 

Acres 

Harvested

North Coast Range Biogeographic Province

Tongass National Forest Tongass National Forest 1950s 221

Total NFS Lands 221

 

State of Alaska State of Alaska -- 24

Total State Lands 24

 

Private & Other Lands Goldbelt Village Corporation 1980s 20,389

City and Borough of Juneau -- 1

Other Land Owners -- 147

Total Private/Other Lands 20,537

 

 

TOTAL PROVINCE HARVEST 20,782

 

Kupreanof/Mitkof Biogeographic Province

Tongass National Forest Tongass National Forest <1950 1,573

Tongass National Forest 1950s 1,096

Tongass National Forest 1960s 6,781

Tongass National Forest 1970s 10,183

Tongass National Forest 1980s 8,335

Tongass National Forest 1990s 5,539

Tongass National Forest 2000s 2,234

Total NFS Lands 35,742

 

State of Alaska State of Alaska 1980s 3,648

State of Alaska 1990s 884

State of Alaska 2000s 54

Total State Lands 4,587

 

Private & Other Lands Kake -- 126

Petersburg -- 484

Kake Village Corporation 1970s–1990s 17,471

Sealaska Regional Corporation <1980 3,755

Sealaska Regional Corporation 1980s 1,831

Sealaska Regional Corporation 1990s 551

Sealaska Regional Corporation 2000s 6,009

Other Private Owners -- 823

Total Private/Other Lands 31,050

 

 

TOTAL PROVINCE HARVEST 71,379

 
Appendix E

Catalogue of Past Harvest E-6 Final EIS

Ownership Category Landowner 

Est. Approx. 

Harvest 

Decade 

Acres 

Harvested

Kuiu Island Biogeographic Province

Tongass National Forest Tongass National Forest <1950 2,570

Tongass National Forest 1950s 344

Tongass National Forest 1960s 3,428

Tongass National Forest 1970s 8,989

Tongass National Forest 1980s 7,852

Tongass National Forest 1990s 4,644

Tongass National Forest 2000s 667

Total NFS Lands 28,494

 

State of Alaska State of Alaska -- 9

Total State Lands 9

 

Private & Other Lands Sealaska Regional Corporation <1980 22

Other Private Owners -- 113

Total Private/Other Lands 135

 

 

TOTAL PROVINCE HARVEST 28,638

 

Central Coast Range Biogeographic Province

Tongass National Forest Tongass National Forest <1950 159

Tongass National Forest 1950s 910

Tongass National Forest 1960s 3,574

Tongass National Forest 1970s 1,087

Tongass National Forest 1980s 164

Tongass National Forest 1990s 586

Total NFS Lands 6,479

 

State of Alaska State of Alaska 1970s–1980s 1,421

Total State Lands 1,421

 

Private & Other Lands Other Land Owners -- 13

Total Private/Other Lands 13

 

 

TOTAL PROVINCE HARVEST 7,913

 
Appendix E

Final EIS E-7 Catalogue of Past Harvest

Ownership Category Landowner 

Est. Approx. 

Harvest 

Decade 

Acres 

Harvested

Etolin Island and Vicinity Biogeographic Province

Tongass National Forest Tongass National Forest <1950 2,565

Tongass National Forest 1950s 1,728

Tongass National Forest 1960s 2,593

Tongass National Forest 1970s 12,666

Tongass National Forest 1980s 8,964

Tongass National Forest 1990s 6,532

Tongass National Forest 2000s 1,016

Tongass National Forest -- 4

Total NFS Lands 36,066

 

State of Alaska State of Alaska 3,764

Total State Lands 3,764

 

Private & Other Lands Wrangell 643

Other Land Owners 68

Total Private/Other Lands 712

 

 

TOTAL PROVINCE HARVEST 40,542

 

North Central Prince of Wales Island Biogeographic Province

Tongass National Forest Tongass National Forest <1950 1,772

Tongass National Forest 1950s 11,460

Tongass National Forest 1960s 50,216

Tongass National Forest 1970s 47,190

Tongass National Forest 1980s 35,623

Tongass National Forest 1990s 33,507

Tongass National Forest 2000s 4,343

Tongass National Forest -- 15

Total NFS Lands 184,125

 

State of Alaska State of Alaska -- 15,384

Total State Lands 15,384

 

Private & Other Lands Hydaburg -- 48

Kasaan -- 16

Thorne Bay -- 180

Haida Village Corporation 1980s–1990s 2,465

Kavilco Village Corporation 1990s 11,811

Klawock-Heenya Village Corporation 1980s–1990s 12,073

Sealaska Regional Corporation <1980 3,240 

Sealaska Regional Corporation 1980s 32,741 

Sealaska Regional Corporation 1990s 24,452 

Sealaska Regional Corporation 2000s 22,835 

Shaan Seet Village Corporation 1980s–1990s 6,858
Appendix E

Catalogue of Past Harvest E-8 Final EIS

Ownership Category Landowner 

Est. Approx. 

Harvest 

Decade 

Acres 

Harvested

Other Private Land Owners -- 3,304

Total Private/Other Lands 120,022

 

 

TOTAL PROVINCE HARVEST 319,531

 

Revilla Island/Cleveland Peninsula Biogeographic Province

Tongass National Forest Tongass National Forest <1950 2,181

Tongass National Forest 1950s 6,812

Tongass National Forest 1960s 6,389

Tongass National Forest 1970s 8,443

Tongass National Forest 1980s 5,827

Tongass National Forest 1990s 11,477

Tongass National Forest 2000s 4,470

Tongass National Forest -- 60

Total NFS Lands 45,658

 

State of Alaska State of Alaska 4,043

Total State Lands 4,043

 

Private & Other Lands Ketchikan -- 39

Sealaska Regional Corporation <1980 151

Cape Fox Village Corporation 1980s–1990s 13,266

Other Land Owners 1980s–1990s 7,406

Total Private/Other Lands 20,862

 

 

TOTAL PROVINCE HARVEST 70,563

 

Southern Outer Islands Biogeographic Province

Tongass National Forest Tongass National Forest 1950s 569

Tongass National Forest 1960s 3,737

Tongass National Forest 1970s 3,058

Tongass National Forest 1980s 5,737

Tongass National Forest 1990s 1,683

Tongass National Forest 2000s 354

Total NFS Lands 15,138

 

State of Alaska State of Alaska 1990s 2,102

Total State Lands 2,102

 

Private & Other Lands Haida Village Corporation -- 4

Klawock-Heenga Village Corporation -- 366

Sealaska Regional Corporation 2000s 31

Shaan Seat Village Corporation 1980s–1990s 3,324

Total Private/Other Lands 3,725

 
Appendix E

Final EIS E-9 Catalogue of Past Harvest

Ownership Category Landowner 

Est. Approx. 

Harvest 

Decade 

Acres 

Harvested

 

TOTAL PROVINCE HARVEST 20,965

 

Dall Island and Vicinity Biogeographic Province

Tongass National Forest Tongass National Forest <1950 77

Tongass National Forest 1950s 79

Tongass National Forest 1960s 213

Total NFS Lands 369

 

State of Alaska Total State Lands 0

 

Private & Other Lands Haida Village Corporation 1980s–1990s 365

Klukwan Villa Village Corporation 1980s–1990s 17,265

Sealaska Regional Corporation <1980 630

Sealaska Regional Corporation 1980s 4,549

Sealaska Regional Corporation 1990s 1,831

Sealaska Regional Corporation 2000s 8,011

Other Land Owners -- 265

Total Private/Other Lands 32,916

 

 

TOTAL PROVINCE HARVEST 33,285

 

South Prince of Wales Island Biogeographic Province

Tongass National Forest Tongass National Forest <1950 410

Tongass National Forest 1950s 60

Tongass National Forest 1960s 467

Tongass National Forest 1970s 368

Tongass National Forest 1980s 276

Tongass National Forest 1990s 994

Tongass National Forest 2000s 716

Tongass National Forest -- 1

Total NFS Lands 3,292

 

State of Alaska State of Alaska -- 351

Total State Lands 351

 

Private & Other Lands Sealaska Regional Corporation <1980 79

Sealaska Regional Corporation 2000s 79

Haida Village Corporation 1980s–1990s 589

Kootznoowoo Village Corporation 1980s–1990s 13,491

Other Land Owners -- 25

Total Private/Other Lands 14,184

 

 

TOTAL PROVINCE HARVEST 17,827

 
Appendix E

Catalogue of Past Harvest E-10 Final EIS

Ownership Category Landowner 

Est. Approx. 

Harvest 

Decade 

Acres 

Harvested

North Misty Fiords Biogeographic Province

Tongass National Forest Tongass National Forest 1950s 81

Tongass National Forest 1960s 960

Tongass National Forest 1980s 68

Tongass National Forest -- 260

Total NFS Lands 1,370

 

State of Alaska State of Alaska -- 818

Total State Lands 818

 

Private & Other Lands Sealaska Regional Corporation 1980s 16

Sealaska Regional Corporation 2000s 8

Total Private/Other Lands 23

 

 

TOTAL PROVINCE HARVEST 2,211

 

South Misty Fiords Biogeographic Province

Tongass National Forest Total NFS Lands 0

 

State of Alaska Total State Lands 0

 

Private & Other Lands Total Private/Other Lands 0

 

 

TOTAL PROVINCE HARVEST 0

 

Ice Fields Biogeographic Province

Tongass National Forest Tongass National Forest 1960s 1,732

Tongass National Forest 1970s 1,311

Tongass National Forest 1980s 996

Tongass National Forest 2000s 5

Total NFS Lands 4,044

 

State of Alaska Total State Lands 0

 

Private & Other Lands Total Private/Other Lands 0

 

 

TOTAL PROVINCE HARVEST 4,044

 
Appendix E

Final EIS E-11 Catalogue of Past Harvest

Ownership Category Landowner 

Est. Approx. 

Harvest 

Decade 

Acres 

Harvested

Glacier Bay/Fairweather Range Biogeographic Province

Tongass National Forest Total NFS Lands 0

 

State of Alaska Total State Lands 0

 

Private & Other Lands Glacier Bay N.P. -- 200

Total Private/Other Lands 200

 

 

TOTAL PROVINCE HARVEST 200

 

Chilkat River Complex Biogeographic Province

Tongass National Forest Total NFS Lands 0

 

State of Alaska State of Alaska 1980s–2000s 17,069

Total State Lands 17,069

 

Private & Other Lands BLM -- 136

Glacier Bay N.P. -- 568

Private/Other -- 2,864

Total Private/Other Lands 3,568

 

 

TOTAL PROVINCE HARVEST 20,637

 
Appendix E

Catalogue of Past Harvest E-12 Final EIS

Part II – Statistics on the Alaska Forest Resources and Practices Act 

Implementation and State Timber Sales in Southeast Alaska 

Part II presents a tabular summary of information provided by the State of Alaska Department of Natural 

Resources, Division of Forestry. Statistical information is not available for harvests prior to the Alaska 

Forest Resources and Practices Act (AFRPA), nor for some years since the Act. Tables E-1 through E-5 

provide statistics regarding the AFRPA, as it has been applied to private and other lands in Southeast 

Alaska. Tables E-6 through E-17 provide information on State timber sales in Southeast Alaska. 

Table E-1 

Forest Practices Act – Summary Statistics for Southeast Alaska, 1991-1998 

1991 1992 1993 1994 1995 1996 1997 1998

New Notifications 

SSE 103 117 145 124 131 146 123 87

NSE 2 0 8 0 3 1 0 0

TOTAL 105 117 153 124 134 147 123 87

Harvest Acreage in New Notifications Received

SSE 21016 37971 28769 33038 22745 30509 26034 16291

NSE 110 0 824 100 227 80 0 0

TOTAL 21126 37971 29593 33138 22972 30589 26034 16291

# Inspections

SSE 146 134 98 119 93 90 42 56

NSE 2 0 8 1 5 0 0 0

TOTAL 148 134 106 120 98 90 42 56

# Variation Trees Reviewed (=approved, denied, and other (e.g., withdrawn)

SSE 350 1344 3581 1660 1054 1116 2571 4113

NSE 83 0 0 0 0 0 0 0

TOTAL 433 1344 3581 1660 1054 1116 2571 4113

Table E-2 

Forest Practices Act – Summary Statistics for Southeast Alaska, 1999-2006

 1999 2000 2001 2002 2003 2004 2005 2006

New Notifications

SSE 79 104 36 43 51 47 43 51

NSE 0 0 19 10 6 6 5 3

TOTAL 79 104 55 53 57 53 48 54

Harvest Acreage in New Notifications Received

SSE 11705 20542 5599 7667 12197 30488 27733 37313

NSE 0 3779 9619 5839 1780 1969 344.3 413

TOTAL 11705.3 24321 15217.8 13505.5 13977 32457 28077.3 37726

# Inspections

SSE 32 89 44 43 58 35 59 20

NSE 0 0 25 24 11 9 13 9

TOTAL 32 89 69 67 69 44 72 29

# Variation Trees Reviewed (=approved, denied, and other (e.g., withdrawn)

SSE 1522 330 103 58 336 948 411 0

NSE 0 0 144 20 199 17 0 0

TOTAL 1522 330 247 78.4 535 965 411 0
Appendix E

Final EIS E-13 Catalogue of Past Harvest

Table E-3 

Forest Practices Act – Road Miles Summary for State of Alaska, 1997 - 2006

Road Miles Notified 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006

SSE 156 104 101 130 39 58 71 69 34.1 25

NSE 0 0 0 0 104 20 10 3 4 3

Mat-Su/SW 13 3 28 0 0 3 5 13 12 46

Kenai-Kodiak 195 50 146 44 65 146 96 57 25 11

COASTAL 364 157 275 174 208 227 182 142 75 85

Fairbanks 1 0 0 3 0 1 7 3 0 0

Delta 0 0 0 0 0 0 0 0 4 0

Tok 3 0 0 0 0 0 0 60 57.75 0

Copper R. 7 5 0 0 0 0 0 46 0 0

NORTHERN 11 5 0 3 0 1 7 109 61.75 0

TOTAL 375 162 275 177 208 228 189 251 136 85

Table E-4 

Southern Southeast Alaska, Forest Practices Act – Detail Statistics 

Yr Notified Geographical Area 

Acre 

Notified* 

Road 

Notified 

Renew 

Ac 

Renew 

Rd 

New 

PCT Ac 

Rnwl 

PCT Ac 

Private Land 

2000 Dall Island 2160.0 

2000 Kupreanof Kake Area 1381.0 14.0 430.0 4.0 629.0

2000 Long Island 1958.7 

2000 POW Big Salt 505.0 179.0

2000 POW Craig Rd Area 25.0 110.0 

2000 POW Hetta Inlet 766.0 8.1 710.0 7.6 

2000 POW Kasaan Peninsula 2091.1 10.5 487.5 1.0 

2000 POW Klawock Rd Area 831.0 3.5 179.5 0.2 

2000 POW Natzuhini Bay 89.0 0.7 113.0 58.0

2000 POW s/sw side Kasaan Bay 1140.0 18.9 354.0 2.1 

2000 POW Soda Bay 807.2 4.1 

2000 POW Trocadero Bay 2267.0 18.2 223.0 0.0 0.0 222.0

2000 Revilla Ketchikan Rd Area 522.0 10.0 54.0 1.5 

2000 Revillagigedo Island 10543.0 

 

2001 Dall Island 1978.0 20.6 230.3 

2001 Kupreanof Kake Area 316.0 3.0 49.0 0.2 610

2001 Long Island 808.0 

2001 POW Big Salt 216.0

2001 POW Hetta Inlet 1856.8 6.0 237.0 

2001 POW Kasaan Peninsula 27.0 0.8 449.5 

2001 POW Klawock Rd Area 55.0 0.4 

2001 POW Natzuhini Bay 208.0

2001 POW s/sw side Kasaan Bay 430.6 3.0 

2001 POW Soda Bay 991.0 8.5 

2001 POW Trocadero Bay 280.0

 
Appendix E

Catalogue of Past Harvest E-14 Final EIS

Table E-4 

Southern Southeast Alaska, Forest Practices Act – Detail Statistics 

Yr Notified Geographical Area 

Acre 

Notified* 

Road 

Notified 

Renew 

Ac 

Renew 

Rd 

New 

PCT Ac 

Rnwl 

PCT Ac 

2002 Dall Island 3835.0 10.4 363.0 2.1 280.0 

2002 Kupreanof Kake Area 1033.7 15.7 549.3 2.3 0.0 610.0

2002 Long Island 699.4 

2002 POW Big Salt 207.0 173

2002 POW Craig Rd Area 23.0 17.0 

2002 POW Hetta Inlet 254.0 164.0 

2002 POW Kasaan Peninsula 969.0 19.2 328.0 1.8 

2002 POW Natzuhini Bay 331.0 3.2 52.0 76.0

2002 POW s/sw side Kasaan Bay 306.0 

2002 POW Soda Bay 671.8 7.4 255.0 1.5 222.0

2002 Revilla Ketchikan Rd Area 244.0 2.3 103.0 1.9 

 

2003 Dall Island 2637.0 15.4 1029.0 5.0 460.0 

2003 Kupreanof Kake Area 3710.3 9.7 297.0 2.4 835.0 

2003 Long Island 360.5 

2003 POW Big Salt 695.0 

2003 POW Craig Rd Area 28.0 

2003 POW Hetta Inlet 602.0 

2003 POW Kasaan Peninsula 1252.5 11.5 0.2 38.0 

2003 POW Klawock Rd Area 2216.0 2.8 

2003 POW Natzuhini Bay 952.0 10.8 264.0 2.2 113.0 

2003 POW Soda Bay 1137.0 15.7 214.0 2.1 

2003 Revilla Ketchikan Rd Area 94.0 0.7 1.5 

 

2004 Dall Island 5189.3 31.7 100.0 119.0 

2004 Kosciusko Island 15.0 0.2 

2004 Kupreanof Kake Area 5056.0 9.5 72.5 1463.0 159.0

2004 Long Island 245.0 

2004 POW Big Salt 601.0 33.0

2004 POW Hetta Inlet 167.0 42.0

2004 POW Kasaan Peninsula 63.0 650.0 38.0 

2004 POW Klawock Rd Area 1082.0 0.4 

2004 POW Natzuhini Bay 3879.0 5.8 402.0 3.4 306.0 

2004 POW Nutkwa Inlet 1571.5 

2004 POW s/sw side Kasaan Bay 1326.0 1605.0 

2004 POW Soda Bay 5020.4 2.1 21.0 134.0

2004 POW Trocadero Bay 2388.0 15.8 542 

2004 Revilla Ketchikan Rd Area 4562.0 1.6 16.0 

2004 Wrangell Island Wrg Rd Area 336.0 2.3 

 

2005 Dall Island 751.0 9.9 658 0.9 

2005 Kupreanof Kake Area 4209.0 4710.5 5.0 216.0 110.0

2005 Long Island 366.0 

2005 POW Big Salt 271 80.0

2005 POW Hetta Inlet 95.0 

2005 POW Kasaan Peninsula 5398.0 1.5 1326 

2005 POW Klawock Rd Area 10.0 
Appendix E

Final EIS E-15 Catalogue of Past Harvest

Table E-4 

Southern Southeast Alaska, Forest Practices Act – Detail Statistics 

Yr Notified Geographical Area 

Acre 

Notified* 

Road 

Notified 

Renew 

Ac 

Renew 

Rd 

New 

PCT Ac 

Rnwl 

PCT Ac 

2005 POW Natzuhini Bay 2209.0 1807 0.6 369 

2005 POW Nutkwa Inlet 785.0 1571.5 

2005 POW s/sw side Kasaan Bay 4936.4 0.5 600.0 

2005 POW Soda Bay 1604.0 69.0

2005 POW Trocadero Bay 8473.2 7.1 638 5.1 

2005 Revilla Ketchikan Rd Area 1.3 2814 

2005 Revillagigedo Island 712.0 10.9 

2005 Wrangell Island Wrg Rd Area 250.0 2.5 332.0 2.3 

 

2006 Dall Island 12890.1 5 725.0 5.9 

2006 Kupreanof Kake Area 7761.2 5486 5.2 501.0 

2006 Long Island 377.5 

2006 Mitkof Petersburg Rd Area 2267.0 2.1 

2006 POW Big Salt 30.0 1563.0 

2006 POW Hetta Inlet 3473.0 1916 

2006 POW Kasaan Peninsula 178.0 

2006 POW Klawock Rd Area 16.0 

2006 POW Natzuhini Bay 694.0 

2006 POW Nutkwa Inlet 400.4 3.7 

2006 POW s/sw side Kasaan Bay 286.0 

2006 POW Trocadero Bay 2422.2 2545.4 2.1 

2006 Revilla Ketchikan Rd Area 2050.0 0.6 

2006 Revillagigedo Island 1025.0 10.1 859 4.8 

2006 Wrangell Island Wrg Rd Area 100.0 0.2 

 

2007 Dall Island 7988.1 7.6 2402.0 3.8 

2007 Kupreanof Kake Area 171.0 191.0

2007 Long Island 853.0 4.3 296.0 

2007 POW Big Salt 106.0 865 

2007 POW Craig Rd Area 39.0 

2007 POW Hetta Inlet 1109 320.0

2007 POW Kasaan Peninsula 362.0 174.0

2007 POW Klawock Rd Area 64.0 

2007 POW Natzuhini Bay 152.0 

2007 POW Nutkwa Inlet 400.4 3.7 

2007 POW Trocadero Bay 292.4 4.1 3039.4 

2007 Revilla Ketchikan Rd Area 14.0 0.5 1000 0.4 

2007 Revillagigedo Island 310.0 4.5 1055.0 4.4 

2007 Wrangell Island Wrg Rd Area 199.0 2.1 

 

Other Public Land (borough, city, 

university) 

2000 Revilla Ketchikan Rd Area 79.0 0.9 199.0 

2003 POW Thorne Bay Rd Area 58.0 0.8 

2003 Wrangell Island Wrg Rd Area 115.0 0.7 

2004 Wrangell Island Wrg Rd Area 110.0 

* Acres notified includes clearcut, partial cut, and salvage of previously cut cedar 
Appendix E

Catalogue of Past Harvest E-16 Final EIS

Table E-5 

Northern Southeast Alaska, Forest Practices Act – Detail Statistics 

DPO ID 

Date 

Received Land Owner-Operator Unit Number 

Unit 

Acres Area Name 

NSE-001 1/16/2001 Mental Health S17A 36 W. Icy Bay 

NSE-001 Mental Health S17B 58 W. Icy Bay 

NSE-001 1/16/2001 Mental Health S18 18 W. Icy Bay 

NSE-002 1/12/2001 SOA/University of AK 43 24 W. Icy Bay 

NSE-002 1/12/2001 SOA/University of AK 44 22 W. Icy Bay 

NSE-002 1/12/2001 SOA/University of AK 45 21 W. Icy Bay 

NSE-002 1/12/2001 SOA/University of AK 47 26 W. Icy Bay 

NSE-002 1/12/2001 SOA/University of AK 48 21 W. Icy Bay 

NSE-003 1/18/2001 SOA/University of AK 8B 9 W. Icy Bay 

NSE-005 1/2/2001 Sealaska Timber 60 59 Hoonah-Eastport 

NSE-005 1/2/2001 Sealaska Timber 107 13 Hoonah-Eastport 

NSE-005 1/2/2001 Sealaska Timber 108 72 Hoonah-Eastport 

NSE-005 1/2/2001 Sealaska Timber 110 111 Hoonah-Eastport 

NSE-005 1/2/2001 Sealaska Timber 137 122 Hoonah-Eastport 

NSE-005 1/2/2001 Sealaska Timber 126 22 Hoonah-Eastport 

NSE-005 1/2/2001 Sealaska Timber 127 68 Hoonah-Eastport 

NSE-005 1/2/2001 Sealaska Timber 128 45 Hoonah-Eastport 

NSE-006 2/15/2001 Sealaska Timber 135 87 Hoonah-Eastport 

NSE-007 3/23/2001 Mental Health S15C 39 W. Icy Bay 

NSE-007 3/23/2001 Mental Health C18A 14 W. Icy Bay 

NSE-007 3/23/2001 Mental Health C18B 11 W. Icy Bay 

NSE-007 3/23/2001 Mental Health C18C 4 W. Icy Bay 

NSE-007 3/23/2001 Mental Health C18D 3 W. Icy Bay 

NSE-007 3/23/2001 Mental Health C18E 4 W. Icy Bay 

NSE-007 3/23/2001 Mental Health C18F 4 W. Icy Bay 

NSE-007 3/23/2001 Mental Health S20 28 W. Icy Bay 

nse-009 4/5/2001 Mental Health C5 66 W. Icy Bay 

nse-009 4/5/2001 Mental Health 0 W. Icy Bay 

NSE-010 6/8/2001 Mental Health C11 137 W. Icy Bay 

NSE-012 7/1/2001 Mental Health C21B 16 W. Icy Bay 

NSE-012 7/1/2001 Mental Health S21A 5 W. Icy Bay 

NSE-012 7/1/2001 Mental Health S23A 27 W. Icy Bay 

NSE-012 7/1/2001 Mental Health S23B 25 W. Icy Bay 

NSE-012 7/1/2001 Mental Health S25 18 W. Icy Bay 

NSE-014 8/29/2001 Mental Health C25 8 W. Icy Bay 

NSE-014 8/29/2001 Mental Health S22A 22 W. Icy Bay 

NSE-015 11/20/2001 Mental Health C1A 4 W. Icy Bay 

NSE-015 11/20/2001 Mental Health C1B 12 W. Icy Bay 

NSE-015 11/20/2001 Mental Health C1C 50 W. Icy Bay 

NSE-015 11/20/2001 Mental Health C2 72 W. Icy Bay 

NSE-015 11/20/2001 Mental Health C25A 15 W. Icy Bay 

NSE-016 10/30/2001 Mental Health S3A 25 W. Icy Bay 

NSE-016 10/30/2001 Mental Health S3B 5 W. Icy Bay 

NSE-016 10/30/2001 Mental Health S5B 26 W. Icy Bay 

NSE-016 10/30/2001 Mental Health S12 14 W. Icy Bay 
Appendix E

Final EIS E-17 Catalogue of Past Harvest

Table E-5 

Northern Southeast Alaska, Forest Practices Act – Detail Statistics 

DPO ID 

Date 

Received Land Owner-Operator Unit Number 

Unit 

Acres Area Name 

NSE-018 3/29/2002 Mental Health C3 85 W. Icy Bay 

NSE-018 3/29/2002 Mental Health C20A 34 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 48A 22 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 310 86 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 311 105 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 312 145 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 314 125 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 314A 6 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 501 12 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 501A 3 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 502A 4 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 502B 6 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 502C 8 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 503 12 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 507 16 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 507 16 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 507A 12 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 509 69 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 510 51 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 601/602 260 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 603 76 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 604 66 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 605 130 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 606 14 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 607 46 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 608 67 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 609 99 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 701 19 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 702 130 W. Icy Bay 

NSE-022 6/25/2001 SOA/University of AK 703 74 W. Icy Bay 

NSE-13 7/22/2001 Mental Health C23 0 W. Icy Bay 

NSE-13 7/22/2001 Mental Health C24 0 W. Icy Bay 

NSE-13 7/22/2001 Mental Health S21 0 W. Icy Bay 

NSE-23 1/26/2002 SOA/University of AK 304 2 W. Icy Bay 

NSE-23 1/26/2002 SOA/University of AK 305 36 W. Icy Bay 

NSE-23 1/26/2002 SOA/University of AK 504 31 W. Icy Bay 

NSE-23 1/26/2002 SOA/University of AK 505A 25 W. Icy Bay 

NSE-23 1/26/2002 SOA/University of AK 505B 6 W. Icy Bay 

NSE-23 1/26/2002 SOA/University of AK 505C 20 W. Icy Bay 

NSE-23 1/26/2002 SOA/University of AK 506 6 W. Icy Bay 

NSE-23 1/26/2002 SOA/University of AK 508 11 W. Icy Bay 

NSE-24 4/5/2002 Sealaska Timber 8A 23 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 15 15 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 16 28 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 17A 31 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 31A 33 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 38A 17 Hoonah-Eastport 
Appendix E

Catalogue of Past Harvest E-18 Final EIS

Table E-5 

Northern Southeast Alaska, Forest Practices Act – Detail Statistics 

DPO ID 

Date 

Received Land Owner-Operator Unit Number 

Unit 

Acres Area Name 

NSE-24 4/5/2002 Sealaska Timber 128A 33 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 113 103 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 129 26 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 134 69 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 136B 82 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 1 46 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 4 13 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 6 13 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 7B 13 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 8 76 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 10 18 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 10a 13 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 14 34 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 17B 14 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 18 11 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 19 42 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 20C 17 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 20D 13 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 26A 49 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 27 51 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 28 20 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 28A 7 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 29 22 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 31 23 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 33B 19 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 36B 83 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 37 30 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 38 8 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 50 21 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 51 26 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 52A 31 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 53 53 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 59C 32 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 85 42 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 96 11 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 97 32 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 136 48 Hoonah-Eastport 

NSE-24 4/5/2002 Sealaska Timber 137 7 Hoonah-Eastport 

NSE-25 7/15/2002 Sealaska Timber 8A 23 Hoonah-Eastport 

NSE-25 7/15/2002 Sealaska Timber 38A 18 Hoonah-Eastport 

NSE-26 9/29/2002 Sealaska Timber 108A 22 Hoonah-Eastport 

NSE-26 9/29/2002 Sealaska Timber 109 23 Hoonah-Eastport 

NSE-26 9/29/2002 Sealaska Timber 111 29 Hoonah-Eastport 

NSE-26 9/29/2002 Sealaska Timber 112 56 Hoonah-Eastport 

NSE-27 2/10/2003 Yak-Tat-Kwaan-Aloha 1 24 Yakutat 

NSE-27 2/10/2003 Yak-Tat-Kwaan-Aloha 2 64 Yakutat 

NSE-27 2/10/2003 Yak-Tat-Kwaan-Aloha 3 91 Yakutat 
Appendix E

Final EIS E-19 Catalogue of Past Harvest

Table E-5 

Northern Southeast Alaska, Forest Practices Act – Detail Statistics 

DPO ID 

Date 

Received Land Owner-Operator Unit Number 

Unit 

Acres Area Name 

NSE-27 2/10/2003 Yak-Tat-Kwaan-Aloha 4 207 Yakutat 

NSE-27 2/10/2003 Yak-Tat-Kwaan-Aloha 5 75 Yakutat 

NSE-27 2/10/2003 Yak-Tat-Kwaan-Aloha 6 45 Yakutat 

NSE-28 2/22/2003 Sealaska Timber 136B 21 Hoonah-Eastport 

NSE-28 2/22/2003 Sealaska Timber 47 120 Hoonah-Eastport 

NSE-28 2/22/2003 Sealaska Timber 115 82 Hoonah-Eastport 

NSE-28 2/22/2003 Sealaska Timber 134 58 Hoonah-Eastport 

NSE-28 2/22/2003 Sealaska Timber 114A 89 Hoonah-Eastport 

NSE-28 2/22/2003 Sealaska Timber 36A 26 Hoonah-Eastport 

NSE-28 2/22/2003 Sealaska Timber 33A 14 Hoonah-Eastport 

NSE-28 2/22/2003 Sealaska Timber 26C 23 Hoonah-Eastport 

NSE-28 2/22/2003 Sealaska Timber 114B 22 Hoonah-Eastport 

NSE-29 5/8/2003 Sealaska Timber 195C 57 Hoonah-Eastport 

NSE-29 5/8/2003 Sealaska Timber 162 60 Hoonah-Eastport 

NSE-29 5/8/2003 Sealaska Timber 171 86 Hoonah-Eastport 

NSE-29 5/8/2003 Sealaska Timber 169A 48 Hoonah-Eastport 

NSE-29 5/8/2003 Sealaska Timber 168 48 Hoonah-Eastport 

NSE-29 5/8/2003 Sealaska Timber 167B 89 Hoonah-Eastport 

NSE-29 5/8/2003 Sealaska Timber 180 12 Hoonah-Eastport 

NSE-29 5/8/2003 Sealaska Timber 180 23 Hoonah-Eastport 

NSE-29 5/8/2003 Sealaska Timber 186 101 Hoonah-Eastport 

nse-31 6/30/2003 Sealaska Timber 44A 19 Hoonah-Eastport 

nse-31 6/30/2003 Sealaska Timber 47 119 Hoonah-Eastport 

nse-31 6/30/2003 Sealaska Timber 49 45 Hoonah-Eastport 

NSE-32 9/11/2003 Sealaska Timber 43B 22 Hoonah-Eastport 

NSE-32 9/11/2003 Sealaska Timber 42A 39 Hoonah-Eastport 

NSE-32 9/11/2003 Sealaska Timber 18 12 Hoonah-Eastport 

NSE-32 9/11/2003 Sealaska Timber 17B 15 Hoonah-Eastport 

NSE-33 3/11/2004 Huna Totem EPSH 400 1752 Hoonah-Eastport 

NSE-34 8/10/2004 Sealaska Timber 13 28 Hoonah-Eastport 

NSE-34 8/10/2004 Sealaska Timber 131 83 Hoonah-Eastport 

NSE-34 8/10/2004 Sealaska Timber 132 61 Hoonah-Eastport 

NSE-35 8/10/2004 Huna Totem 172 45 Hoonah-Eastport 

NSE-36 4/10/2005 Sealaska Timber 26A 30 Hoonah-Eastport 

NSE-36 4/10/2005 Sealaska Timber 101A 17 Hoonah-Eastport 

NSE-37 4/22/2005 Huna Totem 175 56 Hoonah-Eastport 

NSE-37 4/22/2005 Huna Totem 178 77 Hoonah-Eastport 

NSE-38 4/27/2005 Sealaska Timber 10 6 Hoonah-Eastport 

NSE-38 4/27/2005 Sealaska Timber 16 18 Hoonah-Eastport 

NSE-38 4/27/2005 Sealaska Timber 51A 28 Hoonah-Eastport 

NSE-38 4/27/2005 Sealaska Timber 83A 15 Hoonah-Eastport 

NSE-38 4/27/2005 Sealaska Timber 400 24 Hoonah-Eastport 

NSE-39 8/5/2005 Sealaska Timber 16A 13 Hoonah-Eastport 

NSE-40 5/18/2005 SOA/University of AK 704 60 W. Icy Bay 

NSE-41 1/17/2007 SOA/University of AK 204 23 W. Icy Bay 

NSE-41 1/17/2007 SOA/University of AK 205 17 W. Icy Bay 

NSE-41 1/17/2007 SOA/University of AK 207 0 W. Icy Bay 
Appendix E

Catalogue of Past Harvest E-20 Final EIS

Table E-5 

Northern Southeast Alaska, Forest Practices Act – Detail Statistics 

DPO ID 

Date 

Received Land Owner-Operator Unit Number 

Unit 

Acres Area Name 

NSE-43 8/15/2007 SOA/University of AK 203 33 W. Icy Bay 

NSE-44 8/15/2007 Sealaska Timber 802 18 Hoonah-Eastport 

NSE-44 8/15/2007 Sealaska Timber 37 5 Hoonah-Eastport 

NSE-44 8/15/2007 Sealaska Timber 117A 9 Hoonah-Eastport 

NSE-45 10/7/2007 Sealaska Timber 130 6 Hoonah-Eastport 

NSE-45 10/7/2007 Sealaska Timber 808 5 Hoonah-Eastport 

Table E-6 

State timber sales sold 

Volume sold 

Year North-Central South-Central Southeast 

1983 5964 51985 54 

1984 14735 4445 1907 

1985 12182 4698 3298 

1986 4450 2587 424 

1987 9352 3081 7174 

1988 16510 4513 6452 

1989 13872.5 1990 5738 

1990 14317.9 3398.8 18064.5 

1991 9519 565 72.2 

1992 20613 3306 186 

1993 17208 1020 9065 

1994 1569 5564 8903 

1995 107521 28332 4455 

1996 182131

 9368 1109 

FY97 15528 129 5942 

FY98 13211 17754 14623 

FY99 6836 2803 4797 

FY00 6637 5774 8365 

FY01 6064 1857 954 

FY02 4207 1333 11340 

FY03 4813 3779 4094 

FY04 2708 957 8064 

FY05 5594 4934 16003 

FY06 12478 6638 10777 

FY07 6420 30110 24437 1

 Converted from Mcf. 

Note: data collection changed from calendar year (CY) to fiscal year (FY) with some 

overlap between 1996 and FY97.
Appendix E

Final EIS E-21 Catalogue of Past Harvest

Table E-7 

FY 97 STATE TIMBER SALES SOLD - SOUTHEAST 

AREA SALE NAME ACRES

SALE 

DATE USE 

VOL 

MBF 

Ketchikan Ronald Brown 6 7/22/1996 local 37 

Ketchikan Pat Richter 4 8/21/1996 local 43 

Ketchikan Ernie Eads 9 8/22/1996 local 34 

Ketchikan Last Chance Enterprises 5 1/13/1997 local 55 

Ketchikan Ernie Eads 1 2/3/1997 local 8 

Ketchikan Pat Richter 1 3/3/1997 local 4 

Ketchikan Warren Jones 2 3/7/1997 local 46 

Ketchikan Norman Canaday 5 3/18/1997 local 14 

Ketchikan Ralph Porter 1 5/26/1997 local 34 

Ketchikan Daryl Tinkness 1 6/16/1997 local 19 

Ketchikan Ernie Eads 9 6/9/1997 local 228 

Ketchikan Pete Smit 8 5/30/1997 local 54 

SUBTOTAL 12 52 576 

Haines Pond View 22 10/14/1996 local 249 

SUBTOTAL 1 22 249 

Juneau Shadow 45 7/26/1996 Export 1,455 

Juneau Corner 12 9/30/1996 local 141 

Juneau Blackheart 14 11/7/1996 local 425 

Juneau Nufie 79 2/11/1997 local 1,700 

Juneau Thumb Nail 45 2/11/1997 local 802 

Juneau Pt. Frederick #6 9 3/7/1997 Export 446 

Juneau Silas Triangle 6 6/30/1997 mixed 106 

Juneau Magazine Road 3 6/30/1997 Export 42 

SUBTOTAL 8 213 5,117 

Table E-8 

STATE TIMBER SALES SOLD- FY 98 - SOUTHEAST 

AREA SALE NAME ACRES SALE DATE USE VOL MBF 

KETCHIKAN FLEENOR 5 7/25/1997 local 178 

KETCHIKAN SNEATHER 0 10/21/1997 local 7 

KETCHIKAN WHALE PASS ASSOC. I 0 11/3/1997 local 55 

KETCHIKAN WHALE PASS ASSOC. II 0 2/26/1998 local 67 

KETCHIKAN TINKESS 1 11/14/1997 local 5 

KETCHIKAN TRUMBLE 1 11/24/1997 local 1 

KETCHIKAN FLEENOR #2 8 3/6/1998 local 147 

KETCHIKAN GRAY 1 12/8/1997 local 2 

KETCHIKAN SMITH 3 PENDING local 16 

KETCHIKAN EADS 2 5/12/1998 local 44 

KETCHIKAN HAMMAR 3 5/12/1998 local 21 

KETCHIKAN HOLLIS COMM. COUNCIL 0 5/12/1998 local 74 

KETCHIKAN KITKUN 160 6/29/1998 local 4,300 

SUBTOTAL 13 184 4,917 

 

NSE THUNDER CREEK 565 7/15/1997 export 4,331 

NSE BUSTER BENSON 7 8/18/1997 local 80 
Appendix E

Catalogue of Past Harvest E-22 Final EIS

Table E-8 

STATE TIMBER SALES SOLD- FY 98 - SOUTHEAST 

AREA SALE NAME ACRES SALE DATE USE VOL MBF 

NSE HIGHLINE 8 9/2/1997 local 244 

NSE ALASKA POWER & TELE. 0 9/18/1997 local 6 

NSE FRED STRONG 4 10/9/1997 local 32 

NSE SCOTT ROSSMAN 5 5/8/1998 local 23 

NSE SCOTT ROSSMAN #2 2 5/28/1998 local 12 

NSE SCOTT ROSSMAN #3 2 6/15/1998 local 58 

NSE BANANA PT. SALVAGE 2 7/9/1997 local 40 

NSE ROY'S BREAKDOWN 41 7/23/1997 local 1,339 

NSE SILAS 14 7/23/1997 local 466 

NSE ROY SOKOL SALVAGE 1 7/29/1997 local 9 

NSE THUMBNAIL UNIT 3 2 9/12/1997 local 229 

NSE THUMBNAIL II 29 9/15/1997 local 607 

NSE MITKOF HWY ROW 1 11/21/1997 local 16 

NSE HEMLOCK SALVAGE 0 11/21/1997 local 9 

NSE SHADOW SALVAGE 0 11/24/1997 export 120 

NSE HERMIT CREEK 4 12/22/1997 local 102 

NSE PT. FREDERICK #6 0 6/5/1998 local 58 

NSE EASTERN PASSAGE I 83 2/23/1998 local 1,681 

NSE NUFIE II 19 6/9/1998 local 244 

SUBTOTAL 21 788 9,706 

Table E-9 

STATE TIMBER SALES SOLD -- FY 99 COASTAL REGION

AREA SALE NAME ACRES 

SALE 

DATE MBF USE 

SALES SOLD 

KETCHIKAN Fleenor No. 3 6 07/27/98 125 Local 

KETCHIKAN Small #2 4 08/17/98 123 Local 

KETCHIKAN Small #3 3 09/28/98 68 Local 

KETCHIKAN Small #4 6 11/30/98 382 Local 

KETCHIKAN Small #5 4 11/30/98 308 Local 

KETCHIKAN Small #6 1 11/24/98 18 Local 

KETCHIKAN Small #7 3 12/11/98 80 Local 

KETCHIKAN Small #8 3 12/24/98 67.7 Local 

KETCHIKAN Small #9 0.1 03/26/99 10 Local 

KETCHIKAN Small #10 9.9 05/19/99 357 Local 

KETCHIKAN Small #11 4.7 06/01/99 150 Local 

Subtotal 11 44.7 1,688.7 

NSE Thumbnail III 74 09/21/98 1,613 Local 

NSE Eastern Passage I 52 06/01/99 1,429 Local 

NSE 

McCormack Creek 

Rd. Project ROW 0 08/03/98 37.25 Local 

NSE Del Mikkelsen 5 12/03/98 29 Local 

Subtotal 5 131 3,108 
Appendix E

Final EIS E-23 Catalogue of Past Harvest

Table E-10 

STATE TIMBER SALES SOLD -- FY 00 -- SOUTHEAST

AREA SALE NAME ACRES SALE DATE MBF MCF USE 

KETCHIKAN SE-959K 1 07/13/99 3 Local 

KETCHIKAN Coffman Cove 214 07/27/99 5,515 Local 

KETCHIKAN SE-960K 1 09/21/99 14 Local 

KETCHIKAN SE-962K 5 09/21/99 117 Local 

KETCHIKAN SE-1019K 1 03/13/00 12 Local 

KETCHIKAN SE-1021K 5 04/07/00 491 Local 

KETCHIKAN SE-970K 2 05/22/00 27 Local 

KETCHIKAN SE-971K 1 06/08/00 8 Local 

KETCHIKAN SE-1020K 1 34 Local 

KETCHIKAN SE-972K 5 468 Local 

KETCHIKAN SE-973K 8 257 Local 

Subtotal 11 244 6,945.9 

NSE Small #1, SE-474J 3 07/19/99 139 Local 

NSE 

Eastern Passage I, Unit 

4 24 12/30/99 656 Local 

NSE Devils Elbow 2 07/19/99 24 Local 

NSE Porcupine Snow 12/22/99 41 Local 

NSE High Extension 8 02/01/00 49 Local 

NSE Porcupine Wings 24 03/28/00 419 Any 

NSE Porcupine Heights 5 04/05/00 38 Local 

NSE Roy's Favorite 3 06/02/00 53 Local 

Subtotal 8 69 1,419 

Table E-II 

STATE TIMBER SALES SOLD -- FY 01 SOUTHEAST 

AREA SALE NAME ACRES 

SALE 

DATE MBF PURCHASER USE 

SSE SE-979-K 1 01/12/01 20 Jack Dupertuis local 

SSE SE-983-K 2 03/14/01 28 Sealaska export 

SSE SE-1020-K 2 10/16/00 34 Naukati Adventures local 

SSE SE-976-K 7 10/03/00 391 Pat Richter local 

SSE SE-980-K 0 12/08/00 10 Evergreen Timber export 

SSE SE-981-K 2 12/08/00 30 Hummer Enterprises local 

SSE SE-982-K 4 05/16/01 80 B&W Lumber local 

SSE SE-984-K 0 05/17/01 10 Hummer Enterprises local 

Subtotal 8 17 603 0 0 

NSE Ski Hill 5 07/29/00 34 The Stump Co. local 

NSE 37Mile 6 04/10/01 104 The Stump Co. local 

NSE Chilkat Lake 2 04/10/01 19 Bob Jensen local 

NSE Knob 4 2 04/10/01 28 Tophat Logging local 

NSE Birch Hill 1 04/30/01 9 Eager Beaver local 

NSE Knob Extension 1 06/18/01 1 Sage Thomas local 

NSE Knobs Backside 5 06/25/01 24 Carl Smith local 

NSE Half Load 1 01/18/01 11 Hidden Valley local 

NSE Knob 3 Extension 2 02/05/01 16 Green Diamond local 

NSE Daisy 3 02/23/01 65 Hidden Valley local 

NSE SE-741 1 02/26/01 11 Don Peterson local 

NSE Three Peaks 2 03/12/01 20 Green Diamond local 

NSE Knob ABC 2 03/21/01 9 Green Diamond local 

Subtotal 13 33 351 0 0 
Appendix E

Catalogue of Past Harvest E-24 Final EIS

Table E-12 

STATE TIMBER SALES -- FY 02 -- SOUTHEAST

AREA SALE NAME ACRES 

SALE 

DATE MBF USE 

SSE Naukati West 70 04/29/02 2,685 V-A 

SSE East Pass #5 50 04/01/02 1,110 V-A 

SSE Tuxecan 134 04/15/02 4,018 V-A 

SSE Richter #2 4 07/09/01 187 V-A 

SSE Richter #3 3 02/08/02 90 V-A 

SSE Jones 1 0 09/18/01 13 V-A 

SSE Sunde 1 0 05/30/02 7 V-A 

SSE Clark Bay Group 3 11/02/01 26 V-A 

SSE Gildersleeve1 1 09/17/01 24 V-A 

SSE Thorne Bay #1 80 09/14/01 2,539 V-A 

Subtotal 10 345 10,699 0 

NSE 37.5 Mile Fall 4 10/25/01 51 V-A 

NSE 37-Mile Addition 4 07/24/01 28 V-A 

NSE Daisy Salvage 1 10/16/01 31 V-A 

NSE Birch Road A 2 07/13/01 17 V-A 

NSE Birch Pole 1 01/08/02 3 V-A 

NSE Backside 2 3 07/10/01 19 V-A 

NSE Daisy 2 7 05/24/02 117 V-A 

NSE Birch road 2 07/06/01 10 V-A 

NSE Daisy Dead 2 06/06/02 9 V-A 

NSE LS Mountain 10 07/09/01 357 V-A 

Subtotal 10 36 641 

Table E-13 

STATE TIMBER SALES SOLD -- FY 03 -- SOUTHEAST

AREA SALE NAME ACRES 

SALE 

DATE MBF USE 

SSE Yatuk Creek #1 4 10/15/02 179 VA 

SSE Yatuk Creek #2 5 10/15/02 228 VA 

SSE Yatuk Creek #3 2 10/15/02 80 VA 

SSE Yatuk Creek #4 4 10/15/02 41 VA 

SSE Yatuk Creek #5 6 10/15/02 205 VA 

SSE Yatuk Creek #6 4 10/15/02 112 VA 

SSE Yatuk Creek #7 4 10/15/02 308 VA 

SSE Yatuk Creek #8 3 10/15/02 151 VA 

SSE Yatuk Creek #9 64 01/06/03 2,064 VA 

SSE Frederick Rd. #1 4 10/14/02 125 VA 

SSE Thorne Bay Burn #4 2 11/01/02 53 VA 

SSE Thorne Bay Burn #5 2 11/01/02 40 VA 

SSE Sandy Road #1 6 11/01/02 87 VA 

SSE Sunde #2 <1 05/06/03 10 VA 

Subtotal 14 110 3,683 

NSE 

Starigavin ROW NSE1026 1 09/27/02 6 VA 

NSE Tidy Stump SE-759 1 08/23/02 25 VA 

NSE Farm Wood 3 01/17/03 50 VA 

NSE Jensen Skid Road 3 02/18/03 19 VA 

NSE Hemlock Switch 5 02/10/03 67 VA 

NSE Spruce Addition 1 02/04/03 10 VA 

NSE 20 Mile Xing 2 02/26/03 13 VA 

NSE Half Dozen 1 02/28/03 4 VA 
Appendix E

Final EIS E-25 Catalogue of Past Harvest

Table E-13 

STATE TIMBER SALES SOLD -- FY 03 -- SOUTHEAST

NSE Wolf Pack 1 03/10/03 13 VA 

NSE Chilkat Lake Road 2 03/27/03 5 VA 

NSE Spruce Log 2 01/03/03 10 VA 

NSE Hemlock Home 1 01/13/00 13 VA 

NSE Porcupine Clean 1 11/04/02 11 VA 

NSE Farm Birch 2 12/17/02 6 VA 

NSE Wolf Skid 2 04/04/03 4 VA 

NSE Spruce Tap 2 05/05/03 7 VA 

NSE Hemlock Corner 2 05/05/03 41 VA 

NSE 37 Mile Patch 1 05/19/03 10 VA 

NSE 38 Mile Draw 9 05/21/03 84 VA 

NSE Daisy Cleanup 3 06/13/03 64 VA 

Subtotal 20 45 462 

Table E-14 

STATE TIMBER SALES SOLD -- FY 04 -- SOUTHEAST

AREA SALE NAME ACRES 

SALE 

DATE MBF USE 

SSE Boy Scout 19 08/21/03 990.18 local 

SSE Intertie ROW n/a 07/21/03 172.00 local 

SSE Coffman Cove R 1 08/18/03 40.40 local 

SSE Kasaan 1 149 10/21/03 3,238.00 local 

SSE East Naukati 135 05/06/04 3,164.00 local 

SSE Thorne Bay ROW 1 12/12/03 42.43 export 

 Subtotal 6 305 7,647.01 

NSE 

Deats 1-N. 

Douglas 1 03/14/04 1.00 local 

NSE Little Salmon Mt. 8 10/03/03 357.00 local 

NSE 38-mile Draw 5 1 10/02/03 10.00 local 

NSE Spruce Rose 1 07/08/04 11.00 local 

NSE Big Hemlock 2 07/23/03 34.00 local 

NSE Boulder Spruce 3 08/10/03 52.00 local 

NSE Boulder Spruce 2 10 10/30/03 24.00 local 

NSE 38 Mile Pocket 1 11/25/03 33.00 local 

NSE Stretch Time 2 12/10/03 29.00 local 

NSE Ice Road 2 02/06/04 28.00 local 

NSE Boulder 6 x 6 1 05/03/04 21.00 local 

NSE Stretch Melt 2 06/10/04 31.00 local 

NSE Nataga Skid 3 06/10/04 5.24 local 

NSE Stretch 6 11/28/03 53.00 local 

NSE 38 Mile Extension 1 12/09/03 22.00 local 

 Subtotal 15 44 711.24 
Appendix E

Catalogue of Past Harvest E-26 Final EIS

Table E-15 

STATE TIMBER SALES SOLD -- FY 05 -- SOUTHEAST

AREA SALE NAME ACRES SALE DATE MBF USE 

SSE 2058 Road 1/Jones #2 3 07/09/04 36 local 

SSE 2058 Road 2/Jones #3 2 07/09/04 28 local 

SSE 2058 Road 4/Jones #1 2 07/09/04 19 local 

SSE 2058 Road 5/Thorne Bay WP 6 07/27/04 107 local 

SSE 2058 Road 6/Thorne Bay WP 3 07/21/04 65 local 

SSE Sandy Road 2 20 08/20/04 419 local 

SSE Coffman Cove ROW #2 1 08/23/04 8 local 

SSE Thorne Bay 2 130 10/30/04 4130 local 

SSE Control Lake 1-mid 112 11/15/04 3627 local 

SSE Shady Tie-in 40 11/29/2004 987 local 

SSE Kasaan 6 6 11/17/04 179 local 

SSE Control Lake 2 5 12/03/04 121 local 

SSE Control L. 3 8 12/03/04 189 local 

SSE Control L. 4 17 12/09/04 491 local 

SSE Kasaan 2 108 12/17/04 4028 local 

SSE Mt. Point #1 3 05/12/05 149 export 

SSE Choker Setter Cir. 1 06/28/05 23 local 

 Subtotal 17 466 14,606 

NSE Boulder Load 1 7/6/2004 8 local 

NSE Boulder Six X Six 2 1 7/12/2004 8 local 

NSE Alder Rerun 2 7/23/2004 27 local 

NSE Alder Rerun 2 2 9/1/2004 41 local 

NSE Nataga Skid 2 1 8/12/2004 17 local 

NSE Alder III 2 9/17/2004 59 local 

NSE Porcupine Mining 1 9/10/2004 20 local 

NSE Porcupine Mining II 1 9/10/2004 23 local 

NSE Klehini U14 Corner 2 12/11/2004 32 local 

NSE Porcupine Mining III 1 10/15/2004 13 local 

NSE Takshanuk Trail 3 11/7/2004 14 local 

NSE 37 Mile Ridge 2 11/11/2004 15 local 

NSE Porcupine Low Road 1 11/12/2004 10 local 

NSE Battleship Island 1 12/12/04 2 local 

NSE West Herman 2 9 1/3/2005 185 local 

NSE 37 Mile Bowl 2 1/4/2005 27 local 

NSE 37 Mile Bowl 2 1 1/24/2005 38 local 

NSE Purlin 1 02/16/05 1 local 

NSE Pondside 2 02/28/05 31 local 

NSE West Draw 2 03/14/05 21 local 

NSE West Herman 1 23 03/01/05 594 local 

NSE West Draw #2 1 04/01/05 21 local 

NSE Knobs Rerun 2 05/21/05 49 local 

NSE Fabrizio Mining 6 05/27/05 82 local 

NSE Birch Reload 1 05/18/05 6 local 

NSE Nataga Sky 1 06/10/05 22 local 

NSE Dunit Bench 2 06/20/05 31 local 

 Subtotal 27 74 1,397 
Appendix E

Final EIS E-27 Catalogue of Past Harvest

Table E-16 

STATE TIMBER SALES SOLD -- FY 06 -- SOUTHEAST

AREA SALE NAME ACRES SALE DATE MBF USE 

SSE 2058 Rd 8 small/Gutchi Creek #2 5 08/02/05 108 local 

SSE SSE 1230/2058 Rd 8 mid 18 10/01/05 588 local 

SSE Eastern Passage units 6-12 395 11/01/05 9110 local 

SSE Steep Drive 1 10/19/05 20 local 

SSE South Thorne Arm #1 0 10/01/05 2 local 

SSE Leask Lake Sort Yard 5 09/22/05 60 export 

SSE Kasaan 6 6 3/28/2006 179 local 

 

Subtotal 7 430 10,067 

 

NSE Tatshunak Trail 1 8/2/2005 5 local 

NSE Knobs B-C Timber 1 7/25/2005 16 local 

NSE Nataga Stretch 18 7/25/2005 173 local 

NSE Glacier Salvage 10 10/1/2005 100 local 

NSE Spruce Corner 1 10/3/2005 27 local 

NSE KB West Spur 1 10 10/10/2005 144 local 

NSE 1424 Hemlock Ridge 1 12/29/2005 46 local 

NSE 1425 Porcupine Salvage 3 1/6/2006 25 local 

NSE 1426 Billy Goat 3 1/6/2006 24 local 

NSE 1427 Farm Special 5 2/1/2006 38 local 

NSE 1428 Farm Spur 2 3 03/15/06 37 local 

NSE 1429 Billy Goat 2 3 04/11/06 55 local 

NSE Boulder Firewood 1 04/11/06 10 local 

NSE Porcupine Firewood 2 06/26/06 10 local 

 

Subtotal 14 62 710 
Appendix E

Catalogue of Past Harvest E-28 Final EIS

Table E-17 

STATE TIMBER SALES SOLD -- FY 07 -- SOUTHEAST

AREA SALE NAME ACRES 

SALE 

DATE MBF USE 

SSE Bostwick #1 362 11/29/06 12687 local 

SSE 2058 Road Small 6 07/10/06 182 local 

SSE 2058 Road Small 4 07/10/06 98 local 

SSE Control Lake Fir 1 08/25/06 0 local 

SSE Leask Lake Aide 1 08/25/06 19 research 

SSE South Thorne Bay 128 07/02/06 3330 local 

SSE D-1 #1 1 04/02/07 7 export 

SSE 20 Road 26 05/29/07 5145 local 

SSE Whipple Creek 26 04/02/07 2334 export 

SSE Bostwick Trail Lo 0 6/20/2007 13 local 

 Subtotal 10 555 23,815 

 

NSE KB2 1 7/28/2006 17 local 

NSE Cabin Log 4 8/10/2006 41 local 

NSE Spur Road 1 8/10/2006 12 local 

NSE West Herman 3 4 8/25/2006 105 local 

NSE Porcupine Spruce 3 9/12/2006 132 local 

NSE Hemlock Spruce 3 9/12/2006 55 local 

NSE KB3 6 10/26/2006 42 local 

NSE Winds 2 11/2/2006 119 local 

NSE Porucpine Road 1 11/7/2006 5 local 

NSE Warm Springs 5 10/01/06 1 local 

NSE Hidden 2 01/03/07 16 local 

NSE 35 Mile Snow Co 10 04/09/07 9 local 

NSE Sunlight Salvage 2 05/11/07 45 local 

NSE Ski Hill 3 06/05/07 23 local 

 Subtotal 14 47 621.9 
APPENDIX F 

BIOLOGICAL ASSESSMENT 
Appendix F

Final EIS F-i Biological Assessment

Appendix F 

Biological Assessment 

CONTENTS 

Introduction ............................................................................................................................................F-1

Section 1. Biological Assessment for Kittlitz’s murrelet for the Tongass Forest Plan Adjustment......F-3

I. Identification of Endangered, Threatened and Candidate Species and/or Critical 

Habitats for Such Species within the Project Area. ....................................................F-3

II. Overview of Species Distributions, Populations and Habitats....................................F-3

III. Assessment of Effects on the Populations or Habitats of the Species In 

Relation to Proposed Actions of the Tongass Forest Plan Adjustment......................F-4

Relationship with other Agencies and Plans ..............................................................F-4

Determination for Kittlitz’s Murrelet.............................................................................F-4

Documentation of Correspondence with other Agencies ...........................................F-4

IV. Literature Cited ...........................................................................................................F-5

Section 2. Biological Assessment for the Endangered Humpback Whale, Endangered Western and 

Threatened Eastern Steller Sea Lion Populations, and Listed Pacific Salmon and 

Steelhead for the Tongass National Forest Plan Adjustment ............................................F-6

I. Identification of Endangered and Threatened Species and/or Critical Habitats 

for Such Species Within the Project Area...................................................................F-6

II. Overview of Species Distributions and Populations...................................................F-7

Humpback Whale .......................................................................................................F-8

Steller Sea Lion...........................................................................................................F-8

Listed Salmon and Steelhead...................................................................................F-10

III. Assessment of Effects on the Populations or Habitats of the Species in Relation 

to Proposed Actions of the Tongass Forest Plan Adjustment..................................F-10

Humpback Whale .....................................................................................................F-10

Steller Sea Lion.........................................................................................................F-12

Salmon......................................................................................................................F-12

Determination for Marine Mammals and Listed Pacific Salmon/Steelhead .............F-13

Documentation of Correspondence with Other Agencies ........................................F-13

IV. Literature Cited .........................................................................................................F-14

LIST OF TABLES 

Table F-1 Threatened and Endangered Species Listed as occurring on or adjacent to the Tongass 

National Forest from USFWS and NMFS. ...............................................................................F-2

Table F-2 Major Steller Sea Lion Rookery and Haul-out Habitats in Southeast Alaska ..........................F-7
Appendix F

Final EIS F-1 Biological Assessment

Appendix F 

Biological Assessment 

Introduction 

Under Section 7 of the Endangered Species Act (ESA), federal agencies are required to ensure that 

actions are not likely to jeopardize the continued existence of a listed species. This is done in a report 

called a “Biological Assessment.” The effects analysis for threatened and endangered (T&E) species is 

required to address the direct and indirect effects of the action(s) on T&E species and their critical habitat 

(50 Code of Federal Regulations [CFR] 402.02). This documentation complies with Section 7 of the ESA 

which requires all federal agencies, in consultation with the U.S. Fish and Wildlife Service (USFWS) and 

the National Marine Fisheries Service (NMFS), to ensure that their actions are not likely to jeopardize the 

continued existence of T&E species or adversely modify their habitat. It updates previous Biological 

Assessments for the Tongass Plan Revision dated October 1996 (previous versions were also completed 

in August 1990 and April 1992). 

This biological assessment complies with the Forest Service Manual (FSM) 2672.4 and documents the 

potential direct and indirect effects of the proposed alternatives (including the Proposed Action) and the 

cumulative effects of past, present, and reasonably foreseeable actions within the project area or 

adjacent lands on the critical habitats and viability of any federally listed or USDA Forest Service sensitive 

listed species. Species considered in this assessment include any species listed as threatened, 

endangered, proposed, or candidate by USFWS or NMFS. 

Six wildlife species and one plant species under the jurisdiction of USFWS are found (or were once 

found) in Alaska: Kittlitz’s murrelet (Brachyramphus brevirostris), the recently listed northern sea otter 

(Enhydra lutris kenyoni), short-tailed albatross (Phoebastria albatrus), Eskimo curlew (Numenius 

borealis), spectacled eider (Somateria fischeri), Alaska breeding population of Steller’s eider (Polysticta 

stelleri), and Aleutian shield fern (Polystichum aleuticum). Except for the Kittlitz’s murrelet, which is a 

candidate for listing under ESA, none of these species is found in Southeast Alaska, and will not be 

discussed further in this biological assessment. 

Additionally, a number of marine threatened and endangered species fall under the jurisdiction of NMFS. 

These species are at least occasionally, or historically have been, found in Southeast Alaska. They 

include the leatherback sea turtle (Dermochelys coriacea), eastern population of Steller sea lion 

(Eumetopias jubatus), small numbers of the western population of Steller sea lion (E. jubatus), fin whale 

(Balaenoptera physalus), northern right whale (Eubalaena japonica), blue whale (B. musculus), and 

humpback whale (Megaptera novaeangliae). In addition to the above listed species, the Cook Inlet 

beluga whale Distinct Population Segment (DPS) has been proposed for listing as endangered. 

Furthermore, one sockeye salmon (Onchorynchus nerka), six chinook salmon (O. tshawytscha), one 

chum salmon (O. keta), and six steelhead trout (O. mykiss) evolutionarily significant units (ESUs)/DPSs 

are currently listed under ESA and are known to seasonally inhabit the marine waters of Southeast 

Alaska (Table F-1). However, of all these species, the Steller sea lion and humpback whale are known to 

occur in Southeast Alaska, while 14 of the 28 listed salmon and steelhead trout stocks shown in Table F1 occur in Southeast Alaska’s marine waters. 

This combined assessment addresses 12 threatened species, 5 endangered species, and 1 candidate 

(Table F-1)1

. These are the only T&E listed species addressed further in this assessment. The listed 

species covered are divided into two sections: those under the jurisdiction of USFWS (Kittlitz’s murrelet), 

and those under the jurisdiction of NMFS (the remaining 17 species). 

 

1 Note that the eastern stock of the Steller sea lion is listed as threatened, and the western stock is listed as 

endangered. As a result, Steller sea lion is included in this count as a threatened species and an endangered 

species.
Appendix F

Biological Assessment F-2 Final EIS

Table F-1 

Threatened and Endangered Species Listed as occurring on or adjacent to the Tongass 

National Forest from USFWS and NMFS. 

Species/Stock ESU/DPS Designation 1/ ESA Status 

Likely Ranging into 

Alaskan Waters? 2/

Under Jurisdiction of FWS 

Birds 

Kittlitz’s murrelet

Brachyramphus brevirostris

N/A Candidate Yes 

Under Jurisdiction of NMFS 

Marine Mammals 

Humpback whale 

(Megaptera novaeangliae)

N/A Endangered Yes 

Steller sea lion 

(Eumetopias jubatus)

N/A Threatened/ 

Endangered 3/ Yes 

Fish 

Sockeye Salmon Snake River Endangered Yes 

(Oncorhynchus nerka) Ozette Lake Threatened No 

Sacramento River Winter-run Endangered No 

Upper Columbia River Spring-run Endangered Yes 

Snake River Spring/Summer-run Threatened Yes 

Snake River Fall-run Threatened Yes 

Puget Sound Threatened Yes 

Lower Columbia River Threatened Yes 

Upper Willamette River Threatened Yes 

Central Valley Spring-run Threatened No 

Chinook Salmon 

(O. tshawytscha) 

California Coastal Threatened No 

Central California Coast Endangered No 

Southern Oregon/Northern California Threatened No 

Coho Salmon 

(O. kisutch) 

Lower Columbia River Threatened No 

Chum Salmon Hood Canal Summer-run Threatened No 

(O. keta) Columbia River Threatened Yes 

Southern California Endangered No 

Central California Coast Endangered No 

South Central California Coast Threatened No 

Snake River Basin Threatened Yes 

Lower Columbia River Threatened Yes 

Upper Columbia River Endangered Yes 

California Central Valley Threatened No 

Upper Willamette River Threatened Yes 

Middle Columbia River Threatened Yes 

Northern California Threatened No4/

Oregon Coast Threatened No4/

Steelhead 

(O. mykiss

Puget Sound Threatened Yes4/

1/ NMFS defines “species” under the ESA to include evolutionarily significant units (ESUs) for salmon and distinct population 

segments (DPSs) for steelhead. 

2/ Distribution from NMFS 2003. 

3/ The eastern stock of the Steller sea lion is listed as threatened, and the western stock is listed as endangered. 

4/ DPS that were listed since 2004. Alaska distribution assumed. 
Appendix F

Final EIS F-3 Biological Assessment

Section 1. Biological Assessment for Kittlitz’s murrelet for the Tongass 

Forest Plan Adjustment 

November 2007 

This section addresses the potential direct and indirect effects of the proposed alternatives on threatened, 

endangered, proposed, or candidate species managed by the USFWS pursuant to Section 7 consultation 

requirements of the ESA. This Biological Assessment updates a previous Biological Assessment for the 

Tongass Plan Revision (dated October 1996). This update includes these changes to the previous 

Biological Assessment: 

♦ The USFWS published a final rule in the Federal Register (USFWS, 1999) delisting the 

Peregrine Falcon from the Threatened species list. This species is listed as Forest Service 

Sensitive. 

♦ The Kittlitz’s murrelet was officially designated a candidate species (warranted, but 

precluded) on May 4, 2004. 

I. Identification of Endangered, Threatened and Candidate Species and/or Critical 

Habitats for Such Species within the Project Area. 

On May 9, 2001, the Secretary of the Interior was petitioned to list the Kittlitz’s murrelet (Brachyramphus 

brevirostris) as endangered with concurrent designation of critical habitat under the ESA. Petitioners 

cited dramatic reductions in population size over the past decade and declining habitat quality as reasons 

for the requested listing. On May 4, 2004, the Kittlitz’s murrelet was designated a candidate species. 

Common Name Scientific Name ESA Status 

Kittlitz’s murrelet Brachyramphus brevirostris Candidate 

II. Overview of Species Distributions, Populations and Habitats. 

The Kittlitz’s murrelet is closely associated with glacial habitats along the Alaska mainland coast. 

Breeding sites are usually chosen in the vicinity of glaciers and cirques in high elevation alpine areas, 

with little or no vegetative cover (Van Vliet 1993). When present, vegetation is primarily composed of 

lichens and mosses (Day et al. 1983). The species nests a short distance below the peak or ridge on 

coastal cliffs, barren ground, rock ledges, and talus above timberline in coastal mountains, generally near 

glaciers 0.2 to 47 miles inland (Day et al. 1983). The remote and solitary nesting habits lead to extreme 

difficulty in finding nests. Non-breeding or off-duty breeders spend the summer in inshore areas, 

especially along glaciated coasts. 

The Kittlitz’s murrelet is one of the rarest seabirds in North America. The only American population 

occurs in Alaskan waters from Point Lay south to northern Southeast Alaska (Endicott and Tracey Arm). 

The largest breeding populations are believed to be in Glacier Bay National Park and Preserve, Prince 

William Sound, Kenai Fjords, and Icy Bay (Kendall and Agler 1998). According to the petition, the 

southern boundary of the breeding range is LeConte Bay on the Tongass National Forest. Latest 

worldwide population estimates range from 9,500 to 26,500 birds. The best information available from 

the USFWS indicates that Prince William Sound populations have declined by 84 percent since 1984, 

Kenai Fjords area by 83 percent since 1976, Malaspina Forelands by 38 percent and perhaps as much 

as 75 percent between 1992 and 2002, and Glacier Bay by 60 percent between 1990 and 1999. 

Speculated causes for decline include oil pollution, glacial recession, gill-net mortality, and availability of 

preferred forage fish (Kuletz et al. 2003, Piatt and Anderson 1996, van Vliet and McAllister 1994). Effects 
Appendix F

Biological Assessment F-4 Final EIS

of these factors include increased adult and juvenile mortality and low recruitment. Human-caused 

mortality includes gillnet fisheries and oil spills like that from the Exxon Valdez or smaller tourism and 

fishing boats. Increased disturbance from helicopter tours and cruise ships may also be a factor. 

III. Assessment of Effects on the Populations or Habitats of the Species In Relation 

to Proposed Actions of the Tongass Forest Plan Adjustment. 

Due to the Kittlitz’s murrelet’s association with glacial habitat, this species occupies areas outside of 

where timber harvest and associated activities have occurred or are likely to occur. Major threats to this 

species are global warming, which is correlated with a loss of suitable habitat (glacial melt) and reduction 

in prey availability due to warming sea temperatures. Human activity in the marine environment, 

particularly vessel traffic and fishing operations, are additional threats to this species. There is no 

indication that any Forest Service management activity is affecting the Kittlitz's murrelet (USDA Forest 

Service 2004). Consequently, implementing any of the alternatives will not directly or indirectly affect the 

Kittlitz’s murrelet. 

Forest-wide standards and guidelines have been developed for protecting seabird rookeries and 

waterfowl concentration areas (Attachment 1). Adverse effects on Kittlitz’s murrelet populations or their 

habitats are not anticipated with any Forest management activities. 

Relationship with other Agencies and Plans 

The USFWS has responsibility for the Kittlitz’s murrelet. Recovery Plans have not been developed for 

this species. No critical habitat has been designated in Southeast Alaska to date. 

Determination for Kittlitz’s Murrelet 

Based upon this analysis, the Adjustment of the Tongass National Forest Land Management Plan will not 

likely jeopardize the continued existence of Kittlitz’s murrelet, or adversely modify proposed critical habitat 

(if it were to be proposed). 

In addition, formal and informal consultation procedures (as directed by the ESA, as amended, and 50 

CFR 17.7, and FSM 2670) are used with the USFWS on all projects within areas that may be used by 

Kittlitz’s murrelet. Forest-wide standards and guidelines for threatened and endangered species 

(Chapter 4 - Wildlife) direct all projects to follow requirements of the ESA and Forest Service Policy (FSM 

2670). 

Documentation of Correspondence with other Agencies 

Consultation with USFWS occurred throughout the 1997 Forest Plan Revision process and was initiated 

by the Forest Service in September 1987 with written letters requesting a list of threatened, endangered, 

proposed, and candidate wildlife species for the Tongass National Forest. At that time, the determination 

was that the American peregrine falcon was the only listed species that could occur on the Tongass and 

the evaluation of effects in the Biological Assessment indicated that populations of peregrine falcons 

would not likely be adversely affected as a result of implementation of the decision. The USFWS 

concurred with this determination in October 1996. The peregrine falcon was delisted in 1999 and, 

therefore, not assessed further in this updated Biological Assessment. 

For the preparation of this update to the Biological Assessment, current species lists were obtained on 

the USFWS website accessed most recently in November 2007. The Kittlitz’s murrelet was officially 

designated a candidate species (warranted, but precluded) on May 4, 2004 and therefore is automatically 

listed as Forest Service Sensitive. In April 2006, the Forest Service hosted an interagency Conservation 

Strategy Review workshop in Ketchikan, Alaska, which brought together scientists, technical experts, and 

land managers with expertise in conservation biology and natural resource management from the 

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

Southwest Research Stations. The workshop provided a forum for the presentation and discussion of 

relevant scientific information gained since 1997 to be used to inform forest planning decisions. This 

information has been incorporated into the Forest Plan Amendment EIS and this biological assessment. 
Appendix F

Final EIS F-5 Biological Assessment

Informal consultation was initiated by the Forest Service with the USFWS through a phone conversation 

on November 21, 2007 (log number 71440-2008-SL-0010) regarding Kittlitz's murrelet. The USFWS 

concurred that formal consultation was not required. 

IV. Literature Cited 

Day, R. H., K. L. Oakley, and D. R. Barnard. 1983. Nest sites and eggs of Kittlitz's and marbled 

murrelets. Condor 85(3):265-273 

Kendall, S. J., and B. A. Agler. 1998. Distribution and abundance of Kittlitz's murrelets in southcentral 

and southeastern Alaska. Colonial Waterbirds 21(1):53-60. 

Kuletz, K. J., S. W. Stephensen, D. B. Irons, E. A. Labunski, and K. M. Brenneman. 2003. Changes in 

Distribution and Abundance of Kittlitz’s Murrelets Brachyramphus brevirostris relative to glacial 

recession in Prince William Sound, Alaska. Marine Ornithology 31:133-140. 

Piatt, J. F., and P. J. Anderson. 1996. Response of Common Murres to the Exxon Valdez Oil Spill and 

Long-term Changes in the Gulf of Alaska Marine Ecosystem. American Fisheries Society Symposium 

18:720-737. 

USDA Forest Service. 2004. Tongass 5-year review final determination paper. Available online at: 

http://www.tongass-5yearreview.net/p/5-year_Review_Final_Determination_Paper.pdf 

U. S. Fish and Wildlife Service (USFWS). 1999. Final Rule to Remove the American Peregrine Falcon 

from the Federal List of Endangered and Threatened Wildlife, and to Remove the Similarity of 

Appearance Provision for Free-flying Peregrines in the Conterminous United States. Federal 

Register/Vol. 64, No. 164/August 25, 1999, pages 46541-46558. 

Van Vliet, G. 1993. Status concerns for the "Global" population of Kittlitz's Murrelet: Is the "Glacier 

Murrelet" receding? Pacific Seabird Group Bulletin 20(1):15-16. 

Van Vliet, G. B., and M. McCallister. 1994. Kittlitz’s Murrelet: the species most impacted by direct 

mortality from the Exxon Valdez oil spill? Pac. Seabirds 21:5-6.
Appendix F

Biological Assessment F-6 Final EIS

Section 2. Biological Assessment for the Endangered Humpback Whale, 

Endangered Western and Threatened Eastern Steller Sea Lion Populations, 

and Listed Pacific Salmon and Steelhead for the Tongass National Forest 

Plan Adjustment 

November 2007 

This section addresses the potential direct and indirect effects of the proposed alternatives on federallylisted species managed by NMFS. This Biological Assessment updates a previous Biological 

Assessment (dated October 1996,) that was prepared for endangered whales and the threatened Steller 

sea lion for the Tongass Forest Plan Revision process. NMFS concurred with the Forest Service finding 

in that Biological Assessment that the proposed revised Tongass Land Management Plan was not likely 

to adversely affect listed species under the jurisdiction of NMFS. This update includes the following 

changes: 

♦ Consideration of the endangered western population of Steller sea lion as likely to occur 

within the coastal waters possibly affected by the proposed action; 

♦ Consideration of 11 additional species of Pacific salmon that were listed since the previous 

update and may occur within the project area. 

I. Identification of Endangered and Threatened Species and/or Critical Habitats for 

Such Species Within the Project Area. 

The following marine mammals and salmon or steelhead stocks under the jurisdiction of NMFS have 

been identified as possibly occurring within the affected project area and are considered in this 

assessment. 

Marine Mammals

Humpback whale—Endangered 

Steller Sea Lion—Threatened: eastern population, Endangered: western population 

Fish

Snake River Sockeye salmon—Endangered 

Snake River Spring/Summer-run Chinook salmon—Threatened 

Snake River Fall-run Chinook salmon—Threatened 

Upper Columbia River Spring-run Chinook salmon—Endangered 

Lower Columbia River Chinook salmon—Threatened 

Upper Willamette River Chinook salmon—Threatened 

Puget Sound-run Chinook salmon—Threatened 

Columbia River Chum salmon—Threatened 

Snake River Basin Steelhead—Threatened 

Lower Columbia River Steelhead—Threatened 

Middle Columbia River Steelhead—Threatened 

Upper Columbia River Steelhead—Endangered 

Upper Willamette River Steelhead—Threatened 

Puget Sound Steelhead—Threatened 

NMFS completed a final recovery plan for the humpback whale in 1991 and for the Steller sea lion in 

1992. 

There has been no critical habitat officially designated for the whales at this time in Southeast Alaska. 
Appendix F

Final EIS F-7 Biological Assessment

Critical habitat was designated for the Steller sea lion by NMFS in 1993 and represents areas considered 

essential for the continued survival and recovery of this species (NMFS 1993). The eastern population of 

Steller sea lion was listed as threatened on November 26, 1990 (55 CFR 40204) and the western 

population was listed as Endangered on May 5, 1997 (62 CFR 30772). Adult Steller sea lions congregate 

at rookeries for breeding and pupping. Rookeries are generally located on relatively remote islands, often 

in exposed areas that are not easily accessed by humans or mammalian predators. These rookeries, as 

well as haul-outs, have been officially designated as critical habitat in Southeast Alaska (NMFS 2001). 

NMFS’ definition of critical habitat for Southeast Alaska includes a “terrestrial zone, aquatic zone, and an 

air zone, that extend 3,000 feet landward, seaward, and above, respectively, for each major rookery and 

major haul-out in Southeast Alaska.” Critical habitat provides notice to federal agencies that a listed 

species is dependent on these areas for its continued existence and that any federal action that may 

affect these areas is subject to the consultation requirements of Section 7 of the ESA. To date, 3 major 

rookeries and 11 major haul-outs have been identified in Southeast Alaska (Table F-2). 

Table F-2 

Major Steller Sea Lion Rookery and Haul-out Habitats in Southeast Alaska 

Name Rookery Haul-out 

Forester Island X 

Hazy Island X 

White Sisters X 

Benjamin Island X 

Biali Rock X X 

Biorka Rock X 

Cape Addington X 

Cape Cross X 

Cape Ommaney X 

Coronation Island X 

Gran Point X 

Lull Point X 

Sunset Island X 

Timbered Island X 

Source: 50 CFR 226.202, pages 183, 200-203 

No ESA-listed stocks of salmon or steelhead originate in Alaskan streams. However many species and 

stocks are listed that originated from freshwater habitats in Washington, Idaho, Oregon and California 

(Table F-1). Some of these listed species migrate into marine waters off the coast of Alaska. While 

distribution of these stocks is primarily in outer coastal waters some are occasionally present in the inner 

waters of Southeast Alaska and they may feed on prey resources originating within marine and estuarine 

waters of the Tongass National Forest. 

II. Overview of Species Distributions and Populations. 

The following summaries for humpback whale, Steller sea lion, and salmonids were abstracted and 

compiled from information found in the Alaska Marine Mammal Stock Assessments, 2006 (Angliss and 

Lodge 2007), Glacier Bay Biological Opinion (NMFS 2003a), published scientific literature, and 

unpublished reports. 

Humpback whales were listed as endangered under the ESA in 1973 due to reduced population size that 

resulted from significant commercial whaling harvest. Currently, no critical habitat has been designated 

for the humpback whale. 

Due to dramatic declines in total population numbers over approximately a 30 year period, the Steller sea 

lion was listed as threatened under the ESA (55 CFR 40204). In 1997, the Steller sea lion population 
Appendix F

Biological Assessment F-8 Final EIS

was split into two separate populations (western and eastern populations) based on demographic and 

genetic differences (Bickham et al. 1996, 62 CFR 307772). 

A total of 28 listed ESU/DPSs of salmon and steelhead occur in the Northeast Pacific (Table F-1). 

Alhough none of the listed stocks originate from Alaskan streams, 14 could potentially be present in 

Alaskan waters during some period of their marine life stage.

Humpback Whale 

Humpback whales (Megaptera novaeangliae) are currently listed as endangered under the ESA, and 

have been protected since 1965. From the late 1800s through the early 1900s, they were extensively 

commercially hunted, and their current worldwide population is estimated to be only 8 percent of their 

historical numbers. Recent population estimates, however, show signs of recovery (Calambokidis et al. 

1997, NMFS 2002a). 

Humpback whales generally migrate between temperate and tropical waters in the winter and spring 

where they mate and calve, and cooler northern coastal waters where they feed. Feeding occurs near 

the highly productive fjords of the Southeastern Alaskan panhandle and Prince William Sound, from 

approximately May through December, although some individuals can be seen every month of the year 

(Calkins 1986). Peak numbers of whales are usually found in nearshore waters during late August and 

September, but substantial numbers usually remain until early winter. Humpbacks summering in 

Southeast Alaska have been linked to three wintering areas: the coastal waters along Baja California and 

mainland Mexico, the main islands of Hawaii, and the islands south of Japan (NMFS 1991). Those 

whales that feed in Southeast Alaska and migrate to Hawaii are referred to as the Central North Pacific 

stock (NMFS 2002a). 

The local distribution of humpbacks in Southeastern Alaska appears to be correlated with the density and 

seasonal availability of prey, particularly herring (Clupea harengus) and euphausiids, and adults consume 

up to 3,000 pounds a day outside the breeding season. Important feeding areas include Glacier Bay and 

adjacent portions of Icy Strait, Stephens Passage/Frederick Sound, Seymour Canal and Sitka Sound. 

Glacier Bay and Icy Strait appear to be an important feeding area early in the season, when whales prey 

heavily on herring and other small, schooling fishes. Frederick Sound is important later in summer, when 

whales feed on swarming euphausiids. During autumn and early winter, humpbacks move out of the 

Sound to areas where herring are abundant, particularly Seymour Canal. Other areas of Southeastern 

Alaska may also be important for humpbacks and need to be evaluated. These include Cape 

Fairweather, Lynn Canal, Sumner Strait, Dixon Entrance, the west coast of Prince of Wales Island, and 

offshore banks such as the Fairweather Grounds. 

The Central North Pacific stock of humpback whales was estimated to number 4,005 in 1993 (+/- 746, 95 

percent confidence interval) (Calambokidis et al. 1997). A 1997 Forest Service estimate of the Southeast 

Alaska humpback whale feeding aggregation was 300 to 500 animals (USDA Forest Service 1997) 

during summer and fall, although a more recent estimate is 961 animals (+/- 226, 95 percent confidence 

interval) (Straley et al. 2002). The population rate of increase was estimated at 7 percent for Pacific 

humpback whales during 1993–2000 (Mobley et al. 2001), which may be near the species maximum. 

They are regularly sighted in the Inside Passage and coastal waters of the Southeastern Alaska 

panhandle from Yakutat Bay south to Queen Charlotte Sound (USDA Forest Service 1997). 

Because the humpback inhabits shallow coastal areas, it is increasingly exposed to human activity. 

Consequently, these whales may be more susceptible to confrontational disturbance, displacement, and 

loss of habitat from environmental degradation than some other whale species. Specifically, the greatest 

threats to humpback whales today are entanglements in fishing gear, ship strikes, and coastal habitat 

pollution. 

Steller Sea Lion 

The Steller (northern) sea lion (Eumetopias jubata) ranges from Hokkaido, Japan, through the Kuril 

Islands and Okhotsk Sea, Aleutian Islands and central Bering Sea, Gulf of Alaska, Southeast Alaska, and 

south to central California (Calkins 1986, National Marine Mammal Laboratory [NMML] 2003). The 

centers of abundance and distribution are the Gulf of Alaska and Aleutian Islands, respectively. 
Appendix F

Final EIS F-9 Biological Assessment

The Steller sea lion was originally listed under the ESA in 1990 as threatened. At that time, Steller sea 

lion numbers were declining sharply throughout their range and particularly in Alaska. Populations are 

estimated to have declined between the 1950s and 1990 by 78 percent (NMFS 1992). In certain parts of 

Alaska, declines of greater than 80 percent have occurred since 1985. The number of sea lions 

observed on certain rookeries from Kenai Peninsula to Kiska Island declined by 63 percent since 1985 

and by 82 percent since 1960. Critical habitat for Steller sea lions was designated in 1993 (NMFS 1993). 

Specific causes of the population decline are unknown, although population modeling has suggested that 

decreased juvenile survival is a likely driver. The declines are spreading to previously stable areas and 

are accelerating. Significant declines have also occurred on the Kuril Islands. 

In 1997, NMFS classified the Steller sea lion as two distinct population segments, the eastern stock (ES) 

and western stock (WS), and re-evaluated their status. The stock differentiation is based primarily on 

differences in mitochondrial DNA, but also on population trends in the two regions. Steller sea lions 

occurring west of 144°W longitude were reclassified as endangered. The eastern Pacific population, still 

listed as threatened, includes Southeast Alaska and the Tongass National Forest. ES populations are 

increasing in the northern part of the range (Southeast Alaska and British Columbia) and declining in the 

southern end of its range (Oregon, Washington, and California). In this region, habitat concerns include 

reduced prey availability, contaminants, and disease (Sydeman and Allen 1997). Both WS and ES 

stocks are designated as “depleted” and “strategic” under the Marine Mammal Protection Act (MMPA). 

Although ES stock size has increased in recent years, its status relative to its optimum sustainable 

population size is still unknown. 

There is some limited interchange between the WS and ES populations. Raum-Suryan et al. (2002, 

2004) branded 8,596 sea lion pups from 1975 to 2001, and found that a few juveniles from the WS 

moved to the ES region. Resightings of branded Steller sea lions showed wide dispersal from natal 

rookeries, particularly among juveniles, which occasionally traveled over 1,500 km to other rookeries and 

haul-outs and crossing stock boundaries. However, individuals consistently returned to breed, and no 

adult Steller sea lions were observed breeding with the opposite stock (Raum-Suryan et al. 2002). A 

more recent study used satellite transmitters to track distribution and movement patterns of pup and 

juvenile Steller sea lions from both stocks. Overall, movement of individuals between the WS and ES 

populations were documented only in very low numbers, and only among males (Raum-Suryan et al. 

2004). Although some WS individuals have been observed foraging in Southeast Alaska, the WS Steller 

sea lion population will not be discussed in greater detail in this assessment because of the extremely low 

number of sightings and because the existing Standard and Guidelines are not specific to the ES Steller 

sea lion stock and would therefore protect both populations. 

The total estimated population of the ES Steller sea lions is 48,519 or 54,989 in 2002–2005, depending 

on which assumptions are used to calculate the pup multiplier (see Calkins and Pitcher 1982, Trites and 

Larkin 1996). The number of ES pups produced has nearly doubled since 1978, with an annual rate of 

increase of 5.9 percent from 1979 to 1998, although the rate of increase between 1989 and 1997 was 

only 1.7 percent (Calkins et al. 1999). Sease and Gudmundson (2002) estimated a 1.8 percent annual 

increase in non-pup sea lions between 1991 and 2002. In the Southeast Alaska portion of the ES, nonpup counts on trend sites have increased 29.3 percent since 1990 (Sease et al. 2001). The estimated 

abundance of the ES population of Steller sea lions throughout its range is 31,028 animals (NMFS 

2002b). Calkins et al. (1999) suggested that there are probably more sea lions at present than at any 

time in recorded history. The minimum population estimate for Steller sea lions in Southeast Alaska in 

2005 was 20,793 (15,283 non-pups, 5,510 pups). Current population trends in Southeast Alaska are 

moving up, with non-pups at trend sites increasing 56 percent from 1979 to 2002, and pups increasing 

148 percent (Merrick et al. 1992, Sease et al. 2001, NMFS 2006). 

Steller sea lions are opportunistic predators, feeding primarily on a wide variety of fishes and 

cephalopods. Prey varies geographically and seasonally. Some of the more important prey species in 

Alaska are walleye pollock (Theragra chalcogramma), Atka mackerel (Pleurogrammus monopteryguis), 

Pacific herring (Clupea harengus), capelin (Mallotus villosus), Pacific sand lance (Ammodytes 

hexapterus), Pacific cod (Gadus macrocephalus), salmon (Oncorhynchus spp.), and, locally, eulachon 

(Thaleichthys pacificus). 
Appendix F

Biological Assessment F-10 Final EIS

Listed Salmon and Steelhead 

Although none of the listed stocks originate from Alaskan streams, 14 of the 28 listed ESU/DPSs of 

salmon and steelhead could potentially be present in Alaskan waters during some period of their marine 

life stage (Table F-1). All of these originate from the Columbia River system or Puget Sound. Juveniles 

from these ESUs/DPSs move varying distances north from Washington after leaving their natal streams 

to rear in the rich north Pacific waters before returning to their home streams as adults (Groot and 

Margolis 1991, McNeil and Himsworth 1980). They may feed on prey resources originating from marine 

and estuarine waters of the Tongass National Forest, and could occasionally be present in inner waters 

of Southeast Alaska. Overall, listed stocks make up a small portion of total salmon and steelhead in 

waters off the coast of Alaska (NMFS 2003b). Snake River sockeye do not occur within the marine 

waters bounded by the Tongass National Forest in the Inside Passage, but may occur in adjacent waters 

near the western boundaries of the Forest. British Columbia and Washington sockeye stocks normally 

occur south of the Southeast Alaska sockeye stocks below the latitude of 46°N (Burgner 1991). 

Any of the six listed chinook ESUs could potentially be present in marine Alaskan waters, off the outside 

coast to the west of the Tongass National Forest, and some may rarely be present in the marine waters 

of the Tongass National Forest. Columbia River chum and all ESUs of steelhead are likely present in 

Southeast Alaska waters only rarely (Salo 1991, NMFS 2003b). Southerly stocks of chum tend to move 

offshore early in their northern migration (Salo 1991). Chinook and steelhead may use nearshore marine 

and estuarine resources, such as prey fish, which are dependent on the Tongass National Forest. 

III. Assessment of Effects on the Populations or Habitats of the Species in Relation 

to Proposed Actions of the Tongass Forest Plan Adjustment. 

Humpback Whale 

The NMFS recovery plan for the humpback whale identified six known or potential categories of human 

impacts to these species: hunting, entrapment and entanglement in fishing gear, collisions with ships, 

acoustic disturbance, habitat degradation, and competition for resources with humans. The majority (74 

percent) of human-related mortalities and injuries to humpback whales investigated involved commercial 

fishing gear, and 38 percent of these were serious injuries or mortalities. These data were gathered from 

reports submitted to NMFS, Alaska Region, 2001–2005 (NMFS 2007). The estimated minimum mortality 

and serious injury rate incidental to U.S. commercial fisheries in Southeast Alaska is 1.4 humpback 

whales per year (NMFS 2007). Mortality and serious injury caused by ship strikes in Southeast Alaska 

occurred 1.4 times/year between 2001 and 2005. 

National Forest management activities which may have an effect on whale habitats or populations 

generally fall into the categories of acoustic disturbance and habitat degradation. These management 

activities include: the development and use of log transfer facilities (LTF's) and their associated camps, 

the movement of log rafts from log transfer facilities to mills, and the potential development of other docks 

and associated facilities for mining, recreation, and other forest uses and activities. Generally, with the 

development and use of LTF's and other docking facilities for projects, there is an associated increase in 

recreational boating in the immediate vicinity during the construction and use of the facilities. Risks from 

hunting, entrapment and entanglement in fishing gear, ship strikes, and competition for resources with 

humans associated with LTF’s are generally negligible. This is due to the slow speed of watercraft 

associated with the log transfer activity, and the lack of association between LTF’s and the other risks. 

Construction and operation of LTF's and other docking facilities are restricted to small, very localized 

areas of the marine environment. There are 116 LTF's currently on the Tongass National Forest and 

there is an estimated 232 acres of marine benthic disturbance associated with these existing LTF's (2 

acres per LTF). However, not all LTF's are active at the same time and, in recent years, the number that 

are active is a small minority of the total existing. Based on the 2007 logging system and transportation 

analysis and modeling conducted for the 2008 Final EIS, it is estimated that a maximum of 115 new LTFs 

would be needed under the highest harvest alternative (Alternative 7), resulting in an estimated maximum 

of 230 additional acres of benthic habitat disturbance. The 2 acres of disturbance per LTF figure, 

assumes that logs would be placed into the water and rafted, rather than loaded onto barges as is 
Appendix F

Final EIS F-11 Biological Assessment

currently required on many sales. Therefore, it is likely that future effects at each LTF would be even less 

than in the past. 

Generally there is no reasonable potential to directly affect whales with these facilities. During the 

summer of 1989, there was a report of a humpback whale entangled in some cables from an inactive LTF 

site on the Stikine Area. To our knowledge, this is the only direct effect incident related to LTF's. 

Two potential indirect effects of LTF's and other docking facilities and associated activities have been 

identified: 1) effects on whale prey species, and 2) disturbances of whales by boat traffic associated with 

LTF's. 

Effects on Prey. Nemoto (1970) noted that euphausiids and gregarious fish are the primary prey of 

humpbacks. Thirteen species of fish and 57 species of invertebrates were identified as humpback whale 

prey in Southeast Alaska. Humpbacks studied in Glacier Bay and Stephens Passage-Frederick Sound 

were found most frequently in areas of high prey density (Wing and Krieger 1983). 

Construction and operation of all LTF's and similar facilities require U.S. Army Corps of Engineers and 

U.S. Environmental Protection Agency permits, and State of Alaska Tidelands permits. The permitting 

process provides that construction and operation maintain water quality in the specific facility locations, 

and that marine circulation and flushing are maintained. All facilities must be in conformance with permit 

standards. No impacts to the marine environment which would affect whale prey species are anticipated. 

Effects from Disturbance. Humpback whale response to nearby boating activity varies from no 

apparent response to pod dispersal, sounding, breaching, evasive underwater maneuvers, and 

maintaining distance (Baker and Herman 1983, Baker et. al. 1982). Disturbance by boat activity has 

been suggested as one of the possible causes of observed changes in whale distribution in Southeast 

Alaska. Direct pursuit of whales by boats, and frequent changes in boat speed and direction appear to 

elicit avoidance behaviors more frequently than other types of boat traffic. However, whales may readily 

habituate to constant and familiar noise (Norris and Reeves 1978). Whales can be commonly found in 

some areas of Southeast Alaska which have considerable boat traffic; however, whether they are 

habituated to boat traffic has not been documented, as far as we know. Adverse effects from current 

levels of boat traffic have not been documented, as far as we know. 

Two basic types of boat activity would be associated with LTF's: log raft towing and recreational boating 

by workers. Log raft towing frequency would vary between camps, seasons, and years; a general 

average may be about once a week during the working season (U.S. Forest Service, 1989-94 Operating 

Period for the Ketchikan Pulp Company Long-term Sale Area). Tugs would maintain relatively constant 

speeds and directions during raft towing. Constant speed and direction elicit less avoidance behavior 

from whales than other types of boating activity. Log raft towing routes are generally well established, 

and adverse effects from log raft towing have not been documented. 

Recreational boating activity would vary between seasons, years, and camps of different sizes. This 

activity would be concentrated near LTF sites, other docking facilities and camps. It is estimated that 

most recreational boating would occur within a few miles of the site, few trips would be made over 10 

miles, and activity greater than 30 miles from a site would be negligible. This boating would involve 

frequent changes in speed and direction and may include some small amount of whale pursuit, if the 

whales are within sight of the camp or an occupied boat. The effect of such recreational activity on 

whales would depend on many factors such as size of the bay, depth of the waters in the bay, number of 

boats, individual behavior responses of the whales, etc. At the present time, there is not a quantifiable 

way to estimate these possible effects. 

Attachment 2 outlines forest-wide standards and guidelines that have been developed for application on 

all Forest Service permitted or approved activities to minimize or eliminate any adverse impacts on 

humpback whales. 

The amount of human activity in the marine environment associated with Forest management activities is 

only a fraction of the total amount of human activity occurring in the marine environment. Some of the 

other activities include: commercial fishing, sport fishing, hunting, subsistence, tourism, and mariculture. 
Appendix F

Biological Assessment F-12 Final EIS

Many of these activities are not regulated by the Forest Service. NMFS is currently proposing regulations 

for how close humans can approach whales. The purpose of these regulations is to reduce disturbance 

to whales from activities such as whale pursuing. Such regulations would reduce the indirect disturbance 

effects discussed above. 

Steller Sea Lion 

NMFS provides a summary of factors affecting the Steller sea lion populations, including:.reductions in 

the availability of food resources - especially pollock which is the most important prey species for sea 

lions; commercial harvests of sea lion pups; subsistence harvests of sea lions; harvests for public display 

and scientific research purposes; predation by sharks, killer whales and brown bear; disease; the 

inadequacy of existing regulatory mechanisms re quotas on the incidental harvesting of sea lions during 

commercial fishing operations; and other natural or manmade factors such as incidences of fishermen 

shooting adult sea lions at rookeries, haul out sites, and in the water near boats (NMFS 1990, 1993). 

None of these factors are regulated or fall within the jurisdiction of the Forest Service. 

A primary human-caused injury and mortality factor is incidental take during commercial fisheries, though 

mortality by this cause is low (0.8 mortality rate for 2001–2003, or about 1/year for Pacific whiting 

component groundfish trawl) (NMFS 2007). Subsistence harvest is likewise low (mean annual take 

2001–2005: 9), though it is aimed at both the ES and WS stocks of Steller sea lions (NMFS 2007). Illegal 

shooting, entanglement in non-fishery-related manmade material, and research activities also account for 

an additional small amount of annual mortality. The sum of these manmade mortality factors does not 

exceed annual potential biological removal as defined by NMFS for the ES Steller sea lions, and these 

can therefore be considered insignificant. 

Southeast Alaska populations have not declined to the extent that other populations have. Harassment 

or displacement of sea lions from preferred habitats by human activities such as boating, recreation, 

aircraft, LTF’s, log raft towing, etc., is a concern with regard to long term conservation of the sea lion in 

Southeast Alaska. Forest-wide standards and guidelines direct the Forest Service to prevent and/or 

reduce potential harassment of sea lions and other marine mammals due to activities carried out by or 

under the jurisdiction of the Forest Service. These Forest-wide standards and guidelines are listed in 

Attachment 2. 

Salmon 

The USDA Forest Service has no authority over the direct taking of salmon. This responsibility rests with 

the State of Alaska, Board of Fisheries, and ADF&G. As a land management agency, the Forest Service 

may indirectly influence the take of fish, both on and adjacent to the National Forest. Indirect take may 

occur as a result of modification of habitat or improving the opportunity to harvest salmon. Examples of 

the latter include the development of roads, boat launches, saltwater anchorages, or cabins; and special 

use permits for lodges, guides and outfitters. The following analysis considers the potential opportunity 

for indirect taking of the listed Snake River Sockeye, six Chinook salmon ESUs, Columbia River Chum 

salmon, and five steelhead DPSs believed to potentially occur in Alaskan waters (Table F-1). 

Snake River Sockeye. Due to both the lack of suitable sockeye habitat in the Tongass National Forest, 

little or no use of prey resources potentially affected in the nearshore environment, and the lack of 

availability to sport and subsistence fisheries accessed through the Forest, amendment of the Tongass 

National Forest Land Management will not likely adversely affect the Snake River sockeye salmon. 

The management of the Tongass National Forest has no direct or indirect effect on the take of the Snake 

River sockeye salmon. There is only a very limited relationship between the life history of these salmon 

and management of terrestrial habitats of the Tongass. 

Snake River Chinook (All Stocks). Among the listed fish species evaluated, the six Chinook salmon 

ESUs are generally most likely to be found in inner waters of Southeast Alaska. Because chinook 

salmon are piscivores they may feed on fish which are dependent on the waters of Tongass National 

Forest during some stage of their lives, or these prey species may be affected by management actions. 

Additionally, chinook salmon are harvested in the sport and subsistence fisheries which may utilize the 

Tongass for saltwater access. Aquatic habitat protection measures have been designed to provide a 
Appendix F

Final EIS F-13 Biological Assessment

natural range of habitat conditions in the waters of the Tongass National Forest (Riparian Forest-wide 

Standards and Guidelines) and have been developed to reduce or eliminate the likelihood of contribution 

to the degradation of freshwater habitats. Chinook prey species, such as members of the Pacific smelt 

family, Pacific herring, and other Pacific salmon, are not anticipated to be negatively impacted by the 

Tongass Forest Plan Adjustment. 

The Tongass Forest Plan does not schedule any developments which measurably increase the access or 

opportunity to harvest Snake River chinook salmon by sport or subsistence fisheries. Additionally, it is 

likely that such projects that could be developed in the future, such as roads; boat launches; saltwater 

anchorages, cabins, special use permits for lodges, guides and outfitters,and logging camp development 

for the purpose of timber harvest, would have no measurable effect on the listed chinook salmon. 

Columbia River Chum Salmon. Like sockeye, the effects of Tongass National Forest actions on land or 

in nearshore environments are not likely to affect this stock because of their rare presence in the inner 

marine waters of this region and small magnitude of any affects to the marine environment from any 

future actions. 

Steelhead (All five DPSs). The nearshore resources utilized by steelhead could be affected in small 

regions. Again because of low probability of any of these fish being present in the inner waters, and the 

low chance of any adverse effects to prey resources, changes to the Tongass Forest Plan are unlikely to 

cause adverse effects to any of the listed steelhead DPSs. Additionally, as noted above, none of the 

considered actions result in any ground or nearshore marine water disturbance so the considered action 

will have no direct effect on these steelhead DPSs. Specific ground disturbing actions, considered in this 

respect, would be addressed in through agency consultation, as needed, during project specific actions. 

Determination for Marine Mammals and Listed Pacific Salmon/Steelhead 

Based on the analysis above, which takes into account current protection measures required by the 

Marine Mammal Protection Act (MMPA), ESA, and implementation of the Forest-Wide Standards and 

Guidelines (Attachments 2 and 3), the National Forest management activities will not likely adversely 

affect the humpback whale, Steller sea lion, or of the any of the ESUs or DPSs of salmonids or their 

habitats addressed above and listed in Table F-1. 

Since the currently evaluated actions do not permit any ground disturbing activity none of the considered 

actions will have any direct adverse effects to any of the listed species addressed in this section. Any 

proposed actions indirectly resulting from the considered alternatives will be evaluated on case specific 

bases as to their affect to listed species and may include formal or informal consultation with NMFS at the 

time of project evaluation. 

In addition, formal and informal consultation procedures (as directed by the ESA, as amended in 50 CFR 

17.7, and FSM 2670) are used with the NMFS on all site specific projects that implement the Forest Plan. 

Forest-wide standards and guidelines for threatened and endangered species (Attachments 2 and 3) also 

direct that all projects will comply with requirements of the ESA and Forest Service Policy (FSM 2670). 

Documentation of Correspondence with Other Agencies 

Consultation with NMFS occurred throughout the 1997 Forest Plan Revision process and was initiated by 

the Forest Service in September 1987 with written letters requesting a list of threatened and endangered 

marine mammal and anadromous fish species for the Tongass National Forest. The evaluation of effects 

in the Biological Assessment indicated that populations of species under the jurisdiction of NFMS would 

not likely be adversely affected as a result of implementation of the decision. NMFS concurred with this 

determination in November 1996. They concluded Section 7 consultation by stating that consultation 

should be reinitiated if project plans change or new information becomes available that would change the 

basis of this determination, 

Concurrence findings from the 1997 Forest Plan Revision are still valid for this amendment. Extensive 

consultation occurred throughout past revision processes of the Forest Plan; the proposed new Forest 

Plan is an amendment; and the above analysis and determination is consistent with the approach and 

findings of the 1996 Biological Assessment. The Forest Service will continue to adhere to the Forestwide Standards and Guidelines for Threatened, Endangered, and Sensitive species, which was the basis 
Appendix F

Biological Assessment F-14 Final EIS

for concurrence in the November 21, 1996 letter. Consultation will occur when site specific activities are 

proposed that may affect a listed species. 

IV. Literature Cited 

Baker, C. S., L. M. Herman, B. G. Gays, and W. F. Stipel. 1982. The Impact of Vessel Traffic on the 

Behavior of Humpback Whales in Southeast Alaska. Kewalo Basin Marine Mammal Laboratory. 

Univ. of Hawaii, Honolulu, Hawaii. 

Baker, C. S. and L. Herman. 1983. The Impact of Vessel Traffic on the Behavior of Humpback Whales 

in Southeast Alaska. Kewalo Basin Marine Mammal Laboratory. Univ. of Hawaii, Honolulu, Hawaii. 

Burgner, R. L. 1991. Life history of sockeye salmon (Oncorhynchus nerka). Pp 1-118 In: Pacific salmon 

life histories. Groot, C. and L. Margolis (eds.). University of British Columbia Press, Vancouver, BC. 

Calkins, D. G. 1986. Marine Mammals. In: D.W. Hood and S.T. Zimmerman (eds.), pp. 527-560. The 

Gulf of Alaska Physical Environment and Biological Resources. Mineral Management Service 

Publication number OCS Study: MMS 86-0095, U.S. Government Printing Office, Washington, DC. 

Calkins, D. G., and K. W. Pitcher. 1982. Population assessment, ecology and trophic relationships of 

Steller sea lions in the Gulf of Alaska. Environmental Assessment of the Alaskan Continental Shelf. 

Final reports 19:455–546. 

Calkins, D. G., D. C. McAllister, G. W. Pendleton, and K. W. Pitcher. 1999. Steller sea lion status and 

trend in Southeast Alaska. Marine Mammal Science 15:462-467. 

Groot, C. and L. Margolis (eds.). 1991. Pacific salmon life histories. University of British Columbia 

Press, Vancouver, BC. 564 pages. 

Marston, B. H., M. F. Willson, and S. M. Gende. 2002. Predator aggregations during eulachon 

(Thaleichthys pacificus) spawning runs. Alaska Department of Fish and Game, Wildlife Conservation. 

Juneau, Alaska. 8 pp. 

McNeil, W.J., and D. C. Himsworth (eds). 1980. Salmonid ecosystems of the north Pacific. Oregon 

State University Press, Eugene, Oregon. 331 pages. 

Merrick, R. L., D. G. Calkins, and D. C. McAllister. 1992. Aerial and ship-based surveys of Steller sea 

lions in Southeast Alaska, the Gulf of Alaska, and Aleutian Islands during June and July 1991. U.S. 

Department of Commerce, NOAA Technical Memorandum NMFS-AFSC-1. 37 pp. 

Mobley, J. M., S. Spitz, R. Grotefendt, P. Forestell, A. Frankel, and G. Bauer. 2001. Abundance of 

humpback whales in Hawaiian waters: results of 1993–2000 aerial surveys. Report to the Hawaiian 

Islands Humpback Whale National Marine Sanctuary. 16 pp. 

National Marine Fisheries Service (NMFS). 1990. Listing of Steller Sea Lions as Threatened Under the 

Endangered Species Act. Proposed Rule. Department of Commerce, National Oceanic and 

Atmospheric Administration. Federal Register 55:29792-29824. 

National Marine Fisheries Service (NMFS). 1991. Recovery Plan for the Humpback Whale (Megaptera 

novaeangliae). Prepared by the Humpback Whale Recovery Team for the National Marine Fisheries 

Service, Silver Spring, Maryland. 105pp. 

National Marine Fisheries Service (NMFS). 1992. Recovery Plan for the Steller Sea Lion (Eumetopias 

jubatus). Prepared by the Steller Sea Lion Recovery Team for the National Marine Fisheries Service, 

Silver Spring, Maryland. 92 pp. 
Appendix F

Final EIS F-15 Biological Assessment

National Marine Fisheries Service (NMFS). 1993. Final rule, Designated critical habitat; Steller Sea Lion. 

Department of Commerce, National Oceanic and Atmospheric Administration. Federal Register, 

August 27, 1993. 58:45269-45285. 

National Marine Fisheries Service (NMFS). 1995. Proposed rule, threatened fish and wildlife, change in 

listing status of Steller sea lions under the Endangered Species Act. Department of Commerce, 

National Oceanic and Atmospheric Administration. Federal Register October 4. 60: 51968-51978. 

National Marine Fisheries Service (NMFS). 2001. 50 CFR. Part 226.202 Designating critical habitat for 

Steller sea lions. Steller sea lion (Eumetopias jubatus). Available Online: 

http://www.fakr.noaa.gov/protectedresources/stellers/habitat.htm. 

National Marine Fisheries Service (NMFS). 2002a. Stock Assessment Reports (SARS) by 

Species/Stock for the humpback whale. Report 2002, revised October 30, 2001. Available online: 

http://www.nmfs.noaa.gov/prot_res/ PR2/Stock_Assessment_Program/individual_sars.html. 

National Marine Fisheries Service (NMFS). 2002b. Stock Assessment Reports (SARS) by 

Species/Stock for the Steller sea lion. Report 2002, revised September 29, 2001. Available online: 

http://www.nmfs.noaa.gov/prot_res/PR2/Stock_Assessment_Program/individual_sars.html. 

National Marine Fisheries Service (NMFS). 2003a. Draft Marine Mammal Stock Assessment Reports 

(SARS) by Species/Stock. Draft Reports 2003, revised June 2003. R. P. Angliss and K. L. Lodge, 

editors. National Marine Mammal Laboratory, Alaska Fisheries Science Center, Seattle, WA. 

Available online: http://www.nmfs.noaa.gov/pr/readingrm/draft_2003_sars/AK_draft_SARs_2003.pdf. 

National Marine Fisheries Service (NMFS). 2003b. Final programmatic environmental impact statement 

for Pacific salmon fisheries management off the coasts of Southeast Alaska, Washington, and 

California and in the Columbia River Basin. National Marine Fisheries Service, Northwest Region, 

and Alaska Department of fish and Game. http://www.nwr.noaa.gov/Salmon-HarvestHatcheries/Salmon-Fishery-Management/upload/slmn-hrvst-FPEIS.pdf 

National Marine Fisheries Service (NMFS). 2004. Programmatic environmental impact statement for the 

Alaska groundfish fishery management plans for the groundfish fishery of the gulf of Alaska and the 

ground fish of the Bering Sea and Aleutian Islands area. USCD NOAA, NMFS, Alaska Region, 

Juneau, Alaska and Seattle, Washington. 

http://www.fakr.noaa.gov/sustainablefisheries/seis/final062004/COVER.pdf 

National Marine Fisheries Service (NMFS). 2006. Draft revised recovery plan for the Steller sea lion 

(Eumetopias jubatus). National Marine Fisheries Service, Silver Spring, MD. 285 pp. 

National Marine Fisheries Service (NMFS). 2007. Draft Marine Mammal Stock Assessment Reports 

(SARS) by Species/Stock. Draft Reports 2006, revised March 2007. R. P. Angliss and R.B. Outlaw, 

editors. National Marine Mammal Laboratory, Alaska Fisheries Science Center, Seattle, WA. 

Available online: http://www.nmfs.noaa.gov/pr/pdfs/sars/ak2007_draft.pdf 

National Marine Mammal Laboratory (NMML). 2003. Steller sea lion research. [online] 

http://nmml.afsc.noaa.gov. 

Nemoto, T. 1970. Feeding Patterns of Baleen Whales in the Ocean. Pp. 241-381 in J. H. Steele (ed), 

Marine Food Chains. Oliver and Boyd, Edinburgh. 

Norris, K. S., and R. R. Reeves (ed). 1978. Report on a Workshop On Problems Related to Humpback 

Whales (Megaptera novaeangliae) in Hawaii, U. S. Marine Mammal Commission. Washington, D. C. 

Report No. MMC-77/03 (available from National Technical Information Service PB-280794). 
Appendix F

Biological Assessment F-16 Final EIS

Raum-Suryan, K. L., K. Pitcher, D. Calkins, and J. Sease. 2002. Dispersal, rookery fidelity, and 

metapopulation structure of Steller sea lions (Eumetopias jubatus) in an increasing and a decreasing 

population in Alaska. Marine Mammal Science, 18(30): 746-764. 

Raum-Suryan, K. L., M. J. Rehberg, G. W. Pendleton, K. Pitcher, and T. S. Gelatt. 2004. Development of 

dispersal, movement patterns, and haul-out use by pup and juvenile Steller sea lions (Eumetopias 

jubatus) in Alaska. Marine Mammal Science, 20, No. 4: 823-850. 

Salo, E.O. 1991. Life history of chum salmon (Oncorhynchus keta). Pp 233-309. In: Pacific salmon life 

histories, Groot, C. and L. Margolis (eds.). University of British Columbia Press, Vancouver, BC. 

Sease, J. L., and C. J. Gudmundson. 2002. Aerial and land-based surveys of Steller sea lions 

(Eumetopias jubatus) from the western stock in Alaska, June and July 2001 and 2002. U.S. Dep. 

Commerce, NOAA Technical Memorandum NMFS-AFSC-131. 45 pp. 

Sease, J. L., W. P. Taylor, T. R. Loughlin, and K. W. Pitcher. 2001. Aerial and land-based surveys of 

Steller sea lions (Eumetopias jubatus) in Alaska, June and July 1999 and 2000. NOAA Technical 

Memorandum NMFS-AFSC-122. 52 p. 

Sigler, M. F., J. J. Vollenweider, and J. N. Womble. 2003. Availability to Steller sea lions (Eumetopias 

jubatus) of a seasonal prey resource: a pre-spawning aggregation of eulachon (Thaleichtyys 

pacificus). NMFS, Alaska Fisheries Science Center, Auke Bay Laboratory. Final Report J17515. 36 

pp. 

Straley, J. M., T. J. Quinn II, and C. Gabriele. 2002. Estimate of the abundance of humpback whales in 

Southeastern Alaska 1994–2000. Unpublished final report submitted to NMFS. 19 pp. 

Sydeman, W. J., and S. G. Allen. 1997. Trends and oceanographic correlates of pinniped populations in 

the Gulf of the Farallones, California. U.S. Dep. Commer., Southwest Fish. Sci. Cent., Admin. Rep. LJ97-02C, 28 pp. 

Trites, A. W., and P. A. Larkin. 1996. Changes in the abundance of Steller sea lions (Eumetopias 

jubatus) in Alaska from 1956 to 1992: how many were there? Aquatic Mammals 22:153–166. 

USDA Forest Service. Forest Service Manual (FSM) Chapter 2670, Threatened, Endangered, and 

Sensitive Plants and Animals. 

USDA Forest Service. 1982. National Forest System Land and Resource Management Planning. 

Federal Register 47:43026-43052. 

USDA Forest Service. 1989. 1989-1994 Operating Period for the Ketchikan Pulp Company Long-term 

Sale Area - Final Environmental Impact Statement, Volume 6. Tongass National Forest, R10-MB-66f. 

USDA Forest Service. 1997. Tongass Land Management Plan Revision, Final Environmental Impact 

Statement. USDA Forest Service, Tongass National Forest, R10-MB-338dd (Record of Decision, 

Final Environmental Impact Statement—Part 1 and Part 2, Map Packet, Appendix—Volume 1, Volume 

2, Volume 3, Volume 4, and Errata). Alaska Region, Juneau, Alaska. 

Wing, B. L. and K. Krieger. 1983. Humpback Whale Prey Studies in Southeastern Alaska, Summer 

1982. Northwest and Alaska Fisheries Center, Auke Bay Laboratory. National Marine Fisheries 

Service, NOAA. Auke Bay, Alaska. 
Appendix F

Final EIS F-17 Biological Assessment

Attachment 1 

Forest-wide standards and guidelines in the Tongass Land Management Plan for the conservation of 

threatened, endangered, and proposed species (portions excerpted relevant to the Kittlitz’s murrelet). 

Wildlife Habitat Planning: WILD1 

I. Coordination/cooperation with other Agencies, Institutions and Partners 

A. Coordinate with the Alaska Department of Fish and Game, other state agencies, NMFS, the 

U.S. Fish and Wildlife Service, tribal governments, and other cooperators and partners during 

the planning of activities that may affect wildlife. 

1. The Forest should meet at least annually with state and Federal wildlife agencies to review 

resource activities, present progress reports on implementation of past cooperative work or 

agreements, and schedule cooperative work. 

2. Seek to maintain memoranda of understanding with appropriate state, Federal, and local 

agencies and associations. 

B. Emphasize management for indigenous wildlife species and natural habitat except in cases 

where the Forest Service, in cooperation with the Alaska Department of Fish and Game and 

U.S. Fish and Wildlife Service, find desirable alternatives. Special consideration should be 

given to the possible adverse impacts on habitat of sensitive, threatened, and endangered 

species. 

C. Coordinate wildlife habitat surveys, studies, plans and improvement projects with the Alaska 

Department of Fish and Game, U.S. Fish and Wildlife Service, NMFS, and other appropriate 

state, Federal, tribal, local and private agencies. Use the Sikes Act authorities for cooperative 

work with the state. Use agreements and other partnerships to cooperate with other partners. 

D. Coordinate with the Alaska Department of Fish and Game in development of state strategic 

plans and population goals and objectives for wildlife species and attempt to incorporate wildlife 

goals and objectives into forest management. 

E. Provide habitat information to the Alaska Department of Fish and Game to assist in correlating 

hunting seasons, permits, and bag limits to on-the-ground habitat conditions so that population 

and habitat objectives can be achieved. 

II. General Habitat Planning/Coordination 

A. Recognize as wildlife habitat, areas of land and water which can contribute to achieving wildlife 

objectives for consumptive and non-consumptive uses. 

B. Provide the abundance and distribution of habitat necessary to maintain viable populations of 

existing native and desirable introduced species well-distributed in the planning area, i.e., the 

Tongass National Forest. (Consult 36 CFR 219.19 and 36 CFR 219.27.) 

C. Cooperate with the State and, as appropriate, the U.S. Fish and Wildlife Service in managing 

vehicle, boat, and other human use (e.g. hunting and fishing seasons and bag limits) as 

necessary to achieve wildlife objectives, recognizing the access provisions of ANILCA. 

Emphasize management to reduce human disturbance in high value habitat areas and during 

critical periods of wildlife use. 

D. Maintain a Forest program schedule which includes anticipated wildlife habitat and population 

inventory needs, monitoring requirements and proposed habitat improvement and maintenance 

projects. 

E. Use forest plan management indicator species to evaluate the potential effects of proposed 

management activities affecting wildlife habitat (Consult Forest Service Manual 2620). 

F. Develop interagency habitat capability models for any or all of the management indicators to 

systematically assess the impacts of proposed projects during project level analysis. 

Periodically review and update models to reflect the most current habitat relationships and 

habitat modeling technology. 

G. Cooperate with the Alaska Department of Fish and Game to seek to prevent existing 

populations of invasive species from dispersing into Wilderness areas. Address issues 

regarding management, introduction, and re-introduction of wildlife species consistent with 

National and Regional Policy. 

H. When population or habitat declines for a plant or animal species or subspecies indicates that 

long-term persistence is at risk, evaluate the particular species for designation as a Regional 
Appendix F

Biological Assessment F-18 Final EIS

Sensitive Species by the Regional Forester. (Consult FSM 2670 and R10 supplemental 

directions for Threatened, Endangered, and Sensitive Species.) 

III. Seabird Rookeries 

A. Provide for the protection and maintenance of seabird (marine bird) rookeries. 

1. Locate facilities and concentrated human activities requiring Forest Service approval as far 

from known seabird colonies as feasible consistent with the Migratory Bird Treaty Act. The 

following distances are provided as general guidelines for maintaining habitats and 

reducing human disturbance: 

a) For aircraft flights on Forest Service permitted or approved activities, when weather 

ceilings permit, maintain a constant flight direction and airspeed and a minimum flight 

elevation of 1,500 feet (458 meters) for helicopters and fixed-winged aircraft. If at all 

possible, avoid flying over seabird colonies. 

b) Regulate human use to maintain a 250 meter no-disturbance distance from seabird 

colonies on upland habitats. 

2. The availability of garbage to gulls should be eliminated by requiring Special Use 

Permittees to collect and dispose of garbage from their Special Use Authorizations. 

3. Cooperate with state and other Federal agencies to develop sites and opportunities for the 

safe public viewing of these species. Maintain a public education program explaining 

forest management activities related to these species in cooperation with state and other 

Federal agencies. 

IV. Waterfowl and Shorebird Habitats 

A. Maintain or enhance wetland habitats which receive significant use by waterfowl and 

shorebirds. (The Tongass National Forest is a “Priority Forest’ in the national TAKING WING 

Strategic Plan.) “Significant” is relative, but generally relates to use of a specific area by tens or 

hundreds of individuals of one or more species. 

1. Support the international significance of wetland habitats on the Tongass National Forest 

by participating in partnerships such as the North American Waterfowl Management Plan 

and the Western Hemisphere Shorebird Reserve Network. 

2. Identify during project analysis, in cooperation with the Alaska Department of Fish and 

Game and the U.S. Fish and Wildlife Service, wetlands which receive significant waterfowl 

or shorebird use during fall/winter/spring concentrations or nesting, brood rearing or 

molting habitats. 

3. Locate facilities and concentrated human activities requiring Forest Service approval as far 

from known waterfowl or shorebird concentration and nesting areas as feasible. Minimize 

disturbance of waterfowl by restricting, when feasible, development activities to periods 

when waterfowl are absent from the area. 

4. During project analysis, consider the need to rehabilitate waterfowl habitat following 

development activities if there is no feasible alternative to the habitat disturbance. (Also 

see the Wetlands Forest-wide Standards & Guidelines.) 

5. Maintain habitat capability in coastal wetlands and intertidal areas that are important 

migratory staging areas and fall/winter/spring concentration areas, and wetlands that are 

important nesting and brood-rearing habitats, by avoiding, where feasible, all development 

activities which could fill wetlands, drain wetlands, or alter water levels resulting in loss of 

desirable vegetation, or direct loss of habitat. (Consult the Migratory Bird Treaty Act.) 

6. Minimize human disturbance of habitats during important periods of the year (nesting and 

brood-rearing, molting, and winter) by managing human use (such as trails, Off-Highway 

Vehicle use) in significant wetland areas. The following distances are provided as 

guidelines for reducing human disturbance: 

a) Provide a minimum distance of 330 feet (100 meters) between human activities on the 

ground and significant areas being used by other waterfowl. 

7. Develop waterfowl habitat improvement projects in cooperation with appropriate state, 

Federal and local agencies, partner organizations, and individuals. 

8. For Special Use Administration (non-recreational), issue only authorizations which meet 

the objectives of Executive Order 11990 (Protection of Wetlands). Issue permits which 
Appendix F

Final EIS F-19 Biological Assessment

serve to preserve, enhance, or aid in the management of the natural and beneficial values 

of wetlands. 

9. Perform integrated logging system and transportation analysis to determine if other 

feasible routes avoiding areas where significant waterfowl use exists. 

10. If the need to restrict road access is identified during project interdisciplinary review, roads 

will be closed either seasonally or yearlong to minimize adverse effects on waterfowl. 

11. Cooperate with state and other Federal agencies to develop sites for safe public viewing 

opportunities that do not adversely disturb wildlife. Maintain a public education program 

explaining forest management activities related to these species in cooperation with state 

and other Federal agencies. 

B. Conduct activities to avoid or minimize disturbance to habitats within the forest, riparian, and 

estuarine areas which are important nesting, brooding, rearing, and molting areas, for 

Vancouver Canada geese, sandhill cranes, or trumpeter swans. 

Threatened, Endangered, and Sensitive Wildlife Species: WILD4 

Consult FSM 2670 and R10 supplemental directions for Threatened, Endangered, and Sensitive Species. 

I. Threatened or Endangered Species 

A. Kittlitz’s Murrelet 

1. Provide for the protection and maintenance of known Kittlitz’s Murrelet nesting habitats. 
Appendix F

Biological Assessment F-20 Final EIS

Attachment 2 

Wildlife Forest-wide Standards and Guidelines in the Tongass National Forest (portions excerpted 

pertaining to the conservation of marine mammals and their habitats). 

WILDLIFE 

Forest-wide Standards & Guidelines 

Wildlife Habitat Planning: WILD1 

I. Coordination/Cooperation with Other Agencies, Institutions, and Partners 

C. Coordinate with the Alaska Department of Fish and Game, other state agencies, NMFS, the 

U.S. Fish and Wildlife Service, tribal governments, and other cooperators and partners during 

the planning of activities that may affect wildlife. 

1. The Forest should meet at least annually with state and federal wildlife agencies to review 

resource activities, present progress reports on implementation of past cooperative work or 

agreements, and schedule cooperative work. 

2. Seek to maintain memoranda of understanding with appropriate state, Federal, and local 

agencies and associations. 

D. Emphasize management for indigenous wildlife species and natural habitat except in cases 

where the Forest Service, in cooperation with the Alaska Department of Fish and Game and 

U.S. Fish and Wildlife Service, find desirable alternatives. Special consideration should be 

given to the possible adverse impacts on habitat of sensitive, threatened, and endangered 

species. 

E. Coordinate wildlife habitat surveys, studies, plans and improvement projects with the Alaska 

Department of Fish and Game, U.S. Fish and Wildlife Service, NMFS, and other appropriate 

state, federal, tribal, local and private agencies. Use the Sikes Act authorities for cooperative 

work with the state. Use agreements and other partnerships to cooperate with other partners. 

F. Coordinate with the Alaska Department of Fish and Game in development of state strategic 

plans and population goals and objectives for wildlife species and attempt to incorporate wildlife 

goals and objectives into forest management. 

G. Provide habitat information to the Alaska Department of Fish and Game to assist in correlating 

hunting seasons, permits, and bag limits to on-the-ground habitat conditions so that population 

and habitat objectives can be achieved. 

II. General Habitat Planning/Coordination 

A. Recognize as wildlife habitat, areas of land and water that can contribute to achieving wildlife 

objectives for consumptive and non-consumptive uses. 

B. Provide the abundance and distribution of habitat necessary to maintain viable populations of 

existing native and desirable introduced species well-distributed in the planning area, i.e., the 

Tongass National Forest. (Consult 36 CFR 219.19 and 36 CFR 219.27.) 

C. Cooperate with the State and, as appropriate, the U.S. Fish and Wildlife Service in managing 

vehicle, boat, and other human use (e.g. hunting and fishing seasons and bag limits) as 

necessary to achieve wildlife objectives, recognizing the access provisions of ANILCA. 

Emphasize management to reduce human disturbance in high value habitat areas and during 

critical periods of wildlife use. 

D. Maintain a Forest program schedule that includes anticipated wildlife habitat and population 

inventory needs, monitoring requirements and proposed habitat improvement and maintenance 

projects. 

E. Use forest plan management indicator species to evaluate the potential effects of proposed 

management activities affecting wildlife habitat. (Consult Forest Service Manual 2620.) 

F. Develop interagency habitat capability models for any or all of the management indicators to 

systematically assess the impacts of proposed projects during project level analysis. 

Periodically review and update models to reflect the most current habitat relationships and 

habitat modeling technology. 

G. Cooperate with the Alaska Department of Fish and Game to seek to prevent existing 

populations of invasive species from dispersing into Wilderness areas. Address issues 
Appendix F

Final EIS F-21 Biological Assessment

regarding management, introduction, and re-introduction of wildlife species consistent with 

National and Regional Policy. 

H. When population or habitat declines for a plant or animal species or subspecies indicates that 

long-term persistence is at risk, evaluate the particular species for designation as a Regional 

Sensitive Species by the Regional Forester. (Consult FSM 2670 and R10 supplemental 

directions for Threatened, Endangered, and Sensitive Species.) 

III. Marine Mammal Habitats 

H. Provide for the protection and maintenance of harbor seal, Steller sea lion and sea otter 

habitats. 

1. Ensure that Forest Service permitted or approved activities are conducted in a manner 

consistent with the MMPA, the ESA, and NMFS guidelines for approaching seals and sea 

lions. Consult with the appropriate agency for identification of critical timing events, such 

as molting, parturition, etc., and recommended distances to avoid disturbances. "Taking" 

of marine mammals is prohibited; "taking" includes harassment (adverse disturbance), 

pursuit, or attempting any such activity. 

2. Locate Forest Service authorized and approved facilities and concentrated human 

activities as far from known marine mammal haul outs, rookeries and known concentration 

areas as feasible to meet the Alaska Coastal Management Program (ACMP) consistency 

requirements and MMPA. The following distances are provided as general guidelines for 

maintaining habitats and reducing human disturbance: 

a) Locate camps, Log Transfer Facilities, campgrounds and other developments (where 

allowed by the Land Use Designation) 1 mile from known haul outs, and farther if the 

development is large. 

b) Forest Service permitted or approved activities will not intentionally approach within 

100 yards, or otherwise intentionally disturb or displace any hauled-out marine 

mammal. 

c) Dispose of waste oil and fuels off-site as regulated by the Alaska Department of 

Environmental Conservation. 

3. Cooperate with the state and other federal agencies to develop sites and opportunities for 

the safe viewing and observation of marine mammals by the public. Maintain a public 

education program explaining forest management activities related to marine mammals in 

cooperation with state and other Federal agencies. 

Threatened, Endangered, and Sensitive Wildlife Species: WILD4 

Consult FSM 2670 and R10 supplemental directions for Threatened, Endangered, and Sensitive Species. 

I. Threatened or Endangered Species 

A. Steller Sea Lion 

1. Protect Steller sea lion habitats. 

2. Ensure that Forest Service funded, permitted or authorized activities are conducted in a 

manner consistent with the requirements, consultations, or advice received from the 

appropriate regulatory agencies for the MMPA, the ESA, and NMFS guidelines for 

approaching seals and sea lions. "Taking" of sea lions is prohibited; "taking" includes 

harassing or pursuing or attempting any such activity. 

3. Locate facilities, camps, Log Transfer Facilities, campgrounds and other developments 1 

mile from known haulouts, and, farther away, if the development is large. 

4. Cooperate with state and other federal agencies to develop sites and opportunities for the 

safe viewing and observation of sea lions by the public. Maintain a public education 

program explaining forest management activities related to sea lions in cooperation with 

state and other federal agencies. 

B. Humpback Whale 

1. Provide for the protection and maintenance of whale habitats. 

2. Ensure that Forest Service permitted or approved activities are conducted in a manner 

consistent with the MMPA, the ESA, and NMFS regulations for approaching whales, 

dolphins, and porpoise. "Taking" of whales is prohibited; "taking" includes harassing or 

pursuing or attempting any such activity. 
Appendix F

Biological Assessment F-22 Final EIS

Attachment 3 

Forest-wide standards and guidelines in the Tongass Forest Plan for the conservation of threatened, 

endangered, and proposed fish species. These conservation measures serve to protect important habitat 

that may be used for listed Pacific salmon and steelhead. 

FISH 

Forest-wide Standards & Guidelines 

Fish Habitat Inventory and Monitoring: FISH1 

I. Fish Habitat Inventory 

A. Maintain the channel type and stream class (see Glossary) based inventory of all Forest 

streams. 

1. Maintain and update the stream inventory (and GIS mapping) during site-specific project 

planning and analysis. 

a) Consult publication R10-TP-26, A Channel type Users Guide for the Tongass National 

Forest, Southeast Alaska (as revised), for descriptions of the channel types. 

b) Consult the Aquatic Habitat Management Handbook FSH 2090.21 for descriptions of 

Region 10, stream survey methodologies. 

B. Maintain the inventory of Forest streams and watersheds for fish enhancement opportunities. 

C. Maintain, and further develop as necessary, the fish-habitat-objectives database used to 

measure changes in the natural range and frequency of aquatic habitat conditions. (See FISH 

112,IV(B) and Appendix B.) 

Fish Habitat Planning: FISH2 

I. Fish Habitat and Channel Processes 

A. Recognize watershed function and channel processes when planning for the protection, 

restoration or enhancement of fish habitat. (Consult Riparian Forest-wide Standards and 

Guidelines RIP2 and Soil and Water Forest-wide Standards and Guidelines S&W112.) 

1. Consider the effects of upstream and upslope activities during site-specific planning. 

2. Consider the condition of upstream and upslope areas during site-specific planning. 

3. Consider topics such as erosion processes, watershed hydrology, vegetation, stream 

channel morphology, water quality, wilderness designation, recommendations for inclusion 

into the Wild and Scenic River System, species and habitats, and human uses, during 

analyses. 

II. Channel Classification and Process Groups 

A. Use channel type inventories to categorize stream reaches into channel process groups. Use 

channel types and process groups to plan management activities affecting fish and fish habitat 

along all lakes and streams. Process groups and the channel types included in each process 

group are shown in Appendix D, and in publication R10-TP-26, A Channel type Users Guide for 

the Tongass National Forest, Southeast Alaska. These groups may be redefined as more 

information about channel types becomes available. 

1. Map and field-verify streams, lakes and estuaries by channel type and stream class for 

project planning and implementation. 

III. Fish Stream Classification (reference FSH 2090.21 (2001) Chapter 10, Section 12)

A. Determine fish/water quality value class of all streams in the affected area prior to or during sitespecific project planning (also see Riparian Standards and Guidelines). 

B. Use the following classification system across the Forest. 

1. Class I: Streams and lakes with anadromous or adfluvial fish or fish habitat; or high quality 

resident fish waters or habitat above fish migration barriers known to provide reasonable 

enhancement opportunities for anadromous fish. 

2. Class II: Streams and lakes with resident fish or fish habitat—generally steep channels 6 to 

25 percent or higher gradient—where no anadromous fish occur, and otherwise do not 

meet Class I criteria. 

3. Class III: Perennial and intermittent streams with no fish populations but which have 

sufficient flow, or transport sufficient sediment and debris, to have an immediate influence 
Appendix F

Final EIS F-23 Biological Assessment

on downstream water quality or fish habitat capability. For streams less than 30 percent 

gradient special care is needed to determine if resident fish are present. 

A stream segment is designated Class III if the following conditions are met for the 

majority of its length: Bankfull stream width greater than 1.5 meters (5 feet) and channel 

incision (or entrenchment) greater than 5 meters (15 feet). 

Streams that do not meet both the width and incision criteria may be classified as class III 

streams based on a professional interpretation of stream characteristics for the stream 

segment being assessed. The following characteristics could indicate a class III stream: 

a. Steep side-slopes containing mobile fine sediments, sand deposits, or deep soils that 

can provide an abundant source area for sedimentation. 

b. Very steep gradient channels (greater than 35 percent slope). 

c. Recently transported bedload or woody debris wedges (especially if deposited outside 

high water mark). 

d. High water indicators (scour lines, drift lines etc) that greatly exceed observed wetted 

stream width. 

e. Large sediment deposits stored amongst debris that could be readily transported if 

debris shifts. 

4. Class IV: Other intermittent, ephemeral, and small perennial channels with insufficient flow 

or sediment transport capacity to directly influence downstream water quality or fish habitat 

capability. Class IV streams do not meet the criteria used to define Class I, II or III 

streams. Class IV streams must have bankfull width of at least 0.3 meters (1 foot) over the 

majority of the stream segment. For perennial streams, with average channel gradients 

less than 30 percent, special care is needed to determine if resident fish are present 

(resident fish presence dictates a Class II designation). 

5. Non-streams: Rills and other watercourses, generally intermittent and less than 1 foot in 

width, little or no incision into the surrounding hillslope, and with little or no evidence of 

channel scour (Note: these micro-drainage features are not mapped in GIS hydrography 

layers). 

IV. Objectives/Guidelines for Management Affecting Fish Habitat

A. Maintain or restore the natural range and frequency of aquatic habitat conditions on the 

Tongass National Forest to sustain the diversity and production of fish and other freshwater 

organisms. 

B. Use (and update) baseline fish habitat objectives as a reference to evaluate the relative health 

or condition of riparian and aquatic habitat. Use baseline fish habitat objectives, listed below 

(and others as developed), (AFHA, 1995, Bryant et. al. 2004, Woodsmith et. al. 2005) to 

characterize the natural range of habitat conditions by channel types and process groups. 

Specific measurement protocols are described in the Alaska Region Aquatic Management 

Handbook (FSH 2090.21 – 2001-1) 

1. Width-to-depth ratio. Relationship between bankfull width and average bankfull depth, 

expressed as average bankfull width / average bankfull depth. 

2. Large woody debris. Frequency of qualifying large wood pieces per kilometer of stream. 

3. Total key pieces of large woody debris. The frequency of large, structurally integral pieces 

of wood scaled to channel size per kilometer of stream. 

4. Pools per Kilometer. Frequency of qualifying pools per kilometer of stream. 

5. Pool spacing. Frequency of qualifying pools per unit area of channel, length of channel 

surveyed / average channel bed width / number of pools. 
Appendix F

Biological Assessment F-24 Final EIS

6. Residual pool depth per channel bed width. Residual pool depth scaled to channel size, 

residual pool depth / average channel bed-width. 

7. Median particle size. 

8. Pool length per meter. Total qualifying pool length divided by length of survey. 

9. Pool size (relative depth). Average residual pool depth / average bankfull depth. 

10. Relative submergence. Expressed as average bankfull depth. 

C. Maintain or restore stream banks and stream channel processes. 

1. Stream Class I, and Class II streams that flow directly into Class I streams. Maintain, 

restore or improve anadromous, adfluvial, and high value resident fish habitat capability by 

providing natural or improved cover/pool ratio, pool-riffle sequences, and habitat features, 

such as stable large woody debris. Design management activities to maintain stream 

bank, channel and flood plain integrity. 

2. Other Stream Class II: Maintain or restore habitat capability for resident fish populations 

by providing natural or improved cover/pool ratio, pool-riffle sequences, and habitat 

features, such as stable Large Woody Debris. Design management activities to maintain 

stream bank, channel, and flood plain integrity. Avoid impacts to downstream Class I 

streams. 

3. Stream Class III: Design management activities to maintain or restore stream bank, 

channel, and flood plain integrity. Avoid impacts to downstream Class I and Class II 

streams. 

D. Maintain or restore natural and beneficial quantities of Large Woody Debris (LWD) over the 

short and long-term. 

1. Stream Class I, and Class II streams that flow directly into Class I streams. Maintain or 

restore anadromous, adfluvial, and high value resident fish habitat capability by providing 

for natural and beneficial volumes of LWD for rearing, stream energy dissipation, and 

sources of organic matter to the stream ecosystem. Use biological and physical 

characteristics of the stream to determine size classes and distribution of LWD. Limit 

navigational clearing of large wood to the minimum necessary for safety. 

2. Other Stream Class II: Maintain or restore habitat capability for resident fish populations 

by providing LWD, and by designing for future sources of LWD at volumes determined by 

channel type biological and physical characteristics. 

3. Stream Class III: Maintain or restore LWD in channels and banks to prevent changes in 

natural stream bank and stream channel processes. 

E. Maintain or restore water quality to provide for fish production. 

1. Stream Classes I, II, and III: Prevent adverse effects to rearing and spawning habitat. 

Maintain or restore anadromous, adfluvial, and high value resident fish habitat capability. 

Maintain or restore capability for other resident fish populations to the extent feasible. 

Assure no chronic sediment input following soil-disturbing activities. Prevent adverse 

impacts to fish habitat downstream by minimizing siltation. 

2. Implement applicable Best Management Practices. (FHS 2509.22). 

F. Maintain or restore optimum water temperatures for salmonids, considering both winter and 

summer habitat requirements, climate, and natural watershed characteristics. 

1. Stream Class I, and Class II streams that flow directly into Class I streams. Maintain or 

restore optimum salmonid summer stream temperatures at between 50 and 68°F or at 

natural levels. 

2. Other Stream Class II: Maintain water temperatures below 68°F, or at natural levels, to 

maintain or restore habitat capability for resident fish populations. Manage watersheds 

and riparian streamsides to maintain water temperature standards and guidelines for 

downstream Class I streams. 

3. Stream Class III: Manage watersheds and riparian streamsides to maintain water 

temperature standards and guidelines for downstream Class I and II streams. 

G. Maintain, restore or improve, where feasible (see glossary), stream conditions that support the 

migration or other movement of aquatic organisms inhabiting a waterbody. 

1. If a stream crossing cannot be avoided then the best solution for aquatic organism 

passage is generally to maintain the natural stream form and processes from the inlet, 

through the crossing, and into the downstream channel. Bridges, open bottom culverts and 

stream simulated culverts designed and installed to applicable BMPs ( Soil and Water 
Appendix F

Final EIS F-25 Biological Assessment

Conservation Handbook , FSH 2509.22) and design standards (Aquatic Habitat 

Management Handbook, FSH 2090.21) to best meet this objective. 

2. Some stream conditions, engineering constraints or cost may make it desirable to install 

culverts that use a variety of weir/baffles or roughened channel to provide for passage. 

These hydraulically designed culverts rely on matching culvert hydraulic conditions at a 

specified design flow to the swimming performance of a specified design fish (Aquatic 

Habitat Management Handbook, FSH 2090.21). 

3. Stream crossing structures requiring aquatic organism passage will be designed to current 

standards by qualified professionals. 

4. Consult applicable Best Management Practices (see FSH 2509.22). 

5. Consult and improve the inventory of identified fish stream crossings. 

6. As per Memoranda of Understanding between the Forest Service and the Alaska 

Department of Natural Resources (ADNR, 2004), and the Alaska Department of 

Environmental Conservation (ADEC, 1992), culvert installation, stream alignment or 

diversions; dams; low-water crossings; and construction, placement, deposition, or 

removal of any material or structure below ordinary high water all require State 

concurrence. 

7. Overall, the intent is to not disrupt the migration or movement of aquatic organisms, but 

occasionally it is not feasible to protect some sections of habitat and movement will be 

restricted. In determining feasibility consider the following: 

a) Presence of known sensitive, isolated or unique fish populations. 

b) Extent and quality of available habitat and how it is affected by the location of the 

stream crossing. 

c) The cumulative impacts of restricting fish passage at multiple sites in the same 

watershed. 

d) The upstream and downstream linkages between the anadromous and resident life 

strategies of the same species. 

e) Advice from the Alaska Department of Fish and Game and the Alaska Department of 

Natural Resources. 

f) The length of time that a stream structure will restrict movement. 

g) The cost of providing ideal passage conditions compared to less than ideal 

conditions. 

h) Availability of suitable, cost effective compensatory mitigation projects. 

8. The discharge of dredge or fill material from normal silviculture activities such as timber 

harvest is exempt from Clean Water Act Section 404 permitting requirements in waters of 

the United States (404(f)(1)(A). Forest roads qualify for this exemption only if they are 

constructed and maintained in accordance with BMP’s specified in 33CFR 323.4(a). These 

BMPs have been incorporated into BMP 12.5 in the Alaska Region’s BMP Handbook (FSH 

2509.22) 

V. Management Indicators 

A. Use forest plan management indicators to evaluate the potential effects of proposed project 

management activities affecting fish habitat. 

VI. Management Activities

A. Maintain a fish program schedule which includes anticipated inventory needs, proposed habitat 

improvement and maintenance projects, and monitoring requirements. 

VII. Coordination 

A. Coordinate activities that affect fish resources with other Forest disciplines through the 

Interdisciplinary Team process, and with state, other Federal, and local agencies and groups. 

1. Develop and maintain Memoranda of Understanding/Agreements with appropriate state, 

Federal, and local agencies and aquaculture associations. 

2. Coordinate with the state and federal agencies, and the Pacific Northwest Research 

Station, to maintain a continuous program for research, monitoring, and assessment of 

impacts of land-use activities on fish habitat. 

B. Consider the influence of proposed management activities on fishing use patterns. 

C. Consider effects of Off-Highway Vehicle (OHV) travel and road closures on fish habitat and 

populations. 
Appendix F

Biological Assessment F-26 Final EIS

VIII. Projects

A. Use the following priority for fish habitat project work: mitigation for unplanned impacts, 

rehabilitation/restoration, enhancement. For both mitigation and rehabilitation, consider 

alternatives for cost efficiency of performing off-site enhancement (enhancement of a different 

area than where the impact actually occurs). 

1. Location of off-site enhancement shall be governed by the following priorities: 

a) First priority: same stream reach (same species) 

b) Second priority: same stream (same species) 

c) Third priority: same watershed (same species) 

d) Fourth priority: same anadromous fish harvest area (same species) 

e) Fifth priority: differing species, using above priority order 

B. Enhance fish habitat to meet the objectives identified in this plan. Opportunities may include, 

but are not limited to: instream enhancement, lake fertilization, cooperative bio-enhancement 

(e.g., stocking), incubation boxes, and fishway construction. 

1. Use the Cooperative Fisheries Planning process (Consult ANILCA Section 507) and/or 

other cooperative agreements for developing priorities for the enhancement of fish 

resources. 

2. Determine habitat capability on streams and lakes identified for enhancement in the 

Cooperative Fisheries Planning process prior to construction of fish projects. 

3. Update the fish habitat enhancement list (Cooperative Fisheries Planning process) 

periodically. 

C. Recognize bio-enhancement (e.g., stocking of juveniles, use of egg incubation boxes, 

transferring of adult fish to seed stream systems) as part of the fish improvement project costs 

when appropriate. Cooperate/coordinate with fish agencies and aquaculture associations to 

facilitate bio-enhancement. 

D. Fishpass projects abide by the standards and best practices for colonization projects included 

in the Comprehensive Salmon Enhancement Plan for Southeast Alaska, Phase III. 

E. Coordinate new projects to enhance the use of National Forest System lands with the 

recreation program managers. 

Fish Habitat Improvement: FISH3 

I. Planning 

A. Improve or restore fish habitat to work toward the habitat objectives of the Forest Plan. 

B. Construct projects using the most cost-efficient methods, while achieving desired results 

consistent with the Land Use Designation. 

C. During project planning consider the need to monitor the accomplishment of project objectives. 

Need shall be governed by the type of project, with high interest/high investment projects being 

monitored more intensively. 

1. Where needed, develop cooperative agreements with fish/aquaculture agencies and other 

groups to assess the effectiveness of Forest Service habitat improvement. 

II. Construction Coordination 

A. Coordinate all fish habitat improvement using an interdisciplinary process. 

B. Coordinate habitat improvement projects with the Alaska Department of Fish and Game and 

other appropriate agencies and groups. 

III. Monitoring 

A. Conduct monitoring of fish improvement projects to insure their continued function at the design 

level of operation. 

B. Monitor fish production on a representative sample of improvement projects to evaluate 

effectiveness of individual projects, categories of similar projects, and the effectiveness of the 

overall improvement program. 

Fish Habitat Maintenance: FISH4 

I. Maintenance 

A. Provide for the maintenance of fish habitat enhancements. 

1. Fund maintenance of existing projects prior to the construction of new ones. 

2. Include funding for maintenance in the planning and budgeting for all projects. 
Appendix F

Final EIS F-27 Biological Assessment

3. Maintain improvements to assure that investment objectives are met. 

4. When maintenance and operation of an improvement become inefficient , reconstruct 

or remove the improvement. 

5. If an improvement becomes inoperable, reconstruct or remove the improvement. 

B. Develop a written maintenance responsibilities agreement with project cooperators prior to 

project construction. 

Threatened, Endangered, and Sensitive Fish Species: FISH5 

Consult FSM 2670 and R10 supplemental directions for Threatened, Endangered, and Sensitive Species. 

I. Threatened or Endangered Species 

A. There are currently no Threatened or Endangered fish species on the Tongass National 

Forest. 

II. Sensitive Fish Species 

A. Island King Salmon 

1. Provide for the protection and maintenance of runs of king salmon that naturally occur 

on islands including the runs in King Salmon and Wheeler creeks on Admiralty Island. 

2. Coordinate with the Alaska Department of Fish and Game and NMFS on commercial, 

sport and subsistence fish use, hatchery egg take programs, and other activities 

affecting the viability of king salmon runs in order to conserve these unique 

populations. 

3. Avoid the placement of facilities or issuing permits for activities near these streams that 

would increase harvest pressure on these king salmon runs. 

B. Northern Pike 

1. Provide for the protection and maintenance of northern pike found in the Pike Lakes on 

the Yakutat Forelands. This population of northern pike is unique to Southeast Alaska. 

2. Avoid the placement of facilities near the Pike Lakes which would increase harvest 

pressure to the point where the viability of these species is affected. 

3. Coordinate with the Alaska Department of Fish and Game on any activities that would 

affect the viability of the northern pike. 

C. Fish Creek Chum Salmon 

1. Provide for the protection and maintenance of chum salmon in Fish Creek near Hyder. 

This population of chum salmon is characterized by their extraordinary large size. 

2. Coordinate with the Alaska Department of Fish and Game and NMFS on commercial, 

sport and subsistence fish use, hatchery egg take programs, and other activities 

affecting the viability of the chum salmon runs in Fish Creek in order to preserve these 

populations. 

3. Provide for habitat improvement and maintenance to maintain the viability of this run of 

salmon, as necessary. 
Appendix F

Biological Assessment F-28 Final EIS

This page is intentionally left blank. 
APPENDIX G 

TIMBER DEMAND AND SUPPLY 
Appendix G

Final EIS G-i Timber Demand 

Appendix G 

Timber Demand and Supply 

CONTENTS 

Summary................................................................................................................................................... G-1

Introduction ............................................................................................................................................... G-1

Demand Estimation................................................................................................................................... G-3

Using Derived Demand Estimates to Estimate Supply............................................................................. G-7

Development of Timber Sale Requirements to Meet Market Demand ................................................... G-10

Conclusion .............................................................................................................................................. G-11

Acknowledgements................................................................................................................................. G-12

Citations .................................................................................................................................................. G-12

LIST OF TABLES 

Table G-1 Characteristics of scenarios defining demand for Alaska roundwood (adapted from 

Brackley et al. 2006a)...........................................................................................................G-6

Table G-2 Tongass National Forest sale volume necessary to supply derived demand for decked 

log volume and chips reported in Brackley et al. (2006a) (Million Board Feet). ..................G-8

Table G-3 Percent of volume in an average Tongass National Forest stand, by grade and 

species. ................................................................................................................................G-9
Appendix G

Final EIS G-1 Timber Demand 

Appendix G 

Timber Demand and Supply on the 

Tongass National Forest 

Susan J. Alexander, PhD 

Regional Economist, US Forest Service Alaska Region 

December 7, 2007 

Summary 

Since 1990, when the Tongass Timber Reform Act (P.L. 101-626) required the Tongass National Forest 

to take economics into account in planning timber sale programs, a number of demand studies have been 

published by the US Forest Service Pacific Northwest Research Station, assessing derived demand for 

Alaska wood products. Information from these demand assessments is incorporated into short-term 

timber sale planning through a supply model, and into long-term planning through the Forest Plan 

process. This appendix supports text in the Forest Plan amendment EIS, provides additional information 

about the Brackley et al. (2006a) demand estimates, and outlines how the Brackley et al. demand 

projections are incorporated into annual timber sale offer target calculations on the Tongass National 

Forest. 

Introduction 

Section 101 of the 1990 Tongass Timber Reform Act (TTRA) states that: 

Subject to appropriations, other applicable law, and the requirements of the National Forest 

Management Act (P.L. 94-588); except as provided in subsection 9d) of this section, the 

Secretary shall, to the extent consistent with providing for the multiple use and sustained yield of 

all renewable forest resources, seek to provide a supply of timber from the Tongass National 

Forest which (1) meets the annual market demand for timber from such forest and (2) meets the 

market demand from such forest for each planning cycle. 

The 1997 Record of Decision for the Tongass Land and Resources Management Plan Revision 

committed the US Forest Service to develop procedures to insure that annual timber sale offerings would 

be consistent with implementing the “seek to meet market demand” language of the TTRA. Those 

procedures were completed in 2000, and have become known as the “Morse methodology” after their 

author. These procedures are based on the premise that: 

• Forest products markets are volatile, especially in the short run. 

• Timber purchasers in Southeast Alaska have few alternative suppliers of timber if they cannot 

obtain it from the Tongass National Forest. Oversupplying this market has relatively few adverse 

economic effects; undersupplying it can have much greater negative economic consequences. 

• It takes years to prepare national forest timber for sale, including completion of environmental 

impact statements. 

• It is difficult to estimate demand for timber from the Tongass, even a year or two in advance. 

• Industry must be able to respond to rapidly changing market conditions in order to remain 

competitive. 

Accordingly, the Morse methodology establishes a system that seeks to build and maintain sufficient 

volume of timber under contract (timber purchased but not yet harvested, the primary indicator of timber 
Appendix G

Timber Demand G-2 Final EIS

inventory available to the industry) to allow the industry to react promptly to market fluctuations. Industry 

actions such as annual harvest levels are monitored and timber program targets are developed by 

estimating the amount of timber needed to replace volume harvested from year to year. The Morse 

methodology is self-correcting, because if harvest levels drop below expectations, future timber sale 

offerings will also be reduced to levels needed to maintain the target level of volume under contract. 

Conversely, if harvest levels rise unexpectedly, future timber sale targets will also increase sufficiently to 

ensure that the inventory of volume under contract is not exhausted. By dealing with uncertainty in a 

flexible, science-based fashion, the Morse methodology is an example of adaptive management. The 

Forest Service intended the Morse methodology to be the means by which the agency complies year-byyear with the annual demand portion of the TTRA “seek to meet” requirement. Similarly, the agency 

intended to comply with the requirement to seek to meet demand “for each planning cycle” through a 

series of annual applications of the Morse methodology. 

The US Forest Service Pacific Northwest Research Station has published several studies conducted in 

support of Tongass Land Management planning that estimate derived demand for timber in Southeast 

Alaska, including Brooks and Haynes (1997) and Brackley et al. (2006a). The procedures developed by 

Morse (2000) to estimate the timber offer target (supply) incorporate the demand numbers from the PNW 

studies as an input into a spreadsheet. The PNW derived demand projections are trend projections and 

should be interpreted as five-year averages. The Morse methodology relates these derived demand 

projections into an annual calculation of timber sale offer levels. 

The procedures developed by Morse (2000) to estimate the annual sale offering targets from the Tongass 

National Forest address the uncertainty associated with forecasting market conditions, considering the 

continuing transformation of the timber industry and the inability of the Forest Service to respond quickly 

to market fluctuations due to the time it takes to prepare timber for sale. The basic approach developed 

is to allow the industry to accumulate an adequate volume under contract (a measure of inventory), then 

monitor industry behavior and adjust timber program levels to keep pace with the harvest activity. Key 

economic indicators and stumpage market conditions are monitored. The method underwent rigorous 

technical and public review before it was implemented. Since the method was initially developed by 

Morse (2000), inputs to the model have been adjusted to reflect new understandings and information, 

such as share of raw material provided by the Tongass National Forest to local processors, the amount of 

time between purchase and harvest of a timber sale, and mill capacity. In this way, the approach has 

allowed for adaptations to current situations. 

Morse (2000) outlined monitoring goals, with some specific criteria for action. An update of the timber 

demand assessment by Brooks and Haynes (1997) was requested from the US Forest Service Pacific 

Northwest Research Station, because sales to domestic markets now account for more than 35 percent 

of lumber products in Southeast Alaska. The PNW Research Station published new demand projections 

(Brackley et al. 2006a) with some changes in how alternative scenarios were presented and how timber 

volume was characterized. The new projections contain four scenarios, as opposed to the three in 

Brooks and Haynes (1997), and the timber volume in the Brackley et al. (2006a) demand projections is 

demand for decked logs (stacked logs at processing facilities) plus a portion of cedar log shipments out of 

Alaska.in scenarios 1 and 2. The authors acknowledge that pulpwood grade material may be left in the 

woods, but they do not include that volume in these two projections. In the case of scenario 3 and 4, the 

derived demand estimates include pulpwood quality material that is assumed to be left in the woods 

under scenarios 1 and 2, decked logs at processing facilities, and cedar log shipments out of Alaska. The 

new projections do not require a change in the basic methodology for timber offer calculations in the 

procedure outlined in Morse (2000). 

During the 1990s, competition with production in other regions and market conditions led to the closure of 

Southeast Alaska’s two pulp mills and numerous closures of sawmill facilities. The twelve remaining 

active mills operated at about 13 percent of their estimated capacity in 2005. The Tongass National 

Forest contributed about 65 percent of wood sawn by local mills from 2002 to 2006 (Kilborn et al. 2004; 

Brackley et al. 2006b; data from mill surveys conducted by Dan Parrent of Juneau Economic 

Development and on file with the Regional Economist, US Forest Service Alaska Region). Although 

about one-third of sawn wood has come from State of Alaska lands, State lands comprise a relatively 

small percentage of Southeast Alaska forest lands, and State lands cannot indefinitely supply such a high 
Appendix G 

Final EIS G-3 Timber Demand

proportion of the needs of remaining Southeast Alaska sawmills. A very small proportion (less than one 

percent) has come from private lands in the past five years. The primary destination for material sawn in 

Southeast Alaska is currently other states within the U.S. Brackley and Haynes (in press) conclude that 

many of the lumber and wood products markets Alaska mils compete in are higher-end markets in which 

foreign and domestic prices have become fairly similar, through market arbitrage. Haynes at al. (2007) 

found that since 1994, the value of U.S. forest product exports has been in gradual decline while the 

value of imports has steadily increased. Hansen (2006) states that U.S. companies have historically 

jumped into the export market when the domestic market is down, and shifted back to the U.S. market 

when the domestic market improves. In recent years, the U.S. domestic market has been very attractive 

with high housing starts and strong prices in many forest product categories. Haynes et al. (2007) state 

that U.S. demand for forest products is varied and large, averaging 71.4 cubic feet per person per year. 

This per capita consumption of wood products in the U.S. has been relatively constant for 50 years. Total 

U.S. forest products consumption is projected to continue to rise. U.S. imports of wood products are 

projected to rise at a somewhat faster rate than domestic wood supply. U.S. import dependence is 

projected to reach more than one-quarter of the total of all wood products consumed and exported in the 

US by 2010. Economic globalization throughout wood products manufacturing is contributing to a global 

realignment of growth in raw material demands. In addition to this realignment of where manufacturing 

takes place, sheer population growth will drive increases in wood products demand both in the US and 

world-wide. Ince et al. (in press) state that countries such as China are emerging in the 21st century as 

growth leaders in wood raw material and industrial wood product demand. 

Brackley and Haynes (in press) examined trade information and literature on Chinese wood products 

markets, and concluded that one of the most significant events of the 21st century has been the 

emergence of China and other Asian nations into world markets. Although China and other undeveloped 

Asian nations will probably have a minor impact on demand for softwood products produced in southeast 

Alaska in the next 5 years, in the longer term there will be direct and indirect impacts “that will provide 

markets for any level of production the forest products industry in southeast Alaska may attain” (Brackley 

and Haynes, in press; 26). 

In 2007, the US Forest Service in Alaska approved a new policy under which timber purchasers may ship 

to the lower 48 states unprocessed certain small-diameter and low-quality logs harvested from the 

Tongass, up to 50 percent of the volume harvested on each sale. This interstate shipments policy places 

purchasers of Tongass National Forest timber in a similar position as their counterparts in the Lower 48, 

where there is no restriction on interstate shipments of timber harvested from National Forest System 

lands. While it is still early in the implementation of the new policy, full implementation of it over the next 

year or two could make Alaska forest products producers more competitive with their counterparts in the 

Lower 48 States. That may allow Alaska producers to increase their share of domestic forest products 

markets, which would stimulate demand for timber from the Tongass without the construction of new 

processing facilities in Southeast Alaska. In addition, a new veneer mill has opened in Ketchikan that 

uses low-grade sawtimber. 

On the supply side, the cost of preparing stumpage for sale and delivering it to mills has increased, due to 

decreased size of sales, increased fuel costs, legal and procedural challenges to federal timber sales, 

and more constraints on harvest activity in the interest of resource protection. The uncertainty 

surrounding Tongass National Forest sale quantities has increased the risk faced by potential purchasers 

and investors in local processing capacity. 

Demand Estimation 

The method to project timber harvests and output in Alaska followed by Brackley et al. (2006a) is 

essentially the same as that employed in previous estimates of Alaska timber demand by Haynes and 

Brooks (1990), Brooks and Haynes (1990), Brooks and Haynes (1994), and Brooks and Haynes (1997). 

Derived demand is determined by converting demand in all markets, foreign and domestic, to the timber 

volume that is required to produce the defined products utilized by the market. In the model, ratios are 

used to assign a portion of the total global demand to producing regions. Brackley et al. (2006a) then 

estimate the Alaska forest products output, by product, required to meet projected demand, and calculate 

the raw material requirements necessary to support this production, using explicit product recovery and 
Appendix G

Timber Demand G-4 Final EIS

conversion factors. The total raw material requirement (the total derived demand for timber) is a 

combined projection of timber harvest from private ownership, from National Forests, and from nonNational Forest public owners. The projected National Forest timber demand is the quantity of timber 

required to satisfy projected derived demand given harvest by other owners, and given explicit 

assumptions about markets and implicit assumptions about prices (described below). The study analyzes 

trends over a historical period of about 40 years (1965 to 2004) as a basis for a projection of 20 years 

(2005 to 2025) in three key parameters: 

1. The level of forest products imports in Pacific Rim nations. According to Brackley and Haynes (in 

press), the PNW demand studies define the Pacific Rim as the major producing areas of the three 

contiguous Pacific coast states (California, Oregon, and Washington), British Columbia, Alaska, 

the Russian Far East, and major consuming regions of Japan, Korea, Taiwan, and China 

(Haynes and Brooks 1990). Based on other research regarding these markets, the Brackley et 

al. demand study projects that Pacific Rim imports of sawn wood products will increase over the 

next 20 years. 

2. The share of those markets that will be supplied by North American forest products producers, 

which the study projects will remain constant. 

3. The share of North American exports to the Pacific Rim that will come from Alaska. The analysis 

examines four alternative assumptions regarding future trends of the Alaskan share of North 

American exports to the Pacific Rim. 

Brackley et al. (2006a) assembled historic data that describe relevant components of the Alaska forest 

sector and calculated possible future wood needs by using an analysis of trends in factors that influence 

harvests. They also used assessments of current markets from other analysts. Data from the historic 

period of 1965 to 2004 were used as a basis for the projection of the future (2005 to 2025), to avoid 

emphasis on short-term cycles. Trends in consumption (for example, of sawn wood in Japan), and trends 

in production, represented by shipments (for example, of lumber to all destinations) make up the basic 

structure of the model. The authors recognized that the US is a net importer of timber. A mill in Alaska 

has the option to ship products to traditional export markets, emerging new markets, or the lower 48 

states. Demand for wood products is global in nature and increasing amounts of wood products are 

being imported into the United States. The primary determinate of where products will be shipped is 

price. There are many high-value products (such as large timbers for architectural designed buildings, 

and shop grades of lumber) that are now being shipped to the lower 48 from Alaska. 

The demand model calculates the quantity of National Forest timber needed by mills as a residual 

necessary to balance the model. In other words, Brackley et al. (2006a) estimated the roundwood 

equivalent of all material used to produce products from Alaska, and subtracted estimated future volume 

harvested from other landowners to derive National Forest roundwood needs (the “residual”). The results 

in Brackley et al. (2006a) reflect decked roundwood volume (stacks of unprocessed logs) at processing 

facilities. 

Stumpage price projections in the PNW demand studies are linked to price series used and projected in 

the Resource Panning Act assessments (such as Haynes et al. 2007). Stumpage prices in Alaska are 

estimated as a function of prices in western Washington and Oregon. Alaska markets directly interact 

with producers and consumers in other US regions through this price relationship. Brackley and Haynes 

(in press) explain that “market arbitrage is used to understand parity among prices in spatially distinct 

markets where there is the opportunity for open exchange (trade). Market arbitrage is a powerful force 

that keeps prices of different species, grades, and locations within some fixed proportion to each other. 

Abstracting from transportation and transactions costs, for example, prices of one species and grade will 

not exceed prices for other species of a similar grade in the long run because of possibilities of 

substitution.” Tying price in Alaska to price in the Pacific Northwest is how market arbitrage is included 

implicitly in the demand assessment. The mix of products that go into end markets from Alaska are, on 

average, higher quality and more valuable than the average lumber markets in Washington, Oregon, and 

British Columbia (Brackley and Haynes in press). The type of lumber products in the demand projections 

reflects this higher value by the type of markets they compete in. Although price is not explicit in the 

PNW demand studies, it is reflected through this mix of generally higher value products that go into 

various end markets, and by the assumption that Alaska price is a function of US price. 
Appendix G 

Final EIS G-5 Timber Demand

Alaska is one of the last places in western North America that produces products from slow-grown large 

old trees. Old-growth trees and some younger trees in Alaska have special high-quality strength and 

appearance characteristics. Wood products manufactured in Alaska generally go into high-end markets, 

such as window casings and door moldings. These markets are arbitraged throughout the Pacific Rim, 

meaning that prices for these products are similar regardless of what market it goes into—domestic or 

foreign. Brackley and Haynes (in press) illustrate how Alaska producers have shifted in and out of 

domestic markets. Brackley et al. (2006a) accounted for this market arbitrage by assuming export 

products would be synonymous with high-value products that could be sold in domestic or foreign 

markets based on price. 

Brackley et al. (2006a) used information about US exports to Japan, and Japanese import data, as a 

benchmark for the historic data, as such exports represented, until very recently, the vast majority of sawn 

wood production from Southeast Alaska. Data about domestic end markets for sawn wood production 

from Southeast Alaska have been available since about 2000. The information on domestic end markets 

can be difficult to verify. One major question is how much of the product shipped to the Pacific Northwest 

is trans-shipped Trans-shipments are products that are shipped to foreign markets from a different 

customs district than the one in which they were manufactured. In the case of Southeast Alaska, lumber 

manufactured in Alaska is apparently being shipped to foreign markets from the Seattle customs district, 

making it difficult to track many of the very recent end markets and subsequent demand for manufactured 

products from Alaska. Other data used in the Brackley et al. (2006a) analysis includes log sources from 

all ownerships in Southeast Alaska, log and chip shipments out of Alaska to various destinations from all 

owners, harvest by owner, the Alaska market share for manufactured products in North America, and the 

North American market share in Japan. 

The assumptions used by Brackley et al. (2006a) in their four scenarios are outlined in Table G-1. The 

Limited Lumber Production and the Expanded Lumber Production scenarios assume the wood 

processing industry in Southeast Alaska is focused only on processing of sawlogs. The primary 

difference between these two scenarios is the assumption that Alaska will increase its market share in the 

North American export market from 0.39 percent to 1.14 percent in the Expanded Lumber scenario, while 

the Limited Lumber scenario maintains the same market share for Alaska products (0.39 percent) in the 

North American market as a whole. The North American market share of the entire Pacific Rim market 

remains at about 50 percent in all scenarios; what changes is the assumption of how much of that larger 

market will be comprised of wood products from southeast Alaska. In addition, although the market share 

of North American in the larger Pacific Rim market remains at about 50 percent, the total amount of wood 

products consumed in that global market is expected to rise by more than 20 percent by 2025, due to 

increasing populations throughout the Pacific Rim. This projected total increase in consumption is 

consistent with expected rates of increase in consumption reported in the RPA (Haynes et al. 2007) 

projections and considerably lower than the rates reported by the United Nations World Trade 

Organization and Trends Inc, summarized in Brackley et al. (in press). 

Basically, the Limited Lumber scenario assumes the market for sawlogs from Alaska will be relatively low 

and remain so, as the intent of this scenario was to depict the situation the industry has faced over the 

last several years. The Expanded Lumber scenario assumes there will be some kind of demand stimulus 

for sawlog material. Such a demand stimulus could come from an industry marketing program, capital 

investment to make existing sawmills in Alaska more efficient, a change in policy, or some other event 

that enhances the competitive position of Alaskan producers relative to their competitors in the 

continental United States, or a combination of such developments. The recent implementation of a 

limited shipment policy by the US Forest Service in Alaska, in addition to the start-up of a veneer mill in 

Ketchikan, makes the Expanded Lumber Scenario the most likely scenario representing southeast 

Alaska’s near future (Brackley and Haynes in press). 

The Medium Integrated Industry and High Integrated Industry scenarios build on the Expanded Lumber 

scenario, and in addition, both assume there will be a demand stimulus for low grade and utility logs, 

which could come about by the construction of one or more chip and utility log processing facilities in 

Southeast Alaska. These two scenarios assume an increase in markets for Alaska lumber products, but 

not to the extent assumed in the first two scenarios. These two integrated industry scenarios also 

assume varying increases in the Alaska share of the North American export market. The Medium 
Appendix G

Timber Demand G-6 Final EIS

integrated scenario assumes an increase in demand for chippable material equivalent to the construction 

of one chip/utility processing facility in 2008, while the High integrated scenario assumes there will be two 

increases in demand for chippable material, equivalent to the construction of two chip/utility processing 

facilities, one in 2008 and another in 2012. Development of a market for low-quality material is referred to 

as an integrated industry, because all of the material resulting from timber harvest would be processed 

into marketable products. This is displayed as the construction of medium-density fiberboard (MDF) 

plants, but the authors make it clear that an MDF plant is only one way a use for low-quality material 

could develop. Shipments of low-grade material to markets outside southeast Alaska could also be the 

demand stimulus modeled in these two scenarios. 

Table G-1 

Characteristics of scenarios defining demand for Alaska roundwood (adapted from 

Brackley et al. 2006a) 

Scenario 

Characteristic 

Limited lumber 

production 

Expanded 

lumber 

production 

Medium 

integrated 

industry 

High Integrated 

industry 

Million cubic meters 

Pacific Rim lumber imports: 

Starting 8,077 8,077 8,077 8,077 

Ending 11,042 11,042 9,099 10,098 

Million board feet lumber tally 

NA share of Pacific Rim marketa

Starting 2,146.7 2,146.7 2,146.7 2,146.7 

Ending 2,760.5 2,760.5 2,760.5 2,760.5 

Percent 

AK share NA market 

Starting 0.39 0.39 0.39 0.39 

Ending 0.39 1.14 1.60 2.34 

NA share of Pacific Rim 

softwood lumber market 

49.29 49.29 49.29 49.29 

Estimated low-grade 

material in sawmill log 

mixb 

33 33 10 10 

Demand stimulation no yes yes yes 

Market for low-grade 

logs 

no no yes yes 

a. NA is North America, and AK is Alaska. 

b. Estimating amounts of low grade and utility grade logs delivered to sawmills for use as saw logs meeting the definition of a 

number 2 saw log at least 12 feet long. 

The assumptions and structure used in the Brackley et al. (2006a) model affect the results. An example 

of a structural aspect is the way total demand is allocated among ownerships. Since the trend analysis 

model used by Brackley et al. (2006a) calculates National Forest wood demand as a residual (i.e., the 

share of total demand for Alaska wood products not already accounted for by other ownerships), the 

model will be sensitive to assumptions about production from other ownerships. They assumed state 

lands in the region will produce 6.8 mmbf annually. Production from state lands will have an inverse 

relationship to production from Federal lands, all else assumed constant. If nothing else changes in the 

model, less production from State lands will mean more demand from Federal lands, and vice versa. 

The assumptions in the model also affect the results in various ways. The model assumes that low grade 

and utility material in the two lumber production scenarios may be unused, sent to chippers, or exported. 

Changes in their assumptions regarding low grade material utilization may affect the volumes of timber 

actually removed from timber sales. The model also assumes that in the long run, the volume of sawn 

material shipped to the total Pacific Rim market (both domestic and foreign) from North American will 

steadily increase. The proportion stays the same, but the total amounts increase, as the model assumes 
Appendix G 

Final EIS G-7 Timber Demand

the entire market is increasing. In the short run this assumption won’t affect the results. Over a decade 

or more, if this assumption proves incorrect, there will be an effect on projected demand. Given 

population trends in all Pacific Rim market areas, this assumption of increasing demand is very likely. 

The model also assumes that demand for Alaska manufactured products is directly linked to demand for 

North American manufactured products through the share calculation. As the North American share of 

total Pacific Rim markets increases, so will demand for Alaska products, all else constant. In addition, if 

the proportion of Alaska products in the entire North American market increases, demand for Alaska 

products will increase, all else constant. These assumptions change from current levels to the levels 

outlined in Table G-1 gradually throughout the projection period. 

Brackley et al. (2006a) list the following issues that will need further research to assist in better 

predictions in the future. They mention the issue of transshipments. Local sales of lumber within 

Southeast Alaska are not documented; information is needed as to types of products, prices, and so on. 

The price differential between foreign and domestic markets for Alaska wood products needs more 

investigation. Transportation costs are not documented in publicly available databases. The mix of 

dimension versus shop products is only beginning to be assessed, and conversion factors for these 

products in Alaska manufacturing are not well developed. 

Using Derived Demand Estimates to Estimate Supply 

Determining what the demand estimates mean for timber sale offered from National Forest lands in 

Southeast Alaska involves taking the results from Brackley et al. (2006a) and using them as input to a 

supply calculation that seeks to meet annual market demand from the forest. The derived demand 

projections in Brackley et al. (2006a) are one of the inputs to the timber offer calculation developed by 

Morse (2000). In the original model development (Morse 2000), the derived demand input was total 

projected harvest volume from the PNW projections developed by Brooks and Haynes (1997). Timber 

volume in the Brackley et al. (2006a) demand projections in Scenarios 1 (limited lumber) and 2 

(expanded lumber) include decked saw logs, cedar log shipments out of Alaska, chip volumes available 

from sawmill production, and a very small portion of utility or low-grade material that they assumed goes 

directly to mill chippers. The authors acknowledge that pulpwood grade material may be left in the 

woods, but they did not include that volume in these two projections. Scenarios 3 (medium integrated) 

and 4 (high integrated) include decked saw logs, cedar log shipments out of Alaska, chip volumes 

available from sawmill production., utility, and low-grade material. This is different than previous 

projections, which projected demand for Tongass timber as volume of timber in timber sales in the forest, 

and did not disaggregate by species or log grade. The volume reported in Brackley et al (2006a) needs 

to be adjusted to represent total sale volume needed to meet derived demand estimates for the Limited 

Lumber and Expanded Lumber scenarios. Table G-2 illustrates the estimated sale volume represented 

by Brackley et al. (2006a) in their projections. 
Appendix G

Timber Demand G-8 Final EIS

Table G-2 

Tongass National Forest sale volume necessary to supply derived demand for decked 

log volume and chips reported in Brackley et al. (2006a) (Million Board Feet). 

Projected National Forest Timber Harvest—Alaska (MMBF; includes sawlog, utility, 

and shipments from Alaska)a 

Year 1. Limited lumber 

2. Expanded 

lumber 

3. Medium 

integrated 4. High integrated 

2007 49.8 61.9 67 67 

2008 49.8 66.4 139 139 

2009 51.3 72.4 151 151 

2010 52.8 78.5 166 166 

2011 52.8 84.5 184 184 

2012 54.3 90.5 204 286 

2013 55.8 98.1 204 291 

2014 57.3 105.6 204 295 

2015 58.9 113.2 204 299 

2016 58.9 122.2 204 303 

2017 60.4 131.3 204 308 

2018 61.9 140.3 204 312 

2019 63.4 150.1 204 317 

2020 64.9 163.0 204 325 

2021 66.4 175.0 204 333 

2022 67.9 187.1 204 342 

2023 69.4 200.7 204 351 

2024 70.9 215.8 204 360 

2025 72.4 230.9 204 370 

a. Annualized calculation to fulfill derived demand scenarios from Brackley et al. (2006a). This table was created 

using annualized values provide by Dr. Allen Brackley (personal communication, Nov 29 2006) from the 

model used to develop derived demand estimates in Brackley et al. (2006a). The values reported in this table 

have been adjusted to include low quality material not included in the demand projections. The Limited and 

Expanded Lumber scenarios are adjusted from values provided by Dr. Brackley by 33.73 percent to include 

utility volume (14.56 percent) and grade 3 volume (19.17 percent). The Limited and Expanded Lumber 

scenarios include saw logs, cedar export, and chip volumes available from sawmill production. Footnote b in 

Table 2, page 17, Brackley et al. (2006a) states that material delivered to sawmills meets the definition of a 

number 2 saw log at least 12 feet long , so these calculations are adjusted to account for utility and grade 3 

volume. The Medium and High Integrated Scenarios developed by Brackley et al. (2006a) and presented here 

include saw logs, cedar exports, chip volumes, low-grade material, and utility. These scenarios are not 

adjusted. 

The volume adjustment of wood delivered to sawmills, as in the Limited Lumber and Expanded Lumber 

scenarios in Brackley et al (2006a), to volume of wood necessary to be offered in a timber sale requires 

several steps. First is an assessment of the distribution by species in the Tongass National Forest. The 

net volume, by percent, of growing stock on timberland in Southeast Alaska of commercial softwood 

species is as follows: 

Alaska yellow cedar = 10.02% 

Sitka spruce = 26.71% 

Western redcedar = 6.18% 

Western and Mountain hemlock = 57.09% 

The above percentages were calculated from Table 13 in van Hess (2003). 
Appendix G 

Final EIS G-9 Timber Demand

The next step is to assess what percentage of timber is in each grade by species on the ground. The 

following distribution is calculated using cruise data from thirteen timber sales distributed across the 

forest. Grades 2 and 6 are combined because some cruises were done before grade 6 (special mill) was 

implemented. 

Western hemlock grade 3: 33.8% 

Western hemlock grade 2/6: 55.8% 

Western hemlock grade 1: 6.2% 

Western hemlock grade 0: 3.2% 

Sitka spruce grade 3: 15.5% 

Sitka spruce grade 2/6: 64.7% 

Sitka spruce grade 1: 13.2% 

Sitka spruce grade 0: 6.4% 

Utility grade is not part of cruise data. Recent information indicates that 10 percent of all Sitka spruce is 

utility, and 20 percent of all hemlock is utility. By combining the information about percent of grade by 

species, the percent of standing timber by species in an average Southeast Alaska stand, and the fact 

that 10 percent of all Sitka spruce is utility and 20 percent of all hemlock is utility, the following percent of 

net volume by grade and species for standing timber on the Tongass National Forest was derived. 

The following calculation is an example of how percentages of Sitka spruce and hemlock by grade were 

calculated. The percentage of Sitka spruce in grade 3 (15.5) multiplied by the percentage of Sitka spruce 

in an average stand (26.71) yields the percentage of Sitka spruce grade 3 in an average stand (4.14 

percent). We know that ten percent of this grade 3 Sitka spruce is utility. So, 0.41 percent of Sitka 

spruce grade 3 is utility and 3.73 percent of Sitka spruce grade 3 remains (see Table G-3). The utility 

wood from all the grades for Sitka spruce add up to 2.96 percent (Table 3, any errors are due to 

rounding). 

Table G-3 

Percent of volume in an average Tongass National 

Forest stand, by grade and species. 

Species and Grade Percent of Total Volume 

Alaska yellow-cedar 10.02 

Western red-cedar 6.18 

Sitka spruce grade 3 3.73 

Sitka spruce grade 2/6 15.55 

Sitka spruce grade 1 3.18 

Sitka spruce grade 0 1.54 

Sitka spruce utility 2.96 

Hemlock grade 3 15.44 

Hemlock grade 2/6 25.49 

Hemlock grade 1 2.84 

Hemlock grade 0 1.47 

Hemlock utility 11.60 

The amount of utility in an average Southeast Alaska timber stand is 14.56 percent. The amount of grade 

3 is 19.17 percent. The total amount of low-grade material is 33.73 percent. 

The demand numbers reported by Brackley et al. (2006a) are projections of how much wood will be used 

to meet derived demand projections. Timber sales take years to process, and can be held for several 

years by the purchaser in anticipation of future needs. Timber sales must be planned and made available 

in advance of projected needs. The derived demand projections do not include increased timber sale 

volume in anticipation of increases in wood processing (such as increasing use of existing infrastructure, 

or construction of new mills). Such timber would need to be sold in preceding years to provide sufficient 

wood supply. 
Appendix G

Timber Demand G-10 Final EIS

Demand is an estimate, and translating that demand to on-the-ground sale numbers is also an estimate. 

The derived demand projections developed by Brackley et al. (2006a) are used to estimate the market 

demand for the Forest planning cycle. They are also, as noted above, an important input to the model 

(Morse 2000) that the Forest Service uses to compute the offer target or supply of timber from the 

Tongass National Forest in a given year. That procedure will be outlined in the next section. 

Development of Timber Sale Requirements to Meet Market Demand 

The new demand projections in Brackley et al. (2006a) required that the spreadsheet model outlined in 

Morse (2000) for estimating timber sale goals be modified slightly to reflect the four alternatives in 

Brackley et al.(2006a). Modification of the spreadsheet model allows continued implementation of Forest 

Service Sale Preparation Handbook direction (FSH 2409.18, R-10 Supplement 2409.18-2006-5; Ch. 

11.4), which basically states that the procedure outlined in Morse (2000) will be followed in developing 

short-term offer targets. 

The general approach of the timber sale offer model (Morse 2000) is to consider the timber requirements 

of the region’s sawmills at different levels of operation and under different assumptions about market 

conditions and technical processing capacity. These assumptions provide a basis for estimating the 

volume of timber likely to be processed by the industry as a whole in any given year. The specific steps 

in the process are outlined below. 

Volume of Timber Processed Locally. The first stage in the calculations adjusts mill capacity estimates by 

the utilization rate assumed for each of the four scenarios, and by the percent of volume expected to 

come from the Tongass National Forest. This provides an estimate of the volume of logs from the 

Tongass National Forest likely to be processed into lumber by sawmills in Southeast Alaska under the 

different scenarios. These figures are then adjusted upward to account for species and grades of timber 

that are not processed into lumber locally. Given this set of assumptions, the timber supply expected to 

be consumed in a given fiscal year is then computed. 

Inventory requirements. The second stage provides an estimate of the volume of uncut timber inventory 

to carry under different demand scenarios. As described on pages 19-20 of Morse (2000), target 

inventory levels depend on the volume expected to be processed each year and the amount of time 

needed to replenish inventory. The relationship is summarized in Morse (2000; equation 2, page 20) and 

by the timber inventory requirements in the model itself. Because the volume of timber expected to be 

processed varies by scenario, timber inventory requirements also vary from one scenario to another. 

Harvest Projections. The next step in the process is to incorporate the derived demand estimates 

developed by Brackley et al. (2006a), adjusted as shown in Table G-2.

Range of Expected Timber Purchases. By subtracting the volume under contract at the beginning of the 

year from the required inventory , the projected inventory shortfall is calculated. The low range of 

expected timber purchases is replacement for the volume harvested; the high range is the volume 

harvested plus the inventory shortfall so that the inventory requirement is met at the end of the year. 

The Fiscal Year (FY) 1999 to 2006 Department of the Interior and Related Agencies Appropriations Acts 

have included appropriations for preparing additional timber for sale to establish a three-year timber 

supply. In FY 2006, the Act states that: 

That of the funds provided under this heading for Forest Products, $5,000,000 shall be allocated 

to the Alaska Region, in addition to its normal allocation for the purposes of preparing additional 

timber for sale, to establish a 3-year timber supply and such funds may be transferred to other 

appropriations accounts as necessary to maximize this accomplishment. 

While the funding level has been different for each fiscal year, the appropriation for preparation of timber 

sales in order to establish a three year timber supply has remained constant. The reason for establishing 

a three-year supply is to give timber manufacturers in Southeast Alaska enough volume to maintain a 

viable inventory for financial integrity and to respond to market changes at their discretion. 
Appendix G 

Final EIS G-11 Timber Demand

Three-year timber supply. The annual timber supply needs from the Tongass National Forest is 

considered synonymous with the annual timber consumption (i.e., the amount that is expected to be 

harvested in a given year). To estimate the three-year timber supply, the annual consumption is 

multiplied by three years. 

Timber Pipeline. The Tongass timber pipeline was established as a process to “ramp-up” to the threeyear supply over a period of years. It takes about four years to get a project through the analysis and 

preparation process, to be ready to offer for sale. The additional average annual volume needed to meet 

the three-year timber supply in a given fiscal year is the three-year timber supply of timber inventory 

minus timber inventory requirement , spread evenly over a four-year period. 

Total Timber Sale Requirement. By taking the median between the low and high range of the volume 

expected to be purchased, and combining it with the average annual pipeline volume, the total volume 

anticipated for purchase is estimated. 

The measure of meeting the TTRA “seek to meet” and the appropriations bill “three year timber supply” is 

volume sold from the Tongass National Forest. To meet these objectives, a sufficient amount of volume 

must be offered to account for any fall-down between the volume offered and the volume sold. The final 

step in projecting the amount of volume to be purchased is to evaluate the anticipated volume that needs 

to be offered. 

Timber Sale Fall-down. Historically, there has been a difference between the volume offered and the 

volume sold from National Forest timber sales. The reluctance of purchasers to buy timber sales tends to 

increase as markets decrease and/or logging costs increase. Mason et al. (2004) examined why some 

offerings in Southeast Alaska go unsold, and concluded that the probability of a timber sale being 

successfully sold is tied to downstream markets that are inherently difficult to predict, rather than factors 

directly controlled by the Forest Service. 

Projected Offer Objectives. In an effort to project the amount of volume that needs to be offered for each 

of the scenarios, the total timber sale projection is increased to account for fall-down and litigation to 

provide a rough estimate of the volume to be offered for each scenario to meet timber sale objectives. 

Conclusion 

There have been many changes in the wood manufacturing industry in southeast Alaska in the past 

decade. Southeast Alaska’s two pulp mills and numerous sawmill facilities have closed. Remaining 

active mills operate at about 13 percent of their estimated capacity, on average. In 2006, the ratio of 

species sawn in Southeast Alaska mills was about the same as the past six years, with western hemlock 

in the lead (60 percent of total volume sawn), followed by Sitka spruce (27 percent), western red-cedar 

(11 percent), and Alaska yellow-cedar (3 percent). Between 2002 and 2006, sources of logs for local 

mills have been about two-thirds National Forest and one-third State of Alaska, with a very small 

proportion (less than one percent) from private lands. The destination for material sawn in Southeast 

Alaska is now primarily other states within the U.S. (Kilborn et al. 2004; Brackley et al. 2006b). Demand 

for Southeast Alaska wood products in historic export markets, particularly Asia, continues to be low. 

Hansen (2006) states that U.S. companies have historically jumped into the export market when the 

domestic market is down, and shifted back to the U.S. market when the domestic market improves. In 

recent years, the U.S. domestic market has been very attractive with high housing starts and strong 

prices in many forest product categories. Haynes et al. (2007) state that U.S. demand for forest products 

is varied and large. 

On the supply side, the cost of preparing stumpage for sale and delivering it to mills is generally higher 

than in Oregon and Washington, due to transportation and labor costs, decreased size of sales, 

increased fuel costs, legal and procedural challenges to federal timber sales, and more constraints on 

harvest activity on Federal lands in the interest of resource protection. The uncertainty surrounding 

Tongass National Forest sale quantities has increased the risk faced by potential purchasers and 

investors in local processing capacity. 
Appendix G

Timber Demand G-12 Final EIS

In choosing the offer level, it is important to anticipate the consequences of a “wrong” decision. In terms 

of short-term economic consequences, over-supplying the market is less damaging than under-supplying 

it. If more timber is offered than purchased in a given year, the unsold volume is still available for 

purchasing off-the-shelf or re-offered at a minimal investment. However, a significant shortfall in the 

supply of timber available for harvest in a given year can be financially devastating to the industry. 

Planning the timber program requires more than just pure economic factors. To account for delays in 

timber sale preparation, administrative appeals, and/or litigation, sufficient contingent volume must be 

included in the annual timber sale program to account for realistic fall-downs. Budget and organizational 

constraints limit the extent to which the Forest Service can respond to economic cycles and the 

associated fluctuations in timber demand. All of these factors must be considered in evaluating the 

market demand for timber and setting timber offerings. In the final analysis, planning the timber sale 

program is an exercise in professional judgment. The purpose of this paper is to identify the extent to 

which economic analysis contributes to this decision-making process. 

Acknowledgements 

This paper was improved with edits and information from Dr. Allen Brackley and Dr. Richard Haynes. US 

Forest Service Alaska Region staff at the Regional Office and the Tongass National Forest also provided 

important data. 

Citations 

Brackley, A.M.; Rojas, T.D.; Haynes, R.W. 2006a. Timber products output and timber harvests in 

Alaska: projections for 2005-25. Gen. Tech. Rep. PNW-GTR-677. Portland, OR: U.S. 

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

Brackley, A.M.; Parrent, D.J.; Rojas, T.D. 2006b. Estimating sawmill processing capacity for Tongass 

timber: 2003 and 2004 update. Res. Note. PNW-RN-553. Portland, OR: U.S. Department of 

Agriculture, Forest Service, Pacific Northwest Research Station. 15 p. 

Brackley, A.M.; Haynes, R.W. in press. Timber products output and timber harvests in Alaska: an 

addendum. Res. Note PNW-RN-xxx. Portland, OR: U.S. Department of Agriculture, Forest 

Service, Pacific Northwest Research Station. xx p. 

Brooks, D.J.; Haynes, R.W. 1990. Timber products output and timber harvests in Alaska: projections for 

1989-2010. Gen. Tech. Rep. PNW-GTR-261. Portland, OR: U.S. Department of Agriculture, 

Forest Service, Pacific Northwest Research Station. 48 p. 

Brooks, D.J.; Haynes, R.W. 1994. Timber products output and timber harvests in Alaska: projections for 

1992-2010. Gen. Tech. Rep. PNW-GTR-334. Portland, OR: U.S. Department of Agriculture, 

Forest Service, Pacific Northwest Research Station. 32 p. 

Brooks, D.J.; Haynes, R.W. 1997. Timber products output and timber harvests in Alaska: projections for 

1997-2010. Gen. Tech. Rep. PNW-GTR-409. Portland, OR: U.S. Department of Agriculture, 

Forest Service, Pacific Northwest Research Station. 17 p. 

Hansen, Eric. 2006. Global forest products markets: impacts on western forests. Western Forester 

51(3): 1-2 and 22. 

Haynes, R.W.; Brooks, D.J. 1990. An analysis of the timber situation in Alaska: 1970-2010. Gen. Tech. 

Rep. PNW-GTR-264. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific 

Northwest Research Station. 33 p. 

Haynes, Richard W.; Adams, Darius M.; Alig, Ralph J.; Ince, Peter J.; Mills, John R.; Zhou, Xiaoping. 

2007. The 2005 RPA timber assessment update. Gen. Tech. Rep. PNW-GTR-699. Portland, 

OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 212 p. 
Appendix G 

Final EIS G-13 Timber Demand

Ince, P.; Schuler, A.; Spelter, H.; Luppold, W. In Press. Globalization and structural change in the U.S. 

forest sector: an evolving context for sustainable forest management. Gen. Tech. Rep. FPLGTR-170. Madison, WI: U.S. Department of Agriculture, Forest Service, Forest Products 

Laboratory. 

Kilborn, K.A.; Parrent, D.J.; Housley, R.D. 2004. Estimating sawmill processing capacity for Tongass 

timber. Res. Note. PNW-RN-545. Portland, OR: U.S. Department of Agriculture, Forest 

Service, Pacific Northwest Research Station. 12 p. 

Mason, C.; Margolis, M.; Tsournos, P. 2004. SE Alaska timber: why do some offerings go unsold? 

Northwest Journal of Business and Economics XX(xx): 33-48. 

Morse, K.S. 2000. Responding to the Market Demand for Tongass Timber: using adaptive management 

to implement Sec. 101 of the 1990 Tongass Timber Reform Act. Manag. Bull. R10-MB-413. 

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

van Hess, Willem W.S.. 2003. Forest Resources of Southeast Alaska, 2000: Results of a Single-Phase 

Systematic Sample. Res. Paper PNW-RP-557. Portland, OR: U.S. Department of Agriculture, 

Forest Service, Pacific Northwest Res. Station. 
Appendix G

Timber Demand G-14 Final EIS

This page is intentionally left blank. 
APPENDIX H 

COMMENTS AND RESPONSES 
Appendix H 

Final EIS H-i Comments and Responses 

Appendix H 

Comments and Responses 

CONTENTS 

A. Introduction .......................................................................................................................................... H-1

Public Meetings .................................................................................................................................. H-1

Public Input......................................................................................................................................... H-1

Unique Comment Documents...................................................................................................... H-2

Form Comment Documents......................................................................................................... H-2

Comment Document Evaluation......................................................................................................... H-3

Comment Summaries and Responses............................................................................................... H-3

B. Comment Summaries and Responses................................................................................................ H-5

General Comments ............................................................................................................................ H-6

Alternatives .................................................................................................................................. H-6

Cumulative Effects ....................................................................................................................... H-8

Energy.......................................................................................................................................... H-8

Forest Plan - General................................................................................................................... H-8

Forest Plan Monitoring and Adaptive Management..................................................................... H-9

General ...................................................................................................................................... H-10

Key Issues.................................................................................................................................. H-14

Multiple Use ............................................................................................................................... H-15

Public Involvement..................................................................................................................... H-15

Restoration................................................................................................................................. H-17

Schedule .................................................................................................................................... H-17

Standards and Guidelines.......................................................................................................... H-18

Tribal Consultation ..................................................................................................................... H-18

Resource and Issue Comments ....................................................................................................... H-19

Climate and Air........................................................................................................................... H-19

Economic and Social Environment ............................................................................................ H-26

Fish and Watersheds ................................................................................................................. H-59

Geology, Soils, Karst and Caves ............................................................................................... H-71

Heritage and Sacred Sites ......................................................................................................... H-78

Lands.......................................................................................................................................... H-79

Minerals...................................................................................................................................... H-84

Recreation, Tourism and Scenery ............................................................................................. H-85

Roadless Areas and Wilderness................................................................................................ H-90

Subsistence................................................................................................................................ H-92

Timber ........................................................................................................................................ H-98

Transportation and Utilities ...................................................................................................... H-125

Wetlands .................................................................................................................................. H-129

Wildlife, Biodiversity and Plants ............................................................................................... H-129
Appendix H 

Comments and Responses H-ii Final EIS 

CONTENTS continued 

Specific Geographic Area Comments ............................................................................................ H-185

Specific Geographic Area Comments and Responses............................................................ H-185

Specific Places Identified for Protection................................................................................... H-189

C. References ...................................................................................................................................... H-194

Attachment A Letters from Agencies, Elected Officials, and Tribal Governments
Appendix H 

Final EIS H-1 Comments and Responses

Appendix H 

Comments and Responses 

A. Introduction 

The Tongass Land and Resource Management Plan Amendment Draft Environmental Impact Statement 

(EIS) and the Draft Proposed Land and Resource Management Plan were completed and mailed out 

(beginning January 4, 2007) to the 2,300 organizations and individuals on the Tongass National Forest’s 

mailing list. The document and supporting documents were also posted on the project web site 

(http://www.tongass-fpadjust.net). 

The Notice of Availability for the Draft EIS was announced in the Federal Register on January 12, 2007, 

initiating the 90-day formal public comment period. The 90-day comment period was subsequently 

extended from April 12 to April 30, 2007 because severe weather in Southeast Alaska caused some of 

the public meetings/hearings to be rescheduled and delayed some of the Forest’s Tribal consultation 

activities. 

This appendix presents a summary of the comments received during the public comment period and 

provides the Forest Service’s responses to these comments. In addition, Attachment A provides copies 

of the letters received from government agencies, elected officials, and tribal governments. 

Public Meetings 

Twenty-five public meetings were held to elicit public comment over this period. These meetings included 

23 meetings in communities located throughout Southeast Alaska, a meeting in Anchorage, and an 

electronic public meeting held on the internet (Table H-1). These meetings included both open houses 

and hearings. The open houses were informal meetings where participants could review maps and other 

information, and ask questions or discuss the Draft EIS or Forest Plan with Forest Service 

representatives. The hearings were formal opportunities for participants to provide oral testimony on the 

Draft EIS. A total of 204 people provided oral testimony at these hearings, with several people testifying 

at more than one hearing. 

Public Input 

The Forest Service received 84,509 separate pieces of input during the public comment period. These 

pieces of input, referred to here as “comment documents,” were provided in a number of different forms, 

including email, letter, fax, public testimony, and online comment form (http://www.tongass-fpadjust.net). 

As part of the initial comment evaluation process, comment documents were initially divided into unique 

comment documents and form comment documents. 

A comment document is considered a form document when copies of the same document (letter, email, 

comment form, etc.) are submitted by five or more people. Form comment documents are typically 

generated by special interest organizations that encourage their members to write, and provide a written 

template for them to use. In some cases members are encouraged to add their own personal message to 

the template. 
Appendix H 

Comments and Responses H-2 Final EIS 

Table H-1. 

Locations and Dates of the Public Meetings 

Community Location Date 

Anchorage Loussac Library Assembly Chamber 3/30/2007 

Angoon Community Center 4/13/2007 

Coffman Cove City Hall 2/20/2007 

Craig Craig Community Hall 3/1/2007 

Edna Bay Community Building 3/21/2007 

Gustavus School 3/14/2007 

Haines Borough Chambers 3/6/2007 

Hoonah Ranger District 3/7/2007 

Hydaburg City Hall 2/27/2007 

Internet Meeting http://www.tongass-fpadjust.net/ 3/22/2007 

Juneau Centennial Hall 2/27/2007 

Kake Community Hall 3/21/2007 

Ketchikan Discovery Center 3/1/2007 

Naukati School Commons 2/21/2007 

Petersburg City Council Chamber Hall 2/22/2007 

Point Baker Community Building 3/12/2007 

Port Protection Community Building 3/22/2007 

Saxman Saxman Community Center 3/13/2007 

Sitka Sheet'ka Kwaan Naa Kahidi (Community House) 2/22/2007 

Skagway City Chambers 3/5/2007 

Tenakee Springs Community Hall 3/14/2007 

Thorne Bay City Hall 2/22/2007 

Whale Pass Library 2/23/2007 

Wrangell Nolan Center 3/20/2007 

Yakutat High School Auditorium 2/28/2007 

Unique Comment Documents 

Approximately 2.5 percent (2,102) of the comment documents received were classified as unique 

comment documents. The vast majority of these unique documents (1,898) were received from 

addresses in the U.S. Eight unique comment documents were received from Canada, with one apiece 

from Great Britain, France, Switzerland, and Japan. The remaining 192 unique comment documents 

were received with no address information. 

Alaska residents submitted 620 unique comment documents, including 200 comments submitted as 

testimony at public hearings. These comment documents accounted for approximately 29 percent of the 

total unique comment documents received. The next three most frequently represented states were 

Washington (180 comment documents, 8 percent), Florida (130 comment documents, 5 percent), and 

Oregon and Pennsylvania (105 comment documents each, 5 percent each). 

The total number of unique comment documents received in response to this Draft EIS (2,102) is 

approximately 70 percent of the number (2,983) submitted during the public comment period for the 2002 

Draft Supplemental EIS (SEIS) for Wilderness Recommendations on the Tongass (USDA Forest Service 

2003). 

Form Comment Documents 

The vast majority (approximately 97.5 percent) of the comment documents were form responses. 

Thirteen different form comment documents were identified, with the number of copies ranging from 5 to 

43,216. 

Approximately 95 percent of the form comment documents received were from addresses in the U.S. 

Form comment documents were received from all 50 states. Residents of California accounted for 
Appendix H

Final EIS H-3 Comments and Responses

15,600 (19 percent) of the form comment documents sent from within the U.S. The next three most 

frequently represented states were New York (6,220 comment documents, 8 percent of U.S. form 

comment documents), Florida (4,330 comment documents, 5 percent), and Illinois (3,430 comment 

documents, 4 percent). Alaska residents submitted 350 form comment documents, less than 0.5 percent 

of the total received from U.S. residents. 

Form comment documents were also received from 89 other countries. Approximately 15 percent of the 

form comment documents from other countries were from Canada (600 comment documents). The next 

three most frequently represented countries were Great Britain (540 comment documents, 13 percent of 

non-U.S. form comment documents), Australia (280 comment documents, 7 percent), and France (120, 3 

percent). In addition, 1,130 form comment documents were submitted without any address information. 

The large number of documents and locations involved reflects the importance of the Tongass National 

Forest at a national and international level. It also reflects the membership and geographic reach of the 

organizations that prepared the original written templates, as suggested by the concentration of form 

comment documents from addresses in California and New York. 

The total number of form comment documents received in response to this Draft EIS (82,407) is less than 

half the number of form comment documents (174,000) submitted during the public comment period for 

the 2002 Draft SEIS (USDA Forest Service 2003). 

Comment Document Evaluation 

Public comments were submitted to the Forest Service via online comment form, email, U.S. Mail, as 

testimony at a public hearing (in-person or online), and via hard copy comment form. Approximately 97.5 

percent of the total comment documents (82,400) were sent via email. This percentage was higher for 

the form comment documents with 99.3 percent sent via email. Email accounted for 29 percent (about 

600 messages) of the unique comment documents. More than half (59 percent, 1,220 letters) of the 

unique comment documents were sent via U.S. Mail. 

Each comment document was assigned a unique identifier (number) upon receipt and entered into a 

database. Documents were numbered in the order received by the comment management team. 

Summary demographic information for each response was entered into a database, including the name 

and address of the comment author (when provided), the type of comment author (individual, government 

agency, environmental organization, etc.), and the method of transmittal (online comment form, email, 

U.S. Mail, public hearing testimony, hard copy comment form). 

Members of the comment management team read each comment document and identified the comments 

within each document. Comments were identified for one copy of each form comment document. 

Comments were defined for the purposes of this initial identification phase as a coherent segment of text 

that stood alone as a suggestion, idea, request, or critique. Comments were delineated on a hard copy of 

the comment document and each comment was assigned a number. The comment number was entered 

into a database and assigned to a coding category. Up to three key words or terms that further 

characterized the comment, along with additional notes, were entered in separate fields in the database, 

as appropriate. The initial coding categories corresponded for the most part with the resource areas 

addressed in the Draft EIS. A copy of each coded comment document was scanned and saved as a 

unique PDF file. 

Comment Summaries and Responses 

The database allowed the comments to be sorted by coding category and key words. Resource 

specialists and Forest Service managers reviewed all the comments and consolidated the individual 

comments into logical comment summaries, developed responses to the comment summary, and revised 

the analysis or text in the Final EIS, as appropriate. The comment summaries and responses are 

presented in Section B of this appendix. Some comment summaries represent a concern raised once; 

others represent a concern, opinion, or preference that was repeated in a number of different comments. 

This is generally indicated at the beginning of each comment summary. 
Appendix H 

Comments and Responses H-4 Final EIS 

The comment identification process erred on the side of inclusion and more than 5,500 individual 

comments were identified and coded. Many of the identified comments consisted of statements of 

opinion or preference, and did not require a factual response. Comment summaries and responses are, 

however, presented in Section B for a number of these types of comments, primarily to provide 

information to the public or clarify popular misconceptions. 

In accordance with 40 Code of Federal Regulations (CFR) 1503.4, the Forest Service generally 

considered responding in five basic ways to the substantive public comments identified in the following 

sections. 

1. Modifying alternatives. 

2. Developing and analyzing alternatives not given serious consideration in the Draft EIS. 

3. Supplementing, improving, or modifying the analysis that the Draft EIS documented. 

4. Making factual corrections. 

5. Explaining why the comments do not need further Forest Service response. 

Review of the public comments resulted in Alternative 1 being modified between the Draft and Final EIS 

with all Inventoried Roadless Areas being removed from the suitable land base under this alternative. 

After substantial consideration, it was decided that the range of alternatives was sufficient and captured 

the effects of all possible new alternatives. The results of the public involvement and comment process 

did, however, lead to a number of improvements, clarifications, and updates between the Draft and Final 

EIS. These changes are identified where applicable in the following section (Section B). 

The following section presents the comments and responses developed by the resource specialists and 

Forest Service managers that comprise the Interdisciplinary Team for this project. Copies of the 

comment documents received during the public comment period from government agencies, elected 

officials, and tribal governments are presented in Attachment A. All of the responses received are 

available for review in the project planning record. 
Appendix H

Final EIS H-5 Comments and Responses

B. Comment Summaries and Responses 

This section of the Appendix presents a summary of all of the substantive comments, written or oral, 

received during the public comment period for the Draft EIS and provides Forest Service responses to 

these comments. The comments and responses are organized and presented in the following categories: 

General Comments 

♦ Alternatives 

♦ Cumulative Effects 

♦ Energy 

♦ Forest Plan – General 

♦ Forest Plan Monitoring and Adaptive Management 

♦ General 

♦ Key Issues 

♦ Multiple Use 

♦ Public Involvement 

♦ Restoration 

♦ Schedule 

♦ Standards and Guidelines 

♦ Tribal Consultation 

Resource and Issue Comments 

♦ Climate and Air 

♦ Economic and Social Environment 

♦ Fish and Watersheds 

♦ Geology, Soils, Karst and Caves 

♦ Heritage and Sacred Sites 

♦ Lands 

♦ Minerals 

♦ Recreation, Tourism and Scenery 

♦ Roadless Areas and Wilderness 

♦ Subsistence 

♦ Timber 

♦ Transportation and Utilities 

♦ Wetlands 

♦ Wildlife, Biodiversity and Plants 

Specific Geographic Area Comments 

♦ Specific Geographic Area Comments and Responses 

♦ Specific Places Identified for Protection 
Appendix H 

Comments and Responses H-6 Final EIS 

General Comments 

The General Comments section is divided into the following subsections: 

♦ Alternatives 

♦ Cumulative Effects 

♦ Energy 

♦ Forest Plan – General 

♦ Forest Plan Monitoring and Adaptive Management 

♦ General 

♦ Key Issues 

♦ Multiple Use 

♦ Public Involvement 

♦ Restoration 

♦ Schedule 

♦ Standards and Guidelines 

♦ Tribal Consultation 

Alternatives 

Comment: Many comments expressed support or opposition for one or more of the seven 

alternatives. Support for Alternative 1 which would provide the lowest level of timber harvest and 

the highest level of roadless area protection was most prevalent. At the other end of the spectrum 

many respondents expressed support for Alternative 7, which provided the highest level of timber 

output and would support a fully integrated timber industry. 

Response: The seven alternatives evaluated in the Final EIS present a range of reasonable alternatives 

developed in response to the three significant issues identified for this project. Clearly, people disagree 

on what the appropriate mix of timber harvest and roadless area protection should be on the Tongass. 

They also disagree about the risk the different alternatives pose to wildlife viability and other potentially 

affected resources. 

Comment: Some respondents felt that the range of alternatives was inadequate. Some believed 

that Alternative 1 had too much old growth logging and road building, or that no old-growth 

should be cut. Others felt that Alternative 7 might not provide an adequate amount of timber to 

sustain an integrated timber industry in Southeast Alaska and should be modified to eliminate 

old-growth reserves (OGRs), roadless area protections, beach buffers, and Class III stream 

riparian buffers. Some respondents were opposed to any timber harvest, while others 

commented that too much land is being left undeveloped and at least 1.5 million acres were 

needed for timber production and pointed out that this would still leave over three-quarters of the 

old-growth forest undeveloped. 

Response: Alternative 1 was modified between the Draft and Final EIS to reduce the amount of logging 

and road building. All Inventoried Roadless Areas were removed from the suitable land base, as were a 

number of areas of concern, such as Kuiu Island. The Forest has an obligation under the Tongass 

Timber Reform Act (TTRA) to seek to meet the demand for timber. Alternative 7 has an adequate land 

base to exceed the highest levels of potential future timber demand as identified by McDowell Group 

2004 and Brackley et al. 2006. Alternative 7 does not include OGRs or 1,000-foot beach buffers. 

Alternative 7 (as modified in the Final EIS) does not include OGRs, 1,000-foot beach buffers, or buffers 

on Class III streams. 
Appendix H

Final EIS H-7 Comments and Responses

Comment: A number of comments stated that the analysis was too narrowly focused on timber 

demand resulting in an inadequate range of alternatives. These respondents felt that the Draft EIS 

should have examined alternate desired conditions for the Forest and a new array of goals and 

objectives. Other items such as designation of new wilderness areas, road management options, 

the growth in recreation demand, and other OGR options were cited as examples of topics that 

should have been considered in more detail. Some felt that a full revision of the Forest Plan was 

necessary. 

Response: This analysis effort is being conducted in response to the August 2005 Ninth Circuit Court of 

Appeals Court Decision which directed the Forest to take a second look at timber demand, the 

alternatives considered in response to timber demand, and cumulative effects. To respond to the Court in 

a timely manner, the decision was made to limit the scope of the analysis and amend the Forest Plan. 

The suggested topics were covered in the 1997 Plan Revision that this Amendment brings to completion. 

Chapter 1 of the Final EIS explains the Purpose and Need for the analysis and describes the history of 

forest planning on the Tongass. Forest planning is a dynamic process with periodic reviews occurring to 

assess the need for additional changes. 

Comment - Concern was expressed that an alternative that maximized timber harvest within the 

roaded land base was not developed. 

Response: Alternative 1 was modified for the Final EIS to remove all Inventoried Roadless Areas from 

the suitable land base. The timber output level associated with Alternative 1 is intended to represent the 

level of timber harvest that has occurred over the last several years. While it is true that more timber 

might be harvested from this land base, it is unclear if it would truly be sustainable. As the land base 

decreases, standards and guidelines that coincide and other spatial issues become more problematic. 

While some feel that more intensive management on a smaller land base is appropriate, others have 

concerns about issues such as wildlife habitat connectivity and water quality. Some analysis has been 

done regarding the maximum amount of timber that could be harvested from the roaded land base, but a 

separate alternative was not analyzed in detail. 

Comment: Concern was expressed that a preferred alternative was not identified in the Draft EIS. 

Response: As noted in the cover letter that accompanied the Draft EIS, the Forest Supervisor for the 

Tongass National Forest, chose not to identify a preferred alternative for the Draft EIS because he hoped 

that public input in response to the Draft EIS would help the forest make a more informed decision. The 

Forest Service wanted to get comments regarding the merits of all the alternatives and ideas about 

possible combinations of alternatives that would be acceptable. The Forest Supervisor and other 

members of the planning team felt that identifying one of the alternatives as the preferred in the Draft EIS 

could be counterproductive and might lead to polarization rather than a collaborative discussion. 

Comment: Some felt they could only support an alternative that gave great emphasis to 

conserving the forest for future generations rather than highly weighting immediate extractive use 

of the forest. 

Response: All the alternatives in the Final EIS are judged to be sustainable and conserve the forest for 

future generations. 
Appendix H 

Comments and Responses H-8 Final EIS 

Cumulative Effects 

Comment: Several comments urged that the cumulative effects of past logging, particularly on 

private lands, be taken into account when considering future timber harvest. 

Response: Cumulative effects were one of the deficiencies of the 1997 Final EIS identified in the August 

2005 decision issued by the U.S. Court of Appeals for the Ninth Circuit. As noted in the cover letter that 

accompanied the Draft EIS, considerable work was completed for this analysis to acquire information on 

past timber activities conducted on lands managed by the State of Alaska and Alaska Native 

Corporations. This information is included in the cumulative effects discussions presented by potentially 

affected resource in the EIS and supplements the extensive cumulative effects analysis that was 

completed for the 1997 planning effort. 

Energy 

Comment: One comment noted that as fuel and other energy costs continue to increase there will 

be increased interest in wood products and hydroelectric projects on the Tongass. These things, 

the comment noted, will help reduce the region’s dependence on fossil fuels. Another comment 

expressed support for using wood waste and low value material as fuel and cited the current 

project in Craig as an example that should be identified in the Final EIS.

Response: Biofuel and hydroelectric projects do have the potential to reduce fossil fuel consumption, as 

noted in the Final EIS. The wood burning boiler installed by the community of Craig to heat school 

buildings and a recreation facility is identified in the Economic and Social Environment section of the EIS 

as an example of one of several developments that hold future promise for the timber industry in 

Southeast Alaska. As noted in the EIS, several other communities have also shown interest in this type 

of system 

Comment: Several comments stated that the site for the airport identified in the Kootznoowoo 

Wilderness should be on the EIS maps. These maps should also show prospective hydroelectric, 

wind, tidal, and geothermal energy sites, as well as native allotments. 

Response: This Plan Amendment responds to a narrow set of issues defined by the Ninth Circuit Court 

and to some additional issues identified in the 5-year Plan Review. These maps are not intended to 

illustrate all aspects of Forest resources. However, the Angoon Hydroelectric Project will be included in 

the Transportation and Utility Systems LUD on the Forest Plan map. 

Forest Plan - General 

Comment: Some comments stated that the Tongass National Forest should be divided into 

sections or different units for various reasons and each area should be managed separately, 

taking into consideration the uniqueness of each area or applicable laws. 

Response: The Land Use Designations (LUDs) identified in the current and proposed Forest Plans 

consider the uniqueness of areas and allow for the tailoring of management direction to match the 

characteristics of each area. The LUDs take into account all applicable laws and regulations, including 

TTRA, the Alaska National Interest Land Conservation Act (ANILCA), and Wilderness designations by 

Congress. 

Comment: One respondent felt the Forest Plan should be specific to each separate island or 

appropriate island-groupings, with unique management plans and separate standards and 

guidelines applied to each island or island-grouping. 
Appendix H

Final EIS H-9 Comments and Responses

Response: Forest planning takes place at two levels: 1) programmatic planning, as found at the Forest 

Plan level, and 2) project-specific planning that addresses particular site-specific projects, such as 

proposed timber sales or recreation developments. Intermediate planning as proposed in this comment is 

beyond the scope of this analysis. The Forest Service normally evaluates specific projects at the 

landscape assessment or site-specific level during Forest Plan implementation. Nothing precludes the 

Forest Service from applying adaptive management techniques based on appropriate analysis whether at 

the smaller landscape or project level, or at the level represented by the Forest Plan. 

Comment: Concern was expressed that the Experimental Forest LUD should not be classified as 

a Development LUD but instead should be in the Natural Setting LUD group because of the 

restrictions to development. 

Response: Development and Natural Setting are broad categories that are useful for comparing LUD 

designations in alternatives. The Experimental Forest LUD may be a good example of one that is 

somewhere in between these two categories. 

Comment: Some respondents felt that a separate LUD was needed for customary and traditional 

uses. Others asked for an economic zone around certain native communities so that their needs 

would be recognized and have highest priority in those areas. 

Response: Traditional and subsistence uses are widespread and often compatible with other uses and, 

as a result, the current and proposed Forest Plans emphasize the importance of these uses across the 

Forest on most lands rather than identify certain zones. Maps of community use areas were considered 

in alternative development and determination of effects (see the Subregional Overview and Communities

section of the EIS). 

Forest Plan Monitoring and Adaptive Management 

Comment: Numerous comments were received regarding the use of adaptive management. Most 

generally accepted or supported adaptive management but advised caution with respect to the 

potential for misuse. Others expressed concern over the use of adaptive management and 

assumed that the application of adaptive management techniques would mean less protective 

measures for a particular resource. Concern was also expressed that there needed to be a 

monitoring program in place with adequate funding. 

Response: Site-specific projects or activities that implement adaptive management are typically applied 

and reviewed at the project level, though some may be applied Forest-wide. The Forest Plan monitoring 

program considers adaptive management. 

Comment: One comment noted that the information needs for the Conservation Strategy 

identified in Appendix B to the 1997 Forest Plan were presented as a static list of studies that were 

priorities in 1997 with no mechanism that allowed this list to evolve over time. The comment 

noted that funding for research and monitoring is limited and stated that Appendix B to the 

amended Forest Plan needs to incorporate a “dynamic, well-defined process to identify and 

prioritize information needs, and compare results against original hypotheses.” 

Response: Appendix B of the Final Proposed Forest Plan has been updated to better reflect the ongoing 

nature of pursuing new information and the fact that many agencies, academics, and others are involved 

in this process. The appendix also acknowledges that coordination between different agencies and 

researchers is important. 
Appendix H 

Comments and Responses H-10 Final EIS 

Comment: Many general comments on Forest Plan monitoring were received. Identified concerns 

included issues related to adaptive management, evaluation needs and working with cooperative 

agencies. Some comments were concerned about the overall ability of the Forest to fund 

adequate and appropriate monitoring. 

Response: The Monitoring plan for the Final Proposed Forest Plan was extensively edited from the Draft 

EIS. These changes reflect these issues in light of declining budgets while maintaining a robust 

monitoring plan that is adaptable and serves the needs of the Forest Plan. 

General 

Comment: One respondent felt that the Draft EIS failed to adequately scope and analyze the 

effects of emergencies and natural disasters. 

Response: The potential effects of emergencies and natural disasters are beyond the scope of this 

analysis. It may, however, be noted that the Forest Service has emergency procedures in place to deal 

with these types of events. These measures include coordination with other state and federal agencies. 

Comment: Some respondents felt that the Forest Plan objectives were becoming more general 

and vague. They suggested that the objectives be rewritten as narrowly defined, precise, and 

measurable statements. One respondent was particularly concerned about the removal of 

specific trail construction targets, which are expressed in miles of new trail in the existing Forest 

Plan. 

Response: Some of the objectives were edited for clarity in the Proposed Forest Plan. In the past, 

objectives were often expressed as targets in discrete, measurable units, such as numbers of acres, 

structures, or miles. This often resulted in a disconnection between the broader goals the Forest Plan is 

intended to accomplish and these counts of acres, structures, or miles. These types of objectives also 

failed to take into account changes in budget from year-to-year. 

Comment: Concern was expressed that changes to Research Natural Areas and Experimental 

Forests might preclude the State from exercising its wildlife management responsibilities. In 

particular concern was expressed about the required approval of routine activities by the Director 

of the Forest Service’s Pacific Northwest (PNW) Research Station. Reference was made to 

various Memorandums of Understanding (MOUs) that recognize the State’s responsibilities for 

wildlife management. 

Response: The Forest Service recognizes the State’s responsibilities for wildlife management. 

Coordination will be needed between the State, the PNW Research Station, and the affected Ranger 

Districts to ensure that each can fulfill its responsibilities. 

Comment: One respondent wanted the Forest Plan to recognize that commercial ventures for 

raising forest products are a legitimate and authorized use of the National Forest. They also 

wanted the Plan to allow for production of traditional and customary food stocks in commercial 

quantity in wilderness areas. 

Response: Commercial ventures such as this can be considered on a case-by-case basis. There are 

too many variables related to the type of venture and the location to make such a broad statement in the 

Forest Plan. In general, we do not feel that commercial ventures such as this are appropriate in 

designated Wilderness though such proposals could be examined through the special use permitting 

process. 
Appendix H

Final EIS H-11 Comments and Responses

Comment: One comment recommended that the Forest Service prohibit all pesticide use on the 

Tongass. Another comment expressed opposition to “area pesticide spraying” and stated that 

herbicide spraying should “not be used in case of human health emergencies.” Another comment 

expressed a general concern about herbicide use. 

Response: The Forest Service acknowledges the concerns expressed regarding pesticide use, but we 

are not willing to ban all use on the Tongass. Pesticide use is a tool that needs to be carefully evaluated 

on a case-by-case basis with the appropriate site-specific analysis, including public comment. 

The Tongass does not use herbicide for Forest management. Although it is possible that it may be 

needed to control invasive species in the future, there are no plans currently to do so. Any plans for 

herbicide use would require a separate National Environmental Policy Act (NEPA) analysis. 

Comment: A number of comments stated that the Draft EIS was flawed and recommended that a 

revised or Supplemental Draft EIS be issued. Various reasons were cited including the Forest 

Service’s failure to conduct an Analysis of the Management System (AMS), complete the 

Conservation Strategy Review process initiated in 2006, disclose and respond to scientific 

opinion that opposed the proposed action, fully disclose when uncertainty exists, and include 

important information in the Draft EIS. 

Response: Resource-specific and procedure-related concerns are addressed in detail elsewhere in this 

comment response volume. Specific concerns about the conservation strategy are, for example, 

addressed under Wildlife and Biodiversity. Detailed critiques of the timber demand projections developed 

for this Amendment process are disclosed and addressed under Timber Demand in the Economic and 

Social Environment section. The AMS is addressed in response to the following comment summary. 

The Forest Service believes that the Draft EIS fully disclosed and responded to conflicting scientific 

opinion and identified areas where there is known uncertainty beyond that typically associated with all 

types of scientific impact analysis. These discussions have been expanded in the Final EIS, where 

appropriate, and this comment response volume discloses and responds in detail to the opposing 

scientific and other opinions provided by individuals, organizations, and others in response to the Draft 

EIS and Proposed Forest Plan. 

In addition, we believe that the Draft EIS adequately informed the public about the alternatives considered 

and the potential effects so that informed comments could be received. The comprehensive Forest Plan 

Adjustment website established for this project (www.tongass-fpadjust.net) made information available to 

interested parties as the analysis progressed and provided the opportunity for the public to provide 

feedback and input throughout the process. 

Comment: Some respondents felt that the Forest Plan Amendment process was flawed because 

no new AMS was prepared. One comment stated that the “primary goal of the AMS is to analyze 

Forest resource supply and demand and determine whether current management direction should 

change in response to these conditions.” The comment argued that an AMS is necessary to

determine which lands are suitable for timber production, considering whether the land has been 

withdrawn by Congress or administratively, can be reforested within 5 years, and if irreversible 

resource damage would occur if timber is harvested.

Response: The Forest completed the various steps in an AMS and an updated AMS is in the project 

planning record. The suitability determination was the most complete analysis done anywhere to our 

knowledge. Building on past efforts, including the recent SEIS (USDA Forest Service 2003) which 

completed an AMS for all roadless and wilderness areas, we used GIS data to map all areas withdrawn 

by Congress or administratively. We then mapped unstable areas, sensitive riparian areas, and areas 

with soil concerns and removed these areas from the suitable land base. Each remaining area of 

productive forest land was subsequently divided into logical logging settings and individually evaluated 
Appendix H 

Comments and Responses H-12 Final EIS 

using existing NEPA analyses, aerial photographs, LiDAR, LANDSAT, GIS data, and local knowledge. 

Those areas that appeared to have problems were flagged and risk factors were assigned based on the 

problems that were identified. Areas considered unsuitable were identified. Logging engineers then 

identified individual logging settings and the type of yarding methods and road access that would be 

needed to log each unit. They also identified the silvicultural system that would be most likely to be used. 

This process took several months and resulted in the best estimate of timber supply we have ever had, 

both for total supply and for that portion of the total supply that will likely be economical to harvest. The 

demand for Tongass timber was identified in the timber demand analysis prepared by the PNW Research 

Station (Brackley et al. 2006a). 

Comment: A number of comments stated that the Forest Service should use the “best available 

science” or “sound science” in the EIS analysis. A number of these statements were made with 

respect to the existing Conservation Strategy Standards and Guidelines, which some argued are 

not based on sound science. Others stated that the Final EIS should fully incorporate the findings 

of the 2006 Conservation Strategy Review. Others made general statements that some of the 

impact analyses presented in the Draft EIS were not based on scientific analysis, but were just 

speculation or opinions. 

Response: Specific concerns about the scientific basis of particular analyses or components of the 

Forest Plan are addressed in detail elsewhere in this comment response volume. Specific concerns 

about the existing Conservation Strategy Standards and Guidelines are, for example, addressed under 

Timber. Concerns about the Conservation Strategy Review are addressed under Wildlife and 

Biodiversity. 

It is not possible to provide a specific response to general assertions that the Draft EIS analysis is 

speculative or just opinions, but, in general, the Forest Service believes that the Draft EIS employs the 

best available science, to the extent possible. The Draft EIS was reviewed by scientists at the PNW 

Research Station and additional analysis, information, and citations were added to the Final EIS based on 

the results of this review and comments from the public and other agencies. 

Comment: One respondent felt that using total development LUD acres in alternative descriptions 

and effects analyses overstates potential impacts as only a small percentage of the development 

LUDs would be developed or otherwise impacted. 

Response: The distribution of the Forest by LUD group (Intensive Development, Moderate 

Development, Natural Setting, and Wilderness) provides a general basis for comparison between 

different alternatives. Other information, such as suitable acres, provides another basis of comparison 

about the relative impacts of each alternative. 

Comment: Many respondents were opposed to road construction, which was often mentioned in 

connection with clearcutting. Road-related concerns often centered around impacts to wildlife 

habitat and reductions in roadless character. 

Response: The alternatives feature a wide range of road construction levels and potential effects to 

roadless areas. Alternative 1 was modified for the Final EIS to greatly reduce the road construction miles 

and eliminate effects to Inventoried Roadless Areas. However, even in this alternative some road 

construction is needed to access lands suitable for timber harvest. 
Appendix H

Final EIS H-13 Comments and Responses

Comment: Several comments urged that the Tongass Plan Implementation Team papers be 

reviewed and incorporated in the Final EIS, as necessary. 

Response: These papers have been reviewed and incorporated in the Final EIS, as appropriate. 

Comment: Some respondents expressed interest in greater protection of the coastline and 

coastal valleys then occurred in the past. 

Response: The 1997 Forest Plan added extensive protection measures such as the adoption of 1,000-

foot beach and estuary buffers. All alternatives, with the exceptions of Alternative 7, retain these 

important features. Alternative 7 has a 1,000-foot estuary buffer and a 500-foot beach buffer. 

Comment: One comment expressed concern that the Draft EIS said the 5-Year Forest Plan Review 

was part of the purpose and need for the Amendment despite the fact that the Forest Supervisor 

concluded at the end of the 5-Year Review that the plan did not need to be revised at that time. 

Response: The 5-year review pointed out many areas that needed updating but that overall there was 

no reason to begin a full scale revision of the Forest Plan. With the need to respond to the Court order of 

August 2005, it seemed like an excellent opportunity to address some of those items from the 5-year 

review at the same time we responded to the Court. 

Comment: One comment noted that a reduction in timber harvest in temperate zones results in 

the transfer of the needed harvest to tropical areas. 

Response: It seems reasonable to assume that demand for timber will be met and, provided demand 

remains constant or increases, a reduction in harvest in one area will likely lead to an increase in harvest 

somewhere else. The Forest Service is required to seek to provide a supply of timber from the Tongass 

that meets market demand. The Proposed Forest Plan alternatives address a range of potential demand 

estimates. None of the proposed alternatives are expected to result in a transfer of harvest that would 

otherwise occur on the Tongass to other regions of the world. 

Comment: One comment requested that the Final EIS explain the relationship between the 

Amendment and previous planning documents. Concern was also expressed about the statement 

on page 2-8 of the Draft EIS that: “The individual alternative descriptions on the following pages 

only identify items that are not consistent with the current Forest Plan or Proposed Forest Plan.” 

Several respondents found this confusing and were concerned that this would result in 

information not being fully disclosed. 

Response: The Final EIS and Record of Decision (ROD) will clarify this relationship. In summary, the 

amended Forest Plan and ROD will be stand alone documents giving management direction for the 

Tongass. Previous analyzes, such as the 1997 Final EIS, are tiered to and will continue to be used at the 

project level. 

The alternative descriptions presented in Chapter 2 of the EIS focus on the main changes from the 

current Forest Plan to the Proposed Forest Plan, as noted in the above quote. The entire Proposed 

Forest Plan, which includes all the unchanged elements of the current Forest Plan, as well as the 

proposed changes, was published with the Draft EIS. A revised version of the Proposed Forest Plan has 

also been published with the Final EIS. 
Appendix H 

Comments and Responses H-14 Final EIS 

Comment: One respondent felt that the Draft EIS should discuss in more detail the laws related to 

the management of the Tongass and other national forests. They stated that “these statutes and 

their current applicability should be more clearly referenced in the (Forest Plan) and the Draft 

EIS.” 

Response: The Draft and Final EIS documents discuss and reference the laws that are most directly 

applicable to this Forest Plan Amendment. These laws include TTRA, the National Forest Management 

Act, and ANILCA. There are, however, many other laws that have a direct bearing on the management of 

national forests, as well as implementing regulations and court decisions interpreting these laws. These 

laws, regulations, and court decisions are not specifically discussed in the EIS, but additional general 

information is available on the Forest Service’s web site (www.fs.fed.us). 

Key Issues 

Comment: There were several comments regarding the three key issues. Some thought that 

issues one and three were very much the same. Other comments identified additional issues that 

the comment authors thought should be identified as separate key issues. Subsistence, salmon 

conservation, and the social and economic well-being of Southeast Alaska communities were 

proposed as other key issues. 

Response: Key issue one emphasizes the protection of high value roadless areas from development. 

Key issue three emphasizes the protection of wildlife habitat and biodiversity. While the two issues are 

certainly linked, they are two different issues. The key issues for the EIS were developed based on a 

review of the public input received prior to publication of the Draft EIS and are directly related to the 

purpose and need for the Forest Plan Amendment process. This issue identification process is discussed 

in the Public Issues section of Chapter 1 of the EIS. The other resources and resource uses identified in 

the above comment summary are also important aspects of the Forest Plan and are addressed in the 

proposed Forest Plan and the EIS, as appropriate. 

Comment: One comment stated that Allowable Sale Quantity (ASQ) was not an indicator of a 

viable economy. They felt that Southeast Alaska could have a viable economy without timber 

harvest. 

Response: The ASQ is not used in the EIS as an indicator of a viable economy. Rather it is a measure 

of the maximum potential harvest that could be achieved under each alternative. Definitions of viable 

vary, but based on recent trends it appears that population and employment in Southeast Alaska has 

declined slightly and stayed relatively the same, respectively, despite relatively large declines in timber 

harvest over the past decade and more. Other indicators suggest that some communities have been 

more negatively affected by this decrease than others (see the Subregional Overview and Communities

section in the EIS). 

Comment: One comment requested that the description of Key Issue 2 be revised as follows 

(underlined words to be added): 

The Tongass National Forest needs to provide a sufficient economic timber supply to meet 

market demand and help maintain a vibrant, diverse economy” 

The comment defined “economic” timber as timber that a purchaser can harvest at a profit. 

Response: The description of Key Issue 2 presented in the Draft EIS summarizes the issue adequately 

and remains unchanged in the Final EIS. Timber demand and concerns regarding timber supply are 

discussed in more detail under Timber Demand in the Economic and Social Environment section of this 

appendix. 
Appendix H

Final EIS H-15 Comments and Responses

Multiple Use 

Comment: Many respondents talked about the importance of multiple use in guiding future 

management of the Tongass. A balanced approach to managing the Tongass was a common 

theme. But there were two distinct perspectives. Some felt that the multiple use concept 

supports the idea of a large timber industry and higher levels of timber harvest. They often 

mentioned the relatively small area of the Tongass open to timber harvest and stated that these 

lands should be managed intensively. Other comments discussed the idea of multiple use in the 

context of the various other uses found on the Tongass. They felt that timber harvest was 

emphasized too much and, when done at a large scale, was not compatible with other uses. 

Response: Each alternative in the Final EIS represents the concept of multiple use by incorporating the 

full spectrum of land uses, from designated wilderness to lands emphasizing timber management or 

mineral extraction. Each alternative balances these uses differently and the range of alternatives covers 

the various points of view expressed in the comments. 

Comment: One comment argued that the “multiple use” concept is: “a fancy way of (bypassing) 

the trust responsibility of protecting the habitat” and characterized this concept as a “popular 

political maneuver to try to please everyone a little, and still damage the habitat by allowing tree 

cutting so roads can be built without taxpayer expense.” 

Response: Multiple use is required by law (the Multiple Use-Sustained Yield Act of 1960). Changing this 

policy would require an act of Congress and is beyond the scope of this analysis. The Forest Service 

disagrees with this characterization of the application of the multiple use process. 

Comment: Some felt that this Forest Plan Amendment should not decrease the land area open to 

commercial uses such as logging and mining. A number of comments cited ANILCA as indicating 

that no more restrictions would be put into place. 

Response: The Final EIS looks at a wide range of alternatives built around the issue of timber 

harvesting. Three alternatives feature a reduced land base available for logging, two alternatives would 

increase the lands available, and the remaining two would maintain the current land base. No major 

changes to mining opportunities are proposed. 

Public Involvement 

Comment: Some respondents had suggestions for how the public meetings on the Draft EIS 

could have been conducted differently. For example, one person suggested that a question and 

answer session be held between the open house and the public hearing.

Response: There are many different ways to conduct a public meeting. The people that attend our 

meetings often have very different objectives for being there. Some are interested in listening to 

presentations and learning about the issues and planning process. Others want to ask questions about 

issues or places of concern to them. Others have formed their opinion and want nothing more than to 

have a forum to express it. We believe that our meetings, which featured an open house followed by a 

public hearing, made efficient use of the available time and offered a format that met most peoples’ 

needs. 
Appendix H 

Comments and Responses H-16 Final EIS 

Comment: Some respondents requested that the Forest Service have public meetings in more 

small communities. Elfin Cove was one particular community mentioned. 

Response: The Forest Service held public meetings in 24 Alaska communities during the comment 

period for the Draft EIS. We also held an internet public meeting and hearing open to anyone with 

computer access. In addition, Forest Service staff were available by telephone or email to answer 

questions, and comments could be submitted via letter, fax, email, or online comment form. We worked 

hard to get to as many of the smaller communities as possible as evidenced by public meetings in smaller 

communities such as Whale Pass, Port Protection, and Point Baker. One of the reasons the comment 

period was extended by 18 days was to reschedule public meetings cancelled by the weather. 

Unfortunately, we were not able to visit all of the communities in the region. 

Comment: Some respondents felt that the 90 day comment period for the Draft EIS was not 

adequate and that the comment period needed to be extended. 

Response: The Forest Service believes that the comment period was adequate. This is especially true 

given that much of the information in the Draft EIS and Proposed Forest Plan has been on the project 

website (www. tongass-fpadjust.net) for months. For example, the track changes version of the Forest 

Plan showing many of our proposed changes was posted during the summer of 2006. The new timber 

demand study completed by the PNW Research Station was posted in March of 2006. The comment 

period was extended to April 30, 2007 (108 days total) due to the bad weather in Southeast Alaska, which 

caused several of the public meetings to be rescheduled. 

Comment: Some people felt that a hard copy of the Draft EIS should have been mailed to 

everyone because not everyone has a computer to get online or view a CD. 

Response: Nearly 1,000 copies of the Draft EIS and Proposed Forest Plan were distributed. A hard 

copy set of documents costs over $140 with postage. Most people found the CD met their needs and 

distributing CDs rather than hard copies resulted in a significant cost savings to the taxpayer. Anyone 

who requested a hard copy was mailed one at no charge. Hard copies were also placed in libraries 

across Southeast Alaska. 

Comment: Some readers felt that the Draft EIS was not written very well for the lay person in that 

it was too long and technical. 

Response: The Final EIS has been edited to fix areas that seemed to cause confusion and to be more 

consistent in use of terminology. Unfortunately the documents remain fairly lengthy and technical due to 

the complex nature of current science and natural resource management, as well as the need to stand up 

to intense scrutiny and legal challenge. Summary level information is, however, presented in the 

Comparison of Alternatives section in Chapter 2. 

Comment: One comment requested that the Final EIS include a map that identifies the percent of 

public hearing participants that want to protect certain areas and present this information by 

community. 

Response: This is an interesting request, but it is not possible to produce this type of map for a number 

of reasons. These include the fact that many people participating in the public hearings did not identify 

specific areas. Further, even if the Forest Service had surveyed all meeting participants, which we did 

not, there is no guarantee that the people who attended the public meetings are representative of their 

respective communities. 
Appendix H

Final EIS H-17 Comments and Responses

Restoration 

Comment: A number of comments expressed support for more habitat restoration to reverse the 

negative impacts of timber harvest and road building. Many emphasized fixing culverts on 

salmon streams and deer habitat management in young growth. Many said they wanted their tax 

dollars spent in that manner instead of on building new roads. Some pointed out that restoration 

could support good jobs. 

One comment stated that a substantive program needs to be put in place to promote, support, and 

fund a riparian and forest restoration program. The comment also recommended that this 

program have a dedicated funding source, such as a federal trust fund, to ensure it is actually 

implemented. 

Another Comment recommended that the Forest add an objective for the “speedy replacement or 

removal” of all culverts that block fish passage to the Transportation System Riparian Standards 

and Guidelines (RIP2, II, H.1). 

Response: The Final EIS and Final Proposed Forest Plan place more emphasis on restoration including 

management of young growth forest. The Tongass has prioritized the culverts that need to be replaced 

and many of the high priority ones have been replaced. The rate of future replacement is dependent on 

funding. Creating a federal trust fund would require an act of Congress and is beyond the scope of this 

analysis. Although the “speedy replacement or removal” of fish passage blocking culverts has not been 

added to the Riparian Standards and Guidelines in the Final Proposed Forest Plan, this continues to be a 

priority on the Tongass, but is, as noted above, dependent on funding. 

Comment: One comment suggested that the Forest Plan contract restoration work associated 

with past practices to companies actively engaged in the forest products industry to enhance the 

viability of existing Southeast Alaska logging companies. 

Another comment requested that the Forest Service incorporate local and Native hire provisions 

in its hiring practices and reduce the non-resident component of the wood products sector to less 

than 10 percent on Baranof Island. 

Response: Contracts with the Forest Service are awarded on a competitive basis in accordance with 

federal contracting standards. In general, the Tongass National Forest prefers to contract with local 

operators, where possible. ANILCA provides for Native Alaskan hiring provisions for federal employment. 

The hiring practices of private sector companies are outside the scope of this Amendment process. 

Schedule 

Comment: Concern was expressed that some sort of “timeout” proposal might be advanced 

which would delay a decision on the Amendment and not really lead to any long-term solution to 

the issues. 

Response: A decision will be made on this proposed Amendment. References to a “timeout” generally 

refer to how the Forest Plan might be implemented, with the intent to facilitate continued discussions 

about the issues, rather then delay the decision process. 
Appendix H 

Comments and Responses H-18 Final EIS 

Standards and Guidelines 

Comment: There were many detailed comments on the wording of standards and guidelines and 

goals and objectives. They ranged from expressions of support or disagreement to detailed edits 

of the language used. 

Response: These comments were carefully evaluated on an individual basis and changes were made to 

the Forest Plan, as appropriate. Space does not allow for an individual response to each of these 

detailed comments here. 

Comment: One respondent commended the Forest Service for incorporating standards and 

guidelines that address invasive species and recommended that the new section be expanded to 

include discussions of Integrated Pest Management and Executive Order 13112 on invasive 

species. 

Response: The 5-year review of the existing Forest Plan highlighted the need to update the Forest Plan 

to address the threat of invasive species. We believe the direction added provides the appropriate 

guidance to address future invasive species issues. 

Comment: Several respondents discussed the importance of various resource protection 

standards and guidelines and the need to insure that these are mandatory requirements. 

Response: The language in each Standard or Guideline indicates how mandatory the direction is. For 

example, “Commercial timber harvest is not permitted in this LUD” is a standard. “Salvage may be 

permitted...” is a guideline. Standards are mandatory while guidelines, as the name implies, provide 

guidance and are not mandatory. While the Forest Plan provides broad strategic direction that 

employees must follow, there also has to be flexibility for on the ground managers to tailor actions to meet 

the needs of specific locations. Managers always have the option, with appropriate documentation, to 

amend the Forest Plan to meet the needs of specific situations. 

Comment: One respondent suggested that the definition of the estuary fringe presented in 

Chapter 4 of the Proposed Forest Plan include reference to a source, or sources, that identify the 

location of estuaries on the Tongass. 

Response: Estuary is defined in the Forest Plan glossary. This definition clearly identifies where 

estuaries occur and provides sufficient information for the identification of these areas at the project level. 

Comment: Concern was expressed about Wild and Scenic Rivers direction in the Proposed 

Forest Plan that appeared to restrict temporary improvements such as weirs which are fully 

compatible with ANILCA. 

Response: Direction in the Final Proposed Forest Plan has been revised to address this concern. 

Tribal Consultation 

Comment: Concern was expressed that tribal governments and tribal corporations were not 

adequately consulted during this forest planning process. 

Response: The record shows that tribal governments and tribal corporations were consulted throughout 

the process. The District Rangers took the lead in communicating about the Forest Plan Amendment and 

in organizing meetings with tribal organizations. 
Appendix H

Final EIS H-19 Comments and Responses

Comment: One comment objected to the use of Alternative 5 as a baseline for the other 

alternatives because they felt that the 1997 Forest Plan did not feature adequate consultation with 

tribal governments. 

Response: Alternative 5 is used as a baseline for comparison for some of the resource analyses 

because it represents the current Forest Plan and is the no action alternative. The record shows that 

considerable tribal consultation took place in developing the existing Forest Plan. In addition, the current 

Amendment featured a new consultation effort to ensure that tribal issues are heard and understood. 

Comment: One comment expressed the desire for native communities to build a more 

collaborative relationship with the Forest Service. The comment author felt that this type of 

relationship could help these communities be more effective in community development and 

better understand how to take advantage of economic opportunities. This comment specifically 

pertained to the city of Hydaburg. 

Response: The Forest Services supports continued collaboration between the Forest Service and native 

communities and encourages interested parties to work with their local District Rangers. 

Resource and Issue Comments 

The resource and issue comments are divided into the following subsections: 

• Climate and Air 

• Economic and Social Environment 

• Fish and Watersheds 

• Geology, Soils, Karst and Caves 

• Heritage and Sacred Sites 

• Lands 

• Minerals 

• Recreation, Tourism and Scenery 

• Roadless Areas and Wilderness 

• Subsistence 

• Timber 

• Transportation and Utilities 

• Wetlands 

• Wildlife, Biodiversity and Plants 

Climate and Air 

Comment: A number of respondents were concerned about how climate change would affect the 

Tongass. They believe that the results of climate change will be catastrophic for the Tongass and 

include expansion of new species, increased blowdown, and an increase in forest fires. Several 

comments stated that the Draft EIS did not address the significance of the Tongass in global 

carbon storage. Others stated that that global warming will affect Alaska and logging old growth 

forest would release stored carbon into the air, further aggravating the situation. Several 

comments stated that there should be no logging on the Tongass until the Forest Service 

determines how much logging can be done without significant effects on global warming. 

Response: The Draft EIS acknowledges that climate change is occurring and that it is affecting the 

forests of Southeast Alaska; the exact changes likely to occur over the coming decades are not certain 

but are expected to include warmer winters, continued severe storms, and perhaps drier summers. 

These factors, in turn, may lead to increased blowdown and increased insect populations, which would 

adversely affect existing forests and may lead to an increase in fires, although the warming trend has not 
Appendix H 

Comments and Responses H-20 Final EIS 

resulted in these events to date, as noted in the Draft EIS. Information on the risks and uncertainty 

related to the effects of climate change has been added to the Final EIS. As the Draft EIS states, models 

available for estimating climate change are designed to predict changes on a regional level and are not 

detailed enough to predict changes to the Tongass. Consequently, existing models do not agree on how 

global warming will affect Southeast Alaska. Additional information has been added to the Final EIS 

dealing with carbon sequestration and climate change which incorporates recent research. 

As noted in the Climate and Air section of the EIS, logging old-growth forest can result in additional 

carbon entering the atmosphere; although not all of the carbon stored on the logged area is lost. Much of 

the carbon stored in organic matter in the soil, as well as carbon stored in down wood, cull logs, and lowvalue logs left on the site, remains sequestered. Carbon stored in lumber can also be sequestered for a 

time, depending on how it is used. Also, even under the alternative with the highest allowed harvest 

level, more than three-quarters of the existing old-growth forest on the Tongass would be exempt from 

harvest (nearly 3.8 million acres under Alternative 7 and nearly 4.7 million acres under Alternative 1), as 

would nearly all non-productive forest (2.4 million acres). No carbon stored in these forests would be lost 

due to logging. 

As the EIS states, cumulative effects on carbon sequestration depend on the amount of forest land 

harvested; how the harvested wood is used; the management of the non-National Forest System (NFS) 

land in Southeast Alaska; the amount of carbon released during harvest, processing, and transporting 

wood products; on-site decomposition; and the length of the rotation (the period between harvests). If the 

products resulting from harvest are primarily lumber and other building materials, then there is a potential 

that the carbon in these products would be stored for the life of the buildings, longer if the wood is 

recycled or placed in landfills. If the wood is used for paper products or fuel, carbon storage would be 

short term. Any temporary storage of carbon in lumber products may be completely offset by carbon 

released during and after harvest, transportation, and processing. Whether carbon sequestration would 

actually increase or decrease under the alternatives considered in this analysis is unknown. However, 

recent estimates indicate that all the carbon stored in the forests of the Tongass (including carbon stored 

in its soil) represents approximately one quarter of one percent of the stored carbon in forests worldwide. 

Further, carbon stored in all of the world’s forests represents only a small portion of the total carbon 

stored in land vegetation and other terrestrial biomass, in soils, in the oceans, and deep below ground. 

Therefore, the Final EIS concludes that, while carbon storage on the Tongass is important for many 

reasons, small changes in carbon sequestration on the Tongass, whether positive or negative, would 

have only minor effects on atmospheric carbon levels. For comparison, Leighty et al. estimate that 

between 6.4 and 17.2 million metric tons (0.2 to 0.6 percent) of stored carbon has been lost on the 

Tongass since timber harvest began in the early part of the 20th century. For comparison, approximately 

4.5 million metric tons of carbon was released every day to produce electric power in the United States in 

2005 (U.S. Department of Energy 2006). 

Comment: Some respondents believe that the protection of old growth forest may offer the best 

hedge against global warming because old growth forests sequester carbon. Comments also 

noted that old-growth forests may have value on the carbon trading market. 

Response: About 8 percent of the commercial size old growth had been harvested on the Tongass 

National Forest as of 2005. Leighty et al. (2006) estimate that this represents between 0.2 to 0.6 percent 

of stored carbon on the Tongass. If the current Forest Plan (Alternative 5) were to be implemented for 

the next 100 years, which would only occur if new industries and markets developed to process and 

utilize the wood, 82 percent of the old growth forest would still be present in 100 years time. 

Approximately 88 percent would remain under Alternative 1, which has the lowest harvest level, and 

approximately 76 percent would still be present in 100 years under Alternative 7, which has the highest 

harvest level. 

Using the Leighty et al. estimate, this suggests that under 1 percent of the total carbon would be lost 

under Alterative 1 (cumulatively) and less than 2 percent (cumulatively) under Alternatives 5 and 6. 
Appendix H

Final EIS H-21 Comments and Responses

Based on Leighty et al., approximately 0.6 to 1.8 percent (cumulatively) would be lost under Alternative 7, 

the alternative with the highest harvest level. This is the equivalent of approximately 17 days carbon 

emissions from power plants in the United States (refer to the Climate and Air section in the Final EIS). 

These comparisons assume that the projected maximum harvest levels associated with these alternatives 

would be fully implemented over the next 100 years. However, the proposed Forest Plan Amendment 

would only cover the next 10 to 15 years and approximately 90 percent of the remaining old growth would 

still remain under all alternatives when the next Forest Plan is developed. Also, monitoring and adaptive 

management during the planning period may result in changes to harvest levels prior to developing a new 

Plan. It is also worth noting that actual harvest is likely to be lower than the projected ASQ under all of 

the alternatives. 

Whatever carbon is lost during old growth harvest would also be partially offset by young stands which 

accumulate carbon as they grow. Therefore, it is unlikely that preserving all of the remaining old-growth 

forest on the Tongass would have a much greater effect on atmospheric carbon levels than preserving 

the majority of it, which would be the case under all of the alternatives. As noted in the Final EIS, all the 

carbon stored in the Tongass represents a small fraction of the world’s stored carbon. Leighty et al. 

(2006) estimate that all the carbon stored in the forests of the Tongass represents approximately one 

quarter of one percent of the stored carbon in forests world wide. Carbon stored in the world’s forests, 

including forest soils, represents a small portion of total global carbon storage (terrestrial, ocean, and 

fossil carbon pools). As noted in the Final EIS, all terrestrial sources (croplands, tundra, grasslands, 

savannas, etc.) store about one-twentieth of what the oceans store. Therefore, the Final EIS concludes 

that small changes in carbon sequestration on the Tongass, whether positive or negative, would have a 

minor effect on atmospheric carbon levels. 

The possible future value of old-growth forests in the world carbon trading market is currently unknown 

and speculative at this point. 

Comment: Some respondents felt that the impacts of climate change described on pages 3-98 

and 3-99 of the Draft EIS are exaggerated. They believe that it is impossible to predict the effects 

of climate change over the 10 to 15 year life of the plan. Also, many believe trees absorb carbon 

as they grow and, therefore, they argue, society should support timber harvest. In addition, they 

note, young trees consume more carbon dioxide than old trees. 

Response: As noted in the preceding comment response, the Draft EIS acknowledges that while climate 

change is occurring and it is affecting the forests of Southeast Alaska, the exact changes likely to occur 

over the coming decades are uncertain. As the Draft EIS states, models available for estimating climate 

change are designed to predict changes on a regional level and are not detailed enough to predict 

changes to the Tongass. Consequently, existing models do not agree on how global warming will affect 

Southeast Alaska. Additional information has been added to the Final EIS dealing with carbon 

sequestration and climate change which incorporates recent research. 

While research confirms that young trees accumulate more carbon on a yearly basis than old trees, one 

must also take into account the amount of carbon already stored in old forests, including above ground 

vegetation, logs and organic matter on the forest floor, and organic matter in the soil. Some of this is lost 

when the forest is logged and the site is exposed to the sun, increasing decay rates and releasing carbon 

into the air. Also, carbon is released as fuel is burned during harvest, processing, and transporting of 

wood products. As noted in the EIS, carbon can also be stored in lumber and other building materials for 

the life of the buildings, longer if the wood is recycled or placed in landfills. Whether carbon sequestration 

would actually increase or decrease under the alternatives considered in this analysis is unknown. 
Appendix H 

Comments and Responses H-22 Final EIS 

Comment: Some respondents want the Forest Service to consider the impact global warming will 

have on yellow-cedar and end logging of this species. 

Response: The EIS recognizes that the decline and mortality of yellow-cedar is one of the most 

widespread and important forest health problems in Southeast Alaska (see the Forest Health section of 

the Final EIS). This decline is associated with wet, poorly drained sites, and research suggests that 

reduced snow pack in low-elevation areas associated with a warming trend that started in the 1800s has 

exposed fine surface roots to freezing, which in turn kills trees. As the climate continues to warm, yellowcedar decline is likely to continue to spread, especially in the south and east. Conversely, yellow-cedar 

appears to be spreading northward as climate warms, into areas that retain snow longer into the spring. 

Not cutting cedar trees on sites that can no longer support yellow-cedar will not change the fact that these 

trees are growing in areas that cannot support them. Planting yellow-cedar on suitable sites north of its 

current range has a reasonable prospect for success and may aid the species natural movement north. 

Comment: One comment stated that the EIS should measure air quality impacts in terms of the 

total carbon footprint associated with cruise ships, float planes, and related commercial uses of 

the Wilderness. The comment stated that on calm days haze can be seen in Ketchikan, parts of 

Misty Fjords, and Glacier Bay National Park. 

Response: This Amendment responds to the 2005 Court decision which held that the EIS and ROD for 

the 1997 Forest Plan had errors relating to the use of projected market demand for timber, the range of 

alternatives relative to market demand calculations, and cumulative effects of timber harvest activities on 

non-NFS lands. Measuring the total carbon footprint for cruise ships, float planes, and other commercial 

uses in Southeast Alaska would be difficult and time consuming and is not necessary for the analysis of 

the issues identified by the court. In addition, all of the action alternatives propose the same standards 

and guidelines with respect to cruise ships and commercial use in Wilderness. The main variables that 

could potentially affect the size of the carbon footprint from these activities are the number of visitors to 

the region and the demand for commercial recreation activities in Wilderness. The Recreation and 

Tourism section in the EIS discusses potential recreation demand, but it is not possible to project how the 

number of visitors to the region and demand for Wilderness recreation would be affected by each 

alternative with the type of precision required to estimate differences in the resulting “carbon footprint.” 

We were unable to find information on carbon footprint for cruise ships, float planes, or other commercial 

uses in Southeast Alaska in the literature, but we are aware of studies underway to identify cruise ship 

emissions. No results for carbon emissions into the atmosphere have been reported to date specific to 

the cruise ship business in Southeast Alaska to our knowledge. However, we did find a general estimate 

of CO2 released per passenger mile (0.43 kg) (http://www.responsibletravel.com/Copy/Copy100858.htm). 

A rough extrapolation of this, based on the estimated number of cruise ship passengers visiting the 

Southeast Alaska (948,226 in 2005), results in an estimated total of 78,000 metric tons of carbon 

released in 2005 (this assumes each cruise was 7 days and ships averaged 100 miles per day travel, 

including port stays). The portion of this that may have been released in or near wilderness areas is 

unknown. Please note that this is a very rough estimate. For comparison, as noted in response to one of 

the preceding comments, approximately 4.5 million metric tons of carbon were released every day to 

produce electric power in the United States in 2005 (U.S. Department of Energy 2006). 

As noted in the Draft EIS, the air quality for all of Southeast Alaska, except for the Juneau area, is rated 

as good by EPA. Air quality in the Juneau area has improved and has met EPA’s air quality standards in 

recent years, as noted in the Draft EIS. Also, as noted in the Draft EIS, smoke from fires in western 

Canada sometimes crosses into the Southeast Alaskan air shed, causing haze. 
Appendix H

Final EIS H-23 Comments and Responses

Comment: Some respondents stated that although climate models predict warmer winter 

temperatures, they also predict more snow at higher elevations. One comment noted that Juday 

et al. (1998; 41), for example, state there is a strong possibility of heavy snow at high elevations. 

They respondents expressed concern that in some years there will also be more snow in lowelevation areas and note that the deer model does not take this into account. 

Response: It is certainly possible that there will be heavy snowfall in some winters at low elevation, just 

as it is possible that, with global warming, there will be less snow in low-elevation areas in most winters. 

Weather models are not able to accurately predict next year’s snowfall, much less snow levels over the 

next several decades. However, Juday et al (1998) predict (“with some confidence”) low snow 

accumulations in most low-elevation forest in Southeast Alaska. Concerns about the deer model and 

severe winters are discussed in the Wildlife, Biodiversity and Plants section of this appendix under Deer. 

Comment: One comment states that both the HAFCM2SUL and the CGCM1 climate models 

predict a 30 percent increase in the mean seasonal severity rating for fires in Southeast Alaska by 

2060. The comment notes that Dale, Juday, and other scientists predict an increased risk from 

insects and disease. The comment also states that increased rain will lead to more landslides, 

adversely affecting water quality and fisheries in Southeast Alaska. The comment notes that 

Salathe (2006) suggests that a 15 percent increase in precipitation over the whole of Southeast 

Alaska is indicated and the comment states that the resulting increase in soil moisture would 

increase likelihoods of windthrow, stem snap, and mass wasting. 

Response: Our reading of the HAFCM2SUL and the CGCM1 models indicate that they predict a 10 to 

30 percent increase in the fire severity rating, depending on the model. In any case, a 30 percent 

increase in almost no fires (the current condition) would still result in little damage due to fires. As noted 

in the Final EIS, Berman et al. (1999) state that it is difficult to predict the magnitude of area likely to be 

burned in a region with no historic fire record, but they believe that most fires would be small and of low 

intensity. They suggest a scenario in which 5,000 acres might burn over a period of decades, an average 

of perhaps 100 acres a year in an ecosystem that includes over 10 million acres of forest. Juday et al. 

(1998) also suggest that the effects of fires on resources are likely to be low. 

There is no evidence that there has been increased damage from windthrow or insects in the last several 

years, as noted in the Draft EIS. There was a big up-swing in insect damage in the 1990s but this has 

subsided. We can expect other periods of increased insect activity, as insect population cycles ebb and 

flow. This is a natural part of the ecosystem. That said, it is likely that there will be some additional risk to 

forests from both insects and disease as the climate continues to warm. However, there is little evidence 

of increased insect, disease, or blowdown during this decade even though the climate has warmed 

considerably and gale-force storms have increased, as discussed in the Draft EIS. Juday et al. (1998), 

for example, suggest that the increase in gale force winds could result in increased blowdown. However, 

they also state that this had not occurred as of their study, nor did the 2006 survey report such an 

increase, despite the large increase in storm events over the last several decades. Periodic catastrophic 

windthrow has long been a factor in Southeast Alaska and can be expected to continue to be. 

The Draft EIS notes that most studies predict wetter weather in Southeast Alaska over the coming 

decades. As noted in the comment, some researchers believe that increased rain could lead to more 

landslides. This in turn, could affect water quality and fish habitat. There's quite a lot of research about 

rain and snowmelt-driven landslide events (particularly in Washington and Oregon). Whether more rain 

would mean more landslides in Southeast Alaska would depend on local conditions at the time of the 

event, such as the rain characteristics (intensity, duration), the soil conditions (degree of saturation, pore 

pressure), the vegetation characteristics (vegetation cover, root strength) all of which could be affected by 

climate change as well as other factors that might not be so directly affected by climate change (including 

slope angle and any changes in lateral support, loading, or vibrations). Until climate models at the subregional scale include these factors it will be hard to quantify the risk. 
Appendix H 

Comments and Responses H-24 Final EIS 

The Salathe (2006) paper referenced in the comment finds “greater precipitation over the North Cascades 

and extending southward along the Cascades. Increases in precipitation are also found for the Idaho 

Rockies...” We did not see a prediction specific to Southeast Alaska. 

Specific concerns regarding the potential effects of climate change on wildlife are addressed in the 

Wildlife, Biodiversity and Plants section of this appendix 

Comment: Some respondents believe that the forests of the future will need to be resilient to 

novel conditions presented by climate change. They stated that old-growth forests, having 

survived fires, droughts, and insect and disease outbreaks of the past, have shown themselves to 

be resilient to change. Once comment cited recent research in California that indicates that old 

growth is more resilient to fires than plantations and fires are expected to increase in the future 

climate which is expected to have drier conditions. One comment stated that replacing old 

growth forest with young stands would expose the forest to increased risk of fire, insects, and 

disease, and concluded that, therefore, the Forest Service should avoid cutting old growth. 

Response: The old-growth trees present today began life in the cooler climate of the little ice age, which 

began about 700 years ago and ended about 150 years ago. They have not endured fire to any notable 

extent, nor prolonged drought. Southeast Alaska has a cool, wet climate even in the warmest, driest 

years. This is a very different situation than in California, where tree species present in old-growth forests 

have evolved along with fire and drought and have developed coping mechanisms, such as thick bark, as 

a protection from periodic fires. There is little reason to think that old Sitka spruce or western hemlock 

trees would be better suited to a warmer climate than young trees of the same species, nor could one 

make a strong case for the opposite. 

If the climate does get warmer and drier (some predict that it will get warmer and wetter) then hemlock 

and spruce trees would be less well suited to Southeast Alaska than they were during the past cool 

period. The fact that thick-barked, old-growth pine and Douglas fir trees in California are more resistant 

to fire than young trees says little about the resilience to fire of thin-barked, old-growth hemlock and 

spruce trees. Also, as noted in one of the preceding responses, the predicted 10 to 30 percent increase 

in the fire severity rating would still result in few fires and little resource damage. A more realistic threat to 

forest health comes from insects. Experience indicates that insect outbreaks have had a greater effect on 

old forests than on young ones (refer to the Forest Health section of the EIS). 

Comment: One comment stated that it is important to preserve northern forests, which preserve 

50 percent of Earth’s carbon, and also noted that cutting trees will lead to more fires. 

Response: The great majority of the earth’s carbon is in the oceans as discussed in the Climate and Air 

section of the Final EIS. Also, the risk of fire in Southeast Alaska is very small, as discussed in the Final 

EIS. 

Comment: Some respondents believe that the effects of climate change on values/resources 

should be given the same consideration as timber harvest. They state that just because there is 

uncertainty that does not mean the EIS does not have to analyze the possible effects, just as it 

does with timber demand, which is also uncertain. They believe the EIS should analyze the range 

of possible effects that climate change will have on values and/or resources and on achieving the 

desired future condition for these resources. 

Response: Information that discusses the range of effects that climate change may have on achieving 

the desired future condition for various resources has been added to the appropriate sections in the Final 

EIS. 
Appendix H

Final EIS H-25 Comments and Responses

Comment: One comment stated that the Forest Service should lead by example and “enable 

ecosystems to adapt to climate change” by applying the principles outlined in Forest Service 

publications. The comment also stated that the Forest Service should analyze 11 studies that 

were listed in the comment. 

Response: The Tongass planning team reviewed the cited studies, as well as many other studies on 

climate change. Some of the studies recommended in the comment are applicable to Southeast Alaska 

and the Tongass National Forest (e.g., Berman et al. 1999, Juday et al. 1998) and information from these 

studies was added to the Final EIS. Others are very broad based, general discussions on what may 

happen, often in other distant parts of the U.S. (i.e., effects on trout in the southeast U.S., fire risks in the 

western continental U.S., carbon dioxide [CO2] effects on growth rates in the continental U.S.). The 

planning team reviewed this literature, with guidance from scientists at the PNW Research Station, and 

sought to use the most appropriate studies to show the range of possible outcomes for the Final EIS. We 

favored local studies where available. Some of the studies referenced in the comment had limited 

applicability to the Tongass. For example, the comment recommended that we consider Pratsad and 

Iverson (1999), which considers the effect climate change will have on 80 tree species in Eastern North 

America as an example of how we should model changes on the Tongass. However, this study deals 

with trees on a subcontinent-level, and in a less complicated region geographically. By comparison, the 

Tongass is about the size of West Virginia and is made up of a series of islands and a narrow strip on the 

mainland bordered by tall mountains and glaciers to the north and east and by the Pacific Ocean to the 

west. Consequently, it is difficult to predict changes using existing models designed to predict changes 

on a continent or subcontinent level. 

As noted in the Final EIS, models are based on predictions for large regions and do not agree on exactly 

what is likely to happen in local areas such as the Tongass beyond the likelihood that the climate will be 

warmer. Researchers have modeled changes in the range of species at the Alaska regional scale. They 

estimated that the boreal forest will likely move approximately 100 miles north, coniferous and mixed 

forest would advance into the boreal zone, and the southern coastal forests are likely to expand westward 

(various studies cited in Parson et al. 2001). Studies also predict that trees in Southeast Alaska will 

expand their range upward into higher elevations and both yellow-cedar and red cedar will expand their 

range northward. As one of the papers cited in the comment (Hansen et al. 2001) notes, topographic 

barriers between Canada and Southeast Alaska are likely to limit the northward expansion of species into 

Southeast Alaska, therefore we do not anticipate species such as Douglas-fir migrating to the Tongass in 

the foreseeable future. 

The Aber et al. (2001) paper cited in the comment discusses the effects of higher CO2 on tree growth and 

illustrates the difficulties involved in trying to estimate the effects of global warming on the Tongass 

National Forest. While their focus is on the continental United States rather than on Alaska, Aber et al. 

demonstrate the problem of applying general theory to specific areas. There is research indicating the 

higher CO2 levels driving climate change may increase the rate of photosynthesis and therefore tree 

growth, at least in the short term. However, this and other studies indicate that this would only occur if no 

other factor is limiting, such as water or nutrients. Whether water will be limiting in Southeast Alaska is 

unknown. Some models indicate a 10 percent reduction in summer rain across the Tongass but others 

do not. This leaves us without much certainty as to whether growth rates will increase. All we can really 

take from this, and similar studies, is a note of caution; therefore, the Final EIS does not predict increased 

tree growth for the Tongass, though it acknowledges the possibility. Increased tree growth, if it does 

occur, could increase carbon sequestration and future timber production, which in turn could lead to 

shorter recovery rates for disturbed habitats. 

Comment: Several comments stated that the Forest Service should conduct research on 

greenhouse gases and carbon dioxide and identify how logging and re-growth change the carbon 

budget on the Tongass. 

Response: Estimates of the amount of carbon stored in existing forests and the amount lost as a result 

of harvest are included in the Final EIS, as is a discussion of the problems encountered in attempting to 
Appendix H 

Comments and Responses H-26 Final EIS 

estimate the amount of carbon released due to harvest. The PNW Research Station continues to 

conduct research on global warming. 

Comment: One comment expressed concern that timber harvest results in air pollution which 

causes asthma and lung problems. 

Response: As discussed in the Climate and Air Section in the EIS, air quality is good on the Tongass 

and timber harvest has little effect on air quality in the region. In many other regions, logged areas are 

broadcast burned following harvest to dispose of logging slash and this can adversely affect air quality. 

Broadcast burning is not used on the Tongass. 

Comment: One comment pointed out that the construction of interconnecting electric power lines 

would reduce air pollution from diesel generators, and result in a reduction in CO2 emissions. 

Response: Information on this subject has been added to the Climate and Air section of the Final EIS. 

The alternatives would not affect power line construction; all alternatives propose the same 

Transportation and Utility System LUDs. 

Economic and Social Environment 

The Economic and Social Environment comment and response subsection is divided into the following 

categories: 

• Timber Demand 

• Regional Economy 

• Economic Efficiency Analysis 

• Tongass National Forest Budget 

• Payments to the State 

• Communities 

Timber Demand 

Comment: Some respondents felt that the model used by the PNW Research Station to determine 

timber demand was obsolete. In particular, they felt that using a model built around exports to the 

Pacific Rim was a fatal flaw now that domestic markets are the primary destination for Tongass 

timber. They note that the model does not include a single parameter to account for changes in 

domestic markets. 

Response: Brackley and Haynes (in press) state that “the existing model is a robust system that remains 

a valid approach to model demand for Tongass timber because of the limited data on lumber shipments 

and values and production costs.” They go on to explain that Alaska producers are sawing lumber 

products that are, on average, better quality and enter higher priced markets, than lumber manufacturers 

are producing in the western Pacific states and in Canada. These high quality products have similar 

prices in domestic and foreign markets. Using historic data with scenario assumptions to model 

movement of these products in both domestic and foreign markets is a valid approach. 

The method to project timber harvests and output in Alaska followed by Brackley et al. (2006a) is 

essentially the same as that described in publications about previous estimates of Alaska timber demand 

by Haynes and Brooks (1990), Brooks and Haynes (1990), Brooks and Haynes (1994), and Brooks and 

Haynes (1997). The method begins by estimating Alaska forest products output, by product, followed by 

calculating the raw material requirements necessary to support this production, using explicit product 

recovery and conversion factors. The total raw material requirement (the total derived demand for timber) 

is a combined projection of timber harvest from private ownership, from National Forests, and from non-
Appendix H

Final EIS H-27 Comments and Responses

National Forest public owners. The projected National Forest timber demand is the quantity of timber 

required to satisfy projected derived demand given harvest by other owners, and given explicit 

assumptions about markets and implicit assumptions about prices. 

Brackley et al. (2006a) assembled historic data that describe relevant components of the Alaska forest 

sector and calculated possible future wood needs by using an analysis of trends in factors that influence 

harvests. A historic period of about 40 years (1965 to 2004) was used as a basis for a projection of 20 

years (2005 to 2025), to avoid emphasis on short-term cycles. They used information about US exports 

to Japan, and Japanese import data, as a benchmark for the historic data, as such exports represented, 

until very recently, the vast majority of sawn wood production from Southeast Alaska. 

Data about recent domestic end markets for sawn products from Southeast Alaska has been available 

since about 2000. The data on domestic end markets is difficult to verify. One major question is how 

much of the product shipped to the Pacific Northwest is trans-shipped. Trans-shipments are products 

that are shipped into foreign markets from a different customs district than the one in which they were 

manufactured. In the case of Southeast Alaska, lumber manufactured in Alaska is apparently being 

shipped to foreign markets from the Seattle customs district, making it difficult to track many of the very 

recent end markets and subsequent demand for manufactured products from Alaska. 

Other data used in the Brackley et al. (2006a) analysis includes log sources from all ownerships in 

Southeast Alaska, log and chip shipments out of Alaska to various destinations from all owners, harvest 

by owner, the Alaska market share for manufactured products in North America, and the North American 

market share in Japan. Brackley et al. (2006a) allocated their projections of total derived demand to 

foreign export markets (17 percent) and domestic markets (83 percent). They used information from 

Resource Planning Act (RPA) projections and assessments of future demand to estimate increases in 

derived demand in the future, allocated between domestic and foreign markets. 

Predicting demand for federal timber in the wood products market in Southeast Alaska is difficult, due to 

the relatively small size of the market, the kinds of data available, and the structure of land ownership in 

the region. The structure of the model used by Brackley et al (2006a) makes it difficult to assess changes 

in domestic markets. This will need to be addressed in future demand predictions for Southeast Alaska, 

but gathering historic data that can be used in such a trend analysis for recent market shifts is 

problematic. It became clear from data reported by Kilborn et al. (2004) that shipments of manufactured 

wood products from Alaska were shifting from foreign to domestic destinations by 2000, and the 

continued significance of the domestic market through 2004 is illustrated by data reported by Brackley et 

al. (2006b). However, checking this data against data sources for domestic shipments and foreign 

exports is difficult at present, because of lags in reporting and the issue of transshipments. Data used in 

the Brackley et al. (2006a) model was cross-checked by the authors to ensure its reliability. It will take 

more research to assess if the end market information reported by Kilborn et al. (2004) and Brackley et al. 

(2006b) can be reconciled with other sources of data, such as the Harmonized Trade Code information, 

so that verifiable domestic shipment data can be used in future Southeast Alaska wood products demand 

assessments. 

Comment: Some respondents felt that the PNW Research Station demand report was overly 

optimistic and did not accurately account for the challenges faced by producers in Alaska related 

to the competitive disadvantages of higher harvesting, transportation, and manufacturing costs. 

They pointed out that in most years the existing industry has been operating at less than 50 

percent of the installed mill capacity. They felt that new industry investments, associated with the 

higher demand scenarios, were unlikely to occur. Some comments stated that the harvest level for 

the past few years represented the actual demand.

Response: Brackley and Haynes (in press) state that “current production levels and shipment patterns in 

Southeast Alaska demonstrate how the industry has transitioned to operate in current market 

opportunities”. They go on by saying that shifts to “higher proportions of shop lumber, larger sizes of 
Appendix H 

Comments and Responses H-28 Final EIS 

dimension lumber, heavy timbers, and cants should give Alaska producers an opportunity to supply 

products of relatively higher value to both domestic and export markets.” 

Brackley et al. (2006a) selected four scenarios they deemed reasonable and possible, given their 

assumptions. The Limited Lumber Production and the Expanded Lumber Production scenarios assume 

the wood processing industry in Southeast Alaska is focused only on processing of sawlogs. The primary 

difference between these two scenarios is the assumption that Alaska will increase its market share in the 

North American export market from 0.39 percent to 1.14 percent in the Expanded Lumber scenario, while 

the Limited Lumber scenario maintains the same market share for Alaska products in the North American 

market as a whole. The Medium Integrated Industry and High Integrated Industry scenarios both assume 

one or more chip and utility processing facilities will be added to the Southeast wood processing industry. 

These two scenarios assume an increase in Pacific Rim lumber imports, but not to the extent assumed in 

the first two scenarios. These two integrated industry scenarios also assume varying increases in the 

Alaska share of the North American export market. The Medium Integrated scenario assumes markets 

for chip and/or utility material will increase in 2008, while the High Integrated scenario assumes markets 

for chips and/or utility material will increase in both 2008 and again in 2012. Although Brackley et al. 

(2006a) assumed these markets would be the result of processing facilities built in Alaska, any market 

stimulation that results in higher demand for chip or utility material would have the same result. The 

recent policy change regarding appraisal of lower grade material for shipment to the lower 48 states could 

have a similar effect to building a processing facility for lower grade material, in terms of demand 

stimulation. 

Comment: Some respondents felt that demand scenarios should not have been based upon nonexistent facilities. They noted that the demand study prepared by Brooks and Haynes (1997) did 

not count potential demand from proposed facilities.

Response: Brooks and Haynes (1997) had scenarios labeled high, medium, and low. They chose not to 

go into detail in their discussion about how these demand levels might be achieved, simply leaving the 

discussion more general. Brackley et al. (2006a) chose to discuss how their scenarios might look “on the 

ground”, to give an idea to the reader how demand might actually be stimulated under their assumptions 

in their model. The structure of the model itself, however, is simply driven by changes in relative market 

shares based on a number of assumptions, as discussed in response to the preceding comments in this 

section. Brackley et al. based this discussion of how changes in demand might take place based on 

efforts to plan and build various facilities in Southeast Alaska that would utilize lower grade material and 

have been under discussion for some time. However, as mentioned above, the demand stimulation could 

also take place as a result of other events, such as policy changes in timber sale appraisals. 

Comment: Some respondents questioned why a timber demand scenario was not developed for a 

declining timber demand. They cite studies that indicate the possibility of the United States 

playing a smaller role in global wood products markets in the future.

Response: Brackley et al. (2006a) recognized that the US is a net importer of timber. A mill in Alaska 

has the option to ship products to traditional export markets (Japan), emerging new markets, or the lower 

48 states. Demand for wood products is global in nature and increasing amounts of wood products are 

being imported into the United States. Alaska products constitute a small proportion of the total US 

market; very small shifts in how much of the US market Alaska supplies can mean a big change in 

Alaska. 

Brackley and Haynes (in press) state that several short and long-term changes point to an increase in 

demand for wood products from all sources, including Alaska. These changes include a slowing in 

lumber production in sawmills in western Canada, in addition to longer-term factors, such as increased 

interest in renewable energy applications and a projected steady increase in US population and a 

concurrent growth in demand for softwood products. Brackley and Haynes state that the probability of a 

future decrease in demand for lumber from all Pacific Rim markets is virtually zero. In fact, they argue 
Appendix H

Final EIS H-29 Comments and Responses

that projected consumption in domestic markets alone will increase substantially. Therefore, there was 

no compelling reason for the Brackley et al. study to include a scenario showing demand falling, which 

would be contrary to the best scientific information available. 

Estimated demand for Alaska sawn products declined considerably between Brooks and Haynes (1997) 

and Brackley et al. (2006a). The lowest projection of derived demand for sawn products from Alaska in 

Brooks and Haynes (1997) for the period 2003 to 2007 was 130 million board feet (MMBF). The lowest 

projection in Brackley et al. (2006a) for the same period was 30 MMBF. These differences were due to 

changing assumptions from one projection to another, and shifts in the structure of the industry as it 

adjusted after the end of the long-term contracts. Also see Chapter 2 of the Final EIS, Alternatives 

Considered but not in Detail. 

Comment: Some comments stated that even when supplemented by state and private wood 

Alternatives 1 through 6 would not produce enough wood to meet market demand. Others argued 

that Forest Service demand studies have not adequately recognized the value of 100 percent 

wood utilization and the critical need to restore an integrated wood products industry to 

Southeast Alaska. Some stated that only Alternative 7 would produce enough timber (360 MMBF 

per year) to supply a fully integrated timber industry. 

Response: The Medium Integrated Industry (Scenario 3) and High Integrated Industry (Scenario 4) 

scenarios in Brackley et al. (2006a) both assume one or more chip and utility processing facilities would 

be added to the Southeast wood processing industry, creating an integrated industry. The timber 

demand analysis presented in the Economic and Social Environment section of the Final EIS indicates 

that both Alternatives 4 and 7 would provide sufficient volume to meet projected demand under Scenario 

4 in the second decade following plan implementation.

Comment: Some comments were concerned that as designed none of the alternatives provide 

enough timber to sustain a fully integrated timber industry (Brackley et al. Scenario 4). Alternative 

7 has one-third of its harvest in Scenic Viewshed and Modified Landscape LUDs, which would not 

result in economic timber sales. Some stated that a total of 1.5 million acres of commercial forest 

land is required to allow economic timber harvest and provide annual harvest levels of 360 MMBF 

(or some said 370 MMBF) per year. Others commented that the Forest can harvest 360 MMBF per 

year using only 25 percent of the forest land. 

Response: The range of alternatives evaluated in the EIS provides sufficient volume to meet the four 

demand scenarios, when timber from state and private land is considered. One assumption is that, if an 

integrated industry does develop, lower-grade logs from private land would be available for local use, for 

example, in an MDF plant. These logs are currently exported or shipped to the lower 48 states because 

there is no local market for them. As noted in the preceding comment response, the timber demand 

analysis presented in the Economic and Social Environment section of the Final EIS indicates that both 

Alternatives 4 and 7 would provide sufficient volume to meet projected demand under Scenario 4 in the 

second decade following plan implementation. 

Some areas on the Tongass are designated as Scenic Viewshed or Modified Landscape because the 

Forest Service is required to manage for multiple use. The conservation strategy requires managing 

some lands outside of the Wilderness for wildlife (e.g., beach fringe, OGRs). Managing scenic areas as 

Scenic Viewshed protects the scenery resource while making some timber available from these areas. 

Many other areas are important for recreation and therefore are managed as either Scenic Viewshed or 

Modified Landscape. This protects these resources while providing some timber. The bulk of the timber 

harvest under all the alternatives comes from areas classified as Timber Production; these are areas that 

allow more intensive timber harvest, while still protecting other resources, such as fish and water quality 

through stream buffers and other standards and guidelines. 
Appendix H 

Comments and Responses H-30 Final EIS 

Comment: Some respondents felt that the PNW Research Station demand study did not 

adequately take into account the lack of a reliable and economic supply of timber. They argued 

that poor timber sale design is a greater problem than poor markets. A number of comments 

stated that industry would respond to a reliable, economic supply of timber with investments to 

build a competitive integrated industry.

Response: The PNW Research Station has published several demand studies conducted in support of 

Tongass Land Management planning efforts (Brooks and Haynes 1990, 1994, 1997; Brackley et al. 

2006a). These studies estimate derived demand for timber in Southeast Alaska. They do not address 

supply issues. The supply of timber from the Tongass National Forest is determined by two main factors. 

The first is the volume of timber offered for sale by the Forest Service. In April 2000, procedures to 

determine the estimated supply needed were published in ‘Responding to the Market Demand for 

Tongass Timber’ (Morse 2000). These procedures to estimate the timber offer target (supply) incorporate 

the demand numbers from the PNW Research Station studies as an input into a spreadsheet. The 

procedures developed by Morse (2000) to estimate the annual sale offering targets from the Tongass 

National Forest address the uncertainty associated with forecasting market conditions, considering the 

continuing transformation of the timber industry and the inability of the Forest Service to respond quickly 

to market fluctuations due to the time it takes to prepare timber for sale. 

The second factor affecting timber supply is the cost of harvesting and delivering wood to its respective 

intermediate markets: mills in the case of locally processed material, and ports in the case of log exports. 

Although a significant issue, reduced volume offered for sale by the Tongass National Forest is not the 

sole reason for recent harvest declines. Rather than merely securing volume, the challenge facing 

Tongass National Forest timber purchasers is being able to make a profit from new sales volume and 

volumes currently under contract. 

Profitability for Tongass National Forest timber can be affected by (1) the combination of valuable 

materials versus logging costs in a given timber sale, (2) market options for lower grade material coming 

off the Forest, and (3) prices for Southeast Alaskan premium species and grades. Limited market options 

for lower grade material is at least partially the result of the closure of the region’s two pulp mills in the 

1990s, though the removal and sale of low grade and utility logs had been a challenge for independent 

operators in low markets prior to the closures. Many contracts now allow the option of leaving utility 

stumpage in the woods, but current market conditions are still challenging profitability. 

Planning the timber program requires more than just pure economic factors. To account for delays in 

timber sale preparation, administrative appeals, and/or litigation, sufficient contingent volume must be 

included in the annual timber sale program to account for realistic fall-downs. Budget and organizational 

constraints limit the extent to which the Forest Service can respond to economic cycles and the 

associated fluctuations in timber demand. All of these factors must be considered in evaluating the 

market demand for timber and setting timber offerings. In the final analysis, planning the timber sale 

program is an exercise in professional judgment. 

The current status of the timber industry in Southeast Alaska is discussed in the Economic and Social 

Environment section of the EIS and includes the following summary of the difficulties involved in 

accurately projecting future demand. 

Accurately projecting future demand is difficult and cannot be considered an exact science. Market 

demand for Southeast Alaska timber and wood products depends upon numerous difficult to predict 

factors, including changes in technology, growth and exchange rates in key markets, changes in 

consumer tastes and preferences, as well as developments in other producing regions whose 

products compete with those of Alaska. While demand is difficult to predict, industry relies on a 

stable timber supply in order to conduct long-term business planning. 

The section also states specifically with respect to Brackley et al.’s Scenario 1 that: “The current status is 

believed to be largely the result of supply limitations and not necessarily related to market demand.” 
Appendix H

Final EIS H-31 Comments and Responses

Comment: One comment stated that the estimate of installed capacity of 261 MMBF identified on 

page 2-47 of the Draft EIS is low. The manufacturers of the mill equipment estimate that the 

“active, installed capacity” is 370 MMBF. 

Response: The active processing capacity of the timber industry in Southeast Alaska in 2004 and 2005 

was 261 MMBF, as stated in the Draft EIS. This estimate is from the detailed mill surveys conducted in 

those years (Brackley et al. 2006b, Juneau Economic Development Council 2006). This, as stated on 

page 2-47, was the estimated active installed processing capacity in 2005. Total estimated processing 

capacity for those years was 376 MMBF. The difference is the capacity of three mills that were installed 

but not active in 2004 or 2005. These mills were: KPC/Annette Island Hemlock Mill (70 MMBF), Gateway 

Forest Products Veneer Mill (30 MMBF), and Kasaan Mountain Lumber & Log (15 MMBF). This is noted 

in Table 3.22-5 in the Draft EIS. It may also be noted that the analysis summarized on page 2-47 uses 

both the active (261 MMBF) and total (376 MMBF) processing capacities as benchmarks for evaluation. 

The mill capacity discussion presented in the Economic and Social Environment section of the Draft and 

Final EIS documents has been updated in the Final EIS to include the findings of the 2006 mill survey, 

which was completed following publication of the Draft EIS (Juneau Economic Development Council 

2006). There was a net decline of 5.5 MMBF in total and active processing capacity in 2006. Northern 

Star Cedar in Thorne Bay sold equipment capable of processing 8 MMBF and Icy Straits Lumber in 

Hoonah added a linebar resaw and 2.5 MMBF of capacity (Juneau Economic Development Council 

2007). The installed capacity benchmarks used for evaluation of the alternatives have been updated 

accordingly in the Final EIS. 

Comment: One comment stated that the installed capacity figures used in the Draft EIS appeared 

to substantially overstate existing mill capacity. The comment noted that the figures for the mills 

in Hoonah, for example, appeared to be 6 to 10 times their actual processing levels. 

Response: The installed capacity figures included in the Draft EIS are from the annual mill surveys 

conducted in 2004 and 2005 (Table 3.22-5). As explained in the Draft EIS, installed capacity is the 

volume of material that the mill could process in 500, 8-hour shifts. This is not the necessarily the same 

as the amount actually processed in any given year. The actual amounts processed in 2004 and 2005 

are also shown by facility in Table 3.22-5. Actual utilization (or actual processing levels) for the sawmills 

in Hoonah were, as noted in the comment, substantially below the installed capacity in 2004 and 2006 

(see Table 3.22-5). This table has been updated in the Final EIS to include the results of the 2006 mill 

survey (Juneau Economic Development Council 2007). 

Comment: One comment questioned whether the timber demand projections used in the EIS 

considered peak oil concepts and the projected increase in oil prices, which will negatively affect 

the competitiveness of the timber industry in Southeast Alaska. 

Response: The methodology used to develop the PNW Research Station demand projections is 

explained in Brackley et al. (2006a), with additional information provided in an addendum prepared in 

response to comments on the Draft EIS (Brackley and Haynes, in press). 

Comment: One respondent asked if Brackley et al. considered a potential increase in demand 

from the lower 48 states. 

Response: The Brackley et al. (2006) study included the assumption of increasing demand in domestic 

markets. Brackley and Haynes (in press) add further detail to this assumption. Populations in the US are 

projected to continue to rise in the future, along with demand. 
Appendix H 

Comments and Responses H-32 Final EIS 

Comment: One comment stated that there is too much wood fiber on the market from domestic 

and foreign producers and the glut will continue for decades. They believe that the building 

industry doesn’t need or want additional wood from the Tongass.

Response: Brackley and Haynes (in press) argue that Alaska producers have a unique advantage over 

all other manufacturers in the Pacific Northwest in their access to high quality wood. Alaska producers 

compete in different market segments with higher value products, on average, with better visual and 

strength characteristics. Demand for this high quality wood is strong and consistent. 

The Forest Service uses a scientific process, Morse 2000, to determine timber sale offer levels to seek to 

meet annual demand. Among other things it takes into consideration volume under contract and past 

harvest to help determine what the current demand is for timber. 

Comment: The alternatives in the Draft EIS are based on the same faulty logic as those 

alternatives evaluated in the 1997 EIS. TTRA requires that the Forest Service seek to meet market 

demand. Market demand for the past several years has been about 50 MMBF and, therefore, only 

Alternative 1 is consistent with TTRA and the Court order. 

Response: Timber harvest in what economists call an ”imperfect market”, with one major seller and with 

supply limitations, does not equal demand. In other words, recent harvest levels on the Tongass National 

Forest do not equal demand. 

The basic approach of all the PNW Research Station demand studies over the last 17 years has been to 

derive the demand for timber from the Tongass from estimates of demand for the end products 

manufactured from Tongass timber in the markets in which those products are sold. This approach 

makes it possible to estimate the demand that would exist in the absence of the considerable constraints 

currently placed on the supply of timber. Examples of such constraints include appeals and litigation, 

difficulties in preparing sales with positive appraisals, legislation unique to the Tongass that disallows 

timber purchasers from requesting sales with negative appraisals be offered, and funding levels. In 

addition, the limited interstate shipment policy has only recently made it possible for sales to be appraised 

on the assumption that low-grade and small diameter material will be sold in continental US markets, 

which is expected to enable more sales to appraise positive, and allow them to be offered, than was the 

case before the policy was adopted. Finally, the Brackley et al. report mentions other developments such 

as biofuels that could substantially increase future demand, even if the current model cannot quantify 

such effects. 

For all these reasons, we believe the level of timber harvested on the Tongass in recent years is not a 

good basis for estimating market demand for the next decade or two. 

Comment: One comment stated that the following harvest levels represent important thresholds 

for the timber industry: 

• 83.5 MMBF is the bare minimum needed to keep Southeast Alaska mills in operation over 

the next one to two years, while the supply of timber from the Tongass is increased. This 

would allow short-term, single-shift operation of the existing mills. 

• 167.5 MMBF per year is needed to allow existing mills to operate two shifts daily and 

provide 30 MMBF for development of a new facility that would use low-value timber. 

• 231.7 MMBF is needed for the existing mills to operate at full capacity (three shifts daily) 

and provide 30 MMBF for a facility that would use low value timber. 

This, they note, needs to be economically feasible timber, not the ASQ, which has historically 

been much higher than the economically feasible level. 
Appendix H

Final EIS H-33 Comments and Responses

Response: The above volumes are broadly similar to the minimum timber volumes required by various 

processing facilities that are identified in Table 3.22-17 in the EIS. These volumes are used as one set of 

benchmarks against which the projected NIC I component of the ASQ available under each alternative is 

compared. 

Comment: One comment stated that the analysis prepared for the Southeast Conference and 

referenced in the Draft EIS—“Timber Markets Update and Analysis of an Integrated Southeast 

Alaska Forest Products Industry” (McDowell Group et al. 2004)—has been updated. This updated 

version should be used in the Final EIS. The Southeast Conference has also commissioned 

another study—“Level of Harvest Capability Required to Support an Integrated Forest Products 

Industry in Southeast Alaska” (Cascade Appraisal Services, Inc. 2007). The results of this study 

should also be included in the Final EIS. 

Response: The industry capacity reports referenced in the above comment have been reviewed and the 

updated McDowell Group study is cited in the Final EIS. These reports both included comments on the 

Draft EIS. These comments are summarized and responded to in this appendix. 

Comment: One comment stated that the analysis should not use market demand or installed 

capacity to determine how much of the Tongass should be cut. Timber should be harvested on a 

sustained yield basis. 

Response: The EIS used market demand to identify the range of alternatives to be evaluated in the 

Draft EIS because Key Issue 2 for the EIS responds to the requirement under TTRA that the Forest 

Service seek to meet market demand for timber in Southeast Alaska. Installed capacity is not used to 

determine harvest levels, but as one benchmark against which the projected ASQ available under each 

alternative can be compared. All alternatives propose that timber harvest be conducted on a sustainable 

basis.

Comment: One comment stated that the Morse method used by the Forest Service to establish 

annual timber sale objectives and meet demand for Tongass timber on an annual basis has a 

number of shortcomings including a low mill capacity estimate, a “contrived” capacity utilization 

rate, and unrealistic estimates of non-federal sources of timber. The same comment author also 

points out that the Forest Service is not meeting its goal of having an approximate three-year 

supply of timber under contract. The proposed sales identified in the Forest Service’s current 5-

year plan added to the existing volume under demand would not provide three years worth of 

supply for an annual harvest of 150 MMBF, let alone the 350 MMBF industry representatives 

believe is necessary for an integrated industry. 

Response: The Morse methodology is referenced in the Draft EIS, but is not part of the analysis and has 

no bearing on the decision making process. As a result, questions surrounding this methodology are 

beyond the scope of this analysis. This methodology is, however, discussed in Appendix G. 

The Draft EIS identifies that the goal of the Forest Service is to have an approximate three-year supply of 

timber under contract, as cited in the above comment. However, in the same paragraph, the text explains 

that: “(i)n recent years the Forest Service has not been able to achieve a three-year supply under 

contract, mostly due to litigation and administrative policy changes (i.e., Roadless Area decisions).” This 

discussion has been expanded in the Final EIS. 

Comment: One comment pointed out that the Draft EIS (page 3-424) incorrectly references a 

Juneau EDC/Tongass Futures Roundtable demand projection of 248 to 268 MMBF. The comment 

author points out that the Tongass Futures Roundtable has not developed any demand 

projections. 
Appendix H 

Comments and Responses H-34 Final EIS 

Response: This discussion has been revised in the Final EIS and the reference to the Tongass Futures 

Roundtable estimate has been deleted. This projection and the correct source are presented in Table 

3.22-17 in the Final EIS. The correct source is as follows: Estimates developed by the Forest Service 

based on McDowell Group et al (2004), Brackley et al. (2006b), and the Juneau Economic Development 

Council (2006) with updates by Southeast Alaska sawmills. 

Comment: One comment stated that the mill capacities presented in Table 3.22-17 in the Draft EIS 

are incorrect and represent “some very temporary, rough estimates of how much timber the 

currently operating mills needed to survive one year.” The comment then refers the Forest 

Service to the 2005 Mill Capacity and Utilization Study for actual capacity information. 

Response: The estimates presented in Table 3.22-17 in the Draft EIS are, as stated in the title to the 

table, the minimum timber volumes required by various processing facilities. The capacities identified in 

the 2005 Mill Capacity and Utilization Study are presented in Table 3.22-5 in the Draft EIS. A 2006 Mill 

Capacity and Utilization Study was completed between the publication of the Draft and Final EIS 

documents. The results of the 2006 study have been incorporated in the Final EIS (Juneau Economic 

Development Council 2007). 

Comment: One comment stated that the minimum volumes identified in Table 3.22-17 are not 

“additive.” An MDF facility needs 80 to 100 MBF to operate but this volume needs to be utility 

logs and sawmill chips only. If an MDF facility had to rely on higher priced sawlogs for its supply 

it could not be competitive with MDF facilities located elsewhere. The comment author, therefore, 

concludes that a harvest level of approximately 360 MMBF would be required to supply an MDF 

facility. Further, different facilities require different types of logs. 

Response: Table 3.22-17 in the Draft EIS identifies the minimum volumes required by various 

processing facilities. These volumes are used in the following analysis by alternative. The analysis does 

not simply assume that total demand is 248 to 268 MMBF, although this is one measure that could be 

employed. Rather, the analysis evaluates whether each alternative would meet all or part of the 

estimated minimum requirements and discusses ways in which these estimated demand levels could be 

met based on the average timber harvest composition. The average timber harvest composition used in 

this analysis is estimated based on the average composition of recent sales on the Tongass (see Table 

3.22-18 in the Final EIS). 

This alternative-by-alternative analysis also uses the maximum annual average harvest levels (NIC I 

component of the ASQ) with respect to the active and total installed processing capacity and the potential 

planning cycle demand estimate of 360 MMBF. 

Comment: One comment stated that the: “Figure 3.13-11 on page 3-261 (of the Draft EIS) 

incorrectly depicts the volume that must be harvested to supply a veneer plant and an MDF plant. 

The 80 to 100 MMBF of utility logs and chips required by an MDF facility cannot realistically be 

produced from 250 MMBF of timber harvest.”

Response: This comment is not clear. There is no Figure 3.13-11 on this page. It is possible that the 

comment author actually meant to refer to Table 3.13-11, which is on this page, but the comment does 

not appear to pertain to this table, which identifies the sawlog and utility volume identified for each 

alternative and does not identify the volume needed to supply a veneer plant or any other specific facility. 

The ability of each alternative to supply the minimum volumes required by various processing facilities is 

evaluated in the timber demand analysis in the Economic and Social Environment section of the EIS. 
Appendix H

Final EIS H-35 Comments and Responses

Comment: Many comments disagreed with the estimates of demand presented in the Draft EIS. 

Some requested that the Final EIS be clear that not everyone agrees with these estimates of 

demand.

Response: Projected timber demand is discussed in detail in the Economic and Social Environment

section of the Final EIS. This section presents a range of demand estimates and projections, and 

discusses uncertainty about future demand, other studies, and differences of opinion. 

Comment: One comment pointed out that the likelihood of a third party developing an MDF or 

veneer plant in Southeast Alaska was very low, even under Alternative 7. The comment author 

cited the recent closure by Weyerhaeuser of two of their veneer plants in Oregon. Weyerhaeuser 

reportedly stated that these closures were the result of reduced demand for plywood panels due 

to the decline in the housing market and the increased availability of competing products. The 

comment author pointed out that Weyerhaeuser supplied these mills from tree farms adjacent to 

highways and the facilities themselves were located less than two hours from a major Pacific port. 

Response: The derived demand scenarios developed by Brackley et al. (2006a) presented MDF plants 

as an example of how derived demand for low-grade and utility wood might be stimulated. Other 

possibilities include development of biofuels markets, bioenergy applications, or shipment to markets and 

processors elsewhere. Chip prices are volatile and depend on many factors; if chip supplies go down 

regionally and demand increases, prices will increase to the point that shipments of low-grade material 

over longer distances will become a viable option. In the case of biofuels or bioenergy, as the prices of 

substitutes (e.g. oil and gas) increase, the probability of using wood products in these applications will 

increase. The scenarios presented in Brackley et al. (2006a) are designed to encompass a variety of 

future possibilities. 

Comment: A number of comments stated that it is not the Forest Service’s responsibility to 

develop a wood products industry in Southeast Alaska if that industry cannot be operated in an 

economically and ecologically sustainable manner. Others felt that the current industry was 

sustainable. 

Response: The Forest Service is required to seek to meet market demand under the terms of TTRA. 

The existing and proposed Forest Plans are designed to ensure that timber harvest on the forest is 

conducted in a manner that is ecologically sustainable. The EIS evaluates potential demand using a 

number of possible future scenarios. The timber industry will not develop in the region if individual 

facilities are not economically sustainable (i.e., able to operate at a profit). 

Comment: One comment stated that given that the Forest Plan is revised every 5 years it is not 

necessary to project timber demand far into the future and current demand levels should be used 

as a guideline. 

Response: The Forest Plan undergoes a periodic review process every 5 years. The results of the most 

recent 5-year review are discussed on the Tongass National Forest’s 5-year review web site 

(http://www.tongass-5yearreview.net/). The review process is not, however, the same as revising or 

preparing a new plan, this occurs every 10 to 15 years. 

The Tongass estimates timber demand on an annual basis, but is also required under TTRA to seek to 

meet demand for each planning cycle. In order to seek to meet this demand, it is necessary to develop 

projections of demand over the planning cycle and into the future. It is, however, also important to note, 

as stated in the Draft and Final EIS documents, that the Forest Plan itself does not authorize any timber 

harvest. Rather, harvest is authorized by site-specific timber sale projects, which implement the plan. In 

other words, the plan does not directly meet demand for timber; rather it sets the conditions under which 
Appendix H 

Comments and Responses H-36 Final EIS 

the Forest Service can seek to meet market demand through the cumulative sales of the annual timber 

sale program over the planning cycle. 

Comment: One comment asked whether TTRA requires the Forest to meet global timber demand 

or only local demand. 

Response: The TTRA does not make a distinction between local and global demand. The Tongass 

seeks to meet annual demand with the timber offer calculation outlined by Morse (2000). The calculation 

of planning cycle demand by PNW Research Station scientists is derived demand in end markets for 

Tongass wood products, wherever those end markets may be. 

Regional Economy 

General

Comment: One comment stated that the McDowell Group’s 2007 report to the Southeast 

Conference shows that population in Southeast Alaska has decreased since 2000, while the total 

population in Alaska has increased by 6.9 percent over the same period. The comment authors 

urged that the Forest Service to consider and use this information in the Final EIS. 

Response: This information is presented in both the Draft and Final EIS documents. See Table 3.22-33 

in the Draft EIS. (Note that according to the U.S. Census Bureau, the population of Alaska grew by 5.9 

percent between 2000 and 2005, not 6.9 percent as stated in the comment [Table 3.22-33; U.S. Census 

Bureau 2007]). Population data for 2006 are now available and have been added to the Final EIS. 

These data indicate that the population of Southeast Alaska declined from 70,822 in 2005 to 70,053 in 

2006 (Alaska DOL 2007a). 

Comment: One comment noted that population has increased by 31 percent in Southeast Alaska 

since closure of the pulp mills and total personal income increased by 14 percent. The comment 

author noted that if the timber industry really were the “be all and end all” of the Southeast Alaska 

economy, these numbers would be going down, not up.

Response: Data for key economic indicators for 1995 and 2004 are presented in Table 3.22-1 in the 

Draft and Final EIS documents. These data do not support the trends identified in the above comment. 

When adjusted for inflation, total personal income decreased by 4 percent over this period and per capita 

income decreased by 1 percent. Total population decreased by 4 percent over this period and total 

employment was approximately the same in 2004, as in 1995. These data provide a useful overview of 

the Southeast Alaskan economy, but it is important to understand that the costs and benefits of the 

current transition in the regional economy are not evenly distributed. This is discussed further in the 

Subregional Overview and Communities section of the EIS. 

Comment: One comment cautioned the use of regional statistics to evaluate the economy of 

Southeast Alaska and pointed out that Juneau accounts for 40 percent of the population and more 

than half of the region’s economy, and may mask significant trends in other parts of the local 

economy. 

Response: This concern is specifically addressed in the Draft and Final EIS documents. The section of 

the EIS that characterizes the Regional and National Economy presents regional data, as noted in the 

comment, but cautions that the trends exhibited by these data are not evenly distributed throughout the 

region and refers the reader to the Subregional Overview and Communities section of the document. The 

Subregional Overview and Communities section of the EIS addresses this concern directly and provides 
Appendix H

Final EIS H-37 Comments and Responses

and analyses data at the Borough and Census Area level. This is noted on the second page of the 

Economic and Social Environment section of the EIS. 

Comment: One comment stated that the 1995 total personal and per capita income figures for 

Southeast Alaska presented in 2005 dollars in Table 3.22-1 appear to be incorrect. 

Response: The 1995 income figures presented in Table 3.22-1 were developed using data from the U.S. 

Bureau of Economic Analysis (2006a). These data are compiled by Borough and Census Area. The 

estimates presented in Table 3.22-1 were developed by combining the Bureau of Economic Analysis data 

for the Boroughs/Census Areas that comprise Southeast Alaska. The resulting estimates were then 

adjusted for inflation using the Consumer Price Index (All Urban Consumers). A review of these 

calculations did not identify any errors. Table 3.22-1 has been updated in the Final EIS. 

Comment: One comment stated that the data presented in Table 3.22-3, which estimate natural 

resource-based employment for 1995 and 2004, “significantly understate the magnitude of the 

decline experienced by the timber products industry following the passage of the Tongass Timber 

Reform Act in 1990.” 

Response: Table 3.22-3 is part of the section of the EIS that provides a general overview of natural 

resource-based industry in Southeast Alaska and is not intended to illustrate the full extent of the 

reduction in wood products employment that has occurred since employment peaked at 3,543 jobs in 

1990. (Note that this table has been updated and revised in the Final EIS). The general overview is 

followed by sections that discuss specific natural resource-based industries in detail. The section that 

discusses the wood products industry presents employment data from 1986 to 2005. 

Comment: One comment stated that the EIS should explain that the data presented in Table 3.22-

2 provide a poor representation of the contribution made by natural resource-based industries to 

the economy of Southeast Alaska, especially the commercial fishing and recreation and tourism 

sectors. Another comment noted that this table “inexplicably” lumps together “forestry, fishing, 

related activities, and other” into one category and fails to distinguish between these important 

sectors. 

Response: The shortcomings of the data presented in Table 3.22-2 are discussed with respect to 

Recreation and Tourism in the paragraphs immediately following Table 3.22-2. (Note this table has been 

updated in the Final EIS). The section of the EIS that follows Table 3.22-2 presents estimates of natural 

resource-based employment by sector and includes estimates of commercial fishing and recreation and 

tourism-related employment developed from other sources. More detailed employment estimates are 

provided in the following sections that address each natural resource-based industry in turn. 

The data presented in Table 3.22-2 are from datasets compiled by the U.S. Bureau of Economic Analysis. 

These data are compiled and made available in accordance with the North American Industry 

Classification System (NAICS), which groups establishments and employees into the categories shown in 

Table 3.22-2. 

Comment: Several comments expressed the concern that the economic analysis in the Draft EIS 

failed to adequately consider the impacts of logging on other sectors of the economy, and failed 

to adequately quantify other sectors. One comment noted that the Draft EIS “alternatives fail to 

consider the economic realities of standing forest and what it represents monetarily via tourism 

and other recreational and commercial uses beyond timber.” One comment recommended that 

logging be phased out as jobs increase in recreation, tourism, and other sectors. Another 

comment noted that timber harvest is a single use of the forest that reduces other uses of 

harvested areas for many decades. 
Appendix H 

Comments and Responses H-38 Final EIS 

Response: The economic and social analysis presented in the EIS assesses the potential economic 

impacts of the proposed alternatives on recreation and tourism in terms of the effects that projected 

timber harvest and associated road building would have on available recreation opportunities on the 

Forest. The current and proposed Forest Plans include standards and guidelines specifically designed to 

protect Forest values and resources and the economic activities and values associated with them. 

The affected environment portion of the Economic and Social Environment section discusses natural 

resource-based economic sectors of the economy at some length, including wood products, recreation 

and tourism, commercial fishing, mining, and the economic value of natural amenities and quality of life. 

The environmental consequences addresses the potential impacts to these resources, as well as other 

non-use values, including passive use values and ecosystem services. 

Comment: A number of comments expressed concern that timber harvest in areas surrounding 

local communities or areas that are popular for recreation and other uses would have detrimental 

effects on these areas and the economic activities that depend upon them. The same concern 

was expressed with respect to fish and the recreational angling and commercial fishing industries 

that depend on healthy populations of fish. 

Others expressed the same general concern, noting that the Tongass National Forest is worth 

more intact than as harvested timber. Along these lines, many comments stated that the Forest 

should be managed to support sustainable levels of recreation and tourism, commercial fishing, 

and subsistence, with timber harvest limited to small sales for local, value-added processing. 

Response: Concerns raised with respect to impacts to specific places are addressed in Section C of this 

appendix. In general, it may be noted that this EIS provides a programmatic forest-wide analysis 

appropriate for a strategic Forest Plan Amendment. Site-specific projects or activities are best examined 

locally during the decision making process as appropriate for that action. Specific concerns raised with 

respect to the potential impacts of the proposed alternatives on the commercial and recreational fishing 

industries are addressed in the following Commercial Fishing subsection. 

The management alternatives presented in the EIS are all designed to support sustainable levels of 

recreation and tourism, commercial fishing, and subsistence. The areas potentially available for timber 

harvest would, however, vary by alternative, with projected harvest volumes ranging from approximately 

49 MMBF per year under Alternative 1 to 421 MMBF per year under Alternative 7. 

Comment: One comment requested that the EIS disclose the opportunities for commercial timber, 

minerals, and other uses that are foregone in areas allocated to Wilderness, National Monument, 

OGRs, and other restrictive LUDs. They requested that these foregone opportunities be 

quantified in acres, volume, value, and improved habitat. 

Another comment urged the Forest Service to “conduct a comparative economic analysis of the 

short and long term economic impacts of leaving unprotected roadless areas as intact wilderness 

or having these same areas logged.” Another comment requested that the environmental and 

opportunity costs of opening an area to intensive resource development be quantified in the 

overall feasibility evaluations of opening any new areas to this type of development. 

Response: There are trade-offs or opportunity costs associated with all of the alternatives evaluated in 

the EIS. The decision to allocate an area to one type of use or management often precludes another use, 

although this isn’t always necessarily the case. The EIS analysis evaluates the potential environmental 

impacts of the proposed alternatives by resource and, as a result, implicitly includes the trade-offs or 

opportunity costs associated with each alternative. The EIS does not, however, provide a Forest-wide 

inventory of resources that would be available assuming that existing Congressionally-mandated land 

designations and other management policies were not in place because these designations and policies 
Appendix H

Final EIS H-39 Comments and Responses

will remain in place regardless of the alternative selected. As a result, this type of inventory would not 

contribute to the decision making process that the EIS is designed to facilitate. 

The alternatives evaluated in the Final EIS examine a broad range of options concerning roadless areas 

and logging. Although the EIS does not provide a comparative analysis of the economic impacts of 

preserving existing roadless areas or logging all of these areas, Alternative 1 in the Final EIS protects all 

roadless areas and may be compared with the other alternatives that each include varying levels of 

harvest in roadless areas (see the Economic and Social Environment section in the Final EIS). 

The analysis presented in this EIS is programmatic and provides overall Forest-wide direction. Projectspecific analyses are conducted for specific projects, such as a timber sales or recreation developments. 

Project-level analyses do not typically use the term “opportunity costs”, but essentially quantify all the 

impacts—negative and positive—of a proposed project. Potential impacts may include impacts to 

subsistence, wildlife, or particular sectors of the economy. 

Comment: One comment noted that the data included in the Socioeconomic Setting section on 

page 3-8 of the Draft EIS were from 1999 and pointed out that these data should be updated in the 

Final EIS. The comment author stated that the updated data will show that the economy is even 

worse now then it was in 1999 and will show that it is “crucial that the (Forest Plan) do everything 

possible to help the economy.” 

Response: The data identified in this comment have been updated in the Final EIS. These data simply 

identify total population and the largest economic sectors in the region based on employment. More 

detailed analysis of economic and social trends is provided in the Economic and Social Environment

section of the EIS. The Economic and Social Environment section in the Draft EIS included the most 

recent data available when the Draft EIS was prepared, and these data have been updated for the Final 

EIS, as appropriate. 

Comment: One comment requested that the introduction to the Economic and Social 

Environment section of the EIS (page 3-403 in the Draft EIS) identify “adequate infrastructure” as 

an essential element of a healthy economic and social environment. 

Response: The introduction to the Economic and Social Environment section provides a brief overview 

of the contribution of resources from the Tongass National Forest to local communities and the regional 

economy. A general statement about infrastructure is not consistent with the intent of this short section. 

Potential impacts to transportation and utilities are discussed in the Environmental Consequences part of 

the Economic and Social Environment section of the EIS, as well as in the Transportation and Utilities

section. 

Comment: One comment stated that commercial fishing is the largest natural resource industry 

in Southeast Alaska, not recreation and tourism, as stated in the Draft EIS. The comment also 

stated that the number of pages spent discussing each natural resource sector in the economic 

impact analysis reflects the relative level importance assigned by the Forest Service, as well as 

the level of analysis, with Timber assigned 16 pages and Commercial Fishing less than 1 page. 

Response: Natural resource-based industries and their relative contribution to the regional economy of 

Southeast Alaska are discussed in detail in the subsection titled “Natural Resource-Based Industries” in 

the Economic and Social Environment section of the Draft and Final EIS documents. Based on estimates 

for 2004 presented in the Draft EIS, the recreation and tourism sector employed more people than the 

commercial fishing sector (see Table 3.22-3 and Figure 3.22-2 in the Draft EIS). These estimates have 

been updated in the Final EIS. 
Appendix H 

Comments and Responses H-40 Final EIS 

The relative number of pages allocated to a subject is not a reliable indicator of the importance assigned 

to an issue by the Forest Service. However, the commercial fishing section of the economic impact 

analysis is relatively short because: 1) it is not one of the key issues identified through the 2005 Court 

ruling or the 5-Year Forest Plan Review (see Chapter 1 of the Draft and Final EIS documents for details); 

and 2) there are no effects to commercial fishing employment anticipated over the 10 year timeframe of 

this analysis. This conclusion draws upon the analysis prepared for the 1997 Final EIS, which is 

incorporated in this EIS by reference. 

In contrast, the supply of timber is a major focus of this EIS. Key Issue 2 for the EIS responds to the 

requirement under TTRA that the Forest Service seek to meet market demand for timber in Southeast 

Alaska. Estimating market demand is a difficult and contentious task and this is reflected in the Draft and 

Final EIS documents. The timber section of the economic impact analysis assesses the alternatives with 

respect to a number of different demand indicators and other measures of demand and supply. 

Comment: A number of comments emphasized that the timber industry provides relatively highly 

paid jobs that last all year round. This type of comment often involved a comparison with 

recreation and tourism-related employment, which was typically characterized as relatively low 

paid and seasonal. One comment also argued that employment in the timber industry is more 

stable than that in other natural resource sectors.

Response: Wood products jobs do tend to be relatively high paid, with recreation and tourism-related 

employment often relatively low paid and seasonal, but this is not necessarily always the case. The Final 

EIS looks at a wide range of alternatives built around the issue of timber harvesting. Three alternatives 

feature a reduced land base available for logging while two alternatives increase the lands available. 

Multipliers

Comment: One comment stated that the economic impact analysis presented in the Draft EIS is 

“fatally flawed” because it uses economic multipliers, derived from the IMPLAN economic model, 

to estimate indirect and induced employment and income impacts. They cite several studies, both 

empirical and theoretical, to support their claim that impact multipliers in general, and inputoutput models in particular, do not provide accurate estimates of total economic impact. The 

comment also argued that IMPLAN does not provide comparable details for all resource-based 

sectors of the economy and is biased toward timber. The comment author sees evidence of this 

bias in the structure of the model data, which provides data for the lumber and wood products 

sector, but does not identify a recreation sector. 

Response: Some professional economists disagree on the utility of static impact multipliers of the type 

produced by IMPLAN and similar input-output models. These models are, however, a standard tool for a 

broad range of regional analyses conducted by government agencies, academics, and other entities 

interested in estimating the economic impacts of different policy options. IMPLAN in particular has been 

used in numerous and various policy analyses and research settings. The economic impact analysis 

presented in the EIS follows standard analysis procedures by using the IMPLAN model. The analysis in 

the EIS is accompanied by an explicit caveat recognizing that some economists may have reservations 

about the validity of this methodology. As noted in the Draft EIS (pg. 3-410): 

“Concerns have been raised with respect to the ability of IMPLAN and similar input-output models to 

accurately predict indirect and induced effects. Alternate techniques for estimating these effects are, 

however, subject to the same, or similar, criticisms and more accurate estimates are not readily 

available for this analysis. While the multipliers presented here should be viewed with caution, the 

resulting estimates of indirect and induced employment provide a basis for comparison between 

alternatives.” 

In addition, the EIS is careful to distinguish between direct effects on one hand and indirect and induced 

effects on the other. 
Appendix H

Final EIS H-41 Comments and Responses

The multipliers used to assess timber impacts are easier to derive from the IMPLAN model than those 

used to assess recreation and tourism, as noted in the comment. As noted in the same comment 

document, “recreation is scattered among a variety of industries generally classified in services and retail, 

with some in transportation.” The IMPLAN model uses data compiled from standard economic sources 

and it is more likely that the absence of a single recreation sector in the model reflects the form of the 

source data, rather than a deliberate bias toward timber. 

Comment: Another comment also urged caution in the use of IMPLAN data noting that 

employment and income multipliers for Southeast Alaska can be highly variable from year-to-year 

and provided examples of employment multipliers based on 2004 IMPLAN data: logging (2.18), 

sawmills (2.1), gold/silver mining (1.92), commercial fishing (1.22), and seafood processing (1.94). 

The same comment also provided examples of income multipliers. 

Response: As noted in the above comment and on page 3-410 of the Draft EIS, the actual magnitude of 

the estimated multipliers should be viewed with caution. 

The numbers provided in the above comment are different from those used in the EIS, which are based 

on IMPLAN data from 1998. The differences are less than 0.5 in all cases, except sawmill income where 

the difference is 0.78. The use of different multiplier coefficients would affect the total employment 

estimates across all alternatives, but would not affect the relative ranking of the alternatives. Using the 

employment coefficients for timber (sawmills and logging) provided in the comment instead of those used 

in the EIS would, for example, increase the total employment estimate for each alternative by about 8 

percent. As noted in response to the preceding comment: the EIS is careful to distinguish between direct 

effects on one hand and indirect and induced effects on the other. 

The main purpose of using multipliers in this analysis is to acknowledge that economic activity in one 

sector has impacts elsewhere in the economy and these potential impacts should be taken into account 

when considering the employment impacts of the alternatives. 

Comment: One comment noted that a study of the multiplier effect in Southeast Alaska found that 

the multiplier effect with respect to jobs in Southeast Alaska was effectively zero. Another 

comment noted that: “IMPLAN, while useful for appraising the total economic impacts of a Forest 

Plan is insufficient for evaluating impacts on communities.” 

Response: The Forest Service is not aware of a study with the finding that the multiplier effect in 

Southeast Alaska is effectively zero. Research conducted in Southeast Alaska communities did, 

however, find that indirect employment coefficients while applicable at large scales, such as large 

regional or statewide assessments, are not useful at small local scales and may be misleading 

(Robertson 2003). This may be the study that the comment author is referring to. 

The multipliers derived from IMPLAN are used in the EIS analysis to assess the total economic impacts of 

the Forest Plan (as recommended in the comment) at the regional level (Southeast Alaska as whole). 

They are not used to evaluate impacts at the community level. 

Comment: One comment noted that inadequate supplies of timber not only affect loggers and 

mills, but also specialized support businesses and other elements of the timber industry 

infrastructure. The comment notes that if these people leave the industry will fail. 

Response: The economic impact analysis presented in the EIS uses economic multipliers to account for 

potential indirect and induced employment and income impacts. The indirect component for the timber 

industry includes employment and income in industries that provide specialized support and other inputs 

for the timber industry. This type of analysis does not establish levels of economic activity necessary to 
Appendix H 

Comments and Responses H-42 Final EIS 

sustain particular industries or support services, but it seems reasonable to assume that the size of an 

industry or business is directly related to its market. 

Timber

Comment: The statement on page 3-415 of the Draft EIS that the overall patterns of harvest levels 

shown in Figure 3.22-5 generally reflects broader trends in the wood products market 

oversimplifies the situation. Market trends were just one of many factors influencing harvest 

levels, equally important were reductions in timber supply from the Tongass. 

Response: The comment takes the cited statement out of context. The EIS acknowledges that timber 

demand and harvest has been influenced by a number of factors. The overall trend shown in Figure 

3.22-5 does, however, mirror broader trends in the wood products market, as discussed in the Draft and 

Final EIS documents. 

Comment: Table 3.22-8 in the Draft EIS compares the ASQ on the Tongass from 1994 to 2005 with 

actual harvest levels. One comment observed that the Ketchikan Pulp Corporation would have 

logged “a lot more in the 1990s” if the volume had been available and noted that “1995 was the 

highest market of all time.” 

Response: The table referenced in the comment compares actual harvest levels from 1994 through 

2005 with the ASQ for those years. Harvest volumes from 1986 to 2005 are shown graphically in Figure 

3.22-5 in the Draft EIS. (Note: this table and figure have been updated in the Final EIS). These data are 

provided to illustrate the discrepancy between ASQ levels and actual harvest and display trends over 

time. As noted in response to the preceding comment, the EIS acknowledges that timber demand and 

harvest have been influenced by a number of factors. 

Comment: The wood products employment projections in the EIS assume a linear relationship 

between harvest and employment levels, with a one percent change in harvest resulting in a one 

percent change in employment. One comment was concerned that given current trends in 

automation, there is no direct linear relationship between harvest and employment and the use of 

this assumption may lead to an overestimate of timber employment under the higher volume 

alternatives. 

Response: As noted in the Draft and Final EIS documents, the linear relationship between harvest and 

employment is an approximation assumed for the purposes of analysis to allow a comparison between 

alternatives. The relationship between harvest and jobs expressed in the Final EIS as jobs/MMBF is 

based on data collected from 2000 to 2005 (Alexander 2007). The logging and sawmill jobs/MMBF 

coefficients were revised between the Draft and Final EIS documents. These coefficients are believed to 

be representative of current conditions and are suitable for a comparison of alternatives. 

While the resulting projections are suitable for a comparison of alternatives, the absolute values should 

be treated with caution, especially those for the higher volume alternatives. The main reason for this 

caution pertains to the jobs/MMBF coefficients, rather than the idea that ongoing automation could sever 

the relationship between harvest volume and related employment. The existing job/MMBF coefficients 

are based on the current industry structure. The higher volume alternatives assume that a veneer mill 

and some other form of “demand stimulation”, such as an MDF plant, will also be in operation. The 

jobs/MMBF coefficients associated with these facilities are likely different than those associated with the 

sawmills that comprised the industry from 2000 to 2005. Other changes in industry structure or outputs, 

such as an increase in value added products oriented toward local markets, could also result in different 

coefficients. 
Appendix H

Final EIS H-43 Comments and Responses

Comment: One comment noted that many logging jobs go to people from out of state and do not 

contribute to the local economy. This, they stated, is probably not considered in the Draft EIS 

analysis. 

Response: As noted in the Draft and Final EIS documents, nonresidents account for approximately 35 

percent of the employment in the logging industry. This is not accounted for in the direct employment 

estimates, but the total employment estimates are based on region-specific multipliers that take into 

account the fact that some of the income generated through logging employment is spent outside the 

region. Non-resident participation is high for all resource-based employment in Southeast Alaska (see 

Figure 3.22-2 in the Final EIS). 

Recreation and Tourism

Comment: One comment stated that the Draft EIS incorrectly used studies by McDowell Group 

(1999) and Global Insight (2004) to estimate the economic activity associated with the recreation 

and tourism sector in Southeast Alaska. The comment notes that both studies include resident 

and non-resident business travel, as well as vacation travelers and, therefore, estimates 

developed using these studies overestimate recreation and tourism-related economic activity. 

Response: The basic approach and estimated coefficients from the 1999 McDowell Group study were 

used to develop estimates of recreation and tourism-related economic activity for 1999 and 2001 in the 

Draft and Final Tongass SEIS documents, respectively. The findings of this study were used indirectly in 

the Draft EIS to help estimate the current contribution of recreation and tourism to the regional economy. 

The McDowell Group study addressed vacationers, business travelers, and those combining business 

and pleasure, as noted in the comment. However, the study identified the relative share of the total visitor 

impacts associated with what they termed the “vacation/pleasure visitor component” and this ratio was 

used to adjust the data used in the Draft EIS analysis. The resulting estimates were, as a result, broadly 

representative of recreation and tourism (or vacation/pleasure visitors), and not all visitors. This estimate 

and discussion has been substantially revised in the Final EIS, which presents employment data for the 

Leisure and Hospitality sector as a proxy for recreation and tourism. 

Comment: One comment stated that the Draft EIS does not account for the differences in the 

value of different types of recreational experiences. The comment cited a recent study that 

compared sportfishing expenditures in unroaded areas around Bristol Bay with those in roadaccessible areas on the Kenai Peninsula and found that expenditures in the unroaded areas were 

38 times higher than those in road-accessible areas.

Response: As discussed in the Draft EIS (page 3-429), the recreation and tourism economic analysis is 

based on a number of simplifying assumptions, including the following: 

“This approach assumes that the average amount of employment generated by a single RVD is 

constant over time and that this number is the same for both Tongass-related recreation and the 

region as a whole, as well as for different types of recreation on the Tongass.” 

The Draft and Final EIS documents explain that: “While these assumptions may not accurately reflect 

underlying realities, they are necessary to produce a quantified estimate of the relation between 

recreation activity and employment.” 

Comment: One respondent presented the following comments. The analysis assumes that the 

projected reduction in the supply of primitive and semi-primitive recreation opportunities would 

not be severe enough to limit consumption because it assumes that demand would only increase 

by 18 percent over the 2005 to 2010 period. Evidence from California suggests that the demand 

for wilderness hiking and camping by residents increased by 42 percent between 1990 and 1998 
Appendix H 

Comments and Responses H-44 Final EIS 

(Outdoor Industry Foundation n.d.). The EIS should at a minimum include a sensitivity analysis 

that assesses the relative impacts of different projected consumption growth rates. 

In addition, given the long-term impacts of timber harvest and other development activities, the 

recreation component of the economic impact analysis should extend beyond 2010. Even at the 

low growth rates assumed by the analysis, projected demand would begin to exceed supply in 

2017 under Alternative 7 and 2019 under Alternative 1. 

Response: The recreation and tourism component of the economic impact analysis presented in the EIS 

is based on projected future demand and changes to Recreation Opportunity Spectrum (ROS) settings in 

recreation places by alternative. The key assumptions used in this analysis include the use of a linear 

projection based on 1984 to 1995 data collected for recreation places to project future demand (see 

Figures 3.22-7 and 3.22-8 in the EIS) and a series of assumptions about the effects that timber harvest 

would have on ROS settings to estimate the effects of the alternatives on recreation supply. 

The demand projection used for the analysis in the EIS relies upon a number of simplifying assumptions 

(as noted in response to the preceding comment and in the Draft and Final EIS documents), but is based 

on Tongass-specific data and is the best currently available information for the Tongass. The analysis in 

the Final EIS has been adjusted and compares projected changes in ROS supply for the first decade 

following implementation (presented as annual average estimates by alternative) with projected demand 

for 2015. 

The demand projection used in this model assumes that overall recreation demand would increase by 36 

percent from 2005 to 2015. This analysis suggests that demand for ROS1 opportunities would begin to 

exceed supply in 2020 under Alternative 7 and in 2022 under Alternative 1. Increasing the expected 

growth rate in ROS1 demand, as suggested in the comment, results in demand for these opportunities 

exceeding projected supply sooner under all alternatives, but does not increase the differences between 

the alternatives. Projected ROS1 supply under all alternatives would be exceeded within a two to three 

year period and, therefore, the overall effects would remain similar. 

It is also important to recognize that, as explained in the Draft and Final EIS documents, the purpose of 

this analysis is to allow a quantitative comparison between alternatives. The likelihood of demand for 

primitive and semi-primitive recreation opportunities exceeding supply on the 16.9 million acre Tongass 

National Forest in the foreseeable future is low for at least two reasons. First, the analysis discussed in 

the comment is for identified recreation places only (see the Recreation and Tourism section of the EIS 

for details), not the entire forest. In other words, ROS1 supply is assumed to be limited to just 2.2 million 

acres from the total of 13.4 million acres of ROS1 available on the Forest (see Table 3.15-3 in the 

Recreation and Tourism section of the EIS), which viewed in RVDs (using the same assumptions as the 

model) is seven times the projected demand in 2015. 

Second, in order to emphasize the differences between the alternatives, the analysis assumes that 25 

percent of the change in ROS settings projected to occur over a 160 year analysis period would happen 

in the first decade following implementation (by 2015 in the Final EIS). This would not happen, but 

without this assumption there is very little difference between alternatives. 

This analysis is designed to assess the programmatic effects of the alternatives and the finding that there 

is little difference between the alternatives is consistent with this scale of analysis, with standards and 

guidelines expected to minimize potential impacts on cruise ship routes and popular activities and reduce 

the potential for overcrowding in wilderness areas under all alternatives. There could, however, be 

important differences between alternatives on a project-by-project basis, with the alternatives that permit 

more intensive timber harvest potentially impacting existing or potential outfitter/guide use areas and 

other nature-based activities. These potential impacts are identified with respect to important recreation 

places in the Recreation and Tourism section of the EIS. 
Appendix H

Final EIS H-45 Comments and Responses

Commercial Fishing

Comment: Several comments questioned the finding that there would be no impact to the 

commercial fishing industry. 

One comment referenced a recent study prepared for Trout Unlimited (Curley and Bristol 2006), 

which suggests that the majority of salmon originate on the Tongass and depend on roadless 

watersheds. This study, they argue, suggests that timber harvest and road building in roadless 

watersheds would have negative impacts on fish and the commercial fishing industry. The 

comment also pointed out that the fact that much of the future of the fishing industry in Alaska is 

expected to be dependent on factors outside of the Tongass National Forest is beside the point. 

The EIS, they argue, needs to evaluate the potential impacts of the alternatives with all other 

things assumed to be equal. 

Another comment stated that the conclusion that there would be no impact to the commercial 

fishing industry under any of the alternatives ignores a number of issues, including harvest on 

steep slopes with unstable soils and problems with road maintenance and culverts, among 

others. 

Response: The economic impact analysis presented in the Draft and Final EIS documents does discuss 

broader trends that are likely to affect commercial fishing in the future, but also states: “There is not 

expected to be any significant effect to the commercial fishing or fish processing industries over the next 

decade as a result of National Forest activities” (Draft EIS, page 3-457). This, as explained in the Draft 

and Final EIS documents, is because the projected levels of timber harvest represent a relatively small 

proportion of the remaining productive old growth (POG) on the Tongass and an even smaller proportion 

of the entire Forest. In addition, the Riparian Management Standards and Guidelines established in the 

current Forest Plan and included in the Final Proposed Forest Plan are designed to protect salmon 

habitat and prevent impacts to salmon and other aquatic species. 

Risks to aquatic resources would increase with more harvest (see the Fish section in the Draft and Final 

EIS documents). Site-specific evaluations would occur with each timber sale to evaluate potential 

adverse impacts to aquatic resources and identify mitigation measures to reduce any potential impacts. 

One of the goals of project-specific NEPA documents is to ensure that project actions do not result in 

significant adverse impacts to important resources. The potential impacts of the alternatives on fish are 

discussed in more detail in the Fish section of the Draft and Final EIS documents. The study referenced 

in this comment is discussed in the Fish section of this comment response appendix. 

The potential impacts of the past practices and related management actions identified in the last part of 

the comment are part of the baseline for all of the alternatives and would not vary by alternative. These 

potential impacts are discussed in the Fish section of this comment response appendix and the Fish

section of the EIS. 

Comment: One comment stated that in addition to direct timber harvest-related impacts to fish, 

the commercial fishing industry would also be severely impacted if any species of concern, such 

as the marbled murrelet, were listed as endangered under the Endangered Species Act (ESA) as a 

result of timber harvest practices. 

Response: As discussed in response to comments on the Wildlife section of the EIS, the potential 

effects of timber harvest on old-growth habitat are discussed under the marbled murrelet subsection of 

the wildlife analysis, and tables indicating the distribution and protected status of this habitat are provided 

in the Biodiversity section. The potential effects of the proposed alternatives on other species of concern 

are also addressed in the Wildlife section of the EIS. None of the alternatives are expected to result in 

fish or wildlife species on the Tongass being listed as endangered under ESA. 
Appendix H 

Comments and Responses H-46 Final EIS 

Comment: One comment questioned why the discussion of the commercial fishing and seafood 

processing industries in the Draft EIS focuses on salmon, even though the text acknowledges that 

other species comprise about one-quarter of the region’s total catch on a total value basis. The 

comment also expressed concern that the Draft EIS uses data from 1994 to discuss salmon’s 

share of the commercial fishing industry and requested that this information be updated in the 

Final EIS. 

Response: The rationale for this decision on page 3-431 of the Draft EIS (and cited by the above 

comment author) is as follows: 

“While commercial salmon fishing comprises the bulk of Southeast Alaska’s fishing industry, halibut, 

crab and herring fishing combined makes up a substantial proportion of the region’s total catch 

(approximately 24 percent in 1994 on a value basis). There is an important connection between 

salmon and other wildlife and fish species on the Tongass. Crab, halibut, herring, bears, eagles, and 

other species depend on the annual return of millions of salmon and on the juvenile salmon produced 

in the Tongass streams and lakes. As a result, management decisions that affect salmon indirectly 

affect other species that are commercially fished. These relationships are, however, poorly 

understood and difficult to quantify. The commercial fishing discussion presented in this section, 

therefore, focuses on the salmon fishery. Data available for the seafood processing industry, 

however, do not allow for an easy distinction between salmon processors and other firms. Data 

presented for the seafood processing sector, therefore, include the entire seafood processing 

industry.” 

This statement is also included in the Final EIS. This is consistent with the analysis presented in the 

1997 Final EIS and the 2003 SEIS. 

Salmon comprised approximately 42 percent of the commercial fishing industry in 2005 based on exvessel value. Halibut, crab, and herring combined, comprised 30.7 percent of the industry in 2005, 6.7 

percent more than in 1994 (Alaska DOL 2007e). From 2000 to 2006, salmon harvesting ranged from 41 

percent to 48 percent of total fish harvesting employment in Southeast Alaska, comprising 47 percent of 

the total in 2006 (Alaska DOL 2007d). This information has been added to the Final EIS. Employment 

data have also been added for the non-salmon components of the commercial fishing industry. However, 

as noted above, the focus of the commercial fishing impact discussion remains on the salmon fishery. 

Comment: One comment was concerned that self-employed commercial fishermen were not 

included in Tables 3.22-1, 3.22-3, and 3.22-4 in the Draft EIS. The comment asked: “how is it ... 

that whole fisheries and their self-employed participants have ... ‘disappeared’ from the ... 

employment estimates presented in the Draft EIS?” The comment author states that the analysis 

is “hopelessly flawed and patently dishonest” because it fails to include these numbers. 

Response: As stated in the Draft EIS and contrary to the concern raised in the comment, self-employed 

salmon fishermen are included in the salmon harvesting employment estimates (see, for example, page 

3-410, final paragraph or page 3-432, footnote 3). These totals were calculated using data from the 

Alaska Commercial Fisheries Entry Commission and the methodology employed in the 1997 Forest Plan 

Revision Final EIS analysis (see, for example, Table 3.22-3 in the Draft EIS, note 4). 

Employment data were presented in the Draft EIS for the salmon component of the commercial fishing 

industry only. Employment data associated with other components of fishing industry were not included 

in these totals. Salmon harvesting continues to be the focus of the commercial fishing discussions in the 

Final EIS. Employment data are, however, provided for the entire commercial fishing sector in Southeast 

Alaska in the Natural Resource-Based Industries overview presented in the Final EIS. 
Appendix H

Final EIS H-47 Comments and Responses

The following paragraphs address the specific tables referenced in the comment. 

Table 3.22-1: This table provides an overview of the Southeast Alaska economy and does not present 

data by industry. The average annual employment data presented for Southeast Alaska are from data 

compiled by the U.S. Bureau of Economic Analysis (BEA) and include self-employed workers. 

Table 3.22-2: The data presented in this table were also compiled by BEA. These data are compiled and 

made available in accordance with the North American Industry Classification System (NAICS), which 

groups the industries, as shown. Self-employed workers are included in the “proprietors employment” 

category. This information is not available by industrial sector at the borough/census area level. 

Table 3.22-4: This table presents employment and income multipliers for various natural resource sectors 

in Southeast Alaska, including the salmon harvesting and seafood processing sectors. It does not 

present employment estimates. 

Natural Amenities and Quality of Life

Comment: One comment states that while the Draft EIS acknowledges that natural amenities and 

quality of life are important for attracting and retaining residents, it does not quantify this impact 

in the economic impact analysis because the Forest Service essentially claims it would be too 

hard to do so. The Draft EIS does not provide any data, studies, or explanation that supports the 

contention that the proposed alternatives would have no significant effect on the economic 

activity that these amenities are believed to generate. 

Further, the comment continues, the Draft EIS “seems to have made up its own science in support 

of the sophism that protecting natural amenities will somehow degrade quality of life” by stating 

that: “changes in the local economy such as a shift to tourism may impact local atmosphere and 

amenities... These impacts are largely assumed to be negative as tourism leads to crowding and 

the loss of traditional charm, but this need not always be the case” (Draft EIS, page 3-437). 

Response: The Draft EIS concludes that in most cases and localities the effects of the action 

alternatives relative to the no action alternative are not expected to be significant enough in of themselves 

to result in measurable changes to amenity-driven economic activity. This conclusion is based on the 

standards and guidelines that are designed to protect and/or mitigate negative effects to natural 

resources on the Tongass, as well as the relatively small proportion of the Forest that would be disturbed 

under any of the proposed alternatives. 

The importance of the standards and guidelines are discussed with respect to quality of life and other 

difficult to quantify values in the Economic and Social Environment section of the EIS (under Ecosystem 

Services). 

Potential harvest activities under the proposed alternatives would affect a relatively small proportion of the 

Tongass and would be unlikely to affect the predominantly wild and undeveloped nature of the region and 

the role it presently plays in attracting visitors and residents. The EIS notes that this is likely to be the 

case in most cases and localities, but it is possible that this type of impact could potentially occur at a 

local level, if timber harvest were to occur in a presently undeveloped location that is used and valued by 

local residents. This type of impact would be more likely to occur under Alternatives 4 and 7, which 

include more timber harvest, but quantifying the possible extent of this effect would require site-specific 

analysis that is beyond the scope of this programmatic EIS. 

In addition, it should be noted that the existing literature does not provide much direction with respect to 

this type of analysis. Studies to date have tended to focus on a comparison between rural counties that 

include designated Wilderness, and those that do not (see, for example, the literature reviews included in 

Rudzitus and Johnson 2000, Colt 2001, and Sonoran Institute 2006). These broad macro-scale analyses 

have important implications, as discussed in the EIS. However, even proponents of this relationship 

caution that while data suggest that rural counties with Wilderness outperform those without, “a 
Appendix H 

Comments and Responses H-48 Final EIS 

correlation does not imply a cause and effect relationship” or “guarantee that economic prosperity ... (in a 

county) ... will automatically rise following the designation of Wilderness” (Sonoran Institute 2006; 28). 

Indeed, the same comment author who submitted this comment also provided a copy of a paper prepared 

on their behalf, Greater than Zero: Toward the Total Economic Value of Alaska’s National Forest 

Wildlands, in which the authors (Phillips and Silverman 2007, 20) explain that they do not attempt to 

estimate these types of values because Alaska presents a “particular econometric problem” in this regard, 

with the uniform and high presence of “wildlands” across the region preventing a “comparison of 

communities with and without nearby wildlands, because almost all communities fall into the category 

‘with nearby wildlands’.” 

The Draft EIS (page 3-437) states: 

“Although it is difficult to directly measure the importance of natural amenities in attracting and 

keeping residents, proximity to natural environments and the recreational activities they support are 

undeniably a benefit enjoyed by residents, especially in the more rural communities of Southeast 

Alaska.” 

The paragraph continues to explain that changes in traditional economies may not always be perceived 

as positive and uses the example of tourism, which can lead to overcrowding and a loss of traditional 

charm. The discussion also notes that some aspects of tourism development such as restaurants, 

meeting centers, or entertainment facilities that are also used by local residents may have positive effects 

on local residents. It is not clear why the comment author believes this discussion is the result of madeup science and it is not the intent of the EIS authors to convey that “protecting natural amenities will 

somehow degrade quality of life.” The statement quoted in the comment has been revised in the Final 

EIS to discourage this misinterpretation. 

Comment: One respondent noted that the Draft EIS discusses the role of natural amenities and 

quality of life factors attracting new residents to the region. Anecdotal evidence suggests that 

this has happened in Southeast Alaska. The comment notes that this has had positive impacts, 

as suggested in the EIS (e.g., local purchases, human capital), but there is another side to this 

issue with impacts to life-long residents, who may experience increases in home and property 

values and property taxes, as well as a change in collective attitudes, with new residents favoring 

policies that do not necessarily reflect the positions of long-time residents who may make their 

living from the surrounding Forests. The comment states that if this issue is “really relevant to 

Tongass management issues it ought to be addressed in appropriate detail rather than 

speculatively.” 

Response: The issue of natural amenities and quality of life is relevant to the Forest Plan to the extent 

that proposed management decisions may impact these values and affect local residents and 

communities. There are potential downsides associated with retirees and others moving to small 

communities, including those noted in the comment. The discussion presented in the EIS is intended to 

provide a balanced perspective on this issue, but the main point is to assess the potential effects of the 

proposed alternatives on the economic aspects of this issue. As noted in the EIS, local amenities and 

quality of life do not provide employment or generate income in the same way as a sawmill or a tourist 

lodge, but they can serve to attract and keep residents. The EIS concludes that the effects of the action 

alternatives relative to the no action alternative are not expected to be significant enough in of themselves 

to result in measurable changes to amenity-driven economic activity. This is discussed further in 

response to the preceding comment. 
Appendix H

Final EIS H-49 Comments and Responses

Economic Efficiency Analysis 

General

Comment: One comment noted that the calculation of net public benefits is missing or has been 

conflated with the economic efficiency analysis summarized in Table 3.22-29. The comment 

author observed that “(i)n order to accurately represent the PNV (Present Net Value) of 

alternatives it must include all Forest Service costs for all program areas, not just variable costs 

of timber.” Another comment noted that the analysis should include the costs, as well as the 

benefits of non-timber programs, such as recreation and commercial fishing. 

Response: The net public benefit analysis conducted for the EIS is presented in the Economic Efficiency 

portion of the Economic and Social Environment section of the EIS. The introduction to this section has 

been revised to explain the relationship between net public benefits and the economic efficiency analysis. 

The economic efficiency analysis has been expanded in the Final EIS to include program costs for: 

Inventory and Monitoring; Minerals and Geology; Recreation, Heritage, and Wilderness Management; 

Land Management Planning and Land Ownership Management; Vegetation and Watershed 

Management; and Wildlife and Fisheries Habitat Management, in addition to variable timber costs. The 

costs assigned to these categories are estimated based on the average 2005/2006 costs for these cost 

categories and are assumed to remain constant across all alternatives. 

Comment: One comment stated that recent District Court decisions indicate that it is “erroneous 

to presume that monetary values need to be assigned to non-timber resources as you have 

attempted to do in the Draft EIS” and the presentation of this “flawed and misleading” information 

“permeates the Draft EIS and will unduly influence the ultimate outcome without basis in law or 

fact.” The comment further stated with reference to Table 3.22-29 in the Draft EIS that the 

“assumptions, conclusions and management directions based on this table are problematic 

throughout the plan.” 

Response: The economic efficiency analysis summarized in Table 3.22-29 assigned monetary values to 

those goods and services where they could be reasonably assigned in accordance with the 1982 Forest 

Planning rules (36 CFR 219). These resources and the associated potential impacts were important 

factors in formulating the alternatives evaluated in the Draft EIS, but the difference in estimated values 

between timber and recreation and tourism, as shown in Table 3.22-29, did not have an undue bearing on 

this process. As noted in response to the preceding comment, the economic efficiency analysis has been 

expanded in the Final EIS. 

Comment: A number of comments were concerned that the economic efficiency analysis 

presented in the Draft EIS is misleading and represents an “apples and oranges” comparison, 

with actual projected timber receipts and costs compared to hypothetical willingness-to-pay 

values for recreation that are based on outdated survey data from 1988. Comments disagreed on 

how this was misleading. Some felt that the analysis incorrectly suggests that “non-timber uses 

of the Tongass are grossly more beneficial than timber uses from an economic standpoint.” 

Others felt that the comparison overvalues timber harvest relative to other non-timber uses not 

included in the table. 

One comment stated that the following statement on page 3-461 of the Draft EIS was particularly 

misleading: “Recreation and tourism estimates range from approximately 76 times (Alternative 7) 

to 380 times (Alternative 1) higher than those for timber, indicating the importance of the Tongass 

National Forest as a recreation resource for both local residents and outside visitors.”

Response: The economic efficiency analysis has been revised in the Final EIS. The analysis includes 

the consumer surplus (willingness-to-pay) estimates for recreation and tourism, but also includes receipts 

to the Forest from recreation activities as a separate category, as well as recreation program costs. 

Program costs are also included for: Inventory and Monitoring; Minerals and Geology; Heritage and 
Appendix H 

Comments and Responses H-50 Final EIS 

Wilderness Management (this category also includes recreation costs); Land Management Planning and 

Land Ownership Management; Vegetation and Watershed Management; and Wildlife and Fisheries 

Habitat Management. 

The high consumer surplus values estimated for recreation and tourism on the Tongass are believed to 

reflect the importance of these activities to local visitors and outside residents. There is, however, little 

variation in these estimated values by alternative, as discussed in the Draft EIS. The text in the Final EIS 

has been revised to further emphasize this point. 

Comment: One comment noted that Table 3.22-29 suggests that recreation and tourism revenues 

are a reflection of the amount of timber harvest and also suggests that rather than being a broadbased plan that seeks to balance multiple uses this plan is an analysis of the effects of timber 

harvest on other uses. The comment further noted that the table also suggests that other 

program costs are not expected to vary by alternative. Another comment stated that the summary 

in Table 3.22-29 “denies the multiple use concept” by suggesting that recreation and tourism and 

the timber industry cannot work side-by-side without impacting one another. In addition, the 

comment author felt that the values in this table indicate that the “non-use” values of 

nonresidents are given priority over employment opportunities for state residents. 

Response: The analysis summarized in Table 3.22-29 in the Draft EIS has been expanded in the Final 

EIS, as discussed in response to preceding comments on this issue. The revised table provides 

estimated costs and revenues for other Tongass program elements, as well as timber and recreation and 

tourism. While it is likely that program costs would vary by alternative, it is not possible to project these 

variations at this time. 

The table presented in the Draft EIS was not intended to convey that recreation and tourism and timber 

cannot co-exist. However, higher timber harvest levels, especially those projected under Alternatives 4 

and 7, would affect recreation and tourism over the 160 year planning horizon considered in the economic 

efficiency analysis. Timber harvest and road building in unroaded areas would result in an increase in 

Roaded Modified (RM) recreation opportunities, and a corresponding decrease in the availability of 

unroaded recreation opportunities. This is discussed in the Environmental Consequences part of the 

Recreation and Tourism section of the Draft and Final EIS documents under Recreation Opportunity 

Spectrum. 

Comment: One comment stated that the economic efficiency analysis incorrectly suggests that 

the Tongass National Forest should be managed to achieve maximum economic return. The 

Forest Service is required to manage NFS lands for multiple uses, but not necessarily the 

combination of multiple uses that returns the greatest dollar returns or unit outputs. 

Response: The economic efficiency analysis is not intended to suggest that the Tongass National Forest 

should be managed to achieve maximum economic return. More discussion regarding the purpose of 

and requirement for the economic efficiency analysis has been added to the introduction to the Economic 

Efficiency section in the Final EIS. 

Timber

Comment: Several comments noted that the net timber benefits shown in the economic efficiency 

analysis only include direct sale revenues paid to the government and do not capture the full 

benefits of the Tongass timber program. One comment stated that the timber benefit estimate 

should also include the impacts of the money spent harvesting and manufacturing the timber, 

which the comment author estimated as approximately $600 to $700 per MBF. Another comment 

suggested that the benefit estimate should include federal payroll taxes and associated corporate 

income taxes. 
Appendix H

Final EIS H-51 Comments and Responses

Response: The economic efficiency analysis has been revised in the Final EIS. The timber portion of 

the analysis has been adjusted and revenues to the federal government are now estimated using base 

rate values by species and the average species composition of timber on the Tongass. The base rate is 

the minimum value that must be bid for timber to be sold or cut. This rate is lower than the average value 

per MBF harvested in 2005/2006 that was used in the Draft EIS ($7.12/MBF versus $11.69/MBF). 

The regional economic impact benefits of the various alternatives are evaluated in the economic impact 

analysis presented in the Draft and Final EIS documents. This analysis includes the jobs and income 

generated by the money spent to harvest and manufacture the projected timber sale volumes under each 

alternative. As noted in the timber part of the Economic Efficiency section in the Draft and Final EIS 

documents, industry revenues are omitted from the timber benefit calculation “because efficiency analysis 

commonly assumes perfect competition in the private sector. This implies, in turn, that competing 

purchasers of federal timber will bid up the price of stumpage to the point where all economic profits (i.e., 

profits over and above a competitive rate of return to capital) are dissipated.” Federal payroll taxes and 

corporate income taxes are associated with all economic activities supported by Tongass resources. No 

attempt is made to estimate these tax revenues in the Draft or Final EIS documents. 

Comment: Other factors than just stumpage values need to be included in timber appraisals. 

These factors include direct and indirect jobs in the timber industry, as well as other multiplier 

effects. When the value of recreation, tourism, and fishing are estimated these factors are always 

included, but the costs of these other uses versus the user fees are never shown. 

Response: The procedures used for timber appraisals are outside the scope of this Forest Plan 

Amendment. With respect to the Forest Plan Amendment and this EIS, potential timber-industry related 

impacts are discussed in two sections, along with impacts to other resources (recreation and tourism, 

commercial fishing, etc.). These sections are the Economic Impact Analysis and Economic Efficiency 

Analysis parts of the Economic and Social Environment section of the EIS. The economic efficiency 

analysis has been expanded in the Final EIS and includes the costs of administering other programs on 

the Tongass. The economic impacts of the alternatives are evaluated in terms of jobs and income 

(including multiplier effects) in the economic impact analysis.

Comment: One comment stated that the cost of future remediation for roads and logging should 

be factored in and borne by those who profit from the logging and road building. 

Response: The costs associated with planning, implementing, and administrating timber sales, as well 

as associated mitigation activities, are included in the projected costs used in the economic efficiency 

analysis presented in the EIS. These costs include sale preparation, environmental assessments, and 

cultural resource surveys, among others. A second group of costs related to the actual harvest of the 

timber are included in the purchaser’s contract requirements and are reflected in the stumpage value 

received. These costs include the costs of reforestation, road obliteration, and culvert removal among 

others. A third group of costs are largely fixed costs associated with long-term forest management and 

Forest Plan implementation and monitoring, and are not expected to vary significantly by alternative. 

Comment: One comment stated that the Draft EIS fails to identify the true costs of the Tongass 

timber program because it does not disclose the costs of building roads that are necessary for a 

timber sale to go forward (“pre-roading”). Pre-roading contracts are let in advance of timber sales 

and nearly all large sales, especially those in roadless areas, are dependent on this practice. 

Other sales are dependent on advance road improvements to existing logging roads that are 

contracted under maintenance contracts, although this maintenance has no purpose other than to 

facilitate future timber sales. The comment states that these costs need to be disclosed in the 

Draft EIS. 
Appendix H 

Comments and Responses H-52 Final EIS 

Response: Pre-roading is a process whereby roads are constructed into a NEPA cleared project area 

prior to and separate from a timber sale or other resource activity. The intent of pre-roading is to develop 

or expand the transportation network without requiring one resource to carry the entire burden of road 

construction costs. Pre-roading is an administrative decision that requires funding from Congress and is 

subject to the same environmental laws and regulations (NEPA, NFMA, etc.) as other federal actions. 

This practice is best addressed at the project level and is outside the scope of this programmatic EIS. 

Comment: One comment stated that the Draft EIS failed to accurately account for the costs 

associated with the proposed levels of harvest. They argue that the $101/MBF figure used to 

estimate timber costs in the economic efficiency analysis is based on an undocumented estimate, 

which “any examination of expenditures in relation to outputs over the last decade” shows to be 

an underestimate. In addition, this cost per MBF derived from budget allocations assumes that all 

planned sales are actually sold, which is not the case. The Forest Service plans for more volume 

than is actually cut and even projects that make it through the planning phase may not 

necessarily be sold, as was the case with 30 percent of the sales offered between 1998 and 2003. 

Response: The economic efficiency analysis presented in the EIS uses the $101/MBF figure cited in the 

comment to estimate the timber sale costs for each alternative and assumes for the purposes of analysis 

that all sales offered are sold. This estimate is based on historic timber sale preparation costs and 

includes costs for NEPA preparation, sale preparation, sale administration, and engineering support. The 

Forest Service uses the $101/MBF figure to estimate costs as part of its timber sale planning process at 

the individual timber sale level. The use of this figure in this EIS to assess potential costs is consistent 

with these practices and provides an adequate basis to allow a comparison between alternatives, 

recognizing that economic efficiency analyses conducted at the Forest Plan level project outcomes and 

assign approximate valuations to costs and benefits more than 100 years into the future and require 

numerous simplifying assumptions. 

The timber component of the economic efficiency analysis has been revised in the Final EIS. This 

revised version uses the base rates—the minimum value that must be bid for timber to be sold or cut—to 

estimate timber revenues. The average base rate value per MBF used in the Final EIS ($7.12/MBF) was 

estimated using 2006 base rates by species and the average timber sale composition. The benefits 

estimated in the economic efficiency analysis using this value are the absolute minimum that must be bid 

for a timber sale to go forward. These estimated cost and benefit figures indicate that viewed in terms of 

direct costs and revenues to the Forest Service, timber harvest results in a net loss per MBF. These flat 

rates are used to evaluate the alternatives and result in the total projected net loss increasing as the 

projected harvest volume increases. 

Comment: One comment pointed out that a large component of the costs that make logging 

uneconomical on the Tongass are the costs associated with court litigation brought by opposition 

groups. 

Response: These costs are not directly factored into the average timber sale costs used in the economic 

efficiency analysis presented in the EIS. However, litigation has increased the timber sale preparation 

costs incurred by the government and has also had the effect of interrupting the supply of timber to local 

mills. 

Comment: One comment stated that the Draft EIS failed to consider that the effects of noncompetitive bidding reduce estimates of timber revenues. The comment also pointed out that 

almost 50 percent of new sales offered between 1998 and 2005 did not sell and that 20 of the sales 

that did sell were returned to the Forest Service. 

Response: The economic efficiency analysis in the Draft EIS implicitly considered the effects of noncompetitive bidding in the Draft EIS by using the average stumpage value ($11.69/MBF) from actual sales 
Appendix H

Final EIS H-53 Comments and Responses

to estimate revenues. This portion of the economic efficiency analysis has been adjusted in the Final EIS 

and revenues to the federal government are now estimated using base rate values by species and the 

average species composition of timber on the Tongass. The base rate is the minimum value that must be 

bid for timber to be sold or cut. This rate is lower than the average value per MBF harvested in 

2005/2006 that was used in the Draft EIS ($7.12/MBF versus $11.69/MBF).

Comment: One comment stated that the timber industry has manipulated stumpage prices in the 

past and that this could happen again. They recommended that the Forest Service look into this 

practice. 

Response: Analyzing stumpage prices is beyond the scope of this analysis. The economic efficiency 

analysis presented in the Final EIS has been revised to use base rate values to estimate potential 

revenues to the Federal government. 

Recreation

Comment: One comment identified the following specific concerns with the “contingent 

valuation” methodology used to estimate the net benefit of recreation/tourism activity: 

• The estimated sport fishing “willingness-to-pay” value of $1,025.27 (1988 survey data 

adjusted to 2005 dollars) per Recreation Visitor Day (RVD) “defies reason” because it is 

“highly unlikely” that guided and unguided fishing operators would so “vastly under-price 

their product.” 

• Willingness-to-pay methodologies employ survey research to place hypothetical dollar 

values on non-market goods. Use of these values in economic analysis is contentious 

because this type of analysis produces hypothetical, unverifiable values and research has 

found that stated willingness-to-pay is often very different to actual willingness-to-pay. 

• If tourists were willing to pay additional money to visit the Tongass the tourism 

businesses would already be charging them that money. 

Response: There is an extensive academic literature that addresses contingent valuation with respect to 

outdoor recreation and benefit cost analysis, and a number of methodological concerns have been 

identified, including those identified in the above comment. There is, however, broad consensus 

surrounding the use of willingness-to-pay measures with respect to recreation in the academic literature 

and various Federal agency planning regulations and guidance documents, including the Forest Service 

Handbook (FSH 1909.17, Chapter 10). 

The analysis presented in the EIS uses the average net willingness-to-pay value used in the 1997 Final 

EIS (USDA Forest Service 1997a) adjusted for inflation. This value was originally developed based on 

survey research conducted at the national level and then adapted for the Tongass. This is the best 

information currently available for the Tongass. While the estimated sport fishing value is high, as noted 

in the comment, the analysis uses an aggregated figure of $69.13 per RVD. 

The analysis presented in the Draft and Final EIS documents illustrates that there is little difference 

between estimated recreation consumer surplus values by alternative. The overall intent of this analysis 

is to compare alternatives and, while different levels of timber harvest affect the types of recreation that 

may be available in the future, the analysis is not intended to compare the relative values of different 

resources. 
Appendix H 

Comments and Responses H-54 Final EIS 

Non-Market Values and Ecosystem Services

Comment: A number of comments expressed concern that the Draft EIS did not adequately 

address non-market values, which they thought should be assigned monetary values and treated 

on a par with market timber values. Several comments provided lists of “important net benefits” 

that the comment authors felt had been incorrectly excluded from the Draft EIS analysis. The 

most detailed list identified the following “unpriced benefits” that the comment author felt the 

Draft EIS “largely overlooked”: 

“biological diversity; cultural connection to the land such as subsistence; quality of life; 

endangered/threatened species protection; water quality; special non-timber forest products; 

passive use values such as bequest, option, and existence values; educational and scientific 

values; unearned income; ecological services such as carbon sequestration; hydrological 

services; irreversible consequences and lack of substitutes; property values and offsite benefits; 

and visual amenities” 

Response: The items listed in the above comment are all discussed and evaluated in the Draft and Final 

EIS documents and will be considered in the overall decision-making process, as appropriate. The fact 

that these items are not assigned monetary values and quantified in the economic efficiency analysis 

does not lessen their importance to the overall process. This is discussed further in the Economic 

Efficiency section of the Final EIS. 

While the EIS does not attempt to assign monetary values to the non-use values potentially associated 

with each alternative, the text does acknowledges that the non-use values associated with the Tongass 

are likely to be high, especially given the national importance of this issue. The fact that no monetary 

value is attached to non-use values does not lessen their importance in the decision making process; 

decision-makers routinely choose alternatives that do not maximize PNV. Many forest benefits are 

incorporated into forest planning decisions in a qualitative fashion. Also, a large proportion of the Draft 

and Final EIS documents are devoted to revealing impacts to the forest resource that cannot be readily 

expressed in monetary terms. The Forest Service Manual states that decision makers must “[c]onsider 

economic efficiency, along with other factors (emphasis added), in making decisions and in implementing 

and reviewing projects, programs, and budgets” (FSM 1970.3(3)).

Comment: Several comments stated that the Forest Service is required by the 1982 planning 

regulations to assign monetary values to non-market goods and services. Two comments 

supported this contention by quoting the following definition of net public benefits from 36 CFR 

219.3: 

“An expression used to signify the overall long-term value to the nation of all outputs and positive 

effects (benefits) less all associated inputs and negative effects (costs) whether they can be 

quantitatively valued or not” 

One comment supported this position with the following: 

“Economists have made great advances in developing methods to estimate the economic benefits 

generated from the production and conservation of non-commodity resources. Therefore, in 

addition to qualitative descriptions of all non-commodity benefits and costs the decision 

documents must quantitatively estimate the benefits (costs) of conserving (damaging) non-market 

resources.” 

Response: The introduction to the Economic Efficiency Analysis subsection has been revised in the 

Final EIS and highlights the 1982 planning regulations and their relationship to this analysis. The revised 

section explains that the approach taken in the EIS is consistent with the 1982 planning regulations, 

which state that “quantitative and qualitative criteria” may be used to evaluate alternative outputs “when 

monetary values may not be reasonably assigned” (36 CFR 219.12(g)(3)(ii)). This approach is also 

consistent with the definition of net public benefits cited in the above comment, which allows that not all 
Appendix H

Final EIS H-55 Comments and Responses

effects can be “quantitatively valued” (36 CFR 219.3). As noted in the response to the preceding 

question, the economic efficiency analysis is one piece of information for the decision maker to consider, 

but is by no means the only one and a large portion of the EIS is spent evaluating potential effects that 

cannot be reasonably assigned a monetary value at this time. 

Comment: One comment submitted an unpublished draft report that presented the commenting 

organization’s own assessment of non-market values on the Tongass and Chugach National 

Forests (Greater than Zero: Toward the Total Economic Value of Alaska’s National Forest 

Wildlands, Phillips and Silverman 2007). The comment stated that this report estimates that the 

value of wildlands on the Tongass ranges from $1.5 billion to $1.8 billion per year and provided a 

summary of the results (adapted from the Phillips and Silverman draft report). The comment 

expressed surprise that the Forest Service had not included similar estimates in the Draft EIS and 

argued that not including these types of monetary estimates in the Final EIS would “constitute a 

violation of NEPA for failing to disclose significant effects.” 

Response: The analysis prepared by Phillips and Silverman (2007, 3) takes a benefit-transfer approach 

and applies values developed elsewhere and broad macro-scale dollar figures to, in their own words, 

estimate “the total benefits of the wildlands on the Tongass and Chugach National Forests” at “an 

admittedly coarse scale—a first approximation.” In some cases, they note that they were unable to 

provide separate estimates for each forest, instead providing one estimate that covers both forests. This 

analysis provides a rough approximation of total economic values for various “benefit categories” (e.g., 

subsistence, passive use, ecosystem services not otherwise counted, etc.) that are included in the Final 

EIS as illustrations of one set of possible total economic values, where appropriate. The Phillips and 

Silverman analysis also illustrates the difficulties in developing accurate estimates suitable for policy 

analyses that require data at a finer resolution than this type of “coarse scale” approach and, in effect, 

supports the Forest Service’s decision to use these types of estimates to support a qualitative discussion 

of potential impacts to these resources, rather than use these very general values to attempt to quantify 

differences between alternatives in monetary terms. 

In addition to the problems with the total value estimates, Phillips and Silverman (2007) do not address or 

even mention one of the main challenges in implementing this type of analysis in a policy or management 

context, namely, identifying the impacts of the proposed alternatives in units or outputs that can be 

accurately measured in sufficient detail to allow meaningful comparison between alternatives. The 

ecological impact assessments presented in the Draft and Final EIS documents follow standard scientific 

approaches to these types of analysis and typically assess impacts in terms of probability and risk, not in 

numbers of affected deer or salmon, etc. The difficulties associated with identifying production 

relationships and the corresponding units of measurement is generally considered one of the main 

challenges currently facing ecosystem services analyses (Kline 2006). 

Interest in ecosystem services has increased in recent years and, as noted in the preceding comment 

summary, economists have made useful progress in developing and improving methods and techniques 

that can be used to value non-market ecosystem services. Recognizing the potential utility of the 

ecosystem services concept, the Forest Service recently proposed that ecosystem services be used as a 

framework for describing and evaluating the many benefits associated with NFS lands and established an 

Ecosystem Services web site (http://www.fs.fed.us/ecosystemservices/) that provides detailed information 

and resources, identifies and discusses Forest Service efforts in this area, and issues a regular 

Ecosystem Services newsletter. In addition, the PNW Research Station recently issued a technical report 

that attempts to define an economics research program to describe and evaluate ecosystem services 

(Kline 2006). One of the long-term goals of this type of agenda is to allow these types of non-market 

ecosystem services values to be incorporated into management decisions in the future. We are just not 

there yet. 

With respect to the Tongass National Forest, scientists from the PNW Research Station in Juneau have 

recently initiated an ecosystem services research program that is aimed at using the Tongass as a case 

study of the impacts of forest management on the long-term provision of ecosystem services and goods. 
Appendix H 

Comments and Responses H-56 Final EIS 

The initial phase of this program has involved working with the MIMES (Multiscale Integrated Models of 

Ecosystem Services) model developed by leading ecosystem services researchers at the University of 

Vermont. Initial work has focused on developing a simplified, dynamic model of forests and ecosystem 

services and goods. Future research plans involve adapting MIMES to model the impacts of 

management decisions on the flow of ecosystem services and goods. 

Tongass National Forest Budget 

Comment: One comment stated that the Final EIS should disclose the detailed budget (by EBLI) 

and staffing projections needed for each alternative. At least one alternative, they argue, should 

have a smaller budget and ASQ than Alternative 5 (No Action) and mirror more closely what will 

be possible in the future with reduced budgets. The comment notes that: “The plan alternatives 

are all built on a budget and staffing level that will expand to meet potential accomplishments; 

this is unrealistic.” 

Response: The Draft and Final EIS documents evaluate three alternatives (Alternatives 1 though 3) with 

an ASQ that would be lower than is currently the case. 

As discussed in the Draft and Final EIS documents, the Forest Service budget is appropriated through 

Congress on an annual basis. National Forest budget requests are considered as part of total budget 

requests submitted to the United States Congress by the executive branch each year, with Congress 

having final say. The overall forest budget would be affected by variations in the projected level of timber 

harvest, with timber-related budget requirements likely higher under Alternatives 4, 5, 6, and 7, and 

Alternative 1 requiring the lowest level of funding. Budget shortfalls are likely in the future, especially for 

the more timber-intensive alternatives. 

The information presented in the Draft and Final EIS documents is sufficient to allow a comparison 

between alternatives. Detailed budget estimates will continue to be developed on an annual basis 

following the selection of a preferred alternative. 

Comment: Several comments stated that the Forest Service should use the funds presently spent 

managing the timber program to fund programs that manage recreation and tourism. These funds 

should also be used to repair damage from past logging practices and sustain wild salmon runs. 

Response: As noted in response to the preceding comment, the Forest Service budget is appropriated 

through Congress on an annual basis. Funds provided in the budget are allocated for specific purposes. 

Funds allocated to the timber program, for example, are used for that program and the Tongass does not 

have budget authority to reallocate these funds to other uses. Other Tongass programs address 

recreation and tourism, restoration, and salmon, and are also funded by Congress. 

Payments to the State 

Comment: One comment stated that the 2000 Secure Rural Schools Act provided a safety net for 

communities that have historically depended on revenue from timber sale receipts. This 

legislation expired in 2006 and unless the act is reauthorized, Southeast Alaska communities will 

experience a loss of revenues, which at current harvest levels would be approximately $9 million 

annually. This would include about $400,000 the Ketchikan Gateway Borough uses to fund its 

school system. 

Response: The 2000 Secure Rural Schools Act has been extended to 2007, as noted in the Final EIS. 

Future government funding or legislation will be decided in Congress and is beyond the scope of this EIS. 

This Act has provided funds to counties hard hit by reductions in timber harvest throughout the Pacific 

Northwest and other regions, as well as Southeast Alaska. 
Appendix H

Final EIS H-57 Comments and Responses

Communities 

Comment: One comment stated that the “community use areas” used to assess potential effects 

to Sitka and Kake do not appear to adequately represent what these communities consider their 

use areas. 

Response: The community use areas identified in the Draft EIS were originally identified for the 1997 

Forest Plan Revision EIS. These areas are intended to generally represent the areas commonly used or 

related to by community residents in their local, day-to-day work, recreation, and subsistence activities. 

The community use areas are used to provide a more localized representation of data provided 

elsewhere in the Draft EIS. These identified areas may not fully encompass all areas used by local 

residents, but they provide a useful overview of LUD designations and suitable acres within the 

immediate vicinity of each community. Local residents concerned about potential impacts in areas 

outside the identified community use areas can find comparable information for these areas elsewhere in 

the EIS. 

Comment: One comment expressed concern that the Communities subsection of the Draft EIS 

fails to adequately assess the economic effects of the alternatives on each community. The 

comment stated that the “section is focused subsistence use of deer and contradictory and not 

substantiated.” Another comment stated that the Draft EIS does “little to nothing to show the 

effects of each alternative on individual Southeast Alaska communities.” 

Response: The comment does not identify what type of analysis the author thinks would be appropriate 

at the community scale, and does not provide any specific comments that can be addressed or examples 

of how the sections might be considered contradictory. As a result it is not possible to provide a specific 

response. The introduction to the Communities subsection in the Draft and Final EIS documents 

identifies some of the difficulties involved in trying to predict the effects of forest-wide management 

alternatives on community economies and explains that the community analyses do not attempt to 

quantify economic impacts in absolute terms because this is simply not possible (see the subsection 

titled: Analyzing Impacts to Communities). 

The community analyses presented in the Draft and Final EIS documents do, however, provide a 

considerable amount of information about each community and illustrate how each community might be 

affected by the various alternatives. This analysis is consistent with those presented in the 1997 Forest 

Plan EIS and the 2003 SEIS. 

Comment: A number of comments stated that the existing sawmills in Southeast Alaska require 

an economically viable wood supply from the Tongass to operate at full capacity and provide jobs 

in local communities. One comment also stated that the EIS analysis needs to evaluate impacts 

on a community-by-community basis and must not: “claim that the benefits from a growing 

community that does not depend on the timber industry somehow offset the negative impacts on 

communities that depend on the timber industry.” 

Response: The Draft and Final EIS documents evaluate the potential impacts of the proposed 

alternatives on a community-by-community basis in the Communities subsection of the Subregional 

Overview and Communities section. The EIS analysis is programmatic and not site-specific, which limits 

the ability of the analysis to project impacts at the community level. This is discussed further in the 

Communities subsection of the EIS (see the subsection titled: “Analyzing Impacts to Communities”). The 

EIS does not make any “claims” that suggest that benefits to one community outweigh negative effects to 

another. The positive impacts of Forest-wide planning decisions may not, however, be distributed evenly 

across the Forest, with some communities, those in the south, for example, bearing a larger share of the 

negative impacts associated with timber harvest than those to the north.
Appendix H 

Comments and Responses H-58 Final EIS 

Comment: One comment pointed out that the discussion of the Silver Bay sawmill in Wrangell in 

the Communities subsection of the Draft EIS needs to be updated. Silver Bay came out of 

bankruptcy in 2004 and has stated that the mill would like to operate at capacity (65 MMBF 

annually). 

Response: This section has been updated in the Final EIS and now states that Silver Bay continues to 

operate. The updated section also provides summary data based on the 2006 mill survey, which included 

the Silver Bay mill. The facility processed an estimated 6 MMBF in 2006 and employed 30 people 

(Juneau Economic Development Council 2007). 

Comment: One comment noted that the discussion of Hoonah in the Communities subsection of 

the Draft EIS did not mention the Icy Straits Lumber Company mill and its role in the economy of 

Hoonah, and requested that this be added to the Final EIS.

Response: The Icy Straits mill and its location in Hoonah are discussed elsewhere in the Draft EIS (see 

Table 3.22-5, for example), but the mill was not specifically identified in the general discussion of 

Hoonah’s economy presented in the Communities subsection. This information has been added to this 

discussion in the Final EIS. 

Comment: The Draft EIS states that: “Tenakee Springs residents have been vocal in their 

opposition to tourism development.” One comment noted that small-scale, locally-owned 

businesses catering to independent travelers are a large part of the Tenakee Springs economy. 

Local residents opposed cruise ship development, not all tourism development. This should be 

clarified in the Final EIS. 

Response: The cited statement is attributed to Dugan et al. (2006) in the Draft EIS and is taken directly 

from their report: Nature-Based Tourism in Southeast Alaska: Results from 2005 and 2006 Field Study. 

The report presented the results of interviews with nature-based tourism businesses in Southeast Alaska 

communities, including Tenakee Springs. A note of clarification citing the comment author (Chichagof 

Conservation Council) has been added to this statement in the Final EIS. 

Comment: One comment requested a balanced Forest Plan that provides employment 

opportunities in local communities. The comment author noted that people are moving from 

villages to larger urban areas for work and cited the examples of people moving from Hydaburg, 

Craig, and Klawock to Ketchikan, and people moving from Hoonah, Angoon, Kake, and Yakutat to 

Juneau. 

Response: Population data are presented by community in the Communities subsection of the Draft and 

Final EIS. These data indicate that all of the communities referenced in the comment, with the exception 

of Juneau and Hoonah, experienced a net loss in population from 2000 to 2005. Ketchikan also lost 

population over this period. The seven alternatives presented in the Draft and Final EIS documents each 

provide a balance between different land uses on the Tongass, but the balance is weighted differently 

under the different alternatives. 

Comment: Several comments stated that the data provided in the Subregional Overview and 

Communities and Environmental Justice sections of the Draft EIS indicate that Southeast Alaska 

is “in dire economic straits and fully justifies that the ... (Forest Service) ... should do everything 

possible to improve the viability of the forestry and mineral industries.” 

Response: This represents one perspective. Others providing comments believe that the future health 

of Southeast Alaska’s economy is predicated on recreation and tourism and commercial fishing. These 
Appendix H

Final EIS H-59 Comments and Responses

comments argue that continued large-scale logging and mineral exploration seriously jeopardize this 

future. These represent contrasting visions for the future of the region. The Forest Service has proposed 

a range of alternatives that try to balance these competing visions. 

Comment: Many general comments were received expressing concern about the economic plight 

of small isolated communities that have few well paying year-round jobs. One respondent 

focused especially on the community of Hyder in this respect and had a number of requests that 

might improve the situation such as designating a minerals development overlay LUD for the 

historic mining area near Hyder. 

Response: As noted in response to the preceding comment, there are a number of competing visions for 

the future of the region. The EIS evaluates a range of alternatives that try to balance these competing 

visions. A minerals overlay has been added to the Hyder area under all of the action alternatives in the 

Final EIS. 

Comment: One organization providing comments included several lists of “core principles” the 

authors believed the Forest Plan should address and implement with respect to community use. 

These lists included the following: 

• “Establish a shared and balanced vision of the values and uses of the Tongass National 

Forest 

• Protect customary and traditional uses of the forest 

• Protect key community use areas which Southeast Alaskans cherish and benefit from 

economically, socially, and culturally 

• Provide a long-term management vision of the forest which ends the unsustainable 

practice of logging Inventoried Roadless Areas and seeks to meet the needs and benefit 

all who care about the forest, including residents, visitors, and other stakeholders.” 

Response: The proposed Forest Plan alternatives evaluated in this EIS are designed to meet the goals 

identified in the above comment, to the extent possible, recognizing that the Forest Service is required to 

manage the Tongass for multiple uses and also seek to meet demand for timber under TTRA. The 

alternatives considered in this EIS range from Alternative 1, which involves the lowest projected levels of 

timber harvest and would not involve logging in roadless areas, to Alternative 7, which involves the 

highest projected levels of timber harvest and includes logging in roadless areas. The potential impacts 

of the proposed alternatives on customary and traditional uses of the forest and community use areas are 

assessed in the Subsistence and Communities sections of the EIS. 

Fish and Watersheds 

The Fish and Watersheds comment and response subsection is divided into the following categories: 

• General 

• Buffers 

• Culverts and Roads 

• Watersheds 

• Forest Plan and EIS Revisions 
Appendix H 

Comments and Responses H-60 Final EIS 

General 

Comment: Some comments disagreed with the assessment that none of the alternatives would 

result in significant declines of major fish and marine resources. Concern was expressed that 

none of the alternatives adequately protect fish and their habitat because all alternatives include 

some development LUDs in primary fish producing watersheds. Further, one comment stated that 

under all of the alternatives there would be large changes in temperature, sediment, and physical 

conditions in watersheds that supply important habitat for rearing fish. 

Response: The suite of Forest-wide and LUD-specific standards and guidelines that have been in place 

since 1997 have proven through monitoring and research to be effective in protecting fish habitat and fish 

populations. These protections and monitoring efforts will continue under all alternatives. The Final 

Proposed Forest Plan does, however, include a number of changes to the standards and guidelines for 

riparian areas and for fish management, based on information developed in the 5-Year Forest Plan 

Review. 

The EIS acknowledges that risks to aquatic resources would increase with more harvest and would vary 

by alternative (see the Fish section). Site-specific evaluations, and, if needed based on standard and 

guidelines, watershed analysis would be conducted for all timber sale proposals to evaluate if specific 

adverse affects would occur and identify how best to modify the actions to minimize these specific effects. 

One of the goals of the site-specific timber sale NEPA assessments is to ensure that significant adverse 

effects do not occur to important resources as a result of the timber sale. 

Comment: One comment stated that the Draft EIS overstated possible impacts to fish passage 

and karst (page 2-53, Table 2-18) given the protective measures found in the Forest Plan. 

Response: Table 2-18 (Summary of Effects Matrix) in the Draft EIS displays the effects of the seven 

alternatives on all potentially affected resources, including Karst and Fish, in a consistent manner to aid in 

comparison of the alternatives. Forest Plan standards and guidelines are implemented to protect or 

minimize the potential effects at the project level. Specific comments with respect to fish passage are 

addressed elsewhere in this section. Specific comments about karst are addressed in the Geology, Soils, 

Karst, and Caves section of this comment and response appendix. Table 2-18 has been updated in the 

Final EIS to reflect changes made between the Draft and Final EIS and for the Final Proposed Forest 

Plan. 

Comment: One comment requested that additional discussion of the potential effects of the 

alternatives on fish populations and fisheries be provided. Another comment requested 

additional discussion of the potential effects of the alternatives on stream flow, temperature, 

transport of nutrients and feed from headwaters to fish rearing habitat, and the influence of large 

woody debris and beaver dams on fish productivity. One comment also questioned whether there 

really has been no effect on fish or fish populations from past harvest over the last 30 years. 

Response: A general discussion of the types of effects that occur from timber harvest has been added 

to the Fish section of the Final EIS. This discussion includes potential impacts to many of these factors 

(e.g. temperature, nutrients, large woody debris). The effects of the alternatives on these factors are 

addressed indirectly by quantifying the relative difference in risk factors that influence these parameters. 

These factors include acres of harvest and miles of roads, which may, for example, influence temperature 

and large woody debris in streams. The likely effects at specific sites would be addressed through the 

project-specific NEPA process for any future timber sale or other development projects. 

 

Additional discussion has been added to the Final EIS concerning the effects of past timber harvest 

practices on fish or fish populations. (Also see the cumulative effects subsection of the Fish section in the 

Final EIS for overall factors, including past, present, and reasonably foreseeable future actions that could 

affect fish). Effects to fish populations from future actions cannot be directly quantified given the number 
Appendix H

Final EIS H-61 Comments and Responses

of outside variables, such as ocean conditions and population fluctuations. However, past, present and 

future actions are discussed by quantifying factors known to have increased risk to fish habitat. It should 

be noted that all of the proposed alternatives have a substantial number of measures that would be 

implemented during timber harvest to protect fish habitat, many of which were not in place during most of 

the past timber harvest. 

Comment: One comment requested that the EIS acknowledge the importance of salmon and their 

carcasses as input to the ecosystem of the forest and streams. The comment also stated that 

indirect and cumulative effects to salmon should be considered as part of the EIS analysis. 

Response: Additional information has been added to the Final EIS discussing how salmon carcasses 

contribute to production in forest and stream ecosystems. Some general discussion of local effects to 

some anadromous and resident fish populations from older harvest methods has also been added. 

Cumulative effects are addressed relative to the effects of overall timber harvest-related actions with 

respect to risks to fish habitat. Overall effects to fish populations and returning salmon to streams cannot 

be directly determined from this analysis, but the relative direction of effects among the alternatives can 

be inferred. 

Comment: Several comments raised the concern that timber harvest would adversely affect 

spawning fish in upper Tenakee Inlet, noting that this appeared to have occurred in other local 

streams. One comment suggested that the success of salmon production in Tenakee Inlet is due 

to the pristine conditions and noted that cool water is essential for salmon spawning. 

Response: The amount of timber harvest in the Tenakee Inlet area varies by alternative (as shown in 

the alternative maps that accompany the Final EIS). Forest Plan standards and guidelines are intended 

to minimize or eliminate adverse effects to important aquatic resources. Further, specific effects to these 

resources would be evaluated during the project-specific NEPA process for timber sales and other 

projects. 

Comment: One comment stated that the claim that logging harms fishing is contradicted by 

harvest data, which indicates that catch was much higher after most of the heavy harvest 

occurred then it was before. 

Response: Some information has been added to the text in the Fish section discussing likely effects of 

past logging actions on fish numbers. Information is supplied that indicates there have been adverse 

effects from old logging practices on numbers of fish at specific sites. However, changes in the number 

of returning salmon are the result of many factors, including climate and ocean conditions, which play a 

large role and can change returns dramatically. Also there has been dramatic increase in hatchery fish 

production in recent years, affecting overall harvest. Additionally, the total amount of area directly 

affected by timber harvest, relative to the entire Tongass National Forest, is small so that any local 

changes in salmon runs would likely not be apparent in total harvest numbers from Southeast Alaska. 

These concepts are discussed in a number of the references cited in the Final EIS. 

Comment: One comment recommended that the information used to summarize sport fishing 

effort and demand in the introduction to the Fish section in the Draft EIS be updated using the 

Alaska Department of Fish and Game (ADF&G) Statewide Harvest Survey. The comment also 

requested that Dolly Varden and cutthroat trout be added to Table 3.5-1, which lists commonly 

harvested sport, subsistence, and commercial fish. 

Response: This information has been added to the Final EIS. 
Appendix H 

Comments and Responses H-62 Final EIS 

Comment: One respondent wanted to know when and how known problems with siltation from 

forest roads and deposits of detritus from log transfer facilities would be remedied.

Response: Potential siltation from forest roads would be addressed on a site-specific basis during the 

NEPA process for specific timber sales. Siltation would be controlled using Best Management Practices 

(BMPs) for roads, with these practices applied on a site-specific basis. This would also be the case for 

log transfer facilities. Additional information has been added to the text in the Fish section in the Final 

EIS. (See also the Transportation and Utilities section for more detail on potential log transfer facility 

effects.) 

Comment: One comment noted that the latest definition of Essential Fish Habitat in Alaska 

should be used in the text. Another comment clarified how Essential Fish Habitat and the 

Magnuson-Stevens Act applies to this Forest Plan Amendment. 

Response: The current definition of Essential Fish Habitat is included in the Final EIS. The Final EIS 

also discusses the Magnuson-Stevens Act and how it applies to the Forest Plan Amendment. 

Comment: One comment provided a citation they believed was important relative to addressing 

fish die offs in Southeast Alaska streams. The paper noted that adult returning salmon mortalities 

were from natural conditions and not directly related to past harvest conditions. 

Response: This information has been added to the Fish section of the Final EIS under the Important 

Components of Fish Habitat subsection.

Comment: One comment recommended that the Forest Service, in consultation with the State, 

develop objective criteria and protocols to use for stream classification, and train Forest Service 

staff in the application of these protocols. The comment also urged the Forest Service to maintain 

existing flexibility in the Class III guidelines to protect water quality and downstream fish habitat 

in a manner that is practical for timber harvesting. 

Response: The Final Proposed Forest Plan includes objective criteria and protocols for stream 

classification. The Forest Service agrees that taking measures to promote consistent interpretation and 

application is important. A Forest Plan implementation training program will be developed and used to 

promote consistency after the Amendment is completed. That effort will be done collaboratively with the 

State and others. 

Comment: One comment expressed concern over adequate funding for the maintenance of BMPs 

designed to protect fish. The comment author also felt that more protection, beyond BMPs, is 

needed on smaller streams, and pointed out that even non-fish streams have valuable riparian 

functions and also contribute wildlife habitat. 

Response: Overall Forest Service funding is declining but implementation of standards and guidelines is 

not funding-dependent. Protection of fisheries is a high priority and adherence to standards and 

guidelines and monitoring of results will continue. Monitoring has not identified a problem with the current 

level of protection. 

Comment: One respondent was concerned that hatchery fish would compete with wild fish to the 

detriment of wild fish. The comment stated that the Forest Service is standing by and allowing 

hatcheries to destroy the integrity of the wild habitat. 
Appendix H

Final EIS H-63 Comments and Responses

Response: The Forest Service manages habitat for wild fish (and other wildlife) within the Tongass 

National Forest. It does not manage hatcheries. This is a state issue and beyond the scope of this 

analysis. 

Comment: Several comments wanted the Forest Service to reprioritize activities to make 

maintaining and enhancing salmon runs a top priority. 

Response: The Forest Service in the Final EIS and Final Proposed Forest Plan is placing more 

emphasis on habitat restoration, including that relating to salmon habitat. This also includes prioritizing 

culvert replacement for areas that have the greatest need. Funding for this activity is dependent on 

Congress and Forest Service Management decisions. The Final Proposed Forest Plan includes 

standards and guidelines that are intended to protect aquatic resources and prevent effects that would 

inhibit maintaining fish runs. 

Buffers 

Comment: Some respondents felt that global warming may raise stream temperatures and could 

harm anadromous fish. One comment recommended that stream buffers be expanded to ensure 

waters stay cool and fish die offs are not caused by forest practices. 

Response: Generally, stream temperatures on the Tongass are well below the point where fish would be 

affected. Some streams do have periods when they exceed optimal temperatures and the warming trend 

could compound this problem. The stream buffers required by the Final Proposed Forest Plan would 

provide shade which would help keep temperatures cool. Conversely, some streams in Southeast Alaska 

are colder than optimum, and the warming trend may improve conditions for salmon in these streams. 

Past fish die offs have been documented in both harvested and unharvested watersheds and were 

reported to be primarily the result of flow conditions, air temperature, and the density of fish, not 

specifically the lack of shade or other harvest-related conditions. Future harvest practices are likely to 

have little direct effect on the occurrence of fish die offs during spawning. The current buffering system 

will supply abundant shade along fish streams under all alternatives and widening the buffers would not 

substantially change the shading. The one exception is Alternative 7, which would not require buffers on 

Class III streams, which may affect temperature. 

Comment: One comment stated with respect to the importance of cool water temperatures for 

fish that there is an optimum temperature within which temperature changes are not harmful and 

may even be beneficial. 

Response: The text in the Water section of the Final EIS was modified to discuss the importance of 

optimum temperatures.

Comment: Some comments stated that where logging occurs there should be wide stream 

buffers and units should be no larger than 20 to 30 acres. 

Response: Current standards and guidelines require large wind firm buffers on streams. These are 

included in all alternatives. The average opening size is approximately 11 acres currently, primarily due 

to stream buffers. 
Appendix H 

Comments and Responses H-64 Final EIS 

Comment: Several comments noted the importance of headwater streams to the whole system. 

One comment supported including buffers on all Class III streams as recent evaluations and 

literature suggest that these streams require wood to properly function and Class III streams are 

important to the whole system by supplying fish food downstream, and are important to water 

quality. 

Response: All the alternatives except Alternative 7 retain buffers on Class III streams. The effects of not 

having Class III stream buffers on sediment, water quality, and fish food supply are noted in the EIS. 

Comment: A number of comments wanted the plan to ensure that buffer areas were present along 

streams and that roads were not allowed along river banks to ensure good quality habitat and 

prevent water heating and pollution. 

Response: The current Forest Plan provides adequate buffers to ensure temperature is not changed as 

a result of logging. Trees in buffers are only removed where roads cross streams, and guidelines ensure 

that long lengths of stream buffer are not removed for road placement. 

Comment: Several comments requested that riparian and beach buffers recommended in the 

Draft EIS be developed in consultation with the Alaska Department of Natural Resources to ensure 

that they are consistent with Alaska Forest Resources and Practices Act when implemented 

adjacent to non-federal lands.

Response: The process of establishing riparian buffers and beach and estuary buffers included 

addressing the concerns of State of Alaska relative to this issue. The establishment of buffer sizes 

considered many factors including the benefits and deficits of various buffers widths. These buffers were 

primarily established to protect natural resources, including fish and wildlife. With the exception of 

Alternative 7, the buffer widths proposed in this Amendment are the same as those under the current 

Forest Plan and monitoring has shown these buffers to be effective. Reducing buffers adjacent to nonfederal lands to make them consistent with State requirements would not provide the level of protection 

needed to meet the objectives of the Forest conservation strategy. 

Comment: One comment stated that no harvest should be allowed along streams or along the 

beach. Another comment requested that the Forest Service increase stream buffers from 200 to 

500 feet depending on the stream channel. 

Response: All alternatives except Alternative 7 provide no-harvest buffers along Class I, II, and many III 

streams and a 1,000-foot, no-harvest buffer along the beach. Alternative 7 provides no-harvest buffers 

along Class I and II streams and a 500-foot no-harvest buffer along the beach. Stream buffers vary in 

width, depending on site-specific conditions, including stream class, channel type, and the risk of 

windthrow. See Appendix D of the Final Proposed Forest Plan. 

Comment: One comment questioned whether a 100-foot buffer on Class III streams was needed. 

The comment noted that studies suggest that 90 percent of sediment runoff was successfully 

filtered with a 10-foot buffer, and thought a 60-foot buffer would be more than sufficient to filter 

out contaminants.

Response: There are multiple reasons for buffers on Class III stream, not just for filtering. The Final EIS 

notes some of the purposes. A recent review by the Forest Service (Paustian et al. 2006) evaluated the 

appropriateness and need for buffers on Class III streams and the importance of Class IV streams. One 

of the items noted was that large wood was needed in Class III streams for them to properly function. 

Wood from adjacent riparian areas enters these streams in many ways, but requires a riparian source. 
Appendix H

Final EIS H-65 Comments and Responses

Typical mature tree height is often in the range of 100 feet, so reducing the buffer width has the potential 

to reduce wood supply. Some wood from Class III streams, depending on valley morphology, enters fish 

streams and contributes to habitat in those areas as well. The wood in Class III streams also controls 

rates of sediment entry into fish streams. Additionally, more than 50 percent of the water in a basin 

originates in Class III and IV streams. So effects such as changes in water temperature, possibly from 

small buffers, have potential to affect downstream temperature. Much of the food supply in fish streams 

originates from Class III streams and a significant portion of that food source is terrestrial, entering from 

riparian vegetation. A substantial reduction in riparian trees could affect this supply. Alternative 7, 

however, does not require buffers on Class III streams. This alternative would likely have additional 

adverse effects to fish resources not common to the other alternatives. 

Culverts and Roads 

Comment: Several comments were received concerning culverts that block fish passage. A 

concern was expressed that funds for the replacement of past passage problems at existing 

culverts have decreased. Some comments requested that the Forest Service commit to replacing 

existing culverts that currently block fish passage and fund maintenance of existing roads before 

constructing new roads; others suggested that restoring passage at culverts not currently 

meeting fish passage criteria should be a high priority for the Forest and that plans to repair 

passage problems in future timber sales should be included in the Proposed Forest Plan. Some 

respondents requested that an analysis identifying how culverts influence cumulative effects to 

fish resources be included in the Final EIS. 

One comment requested that a recently developed model for determining the biological 

significance of not meeting passage at individual culverts be included in the EIS analysis, as well 

as the cost of fixing past culvert passage problems. The comment also requested that specific 

citations concerning road and culvert effects on fish be noted in the EIS text. 

Response: The Forest Service considers fish passage to be an important priority and has an ongoing 

program to eliminate or replace culverts that do not provide passage. The Forest Service plans to 

continue to address past culvert problems as funding is available. The budget for this work is 

appropriated through Congress on an annual basis. National Forest budget requests are considered as 

part of total budget requests submitted to the U.S. Congress by the executive branch each year, with 

Congress determining the annual appropriation. Determining funding levels is outside the scope of this 

Forest Plan Amendment EIS. Current standards and guidelines for culvert installation have requirements 

to ensure fish passage is provided when fish are present at the crossing areas. These guidelines differ 

from the guidelines that were in place when most of culverts that have fish passage problems were 

installed. As a result, fish passage problems from future installations are expected to be comparatively 

rare. 

Additional information on the status of the current culvert inventory relative to fish passage has been 

added to the Fish section of the Final EIS. The number of potential stream crossings identified in the EIS 

provides a relative approximation of the potential number of culverts by alternative; an exact number of 

future culverts cannot be determined prior to site-specific analyses. The exact number of culverts would 

be determined for each specific timber sale or other project and the potential effects would be addressed 

as part of the project-specific NEPA analysis at that time. The Forest has a substantial database that 

identifies the status of nearly all existing culverts and includes fish passage information. Two citations 

were added to the Fish section in the Final EIS, as requested; however, some of the other citations were 

not added because the issues they addressed had already been discussed in the analysis, and the 

information these documents provided on the number and status of culverts on the Tongass was less 

exact and older than the specific data reported in the Final EIS. 
Appendix H 

Comments and Responses H-66 Final EIS 

Comment: One comment questioned the use of the term “restored” for improving fish passage 

for culvert replacement. The comment stated that in a substantial number of cases passage 

conditions before culvert replacement would have allowed most fish to pass most of the year, and 

replacement in many of these cases was intended only to ensure passage at infrequently 

occurring flow conditions. 

Response: The discussion of culvert replacement presented in the Fish section under Fish Habitat 

Enhancement has been expanded in the Final EIS to provide additional information with respect to culvert 

replacement. 

Comment: One comment stated that the characterization of road effects on stream sedimentation 

in the Fish section under General Effects, Roads, was exaggerated. The comment included a 

document containing data from some specific sediment studies. Additionally, the comment noted 

that the Draft EIS statement that roads could contribute to overharvest of fish should be excluded 

because fish harvest is a fish management issue and not a direct result of road development. 

Response: The text does not specifically quantify the magnitude of road effects on sediment and, 

therefore, the EIS does not exaggerate the effects. Potential sediment effects are evaluated on a sitespecific basis during the NEPA evaluation of timber sales. The general statements on road/sediment 

effects and the effects to fish harvest in the Draft EIS were retained in the Final EIS. Fish harvest is a 

management issue, but increased access can lead to overharvest in the absence of harvest management 

actions and it cannot necessarily be assumed that ADF&G harvest management would change fishing 

regulations in areas where new roads are built. Again, site-specific effects would be evaluated through 

the NEPA process for each timber sale. 

Comment: One comment stated that using the number of road crossings and road miles by 

alternative as an index of sediment input and fish passage problems was not justified. The 

comment stated that new culvert designs ensure fish passage and road management would 

ensure sediment runoff meets standards. 

Response: The standards and guidelines in the Final Proposed Forest Plan are intended to achieve 

these goals. However, even with the best practices not all goals are completely achieved. For example, 

the EIS notes that culverts installed under the new guidelines are very good at achieving the passage 

guidelines, with 93 percent meeting current passage criteria. Therefore, if the percent not meeting the 

criteria (e.g., 7 percent) remains the same the greater the number of culverts installed, the greater the 

number of potential fish passage problems. Also, monitoring indicates that even under new standards for 

road construction some short term increases in turbidity occur. Therefore, as with culverts, the greater 

the number of road miles, the greater the likelihood of exceeding the sediment (turbidity) standards. 

Thus, the comparison is a reasonable way to assess the alternatives on a forest wide basis. Site-specific 

evaluations of potential passage and sediment problems would be made for any future timber sale 

through the NEPA process and more specific information would be used at that time to evaluate potential 

effects. 

Comment: One comment noted that there are always impacts to water from road construction or 

presence and that the EIS should display a habitat reduction factor for every mile of road 

constructed. 

Response: The EIS acknowledges the risks of roads to fish habitat and states the greater the number of 

road miles the greater the risk. But with new guidelines for construction, the plan is to keep these risks to 

low levels with measures such as avoiding steep unstable slopes, taking roads out of use after harvest is 

complete, including removal or bypassing culverts, and ensuring new culverts meet more stringent fish 

passage criteria. Therefore it is not reasonable or possible to develop a reduction of habitat amount 

based on the number of road miles. The specific effects of proposed road systems will be evaluated 
Appendix H

Final EIS H-67 Comments and Responses

during the NEPA process for timber sales and other projects, and as needed adjustments will be made to 

the individual plan to reduce the risks and ultimately the effects of roads to fish habitat. 

Watersheds 

Comment: Several comments wanted the Forest Plan to prevent all road building and logging in 

primary salmon producing watersheds as identified by ADF&G and specify that watershed 

analyses be completed prior to any timber sale. Some comments noted that entire watersheds 

need to be protected from development to ensure the protection of anadromous fish resources. 

Some comments recommended that additional protections should be applied to 23 specific 

watersheds. The suggested protections primarily relate to new roads . 

Many respondents asked that watersheds be protected. Some mentioned high value watersheds 

while others discussed the importance of protecting “intact” watersheds—those that have all their 

ecological parts and functions—from timber harvest and road construction. One comment 

included a summary of the findings of the 1997 Panel that evaluated potential harvest alternative 

guidelines and the potential concerns for these actions, and also cited a document by Bryant and 

Everest (1998) that discusses the likely effects of past and future harvest on fish stocks in 

Southeast Alaska. 

Response: The Forest Service does not dispute that watersheds without disturbance have a greater 

chance of having consistent runs of salmonid stocks than those that are highly disturbed. However, 

current standards and guidelines for timber harvest and road construction are greatly improved over past 

methods, and comparing past impacts to salmon stocks from old harvesting methods to current ones is 

not an appropriate comparison. While there is a legacy of some problems from past actions, future 

conditions in newly harvested watersheds would not have marked impacts. The EIS acknowledges the 

potential problems, concerns, and risks identified by the 1997 panel and many of the panel 

recommendations for protecting fish resources and watersheds were included in the alternatives. 

Comparisons provided by Bryant and Everest (1998) consider the effects of past harvest practices, as 

well as those that were implemented at that time (1998). They note the importance of maintaining pristine 

watersheds, but they also indicated that 75 percent of the Tongass National Forest is in relatively 

protective LUDs. Current analysis based on road miles indicates that 70 percent of all Tongass National 

Forest Value Comparison Units (VCUs) have no roads, and are, therefore, undeveloped. The 

alternatives considered in this EIS could reduce this percent over a 100 year period to between 51 and 68 

percent, depending on the alternative. This would only occur if the alternative is fully implemented and it 

may be noted that harvest over the last decade has been much less than predicted in the current plan. In 

any case, the majority of the Tongass would remain pristine under any alternative. 

As noted in the EIS, the National Marine Fisheries Service (1996) considers most watersheds with less 

than 2 miles of road per square mile to be “properly functioning” with respect to ESA-listed salmon and 

steelhead. Currently, less than 3 percent of the VCUs on the Tongass National Forest exceed this road 

density. Under the alternatives considered in this EIS, this percent could increase to about 6 to 10 

percent over a 100 year harvest period if site-specific NEPA analysis indicated that exceeding this road 

level would not significantly affect the watershed. It is likely that over 90 percent of watersheds within the 

Tongass would still be considered “properly functioning” 100 years from now even under Alternative 7. 

ADF&G (1998) developed a list of VCUs that met certain requirements relative to importance for fisheries, 

wildlife, and other community factors. They identified about 26 percent of all VCUs in Southeast Alaska 

as “Primary Salmon Producing Watersheds.” The state used this document to provide a request to the 

Forest Service for revisions to the 1997 Forest Plan. The Forest Service considered the request by the 

State, which made the following recommendation: 

“work with communities to determine which of these areas should have appropriate management 

prescriptions that protect community use and fish and wildlife values. Avoiding or minimizing timber 
Appendix H 

Comments and Responses H-68 Final EIS 

harvest in areas of high community use will increase predictability and reliability of the timber supply 

and ensure the viability of all forest uses.” 

The watersheds referred to include the primary salmon-producing watersheds. The quote above 

indicates there was not a specific request to prevent all harvest and road building in all of the primary 

salmon producing watersheds, but to work with communities in development of specific harvest plans. 

The Forest Service has done this in the past and will work with communities in the future. As illustrated 

by the preceding quote, it is apparent from the ADF&G (1998) document that total elimination of harvest 

in all these watersheds was not the intent of the evaluation or recommendations at that time. 

The Forest Service believes that the standards and guidelines and the NEPA analysis for specific timber 

sales will adequately protect the fish resources in these watersheds. Reclassifying these watersheds to 

different LUDs is not required to meet resource protection objectives. Watershed analysis is designed to 

help set the stage for project planning and associated environmental analysis; however, requiring 

complete watershed analysis prior to any timber sale is not required to meet Plan objectives. Additional 

analysis was done for the Final EIS to determine the effect of each alternative on intact watersheds. This 

type of analysis will help ensure that watershed functions are maintained whatever project may be 

planned. 

Comment: One comment noted that although the proposed Forest Plan includes increased 

protection for headwater streams, watershed analysis and cumulative effects analysis should be 

conducted before any significant resource extraction takes place. 

Response: The Forest Service believes that the proposed standards and guidelines would adequately 

protect fish and water resources on the Tongass National Forest and does not see a need for additional 

restrictions at the Forest Plan level. Analysis conducted under the NEPA process would evaluate sitespecific resource impacts and cumulative effects from individual timber sales or other extractive activities, 

and adjustments would be made as needed to ensure protection of these resources. The amount and 

location of land available for timber harvest varies greatly by alternative. Forest Plan standards and 

guidelines protect watershed resources and watershed analysis can be conducted where conditions 

indicate the need. 

Comment: One comment provided information on the status of development in flood plain forests 

and stated the information provided indicated that some areas that have already been moderately 

developed should get greater watershed scale protections for flood plain forests associated with 

anadromous fish streams. They also noted this is justification for protecting a greater number of 

intact watersheds with high salmon values and pointed out that active restoration should occur in 

these areas. 

Response: The current standards and guidelines include large buffers for floodplain streams, much 

larger than existed in past decades. The Forest Service believes that these are adequate to protect 

anadromous fish resources in flood plain areas. Additionally, the level of past development within 

watersheds is one of the factors considered when developing timber sales. These factors are all 

considered during the site-specific timber sale NEPA process. As noted in the Final EIS, there already 

are large tracts of watershed within the Tongass Forest that are not included in any harvest plan. At this 

time the Forest Service does not believe setting aside additional specific watersheds is needed to protect 

anadromous fish resources. 

Comment: One comment noted that a recent Trout Unlimited document “Where the Wild lands 

are: Southeast Alaska” (Curley and Bristol 2006) states that 72 percent of all salmon populations 

in southeast Alaska are found in undeveloped watersheds. Another comment noted that the 

salmon and steelhead population distribution relative to roadless watersheds ranges from 67 to 

76 percent, depending on the fish stock. 
Appendix H

Final EIS H-69 Comments and Responses

Response: Currently, approximately 70 percent of all VCUs in the Tongass National Forest have no 

roads (see Table 3.6-9 in the EIS), while the remaining 30 percent have varying amounts of roads. The 

ratio of “roaded” to “unroaded” VCUs is similar to the ratio of where salmon populations occur. Seventytwo percent of the salmon are in 70 percent of the VCUs. One implication of this comparison could be 

that the relative distribution of salmon populations is independent of roads and other development. We 

are not implying that past harvest has had no effect on fish resources; only that interpretation of this 

general statement does not present a good measure of effects of development.

Comment: Several comments requested that certain watersheds be restored. One comment 

included an ecologically based list of watershed restoration projects they would like the Forest 

Service to consider. 

Response: The Forest Service has increased emphasis on restoration considerations in the Final 

Proposed Forest Plan. There are several ongoing actions in place, such as road decommissioning and 

repair, culvert improvement for fish, and various habitat enhancement projects. All of the activities are 

dependent on funding and overall assessment of needs with consideration of which specific watershed 

areas have priority for restoration activities. There are general plans to improve the common watershed 

problems related to roads forest wide. 

Comment: One comment recommended that the Forest form one watershed analysis team to 

perform consistent, high quality watershed analyses prior to any timber harvest. 

Response: The Forest uses an interdisciplinary approach to analysis, as required by NEPA. The Forest 

intends to provide training to ensure that analysis teams provide consistent analysis across the Forest. 

Forest Plan and EIS Revisions 

Comment: One comment asked why the word “assured” has been removed from before “protect 

riparian habitat” in Riparian standard and guideline 1.II.A.1? 

Response: Numerous minor edits have been made throughout the Proposed Forest Plan to provide 

clarity, promote consistent interpretation, and to reduce redundancy. These minor edits were carefully 

considered so as to not significantly change the basic intent of the text or Plan itself. “Protect riparian 

habitat” is a direct, clear statement, while “Assure the protection of riparian habitat” is a somewhat 

convoluted way of saying the same thing. The basic objective remains the same. 

Comment: One respondent suggested adding a fish restoration section to the Fish Standards and 

Guidelines in the Proposed Forest Plan. 

Response: Fish restoration has been a priority on the Tongass for many years. It is one of the primary 

goals listed in the Proposed Forest Plan (see page 2-3). Standards and guidelines for fish restoration are 

included in the Fish section of the Final Proposed Forest Plan. 

Comment: Concern was expressed that Class II fisheries value identified in the Proposed Forest 

Plan might be too closely tied to economic value and not consider ecological, genetic and other 

values. 

Response: The intention was to simply contrast the value of Class II streams with Class I streams. 

While they all have important values, Class II streams clearly have less overall value to fisheries because, 

as stated in the text, they are not anadromous and often have natural barriers to fish movement. 
Appendix H 

Comments and Responses H-70 Final EIS 

Comment: One comment stated that steelhead should be listed as a species of concern in the 

EIS. 

Response: A species of concern is a specific Federal ESA designation used by the U.S. Fish and 

Wildlife Service or the National Oceanic and Atmospheric Administration (NOAA) Fisheries. No steelhead 

population in Alaska is currently identified by either agency as a species of concern under this 

designation. Assigning this type of designation is outside the Forest Service’s responsibility and the 

scope of this Forest Plan Amendment. The Forest Service does, however, develop a list of “sensitive 

species” which includes some fish, as noted in the EIS. No steelhead stocks have been determined to 

meet this designation on the Tongass National Forest. This species list is periodically reviewed and if 

warranted based on the status or sensitivity of a stock, the species on this list can be changed. 

Comment: One comment recommended that "bankfull width" be changed to "average bankfull 

width" in the Fish Standards and Guidelines. They also recommend that the Proposed Forest 

Plan distinguish between restoration and improvement because they believe that the Forest 

should focus on restoration activities. 

Response: Bankfull width is the correct term. The word "average” from "average bankfull width" was 

removed from the equation in the next line to be consistent. Restoration was added to the Fish Habitat 

Improvement section and the following statement: "Give priority to restoration projects" was added under 

Fish Habitat Restoration and Improvement. 

Comment: One comment recommended that the Watershed Resources Improvement subsection 

in the Soil and Water Standards and Guidelines be changed to Watershed Restoration and that 

several similar changes be made in the text. 

Response: These changes have been made in the Final Proposed Forest Plan. 

Comment: One comment recommended that a passage and citation be added to Appendix G 

concerning the potential harmful effects of bark debris near Log Transfer Facilities. 

Response: This change has been made in the Final Proposed Forest Plan.

Comment: One comment stated that the term "riparian project areas" used in Riparian Planning II, 

B. 3 (on page 4-62 of the Proposed Forest Plan) should be further described.

Response: This term is not used in the standards and guidelines. The term "Riparian Management 

Areas" is used throughout, including the location referenced in the comment. This term is defined in the 

glossary to the Proposed Forest Plan. 

Comment: One comment recommended that the Riparian Management Area be expanded to 

include the “entire floodplain for unconfined alluvial flood plain channels, alluvial fan channels, 

and glacial outwash channel, high mass-movement hazard soils and wetland fens.”

Response: As noted in Appendix D of the Final Proposed Forest Plan, the areas identified in the 

comment are generally included in the riparian buffers. 
Appendix H

Final EIS H-71 Comments and Responses

Comment: One comment stated that some of the groups involved with habitat enhancement 

activities were not identified in the Fish section under Fish Habitat Enhancement. 

Response: This section has been modified in the Final EIS to identify additional groups involved in 

habitat enhancement.

Comment: One comment requested that several edits be made to the subsection of the Draft EIS 

Fish section that addresses invasive aquatic species. These changes included the addition of a 

specific citation and the addition of cordgrass and green crab to the discussion of invasive 

species. 

Response: This information has been included in the Final EIS. 

Geology, Soils, Karst and Caves 

Comment: Several comments cited the unique and valuable nature of karst lands in the Tongass 

National Forest, the connection between karst lands and fisheries resources, and a legacy of 

damage to karst lands caused by historic timber harvest as justification for further protections of 

karst lands in the Proposed Forest Plan. Some comments favored no additional timber harvest or 

road construction activities on karst lands and one suggested that substantial portions of secondgrowth karst forests should be allowed to return to old-growth conditions. Several comments 

called for additional research into karst systems and potential impacts of land management 

before allowing any further timber harvest on karst lands. One comment noted that the Draft EIS 

did not present permanent protection of karst lands as the best way to ensure ecological integrity. 

Another suggested greater protections for moderate vulnerability karst lands, including avoiding 

road construction and rehabilitating and restoring existing roads. 

Response: The Forest Service considered a range of alternatives that included differing degrees of 

potential timber harvest and road construction activities. All but Alternative 5 (the No Action Alternative) 

would move about 42,870 acres of high vulnerability karst lands into the Special Interest Area LUD. 

Geologic Special Interest Areas have unique geologic features, including caves. Chapter 3 of the Final 

Proposed Forest Plan states that Special Interest Areas would be classified as unsuitable for timber 

production. Under the action alternatives, limited salvage of windthrown timber would be allowed along 

existing roads within these areas, as long as karst and cave resource values were met. Opportunities for 

management of the young-growth stands in these areas are emphasized consistent with protection of 

karst and cave resources. 

The Draft EIS evaluated the potential effects of each alternative on karst resources. These alternatives 

did not exclude harvest from all karst lands, in part based on the findings of the Karst Review Panel that 

the implementation of the Karst and Cave Standards and Guidelines from the current Forest Plan had 

ensured a high level of protection for karst resources overall (Griffiths et al. 2002). The Panel noted high 

standards in both the philosophy of management and the way that specific management practices were 

formulated and applied. Implementation of specific policies and procedures was found to be very good 

and in general compliance with the stated goals and objectives of the karst program. The Panel also 

noted the extent to which high vulnerability karst had been protected since 1997. In addition, the Panel 

outlined the actions required to more actively manage karst landscapes covered with second growth 

stands and recommended a new procedure for assessing the autogenic (precipitation on carbonate 

rocks) recharge component of karst units. These suggestions were incorporated into the action 

alternatives. Refer to the EIS for additional information. 

The Karst and Cave section of Appendix B to the Final Proposed Forest Plan identifies several research 

needs, including studies that better define the effects of timber harvest and road construction on karst 

lands, and studies to determine the influences of forest road construction on sediment and woody debris 

delivery to karst drainage systems. The Proposed Forest Plan requires an adaptive management 
Appendix H 

Comments and Responses H-72 Final EIS 

approach for managing karst resources that will allow incorporation of research results in management 

approaches. More information is provided in Chapters 4, 5, and 6 of the Proposed Forest Plan. 

Comment: A number of comments expressed concern about the lack of enforceable standards in 

the proposed Karst and Cave Resources Forest-wide Guidelines (and related Appendix H). 

Several comments noted that this section of the Proposed Forest Plan differed from others by 

providing only guidelines, as opposed to standards and guidelines. Many offered that the 

Proposed Forest Plan was significantly improved with respect to karst management, but several 

comments suggested that the language in the proposed Karst and Cave Resources Forest-wide 

Guidelines (and related Appendix H) allowed too much flexibility in karst management through the 

use of terms like “should” and “may” instead of “shall”. A few comments noted that the 

Equivalent Clear-cut Area approach described in Appendix H could mitigate impacts from 

previous timber harvest on karst lands but that the approach was “hypothetical” and not 

enforceable. 

Many suggested that the adaptive management approach would allow politics to sway decisions 

to the detriment of karst resources. Furthermore, two comments noted the lack of detailed 

monitoring requirements to implement the adaptive monitoring approach. 

Response: The Proposed Forest Plan includes both standards and guidelines but generally requires 

managing karst lands with an adaptive management approach. The title of the section has been revised 

to Karst and Cave Resource Standards and Guidelines to reflect that Karst and Cave Standards and 

Guidelines are consistent with, and as enforceable as, standards and guidelines related to other 

resources in the Forest Plan. The Karst and Cave Resource Standards and Guidelines (Chapter 4) allow 

karst managers to exercise their professional judgment in developing karst management strategies and 

prescriptions. As knowledge is gained from implementation, monitoring, research, and studies, 

recommended practices will be modified to reflect the needed changes. 

Chapter 5 of the Proposed Forest Plan describes monitoring and evaluation as key aspects of adaptive 

management, which provide feedback on implemented activities and the effectiveness of associated 

resource protection or mitigation measures. Additional sources of feedback include scientific literature 

and studies, resource inventories, changes in technology, and public concerns. Chapter 6 describes the 

monitoring and evaluation plan for Karst and Cave Resources. The monitoring and evaluation plan is not 

intended to depict all monitoring, inventorying, and data gathering activities undertaken on the Tongass, 

or to limit monitoring. Many other monitoring activities are conducted under direction contained in sitespecific project plans developed under the programmatic guidance of the Forest Plan. 

Comment: One comment supported the Autogenic Recharge Area Assessment Procedure and 

Equivalent Clear-cut Acre approaches described in Appendix H of the Proposed Forest Plan. 

These approaches allow for consideration of past timber harvest and other management activities 

on karst lands in evaluating karst lands for potential future activities. The comment expressed 

concern, however, that these approaches may not be implemented as proposed. 

Response: The Proposed Forest Plan establishes the adaptive management strategy for managing 

karst resources. Using this approach, the Autogenic Recharge Area Assessment Procedure, Equivalent 

Clear-cut Acre, and other approaches would be overseen by qualified karst managers. See also the 

response to the preceding comment. 

Comment: One comment stated that impacts from roads on moderate vulnerability karst lands 

should be monitored, and road maintenance activities, including culvert replacement, should not 

damage karst areas. Another comment noted that road construction seems to be addressed fairly 

well in the Proposed Forest Plan, but stated that standards and guidelines should require 

maintenance of existing roads to include construction of drainage systems that meet current 
Appendix H

Final EIS H-73 Comments and Responses

guidelines. The comment also stated that retired roads should include drainage systems that are 

protective of karst lands. A third comment requested that a standard be added requiring adequate 

“restocking on stored roads”, and the exploration of restoration options, such as road 

obliteration, on moderate and high vulnerability karst lands. 

Response: The Proposed Forest Plan is programmatic, meaning that it provides forest-wide 

management direction. Chapter 6 of the Proposed Forest Plan lists monitoring of compliance of landdisturbing projects (which would include roads) with Karst and Cave Forest-wide Standards and 

Guidelines, as well as monitoring of the effects of management activities (which would include roads) on 

karst resources. Road maintenance activities and any reconstruction or restoration activities would be 

covered under a project-specific plan which would be evaluated through a separate NEPA process. 

Road-related management activities would be implemented under the Karst and Cave Forest-wide 

Standards and Guidelines. 

Comment: One comment stated that no recreation development should be allowed on high 

vulnerability karst lands and pointed out that the Proposed Forest Plan allows limited recreation 

development on high vulnerability karst lands. 

Response: Section 3 (High Vulnerability Karst Lands), subsection b (Karst Management Objectives and 

Appropriate Land Uses) describes the limited recreational development that may be appropriate on high 

vulnerability karst lands. This section further explains that recreational facilities and trails would have to 

consider karst resource values and objectives, particularly with respect to reducing disturbance of 

significant epikarst features and sensitive soils, and the use of construction methods that avoid erosion 

and diversion of natural drainage waters into karst features. The Forest Service believes that this 

consideration would sufficiently limit recreational developments to protect high vulnerability karst lands. 

Comment: One comment applauded the focus on managing second growth on karst lands, but 

wanted to see thorough scientific studies (including monitoring and evaluation) before any largescale second-growth management is implemented. The comment stated that road construction 

for management would damage karst lands, and expressed concern that research be conducted 

to determine whether pre-commercial or commercial thinning would benefit karst lands and to 

assess the potential impacts. 

Another comment noted that funds for pre-commercial thinning are limited, and that the Forest 

Service should prioritize thinning on second-growth areas that will be available for future 

harvesting and can benefit wildlife, rather than on karst areas where timber harvest is not allowed. 

Other comments stated that implementation and effectiveness monitoring of young-growth 

management on karst lands should be required to assess whether karst management objectives 

can be met.

Response: The Proposed Forest Plan notes that pre-commercial thinning is appropriate on all karst 

lands when the karst management objectives can be met. It does not attempt to prioritize funding for precommercial thinning projects on or off karst lands. The specific benefit of pre-commercial thinning 

projects on wildlife or timber potential would be assessed during the project-specific planning process. 

Chapter 6 of the Proposed Forest Plan describes implementation and effectiveness monitoring under 

karst and caves. This includes monitoring the compliance of land-disturbing projects with Karst 

Standards and Guidelines, and monitoring of effects of management activities on caves and karst 

landscapes, both of which would address young-growth management on karst lands. 

As described in the response to a previous comment summary, the Karst and Cave section of Appendix B 

identifies the need for research to better define the effects of timber harvest and road construction on 

karst lands. The results of these studies will be incorporated into management decisions through the 

adaptive management approach described in the karst sections of the Proposed Forest Plan, as well as 

in Chapter 5. Finally, all the alternatives except Alternative 5 (the No Action Alternative) would move 
Appendix H 

Comments and Responses H-74 Final EIS 

about 42,870 acres of high vulnerability karst lands into the Special Interest Area LUD. These areas 

would be classified as unsuitable for timber production. 

Comment: One comment stated that the Draft EIS failed to take into account past timber harvest 

on karst lands, and instead of protecting the remaining karst forest by strengthening standards 

and guidelines, it proposes to weaken them. The comment specifically notes that future timber 

harvests are proposed on karst lands in Tuxekan, Hecata, northwest Prince of Wales Island, and 

Kosciusko. Another comment notes that the cumulative effects of previous timber harvest and 

road construction on karst lands were not considered in developing the standards and guidelines 

for future timber harvest. 

Response: The Final EIS takes into account past timber harvest activities. Furthermore, the EIS 

discloses that all but Alternative 5 (the No Action Alternative) would move about 42,870 acres of high 

vulnerability karst lands into the Special Interest Area LUD. As noted in response to a previous comment 

summary, Chapter 3 of the Final Proposed Forest Plan states that Special Interest Areas would be 

classified as unsuitable for timber production. The EIS includes a discussion of cumulative effects, 

including the effects of previous and proposed timber harvest and road construction activities on karst 

lands by alternative. This discussion has been expanded in the Final EIS. Site-specific activities, such as 

specific timber harvests, are beyond the scope of this document and are instead addressed at the local 

level under separate NEPA processes. 

Comment: One comment expressed concern about the following statement under Karst in Table 

2-18 (Summary Effects Matrix) of the Draft EIS: “The relative effects on karst resources are 

proportional to the amount of karst lands in the mapped suitable forest land base.” The comment 

asserted that timber harvest would have no significant impact on karst and that construction 

would have very minimal impacts on karst. 

Response: The Draft EIS states: “Potential effects on karst lands from planned timber harvesting, 

associated road construction, and quarry development may occur; however, with careful implementation 

of the current or proposed standards and guidelines (as modified through ongoing monitoring and 

adaptive management), and site-specific mitigation measures (designed and implemented at the project 

level), the Forest expects to mitigate the effects of any proposed activity. Site-specific mitigation 

measures include protection of the high vulnerability karst areas and features, partial cutting, reduced 

harvest unit size, use of logging systems that achieve at least partial suspension, reductions in rate of 

harvest, and other changes in logging practices.” 

This text in Table 2-18 has been clarified in the Final EIS. 

Comment: One comment noted that the Tongass does not have a catchment area management 

strategy for autogenic recharge areas and asked what steps were in process to develop this 

strategy. 

Response: The Proposed Forest Plan provides the direction necessary to protect and manage 

autogenic recharge areas and other specific needs associated with karst and cave resources. 

Comment: Based on the Federal Cave Resource Protection Act, one comment requested that the 

word “feasible” be changed to “practical” in the sentence: “Maintain, to the extent feasible, the 

natural karst processes and the productivity of the karst landscape while providing for other land 

uses where appropriate.” 

Response: The proposed change from feasible to practical has been incorporated in two places in the 

Proposed Forest Plan, as suggested. 
Appendix H

Final EIS H-75 Comments and Responses

Comment: One comment requested more specific guidance regarding when, and how many, dye 

trace studies are needed to credibly delineate recharge areas during karst vulnerability mapping. 

Response: The Proposed Forest Plan adequately addresses the need for design criteria for dye trace 

studies to delineate recharge areas during karst vulnerability. It is also reasonable to assume the proper 

skill level and expertise will be used in all karst-related work including dye trace studies. 

Comment: One comment stated that the Draft EIS lacks important information to assess impacts 

of the alternatives on karst resources, including: miles of road on karst lands, acres of previously 

harvested karst lands, how well harvested karst lands have regenerated, how well roads on karst 

lands have been maintained, and the current road maintenance backlog. 

Response: The Draft EIS states: “GIS queries show that a total of 95,479 acres (21 percent) of the karst 

lands managed by the Tongass National Forest have experienced timber harvest.” The Draft EIS also 

explains, “In some portions of the Tongass National Forest, 70 to 80 percent of the commercial forest 

land within specific karst blocks has been harvested. It is estimated that about 50 percent of the karst 

lands below 1,400 feet in elevation and on slopes less than 60 percent in the Thorne Bay Ranger District 

have had timber harvest (based on the GIS database).” Additional information has been added to the 

Final EIS, including miles of road on karst lands, and a discussion of how well harvested karst lands have 

regenerated and how well roads have been maintained. 

Comment: One comment requested that section D.1 on page 4-22 of the Proposed Forest Plan 

refer to section D.2.c. This reference would clarify the proposed management of a high 

vulnerability feature within a low vulnerability area and the applicable karst feature buffers that 

would apply. 

Response: This change has been made to the Proposed Forest Plan, as suggested. 

Comment: One comment expressed concern over the designation of “minor” resurgences with 

almost no connectivity between the open atmosphere and the underground system as moderate 

(as opposed to high) vulnerability karst lands. The comment mentioned observations of karst 

systems with resurgent springs with no surface connectivity but that may merit high vulnerability 

status. The comment expressed doubt that sufficient field reconnaissance would be possible to 

accurately characterize high vulnerability areas. 

Response: The Proposed Forest Plan states that resurgences can be classified as moderate or high 

vulnerability depending on size, habitat, and level of atmospheric connectivity between the resurgence 

and the underground karst system. Minor resurgences which seep out of the ground between gravels 

with almost no connectivity between the open atmosphere and the underground system will be classified 

moderate vulnerability. This designation will be made by a qualified karst management specialist, who 

would also design appropriate protection measures for moderate vulnerability resurgences and springs on 

a case-by-case basis. 

Comment: One comment strongly objected to the wording in the Proposed Forest Plan that 

indicated that the karst lands on the Tongass National Forest were considered open to mineral 

development. The Proposed Forest Plan states: “It is not the intent of these standards and 

guidelines to restrict any lands from mineral development, though that may be appropriate if a 

specific project or area is allocated to the "Special Interest Area” Land Use Designation.” The 

comment paraphrased the 1988 Federal Cave Resources Protection Act requirement that the 

agency responsible for land management in karst areas must protect those caves and features. 
Appendix H 

Comments and Responses H-76 Final EIS 

Response: The Federal Cave Resources Protection Act of 1988 states that NFS lands will be managed 

in a manner which, to the extent practical, protects and maintains significant cave resources in 

accordance with the policies outlined in the Forest Service Directive System and the management 

direction contained in the individual forest plans. The Proposed Forest Plan states that the impacts of 

any proposed mineral development within the karst landscape would be analyzed through the 

environmental analysis that would be triggered once a Plan of Operation was received. 

Comment: One comment expressed concern that the Forest Service will continue to hold cave 

location information confidential and not distribute location information per the 1988 Federal Cave 

Resources Protection Act. The comment encouraged continued collaboration with caving 

organizations, including collaboration to define appropriate uses, discuss cave classifications, 

consider potential cave developments, and solicit volunteers. 

Another comment commended the Forest Service for the extensive rewriting of the Forest Plan, 

noting that management of karst and cave resources was better defined and more clearly 

described than in the previous Forest Plan. They anticipate future collaboration and volunteer 

work with the Tongass. 

Response: The Forest Service intends to continue to “foster communication, cooperation, and exchange 

of information between land managers, those who utilize caves, and the public”, per Section 4 (c)(2) of 

the 1988 Federal Cave Resources Protection Act. The Forest Service also intends to continue to 

implement 36CFR 290.4 and Section 5 of the Federal Cave Resources Protection Act, which requires 

that it maintain the confidentiality of information concerning the nature and location of significant caves. 

Comment: One comment expressed concern about the change in non-harvest buffers related to 

insurgent streams in moderate vulnerability karst lands between the previous Tongass Plan 

Implementation Team clarifications and the Proposed Forest Plan. The Tongass Plan 

Implementation Team clarifications suggested that non-harvest buffers extend from the edge of a 

sinking or losing stream and cover 100 feet plus 2 tree lengths within no less than 1 mile 

upstream or to the stream’s source. The Proposed Forest Plan indicates that the 100-foot noharvest buffer would extend only 0.25-mile upstream. The comment stated that this change is 

significant and should be reassessed and justified to the public. 

Response: The Final Proposed Forest Plan provides for protection of karst and cave resources and 

promotes adaptive management principles achieving this. Additional buffers could be implemented 

where recommended by a qualified karst manager to ensure compliance with the Karst and Cave 

Resource Standards and Guidelines. 

Comment: One comment noted that the reference to harvest on 72 percent slopes had been 

moved from the karst appendix (Appendix H) to the Soil and Water section of the Proposed Forest 

Plan. Given the potential soil loss, hydrologic change, and mass wasting impacts related to 

timber harvest, roads, and other development activities on steep karst lands, the comment 

requested that no harvest on steep slopes be the standard and not under the discretion of the 

District Ranger on a case-by-case basis. 

Response: The Proposed Forest Plan states: 

“At the forest plan level, slope gradients of 72 percent or more are removed from the tentatively 

suitable timber base due to high risk of soil mass movement and accelerated erosion of Class IV 

channel systems. At the project planning level, the Forest Supervisor or District Ranger may approve 

timber harvest on slopes of 72 percent or more on a case-by-case basis, based on the results of an 
Appendix H

Final EIS H-77 Comments and Responses

onsite analysis of slope and Class IV channel stability and an assessment of potential impacts of 

accelerated erosion on downslope and downstream fish habitat, other beneficial uses of water, and 

other resources. It is anticipated that harvest of these areas will be a small percentage of the total 

harvest unit.” 

Proposed timber harvest on slopes greater than 72 percent would undergo an onsite analysis and an 

assessment of potential effects on downslope resources, including karst. 

Comment: A number of comments noted that the Tongass should make sure that karst lands are 

not transferred to entities with fewer measures to ensure karst protection. They note that if karst 

lands are transferred, the transfer should include special considerations requiring management 

practices that are as protective or more protective of karst lands. Karst managers would need to 

work with land transfer experts to ensure that karst lands continue to receive at least the level of 

protection that the Forest Service currently provides. One comment noted that many of the 

proposed land exchanges and adjustments with Sealaska contain valuable karst lands. The 

comment notes that the Draft EIS does not discuss how the Forest Service will treat land 

exchange or adjustment requests that involve karst lands. 

Response: While Appendix C discusses several proposed land exchanges, this does not mean that they 

are likely to occur or would occur exactly as depicted. Land exchanges are discretionary, voluntary real 

estate transactions between federal and non-federal parties. The Forest Service is not required to enter 

into a land exchange when presented with a proposal. Any exchange would require NEPA analysis, most 

likely an EIS, which would include public involvement and would disclose any adverse effects to karst and 

cave resources, as well as to other resources. The Draft EIS discloses that the Sealaska proposal 

presented to the Forest Service does not provide any assurances that important resources on the lands 

Sealaska proposes to acquire would be protected to the same degree as under national forest 

management. Specifically, the proposal does not include assurances that karst and cave resources 

would be protected. 

The cumulative effects section of the Draft EIS has been expanded to include a discussion of the 

potential effects of future land exchanges on karst resources. 

Comment: One comment supported the new Geologic Special Interest Areas. The comment 

noted that while legislated protections would be stronger and more protective of karst wilderness 

areas, the Special Interest Areas are an excellent first step in providing permanent protection for 

the “best of the best” karst lands. Continued collaboration was suggested to increase the 

protection of Special Interest Areas. 

Response: The Forest Service considered a range of alternatives that included differing degrees of 

proposed timber harvest and road construction activities. The Draft EIS evaluated the potential effects of 

those alternatives on karst resources and disclosed the findings of the Karst Review Panel, which found 

that implementation of the Karst and Cave Standards and Guidelines from the current Forest Plan had 

ensured a high level of protection for karst resources overall (Griffiths et al. 2002). As noted in one of the 

preceding responses, the Forest Service intends to continue collaboration with those who use caves and 

the public. 
Appendix H 

Comments and Responses H-78 Final EIS 

Heritage and Sacred Sites 

Comment: One comment requested that the Final EIS clarify the types of traditional use that are 

permitted in Conservation System Units, including designated Wilderness. The definition of 

traditional activities in the Region 10 Forest Service Manual (1/27/99) includes recreational 

pursuits. The comment authors stated that they strongly disagree with the inclusion of recreation 

in this definition and requested that the Forest Service adopt and implement a definition similar to 

that employed by the National Park Service, which defines “traditional” as an activity that 

occurred when ANILCA was passed and involves the consumptive use of one or more natural 

resources of Old Denali Park, such as hunting, trapping, fishing, berry picking, or similar 

activities. 

Response: Traditional uses are allowed in designated wilderness as authorized by ANILCA. Updating 

Regional manuals and handbook definitions is beyond the scope of this Amendment.

Comment: Some respondents asked that protection of Native sacred sites be of paramount 

importance. They felt that working together was critical for any protection measures to succeed. 

One comment suggested that the Forest Service employ a tribal liaison to insure that sites are 

protected. 

Response: We agree that protection of these sites is very important. All alternatives, except Alternative 

5 (No Action), include updated heritage direction for sacred site identification and management. These 

changes include strong direction for communicating and working with tribal governments. 

Comment: Some respondents felt that the Forest Service should seek National Historic Landmark 

designation, or otherwise protect, certain historic sites. Sites mentioned included the World War 

II site at Hunter Bay, the Russian Colonial sites at Salmon Lake, and the site near the falls of 

Redoubt Lake. 

Response: We will share this information with our Heritage Program Manager but landmark designation 

is outside the scope of the Forest Plan Amendment. 

Comment: One respondent felt that the Forest Service listens more to other agencies and 

organizations than it does to tribal governments indicating a bias. 

Response: The Forest Service does not believe this to be the case. We continue to consult and 

communicate with tribal governments, as well as other agencies and organizations. 

Comment: Some respondents expressed concern about timber harvest and new road and trail 

development and the potential impacts on sacred and traditional hunting, gathering and fishing 

sites. They wanted to be informed if new development was being considered. 

Response: New development or other site-specific projects would only occur after project level analysis 

that includes public involvement and tribal consultation. 

Comment: One respondent stated that the Forest Service needs to not only guard against future 

adverse impacts to native allotments but also should restore allotment lands damaged by timber 

harvest and road building. 

Response: Native allotments are private land and beyond the scope of this Amendment. 
Appendix H

Final EIS H-79 Comments and Responses

Comment: One tribal corporation felt that the Proposed Forest Plan should have additional 

requirements related to sacred sites, greater specificity of disclosure, no confidentiality 

requirements, and a requirement to provide an annual report in person to the board of directors. 

Response: The Proposed Forest Plan is consistent with updated Forest Service direction on 

management of sacred sites and consultation. 

Lands 

Comment: One comment stated that Sealaska Corporation’s remaining entitlement acreage is 

underestimated in Appendix C and that Section 205 of the Alaska Land Transfer Acceleration Act 

increased the minimum additional acreage to be allocated to Sealaska. Sealaska estimates that 

between 65,000 and 85,000 acres is required to complete Sealaska’s Alaska Native Claims 

Settlement Act (ANCSA) entitlement, not 64,000 acres as the Forest Service states. 

Response: We recognize that the actual final acreage to be conveyed may be unknown at this time. 

Based on the best information available, both the Forest Service and the USDI Bureau of Land 

Management (BLM) agree that approximately 64,000 acres of ANCSA entitlement remain to be conveyed 

to Sealaska Corporation. This includes about 20,000 acres of unconveyed lands remaining from a 1988 

AFN/BLM Agreement and approximately 44,000 acres of 14(h)(8) lands resulting from the 2004 Alaska 

Land Transfer Acceleration Act, PL 108-452. (Using exact figures, this totals 63,622.10 acres. In 

addition, Sealaska may be entitled to several additional acres in selected but unconveyed 14(h)(1) sites. 

It is unlikely that the total would exceed 63,650 acres.) 

Prior to passage of PL 108-452 in 2004, BLM and the Forest Service estimated Sealaska’s remaining 

entitlement as being between 59,000 acres and 64,000 acres. The 2004 legislation helped verify the 

current estimate of 64,000 acres. 

Comment: One comment stated that Appendix C underestimates the public advantages of 

releasing the 327,000 acres of land that are withdrawn for Sealaska selections and conveyances. 

This large acreage remains encumbered and restricted from commercial timber production, 

investment, and active management while it remains withdrawn. 

Response: Those lands that are withdrawn, but not selected by Native Corporations and also those 

lands that are selected, but not conveyed continue to be managed by the Forest Service, with certain 

requirements. The actual effects or public advantages of removing the encumbrances are difficult to 

quantify. 

On lands withdrawn, but not selected by a Native Corporation, the requirements of 43 CFR, Section 

2650.1(a) apply: “Prior to the Secretary’s making contracts or issuing leases, permits, rights-of ways, or 

easements, the views of the concerned regions or villages shall be obtained and considered ...” In 

addition, all proceeds collected from contracts (including timber sales), leases, permits, rights-of-way, or 

easements on lands withdrawn for Native selection are deposited in an escrow account managed by the 

Bureau of Indian Affairs. Road development and habitat enhancement projects may still be authorized on 

these lands. 

On lands that have been selected, but not conveyed, Forest Service policy is to authorize no contracts, 

special use permits, mineral materials permits, easements, right-of-way or other third party interests 

without the consent of the affected native corporation, unless specific authorization is received from the 

Regional Forester. 

Lands that are withdrawn, but not selected, are managed by the Forest Service subject to certain 

restrictions but they are not encumbered to the extent that the actual selected lands are.
Appendix H 

Comments and Responses H-80 Final EIS 

Comment: One comment stated that Appendix C overestimates the effect on Tongass timber 

harvest from the completion of Sealaska’s entitlement through land exchanges and adjustments, 

and understates the corresponding gain in available land and timber from acres transferred to the 

Tongass National Forest. These effects are portrayed as much larger than a potential transfer of a 

similar amount of acres to “unrecognized Southeast Alaska communities.” 

Response: This discussion was specific to the exchange proposal as submitted by Sealaska. The 

effects discussion was based on an actual analysis of the exchange proposal effects. Lands transferred 

to the Tongass (based on the proposal) would not be available for timber production but rather, were 

chiefly valuable for recreation and scenic values. These impacts differ to those identified for the 

“unrecognized Southeast Alaska communities” proposal because that analysis was hypothetical. There 

are no actual parcels that can be identified and analyzed. The Sealaska exchange analysis was based 

on actual parcels identified by Sealaska for their timber values. 

Comment: One comment stated that Appendix C ignores the positive aspects of timber lands 

transferred to Sealaska and the corresponding positive impact to the Southeast Alaska forest 

industry and economy. Lands transferred to Sealaska would still be available to support the 

timber industry in Southeast Alaska.

Response: As virtually all timber from Sealaska lands has historically been exported in unprocessed 

form, it seems reasonable to assume that timber harvest from any transferred lands would support 

logging and transportation-related jobs, but would be unlikely to support local or regional sawmills or 

smaller value-added woodworking operations. 

Comment: One comment stated that Appendix C mischaracterizes the change in other land 

allocations and resources attributed to the completion of Sealaska’s entitlement by 

overestimating the acreage to be conveyed and by ignoring the effects of releasing the 327,000 

acres of lands withdrawn and encumbered for Sealaska selections and conveyances and the 

benefits associated with Roadless and other lands valued for wildlife habitat, recreation, 

subsistence, scenery and other public uses that would be transferred to the National Forest. 

Response: The discussion in Appendix C of the Draft EIS is very specific to the land exchange proposal 

submitted by Sealaska Corporation. The purpose of discussing the proposed exchange in Appendix C 

was to give a general estimate of the effects of completing the proposed exchange. It was not intended 

to provide a detailed accounting of the effects. As stated in Appendix C, it would be difficult to determine 

the actual acreage that might be transferred without an appraisal and very unlikely that all of the lands 

proposed for exchange would actually be transferred. Therefore, we cannot provide a full accounting of 

the possible effects. While there would be a benefit to some resources from acquiring the areas 

Sealaska proposes to exchange to the NFS, there would be a corresponding loss of these values on the 

95,000 acres Sealaska wishes to acquire. 

As for ignoring the benefits of releasing the 327,000 acres of encumbered land, we estimate that 

approximately 171,000 acres are encumbered by Sealaska selections, not 327,000 acres. We also 

estimate that approximately 64,000 acres of these selected lands would actually be conveyed to 

Sealaska Corporation, considerably less than the 95,000 acres Sealaska proposes to acquire. As noted 

in an earlier response in this section, the management restrictions on lands withdrawn but not selected 

are less than the comment suggests.

Comment: One comment stated that the adjustment to suitable timber land base shown on page 

3-226 of the Draft EIS is an underestimate if the Forest Service used the 171,000 acre figure rather 

than the entire 327,000 acres encumbered within the Sealaska withdrawal areas. The effects to 

the timber program of resolving entitlement would be positive because the encumbrance on the 

remaining 327,000 acres would be removed and these acres could be managed for timber. 
Appendix H

Final EIS H-81 Comments and Responses

Response: As noted in the response to the preceding comment, the Forest Service believes that 

171,000 acres is correct and the management restrictions that apply to withdrawn but not selected lands 

are less restrictive than the comment author states. 

Comment: One comment stated that Appendix C erroneously suggests that heritage, karst and 

cave, and subsistence resources and uses could be adversely affected by conveyances to 

Sealaska because of differences in legal requirements applicable to Native Corporations 

compared to NFS lands. The comment notes that this suggestion ignores Sealaska’s established 

leadership in heritage resource protection and in land stewardship. 

Response: This discussion was specific to the land exchange proposal submitted by Sealaska 

Corporation. There were no assurances in the proposal or in discussions with Sealaska that resources 

on lands to be exchanged to Sealaska would be protected to the same degree as under current NFS 

management. The legal requirements for resource protection on NFS lands are different from those on 

private land. Information about the resource values on lands for potential exchange to the United States 

by Sealaska has been added to the Final EIS. 

Comment: One comment stated that Appendix C does not recognize that Section 22(f) of ANCSA 

was included to provide for the adjustment of Native Corporation land conveyances and that 

legislative adjustments to ANCSA will continue until entitlements are resolved to meet the 

statute’s original promise. 

Response: Section 22(f) of ANCSA allows land exchanges with Village Corporations, Regional 

Corporations, individuals, or the State for the purpose of effecting land consolidations or to facilitate the 

management or development of the land. However, land exchanges are discretionary, voluntary real 

estate transactions between the federal and non-federal parties. The Forest Service is not required to 

enter into a land exchange when presented with a proposal. This is clarified both in the Lands section of 

the Final EIS and in Appendix C. 

Comment: One comment stated that Appendix C is incorrect in stating that Sealaska is not 

currently authorized to receive lands outside the ANCSA withdrawal areas under ANCSA since 

ANCSA (Section 22[f]) clearly authorizes Sealaska to acquire lands outside the withdrawal areas 

through exchange. In addition the Appendix incorrectly indicates that exchanges generally must 

be for equal appraised market value. Both ANCSA and ANILCA contain authority for exchanges 

found to be in the public interest to take place for other than equal value. 

Response: The Forest Service disagrees with the statement that Sealaska is currently authorized to 

receive lands outside the ANCSA withdrawal areas because of Section 22(f) of ANCSA. As noted in the 

preceding response, Section 22(f) of ANCSA allows for land exchanges with Native Corporations. 

Hypothetically, Sealaska could receive land outside of the withdrawal areas through a land exchange. 

Land exchanges are discretionary and voluntary. Currently, there is no binding land exchange agreement 

in effect between the Forest Service and Sealaska Corporation. 

Generally, land exchanges are on an equal value basis and cash payments can be used to equalize land 

values up to 25 percent of the appraised value of the federal land. It is also correct that both ANCSA in 

Section 22(f) and ANILCA in Section 1302(h) provide that exchanges shall be based on equal value and 

contain provisions for cash equalization, except that exchanges can be made for other than equal value 

when the parties agree, and the Secretary of Agriculture determines that it is in the public interest. 

Comment: One comment stated that Appendix C treats Sealaska’s land entitlements and 

adjustment proposal as a negative encumbrance that the Forest Service will address grudgingly 
Appendix H 

Comments and Responses H-82 Final EIS 

and fails to recognize that completing conveyances of land to Sealaska in a sustainable 

configuration is an entitlement under ANCSA. 

Response: The Forest Service recognizes Sealaska Corporation’s right to receive its full entitlement 

under ANCSA and will continue to work with the BLM in processing conveyance documents for selected 

lands. Appendix C has been reviewed and edited in response to these concerns. 

Comment: One comment stated that many of the “defects” in Appendix C also appear in the Draft 

EIS. The cumulative effects sections in the Draft EIS overestimates the potential adverse effects 

and underestimates the benefits of timber harvest on Sealaska and other Native Corporation lands 

by not adequately recognizing the protective BMPs that Sealaska and other owners apply.

Response: While the Forest Service agrees that the BMPs are beneficial, management on NFS lands 

provides a higher degree of resource protection and these differences were considered in the effects 

analyses included in the Draft EIS. 

Comment: One comment stated that the statement on page 3-223 of the Draft EIS that a revision 

of the Forest Plan would be required to accommodate an exchange with Sealaska is erroneous. 

They noted that the Forest Plan provides for land exchanges and other adjustments. 

Response: The Proposed Forest Plan does provide for land exchanges and other types of land 

adjustments. The referenced statement has been clarified to indicate that implementation of the 

Sealaska land exchange proposal would likely require a Forest Plan Amendment or Revision, based on 

the magnitude of the resulting changes in LUDs. 

Comment: One comment stated that Appendix C did not adequately depict the real effects of the 

identified potential land exchanges. 

Response: The purpose of Appendix C was to show that a number of Congressional bills for land 

conveyance and land exchanges have been proposed and that any of the proposals to convey land to the 

State or to Native Corporations, if enacted, could have a major impact on the mix of goods and services 

that the Tongass provides. 

Many of the proposed land exchanges are unlikely to occur or occur exactly as depicted. Land 

exchanges are discretionary, voluntary real estate transactions between the federal and non-federal 

parties. The Forest Service is not required to enter into a land exchange when presented with a proposal. 

Before an exchange could occur a detailed environmental analysis, including public involvement, would 

have to be done. Due to the magnitude of these potential exchanges and their potential impact on the 

mix of goods and services, a Forest Plan Amendment would also likely be needed. We have updated 

Appendix C for the Final EIS and improved the analysis based on the comments received. Please keep 

in mind that Appendix C was not intended to be a full disclosure of site-specific environmental effects. 

That will come later as described above. 

Comment: One comment stated that the 1995 Greens Creek Land Exchange included a 25 percent 

royalty paid to counties. Since there are no counties in Southeast Alaska, if there are any 

associated royalties, the City of Angoon should receive a share. 

Response: This issue is beyond the scope of this Forest Plan Amendment. 
Appendix H

Final EIS H-83 Comments and Responses

Comment: One comment stated that the Forest Service should support hydroelectric power 

development in Angoon, where it is needed for economic development and to support local 

lifestyles.

Response: A hydroelectric project is currently being analyzed in an EIS. The Draft EIS was issued in 

April 2007 and the Forest is working on the Final EIS. This is a separate process from this Forest Plan 

Amendment and will continue regardless of which alternative is selected. 

Comment: One comment stated that many of the provisions in the Plan Amendment are 

inconsistent with ANILCA (Off-Highway Vehicle [OHV] use restrictions, limits on the type of public 

recreation allowed in the wilderness, and limits on group size, restrictions on fish and wildlife 

management projects in Wild and Scenic River corridors, Research Natural Areas, and 

Experimental Forests).

Response: The travel management standard was revised in the Proposed Forest Plan to ensure that the 

plan did not make any travel management decisions. These decisions are made through local travel 

management plans. However, the Forest Service does have the authority to restrict access and use for 

overall sound management of public lands and to meet other laws and objectives. We believe that the 

proposed alternatives are compatible with ANILCA. ANILCA recognizes the need to be consistent with 

other laws such as the wilderness protection measures found in the Wilderness Act, the multiple use 

mandate found in the Multiple Use Sustained Yield Act, as well as the National Forest Management Act 

and TTRA. These laws give the Secretary of Agriculture considerable flexibility to provide public benefits 

and provide for sound management of public lands. 

Consistent with Section 810 of ANILCA, the Final Proposed Forest Plan has been evaluated for potential 

effects on subsistence uses and needs. A cumulative effects analysis of resource developments on 

subsistence resources is included in the Subsistence section of the Final EIS. Two actions included in 

Section 810 were completed for the Draft EIS: (1) giving notice to the appropriate State agency, local 

committees and regional councils; and, (2) giving notice of, and holding, “a hearing in the vicinity of the 

area involved.” Because the area is the entire Tongass National Forest, such hearings were held in 23 

communities throughout Southeast Alaska for the Draft EIS. 

The plan does not authorize any land-disturbing activities. The continuation of subsistence opportunities, 

and reasonable steps to minimize effects on subsistence resources, are provided for, in each alternative, 

by the Forest-wide standards and guidelines for subsistence, as well as related standards and guidelines 

for riparian areas, fish, and wildlife. Many important subsistence areas were assigned LUDs that exclude 

timber harvesting. In addition, the beach and estuary fringe Forest-wide standards and guidelines apply 

to all beach fringe and estuarine areas not under more restrictive designations. Adverse impacts to 

subsistence uses and resources are minimized though these measures. Potential site-specific effects on 

subsistence uses and reasonable ways to minimize these effects will be considered and analyzed during 

project-level planning. 
Appendix H 

Comments and Responses H-84 Final EIS 

Minerals 

Comment: A number of comments stated support for the mineral industry and noted that the 

industry history in Southeast Alaska included the creation of family wage jobs, as well as the 

provision of other economic benefits to communities. Comments also noted that mining occurs 

where economic deposits are found and expressed concern regarding reasonable access and 

cost of entry due to more restrictive LUDs. Some comments requested that the Forest Service 

devote resources to identifying and better understanding mineral resources on the Forest. Others 

were concerned about access to patented mining claims in Inventoried Roadless Areas.

Response: The Forest-wide standards and guidelines for Minerals and Geology support mineral 

development. The Forest Service also engages in minerals and geology-related research, with the extent 

of this research dependent on available funding. Mineral Resources, including the laws and regulations 

that provide for access to valuable mineral deposits, are discussed in the Minerals section of the Final 

EIS. 

For all seven alternatives, 25 percent of the acreage of identified mineral resources is in areas that have 

been withdrawn. Alternatives 7 and 4 have the fewest acres of identified mineral resources in LUD 

allocations potentially causing higher costs for their exploration and development, and Alternative 1 by far 

the most. The other four alternatives fall between these two in a fairly close grouping near the middle of 

the range. None of the alternatives would prohibit reasonable access to patented mining claims. 

Comment: Several comments suggested that compliance of the Proposed Forest Plan with the 

Mining and Mineral Policy Act of 1970 should be evaluated. This act, along with the General 

Mining Law of 1872, Federal Land Policy and Management Act of 1976, and the National Materials 

and Minerals Policy Research Act of 1980 were cited by several respondents in support of mineral 

development. 

Response: The Proposed Forest Plan and the minerals analysis presented in the Draft and Final EIS 

documents are consistent with the Mining and Mineral Policy Act of 1970. The Minerals section of the 

Draft and Final EIS documents specifically states that the Forest Service: “recognizes that minerals are 

fundamental to the Nation’s well being and, as policy, encourages the exploration and development of the 

mineral resources it manages. The Secretary of Agriculture has provided regulations (36 CFR 228) to 

ensure surface resource protection, while encouraging the orderly development of mineral resources on 

NFS lands.” 

Mineral Resources, including the laws and regulations that provide for access to valuable mineral 

deposits, are discussed in the Minerals section in the Draft and Final EIS documents. 

Comment: Several comments were opposed to mineral exploration and development on Duke 

Island and suggested the area be withdrawn from mineral entry. 

Response: No new withdrawals are proposed under any of the proposed alternatives. Future 

exploration and development on and around Duke Island would be subject to regulation by 36 CFR 228. 

For projects requiring a federal action (such as approval of a mining plan of operations), impacts to 

surface resources would be analyzed and disclosed on a site-specific basis, as required under NEPA. 

Comment: One comment objected to the term “hardrock” when referring to locatable minerals 

and pointed out that many locatable minerals are recovered by placer mining. 

Response: The term “hardrock minerals” is commonly used synonymously with locatable minerals. The 

comment is correct that locatable minerals are found in, and recovered from, placer deposits. The text in 

the Final EIS has been edited to make this clear. 
Appendix H

Final EIS H-85 Comments and Responses

Comment: One comment expressed concern related to the permitting delays of a specific project, 

and the process in general, as a result of public appeals. 

Response: Project specific analysis, public disclosure, and response to public concerns are required of 

all projects as required by law. The regulations under which operating plans are processed would not be 

changed by any of the alternatives considered in this analysis and are beyond the scope of this analysis. 

Comment: One comment suggested changing a reference to the U.S. Bureau of Mines, as it was 

abolished in 1996. 

Response: The text in the Final EIS has been updated to reflect this. 

Comment: Some comments disagreed with the Minerals cumulative effects finding that: “Other 

than mineral resources that are currently under development (specifically, the Kensington 

deposit), the Forest Service does not have sufficient information to identify any specific mineral 

development as reasonably foreseeable.” They pointed out that exploration has been ongoing 

throughout the Tongass for years. They specifically noted the Niblack property, near Ketchikan. 

Response: The Forest acknowledges that exploration is ongoing in varying degrees throughout the 

Tongass. As the likely development of such prospects is dependent on several factors, including the 

findings of exploration programs, metal prices, and private funding, it is not possible for the Forest to 

determine which projects are reasonably foreseeable at this time. 

Comment: Some comments either opposed mining or expressed concern over potential impacts, 

such as water quality degradation or acid mine drainage. 

Response: All existing and future exploration and development on the Forest are subject to regulation 

under 36 CFR 228 for the protection of surface resources. For projects requiring a federal action (such 

as approval of a mining plan of operations), site-specific impacts to surface resources, including wildlife 

and cultural resources, would be analyzed and disclosed as required by NEPA. Specific projects already 

analyzed and approved under NEPA are outside of the scope of this document. 

Recreation, Tourism and Scenery 

Comment: Several comments noted that restrictions on OHV use on inactive logging roads 

primarily deny local residents looking for local access and have a negative effect on local 

economies. Commercial operators, in contrast, are allowed wilderness access. Closing logging 

roads to OHV access to protect wildlife seems disingenuous when the same wildlife are regularly 

viewed from aircraft. 

Another comment noted that all roads on the Tongass are currently open for OHV use and there 

has been an exponential increase in OHV use of roads on Kuiu, Baranof, and Chichagof islands 

where there are extensive road systems. The comment author notes that illegal OHV use of 

closed roads is increasing, as are detrimental effects to the environment. Others requested that 

OHV access be allowed only where specifically permitted.

Response: Each Ranger District will work with the state and local governments, tribes, and the public, as 

required by NEPA in developing their access and travel management plans. The Standard in the Final 

Proposed Forest Plan has been updated to state: “Each ranger district will designate the roads, trails, and 

areas open to motor vehicle use on a motor vehicle use map. All operations must be in accordance with 

those designations.” 
Appendix H 

Comments and Responses H-86 Final EIS 

The revised Forest-wide Recreation and Tourism Standards and Guidelines also include the following 

directive: 

3. Provide a diversity of OHV recreational opportunities across the forest where consistent with the 

criteria in FSM 2355 and 36 CFR 212, which include: 

a) The use is consistent with established land management and resource objectives. 

b) The use is consistent with the capability and suitability of the resource. 

c) There is demonstrated demand which cannot be better satisfied elsewhere. 

More information is provided in Chapter 4 of the Final Proposed Tongass Forest Plan in the section that 

addresses Recreation and Tourism. 

Comment: A number of people at the public hearing in Juneau commented that there is presently 

nowhere in the vicinity of their community where they are legally allowed to ride OHVs or 

snowmobiles. They requested that there be areas designated on the Forest for OHV use. 

Comments noted that there are more than 100 hiking trails and no authorized OHV trails/roads. 

One person commented that where there are potential conflicts between motorized and nonmotorized uses, different uses should be authorized at different times. Others noted that the 

Forest Service should plan for balanced use between motorized and non-motorized uses.

Others commented that hiking trails in the Juneau are fully used by hikers, bikers, runners, 

mountain climbers, and other non-motorized users and requested that OHV use not be permitted 

on the existing trail system in this area. Concern was also expressed about the impact OHV use 

would have on fragile soils and ecosystems along the existing trails. 

Response: The Proposed Forest Plan is programmatic, meaning that it provides forest-wide 

management direction. Management direction with respect to OHV use is provided in the Forest-wide 

Recreation and Tourism Standards and Guidelines in the Final Proposed Forest Plan (Chapter 4). Sitespecific activities, such as the designation of trails for OHV use, are beyond the scope of this document 

and are instead addressed at the local level. The issue of OHV use and access is addressed in the 

access and travel management plan that will be prepared for the Juneau Ranger District. 

Comment: A number of comments expressed concern about resource damage caused by OHV 

use and requested that the Forest Service ensure that OHV use does not negatively impact 

wetland and habitat values. Potential negative impacts include fish habitat damage, the 

introduction of invasive species, alteration of successional pathways, and degradation of wetland 

vegetation, soils, and hydrology. 

Response: As noted in response to the first comment in this section, each District is analyzing how to 

provide reasonable access for subsistence and other uses in their access and travel management plans 

and accompanying NEPA documents. See the earlier response and the Final Proposed Forest Plan for 

further information. 

Comment: A number of comments requested that the Forest Service maintain and fix the existing 

cabins on the Tongass and also consider opening new cabins. In addition to this general request, 

comments were also submitted with respect to specific cabins that comment authors were 

particularly concerned about. These included the Karta River, Kook Lake, Smugglers Cove, and 

Helm Bay cabins. 

Response: The Proposed Forest Plan provides broad strategic direction for overall management of the 

Forest. The Forest-wide Recreation and Tourism Standards and Guidelines in the existing and Proposed 

Forest Plans, for example, direct the Forest Service to identify opportunities to enhance existing, and 

provide additional, recreation opportunities, including those related to public recreation cabins. The 

Proposed Forest Plan also identifies where cabins and other types of recreation and tourism-related 
Appendix H

Final EIS H-87 Comments and Responses

development can take place on a Forest-wide basis based on LUD classifications. Cabins are considered 

minor developments in the existing and Proposed Forest Plans. Minor developments are considered 

compatible with the Semi-Remote Recreation, Recreational River, Scenic Viewshed, and Scenic River 

LUDs and may be allowed in 10 other LUDs based on a case-by-case evaluation. Site-specific projects 

or activities related to specific existing or proposed cabins are addressed at the project level. More 

information is provided in Section 4 of the Final Proposed Tongass Forest Plan in the section that 

addresses Recreation and Tourism. Cabin maintenance and construction depends on funding from 

Congress or other sources. 

Comment: Several comments requested that the Forest Service do a better job of maintaining and 

marking existing trails and consider creating new trails for local residents, as well as visitors, 

particularly in areas surrounding communities where the majority of existing recreation 

opportunities require a boat to access. Some respondents identified trails that they were 

particularly concerned about. These included the existing Beaver Lake Trail and the potential for 

a new trail from Skagway to White Pass City. 

Another comment noted that existing logging roads could be used to provide mountain biking and 

hiking opportunities in the vicinity of communities. The same comment author expressed 

concern that the road providing access to a favorite hiking trail was not adequately maintained. 

Response: As noted in response to similar requests with respect to public cabins (see the preceding 

comment and response), the Final Proposed Forest Plan provides broad strategic direction for Forestwide management. Site-specific projects and activities related to trails are addressed at the project level. 

The revised Forest-wide Recreation and Tourism Standards and Guidelines include a number of 

directives that pertain to local recreation facilities and planning. Trail maintenance and construction 

depend on funding. 

Comment: One comment identified the following concerns with respect to recreation encounter 

rates. Are the recreation encounter rates identified in the Proposed Forest Plan meant to guide 

management activities, with action taken to reduce use if rates are exceeded, or are they meant as 

guidelines for visitor expectations? Using encounter rates to guide management activities across 

the board ignores the fact that other factors—such as weather or mosquitoes—may be equally or 

more important in measuring user satisfaction. Similarly the impact of encounters may vary 

based on terrain and vegetation. 

Response: The recreation encounter rates are identified by ROS class in the Final Proposed Forest 

Plan in the proposed ROS standards and guidelines in Appendix I. The encounter rates have been 

updated in the Final Proposed Forest Plan for the Primitive, Semi-Primitive Non-Motorized, and SemiPrimitive Motorized ROS settings. Encounter rates for the other ROS settings (Roaded Natural, Roaded 

Modified, Rural, and Urban) are unchanged from the current Forest Plan. The main purpose for these 

updates is to clarify commercial group sizes in these settings. The identified encounter rates are 

generally intended to guide management activities and may also help guide visitor expectations. Action 

may be taken on a case-by-case basis if these encounter rates are exceeded. Group size guidelines will 

be enforced. 

Comment: One comment observed that the niche market for eco-tourism is likely to remain 

unaffected because none of the alternatives would affect Wilderness and LUD II designations and 

all alternatives continue to set aside vast acreages of remote and semi-remote recreation. The 

comment also noted that only road-based recreation opportunities are likely to vary by alternative. 

Other recreation activities are likely to remain unchanged. Opportunities for expanded roadbased recreation could occur under Alternative 4 through 7, but are not likely to occur under 

Alternatives 1 through 3. 
Appendix H 

Comments and Responses H-88 Final EIS 

Response: The potential impacts of the proposed alternatives on recreation and tourism are evaluated 

in the Recreation and Tourism section of the EIS. The alternatives would result in shifts toward the 

roaded end of the ROS based on the amount of timber harvest and associated road construction that 

could occur. Potential road construction would be greatest under Alternatives 4 and 7. However, while 

there would be a relative increase in new roads, with access provided to presently undeveloped areas, 

nearly all new roads would be closed following harvest and not available for use by highway or highclearance vehicles. 

Comment: Several comments noted that a survey of Tongass hunting and fishing guides showed 

that two-thirds of them support a prohibition on logging and new road building in roadless areas. 

Some comments also noted that: 

“In the view of some long-term guides operating in the Tongass, we are nearing a “now or 

never” point in regard to how much habitat can be lost and still be able to sustain populations of 

fish and game that will allow for future opportunities for hunting and fishing on the Forest.” 

Response: The comments did not provide any further information with respect to the cited survey, but 

this sentiment has been expressed by a number of people providing comments on the Draft EIS. 

Alternative 1 was modified between the Draft and Final EIS documents to reduce the amount of logging 

and road building, with all Inventoried Roadless Areas and a number of areas of concern, such as Kuiu 

Island, removed from the suitable land base. The potential effects of the proposed alternatives on fish 

and wildlife populations are evaluated in the Fish and Wildlife sections in the EIS. 

Comment: Some felt that the Tongass would be better to emphasis recreation use rather than 

timber harvest. One comment noted that the Forest Service should manage the land base to meet 

recreation demand. 

Response: The Final EIS shows that recreation is a large and growing use of the Forest. Each 

alternative allows for this trend to continue. The existing and Proposed Forest Plans provide 

management direction for the Forest as a whole. The Forest-wide Recreation and Tourism Standards 

and Guidelines provide recreation and integrated resource planning direction. This includes direction for 

land managers to identify opportunities to enhance existing, and provide additional, recreation activities, 

opportunities, and services where desirable to meet local or Forest-wide recreation demands. 

The Forest Service uses the ROS system to inventory existing and potential recreation opportunities on 

the Forest. The Recreation and Tourism section in the EIS assesses the potential impacts of the 

proposed alternatives on recreation and tourism in terms of ROS settings and identified recreation places. 

Comment: One respondent stated that local tourism businesses should be permitted to use the 

forest rather than businesses associated with cruise ships where the same service is being 

offered. Another comment encouraged the Forest Service to give priority to small businesses 

offering recreation opportunities on the Tongass because large-scale tourism related to increased 

cruise ship activity can be very difficult to manage and large scale users tend to drive out smaller 

business users. 

Response: The Proposed Forest Plan provides broad strategic direction for Forest-wide management 

with respect to Recreation and Tourism and special use permits. Forest-wide direction for public 

outfitter/guide services is identified in Section 4 of the Final Proposed Forest Plan in the section that 

addresses Recreation and Tourism. In general, the services of outfitter/guides should facilitate use, 

enjoyment, understanding, and appreciation of National Forest recreation settings. The Final Proposed 

Forest Plan direction does not specify that local businesses should be given preference over cruise shiprelated activities or that small users should be given preference over large (cruise ship-related) users. 
Appendix H

Final EIS H-89 Comments and Responses

Potential permit holders are evaluated on a case-by-case basis through the special use permitting 

process, which generally does not allow for a business size preference. 

Comment: Concern was expressed that the Wilderness direction was being changed to 

discourage dispersed recreation use in pristine areas as a way to resolve conflicts in areas of 

concentrated use. 

Response: The intent of this direction is to maintain the solitude found in pristine areas. The first choice 

for resolving conflicts in areas of concentrated use would be to relocate that use to areas outside the 

wilderness boundary. 

Comment: One comment noted that the Proposed Forest Plan’s Recreation and Tourism 

Standards and Guidelines acknowledge that commercial tourism may conflict with local residents 

use of the same area, but do not require the Forest Service to consider the off-site impacts of 

activities permitted on NFS lands. The comment notes that the Forest Plan should provide an 

adequate framework to protect local residents and nonmotorized recreationists from commercial 

recreation–related noise. The Recreation and Tourism Standards and Guidelines should clearly 

state that “one consideration to be weighed by the Forest Service in promoting additional 

commercial tourism use of the Forest is the impact such increased activity could have on Juneau 

or other similarly situated communities.” The comment also stated that “natural quiet” should be 

identified as a forest value or resource. 

Response: The Forest Service believes that the Final EIS and Final Proposed Forest Plan adequately 

recognize that noise associated with commercial and other motorized recreation can have detrimental 

effects on other Forest users, as well as on surrounding communities. Although not explicitly spelled out 

in the Final Proposed Forest Plan in the way suggested in the comment, the potential noise impacts 

associated with commercial tourism use are an important element of project-specific evaluations. 

Comment: One comment expressed concern about a proposed LUD change that would occur 

north of Juneau under all of the action alternatives. This change would be from Remote 

Recreation to Semi-Remote Recreation. The comment noted that this area includes the Herbert 

Glacier and Eagle Glacier recreation areas, among others. The comment also noted that the 

rationale for this proposed change is not explained in the Draft EIS and was concerned that the 

change is proposed to allow an expansion of helicopter landing sites in the area. Any changes to 

helicopter operations on the Juneau Icefield should be part of a separate action, as they were in 

2002. 

Response: The snow accumulation zone on the Juneau Icefield has retreated to higher elevations 

perhaps as a result of climate change. This has rendered a number of minor development sites (e.g. dog 

sled camps) unsuitable for use as the thinning snow layers expose crevasses during the middle of the 

operating season. This hazard requires removal of the camps to a more suitable location, generally 

higher in elevation where there is more snow. The Remote Recreation LUD does not allow development 

of minor developments, like dog sled camps, while the Semi-Remote Recreation LUD would allow 

consideration of this type of use. 

This change in the LUD boundaries would allow the Forest Service to consider moving minor 

developments into areas where standards and guidelines for the previous LUD would not have allowed 

this use. It should be noted that this change in LUD boundaries would not affect the Forest Service’s 

ability to allow an expansion of helicopter landing sites in this area, because glacier landing tours are 

allowed in both the Remote Recreation LUD and Semi-Remote Recreation LUD under the current and 

Proposed Forest Plans. This explanation has been added to the Recreation and Tourism section of the 

Final EIS. 
Appendix H 

Comments and Responses H-90 Final EIS 

The 2002 ROD for the Helicopter Landing Tours on the Juneau Icefield will be reviewed for consistency 

with this Amendment, but any changes to the 2002 ROD would have to be made in compliance with 

applicable NEPA regulations and Forest Service policy. 

Comment: Some respondents expressed concern regarding the impacts of timber harvest on 

scenic resources and ultimately on the tourism/visitor industry. They urged that this be a major 

consideration in the decision making process. 

Response: The Final EIS discloses the potential impacts of timber harvesting on scenic resources (see 

the Scenery section). This was a major consideration in the design of alternatives. Even Alternative 7, 

with the highest amount of timber harvest, was designed to protect key seen areas. The basic scenery 

management information, including seen and unseen areas from high visitation sites, was updated as 

part of this analysis. 

Comment: One respondent noted that while they had heard stories that tourists on cruise ships 

do not notice clearcuts, this was not the case with the passengers who traveled on the boats they 

operate on the Tongass under a special use permit. The respondent noted that they receive lots 

of comments from customers concerned about clearcuts. 

Response: As part of the Forest Plan Amendment process, the Forest Service has updated the Seen 

Area analysis and Visual Priority Routes and Use Areas for the Tongass (see Appendix F of the Final 

Proposed Forest Plan). Scenery is emphasized from these areas. Please note that many of the 

clearcuts visible from ships are on non-NFS lands. 

It seems reasonable to assume that timber harvest may be more visible from some locations than others 

and that some visitors are more sensitive to the visual evidence of clearcut or other harvesting than 

others are. The potential impacts to Visual Priority Routes and Use Areas are evaluated for each 

alternative in the Scenery section of the EIS. In addition, site-specific visual analysis is conducted at the 

project-level for all projects. 

Roadless Areas and Wilderness 

Comment: One respondent felt that the method to map and delineate Inventoried Roadless Areas 

(pg 3-357 of the Draft EIS) was illogical as it failed to recognize the difference between pristine 

roadless watersheds and parts of developed watersheds that do not have roads. 

Response: The process for defining and mapping Inventoried Roadless Areas has been established for 

many years and was used in the 2003 SEIS. The Forest Service recognizes the potential difference in 

value between roadless areas and this is reflected in our alternative development and analysis. There is 

no policy that would have us not consider areas as roadless just because they happen to be in a 

watershed that has some level of past management activity. 

Comment: Several comments suggested that the Proposed Forest Plan eliminate the roadless 

area designation. 

Response: This is beyond the scope of this Forest Plan Amendment. The identification of roadless 

areas and their use as an inventory is well established in Forest Service policy. Management of these 

areas is a significant issue that must be addressed. 

Comment: Many respondents asked that roadless areas be protected (from timber harvest, oil 

and gas development, and road building). Some specified that all roadless areas be protected, 
Appendix H

Final EIS H-91 Comments and Responses

while others were very broad in just saying the Tongass needed to be protected. Some listed 

specific “special areas” they wanted protected. Many asked for wilderness designation for these 

areas. One comment stated that the alternatives should include recommendations for additional 

Wilderness. 

Response: Management of Inventoried Roadless Areas was one of the three key issues used to 

develop alternatives. Alternatives were designed to meet different levels of timber output while limiting 

entry into roadless areas. In each case, the more sensitive, higher value roadless areas were avoided as 

much as possible. In addition, Alternative 1 was modified in the Final EIS to ensure that all Inventoried 

Roadless Areas are outside the land base designated suitable for timber harvest. As the timber output 

level increases in the other alternatives, roadless areas were added to the suitable land base as 

necessary, starting with those within logical extensions of the current road system working up to higher 

valued roadless areas necessary to achieve the higher timber output levels in Alternatives 4 and 7. 

Consideration of wilderness designation was outside the scope of this analysis. Recommendations for 

adding wilderness to the Tongass National Forest were evaluated in the 2003 SEIS (USDA Forest 

Service 2003). It was concluded that such recommendations were not needed because there was no 

compelling need for additional wilderness on the Tongass at that time. This decision was reviewed as 

part of this EIS process to ascertain if that conclusion is still valid today. 

Comment: Several respondents felt that the National Roadless Rule should be reinstated to apply 

to the Tongass. 

Response: While the application of a national policy is beyond the scope of this analysis, Alternative 1 

has been modified to exclude timber harvest and road building from Inventoried Roadless Areas. 

Comment: One respondent felt that the Draft EIS treated Designated Wilderness and Inventoried 

Roadless Areas as if they were the same, even though they are clearly different. 

Response: The Forest Service recognizes the significant difference in management options between 

Wilderness and roadless areas. Wilderness has its own LUD while roadless areas are allocated to 

various LUDs depending upon the alternative. While management options are clearly different, these 

areas are viewed similarly in terms of current wildlife habitat and biodiversity analysis. They both provide 

unroaded, unmodified habitat that is valuable for some species. 

Comment: One comment recommended that 66 Tongass rivers be designated as Wild and Scenic 

Rivers in accordance with the proposal prepared by the Southeast Alaska Conservation Council 

and the Tongass Rivers Coalition: Tongass Rivers: the Lifeblood of the Rainforest (“Citizens’ 

Proposal”). The comment noted that these rivers and those proposed as Wild and Scenic in the 

current plan should have 0.5-mile (rather than 0.25-mile) buffers to protect their outstanding 

values. The same comment also expressed support for the Wild and Scenic rivers proposed in 

the 1997 ROD to be designated as such. Where there is conflict between the classifications in the 

1997 ROD and the “Citizens’ Proposal” the comment author requested that the “Citizens’ 

Proposal” take precedent. 

Response: Wild and Scenic River designations are made by Congress and are outside the scope of this 

Amendment. The 1997 Forest Plan ROD recommended to the Chief of the Forest Service over 30 rivers 

and lake systems be forwarded to Congress for designation. The current list of recommended river 

systems is not being considered for change in this Amendment. 
Appendix H 

Comments and Responses H-92 Final EIS 

Subsistence 

Comment: Some respondents stated that hunting and fishing access are provided for all user 

groups and felt that the implication that roads have negative impacts on hunting is incorrect. 

Response: The EIS states that under ANILCA, only rural Alaska residents qualify for subsistence 

hunting and fishing on federal lands. The Final Proposed Forest Plan directs the Forest to “maintain 

reasonable access to subsistence resources as required by ANILCA, Section 811 and to address 

subsistence concerns when developing road management objectives for forest roads” (SUB-1, I). The 

Final EIS states that road networks provide greater access to areas previously unconnected and can 

affect subsistence both positively and negatively by providing access, dispersing hunting and fishing 

pressure, and creating the potential for increased competition. 

Comment: Some comments stated that timber harvest near towns has forced subsistence users 

(i.e., spruce root basket weavers, deer hunters) to move further out. They believe that debris and 

felled trees in harvest areas have negative effects on hunting. 

Response: The EIS looked at the likely effects of the different alternatives on subsistence resources in 

two parts: effects on subsistence resources and uses important to each rural community and overall, on a 

Forest-wide basis, based on general considerations of effect in terms of abundance and distribution, 

access, and competition. The 1997 Forest Plan EIS included discussions of 32 Southeast Alaska 

communities with a state land-selection base. This EIS provides brief updates of the affected 

environment section of the community discussions, where applicable. Each community assessment 

provides potential effects by Community Use Area, Economy, and Subsistence. The Final Proposed 

Forest Plan contains Forest-wide standards and guidelines; for example, directing the Forest to locate 

and manage Forest management activities that consider impacts upon rural residents who depend upon 

subsistence uses of the resources of the NFS lands. 

Comment: It is important to some respondents that the Forest Service ensure that fish and 

wildlife resources do not “reach a point where continued levels of harvest would jeopardize stock 

to unsustainable levels and result in use-priority restrictions.” 

Response: With regard to this Proposed Forest Plan, deer is the only subsistence resource that is 

potentially significantly affected by any of the alternatives. The EIS discusses the potential effects on 

subsistence by alternative and within the individual community assessment discussions, as appropriate. 

Different alternatives may result in a significant restriction of the subsistence uses of deer, due to 

potential effects on abundance and distribution, and on competition. However, the Subsistence, Fish, 

and Wildlife Forest-wide standards and guidelines are designed to help ensure that fish and wildlife 

resources do not reach a point where continued levels of harvest would jeopardize stocks to 

unsustainable levels and result in use-priority restrictions. The Forest Service will seek to maintain 

abundance and distribution of subsistence resources necessary to meet subsistence user needs. The 

Forest Service will also continue to consult with the Southeast Alaska Federal Subsistence Board. If, for 

some reason, population levels drop to where restrictions in use need to occur (i.e., severe winter such as 

occurred in 2006/07) the Forest Service would follow the regulatory process, working with the Federal 

Subsistence Board. 

Comment: A number of comment stated that the Final EIS should take a closer look at the 

cumulative effects of past, present, and future logging on deer and other subsistence resources 

on Prince of Wales Island. Comments also stated that the Forest Service should consider 

changing LUD assignments in places like Craig or Hydaburg that are surrounded by lots of private 

and public logging. 
Appendix H

Final EIS H-93 Comments and Responses

Response: The Forest did take a good look at the cumulative effects of past, present, and future 

management on deer and other subsistence resources on Prince of Wales Island. Specific to Prince of 

Wales Island, the EIS assessed the potential impacts for Coffman Cove, Craig, Edna Bay, Hollis, 

Hydaburg, Kasaan, Klawock, Naukati, Point Baker, Port Protection, Thorne Bay and Whale Pass in the 

Communities subsection of the Subregional Overview and Communities section. Summary tables are 

provided for each community, comparing the acres allocated to types of LUD group by alternative. For 

example, LUD groups in Coffman Cove’s community use area (1,228,786 acres total) would range from: 

wilderness – 122,719 acres; mostly natural – 758,086 acres, moderate development – 98,294 acres, 

intensive development 249,686 acres under Alternative 1 to wilderness – 122,719 acres, mostly natural – 

218,709 acres, moderate development – 340,708 acres, intensive management – 546,652 acres under 

Alternative 7. A summary is provided of the potential impacts on subsistence resources by alternative for 

each of the community use area. If, as time goes on, it looks like a change of LUD is necessary, the 

Forest would follow its standard amendment process for the Forest Plan. 

Comment: Some comments stated that Forest Service roads open up subsistence areas to 

outside use which often has a negative impact on local users and resource sustainability. They 

would like the Forest Service to study the effect that building roads adjacent to sensitive 

subsistence areas has on subsistence resources. Another comment said the Final EIS needs to 

address the effects of competition on subsistence use. 

Response: The Forest has looked at the potential impacts or effects of road building on subsistence 

resources, areas, and users. The Forest acknowledges in the EIS that road networks provide greater 

access to areas previously unconnected and can affect subsistence both positively and negatively by 

providing access, dispersing hunting and fishing pressure, and creating the potential for increased 

competition. Monitoring and evaluation of wildlife, fish, and subsistence comprise an essential feedback 

mechanism within an adaptive management framework to keep the Plan dynamic and responsive to 

changing conditions. Monitoring population trends and their relationship to habitat changes for 

management indicator species (MIS) (a lot of which are subsistence species), as well as analyzing if the 

effects of management actions on subsistence users in rural Southeast Alaska communities are 

consistent with those estimated in the Final Proposed Forest Plan, will provide information to be used to 

determine whether changes in management direction are needed. Thus, the Forest is studying the effect 

that building roads adjacent to subsistence areas might have on subsistence resources and will work with 

the appropriate state agencies, local communities, the Southeast Alaska Federal Subsistence Regional 

Advisory Council, and State Fish and Game Advisory Committees to analyze potential changes. 

The EIS does address competition on subsistence use. Competition for the more abundant wildlife and 

fisheries resources near rural communities results from a combination of factors. Examples include fish 

and game regulations, mobility, and the natural distribution of game species across the Tongass, 

decreases in resource populations because of habitat reductions, decreases in resource populations 

because of over-harvest, and access provided to rural communities in the form of roads, ferries, and 

commercial air carriers. Specific assumptions were used to analyze competition in the 1997 Forest Plan 

Revision Final EIS, which concluded that implementation of Alternative 11 (the selected alternative) would 

result in a significant possibility of a significant restriction of subsistence use by increasing competition for 

some subsistence resources by non-rural, as well as rural residents. The possibility of a significant 

restriction, resulting from a change in competition, would be the same as or less than the possibility under 

Alternative 11 of the 1997 Forest Plan Final EIS for Alternatives 5 and 6 evaluated in this EIS. There 

would be a relative reduction in risk under Alternatives 1, 2, and 3, and an increase in risk under 

Alternative 4 and especially under Alternative 7. 

Comment: There was a concern shared by some respondents that the non-subsistence areas 

associated with the borough of Juneau will grow as their borough boundary grows. 

Response: This concern is beyond the scope of this planning effort. However, if the borough of Juneau 

were to grow, there should not be a change to outlying communities with regard to rural versus non-rural 
Appendix H 

Comments and Responses H-94 Final EIS 

designation. The Federal Subsistence Board will determine if an area or community in Alaska is rural, not 

the Forest Service. In determining whether a specific area of Alaska is rural, the Board shall use the 

guidelines provided in 50 CFR Part 100. 

Comment: Some respondents from various communities believe the Proposed Forest Plan needs 

to include a section that better protects specific fish and wildlife stocks for subsistence purposes. 

They state that these are areas of concern that have developed over the past few years with 

respect to the State’s ability to continue management of ‘subsistence resources’ and affect the 

people of these communities on the Tongass. 

Response: While many of the areas identified by respondents are specific sites that are important to the 

subsistence users of particular communities, the Forest-wide standards and guidelines for Subsistence, 

Wildlife, and Fish are in place to protect fish and wildlife resources for subsistence purposes, across the 

Forest. The Forest will seek to maintain abundance and distribution of subsistence resources necessary 

to meet subsistence user needs. Monitoring population trends and their relationship to habitat changes 

for MIS (a lot of which are subsistence species), as well as analyzing if the effects of management actions 

on subsistence users in rural Southeast Alaska communities are consistent with those estimated in the 

Final Proposed Forest Plan, will provide information to be used to determine whether changes in 

management direction are needed. The Forest will continue to work with the appropriate state agencies, 

local communities, the Southeast Alaska Federal Subsistence Regional Advisory Council, and State Fish 

and Game Advisory Committees to analyze if changes need to occur with regard to specific fish 

populations and management activities. A proposal would then go to the Federal Subsistence Board for 

a determination. 

Comment: Some respondents believe the Proposed Forest Plan needs to plan and provide for 

deer populations for subsistence and that the current deer models are weak or not applicable to 

large-scale, landscape-level analysis involving landscape patterns, such as sizes and location and 

timber stands. 

Response: The Forest will seek to maintain abundance and distribution of subsistence resources 

necessary to meet subsistence user needs. Subsistence use is addressed specifically in Forest-wide 

standards and guidelines and subsistence resources are covered by the Forest-wide standards and 

guidelines for fish, wildlife, and riparian areas and biodiversity, among others. Fish and wildlife habitat 

productivity would be maintained at the highest level possible under all alternatives, consistent with the 

overall multiple-use goals of the current Forest Plan, with improved protection under the Final Proposed 

Forest Plan. In addition, each of the Forest LUDs contains direction to follow the Forest-wide standards 

and guidelines for Subsistence. The potential effects of the alternatives on wildlife productivity are 

discussed in more detail in the Wildlife section of the EIS. The deer model used for the Plan is a tool, 

used to evaluate the relative differences among alternatives in the context of a risk assessment. The 

Forest acknowledges that there are weaknesses or limitations in the use of this model when applied at 

the watershed or project planning level. It is however, the most appropriate tool for analysis over large 

planning areas such as the entire Tongass National Forest or at the scale of a watershed analysis area 

(WAA). Specific concerns raised with respect to the deer model are addressed in the Wildlife, 

Biodiversity and Plants section of this appendix under Deer.

Comment: One comment stated that a decline in old-growth forest wildlife habitat capability due 

to timber harvest on Native Corporation, Tongass, and other lands does not translate into reduced 

abundance of deer or other subsistence resources. 

Response: The potential effects of the alternatives on wildlife productivity are discussed in more detail in 

the Wildlife section of the EIS. While it’s true that after the initial years following logging, there is a rapid 

increase in deer forage production about 20 to 30 years after harvest, the vigorously growing hemlock 

and spruce shade out the understory forage during the next 100- to 150-year period. However, as stated 
Appendix H

Final EIS H-95 Comments and Responses

in the EIS, it is important to note that forest management on the Tongass has produced more forage than 

assumed by the deer model, through the management of second growth stands. The Forest is looking at 

young-growth management (in cooperation with the PNW Research Station) to evaluate the potential 

benefits of treating pre-commercial stands to increase wildlife habitat and wood production. There are 

still many uncertainties related to appropriate young-growth treatment designs, specific beneficial effects 

of such treatments, and the implications for deer. Initial results are looking promising. However, when 

comparing alternatives for this EIS, Alternative 7 would not include OGR and would have the largest 

potential long-term effects on the availability of deer for subsistence purposes. 

Comment: Some felt that the Draft EIS does not adequately recognize the importance of 

subsistence use taking place on the Tongass National Forest, does not provide sufficient 

protection for this use, and does not provide enough information to evaluate the foreseeable 

effects of proposed timber management and increased levels of tourism and non-subsistence 

consumptive use. 

Response: The Forest does recognize the importance of subsistence use taking place on the Forest. 

There are specific Forest-wide standards and guidelines related to subsistence. Other Forest-wide 

standards and guidelines, such as for fish, wildlife, and riparian, provide for species habitat planning and 

protection, which benefit subsistence species and resources. The Forest will continue to work with the 

appropriate state agencies, local communities, the Southeast Alaska Federal Subsistence Regional 

Advisory Council, and State Fish and Game Advisory Committees to analyze if changes need to occur 

with regard to a specific subsistence resource and any of the Forest’s management activities. The 

Wildlife section of the EIS provides an in-depth discussion of the potential impacts to subsistence 

resources by alternative. In addition, both the Subsistence and Subregional Overview and Communities

sections of the EIS discuss potential impacts to subsistence, looking at many different factors related to 

Forest management. 

Comment: Some believe that the Proposed Forest Plan should include a subsistence land-use 

designation that would protect the most important subsistence use areas for rural communities. 

The amended Forest Plan should plan for subsistence not just assess the effects of other plan 

activities on subsistence. 

Response: While it’s true that there is not a land-use designation specific to subsistence, subsistence 

resources are important to the Tongass. We think it is better to manage for subsistence on all NFS lands 

rather than designate certain lands to a subsistence LUD. There are Forest-wide standards and 

guidelines set up to protect subsistence resources. Monitoring and evaluation for subsistence is 

designed to make sure that our actions are not negatively impacting subsistence resources. The Forest 

will continue to work in accordance with ANILCA Title VIII. In addition, each of the Forest LUDs contains 

direction to follow the Forest-wide standards and guidelines for subsistence. 

Comment: Some respondents stated that the provision for periodic harvest assessments and 

other studies of subsistence – included in the 1997 Forest Plan – appears to have been dropped 

from the Proposed Forest Plan. 

Response: This provision has not been dropped. The Forest-wide standard for subsistence 1.D states: 

“evaluate changes in subsistence use patterns and activities in cooperation with appropriate state and 

federal agencies by conducting periodic surveys of fish and wildlife populations and subsistence harvest 

and consulting with subsistence user groups.” 

Comment: One respondent stated that “given the importance to the rural economy of subsistence 

hunting, we think impacts on subsistence should be heavily weighted when deciding on an 

alternative. 
Appendix H 

Comments and Responses H-96 Final EIS 

Response: Potential impacts to subsistence resources are one of many factors that will be taken into 

consideration by the deciding official when reviewing the various alternatives. 

Comment: One respondent stated that the Draft EIS needs to show the relative impacts of the 

different alternatives. The alternatives with larger amounts of harvest (Alternatives 4 and 7) would 

result in larger restrictions and that the Draft EIS should also consider the impacts to important 

subsistence use areas as these impacts would have greater effect than impacts to less important 

subsistence areas. 

Response: The Draft does show the relative impacts of the different alternatives. Deer habitat capability 

in 2005 and after 100+ years of full implementation under each alternative (expressed as a percent of the 

1954 habitat capability) is displayed in table form for each of the 32 individual community assessments in 

the Subregional Overview and Communities section of the EIS,. These tables show that deer habitat 

capability would be potentially reduced the most under Alternatives 7 and 4, within the development 

LUDs. These assessments specifically address the potential effects to the WAAs that are most important 

for subsistence for each community based on past deer harvest patterns. 

Comment: A number of respondents commented that the Draft EIS fails to demonstrate that the 

proposed restrictions on subsistence use are necessary, that the proposed harvest would involve 

the minimum amount of land necessary, or how adverse impacts to subsistence uses and 

resources would be minimized. A number of respondents also commented that under ANILCA 

Section 10 three conditions need to be determined by the head of the federal agency before any 

significant restriction on subsistence use may be affected. 

Response: The EIS is not currently proposing a restriction on subsistence use. It states that, “the 1997 

deer analysis was much in line with the earlier...analyses... It indicated that deer habitat capabilities in 

several portions of the Tongass may not be adequate to sustain the current levels of deer harvests, and 

that implementation of any Forest Plan alternative could, therefore, be accompanied by a significant 

possibility of a significant restriction on the abundance and/or distribution of subsistence use of deer.” 

The EIS further states: “Under the alternatives analyzed in this EIS, the possibility of a significant 

restriction, resulting from a change in abundance or distribution, would be the same as or less than the 

possibility under Alternative 11 of the 1997 Forest Plan Revision Final EIS for five of the seven 

alternatives. This risk would, however, likely be higher under Alternatives 4 and 7 because these 

alternatives anticipate a higher level of timber harvest than the current Forest Plan (Alternative 5, No 

Action).” 

An ANILCA Section 810 evaluation and determination is not required for approval of a Forest Plan 

Amendment, which is a programmatic level decision that is not a determination whether to ”withdraw, 

reserve, lease, or otherwise permit the use, occupancy, or disposition” of National Forest land. This EIS 

is part of the Forest Plan Amendment process and, therefore, does not require an ANILCA Section 810 

evaluation and determination. 

Comment: The Tongass National Forest should collaboratively identify local subsistence and 

community use areas on the Tongass and incorporate these areas into an expanded protected 

areas strategy. 

Response: The EIS looked at the likely effects of the different alternatives on subsistence resources in 

two parts – effects on subsistence resources and uses important to each rural community and overall or 

on a Forest-wide basis, based on general considerations of the effects in terms of abundance and 

distribution, access, and competition. The 1997 Forest Plan EIS included discussions of 32 Southeast 

Alaska communities with a state land-selection base. This EIS provides brief updates of the affected 

environment section of the community discussions, where applicable. Each community assessment 

provides potential effects by Community Use Area, Economy, and Subsistence. Each of the Forest LUDs 
Appendix H

Final EIS H-97 Comments and Responses

contains direction to follow the Forest-wide standards and guidelines for subsistence. Additional 

collaboration will occur at the project- or site-specific level for District projects. 

Comment: Alternative 7 is better for subsistence than is portrayed in the Draft EIS. Alternative 7 

would improve subsistence because of better access and timber harvest is much better for deer 

than is indicated in the Draft EIS. 

Response: It may be that actively managed young growth is better deer habitat than the old growth 

based deer model predicts. That is one of the reasons young growth management has more emphasis in 

this Amendment. However, in the absence of a new scientifically based deer model that incorporates the 

ability to better account for differential habitat values, we will continue to use the best scientifically 

defensible information available. Old-growth habitat is still considered to be the highest value habitat for 

deer because of the quality of food in the understory and the high canopy cover, which results in lower 

snow depths on the ground during critical winter periods. 

Comment: One respondent asked for a return of traditional rights to Hydaburg for the area from 

Cape Chacon to the Maurelle Islands. 

Response: It is not clear what the comment means by “return of traditional rights” but changes to 

subsistence regulations are outside the scope of this Forest Plan Amendment. 

Comment: Some respondents shared their opposition to subsistence regulations and their belief 

that the federal government does not have any authority over Indigenous tribes or Indigenous 

people. They talked about their rights as a sovereign nation and their opposition to subsistence 

rights being given to non-native residents. They feel that Indigenous people should have priority 

for use of natural resources. Some felt that the Forest Service should compensate tribes for 

cutting trees or turn over control of resources to tribal governments. 

Response: These are complex legal issues that are outside the scope of this Forest Plan Amendment. 

The Proposed Forest Plan will continue to be consistent with current laws and regulations. 

Comment: Some comments stated that the Draft EIS does not take into account the economic 

value of cultural and other Forest-related tribal activities. 

Response: The comment does not provide any context for this statement or identify the specific values 

that the comment author believes the Draft EIS fails to account for. As a result, it is not possible to 

provide a specific response to these concerns. Other specific concerns raised with respect to 

subsistence and heritage values are addressed in the Subsistence and Heritage sections of this comment 

response volume.

Comment: One respondent was interested in an area being designated for harvest of 500 year old 

cedar trees for totem poles and canoes as well as bark for weaving. They also asked for an area 

for spruce roots for basketry. 

Response: These specific needs should be brought to the attention of the local District Ranger who is in 

the best position to address them at the site-specific level. 

Comment: One comment noted that healthy salmon stocks support commercial, subsistence, and 

recreational fishing activities and have been an important part of the cultural fabric of indigenous 

people of the Tongass for literally thousands of years, as they are in the present day. 
Appendix H 

Comments and Responses H-98 Final EIS 

Response: We agree that healthy salmon populations are an important component of the Tongass 

ecosystem that support many human uses, provide prey for a variety of wildlife species, and act as a 

source of nutrients for the environment. 

Timber 

The Timber comment and response subsection is divided into the following categories: 

• Harvest Methods 

• Old-Growth Timber 

• Young-Growth Timber 

• Alaska Yellow-Cedar 

• Harvest-General 

• Spectrum Model Analysis 

• Timber Sale Economics 

• Timber Supply 

• Allowable Sale Quantity 

• Tongass Futures Roundtable 

• General 

Harvest Methods 

Comment: One comment noted that the Draft EIS did not appear to present information on how 

the timber would be harvested under each alternative. 

Response: The Regeneration Methods subsection of the Timber section discusses harvest methods. 

Table 3.13-9 in the Timber section identifies the projected acres by harvest approach (even-aged, twoaged, uneven-aged) for each alternative. 

Comment: Some respondents requested that the Forest Service concentrate harvest in fewer, 

more-intensively managed areas to avoid entering new watersheds. They noted that applying the 

conservation strategy forces the harvest to be spread over a larger area. Others suggested that 

cutting less efficiently but over more acres would be a greener approach. 

Response: Concentrating harvest in fewer areas and harvesting these areas more intensively would 

reduce the area needed for a given harvest level. However, it could also lead to adverse effects on water 

quality, wildlife, visual quality and other resources in the intensively managed areas. On the other hand, 

cutting fewer trees per acre would disturb more acres of land for the same volume of timber and would 

also require more roads. 

Table 3.13-9 in the Timber section identifies the projected acres by harvest approach (even-aged, twoaged, uneven-aged) for each alternative. All seven proposed alternatives employ a combination of 

harvest approaches with projected harvest levels more concentrated in some areas than others. 

Comment: One respondent believed that trees retained in harvest units should be looked at as an 

investment in non-timber resources and should not be offset by harvesting larger units, 

harvesting more units, or harvesting the retention later. 

Response: The Forest does view the retained trees in harvest units as important for wildlife and does 

not plan to harvest them later. However, one consequence of retaining trees in harvest units is a 

reduction in harvest per acre, which needs to be made up by harvesting more areas in order to meet a 
Appendix H

Final EIS H-99 Comments and Responses

given level of demand. This is the trade off between leaving structure in harvest units as opposed to 

harvesting a smaller area more intensively. 

Comment: One respondent stated that: “The change from removing large volumes of timber from 

concentrated areas using cable yarding systems to scattered small, units has affected sale 

economics and logging systems capabilities.”

Response: Changes to timber sale design and logging systems affect harvest economics as noted in the 

comment. Logging large units, with no stream buffers to break up the unit, is more economical and more 

easily accomplished with cable logging systems. 

Comment: Several comments stated that harvest should be limited to salvage logging or to 

previously disturbed areas with low environmental value, such as unused roads. Another 

comment suggested harvest should be restricted to 40 MMBF per year, the harvest rate between 

1909 and 1950. 

Response: The overall objective of all seven alternatives is to provide a balance between supplying 

enough timber to meet demand while protecting the environment. Limiting harvest to salvage logging 

would not meet projected demand under any of the alternatives. Alternative 1 was revised between the 

Draft and Final EIS documents and restricts harvest to roaded areas only. This alternative has a 

projected ASQ of 49 MMBF per year, which is close to the 40 MMBF identified by the comment author. 

Comment: Some respondents opposed the use of clearcutting as a common harvest method. 

They argued that clearcuts are ugly and have negative impacts on fish and wildlife and tourism. 

Others argued that not clearcutting amounted to high-grading and would not produce healthy 

young stands. 

Response: The alternatives feature a range of potential harvest methods. All alternatives include acres 

scheduled for even-aged harvest, also known as clearcutting (see Table 3.13-9 in the Timber section of 

the Final EIS). Even-aged harvest can be an effective harvest method in many cases because it provides 

regeneration of desired species, effective tree disease control, viable harvest economics, compatibility 

with the use of standard logging systems, and minimizes windthrow problems. The circumstances under 

which clearcutting is practiced on the Tongass are discussed in the Regeneration Harvest Methods 

subsection of the Timber section of the Final EIS. 

Research indicates that stands that regenerate following partial harvest are healthy and provide good 

habitat. Uneven-aged and selective harvest treatments are established forestry practices that, if done 

properly, can produce healthy stands; however, the risk of windthrow and dwarf mistletoe infection is 

higher. This is discussed further in the Timber section of the Final EIS. 

The potential effects of the alternatives on fish, wildlife, and tourism are evaluated in the Fish, Wildlife, 

and Recreation and Tourism sections of the Draft and Final EIS documents. 

Comment: One respondent stated that there are many reasons for clearcutting besides those 

listed in the Draft EIS and provided a brochure the Forest Service produced in 1972 in support of 

this claim. Another comment stated that clearcutting is the only way to harvest on the Tongass 

because thinning spruce-hemlock stands results in wounded trees. 

Response: Timber harvest methods are discussed in the Regeneration Methods subsection of the 

Timber section of the EIS. The brochure from 1972 provides an interesting perspective on the thinking at 

the time. Much additional information has been acquired on forest management in the last 35 years. 
Appendix H 

Comments and Responses H-100 Final EIS 

Contemporary professional forestry practices include a wide range of tools, techniques, and treatment 

methods that are all part of the range of tools available for managing the Tongass. Thinning can result in 

tree wounds, as noted in the comment; however, research indicates that if done with care, thinning can 

be successful. This is discussed further in the Timber section of the Final EIS. 

Comment: One respondent stated that two-aged stands are just clearcuts with a few clumps of 

trees left in the units or along the boundaries. This, they argue, still results in an even-aged 

stand.

Response: Timber harvest methods are discussed in the Regeneration Methods subsection of the 

Timber section of the EIS. Harvest methods on the Tongass include three broad groups of methods: 

even-aged systems, two-aged systems, and uneven-aged systems. Two-aged harvest systems do not 

result in “clearcuts with few clumps of trees.” The description of two-aged harvest has been revised in the 

Final EIS and explains that the intent with a two-aged stand is to leave up to 30 percent of the trees in 

order to create a stand with two age classes. This is often done by specifying a diameter limit, for 

example, leaving all trees between 9 and 18 inches diameter at breast height (dbh). The reserve trees 

provide structural diversity and an older aggregation of trees within the otherwise young-growth stand. 

This system has been used on the Tongass to meet scenery and wildlife objectives. 

It is possible that the comment author is confusing two-aged systems with the clearcut with reserves 

system, which could conceivably be described as “clearcuts with a few clumps of trees left in the units or 

along the boundaries.” Approximately 10 percent of the trees are left in these units but the intent is an 

even-aged stand. This is discussed further in the Regeneration Methods subsection of the Timber

section of the EIS. 

Comment: Some comments stated that logging practices should be limited to selective cutting. 

High quality trees should be used for structural timbers not chips or pulp. 

Response: High quality logs are used for lumber not chips or pulp. It is the low-quality logs and the 

outer portions of the other logs that are used for chips (see Figure 3.13-2 in the Timber section in the 

Final EIS). There are a number of advantages to selective cutting, described here as two-aged and 

uneven-aged harvest, such as less potential impact on wildlife habitat and scenery. There are also some 

drawbacks, more acres must be disturbed for a given volume of wood compared to even-aged harvest 

(clearcuts and clearcuts with reserves), more roads are typically needed, and there are some concerns 

with respect to windthrow and logging damage to the remaining trees. 

Additional information on selective harvest has been added to the Timber section of Final EIS. All seven 

proposed alternatives employ a combination of harvest approaches with projected harvest levels more 

concentrated in some areas than others. 

Comment: One comment stated that: “Eliminating clearcutting would reduce, though not 

eliminate, the need to deal with low grade utility logs.” 

Response: Low grade utility logs would be included in harvest units under all three of the broad groups 

of harvest methods (even-aged, two-aged, and uneven-aged) proposed under each alternative. 

Eliminating even-aged systems or clearcutting would not substantially reduce the utility log component of 

potential timber sales. Selectively logging only the high-quality trees could reduce the amount of utility 

logs harvested. This practice is often referred to as “high grading” and In the long run this approach may 

not result in healthy forests if only the best and healthiest trees are removed leaving the rest to 

reproduce. This type of selective cutting also requires more road building and more frequent entries for 

an equal amount of volume. 
Appendix H

Final EIS H-101 Comments and Responses

Comment: Concern was expressed that leaving low grade logs in the woods wastes resources 

and harms wildlife. 

Response: Timber sale purchasers are only allowed to leave utility grade logs in the woods. Utility 

grade logs cannot be sawn into lumber due to rot and other problems. While the Forest tries to utilize low 

value logs, those left in the woods often provide habitat for many species for extended periods of time. 

The effects of leaving low value logs in the woods are evaluated for all potentially affected resources, 

including wildlife, at the project level. 

The recently approved Limited Interstate Shipment Policy (March 2007) is expected to increase the 

utilization of timber harvested on the Tongass and improve the economics of timber sales by providing a 

market for smaller diameter and low grade material that cannot be processed profitably by sawmills in 

Southeast Alaska. This is discussed further in the Economic and Social Environment section of the Final 

EIS. 

Comment: Concern was expressed that helicopter logging is too expensive to be practical. One 

comment suggested that helicopter logging can result in “high-grading” because of the high cost 

of removing lower value material. Others recommended helicopter logging as the best method. 

Response: Helicopter logging is generally more expensive than cable logging. Many areas of the Forest 

are too costly to harvest with a helicopter. Some high-value stands with short yarding distances may be 

economical, depending on fuel costs and timber values. Helicopter yarding generally has less 

environmental impact than other methods and is often prescribed as a harvest method to protect resource 

values by reducing disturbance on the ground. 

Comment: One comment expressed concern that the Draft EIS assumes that “timber stands of 

varying volume will be (logged) proportionate to their occurrence within biogeographic provinces 

or ecological subsections,” but there is nothing in the Proposed Forest Plan that requires this 

distribution or prevents “high-grading.” The comment argues that the Final EIS, therefore, needs 

to explicitly evaluate the potential effects of “high-grading” in the Environmental Consequences 

analyses. The comment notes that this practice results in unsustainable harvest levels and has 

detrimental effects on the environment, including wildlife. 

Response: The potential environmental impacts are assessed based on the projected ASQ. Modeling 

indicates that all of the alternatives would harvest the suitable land base at a sustainable level, as 

discussed in the Timber section of the EIS. 

Actual harvest is likely to be lower than the projected ASQ and actual volumes harvested under any of the 

alternatives may be affected by a range of different factors that are difficult to predict at this point. It is 

important to remember that the Forest Plan does not authorize any ground disturbing activities or create 

any environmental consequences. The main function of the Final EIS is to compare and contrast 

alternatives in a general way using broad projections based on full implementation of each alternative. 

With that in mind, the ASQ represents the maximum allowable timber harvest under each alternative and 

allows an appropriate and consistent comparison between alternatives. This essentially represents a 

worse-case approach that ensures that the potential effects of each alternative are fully accounted for. 

Also, the OGRs proposed in most watersheds contain high-value forests which have been set aside for 

wildlife habitat and legacy standards apply to VCUs that have high levels of harvest. This is discussed 

further in the Wildlife section in the EIS. 

More detail on the proposed harvest methods is provided in the Regeneration Methods subsection of the 

Timber section of the Final EIS. Table 3.13-9 in the Timber section identifies the projected acres by 

harvest approach (even-aged, two-aged, uneven-aged) for each alternative. 
Appendix H 

Comments and Responses H-102 Final EIS 

Old-Growth Timber 

Comment: Some respondents disagreed with the statement under Key Issue 3 (page 1-7 in the 

Draft EIS) that big tree old growth has been disproportionately harvested. They assert that big 

tree old growth is well distributed across the Tongass. 

One comment pointed out that pulp companies were not seeking big trees and provided a graph 

that showed the size distribution of spruce trees harvested by the Ketchikan Pulp Corporation 

during selected years in the 1980s and 1990s. The comment also noted that the average tree 

harvested in the 1980s and 1990s was 10 inches in diameter.

Response: The text on page 1-7 in the Draft EIS states that: “Although less than 10 percent of the POG 

habitats on the Tongass have been converted to second growth, this percentage is much higher for 

certain types of old growth, such as lowland and big tree old growth.” This statement is consistent with 

our experience on the ground and supported by the GIS analyses conducted in support of this Forest 

Plan Amendment EIS. 

Comment: Some comments pointed out that the amount of old-growth harvest under any of the 

alternatives is very low and argued that this suggests that claims that the forest had been overharvested are untrue. Some suggested that we either revise Table 2-16 on page 2-41 of the Draft 

EIS to show that even under Alternative 7 approximately 76 percent of the POG remains or 

discuss this in the text. 

Response: Low is a relative term. To some, harvesting 20 percent of the old growth is a very high 

amount, while to others it is very low. Table 2-16 in the Draft EIS summarizes the key components of 

each alternative with specific reference to the conservation strategy. The amount of POG remaining 

under each alternative is identified in Table 2-17 on the following page in the Draft EIS. 

Comment: Concern was expressed that most—with some citing as much as 96 percent—of the 

old growth forest has been cut and argued that the remaining old growth should be protected. 

Response: This is not correct. Over 90 percent of the old-growth forest that existed on the Tongass 100 

years ago still remains. Even under Alternative 7, more than 75 percent would remain after another 100 

years of harvest. 

Young-Growth Timber 

Comment: Support was expressed for the Tongass to transition to a second-growth (younggrowth) timber program. Some felt that the alternatives did not adequately develop this concept 

and the Draft Plan did not display a plan for managing young growth. Some felt that only second 

growth forest should be cut.

Response: Additional analysis has been done for the Final EIS to examine the potential for a greater 

reliance on young-growth timber. In general, projections show young growth becoming a major 

component of timber harvest in about 30 years and being the majority of timber harvested in 60 years. 

The Final Proposed Forest Plan has been modified to place greater emphasis on moving in this direction 

more quickly. While there are opportunities to both improve wildlife habitat and produce timber by 

thinning young stands that have reached commercial size, it will take time for these stands to reach 

commercial size as most young forests on the Tongass are less than 50 years old. 
Appendix H

Final EIS H-103 Comments and Responses

Comment: Some comments stated that accelerated harvest of young stands may require 

changing national policy and Tongass regulations to allow stands of young trees to be cut before 

they reach the culmination of mean annual increment (CMAI) of growth. 

Response: It does not appear that CMAI is a constraint to harvesting young-growth stands. The 

benchmark analysis conducted for this Forest Plan Amendment shows little effect by removing this 

constraint. Without thinning, stands can be regenerated as young as 70 years of age. They can be 

commercially thinned as early as 40 years. In any case, changing the National Forest Management Act 

to permit stands to be harvested before they reach 95 percent of CMAI would require an act of Congress 

and is beyond the scope of this analysis. 

Comment: Some respondents strongly support converting to young-growth management but 

recognize that it will be many years before stands are old enough. They believe that the rotation 

age should be 90 years not 160 years for young-growth stands. They believe that providing 

additional volume may require relaxing standards and guidelines such as selective logging in the 

beach fringe more than 500 feet from the shore and in riparian areas 

Response: Based on Spectrum modeling, the rotation age for young-growth stands on better sites could 

be 60 years without precommercial thinning and 70 years with precommercial thinning. If commercial 

thinning is also implemented, the regeneration period is delayed. This is because thinning of either kind 

reduces the number of trees per acre, which extends the growth period for the remaining trees, which 

also extends the time it takes for them to reach CMAI. The Forest is strongly considering thinning young 

stands in the beach buffer and in other areas set aside for wildlife, in order to improve wildlife habitat 

conditions in these dense stands. Trees cut in these stands in excess of down wood habitat needs would 

be available to mills (this would contribute to available wood supply but not to ASQ). As noted in the Draft 

EIS, young-growth stands generally have much higher volumes and lower defect than old-growth stands. 

We anticipate that the current ASQ could be met entirely from young-growth stands by the latter part of 

this century. 

Comment: One respondent found “The age class information provided is confusing. What is 

apparent is that no second growth will be available for regeneration for at least 30 years. This 

makes it even more important to have a standard that prevents high-grading.” 

Response: The age class information presentation has been revised in the Timber section in the Final 

EIS and the discussion of young-growth management has also been expanded in the Final EIS. There 

are some stands that could be regenerated in this planning period, though not a great deal of volume 

would be generated. Concerns with respect to high grading are discussed in the preceding section. 

Comment: Several comments expressed support for a 200-year rotation with thinning in Scenic 

Viewshed and Modified Landscape LUDs because this is the minimum time needed to produce a 

quality saw log. 

Response: Generally, modeling indicates a rotation of approximately 170 years for Scenic Viewshed; 

however, it may be longer in some areas, depending on site quality and stand management. Areas in the 

far north of the Tongass may require longer rotation periods to reach commercial size. 
Appendix H 

Comments and Responses H-104 Final EIS 

Alaska Yellow-Cedar 

Comment: One comment expressed concern about the reported loss of 500,000 acres of yellowcedar on the Tongass, which the comment author believed might be the result of climate change. 

The comment states that this offers an opportunity to salvage log dead and dying yellow-cedar 

instead of continuing to log healthy trees. 

Another comment stated that no more live cedar should be cut and there should be no more 

salvage of cedar until studies show that cutting these dead trees is “sound science.” Another 

comment argued that the Tongass mismanages yellow cedar and does not take into account its 

present ecological troubles. This comment also requested that the Proposed Forest Plan include 

a special section devoted to the careful management of this species. 

Response: The EIS recognizes that the decline and mortality of yellow-cedar is one of the most 

widespread and important forest health problems in Southeast Alaska (refer to the Forest Health section). 

This decline is associated with wet, poorly drained sites, and research suggests that reduced snow pack 

in low-elevation areas associated with a warming trend that started in the 1800s has exposed fine surface 

roots to freezing, which in turn kills trees. As the climate continues to warm, yellow-cedar decline is likely 

to continue to spread, especially in the south and east. Conversely, yellow-cedar appears to be 

spreading northward as climate warms, into areas that retain snow longer into the spring. 

Salvage logging of yellow-cedar is permitted under the current and Proposed Forest Plans. Harvest of 

healthy yellow-cedar is also permitted and is expected to occur under all seven alternatives. Cedar has 

been studied for many years. We are not aware of any studies that show harvesting cedar is more or 

less problematic than harvesting spruce or hemlock. 

Harvest-General 

Comment: Many respondents stated their opposition to logging. Some were opposed to all 

logging, while others were specifically opposed to logging old-growth. Many mentioned wildlife 

habitat protection as the primary reason while others simply said they wanted to protect the 

Tongass. 

Response: The alternatives feature different levels of potential harvest activity which would likely result 

in different configurations of a wood products industry in Southeast Alaska. All of the alternatives feature 

some level of logging to meet the requirements of TTRA to seek to meet market demand for timber. 

Alternative 1 proposes the least old-growth harvest (approximately 1,180 acres per year) and Alternative 

7 the most (approximately 10,000 acres per year). The Final Proposed Forest Plan places greater 

emphasis on harvesting young growth but a complete transition from old growth to young growth is likely 

several decades away. 

Comment - One comment suggested that we not use the word “harvest” when discussing timber 

management activities. The comment author argued that the word was part of a marketing 

campaign to make logging of old growth forest more appealing. 

Response: Timber harvest is a broadly accepted term used in a wide range of academic and 

professional contexts, including forestry texts, research studies, and scientific articles. The term is used 

to describe all forms of logging, not just logging on old growth forests. 

Comment: One comment noted that one of the great things about the Tongass is the natural 

regeneration that follows timber harvest. Others commented that logged areas are slow to grow 

back, and need to be thinned, some twice. Another comment stated that trees in Southeast 

Alaska don’t reproduce as fast as trees in other areas and harvest levels need to reflect this. 
Appendix H

Final EIS H-105 Comments and Responses

Response: The spruce-hemlock forests of Southeast Alaska are among the most productive in the world 

according to Silvicultural Systems for Major Forest Types of the United States (USDA Forest Service, 

1983). Most areas on the Tongass regenerate naturally and very little tree planting is necessary. Most 

young stands need to be thinned to improve growth. Regeneration is generally rapid on the Tongass, 

with tree growth generally faster in the south than in the north. 

Comment: One comment stated that any restrictions on harvesting timber should be based on 

peer-reviewed science. 

Response: Standards and guidelines for timber harvest are based on science and many years of 

experience managing timber harvest on the Tongass. 

Spectrum Model Analysis 

Comment: Some respondents felt that the Forest Service failed to identify the benchmarks it uses 

to determine the range of alternatives. They believe the Forest Service used the benchmarks from 

the 1997 Plan but did not explain how these were used and did not identify: 1) the costs and 

benefits associated with the minimum level of management needed; 2) the maximum physical and 

biological outputs of forest resources and the associated costs and benefits; and 3) the estimates 

of the PNV of forest resources with established market value. 

Response: Benchmark analyses were conducted for the Final EIS to determine the minimum and 

maximum physical and biological outputs of forest resources, the maximum PNV of the forest resources 

and the influence of management constraints on outputs of forest resources. These analyses are 

included in the updated AMS included in the planning record. Accordingly, the desired biological outputs 

of the Alternatives are set at feasible levels as determined by the analysis. Information about costs and 

benefits is described in detail in Appendix B of the Tongass National Forest Land Management Plan Final 

EIS. 

Comment: One comment questioned if all withdrawn lands were properly considered in 

determining suitable lands. As an example, they cited land adjacent to the West ChichagofYakobi Island Wilderness that was purchased and should have become part of the Wilderness. 

The comment author noted that both the 2003 SEIS map and the 2007 Draft EIS map show this 

area as semi-primitive recreation instead of Wilderness. 

Response: The area cited in the comment is part of the Wilderness. The mapping error that identifies 

this area as semi-primitive recreation has been corrected in the Final EIS. This area was not included in 

the suitable land base, as maps of the suitable land in the planning record show. Also, as can be seen in 

the alternative maps included with the Draft EIS, this area was not shown as available for harvest in any 

of the alternatives. 

Comment: One respondent had questions about how the timber was modeled. They wanted more 

information about how lands identified as suitable were stratified into categories with similar 

costs and returns; how the level identifiers reflect the costs and returns associated with the 

location of suitable timber in relation to mills, one of the factors possibly contributing to the 1997 

FORPLAN’s overestimate of ASQ; how the agency stratified lands in the Spectrum model; how 

slope stability was factored into any of the 5 analysis areas; how slope stability was considered in 

the “operability analysis”; and whether this “operability analysis” formed the basis for the 

operability in Spectrum. 

The comment also stated that “slope stability should appear in Spectrum as a stratification layer 

not as a constraint because slope divides the land into categories with similar management costs 
Appendix H 

Comments and Responses H-106 Final EIS 

and returns. In addition, the comment stated that the “roaded classification stratification may 

provide stratification for costs associated with transportation. Please explain to what extent this 

stratification accounts for costs associated with access limited areas. Access-limited areas are 

difficult to log because although the timber is operable, the costs associated with accessing and 

transporting logs to a mill cannot be covered by the value of the timber.”

Response: Five unique level identifiers were used to stratify the landscape into Spectrum analysis 

areas. Slope was not used explicitly as a level identifier; rather it was considered in no fewer than three 

of the Spectrum modeling processes. First, lands with slopes greater than 72 percent were classified as 

having “extreme hazard soils” and were removed from the suitable land base (and the model) during the 

suitability analysis (Appendix A-3). Secondly, the logging systems and transportation analysis (LSTA) 

that was used to derive the operability level identifier considered slope indirectly through the road building

necessary to access a stand. If an area could not be accessed by building a road (due to slopes or other 

factors), those analysis areas were assumed to require helicopter or cable logging at a higher cost. 

Finally, the Regulation Class of an analysis area is partially-derived from the slope-driven Visual 

Absorption Capacity (VAC) classification of the land. Regulation classes with lower VAC have more 

management restrictions and higher costs. We are confident that cost differences due to slope have 

been adequately captured in the stratification scheme and suitability analysis of the landscape. 

Distances to mills and appropriate transportation costs are accounted for with the VCU level identifier. 

Analysis areas in VCUs farther from a mill will incur a higher transportation cost. See Appendix B for 

more information. 

Comment: One comment questioned what legal authority allows the Forest Service to build roads 

with public funds in order to make sales sellable and wanted the EIS to explain: the total projected 

“pre-roading” and the locations of these needed roads and their purposes; what these purposes 

are and in what roads analysis this need is documented in; how the contract and management 

costs were included in Spectrum as direct costs against revenues; and requested that the Forest 

Service itemize contract management costs incurred for roads built since 2002.

Response: Funds for road building have been “earmarked” in annual appropriations enacted into law. 

The underlying authority to build roads for National Forest purposes is at 23 United States Code (USC) 

205. 

Pre-roading is a process whereby roads are constructed into a NEPA cleared project area prior to and 

separate from a timber sale or other resource activity. The intent of pre-roading is to develop or expand 

the transportation network without requiring one resource to carry the entire burden of road construction 

costs. Pre-roading is an administrative decision that requires funding from Congress and is subject to the 

same environmental laws and regulations (NEPA, NFMA, etc.) as other Federal actions. This practice is 

best addressed at the project level and is outside the scope of this programmatic EIS. Road contract and 

management costs have not been included in Spectrum as direct costs against revenues 

The Forest Service does not track specific contract management costs on road construction. For 

budgeting purposes there is an estimated cost of about 10 percent of contract costs for administration of 

the contracts. Contract administration costs can vary depending on a number of factors, including but not 

limited to contract size, scope, technical complexity, and logistics. 

Comment: One comment asked: “Where is the standard or guideline in the Plan that prevents 

high grading? Constraining this was clearly modeled in Spectrum but without a companion 

standard in the Forest Plan, what would prevent this from occurring. If it is the NIC 1 and NIC 2 

requirement, is this a standard or a guideline? We are not aware of any language in Section 301 

of TTRA that constrains or prevents this. If it is in the Forest Service Handbook (FSH 2409.18), 

which section prevents this? If it does, we do not consider Forest Service Handbook language a 
Appendix H

Final EIS H-107 Comments and Responses

sufficient protection from high grading considering that the Forest Service can change the 

handbook without public oversight or input.” 

Another comment expressed concern that the most valuable logs on the Tongass are being 

exported without primary processing because it is more profitable to export raw logs than to 

process them in Southeast Alaska. The comment noted that although cedar only comprises a 

small share of commercial forestland on the Tongass, it is the most highly valued species, and 

appears to be driving many Tongass timber projects. Another comment expressed the same 

concern and noted that the industry has been unable to find a market for anything other than the 

highest quality saw timber. 

Response: The Multiple-Use Sustained-Yield Act requires the Forest Service to manage NFS lands in a 

sustainable manner. This direction is reflected in the goals and the desired condition for the Timber 

Production LUD on page 3-127 of the Proposed Forest Plan. Cedar occurs as a minor tree species in 

most stands. The comment that cedar is driving many Tongass timber sale projects is not supported by 

historical data. 

Comment: One respondent asked how exactly was each constraint defined in Spectrum and were 

they defined and used in the same way for each alternative?

Response: Constraints, or limitations on management activities to motivate the model to achieve desired 

conditions, are complex in definition, function and application. Appendix B has been updated to more 

clearly address these questions. In general, constraints can be classified into four categories: 

Stand-level exogenous constraints: These constraints are applied before the Spectrum model is built. 

They are generally applied by evaluating the entire suite of potential management prescriptions available 

to a stand and only giving the model a choice between those prescriptions that may make the most sense 

to apply on the ground. These are derived by the forest silviculturist and other specialists. 

Stand-level endogenous constraints: These are typically accounting constraints applied to each stand to 

ensure that all acres are assigned a management prescription and that no more than the available acres 

of a stand get assigned to a management prescription. These are part of a standard model formulation. 

Forest-level exogenous constraints: The suitability analysis used to identify potentially-manageable acres 

is an example of this type of constraint; typically a National Forest is not able to manage all acres within 

the Forest, and unsuitable acres on the Tongass were not included in the Spectrum model. 

Forest-level endogenous constraints: Generally, the forest-level endogenous constraints are the ones 

generically referred to as “Spectrum constraints” or simply “constraints”. They are often the most dynamic 

of the four constraint types, as the other three are usually static by the time the Spectrum model is run. 

Each Alternative used a unique set of forest-level endogenous constraints, although there were some that 

were standard and did not need to be modified between alternatives. Appendix B describes these 

constraints in more detail and how constraints were applied to the different alternatives. 

Comment: One respondent observed that the Spectrum model has an objective function that 

attempts to maximize present net worth and the present net worth of harvests is embodied in a 

single coefficient: Dij. They asked that we explain in detail how the grouping of analysis areas 

affects the value of Dij and how these coefficients were calculated. 

Response: Dij is the discounted objective function coefficient for stand “i" management regime “j” to 

represent the PNV of that management option. A management regime includes the management 

prescription associated with the stand as it exists today, as well as any and all prescriptions associated 

with stands regenerated in the future. Generalizing the landscape into the analysis areas is a standard 

part of the modeling process necessary to produce a model that can be solved in a reasonable manner. 
Appendix H 

Comments and Responses H-108 Final EIS 

Calculation of Dij is a standard part of the Spectrum model to account for the appropriate revenues and 

costs associated with each management option. Appendix B has been updated to better explain the PNV 

calculation and objective functions used in the model solution process.

Comment: One comment stated that “there is no information on how the management 

prescriptions were mapped for each alternative, nor on the exact methodology, rules, and 

sideboards that would allow for replication of the process with a common outcome. Please 

explain how the management boundaries were determined under each alternative.” 

Response: Table II-16, page 2-41 and the individual alternative descriptions in Chapter 2 of the Final 

EIS show that all the alternatives, except Alternative 2, were based on previously developed alternatives 

in prior analyses. 

Comment: One respondent stated: “The requirements of 36 CFR 219.14(c) were not met. Lands 

that are not cost-efficient should not be suitable. Although Congress decided the Forest Service 

need not consider economic factors in identifying lands not suitable for timber production, this 

does not relieve the Forest Service of disclosing the costs and benefits associated with including 

uneconomical suitable lands in the timber base. The law does not exempt the agency from 

managing the Tongass on a cost-efficient basis. The Forest Service must disclose the results of 

the (corrected) Spectrum analysis as it pertains to cost-efficiency. There are three classes of 

land: 1) lands where agency revenue exceeds agency costs; 2) lands where agency costs exceed 

agency revenue; and 3) lands where logger costs exceed revenues to the logger. Modeling pond 

log values has obscured all of the above.”

Response: The respondent’s assertion that the requirements of 26 CFR 219.14(c) were not met is 

incorrect. The Spectrum model is designed to evaluate a management strategy for cost efficiency. This 

is most commonly addressed by an objective function that maximizes the cumulative PNV of all potential 

management prescriptions on all potentially suitable lands, with the requirement that the desired 

conditions of the forest are met (36 CFR 219.3 “Cost efficiency”). This is exactly the formulation used by 

the Tongass. One of the many desired conditions of the 2007 Tongass plan is to meet and maintain a 

timber demand level consistent with the Alternative being analyzed. In doing so, it may be necessary to 

employ management strategies on some lands where costs of the management activity are greater than 

the benefits realized for the timber under current market conditions. However, since the alternatives were 

evaluated using a linear programming optimization model (Spectrum) with an objective function to 

maximize PNV, the most cost-efficient management scenario is identified for each alternative in 

accordance with 36 CFR 219.14(c)(3). 

The costs and benefits associated with each management prescription identified in the Spectrum model 

solution, while voluminous, are included in the planning record. Stumpage value varies according to 

logging system, distance from the mill, road building requirements, quality of the timber, etc. Recognizing 

all of the potential logger-incurred costs against the pond log value allows for site-specific stumpage 

values to be calculated internally by the Spectrum model in much more detail than a forest-wide 

externally-derived stumpage value. Factors contributing to the stumpage value in the model include the 

positive pond log value (adjusted downward to exclude logger profit and risk) less the logging cost, road 

building and reconstruction costs, felling and bucking costs, camp/commute costs, Log Transfer Facility 

costs, and timber hauling costs (raft, barge and/or road). Agency-incurred costs that are evaluated by the 

Spectrum model but do not contribute to stumpage include sale preparation and administration, 

precommercial thinning, and planting costs. Agency-incurred costs are included as a part of the costefficiency analysis outlined in 36 CFR 219.14(b). See Appendix B for further information on this 

calculation. 

The comment author requested and has been provided with all of the information necessary to calculate 

stumpage value for any Analysis Area of interest. This information is sufficient to allow the comment 

author to identify the three classes of land they note in the comment. 
Appendix H

Final EIS H-109 Comments and Responses

Comment: One respondent asked that the Forest develop a map of lands not suitable for timber 

production to help implementers make sure they are not proposing timber sales in these areas. 

Response: Maps of suitable acres for each alternative are included in the planning record. Suitable 

areas are mapped in a geographic information system (GIS). Lands not identified as “suitable” are 

considered to be not suitable for the purposes of timber sale planning. Further, field work is conducted as 

part of each timber sale planning process to determine if the map of the suitable lands in the project area 

is correct. There are generally features which cannot be detected without a field exam. 

Comment: One comment noted that two aspects of MIRF were not accounted for in the Spectrum 

analysis: the habitat conservation areas (large, medium, and small), which blocks access to 

timber areas, and the legacy standard which requires that 10 to 30 percent of the timber in all 

units be left. As a result, the comment suggests that the modeling constraints significantly under 

estimate the adverse effects of these standards and guidelines.

Response: We believe that the Spectrum model adequately accounts for these factors. See Appendix B 

to the Final EIS for more information on modeling. 

Comment: One comment stated that short-distance helicopter yarding should not be included in 

the NIC I. They believe that the definition of NIC 1 has been redefined from the 1997 Plan. There 

are no documents to the comment author’s knowledge that “demonstrate that this “new” normal 

operability category would be economic under most market conditions.” As a result, NIC I may 

have little relevance to an economic timber supply and the comment author states that Appendix 

B in the Draft EIS needs to be updated to fully describe the modeling process. 

Response: This is not a change. NIC I under the current (1997) plan includes short span helicopter (see 

page 3-280 of the 1997 Final EIS). Appendix B has been revised for this Final EIS to address this and a 

number of other comments raised during the public comment period on the Draft EIS. 

Comment: Analysis of bid price paid for sales of varying sizes from October 1, 2004 to December 

31, 2005 showed a range of prices between $13.45 and $85.34 per MBF. This is in sharp contrast 

to the average pond log value used in Spectrum analysis of $273 per MBF. How was the timber 

sale revenue estimate ($11.69/MBF) used in the economic efficiency analysis estimated and was 

this figure used in the Spectrum analysis. 

Response: To clarify, the Tongass recognized several unique pond log values in its economic analysis; 

for old growth this consisted of a value for each of three volume strata in each of the five geographic 

zones, or 15 unique values. Young growth values vary by the age at which they are harvested. However, 

as the respondent has pointed out, the actual bid price (stumpage value) of a timber sale has a great deal 

of variability associated with it. We contend that this variability is directly correlated with the costs 

associated with the timber removal, i.e., the logging system used, transportation requirements to get it to 

the mill, etc. Thus, stumpage value is an inherent calculation done by the Spectrum model to generate a 

unique value for each distinct geographic unit (Analysis Area). For the Final EIS, we have included a 

more detailed economic analysis for timber value in Appendix B Table B-2. 

The $11.69/MBF average stumpage value used in the Draft EIS represents the forest-wide average price 

paid for timber sales in 2005/2006. This value does not consider the site-specific variability in stumpage 

values calculated by the Spectrum model and was not used in the Spectrum model analysis. It should be 

noted that the economic efficiency analysis has been updated in the Final EIS. 

Comment: One comment summarized sales data from October 2004 to December 2005 and 

concluded that the average bid price per MBF was higher for micro sales and small sales, then for 
Appendix H 

Comments and Responses H-110 Final EIS 

relatively large sales. This, the comment noted, suggests that one of the alternatives in the EIS 

should have focused on microsales, rather than large sales. “Unfortunately,” they note “none of 

the alternatives in the Draft EIS appear to be based on benchmark analyses that evaluate the 

option of shifting management resources away from large sales to micro and small sales.” 

Response: The seven alternatives evaluated in the Final EIS offer a broad range of potential responses 

to future timber demand. These alternatives do not specify the size of the sales that would be offered 

under each alternative. The Forest Service would continue to offer small and micro sales under all of the 

alternatives. 

The benchmark analyses conducted show the difference in values between geographic areas, logging 

systems, stocking levels, maximum management size, and distances to nearest processing facilities. 

This is consistent with the planning rule that requires landscape stratification by factors that influence 

economic efficiency. Updated benchmark analyses were conducted according to this stratification. 

Comment: One comment asked for more detail concerning the timber policy constraint used in 

the Spectrum model to ensure that all timber harvest meets sustained yield requirements. The 

comment asked that we explain the following: 

 “1. which specific constraints were applied for each alternative and in what sequence; 

2. whether planners conducted a Spectrum run that does not maximize timber harvest in the first 

decade before maximizing present net value; 

3. whether planners ask Spectrum to maximize present net value subject to the requirement that it 

cut the volume of timber in the above run; 

4. what discount rate was applied to maximize the present net value run; and 

5. whether planners used nondeclining net revenue constraints in any model runs.” 

Response: Regarding the constraints applied to each alternative, Appendix B has been updated to 

include more description as well as a table describing which constraints were applied to each Alternative. 

The nature of the Spectrum model allows for all constraints to be included simultaneously; there is no 

hierarchical order of importance assigned to the different constraints. 

Regarding the timber harvest level in the first decade, the model is constrained to meet a harvest level 

consistent with the design of the alternative. These levels were derived independently of the maximum 

potential Decade 1 harvest level, save that to insure the ability to implement the plan, the level must be 

less than the maximum. 

The model scenarios evaluated for each alternative found the maximum PNV of the alternative under the 

appropriate constraints, including the appropriate timber harvest level, of each Alternative. 

The model used a 4 percent annual discount rate. 

There is no constraint to consider non-declining revenues from decade to decade. See Appendix B 

“Solution Process” for more information on the Spectrum model formulation. 

Comment: One comment noted that Appendix B in the Draft EIS indicates that the Spectrum 

analysis did not assign a value for utility logs under Alternatives 1, 2, 3, 5, and 6, but assigned 

utility logs a positive value under Alternatives 4 and 7 based on the assumption that there would 

be a market for these logs (MDF, Bioenergy, or similar facilities). Alternatives 3, 5, and 6 should 

also assign a positive value to utility logs because they assume there would be enough volume to 

operate a veneer mill. The decision to give no value to utility logs under certain alternatives also 

ignores the new Region 10 transshipment policy. 
Appendix H

Final EIS H-111 Comments and Responses

Response: For the Final EIS, a utility pond log value of $72 per thousand board foot volume was 

recognized for Alternatives 4, 5, 6, and 7. This price was based on an analysis of recent prices (see 

Appendix B for source information). However, we recognize that this positive revenue will rarely, if ever, 

outweigh the costs associated with its removal from the stand and transportation to the mill. The recently 

enacted Limited Interstate Shipment Policy (March 2007) allows limited interstate shipment (to the lower 

48 U.S. states) of unprocessed Sitka spruce and western hemlock. This could provide a market for small 

diameter and low-grade material in the future under all alternatives, but the value this would add to utility 

logs is currently unknown. However, viewed in terms of the Spectrum analyses, utility wood value is not 

likely to have a large impact on the amount or timber produced or the management schedule of any 

Alternative. 

Comment: One comment stated that the costs described in the Draft EIS Appendix B and used in 

the Spectrum analysis do not appear to correlate with the costs used to compare the alternatives 

in the economic efficiency analysis (Table 3.22-29, page 3-460). 

Response: Appendix B shows two different types of costs used in Spectrum modeling; those incurred by 

the timber buyer and those incurred by the Forest Service. Costs incurred by the timber buyer are 

counted against the pond log value to determine actual stumpage value (see Final EIS Appendix B for 

further information on this calculation). Stumpage value calculated in the model as a function of pond log 

value less cost incurred by the timber buyer approximately corresponds to the historic stumpage value 

shown in Table 3.22-29 of the Draft EIS. The two analyses are discrete in that Spectrum uses stumpage 

values specific to each land area and Table 3.22-29 shows the historic average stumpage [base rate in 

the Final EIS] of sold wood. The analyses are similar in that ultimately they both evaluate each 

Alternative’s anticipated revenues to the Forest Service. 

Agency-incurred costs are included in the Spectrum model to determine the overall economic value of the 

harvest schedule associated with each Alternative. Agency-incurred costs in the model and described in 

Appendix B correspond to the agency-incurred costs shown in Table 3.22-29. 

Comment: One comment stated that it is unclear from the documentation exactly what figures 

were included as revenues in Spectrum. The comment asked the following questions: Were any 

non-timber benefits modeled in Spectrum? Were any non-timber benefits modeled in Spectrum in 

determining the suitable land base and the PNV of harvest? If this occurred in either case, please 

explain why and what those figures were (dollar amounts). 

Response: Pond log values that varied by volume class and geographic zone were the only monetary 

revenues modeled in Spectrum. These values are further described in the “Activities and Outputs” 

section of Appendix B. Only the costs and benefits described in Appendix B were used to determine the 

PNV of the Alternatives and Benchmarks analyzed with the Spectrum model. Pond log values were the 

only revenues used in the “Stage II Suitability Analysis” described in Appendix B.

Comment: One comment stated that mitigation measures to not seem to have been accounted for 

in the cost calculations and made the following points. The cost of mitigation activities needs to 

be accounted for in determining timber suitability. If the Forest Service must complete required 

mitigation measures then these costs should be reflected in either the stratification of analysis 

units according to a range of conditions or in a range of stumpage prices by mitigation 

requirements. The cost is especially tied to factors such as slope, proximity to streams, proximity 

to cultural resources, proximity to threatened and endangered plant and animal habitat, all of 

which can be stratified. As the mitigation costs are not the same on all sales some grouping of 

mitigation costs by harvest type or ecological condition or habitat location should be calculated. 
Appendix H 

Comments and Responses H-112 Final EIS 

Response: Appendix B describes two processes that were used to incorporate the effect of mitigation 

measures for each alternative. The “Regulation Class Process” describes how Scenic Integrity 

Objectives, Visual Absorption Capacity, Distance Zone, and LUD were used to identify lands that required 

varying levels of mitigation for scenery and other considerations. Regulation classes with more harvest 

restrictions generally have higher harvesting costs. 

Secondly, the “Model Implementation Reduction Factors (MIRF)” section describes how the impacts of 

stream buffers, slope and soil hazards, wildlife concerns, and other factors were considered in the model. 

MIRF were applied to a stratification by Administration area, volume class, and harvest system. 

Timber Sale Economics 

Comment: A number of comments supported Alternative 7 with some modifications. They felt 

that some of the Conservation Strategy Standards and Guidelines lacked a basis in science and 

should be removed from Alternative 7. These standards and guidelines include: the 1,000-foot 

beach buffer, OGRs, Class III stream buffers, the Legacy standard, and the Goshawk and Marten 

standards. Many of these comments argued that these measures are the main reasons that the 

Tongass has been unable to offer economic timber sales. 

Response: These recommendations were considered and evaluated as part of Alternative 7. These 

measures are all important components of the Forest’s conservation strategy, which is an integral part of 

meeting our multiple use objectives and the legal requirement that we maintain viable wildlife populations. 

The wildlife assessments completed for the current Forest Plan found that alternatives that did not 

provide a comprehensive conservation strategy had a higher risk of not maintaining viable populations of 

some wildlife species. The U.S. Fish and Wildlife Service has indicated that the conservation strategy 

adopted under the 1997 Plan was a major factor in not listing the Queen Charlotte goshawk as 

threatened under the ESA. See Appendix D of the Final EIS for more information about the scientific 

rationale behind the conservation strategy. 

Alternative 7 as proposed in the Draft EIS did not have these standards and guidelines except for the 

Class III riparian standard (see, for example, Table 2-16, page 2-41). Alternative 7 has been modified in 

the Final EIS and it no longer includes buffers on Class III streams. 

Comment: One respondent believed that Forest Service sale design should maximize production 

while protecting the resources that need protection. 

Response: Forest Service timber sale design is intended to meet market demand in an economically 

efficient manner, while protecting other resources. 

Comment: One respondent felt that the timber market is cyclical so sales should be designed so 

that they are operable in all markets. 

Response: This may not always be possible, given the high cost of operation in an island archipelago, 

spikes in fuel costs, and the location of the Tongass in relation to markets. One of the Proposed Forest 

Plan’s stated goals (page 2-5) is to provide timber in an economically efficient manner. 

Comment: A number of respondents stated that logging should not be subsidized with taxpayer 

dollars. Others stated that subsidies should be factored into the economic analysis of the 

alternatives. Conversely, one comment stated that subsidized logging was needed to revitalize 

Alaska’s economy.
Appendix H

Final EIS H-113 Comments and Responses

Response: The issue of whether or not the federal government is subsidizing the timber industry is 

beyond the scope of this analysis. During low market conditions the cost of planning, preparing and 

administering timber sales are often higher than the value paid for the timber. This is factored into the 

economic efficiency analysis presented in the Economic and Social Environment section of the EIS. One 

of the Forest Service’s objectives for the Tongass National Forest under TTRA is to promote community 

stability by seeking to provide a stable supply of timber that meets annual market demand. 

Comment: Some respondents felt that timber sales must be economic or it defeats the purpose of 

offering them. They argue that planning teams should include people with experience in planning 

economic sales. Some requested that a standard requiring sales to be economic be added to the 

Proposed Forest Plan. Not having economic sales has lead to the Forest not achieving the ASQ. 

Others felt that costs would always be too high to compete with other regions. 

Response: We agree that timber sale expertise is important. The Forest Service is already prohibited 

from offering deficit timber sales. The high cost of doing business in Alaska as well as current market 

conditions contribute to the economics of timber sales. The Tongass will continue to work to make timber 

sales as economic as possible while protecting other resources. But it is not our responsibility alone. 

Industry needs to find new markets, develop value-added products, and become more efficient to reduce 

costs and improve profits. 

Comment: Concerns were expressed about the difficulty of having economic harvest units in 

Scenic Viewshed and Modified Landscape LUDs where partial cutting is often required. 

Response: The bulk of the timber harvest under all the alternatives comes from areas classified as 

Timber Production; these are areas that allow more intensive timber harvest, while still protecting other 

resources, such as fish and water quality through stream buffers and other standards and guidelines. 

The proposed Plan Amendment updates the Seen Area analysis and Visual Priority Routes and Use 

Areas as a step in this process (see Appendix F of the Final Proposed Forest Plan). While we want to 

foster more economic timber sales we also recognize the importance of maintaining our outstanding 

visual resources. 

Comment: Several comments made the following general argument. The overall goal of the 

Tongass timber program should be to transition to second-growth timber. Full transition will take 

at least 50 years and in the interim the Forest Service needs to provide a sufficient, predictable 

supply of old-growth timber that will sustain the existing industry and have the flexibility to 

increase this supply if the industry were to expand. This harvest should be concentrated in 

intensively managed areas and standards and guidelines should be relaxed in these areas to 

improve timber sale economics, in exchange for more stringent guidelines applied elsewhere. 

Response: The Forest Service supports the overall goal to transition to second-growth (young-growth) 

timber harvest over time; however, it will be decades before there are enough young stands to provide a 

sufficient timber supply to meet market demand in accordance with TTRA. Table 3.13-9 in the Timber

section identifies the projected acres by harvest approach (even-aged, two-aged, uneven-aged) for each 

alternative. All seven proposed alternatives employ a combination of harvest approaches with projected 

harvest levels more concentrated in some areas than others. 

None of the alternatives propose that standards and guidelines be “relaxed” in harvest areas in exchange 

for “more stringent guidelines” applied elsewhere. Alternative 7 does, however, exclude or relax the 

components of the conservation strategy—the 1,000-foot beach buffer, the Goshawk and Marten 

Standards and Guidelines, the 100-foot buffer on Class III streams, and the small, medium and large 

OGRs—that the timber industry argues result in uneconomic sales. 
Appendix H 

Comments and Responses H-114 Final EIS 

Comment: One comment stated that some State forests and all private forests can be managed 

for positive economic returns and argued that the Forest Service should also be able to move in 

that direction. Another comment stated that the Forest Service should avoid scheduling sales in 

areas that are uneconomic to harvest. 

Response: NFS lands are governed by different laws than state and private forests and this affects the 

relative costs of harvesting timber. The Forest Service will continue to work to make timber sales as 

economic as possible while protecting other resources. 

Comment: Several comments requested that the Forest Service set aside funds from timber 

harvest for post harvest treatments and studies. 

Response: This program already exists. It is authorized by the Knutzen-Vandenberg Act. The Forest 

Service may “require any purchaser of National Forest timber to make deposits of money, in addition to 

the payments for the timber, to cover the cost to the United States of (1) planting...removing undesirable 

trees or other growth...improving the future productivity of the renewable resources of the forest...” Sale 

receipts in excess of base rates can be used for this program. 

Comment: Some respondents requested that the Forest Service not allow round log exports. 

Concern was expressed about utility log exports and the recent decision to allow the export of 

low-grade and smaller logs. This, they argue, creates jobs and encourages investment in other 

states and countries not Alaska. Concern was also expressed that the Draft EIS and market 

demand analysis fails to take these log exports into account. One comment was also concerned 

that no NEPA analysis was prepared for this policy change. 

Response: Export of logs is a policy decision and beyond the scope of this analysis. Issues surrounding 

NEPA for other projects and policy decisions are also beyond the scope of this project. 

The limited interstate shipment policy referenced in this comment is not addressed in the Draft EIS 

because it was not approved until March 14, 2007, more then two months after the Draft EIS was 

published. The potential implications of this policy are discussed in a number of locations in the 

Economic and Social Environment section of the Final EIS. 

People often use the term “export” to refer to the interstate shipment of logs, that is, shipment to other 

parts of the U.S. The shipment of these logs to other states directly supports employment in the logging 

and transportation sectors in Southeast Alaska. It also provides a market for low grade logs that currently 

are often left in the woods because there is no economical processing facility for this material in 

Southeast Alaska. The new policy, therefore, has the potential to indirectly support logging and sawmill 

employment because it improves timber sale economics and may allow sales to go forward that would 

otherwise not be profitable. 

Comment: The Morse Report (2000) states cedar will be processed locally because the Seley 

Corp has a mill designed to process cedar but the Draft EIS says it will be exported. 

Response: The text in the Economic and Social Environment section of the Final EIS has been revised 

to clarify that there are some local facilities that are able to process limited amounts of cedar. 
Appendix H

Final EIS H-115 Comments and Responses

Timber Supply 

Comment: One comment stated that page 2-23 of the Draft EIS over estimates the amount of 

harvest from state and private lands under Alternative 4. The same comment author later states 

that the Brackley et al. (2006a) estimate of 6.8 MMBF per year from state and private lands seems 

reasonable, with no increase in available timber from state and private lands likely in the future. 

Response: The only reference to state and private harvest on page 2-23 of the Draft EIS, or elsewhere 

in the referenced section, is the statement that “private and state lands also contribute to satisfying 

market demand”. The amount is not quantified. The Brackley et al. estimate of 6.8 MMBF is referenced 

in the Draft and Final EIS documents. It may be noted that this estimate applies only to state lands and 

does not include projected future harvest on private lands in Southeast Alaska. 

The analysis presented in the Draft and Final EIS documents evaluates how well the NIC I component of 

the ASQ available under each alternative would meet various demand-related benchmarks. This analysis 

focuses on Tongass timber, which is assumed for the purposes of analysis to be the only source of timber 

in the region. 

Comment: A number of comments requested that the Forest Service provide sufficient economic 

timber to supply an integrated timber industry, which would support local employment and 

contribute to the regional economy. Some comments stressed the need for local mills that could 

process low-quality logs so they would not need to be exported. 

Response: The EIS evaluates a range of alternatives. Alternatives 3 through 7 would provide sufficient 

volume to supply an integrated timber industry based on the demand projections developed by Brackley 

et al. (2006a). Alternatives 3, 5, and 6 would provide sufficient volume to support a Medium Integrated 

Industry (Brackley et al.’s Scenario 3). Alternatives 4 and 7 would provide sufficient volume to support a 

High Integrated Industry (Scenario 4). Timber demand is evaluated in detail in the Economic and Social 

Environment section of the Draft and Final EIS documents. Both the Medium and High integrated 

industry scenarios require some form of demand stimulus that would create demand for lower grade logs. 

Brackley et al. suggested that this might take the form of a medium density fiberboard (MDF) plant or a 

biomass facility established in the region. 

Comment: One comment stated that development of an integrated industry would require an 

integrated land management policy across state, federal, trust, and private lands. The comment 

author offered a series of recommendations that included placing an emphasis on the most value 

and family wage jobs per board foot for the least volume harvested, providing incentives for local 

mills through tax breaks, and restricting the export of unprocessed logs, among others. 

The same comment author pointed out that imported wood is used for many projects in Alaska 

and wanted the state to fund a state log grading agency. The comment also noted that more 

investment is needed to develop the local wood manufacturing industry. 

Response: While the Forest coordinates management with other land owners where possible, state and 

private land managers often have different goals. The State of Alaska is a Cooperating Agency in this 

analysis effort. Although the Forest Service supports the restoration of an integrated timber industry, 

developing incentives and tax breaks is beyond the scope of this analysis, as is the log export policy for 

non-NFS landowners. Funding for state agencies is also beyond the scope of this analysis. 

Alternatives 3, 4, 5, 6 and 7 are designed to provide a stable timber supply that would be sufficient to 

support a Medium or High integrated industry. This is discussed further in the Economic and Social 

Environment section of the EIS. The Forest Service also supports a number of initiatives and pilot 

programs, including the non-profit Ketchikan Wood Technology Center. 
Appendix H 

Comments and Responses H-116 Final EIS 

Comment: One comment suggested that the timber industry should be responsible for providing 

their own timber (such as fast-growing eucalyptus for pulp and bamboo) and the Forest Service 

should provide an incentive for this transition by charging high prices for any timber it does 

supply. Another comment suggested other plants or recycled material be used. 

Response: The Forest Service has no control over what is grown on private lands. It may, however, be 

noted that neither eucalyptus nor bamboo are native to Southeast Alaska. The Tongass is required to 

seek to meet market demand under TTRA. Timber sales designed to meet this demand are offered using 

a competitive bid process, with prices determined by the interaction of supply and demand. In general, it 

seems reasonable to assume that recycled materials have the potential to replace some products that 

currently come from new lumber. 

Comment: One comment pointed out that the Ketchikan Veneer Mill recently completed a 

successful test run of their equipment using local logs and project that the facility will initially 

need 2.1 MMBF of veneer-quality logs per month to operate, with this amount increasing to 3.65 

MMBF per month after six months. The comment author notes that a commitment from the Forest 

Service is required before operations can proceed further. 

Response: The Forest’s goal is seek to meet the market demand for timber as required by TTRA. The 

projected demand identified in this comment would result in annual demand of 43.8 MMBF, approximately 

13.8 MMBF higher than the installed production capacity estimated for this facility by the Juneau 

Economic Development Council (2007). The timber demand analysis subsection in the Economic and 

Social Environment section of the Final EIS evaluates the ability of the proposed alternatives to meet 

projected demand based on the PNW study (Brackley et al. 2006a) and a series of other measures, 

including installed capacity. 

Comments: Many comments expressed support for local mills that either produce value added 

products or products required to serve local markets. Comments recommended that the Tongass 

provide enough wood to support value added mills. A number of comments stated that timber 

sales should be designed for small operators and spread across the forest to accommodate local 

operators without impacting other existing public uses. One comment expressed support for the 

Forest Service’s recent decision to offer sales targeted at small operators. 

Response: The Forest Service seeks to provide wood for mills that produce value added products 

and/or serve local markets as part of its requirement under TTRA to seek to meet the demand for 

Tongass wood. Many comments express support for some form of value added industry, but do not 

clearly define what they mean by value-added. The larger existing mills on the Tongass, which are not 

very large by most standards, produce value added products and support local employment. The 

demand associated with these mills is also part of the market demand that the Tongass must seek to 

meet under TTRA. The Final EIS identifies potential market demand for the planning cycle and identifies 

areas of the forest that need to be withdrawn from commercial timber production in order to protect 

wildlife and other resources. 

The alternatives feature different levels of potential harvest activity that would likely be associated with 

different configurations of a wood products industry in Southeast Alaska. Projected harvest levels 

evaluated in the Final EIS range from 49 MMBF under Alternative 1 to 421 MMBF under Alternative 7 in 

the first decade following implementation. 
Appendix H

Final EIS H-117 Comments and Responses

Comment: One comment asked for specific information in the Final EIS on how each alternative 

would affect small mills in the Thorne Bay area. 

Response: It is difficult to predict how any specific small mill would be affected by an alternative, beyond 

assuming that if demand is met then there will be enough wood to support small mills as well as larger 

mills. However, wood is sold through a competitive bidding process and there is no guarantee that a 

specific mill will succeed in meeting its needs in a competitive market. 

Allowable Sale Quantity 

Comment: One comment stated that: “if it is true that the lack of shelf stock is keeping industry 

from expanding then the agency has the authority to create additional shelf stock without raising 

ASQ. ASQ constricts the sale of timber not preparation of sales. If demand does increase, the 

agency can raise ASQ. Right now there is no reason to do so.” 

Response: While it is true that merely planning timber sales does not affect the ASQ, shelf stock that 

could not be sold without violating the ASQ would be of limited value. The Final EIS evaluates seven 

alternatives in detail. Three of those alternatives have a lower ASQ than the current plan, two are the 

same as the current plan, and two are higher. 

Comment: Some respondents felt that the current ASQ seemed sufficient, but noted that the 

Forest Service should remain flexible in case demand rises. 

Response: The Forest Service reviews demand on a regular basis and can amend or revise the Forest 

Plan as needed to meet its obligations under TTRA. 

Comment: Some respondents believe that the Forest Service should act quickly to make timber 

available and to add timber to the “pipeline”. 

Response: The provision of timber is a priority under the current plan and would continue to be so under 

the amended Forest Plan at levels determined in the new plan and as funding and personnel allow. 

Comment: Several comments stated that the ASQ is too high under the higher volume 

alternatives because: “Brackley et al.’s timber demand projections were used to model harvest 

and determine the ASQ.” 

One comment stated that TTRA requires the Forest Service to seek to provide “a supply of 

timber” (singular) that meets “the market demand” (singular) for timber from the Tongass 

(emphasis added in the comment), not the multiple demand amounts evaluated in the Draft EIS. 

Response: The demand levels used to help develop a range of alternatives were developed by 

specialists at the PNW Research Station (Brackley et al. 2006a) and represent the only peer-reviewed 

demand estimate available. Specific concerns identified with respect to the Brackley et al. study are 

discussed in the Economic and Social Environment section of this Comments and Responses volume, 

under Timber Demand. Additional information on the Brackley et al. analysis is provided in an addendum 

report that addresses questions and concerns raised with respect to the original analysis (Brackley and 

Haynes, in press). 

The Forest Service considered the Brackley et al. analysis and other studies of timber demand to create a 

broad range of alternatives. Implementation of the selected alternative will provide one supply of timber 

that will meet the market demand for timber from the forest in accordance with TTRA. 
Appendix H 

Comments and Responses H-118 Final EIS 

Comment: One comment asked for a 10 year timber sale schedule and stated that the National 

Forest Management Act and its implementing regulations require the Forest to publish a 10-year 

harvest schedule. Another comment requested that the Forest Service prepare a detailed timber 

harvest schedule to ramp up to the timber under contract level of 1,080 MMBF (3 years worth of 

timber at 360 MMBF per year). 

Response: The requirement to identify a “planned timber sale program” in NFMA Section 1604(f)(2) is 

accomplished by the information provided in the Final EIS which displays the projected ASQ volume by 

Forest Plan alternative. The requirement does not mandate a compilation of individual proposed actions. 

The Forest Service currently prepares 5 year sale schedules to implement the Forest Plan and will 

continue to do so as part of the implementation process under the amended Forest Plan. The Forest 

Service would like to increase the volume under contract and the shelf volume (prepared but unsold 

sales) to help provide more stability to the timber industry. The amount of new volume to be offered to 

meet the Forest’s general goal of having 2 to 3 years of unharvested timber under contract will depend on 

the selected alternative. 

Comment: One comment stated that: “The Draft EIS states that it is unlikely that all acres 

modeled and scheduled for harvest will actually be cut. This is likely to be true as long as the 

federal bureaucracy controls the timber supply. This is another reason to keep the ASQ high.” 

Another comment stated that lawsuits by environmental groups have tied up the “few 

economically viable timber sales” offered on the Tongass in recent years actively leading to the 

“current situation.” This comment argues that the Tongass should plan to offer sale volumes in 

excess of market demand—the comment author suggests twice the market demand volume may 

be necessary—to ensure that sufficient volume “make(s) it past the environmental appeals 

process and to the market.” 

Response: When crews review the areas scheduled for harvest by the model, they are likely to find 

some areas do not have sufficient volume to be considered commercial forest land, some areas will prove 

too costly to road or too uneconomic to log. This is likely to be the case regardless of who manages the 

land. In addition, because of the protections needed to maintain habitat for wildlife and protect viewsheds 

that are important to the tourist industry, additional falldown in harvest volume is anticipated and built into 

the model. 

The ability of the alternatives to meet potential demand is assessed against a series of measures in the 

Economic and Social Environment section of the Draft and Final EIS documents. These measures 

include the four scenarios identified in the projections developed by Brackley et al. (2006a), current 

production levels, installed and active production capacity, and the minimum estimated volumes required 

to support various processing facilities. The comparison between the four scenarios presented in 

Brackley et al. and the alternatives is based on the total ASQ volume. The comparisons between the 

alternatives and the other measures are based on the NIC I component only, which includes lands that 

can be harvested with normal logging systems. 

The Forest Service hopes that regional stakeholders can reach consensus and avoid lawsuits in the 

future and supports the efforts such as the Tongass Futures Roundtable.

Comment: Concern was expressed that the ASQ is a very poor indicator of how well each 

alternative would supply timber to the local industry. Actual production is historically well below 

the established ASQ. 

Response: It is true that ASQ is a ceiling and not a guarantee of actual production. But it remains a 

viable measure of the potential of each alternative to supply timber to local markets. The actual amount 

of timber that might be sold and harvested in each alternative is always speculative as it is dependent 
Appendix H

Final EIS H-119 Comments and Responses

upon numerous factors such as timber demand, volume under contract, lumber prices, Forest Service 

budgets and appeals and litigation. 

Comment: Several comments stated that the Spectrum model analysis overstates the likely 

economic sale volume by more than 30 percent. This has two effects on the analyses presented 

in the Draft EIS. First, the ASQ volumes overestimate the amount of economic timber that would 

be available under each alternative. Second, this overstatement results in an overestimate of 

potential environmental impacts in all cases where the ASQ is used as part of the analysis. The 

ability of the alternatives to meet the four demand scenarios identified in Brackley et al. (2006a) 

and the potential environmental impacts of the alternatives should be assessed using a new 

category, the “Programmed Sale Quantity” (PSQ), which should be based on less than 70 percent 

of the ASQ.

Response: As stated in a number of locations in the Draft and Final EIS documents, the ASQ is a 

ceiling; not a future sale level projection or target and it does not reflect all of the factors that may 

influence future sale levels. Actual harvest is likely to be lower. 

The ability of the alternatives to meet potential demand is assessed against a series of measures in the 

Economic and Social Environment section in the EIS. These measures include the four scenarios 

identified in the projections developed by Brackley et al. (2006a), current production levels, installed and 

active production capacity, and the minimum estimated volumes required to support various processing 

facilities. The comparison between the four scenarios presented in Brackley et al. and the alternatives is 

based on the total ASQ volume. The comparisons between the alternatives and the other measures are 

based on the NIC I component only. The use of NIC 1 volume in the Final EIS generally corresponds to 

the suggestion to use the more economic component of the ASQ for evaluation purposes. 

The potential environmental impacts are assessed based on the projected ASQ. Actual harvest is likely 

to be lower and actual volumes harvested under any of the alternatives may be affected by a range of 

different factors that are difficult to predict at this point. It is important to remember that the Forest Plan 

does not authorize any ground disturbing activities or create any environmental consequences. The main 

function of the Final EIS is to compare and contrast alternatives in a general way using broad projections 

based on full implementation of each alternative. With that in mind, the ASQ represents the maximum 

allowable timber harvest under each alternative and allows an appropriate and consistent comparison 

between alternatives. 

Comment: Concern has been expressed that the ASQ would restrict movement toward the 

planning cycle demand of 360 MMBF per year if it was lower than the planning cycle demand. 

Response: The ASQ is a decadal ceiling and should not be confused with the average or annual sale 

quantity. The ASQ is the maximum amount of timber that can be sold from regulated or scheduled timber 

lands during each decade over the life of the Forest Plan and is typically presented as an annual average. 

Annual harvest is not, however, constrained to this annual average, provided that the cumulative annual 

harvest volume does not exceed the decadal ceiling. This may result in annual harvests that exceed the 

average annual ASQ for a number of years. For example, if during the first part of the decade only half of 

the average annual volume was sold, that volume could be made up by selling more than the average 

during the remainder of the decade. With the current timber harvest levels low relative to the ASQ and 

planning cycle demand, such decadal flexibility should allow sufficient volume to respond to increases in 

industry growth and demand for timber. 

The Forest Service also has established procedures (Forest Service Handbook 2409.13) for analyzing 

departure from the established ASQ ceiling to determine whether or not it is possible to better meet 

multiple use objectives. Those procedures include several criteria or conditions in which evaluation of 

departure from the ASQ would be needed. One of the set of conditions listed is when implementation of 

the ASQ could have a substantial adverse impact in the economic area in which the forest is located. For 
Appendix H 

Comments and Responses H-120 Final EIS 

example, if the level of harvest has increased and the cumulative amount of timber sale volume is 

approaching the decadal ceiling, there may not be sufficient new sale volume to support market demand. 

If this were likely to be too disruptive to the local economy, departure procedures could be triggered to 

sell more than the ASQ decadal ceiling. This volume could be made up in the next decadal ceiling or 

forest amendment processes, including public involvement, would be used to adjust the ASQ accordingly. 

Comment: Is this statement in the Draft EIS true: “additional volume can be produced from, for 

example, wildlife habitat enhancement in young-growth forests...” 

Response: Many OGRs contain old clear cuts. Thinning the young stands that have grown in these 

areas can enhance development of large trees. Any commercial-size wood removed from these areas 

would not count toward ASQ. This statement has, however, been deleted from the Final EIS because it 

was easy to misinterpret. 

Tongass Futures Roundtable 

Comment: A number of comments mentioned the need to find consensus on the lands available 

for timber harvest. Some mentioned the Tongass Futures Roundtable and expressed support for 

this group and its identified goals. As noted in the comments, one of the group’s goals is to 

develop a 24- to 36-month supply of timber to bridge the period needed for a consensus approach 

among stakeholders to agree on which watersheds should be protected and which should be 

available for timber harvest. 

Response: The Forest Service supports the goals and objectives of the Tongass Futures Roundtable 

and appreciates the work that this group is doing to work toward consensus on Tongass issues. 

Comment: One comment expressed concern that the Tongass Futures Roundtable might have 

too much influence on the ROD. They felt that there was no way one group could represent all 

interests. 

Response: As stated above, the Forest Service supports the efforts of the Roundtable to bring various 

interest groups together to discuss Tongass issues, but we recognize that this one group does not speak 

for everyone. It should be noted that as of the date of this publication the Tongass Futures Roundtable 

has not brought forward any specific recommendations beyond some very general goal statements. The 

rationale for the decision for this project will be discussed in the accompanying ROD. 

General 

Comment: Some respondents believe that Alternative 7 was not fairly treated in the Draft EIS. In 

particular they felt that the negative effects of timber harvest were overstated. A related comment 

was the impression that the Draft EIS has a “logging is bad” bias. 

Response: As the Final EIS notes, timber harvest provides jobs and resources that people need, such 

as lumber for housing and also benefits species that are associated with early seral conditions. However, 

timber harvest, and the associated road construction, does increase the risk of negative effects on 

wildlife, old growth forests, streams, and other resources and the EIS attempts to depict this fairly. As 

Alternative 7 has the highest level of timber harvest, it also has the highest risk of possible negative 

effects. 
Appendix H

Final EIS H-121 Comments and Responses

Comment: Concern was expressed that Sealaska cannot be expected to continue harvesting at 

the same level it has been during the next decade if it does not get it’s ANCSA entitlement in that 

period. 

 

Response: The EIS assumes for the purposes of analysis that Private (Native Corporation) and State 

harvests would be 109 MMBF per year for the first decade following Forest Plan implementation under all 

of the alternatives (Brackley et al. 2006a). Private land management is not part of the scope of this 

analysis except to the extent that it informs the cumulative effects analysis for potentially affected 

resources. Specific questions and comments related to ANCSA and Sealaska are addressed in the 

Lands section of this comment and response appendix. 

Comment: One comment noted the following concerns with respect to the tables presented in the 

Timber section of the Draft EIS: 

• Tables 3.13-1, 3.13-2, and 3.13-3 identify different numbers of total suitable acres 

• The acres presented for items 7 and 8 in Table 3.13-8 are different under Alternative 1 than 

under the other alternatives 

• The total suitable acres identified for Alternative 1 in Table 3.13-8 are slightly lower (6 acres) 

than those presented in Table 3.22-31 

• Table 3.13-10 and the text on page 3-260 of the Draft EIS do not appear to match 

• Table 3.13-14 is supposed to show age class distribution for suitable timberlands, but instead 

shows total timberlands 

• Total timberlands identified in Table 3.13-14 do not match the totals for lines 13 and 14 in 

Table 3.13-8. 

Response: The suitable acre numbers have been updated in the Final EIS and are presented 

consistently throughout the document. The other identified typographical errors and inconsistencies have 

also been corrected in the Final EIS. 

Comment: One comment stated that: “Using US Forest Service GIS data, there are over 1.8 

million acres of commercial timber with an estimated 29 billion board feet of timber. This is 

enough to produce an annual sale volume of 365 MMBF over an 80-year rotation. Second growth 

will help augment this amount, easing the transition to second-growth management. Lowering 

the rotation age to 70 years would require less old-growth harvest.”

Response: While this may be correct, not all commercial forest land is available for harvest due to the 

need to consider other resources and uses. 

Comment: Several comments questioned why the acres in development LUDs and the ASQ for 

Alternative 1 in the Draft EIS do not match those for Alternative 8 in the 2003 SEIS. The number of 

acres increased from 1.1 million to 1.2 million, but the ASQ dropped from 96 MMBF to 52 MMBF. 

Concern was also expressed that the ASQ for Alternative 5 (No Action) in the Draft EIS is 267 

MMBF compared to 259 MMBF for the same alternative in the 2003 SEIS. 

Another comment pointed out that the statement in the Draft EIS that approximately 767,000 acres 

have been harvested in Southeast Alaska conflicts with the PNW Research Station General 

Technical Report (GTR) 386 from 2006, which states that over 1 million acres had been cut at that 

time. 

Response: Alternative 1 in the Draft EIS included some roadless area, while Alternative 8 in the SEIS 

did not. Also, the ASQ under Alternative 1 was limited to the amount needed to reflect recent timber 

harvest levels on the Tongass. The alternative was not designed to maximize production from the roaded 

area. Page 3-442 of the Draft EIS mentions that this alternative has the potential to produce more timber 
Appendix H 

Comments and Responses H-122 Final EIS 

volume. For the Final EIS we eliminated all roadless areas from the suitable land base in Alternative 1, 

thereby reducing the number of suitable acres while keeping the ASQ the same. We left nearly the entire 

roaded area in Alternative 1 even though not all of these acres would be needed to harvest at the lowest 

demand level. 

Regarding the no action alternatives, the SEIS used an excel spreadsheet to estimate ASQ based on the 

old FORPLAN runs. The Draft EIS used the new Spectrum model. This accounts for the differences in 

the two no action alternatives. In hindsight, it appears that the no action alternative in the SEIS could 

produce the 267 MMBF estimated in 1997 but the excel spreadsheet estimate used in the 2003 SEIS was 

reasonably close (less than 3 percent difference). 

Recent estimates of the amount of harvest are more accurate due to improvements in GIS technology. 

Comment: Some concern was expressed about blowdown, especially in light of prediction of 

increased storm events due to global warming. Comments were particularly concerned about 

blowdown along the margins of harvest units and in the 100-foot wide stream buffers. A number 

of comments recommended that the Forest Service conduct research on blowdown and 

windthrow patterns and use this information in harvest planning.

Response: Blowdown can be a serious problem, especially in areas that are subject to catastrophic wind 

events. Buffers on streams require more than the 100-foot buffers on each side of the stream. Standards 

require a reasonable assurance of a windfirm buffer. The width of each buffer depends on the windthrow 

risk of the area. We will continue to monitor and acquire more information about blowdown in Southeast 

Alaska. In addition, the Forest Service supports research on windthrow through the PNW Research 

Station. 

Comment: Some disagreed with the statement in the Draft EIS that alternatives with more road 

building and harvest are likely to result in more blowdown if climate change results in more 

storms, as some predict. 

Response: Windthrow associated with roads and harvest units is well documented, as is the increase in 

storm events in the last few decades. While, to date, the increase in storm events has not resulted in a 

documented increase in windthrow, the potential should not be ignored when planning harvest units. 

Comment: One comment stated that “because of the risk of blowdown, logging prescriptions 

tend to not leave strips of unharvested old growth between units. Instead new units are placed 

adjacent to old units, which leads to mega-units much larger than the maximum 100 acres. The 

Plan needs to include standards that prohibit this practice.” 

Response: The average opening in recent years has been approximately 11 acres. A new unit is not 

placed next to an old one until the trees in the existing harvest unit are established (4.5 feet tall, and free 

to grow), as required by existing regulations. In some cases (especially in areas subject to catastrophic 

windstorms) adjacent units may only be 10 or 20 years apart because the risk of blowdown results in not 

leaving an area of old growth between units. This has some positive and negative effects. On the one 

hand, concentrating harvest in a smaller area reduces fragmentation and allows wider travel corridors to 

be maintained. Also, it reduces the problem of blowdown, assuming the new unit is placed correctly in 

regards to the wind. On the other hand, it can lead to larger areas of young-growth forest, which can 

reduce the usefulness of portions of the area to some wildlife species, including generalist species that 

like edge habitat. 
Appendix H

Final EIS H-123 Comments and Responses

Comment: Several comments pointed out that the north half of the Tongass has a very different 

ecosystem from the south half of the Forest and should be looked at differently when it comes to 

timber harvest. The north part of the Forest is slower growing and there are only a few small mills 

to support. Some also noted that communities in the south are dependent on timber harvest 

while those in the north are more dependent on recreation and tourism. 

Response: The seven alternatives considered in detail in the Final EIS provide a wide range of options 

for management of the Forest. Most alternatives recognize that the south part of the Forest has more 

accessible and economically viable timber stands and this is reflected in how the timber LUD is allocated. 

Modeling assumptions in the Spectrum model also reflect higher growth rates and timber volumes and 

lower logging costs in the south part of the Forest. The decision maker also has the option of making a 

decision that could further recognize the differences between the north and south halves of the Forest. 

The regional economy is discussed in detail in the Subregional Overview and Communities section of the 

Final EIS. 

Comment: One respondent stated that they understand pine is being replanted on the Tongass 

and requested that the Forest Service at least plant native species. 

Response: Very little pine, if any, is planted on the Tongass. Only native tree species (using local seed 

sources) are planted. Most regeneration is from natural seeding from trees adjacent or within the harvest 

unit. This is discussed on page 3-245 of the Draft EIS. While the Tongass does contain one native pine 

species, the Forest Service is not aware of it ever having been planted for timber production. 

Comment: One respondent requested that the Forest Service supervise all timber sales on NFS 

lands and not privatize this task. The comment also stated that helicopter loggers should be 

required to clean up areas they use. 

Response: Forest Service directly oversees all timber sales on the Tongass National Forest. All timber 

sale contracts specify the cleanup required. 

Comment: One comment expressed concern about the scaling practices used by the Forest 

Service and suggested that corrupt scaling practices may have resulted in larger harvest areas. 

The comment also questioned whether the Forest Service has an accurate picture of the 

harvested areas on the Forest. 

Response: The comment provides no detail about the alleged “corrupt” scaling practices employed by 

the Forest Service and, therefore, it is not possible to provide a detailed response other than to say that 

the Forest Service is not aware of any “corruption” in the way it scales logs. The Forest Service 

conducted a detailed analysis of the Tongass National Forest as part of this overall Forest Plan 

amendment process. This included mapping productive forest land on the Tongass based on existing 

NEPA analyses, aerial photographs, LiDAR, LANDSAT, and GIS data, and local knowledge. 

Comment: One comment stated that logging slash should be removed and noted slash is burned 

or chipped in Washington and Oregon. 

Response: Leaving woody debris (logging slash) on site retains important wildlife habitat components 

and nutrients. Burning slash would release carbon into the atmosphere and would be out of place in an 

environment that does not normally have fire. Chipping slash would be costly and would not result in any 

meaningful benefit since fire risk is very low in Southeast Alaska. Slash is treated in Oregon and 

Washington in areas where fire risks require fuel treatment but many areas no longer burn (or chip) slash 

because fire risks are low. This is the case, for example, in most areas west of the Cascades in 

Washington. 
Appendix H 

Comments and Responses H-124 Final EIS 

Comment: One comment opposed all logging until surveys of wildlife, rainfall, tree growth, and 

soils have been completed. Another comment recommended that a watershed analysis be 

completed prior to every timber sale. 

Response: Site-specific analyses required prior to timber harvest include wildlife surveys and vegetation 

surveys, including tree growth sampling to validate the growth potential of each site where harvest is 

being considered. Soil surveys have been completed for the Forest and these surveys are groundtruthed for individual project areas as part of the analysis prior to approving timber harvest. Watershed 

analyses are completed prior to a timber sale when the existing level of disturbance indicates the need. 

Comment: The Forest Service should use all tools available for managing timber, such as the 

size-density model and the Marxan Model. 

Response: The size-density model is a potentially useful tool that the Forest is currently developing and 

it was used in the analysis presented in the EIS. The Forest is also looking at the Marxan Model and 

other tools. 

Comment: One comment requested that the Forest Service restore the timber volume class 

designations 1-7 in the Proposed Forest Plan. The comment stated that the system used to 

replace these classes is much less precise. 

Response: Volume classes 5, 6, and 7 were combined because there is no significant difference 

between them. This is discussed on page 3-244 of the Draft EIS. 

Comment: Several comments stated that local industry has done a poor job of managing their 

lands. Extensive harvest on private lands has adversely affected subsistence, wildlife, and 

streams and other resources. 

Response: The Forest Service has no control over management of non-NFS lands. The impacts of 

management practices on adjacent lands are evaluated in the Cumulative Effects discussions presented 

for each resource, as appropriate. 

Comment: Some comments stated that they have confidence in the Forest Service to manage 

public forest resources. One comment expressed support for the Forest Service, but suggested 

that the Forest Service also consider private sustainable forestry projects, such as the Pioneer 

Forest in Missouri. 

Response: Thank you for the expression of confidence. The Forest Service continues to conduct 

research and develop new management approaches and strategies. The management of private lands is 

outside the Forest Service’s jurisdiction, but innovations in other areas may be applicable to land 

management on the Tongass. 

Comment: One comment recommended that Congress establish a dedicated timber reserve on 

the Tongass. 

Response: Congressional actions are beyond the scope of this Forest Plan amendment process. 
Appendix H

Final EIS H-125 Comments and Responses

Transportation and Utilities 

The Transportation and Utilities comment and response subsection is divided into the following 

categories: 

• Roads 

• Transportation and Utility Corridors 

• Energy and Utilities 

Roads 

Comment: Some respondents expressed concern about the large backlog of maintenance work 

that needs to be completed and thought that roads should be the focus of restoration. They 

believe that the EIS should include transportation alternatives that look at various reasons to 

deconstruct existing roads and limit new road construction, such as protecting wildlife habitat, 

saving maintenance money, and protecting watersheds and fish. 

Response: The Forest is working through the Roads Analysis Process and Travel Management 

planning to identify the roads that will be needed in the future and those that should be closed, as well as 

to identify and correct road problems, including fish passage. Both of these processes include extensive 

public participation. The Draft EIS did not include alternatives for managing the existing road system 

because this issue is being dealt with at the local level. The issue identification process for this EIS is 

discussed in the Public Issues section of Chapter 1 of the EIS. Using the Roads Analysis Process and 

Travel Management planning, the Forest has already decommissioned approximately 100 miles of roads 

and placed into storage a significant portion of the road system. The Forest used the roads analysis 

process to identify maintenance needs and prioritize funding to deal with the most serious problems first. 

Comment: Concern was expressed about the use of road storage. One comment stated that 

storage can be a valuable tool that is a vast improvement over past abandonment practices, but, 

at its worse, storage can fail to prevent erosion and resource damage. They note that repeatedly 

opening and closing roads harms wildlife and introduces “pulses of sediment” into watersheds. 

Another comment noted that storing roads has limited effectiveness.

Response: Roads are placed into storage when there is a long-term need for the road but the road will 

not be needed in the near-term. In the past, these roads were left open and often revegetated naturally, 

which in effect closed them to vehicle use. However, culverts sometimes plugged and this has led to 

roads washing out. There have also been other erosion problems and fish passage problems with many 

of these roads. Placing roads in storage restores natural drainage where needed and corrects erosion 

problems. Roads may remain in storage for one or several decades. The intent is not to repeatedly open 

and close them, as the comment implies. These roads quickly revegetate reducing the fragmentation that 

roads can cause. Alder often dominates old roadbeds, which adds nitrogen to the soil and helps forbs 

and other understory vegetation grow. As noted in the Final EIS, recent research indicates that areas 

with alder provide high-value forage areas for deer. It is true that when they are reopened, some 

sediment may be released but there is much less disturbance than would be the case with new 

construction. We believe that road storage is a valuable strategy for managing the road system. 

Comment: Concern was expressed about the long-term impacts of temporary roads, especially 

sediment produced in the first 5 years. Others suggested that the Forest Service consider the use 

of lower impact temporary roads instead of “spec” roads. 

Response: We agree that temporary roads can cause sediment problems and that these roads should 

be constructed correctly and closed as soon as practical following completion of the project that they were 
Appendix H 

Comments and Responses H-126 Final EIS 

constructed for. This was not always done in the past. The Forest generally proposes lower impact 

temporary roads in areas where long-term access is not needed. 

Comment: Some believe that the Plan Amendment is not consistent with ANILCA provisions of 

off-highway use as all areas will be closed to OHV use unless designated open. ANILCA requires 

that all areas be open for subsistence use, subject to reasonable regulation. 

Response: The Plan Amendment will have no effect on this issue. Each Ranger District on the Tongass 

is analyzing how to provide reasonable access for subsistence and other uses in their Travel 

Management Plans and accompanying NEPA documents. The Draft EIS simply discussed what the 

National OHV rule states and the process for determining which areas and roads would be designated 

open. Each District will work with the state and local governments, tribes, and the public, as required by 

NEPA. The standard in the Final Proposed Forest Plan has been updated to state: “Each ranger district 

will designate the roads, trails, and areas open to motor vehicle use on a motor vehicle use map. All 

operations must be in accordance with those designations.” 

Comment: One comment stated that the conservation community may support some extensions 

of the road system into the margins of adjacent roadless areas on a case-by-case basis as long as 

connectivity is maintained. 

 

Response: All alternatives except the revised Alternative 1 allow the extension of existing road systems 

and new road construction in roadless areas. Alternatives 2 and 3 would restrict these road extensions to 

lower value roadless areas. Refer to the alternative descriptions in Chapter 2. 

Comment: One comment requested that the Forest Service require all roads to be constructed 

above grade and prohibit road-related alterations to natural surface water or ground water. 

Response: The Forest has many different site-specific situations where it is best to construct roads 

either “above grade” or “below grade”. The design and standards of roads are site specific and should be 

addressed and commented on during the planning phase at the project level under NEPA. The Forest 

will continue to coordinate management actions with the Alaska Department of Environmental 

Coordination (ADEC) and ADF&G in the implementation of existing BMPs and development of new 

BMPs. 

Comment: Some comments expressed the desire for road access to the forest. Others noted the 

importance of roads originally built for timber harvest that connect communities. 

Response: All alternatives include retaining existing roads and construction of new roads as needed for 

each alternative. The Draft EIS (page 3-229) acknowledges that the existing transportation system that 

connects communities was originally constructed largely in support of timber harvesting. 

Comment: One respondent thought it would be more helpful for the Final EIS to display average 

road density in the individual VCUs with past harvest or proposed new harvest by alternative, and 

not include VCUs with no development in the average density calculation because this skews the 

average.

Response: The EIS displays existing and projected future road densities in many ways other than 

simple averages. In the Fish section, Table 3.6-8 presents average road densities for NFS lands, for nonNFS lands, and for all lands combined, under existing conditions and under each of the alternatives. As 

the comment implies, these averages are Forest-wide so they include areas with and without 

development. Since there are almost 950 VCUs on the Tongass, it would take many pages to present 

this information by VCU. Table 3.6-9 was developed (in lieu of presenting a catalogue of VCU road 
Appendix H

Final EIS H-127 Comments and Responses

densities in a multi-page table) in order to provide summary information on the number of VCUs on the 

Tongass that have different road densities by placing each VCU into road density categories and then 

calculating the percentage in these categories. Each VCU was placed into one of six road density 

categories, ranging from 0 miles per square mile to >4 miles per square mile. This was done for existing 

conditions and for future conditions under each alternative (after 100+ years). It was also done for NFS 

lands only and for NFS and non-NFS lands combined. If the reader wants to determine the exact number 

of VCUs in each category, the total numbers of VCUs used in the calculations are presented in footnotes 

at the bottom of the table and can be multiplied by the percentages in the table to calculate actual 

numbers of VCUs. 

In addition, Table 3.10-10 at the end of the Wildlife section in the EIS presents the same information by 

WAA for both NFS lands and NFS lands combined with non-NFS lands. Further, it also presents the 

same information for open roads (those that are maintained as open for vehicle traffic). 

Transportation and Utility Corridors 

Comment: Some respondents felt that the Final Proposed Forest Plan should include all 34 road 

and utility corridors in the State’s Southeast Alaska Transportation Plan. They noted that the draft 

plan does not include 8 of the 34 corridors. They felt that the regional intertie system will allow 

communities to switch from diesel to low-cost, environmental friendly energy and surplus energy 

could be exported. They requested that the Plan state that hydropower and other renewable 

energy development is a legitimate, authorized use on the National Forest. 

Response: One of the stated goals of the Proposed Forest Plan (page 3-143) is: “To provide for, and/or 

facilitate the development of, existing and future major public Transportation and Utility Systems.” The 

EIS specifically mentions those corridors specified in the MOU that the Forest Service and the State of 

Alaska recently signed. Most of these corridors are included in a separate LUD that overrides underlying 

LUDs. Those not included in the Proposed Forest Plan represent alternatives to these corridors or 

appear to be unlikely to be developed during the life of the Forest Plan. The Forest will consider all 

proposals recommended by the State, as well as any reasonable alternative corridors, during project-level 

NEPA analysis. Some additional corridors were added to the Final EIS after further discussion with the 

State of Alaska. 

Comment: One comment stated that given that many of the roads and utility corridors authorized 

by Public Law 109-59 would take priority over all underlying LUDs, including many that do not 

normally allow road construction, it is critically important to fully analyze the cumulative effects, 

along with existing roads, roads proposed under each alternative, roads on non-NFS lands, and 

proposed energy infrastructure under Public Law 109-59. One comment stated that: “the Draft EIS 

fails to analyze the adverse effects of including a road right-of-way across North Baranof. This 

road would cross two large Inventoried Roadless Areas and harm wildlife, soils, water, fish, and 

subsistence. The majority of the road would go through OGRs and the beach buffer. It would 

cross 5 major watersheds, 2 of which are listed as impaired due to sediment. The proposed road 

corridor across Baranof crosses a fault line and the engineering reports indicate it will be closed 

weeks to months each year due to avalanches.”

Response: This Forest Plan Amendment would not approve any of these road and utility corridors. It is 

only ensuring that the option to construct a road or power line is maintained. When a road or power line 

is proposed, it will be analyzed under NEPA, along with reasonable alternatives, including No Action (i.e., 

not building the road), along with the cumulative effects of that project and other foreseeable projects. As 

of this time, the North Baranof road mentioned in the comment is one of many roads that have been 

discussed, but it is not being actively analyzed. Additional information has been added to the Final EIS to 

examine the cumulative effects of those roads believed most likely to be constructed during the life of the 

amended Forest Plan.
Appendix H 

Comments and Responses H-128 Final EIS 

Comment: Some respondents wanted road and utility corridors north from Angoon to Greens 

Creek, south to Hood Bay, and north to a patented coal mine.

Response: These routes are not listed by the State in their travel management plan. But when a project 

is proposed and examined in detail, other alternatives such as this could be considered. The Forest 

Service is unlikely to support major corridors through designated wilderness and such an action would 

require Congressional approval. 

Comment: One respondent asked that we run the utility corridor a little further along Takatz Lake 

as the lake is a potential hydropower source for Sitka.

Response: This option could be considered as an alternative to the State proposal if this project were to 

move forward to the analysis phase. 

Energy and Utilities 

Comment: Some felt that the amended Forest Plan should recognize and address the prohibitive 

cost of regulations contained in the present Forest Service Handbook that limit or prevent 

efficient development, production, and distribution of energy resources. Identified constraints 

included stream buffers and scenery protections, required appraisals and acquisition of timber in 

proposed corridors. One comment also noted that, due to the high administration costs, small 

projects should be exempted from regulation. 

Response: Utility development is an important use of the National Forest; however, laws and regulations 

governing the use of NFS lands apply to all projects. 

Comment: Some respondents felt that the amended Forest Plan should identify existing and 

potential hydroelectric resources and federally recognized watersheds, reserves, or permit areas. 

Areas of identified concern included the Soule River and North Fork River valley and drainage and 

the Thayer Creek Hydro Reserve

Response: As noted earlier, the Final Proposed Forest Plan supports development of hydroelectric 

resources. Each project needs to be evaluated individually on its own merits. As noted in the 

Transportation and Utilities section, the Thayer Creek hydroelectric facility and transmission line are 

authorized by Congress and are currently being analyzed in a separate EIS. 

Comment: Some comments stated that the Forest Service failed to adequately address energy 

development opportunities and that the Plan should prioritize the energy resources on the Forest. 

One comment believed that ANILCA provided the legal mechanism to implement less expensive 

corridors. 

Response: Potential and ongoing energy developments are discussed in the Draft and Final EIS 

documents. Sufficient guidance under allowable uses as defined by the LUDs is contained within the 

Plan itself and procedures and permit processes are in place for such development. As noted in the Final 

Proposed Forest Plan, the corridors within the Transportation and Utility LUD take precedence over 

underlying LUD standards and guidelines. 
Appendix H

Final EIS H-129 Comments and Responses

Wetlands 

Comment: Concern was expressed that the Proposed Forest Plan that accompanied the Draft EIS 

proposed to eliminate protections for forested wetlands covering more than 100,000 acres without 

disclosing the effects of this change.

Response: We assume that this comment refers to the organic soils discussed in Appendix B 

(Information Needs) in the 1997 Plan: Maybeso, Kaikli, Karheen, and Kitkun Soil Series. Additional 

information on the timber productivity and response to harvest on these soils was listed as a need. The 

1997 ROD stated that information related to the effects of timber harvest on these soils was incomplete 

and harvest was to be avoided on these soils until the ongoing research study of these issues was 

complete, at which point the decision would be reevaluated (or earlier if monitoring information 

warranted). In 2000 the Forest issued a report on this study and the Forest Supervisor issued a decision 

stating that these soils were suitable for timber production. The Plan Amendment does not propose any 

change to the existing standards and guidelines for these soils. 

Wildlife, Biodiversity and Plants 

The Wildlife, Biodiversity and Plants comment and response subsection is divided into the following 

categories: 

• General 

• Conservation Strategy 

• Old-Growth Mapping 

• Legacy and Goshawk/Marten Standards and Guidelines 

• Population Viability 

• Management Indicator Species 

• Wildlife Cumulative Effects 

• Restoration and Young-Growth Management 

• Threatened, Endangered and Sensitive Species 

• Endemic Species 

• Birds-General 

• Marbled Murrelet 

• Goshawk 

• Marten 

• Wolf 

• Deer 

• Elk 

• Brown Bear and Black Bear 

• Plants 

General 

Comment: The Draft EIS contains an inadequate discussion of the effects of climate change on 

Tongass fish and wildlife and should include a full analysis of climate change impacts on forest 

species and habitat distribution, including how climate change will alter the amount and 

distribution of old-growth. 

Response: A discussion of the impacts to wildlife species from climate change has been expanded in 

the Final EIS text. Climate change is described in general terms due to the many unknowns surrounding 

its anticipated effects, though specific examples are brought forward. Discussion of potential changes in 

the amount and distribution of old-growth is also provided in the Timber and Biodiversity sections of the 

Final EIS. Also see comments and responses in the Climate and Air section of this appendix. 
Appendix H 

Comments and Responses H-130 Final EIS 

Comment: Timber harvest can result in the loss of habitat for deer and bear which are important 

to the lives of the local human population. 

Response: Effects to deer and bear habitat are discussed in the Wildlife section of the Final EIS; effects 

to subsistence and subsistence resources is discussed in the Subsistence section and by community in 

the Subregional Overview and Communities section of the Final EIS. Note that timber harvest affects 

deer and bear habitats, but rarely would result in a complete loss of habitat. 

Comment: A number of comments were received suggesting topics for future research. Topics 

included studies of Kuiu Island marten to assess implications of forest management practices and 

possible mitigation measures, marbled murrelet habitat associations, and how different structural 

and compositional attributes of old-growth forest affect wildlife species. 

Response: Appendix B of the Final Proposed Forest Plan addresses information needs including 

processes for prioritization and updating such programs. This framework is an ongoing process and our 

intent is to develop a Web-based tool to better facilitate sharing information among the many state and 

federal agencies, academia, and other entities involved in the study and research of Tongass National 

Forest topics. 

Comment: Habitat changes associated with forest harvest are temporary, with rapid recovery for 

such variables as amounts of edge and cover for hiding and dispersal; the plan contains limited 

recognition of these relationships or their contribution to habitat quality. 

Response: Temporary is a relative term. For some species, such as black-tailed deer, recently 

harvested units provide suitable habitat in the years immediately following timber harvest due to 

increased forage production. However, these stands provide relatively low value after about age 25 and 

until about age 75 years or beyond, when forests are in the stem exclusion stage of stand development, 

which is characterized by small, dense trees with little understory vegetation. For some other species, 

harvested units provide little value until they regain old-growth characteristics either because of specific 

structural elements (e.g., large woody debris) found in these stands, or because of the presence of prey 

populations that are dependent on old-growth. Once stands transition out of the stem exclusion stage, 

they begin to provide the components of good quality wildlife habitat, including larger trees, small canopy 

gaps, snags and downed logs. This can begin to occur as early as age 50, however, the literature 

suggests that stands do not begin to take on the characteristics of old growth until they reach at least 150 

years of age (Alaback 1982). As discussed in the Timber and Wildlife sections of the Final EIS, active 

management of young-growth stands may reduce this time to some extent. 

Comment: Growing recreation and other resource needs on the Tongass require better 

identification of the value of non-forested resources (e.g., high elevation, beach fringe, and 

wetlands). For example, Aleutian tern, arctic tern, and black oyster-catcher use areas should be 

identified and protected from disturbance. Special protection should also be given to watersheds 

that encompass beach meadows, a rare habitat type in Southeast Alaska, and peri-glacial 

habitats. 

Response: Beach and Estuary Standards and Guidelines are provided in the 2007 Forest Plan as well 

as in all of the 2008 Final EIS alternatives. In the 2007 Forest Plan and the 2008 alternatives (except for 

Alternative 7, which has a reduced Beach and Estuary buffer of 500 feet, a 1,000-foot buffer provides a 

high degree of protection for shoreline and marine habitats. These standards and guidelines emphasize 

the protection and maintenance of the ecological integrity of shoreline and shoreline forest habitats for 

shorebirds, other marine-associated species, and the many upland species that make high use of these 

habitats. In addition, the Riparian Standards and Guidelines address the protection of streamsides, 

lakes, and ponds, wetlands, other non-forested habitats, and floodplain/glacial outwash habitats. The 

Final EIS shows that recreation is a large and growing use of the Forest. However, this analysis effort is 
Appendix H

Final EIS H-131 Comments and Responses

being conducted in primarily in response to the August 2005 Ninth Circuit Court of Appeals Court 

Decision, which directed the Forest to take a second look at timber demand, the alternatives considered 

in response to timber demand, and cumulative effects. Therefore, the scope of the analysis focuses 

primarily on forested habitats that are likely to be affected by timber harvest and associated activities. 

Comment: One comment stated: “We are very disturbed about discussions we are hearing about 

between the timber industry, the Forest Service, and others regarding the need for “intensive” 

timber management within the matrix lands. These conversations are happening outside the 

public arena in violation of NEPA, and appear to be based on the desire to increase timber 

economics rather than scientifically based publicly reviewed decisions. We consider the use of 

adaptive management to increase timber economics an extreme abuse of power and in clear 

violation of the numerous laws and public trust responsibilities the agency has.” Another 

commenter was concerned about the Forest Service’s move toward “intensive management” 

because the result of multiple entries into previously harvested units has often resulted in the 

creation of “creeping mega-cuts” which destroy wildlife corridors. 

Response: The Forest Service meets with, and discusses ideas with, a wide range of stakeholders, 

including the State, local governments, industry groups, and environmental groups. The Forest is 

interested in developing economic timber sales and is willing to listen to ideas on how best to develop 

economic sales, while maintaining consistency with the Plan’s goals and objectives, meeting the Plan's 

standards and guidelines, and being compliant with all laws and regulations. Modifications to certain 

standards and guidelines are being considered in some alternatives, but none of the alternatives include 

“intensive” timber management. 

The “creeping mega-cuts” that the commenter refers to are a characteristic of logging that took place 

primarily in the 1960s through the 1980’s, as well as more recently on some private lands. The adoption 

of the 1997 Plan created many “checks and balances” that result in avoidance of this situation on NFS 

lands. Adjacency requirements and watershed protection standards limit the size of clearcuts under all 

alternatives, and Class I, II, and III stream buffers, old-growth retention requirements, and many other 

standards and guidelines also limit opening size and total harvest acres per watershed. Even under 

Alternative 7, which includes the most intensive harvest among the alternatives, about 62 percent ((1.3 

million of the 2.1 million acres) of the old growth within the matrix (development LUDs) would not be 

harvested, even after 100 or more years of harvesting at the maximum rate allowed by the alternative 

(see Table 3.9-12 in the Biodiversity section). This is in addition to the 2.8 million acres of old growth 

protected by reserves (non-development LUDs) under Alternative 7. 

Comment: Fish and wildlife belong to the states and therefore identification of management 

objectives should be done by the State of Alaska and not the Forest Service. 

Response: The Forest Service is responsible for setting management objectives for fish and wildlife 

habitats on NFS lands, including ensuring adequate habitat is maintained on the Tongass National Forest 

to sustain viable and well-distributed populations, as required under the NFMA. The Forest Service does 

work closely with the State of Alaska on joint matters related to management of fish and wildlife. 

Comment: Roadless areas are crucial to the protection of the Nation’s wildlife, fisheries, and 

water resources. 

Response: We generally agree with this statement. However, what is more important is how the lands 

within roadless areas are managed through time. It is a primary purpose of forest planning to determine 

how best to balance the multiple-use objectives for all NFS lands, including those which are roadless. 

Over 90 percent of the Tongass is considered roadless; thus roadless areas are not a rare commodity on 

the Tongass, in contrast with roadless areas found in the national forests located in the lower 48 states. 
Appendix H 

Comments and Responses H-132 Final EIS 

Comment: Section II.H of the Wildlife Planning Standards and Guidelines do not require action 

until risk to long-term persistence is determined to exist. Also, the standards and guidelines 

assume that species abundances are known, but this is rarely the case on the Tongass, and the 

standard and guideline does not consider distribution. 

Response: These standards and guidelines require evaluation of that species for designation as a 

Regional sensitive species by the Regional Forester, should a significant population or habitat decline 

occur. This does not preclude action being taken prior to that point. Additionally, they require 

coordination with state and other federal agencies where species concerns may be addressed well before 

they reach sensitive-species designation status.

Comment: We must preserve the ecological diversity of the forest, fauna, and salmon. 

Response: The Forest Service agrees and strives to provide multiple resource uses while maintaining 

biological diversity. 

Comment: To the extent possible, implementation of conservation measures should be flexible 

enough to enable tailoring them to site-specific conditions and facilitate design of economically 

feasible timber sales. Measures may vary from area to area to reflect different species 

concentrations and sensitivities, and to concentrate timber harvesting in intensively managed 

areas rather than dispersing harvest throughout the forest. Intensive timber management which 

minimizes the area affected by timber harvesting will have the least impact on conservation 

values and the best chance for broad public support. 

Response: Standards and guidelines presented in the Forest Plan are purposefully general in some 

instances in order to allow site-specific conditions to influence their application. See also the comments 

and responses in the Timber section of this appendix. 

Comment: As part of the The Nature Conservancy (TNC)-Audubon Alaska (Audubon) 

conservation assessment biological values and risks for focal resources (e.g., large trees, salmon 

habitat, deer habitat) were evaluated within each biogeographic province. An index of relative 

biological value, defined as the percent contribution of each biogeographic province to the total 

distribution of habitat values for each species or ecological system. Given that this suite of focal 

resource targets represents a range of terrestrial, freshwater, and nearshore marine ecosystems, 

this index provides a reasonably robust ranking of biological values associated with coastal 

forest ecosystems. Several comments suggested that the Forest Service incorporate the major 

elements of the conservation assessment and strategy, developed by Audubon and TNC (Albert 

and Schoen 2007), into the Final Proposed Forest Plan. This design is intended to provide 

watershed-scale protection to the highest ecological value intact watersheds in each 

biogeographic province on the Tongass and also maintain core areas of ecological value in a 

selection of the highest value modified watersheds. Rather than distributing timber harvest and 

road building across the entire forest, this design works to aggregate these activities in fewer 

watersheds. Comments from TNC and Audubon note that subsistence and community use areas 

were not incorporated into the design and that the conservation design should be fine tuned to 

incorporate these resources. 

Response: Information from the TNC-Audubon conservation assessment has been incorporated into the 

Final EIS as appropriate to strengthen the biodiversity analysis, and in the modification of alternatives. 

The Biodiversity section also provides more extensive quantification of the existing levels of large-tree 

POG, high-volume POG, karst POG, and intact watersheds by biogeographic province; it also makes 

projections for these measures into the future under each alternative, on NFS lands and cumulatively, for 

all of Southeast Alaska. The alternatives considered in the Final EIS were not designed around the Albert 

and Schoen (2007) report, but Alternatives 1, 2, and 3 take into account some of the considerations 
Appendix H

Final EIS H-133 Comments and Responses

raised in that report. The Biodiversity section cites Albert and Schoen (2007) throughout the subsection 

that describes the forest-wide distribution of old-growth; however, while the Audubon and TNC 

assessment provides a summary of recent literature related to individual wildlife species, the Wildlife

section incorporates information from individual studies, citing them directly. 

Comment: The original 21 biogeographic provinces were based largely on topographic features 

and generalized information about biotic communities in Southeast Alaska, rather than scientific 

research. This Amendment incorrectly states that the original biogeographic provinces were 

based on conclusions drawn about similar species comparisons. Alternative biogeographic 

provinces have been proposed that do rely on peer-reviewed scientific research. 

Response: The respondent appears to have drawn an incomplete conclusion from how biogeographic 

provinces are described in the EIS. The description summarizes that they are generally characterized by 

similar wildlife species composition, similar distribution of wildlife species, geologic and water barriers 

resulting from glaciation and other events, and generally similar climatic conditions and physiographic 

characteristics. It is recognized that these provinces are a broad land classification. It is useful to 

continue using the same classification for comparison with the 1997 Final EIS and it is very similar to the 

provinces used in the TNC-Audubon conservation assessment. 

Comment: The Biodiversity section focuses on timber and forest management and addresses 

biodiversity from an ecosystem-level perspective. It should address species and genetic 

biodiversity. 

Response: As stated in the Biodiversity section, conserving biodiversity is about maintaining genetic, 

species, community or ecosystem, and landscape levels of biological organization. As the respondent 

noted, the Biodiversity section addresses conservation of species and other elements of biodiversity by 

using a broader “coarse filter,” or ecosystem/landscape based strategy for conserving biological diversity. 

Finer scales of biodiversity (i.e., individual species and genetics) are addressed in the Wildlife, Plant, and 

Fish sections of the Final EIS. 

Comment: In the Biodiversity section, the first paragraph of the Old-growth Conservation 

Strategy subsection of the Affected Environment states “Approximately 78.5 percent, or 13.2 

million acres, of the Tongass is in Wilderness or mostly natural settings...” These statistics 

mislead rather than contribute to the discussion of the conservation strategy because the focus of 

the strategy is on old-growth and very little old-growth occurs under these designations. This 

statement does not belong here at all. 

Similarly, the next paragraph states “approximately 85 percent of the old-growth existing in 

1954...” This statement presents statistics for the broadest of forestland categories, old-growth, 

by including both POG and non-POG. The real threat is to POG and therefore this statistic should 

include only POG. 

Response: Although these portions of the Biodiversity section have been revised in the Final EIS, it is 

appropriate to discuss both the percentage of all lands and the percentage of POG within reserves. 

Secondly, old-growth percentages that are discussed do represent only POG – all of the percentages 

given for old growth in the effects analysis are for POG or a subset of POG (e.g., large-tree POG). 

Comment: The sections of the Draft EIS that discuss biodiversity and wildlife are largely devoid 

of any analysis and clearly do not meet the hard-look standard required by NEPA. 

Response: The Biodiversity and Wildlife sections in the EIS take into account the best scientific 

information available. Extensive quantification of effects using GIS analysis, habitat modeling, and forest 

management modeling, an inventory of harvest and road development on all lands of Southeast Alaska, 
Appendix H 

Comments and Responses H-134 Final EIS 

along with future development projections, and the application of expert wildlife viability panels. 

Nevertheless, the analysis presented in the Draft EIS was expanded substantially for the Final EIS and 

we believe these analyses are adequate. 

Comment: For the discussion of forest “composition, structure, and function” the introductory 

section of the Draft EIS Biodiversity section refers the reader to sections of the 1997 Final EIS. 

This is confusing because much of that information has been updated on the following pages of 

the Draft EIS. 

Response: It is true that much information with respect to biodiversity has been updated since 1997. 

The definitions of composition, structure, and function, however, have not changed from those given in 

the 1997 Final EIS, which is appropriately incorporated by reference because it includes further 

information on these components of biodiversity that might be of interest to the reader. What has 

changed, however, is how we take these ecosystem components into account. For example, the Size 

Density Model (SDM) is now available for use in the biodiversity analysis. Thus, the discussion in the 

Biodiversity section referenced in the comment differs from that in the 1997 Final EIS.

Comment: In contrast to parts of the world where significant logging has occurred, the Tongass 

can be an example of how sustainable logging can be conducted on public land, not only for 

Southeast Alaska, but for the world. 

Response: We agree. The Tongass strives to manage a timber program that is sustainable, while 

providing for sustainability of multiple other resources. 

Comment: The Draft EIS is incorrect in stating that logging will be concentrated in four 

biogeographic provinces; this is not true because all alternatives allow intensive logging under 

Timber Management as well as less intensive but still consequential logging in the Modified 

Landscape LUD. 

Response: The majority of harvest would remain “concentrated” in these four biogeographic provinces. 

However, under some alternatives, logging and road construction would be more extensive in areas 

outside of these provinces. Alternative 1 would not enter any inventoried roadless areas whereas 

Alternative 7 proposes to harvest the most timber from roadless areas. The commenter also appears to 

be confusing biogeographic provinces with LUDs. 

Comment: Increased predation occurs in logged area because there are so many more small 

mammals in those areas. This is good for raptors, etc. The Forest Service even issued an alert in 

the 1960s because they were alarmed at the dramatic increase in mice in clearcuts. The mice 

were allegedly eating too many of the tree seeds. 

Response: It is true that timber harvest can benefit some species while adversely affecting others. 

Comment: One respondent was very disappointed to see that National Monument Lands, which 

are fully protected from timber harvest, had relatively low value to wildlife and felt that the Forest 

Service depicted the alternative maps deceivingly. Another respondent made a similar comment 

about the inclusion of low value habitat in Wilderness and LUD II designations. 

Response: The wildlife values depicted across the Tongass, including those within National Monuments, 

are reasonable. A National Monument is an area of land that is set aside to preserve some feature of it 

that makes the land important. This may include anything from scientific or historical interests to scenic 

beauty and wildlife protection. There are two National Monuments on the Tongass: Misty Fiords and 
Appendix H

Final EIS H-135 Comments and Responses

Admiralty Island. National Monument Lands are created by presidential proclamation, not by the Forest 

Service, thus the alternative maps depict these areas as they have been designated. Although Misty 

Fiords contains large expanses of non-forested lands, Admiralty National Monument represents one of 

the highest value habitat areas in all of Southeast Alaska. It contains the second highest acreage of POG 

among all provinces in Southeast Alaska (598,000 acres). The vast majority of Admiralty Island remains 

intact and, as a result of the abundance of POG in this province, including high-volume and large-tree 

POG, it represents a massive reserve and reservoir for biological diversity in Southeast Alaska. In 

addition, Wildernesses and LUD II areas are highly variable in terms of their wildlife habitat values and 

availability of POG. The Karta Wilderness and the Nutkwa LUD II area on Prince of Wales Island contain 

very high fish and wildlife habitat values and extensive areas of POG. 

Comment: The Tongass manages one of the largest island archipelagos in the world and 

nowhere is this important point emphasized in the Proposed Forest Plan or Draft EIS, particularly 

in the description of the forest in Chapter 2. 

Response: The point that the Tongass is an island archipelago is discussed in the Biodiversity and 

Wildlife sections of the EIS. The extensiveness of the island archipelago is also described in the 

description of the forest in Chapter 1. 

Comment: There is very little young-growth on the Tongass. Converting a small portion of the 

old-growth to young-growth will actually add to biodiversity (i.e., broader more balanced 

distribution of forest age classes). 

Response: At a landscape-scale, old-growth forests on the Tongass are highly diverse, typically 

including heterogeneous stands of productive forests within a mosaic of unproductive forests and nonforested areas comprised of shrub and herbaceous plant communities. They are also diverse at the 

stand-level, possessing structural attributes that provide habitats for a variety of species such as live oldgrowth trees, dead standing trees (snags), fallen trees/ logs, and an overstory consisting of multiple 

canopy layers; they also have smaller understory trees, canopy gaps, and patchy understories. Timber 

harvest reduces this diversity by creating a more uniform stand of young-trees. Old-growth forests can 

also provide ecological functions that are lacking, or less developed, in younger stands. There are 

opportunities to manage the more than 400,000 acres of young stands on the Tongass to increase 

biodiversity, which are described in the Timber, Biodiversity, and Wildlife sections of the Final EIS. 

Comment: The Tongass National Forest should work with private and state forest managers in 

developing unified definitions and inventories for old-growth forest types, and accurately monitor 

their abundance and rates of change. 

Response: The Forest Service routinely collaborates with other agencies and private landowners. 

Comment: The Draft EIS does not disclose the sources and reasons for its assumptions that POG 

originally comprised 50 percent of all non-NFS lands and that 25 and 50 percent of the remaining 

private and state-owned lands, respectively, will be logged. 

Response: The quantification of POG on non-NFS lands has been refined and is more accurately 

depicted in the Final EIS. Appendix E has been added to the Final EIS which provides a catalogue of 

past harvest, detailing the acres of harvest by owner by biogeographic province and by decade or period 

(where known), in addition to detailed information provided by the State on past harvest. An expanded 

cumulative effects discussion has been added to the Biodiversity section on future harvest on non-NSF 

lands. 
Appendix H 

Comments and Responses H-136 Final EIS 

Comment: One comment expressed concern that slash from helicopter logging could hinder 

wildlife movement. 

Response: Silvicultural prescriptions routinely consider slash disposal requirements in light of resource 

issues which are tracked at the project level. 

Conservation Strategy 

Comment: Some respondents believe that Alternatives 1,2, 3 and 6 have better biological 

locations for the small OGRs, which were identified during the 2006-2007 interagency review effort 

and meet the 1997 Forest Plan Appendix K criteria, and believe that one of those alternatives 

should be selected. 

Response: We agree that the changes made to old-growth reserves in these alternatives are an 

improvement from a biological point of view. 

Comment: To help prevent the need to list the goshawk and wolf under the ESA several 

respondents recommended that the Forest Service select the preferred biological locations for the 

48 other small OGRs as indicated by the interagency Small Old-growth Reserve Work Group 

(particularly if interagency review cannot be completed in time for the Final EIS) and maintain the 

existing elements of the conservation strategy, including the forest-wide network of OGRs, the 

1000-foot beach and estuary fringe, and the existing Goshawk Foraging Habitat Standards and 

Guidelines; it was noted that the old-growth reserve system was cited by the Fish and Wildlife 

Service as reasons that these species did not warrant listing. Some respondents expressed 

concern that eliminating these measures would open the possibility that any decisions made by 

the Fish and Wildlife Service could be remanded. 

Response: Alternatives that eliminate major elements of the conservation strategy are ranked as having 

a lower relative likelihood of sustaining well distributed goshawk and wolf populations. A detailed 

discussion of the existing and proposed changes to the Goshawk Standards and Guidelines is provided in 

Appendix D of the Final EIS. The USFWS published a new finding on the goshawk in November 2007, 

after the release of the Draft EIS. They found that the best available information on biological 

vulnerability and threats to the goshawk does not support listing the Alaska population segment as 

threatened or endangered at this time. This conclusion was based on conservation measures that were 

included in the 1997 Forest Plan. Conclusions from this finding have been considered in the goshawk 

subsection in the Final EIS. 

Comment: The Draft EIS fails to disclose or consider findings and relevant data from recent 

literature or the 2006 Conservation Strategy Review workshop regarding endemics.

Response: .The discussion of endemism has been updated to include the most current literature on 

endemics, including information presented at the 2006 Conservation Strategy Review workshop. 

Comment: A number of comments were received on the adequacy and necessity of the 

conservation strategy. Several respondents commented that the forest-wide conservation 

strategy adopted in the 1997 Forest Plan is an improvement over previous plans but is flawed. 

Some felt that it is overly protective and its value and effectiveness should be peer-reviewed. 

Respondents with this opinion viewed the conservation strategy as simply a way to give other 

agencies a “veto voice” in management of the forest, or felt that congressionally designated 

reserves or other protections (e.g., buffer and retention requirements and state BMPs) were 

adequate protection for plants animals, and landscape connectivity, making other reserves and 

species-specific standards and guidelines unnecessary. Other respondents felt it was a more 
Appendix H

Final EIS H-137 Comments and Responses

than adequate strategy to support well-distributed, viable wildlife populations. Finally, other 

respondents felt that the conservation strategy was not protective enough, stating that the Draft 

EIS does not provide science-based rationale for concluding that the conservation strategy 

continues to be valid. Several of these respondents suggested that the Forest should base 

management efforts on an island-centered model given that the Forest covers one of the largest 

island archipelagos in the world. These respondents felt the Draft EIS fails under NEPA to 

disclose the uncertainties behind the strategy. 

Response: Although many uncertainties remain regarding managing wildlife on the Tongass and the 

effectiveness of the Tongass conservation strategy, the underpinnings of the strategy continue to be a 

valid model for conserving biodiversity on the Tongass. The conservation strategy was developed as an 

interagency effort and was peer-reviewed by independent scientists and natural resource managers using 

their expertise and best available science. The Wildlife section of the Final EIS discloses the existing 

uncertainties surrounding the conservation strategy. Appendix D of the Final EIS provides a summary of 

a review conducted by Haufler (2006) on the developments in the field of conservation science produced 

since 1996, which includes an evaluation of the Tongass conservation strategy. 

Comment: The conservation measures proposed to provide for viability of wildlife species on the 

Tongass are inadequate (i.e., insufficient reserves, inadequate connectivity, too much 

fragmentation), as concluded by a joint statement issued by peer review committee members 

(Kiester and Eckhardt 1994). Any claim made in the EIS that well-distributed, viable populations 

are reasonably assured over the long-term under any of the alternatives is not borne out by 

scientific opinion 

Response: Appendix D of the Final EIS summarizes the development of the conservation strategy and 

peer reviews conducted to date. It provides the rationale behind the reserve-based strategy and 

describes major steps leading to its development, including the pioneering work of the Interagency Viable 

Population Committee (VPOP; Suring et al. 1993) which designed an initial landscape conservation 

strategy they felt was capable of assuring the maintenance well-distributed wildlife populations across the 

Tongass. The joint statement, referred to in the above comment (Kiester and Eckhardt 1994), stemmed 

from an independent review of the VPOP strategy conducted by the Forest Service Pacific Northwest 

Research Station (PNW). This joint statement did identify several weaknesses in the strategy, as stated 

by the respondent. Importantly, however Kiester and Eckhardt (1994, p.3) noted that the PNW Review 

only considered the network of mapped VPOP large and medium HCA’s and Congressionally protected 

areas such as Wilderness, Monuments and Legislated LUD II areas. The VPOP reserve network was not 

examined in the context of the entire Forest Plan or a fully articulated planning alternative containing the 

strategy. The scientists were unable to consider other LUDs that effectively function as reserves and 

conserve the old-growth ecosystem—a very important component incorporated into the development of 

the old-growth habitat conservation strategy in the Proposed Forest Plan and the analysis in the EIS. 

Please see Appendix D of the Final EIS for further discussion of the Forest Service response to the PNW 

review (Suring et al. 1994) and the progression from this response to the development of the final 1997 

conservation strategy. 

Comment: Appendix N of the 1997 EIS should be updated and this information should be 

incorporated into the Final EIS. 

Response: Appendix D of the Final EIS serves as an update to Appendix N of the 1997 EIS and 

includes additional background information used to support the wildlife analysis. 
Appendix H 

Comments and Responses H-138 Final EIS 

Comment: Assumptions that timber harvest impacts on wildlife require restriction such as beach 

buffers, riparian buffers, and OGRs are simplistic because some harvest methods (e.g., selective 

cuts, small clear-cuts) can be conducted in these areas with minimal negative impacts. 

Response: The reserve system serves two important functions in that it provides a means for protecting 

old-growth habitat as well as maintaining landscape connectivity. Though timber harvest can be done in 

a way to reduce effects to wildlife and may improve habitat quality for some species, any level of timber 

harvest increases the amount of habitat fragmentation which breaks large blocks of habitat into smaller 

parcels resulting in smaller and more isolated residual habitat patches. Open spaces left by timber 

harvest can act as travel barriers for some species, thus limiting interaction between subpopulations, and 

increase the risk of predation for other species that venture across them. For species that are sensitive to 

human activity or have restricted mobility, even small areas of timber harvest may create barriers to their 

ability to move across the landscape. A detailed discussion of fragmentation and its effects is included in 

the Biodiversity and Wildlife sections of the EIS. 

Comment: Logging in the beach fringe causes obstructions for wildlife moving through; a 

reduced beach buffer would avoid this situation. 

Response: Heavy log concentrations, such as that left as slash from selective logging, can obstruct the 

movement of larger wildlife species (i.e., deer), but benefit other species by providing places to forage, 

hide, seek shelter, and den. The beach fringe is classified as unsuitable for timber harvest, though a 

limited amount of timber harvest not counting toward the ASQ may occur (e.g., timber sold as part of a 

salvage sale, specialty wood products, for habitat restoration, for customary and traditional uses, etc.) 

Reducing the beach fringe would not reduce the amount of downed wood left from these uses, but would 

be more likely to increase the amount of slash by expanding the area in which timber harvest can occur. 

Comment: Some commenters thought that the ecological rationale for expanding the beach 

buffer to 1,000 feet is not clear. Others felt that the 1,000-foot beach fringe buffer standard and 

guideline should be retained to support viable, well-distributed wildlife populations. 

Response: The beach buffer provided under the current Forest Plan is 1,000 feet and would remain that 

size under Alternatives 1, 2, 3, 4, 5, and 6. None of the alternatives propose to expand it. Under 

Alternative 7 the beach buffer would be reduced to 500 feet. Rationale for this reduction is provided in 

Appendix D. The 1,000-foot buffer requirement was based on the recognized importance of the beach 

fringe zone as indicated by high habitat capability model ratings for a variety of species (bald eagle, 

marten, river otter, brown bears, black bears, and deer), observations of nesting bald eagles and radiotagged goshawks, its high value for landscape connectivity, as well as the available scientific literature. 

The importance of the beach buffer to wildlife is discussed in the description of the affected environment 

in the Wildlife section. 

Comment: Retaining the Tongass Conservation Strategy in its entirety will provide the Forest 

Service with a tool with which it can build ecosystem resilience on the Tongass and manage 

natural resources effectively in the face of climate change. 

Response: We agree that a system of OGRs, various buffer requirements, and non-development LUDs 

are a means for maintaining a level of biodiversity capable of adapting to the effects of changing 

environmental conditions. A statement expressing this has been added to the discussion of cumulative 

effects in the Wildlife section of the EIS. 

Comment: Several respondents suggested that a finer-scale analysis of landscape connectivity 

should be conducted at the level of ecological subsections to identify additional corridors and 

included in a Supplemental Draft EIS. Several respondents identified additional landscape pinch-
Appendix H

Final EIS H-139 Comments and Responses

points or areas where landscape connectivity is an issue and suggested that these areas be 

addressed in the Final EIS; others requested that areas that could become pinch-points in the 

future due to future timber harvest be evaluated. Other respondents were not clear how the initial 

set of pinch-points were selected. 

Response: We recognize that there are a number of additional pinch-points on the Tongass that were 

not addressed specifically in the Draft EIS. We provided a detailed evaluation of those pinch-points that 

were located in areas where a substantial amount of timber harvest has occurred and is likely to occur in 

the future. As noted in the Wildlife section, timber harvest could affect “ecological pinchpoints” or areas 

where habitat conditions, rather than landscape features, facilitate movement across the landscape. The 

detailed level of analysis required to assess effects to these areas is necessarily done at the project level 

when site-specific conditions and project-specific details can be taken into account. 

Comment: Several respondents identified minimizing habitat fragmentation as an important issue 

in developing the Final EIS and Final Proposed Forest Plan. 

Response: Habitat fragmentation is discussed in detail in the Wildlife and Biodiversity sections of the 

EIS. Alternatives that would result in the least habitat fragmentation (i.e., those with the smallest amount 

of timber harvest and road development) were rated as having the lowest level of effects to wildlife 

populations. 

Comment: The timber industry requires about a quarter of the old-growth on the Tongass, which 

would leave the remaining old-growth for the conservation strategy; therefore the Forest should 

eliminate protective measures such as the Marten and Goshawk Standards and Guidelines, the 

old-growth reserve system, and Class III stream buffers, and should reduce the beach buffer.

Response: Providing an appropriate juxtaposition of habitats and ensuring connectivity across the 

landscape (both structural through buffers and reserves and functional through management of matrix 

lands) is essential to providing a functional landscape capable of supporting viable and well-distributed 

wildlife populations. Timber harvest on the Tongass has been disproportionate, focusing on forest stands 

at lower elevations, with the largest trees, and concentrated in certain biogeographic provinces. These 

areas are generally the most productive for wildlife and, therefore, timber harvest has disproportionately 

affected wildlife and habitat in these areas. Thus, simply allowing a quarter of the remaining old-growth to 

be harvested without consideration of the spatial distribution of harvest or provision for the protection of 

important elements within the old-growth ecosystem (i.e., legacy trees or specific forest structural stages) 

would result in further disproportionate effects. 

Comment: The Forest Service should explicitly list the concerns and issues identified by 

scientists during the 2006 Tongass Conservation Strategy Review workshop and identify how 

each was addressed. Many issues appear to not have been incorporated in the Draft EIS or the 

Proposed Forest Plan.

Response: The NFMA planning regulations provide direction to conduct an evaluation of the Forest Plan 

after 5 years of implementation (36 CFR 219.12(g)), including a review of the effectiveness of the Plan’s 

old-growth conservation strategy to conserve biodiversity and prevent the need to list species under the 

ESA. The 2006 Conservation Strategy Review workshop represented the first step in the evaluation 

process, with the purpose of identifying considerations to be addressed in the overall review of the 

strategy. A report documenting the workshop, found in the project record, represents the second step. It 

is one of several documents responding to the Forest Plan review that serve to provide issues and 

information for use in current Forest Plan Amendment process and in managing resources under the 

Forest Plan. 
Appendix H 

Comments and Responses H-140 Final EIS 

Subsequent steps will include an assessment of each consideration identified herein, based on workshop 

information, peer-reviewed scientific literature, the recent Review of Conservation Science Produced 

Since 1997 and Its Relationship to the Tongass National Forest Land and Resources Management Plan

(Haufler 2007), as well as input from various state and federal agencies. These assessments will 

culminate in a determination of how each consideration will be dealt with. Some considerations have 

been addressed in time for incorporation in this Forest Plan Amendment Draft EIS, others in time for 

incorporation in the Final EIS, and others, which might require additional interagency consultation, the 

formation of specialized workgroups, and more detailed development, will be implemented after the Final 

EIS. These long term considerations could lead to conservation strategy-related adjustments to the 

amended Forest Plan through additional amendments or identified as information needs. This effort will 

be summarized in a forthcoming Conservation Strategy Review Proceedings Assessment Report, which 

will include a matrix of the consolidated consideration that will identify how individual considerations will 

be addressed. Additional scientific information presented at the workshop has been included in the Final 

EIS. 

Comment: The Conservation Strategy and Landscape Connectivity discussion in Chapter 2 of the 

Draft EIS incorrectly characterizes Alternative 7 as having a poor distribution of high-quality oldgrowth, given that over 80 percent of the commercial old-growth and over 75 percent of the 

productive old-growth remain and are well scattered across the forest and the wide distribution of 

non-development LUDS, minimum development LUDS, and buffer requirements. 

Response: The conclusion about Alternative 7 was based on what potential results would be over the 

long-term. Alternative 7 would have extensive areas consisting of development LUDs with no reserves 

and a reduced beach fringe for connectivity. Although there would be extensive old growth left within the 

development LUDs as a result of standards and guidelines, the lack of larger patches of old growth, as 

are found in reserves, is the major reason for the conclusion. 

Comment: The forest-wide mapping of small OGRs could impact resources other than wildlife 

and should be fully analyzed in the Final EIS. Project-level adjustments to OGRs should continue 

to be allowed.

Response: Forest-wide small old-growth reserve mapping efforts provided an opportunity to conduct a 

landscape-scale review of the small OGRs. This effort was proposed primarily to develop a consistent 

and more efficient method of review, and to more accurately define the location of small OGRs to 

enhance the Proposed Forest Plan conservation strategy rather than complete the review on a project-byproject basis. The review process involved the incorporation of a biological consensus recommendation 

for each old-growth reserve under review, determined through interagency analysis, and was followed by 

another review that took into account other resource considerations, including timber and timber sale 

economics. Project level adjustments will be considered if significant new information becomes 

available. 

Comment: The conservation strategy does not quantitatively assess the additional amount of 

productive old-growth reserved by restrictions to harvest on high hazard soils and karst lands. 

Response: Standards and guidelines preclude or significantly limit timber harvest in areas of high 

hazard soils, steep slopes (greater than 72 percent), high vulnerability karst terrain, visually sensitive 

travel routes and use areas, and timber stands that are technically not feasible to harvest. The timber 

deferred from harvest by these standards and guidelines is determined at the project level, usually as a 

result of on the ground inspection during project implementation. Although it cannot be precisely 

determined at the forest planning level, the acreage of POG that is set-aside due to oversteepened 

slopes, other areas of very high mass movement potential, and karst , based on digital elevation 

modeling, soils mapping, and geologic mapping. In addition, estimates of the amount of additional 

restrictions that are implemented during a project are included in the Model Implementation Reduction 
Appendix H

Final EIS H-141 Comments and Responses

Factor. These combined reductions are used in all POG predictions and in calculations of the ASQ in the 

Spectrum model (see page 3-261 to 263 in the Draft EIS). These quantifications are used for describing 

and testing of the matrix part of the conservation strategy. The degree of old growth retained within the 

matrix through time, through OGRs, stream buffers, and implementation of standards and guidelines for 

karst, steep slopes and other resource concerns was considered and is a very important component of 

the overall strategy. 

Comment: One comment indicated that the Draft EIS does not provide information necessary to 

evaluate the proposed conservation strategy and does not document the basis for the strategy, 

thereby violating NEPA. Some respondents requested an extension of the public comment period 

until the scientific rationale behind the conservation strategy is presented. The Final EIS should 

include additional discussion for the scientific basis for changes to the conservation strategy. 

Response: The Draft EIS described the framework for the Tongass conservation strategy in detail in the 

Old-Growth Forest Conservation Strategy subsection of the description of the affected environment in the 

Wildlife section. The basis for the conservation strategy and overview of its development was provided in 

the introduction to the Environmental Consequences portion of the Wildlife section, followed by a 

description of what changes to the strategy are proposed under each of the alternatives. An analysis of 

effects of changes to that strategy is provided in general under the Old-Growth Forest Conservation 

Strategy subsection and under individual species where appropriate (i.e., goshawks and marten). The 

conservation strategy was also described and discussed in the Biodiversity section of the Draft EIS. 

Appendix D of the Final EIS elaborates on the information related to the conservation strategy provided in 

the Draft EIS and provides additional discussion of the history and background of the strategy and the 

scientific rationale behind changes. This appendix also provides a comparison between existing and 

proposed plan components. 

Comment: The 2006 conservation strategy review did not allow public participation, either during 

or after presentations, and no final report has been prepared to date incorporating interagency 

review. Scientists comprising the panel of experts did not constitute an independent review body 

and members of the original 1997 panel were not asked to participate even though many continue 

to be leading experts in their field; in contrast there was a high level of participation of Forest 

Service employees without biological expertise. 

Response: The purpose of the 2006 Conservation Strategy Review workshop was to 1) facilitate robust 

discussion among members of an interagency Workgroup and scientific and technical experts regarding 

new information attained since 1997 that may be relevant to the conservation strategy; and 2) generate 

and discuss science-informed “considerations” relative to the strategy. Scientists considered to be 

experts in their fields of study were invited to participate and were charged with the task of conducting an 

independent review of new scientific or other relevant information since 1997, presenting a summary of 

key findings regarding what the new information meant relative to the Tongass conservation strategy, and 

providing “considerations” for the workshop record and the Workgroup to discuss regarding the strategy. 

These presentations were followed by a discussion between the 6-member interagency Workgroup and 

the presenters, and other collaborating scientists. The Workgroup could call on other subject matter 

experts for input as necessary. Sometimes this included experts in resource fields other than biology who 

provided valuable insight into problems encountered when implementing Conservation Strategy 

Standards and Guidelines. A final report summarizing the workshop proceedings, including a written 

record of all discussion attributing comments to individual scientists and listing all considerations, is in the 

project record. The purpose of this report, and the workshop itself, extends beyond this Forest Plan 

Amendment and is intended to assist the Forest Supervisor in considering the need for adjustments to the 

Forest Plan Monitoring Program, Forest Plan standards and guidelines, and aspects of the conservation 

strategy. The results will also guide future investments in research and management studies by the 

Tongass National Forest and its interagency partners. Relevant new science presented during the 

workshop has been incorporated into the Final EIS and some considerations have been addressed as 

part of this effort. 
Appendix H 

Comments and Responses H-142 Final EIS 

The workshop was open to the public and consequently the audience included other subject matter 

experts, not participating in the presentations, and members of the public at large. During specific topic 

sessions, the audience was invited to submit written considerations for the workshop record. The same 

form that was being used by presenters and the Workgroup to describe considerations was provided for 

the audience’s use. All considerations submitted by audience members were included in the workshop 

record. The public was also welcomed to submit considerations relevant to the conservation strategy 

review workshop via the project website which included PowerPoint presentations from the workshop, 

through April 21, 2006. 

Comment: Project-level review of small OGRs that do not meet criteria in Appendix K of the 1997 

Forest Plan should follow the format used by the 2006-2007 Interagency Small Old-growth 

Reserve Work Group (Hansen et al. 2006), including using a standardized review protocol, 

documenting changes made to OGRs, identifying how the proposed changes meet Appendix K 

criteria, assessing the effects of roads in and adjacent to OGRs, and documenting implementation 

of Tongass Plan Implementation Team clarification “Conveyance on Overselected Lands and the 

Old-growth Habitat Land Use Designation;” these items should be included in Appendix K of the 

Forest Plan. 

Response: Appendix K has been revised in the Final Proposed Forest Plan to incorporate the format 

used during the 2006-2007 interagency review. 

Comment: A forest-wide review of medium OGRs is warranted, comparable to that conducted for 

small OGRs by the Interagency Small Old-growth Reserve Work Group. 

Response: There is little indication that such a review is warranted. Appendix D of the Final EIS 

provides a summary of a review conducted by Haufler (2007) on the developments in the field of 

conservation science produced since 1996. The author concluded that “the conservation strategies used 

in the plan are still valid at the present.” New information and knowledge relative to conservation biology 

will continue to evolve. The amended Forest Plan, including the conservation strategy will be reviewed 

again in 5 years and if a more intense review to components of the strategy are warranted it can be done. 

Comment: Many wildlife species live and travel through young-growth timber just as well as they 

do in old-growth, maintaining connectivity between OGRs; therefore Conservation Strategy 

Standards and Guidelines are unnecessary as roads provide travel corridors for wildlife whether 

closed or left open. 

Response: Old-growth forest provides key habitat components for many species that are not available in 

young-growth (i.e., large trees, snags, downed trees, full canopy cover, and an open understory). These 

habitat components provide essential denning, nesting, foraging, perching, and hiding opportunities for a 

variety of species. Though roads may be used as travel corridors for some species, many species are 

extremely sensitive to activity along open roads and avoid areas near roads. Timber harvest and roads, 

whether closed or open, increase habitat fragmentation which breaks larger sections of forested habitat 

into smaller, isolated patches and reduces the effectiveness of interior habitat. Openings created by 

timber harvest and roads can also become travel barriers, particularly for species that are less mobile or 

have very limited gap-crossing abilities. Roads also increase human access and thus the susceptibility of 

wildlife to hunting (illegal and legal) and other disturbance. Therefore, maintaining well-connected oldgrowth forest across the landscape is key to maintaining well-distributed wildlife populations on the 

Tongass.
Appendix H

Final EIS H-143 Comments and Responses

Comment: The Tongass conservation strategy is overly costly and is the primary reason the 

Forest Service has not been able to prepare economic timber sales and has resulted in the loss of 

hundreds of jobs. Alternatives 1, 2, 3, and 6 cannot be implemented because they include the 

conservation strategy that increases harvest costs. 

Response: The conservation strategy is the primary means by which the Forest Service meets its 

multiple use objectives as required under the NFMA. It is designed to maintain viable, well-distributed 

wildlife populations while enabling an active timber sale program. We are not aware of evidence that the 

conservation strategy has resulted in the loss of hundreds of jobs. 

Comment: The statement in the Draft EIS that “because of the reduction or elimination of the oldgrowth reserve system under Alternatives 4 and 7, respectively, these alternatives could have a 

low or moderate likelihood of maintaining viable, well-distributed wildlife populations” is 

incorrect. 

Response: It is true that Alternatives 4 and 7 would have a reduced likelihood of maintaining viable, 

well-distributed wildlife populations relative to Alternative 5 which harvests less timber, involves less road 

building, and incorporates more protective conservation measures. This statement has been clarified in 

the Final EIS text. 

Comment: One comment stated that the Proposed Forest Plan is focused on protecting oldgrowth blocks at the watershed scale, which will ultimately lead to reduced habitat diversity, 

increase fragmentation, increase road impacts and human access, and will generally lead to the 

erosion of ecosystem integrity within the watershed. 

Response: During the planning process prior to the 1997 Forest Plan, small OGRs received varying 

levels of review but were placed within each VCU; roughly equivalent to a watershed) in an effort to 

ensure that the protection of old-growth habitat was well-distributed across the Forest. The 1998 

Tongass Plan Implementation Team clarifications provided for further, project level evaluation and 

adjustment of these reserves. Initially these reviews were conducted in association with individual timber 

sales, focusing on specific VCUs, covered by the project area. However, more recently reviews have 

taken a broader focus and have been completed for all OGRs on an island or other logical geographic 

scale. Most recently, in 2006 and 2007 a forest-wide review of small OGRs was conducted which had the 

objective of enabling large-scale, landscape issues to be considered in the placement and configuration 

protected blocks of old-growth. 

Comment: In addition to reserve lands mentioned in the Proposed Forest Plan, a number of 

additional reserve lands are present in Southeast Alaska and adjacent British Columbia that also 

provide habitat for a number of wildlife species addressed by the Forest Plan. 

Response: The Forest Service agrees with this statement. 

Comment: The Draft EIS recognizes that matrix lands play a vital role in providing functional 

connectivity across the landscape but fails to take a hard look at the impact of the alternatives. 

There are no alternative methods for matrix land management. Some respondents contend that 

because management of the matrix is important for maintaining viable populations of wideranging species, the matrix itself needs to be defined in terms of its role in the conservation 

strategy. They quoted various participants at the 2006 Conservation Strategy Review workshop 

who emphasized the importance of matrix lands in meeting habitat, prey, and connectivity 

requirements. They also felt that the Legacy Standards and Guidelines need to convey the role of 

matrix lands in the conservation strategy. 
Appendix H 

Comments and Responses H-144 Final EIS 

Response: Forest Plan standards and guidelines are the framework for matrix land management on the 

Tongass. Changes to standards and guidelines proposed under the alternatives are discussed under the 

corresponding sections in the Final EIS. Appendix D provides additional discussion of the rationale 

behind proposed modifications to or replacement of Wildlife Standards and Guidelines. We recognize the 

habitat and connectivity values of matrix lands; hence the numbers of standards and guidelines 

applicable to lands considered for timber harvest can contribute to longer term old growth within those 

lands. The sum of those ensures the functionality of the entire ecosystem from the reserves and between 

the reserves in the matrix. The reserves help us meet the requirement for species well distributed across 

the Forest; standards and guidelines applied to matrix lands help ensure we will not likely approach 

minimum habitat needs through time. 

Comment: Some respondents felt that the Draft EIS and Proposed Forest Plan fail to take a hard 

look at landscape linkages and wildlife corridors and protect these areas, especially given that the 

ecological value of many of these areas has been reduced by historic (e.g., timber harvest) and 

current activities (e.g., recreation). Some felt that the Draft EIS does not cite any scientific 

evidence or peer-reviewed study to support the contention of the Forest Service that protected 

corridors (i.e., beach, riparian, estuarine buffers) will function to provide connectivity in heavily 

logged or roaded landscapes. Others felt that it seemed as though the Draft EIS and the Forest 

Pan assume these provisions will remain in pristine condition and function as corridors. One 

respondent commented that they would like to see patches of old growth modified so that they 

are associated with natural corridors for wildlife and stream protection. 

Response: It is true that the effectiveness of conservation strategy reserves and buffers in relation to 

their size, landscape pattern, and geographic distribution has yet to be scientifically tested. A statement 

to this effect has been added to the Final EIS text. Landscape connectivity was an integral feature of the 

original VPOP landscape conservation strategy (Suring et al. 1993), one of the precursors to the current 

conservation strategy. VPOP reviewed the available literature and concluded that there was limited 

empirical support for corridors but that this should not preclude their inclusion in landscape conservation 

planning. They reasoned that landscape habitat connectivity was an important component of 

conservation planning to facilitate animal dispersal and movement, whether specifically designed as 

corridors or through overall management of a habitat matrix. Appendix D of the Final EIS provides a 

detailed review of steps leading up to the development of the conservation strategy. 

Comment: The fact that roads contribute to habitat fragmentation should have been considered 

in the Draft EIS. Please consider additional road restoration and closures. 

Response: Road-related habitat fragmentation is described throughout the Wildlife section of the Final 

EIS. A transportation objective under the Final Proposed Forest Plan is to manage and maintain roads to 

protect water, soil, fish, and wildlife resources. Decisions related to the restoration or closures of specific 

roads are made at the project level. 

Comment: Several respondents feel that the Landscape Connectivity Standards and Guidelines 

are incomplete and lack a definition for connectivity, directives on critical aspects of connectivity 

(e.g., no requirement for corridor designation and no minimum corridor width or means for 

determining necessary width). Some suggested that the standards and guidelines should also 

mandate a procedure for connectivity analyses and evaluation of long-term population viability. 

One respondent thought there seemed to be an emphasis on connectivity within medium and 

large OGRs rather than between reserves, and no measurable means to ensure connectivity is 

provided. Several respondents pointed out that there is no requirement for connectivity between 

small OGRs and that connectivity is not being preserved on the ground; suggestions were made 

to designate physical corridors to provide direct connectivity between small OGRs and to develop 

standards and guidelines requiring connectivity between small OGRs. 
Appendix H

Final EIS H-145 Comments and Responses

Response: Connectivity between reserves was a consideration in the design of the Conservation 

Strategy and was also considered during the small old-growth reserve updates for this Plan. The 

Landscape Connectivity Standards and Guidelines are to be implemented during the environmental 

analysis for projects proposing to harvest timber, construct roads, or otherwise significantly alter 

vegetative cover. These standards and guidelines are purposefully general because decisions regarding 

connectivity are made most appropriately at the project level, when site-specific information can be 

incorporated. The intent of these standards and guidelines are to provide project teams with some 

flexibility for addressing this issue. As noted in the comment, these standards and guidelines are 

intended only for connectivity between medium and large OGRs. Corridors between small OGRs are not 

necessary because the intent of the small reserves is to provide old growth representation at the VCU or 

watershed scale. Connectivity throughout the matrix is an important part of the conservation strategy and 

is basically provided through time by a combination of Beach Fringe, Riparian Buffers, other standards 

and guidelines (e. g, unstable soils, low site soils, karst, etc), retention from Legacy, unscheduled timber, 

and other project-level retention, including patches that are not accessible due to logging system 

considerations. 

Comment: A number of comments were received regarding proposed changes to small OGRs. 

Some respondents felt that changes were driven by timber production at the expense of 

conservation of wildlife habitat and were under the impression that the Forest Supervisor 

promised project-level reviews to fix inadequacies in proposed reserve design. These 

respondents requested discussion of the impacts of these changes on the conservation strategy. 

Concern was expressed that the Forest Service was in violation of NEPA by not making update 

maps of the proposed changes available to the public, involving the public in the decision-making 

process, or disclosing the objective of the review. Specific recommendations for individual 

reserves were also given, including use of the GIS database developed by The Nature 

Conservancy and Audubon Alaska. Several respondents voiced support for the original 

interagency review team’s proposal. 

Response: As part of the current Forest Plan Amendment process, the Forest worked with the State of 

Alaska and the USFWS to complete a more comprehensive small old-growth reserve mapping effort. The 

objective of the interagency team review was to develop a consensus biological recommendation on 

small reserve locations that is consistent with Forest Plan criteria, eliminating the need to conduct further 

project-level reviews in most cases. This process was conducted in 2006 and 2007 and included the 

development of a biological recommendation, a refinement of that proposal with Forest Service Ranger 

District staff, and a further refinement by the Forest Supervisor. This refinement process was conducted 

in order to consider multiple-use objectives in addition to pure biological ones. The result was an overall 

increase in Old-growth LUD acreage compared to the current plan. Appendix D of the Final EIS also 

includes a discussion of how these updates were made and related results. 

Comment: The current strategy for designing OGRs is flawed in that it does not take into account 

individual island variation. 

Response: Criteria for designing OGRs are provided in Appendix K of the Final Proposed Forest Plan 

and Appendix D of the Final EIS. The process for evaluating small OGRs on the project level is actually 

very location-specific in that it requires that Appendix K criteria be met on a site by site basis, taking into 

account local knowledge of species and habitats and thus variation among individual islands. Note that 

significant effort has been made during this amendment process to evaluate and adjust all of the small 

OGRs. Only a small number should require adjustment at the project level now. 

Comment: Through the designation of small, medium, and large OGRs there is an inordinate level 

of emphasis placed on productive old-growth forest. This ignores the habitat value of managed 

forests, as well as non-productive and low-volume forests, and the fact that when harvest 

changes the seral stage of a forest there are “winners and losers” with respect to habitat 
Appendix H 

Comments and Responses H-146 Final EIS 

suitability. There will be a higher level of wildlife diversity associated with habitats found in a 

forest of a variety of development stages and therefore reserves should incorporate more than 

just productive old-growth. 

Response: There are a variety of factors that go into the designation of OGRs in terms of their 

placement and configuration, productive old-growth habitat being one of them. Reserves provide 

connectivity between high and low elevation areas and between Old-Growth LUDS and other nondevelopment LUDS, protect areas of high value winter range, and nesting habitat for goshawks and 

murrelets The naturally fragmented landscape of the Tongass means that many reserve incorporate 

forest stages other than old-growth, either created naturally through blow down or past timber harvest. 

Comment: Some respondents feel that the coarse-filter component of the conservation strategy 

fails to recognize the MIS and Sensitive species addressed by the Proposed Forest Plan, whereas 

others feel that the conservation strategy fails to take into account logging on adjacent nonfederal lands. Both groups of respondents suggested that the level of protection afforded by the 

Proposed Forest Plan should be increased or decreased accordingly. 

Response: The conservation strategy was designed to provide a range of habitats within the boundaries 

of the Tongass National Forest in part to account for conditions or predicted conditions on adjacent or 

nearby non-NFS lands. 

Comment: Several comments were received expressing support for maintaining some or all 

elements of the conservations strategy. Some respondents felt that the system of large, medium, 

and small OGRs, along with beach and riparian buffers, must remain the cornerstone of the 

conservation strategy because it provides a safety net for conservation of viable fish and wildlife 

populations. 

Response: The array of alternatives evaluated in the Final EIS is designed to address a full range of 

roadless development and timber supply/demand levels. Alternatives that reduce or remove elements of 

the conservation strategy do so to increase the amount of harvestable timber, which increases the risk to 

maintaining viable populations of wildlife. 

Comment: Comments were received that encouraged the Forest Service to review any remaining 

small OGRs (OGRs) not finalized during the forest-wide interagency review effort with an eye to 

timber operability as well as fish and wildlife conservation. The newly proposed locations and 

sizes for the reserves that were reviewed appeared better than they were previously. However, of 

particular concern is that project-level reviews have removed 5,100 acres of POG from the suitable 

land base from 1998 to 2005 (USDA 2005). This steady erosion of the timber base presents an 

obstacle to maintaining a viable timber industry in Southeast Alaska. Therefore the commenters 

indicated they supported the joint effort to finalize locations of small OGR across the Tongass and 

encouraged this collaboration past this planning effort and further urged that the transfer of POG 

from the suitable land base to small OGR be kept to a minimum to meet criteria in Appendix K. 

Response: We agree that the OGRs revised during the 2006-2007 Interagency Review, with 

subsequent review by the Forest Plan Adjustment Interdisciplinary Team (IDT) and Forest Supervisor, are 

in better locations. The Forest-wide review of small OGRs was done primarily to develop a consistent 

and more efficient method of review and to more accurately define the location of small OGRs to enhance 

the Forest Plan conservation strategy, achieving consistency with criteria in Appendix K of the Forest 

Plan. Concerns identified as a result of the Forest Plan Maintenance Program were also addressed in 

this review, one of which was that total acres added to OGRs are reducing suitable acres. The net result 

of the review was an increase of 39,000 acres in the Old-Growth Habitat LUD (effective under 

Alternatives 1, 2, 3, and 6). In addition to this expansion, some areas containing Old-Growth Habitat LUD 

were converted to other non-development LUDs (e.g., Special Interest Area and Semi-Remote 
Appendix H

Final EIS H-147 Comments and Responses

Recreation) and remain a part of the old-growth reserve network. Appendix D of the Final EIS addresses 

changes in the Old-Growth Habitat LUD and other non-development LUDs resulting from this review. 

Comment: Alternative 4 proposes to apply the Old-Growth Habitat LUD in four biogeographic 

provinces and maintain 33 percent of old-growth in the remaining provinces. It is detrimental to 

wildlife because it does not specify the distribution of the 33 percent retention requirement, 

potentially resulting in widely spaced single trees of little value to species dependent on large 

contiguous blocks of habitat, and disregards scientific information indicating the importance of 

other biogeographic provinces (Kuiu Island, Admiralty, and the mainland provinces) which 

contain endemic mammal populations. 

Response: It is true that under Alternative 4 all VCUs (with minor exceptions) outside of the four 

biogeographic provinces where OGRs are required would be required to retain 33 percent of their oldgrowth with no requirement to consider spacing, location, size, shape, or composition in the design of the 

retained acres, as is the case under Alternatives 1, 2, 3, 5, and 6, where the direction provided in 

Appendix K of the current Forest Plan (Old-Growth Habitat Reserve Criteria) applies. The EIS discusses 

the effects of Alternative 4 on wildlife, including endemic mammals. 

Comment: The biodiversity analysis should also look at changes in connectivity redundancy, 

corridor width, and corridor effectiveness. 

Response: Corridor redundancy is addressed by the Legacy Standards and Guidelines (see Appendix D 

for discussion of the rationale for its development) and was also a consideration during the 2006-2007 

Forest-wide interagency small old-growth reserve review (i.e., OGRs overlapping the beach fringe). 

Effects of proposed changes in corridor width are discussed in the Wildlife section of the Final EIS. There 

still remains uncertainty regarding the effectiveness of various elements of the conservation strategy, 

including connectivity requirements. This is addressed in the Biodiversity and Wildlife sections of the 

Final EIS. 

Comment: Characteristics and outcomes that an effective conservation strategy should have 

were listed in the Draft EIS. This list should include: 1) it should anticipate and allow for losses of 

particular habitats to stochastic events (including catastrophes) on a landscape scale and, as may 

be appropriate for finer species, at a finer scale; (2) it should anticipate and make allowances for 

natural habitat losses, considering also the effects of climate change; and (3) other statements 

from the joint statements by the peer reviewers of the 1997 Forest Plan. 

Response: The conservation strategy was developed primarily to maintain viable, well distributed oldgrowth associated wildlife populations. The objectives are to contribute to habitat capability of fish and 

wildlife resources to support sustainable human subsistence and recreational uses; maintain biodiversity 

and ecological processes in old growth habitats; and to restore previously harvested stands to old growth 

forest condition at an accelerated rate. Catastrophic events at a landscape scale would be difficult to 

predict and nearly impossible to plan for across the landscape. Similarly, predicting climate change 

effects to Southeast Alaska forests is problematic. The relatively large and comprehensive conservation 

strategy is expected to be resilient enough to accommodate such uncertainty. This coupled with the 

relatively small portion of the Tongass that is considered available for management of timber into the 

future deems the risk and uncertainty within acceptable limits. Additionally, the ongoing monitoring and 

study by state and federal agencies, academia and others along with periodic reviews of the Forest Plan 

provide ample opportunities to respond to such risk and uncertainty in a responsible manner into the 

future. 
Appendix H 

Comments and Responses H-148 Final EIS 

Comment: Concerns raised about the inadequacy of the old-growth reserve system (e.g., 

reserves not large enough to support intended number of female marten, encompass an entire 

wolf pack home range, or a sufficient number of female brown bears on Baranof and Chichagof 

islands) were not addressed in the Draft EIS. 

Response: Each of these concerns emphasizes the importance of matrix management. Matrix 

management and the uncertainties related to the adequacy of the reserve system are discussed in the 

Wildlife section of the Final EIS. In addition, several alternatives include increases to the reserve system 

(Alternatives 1, 2, 3, and 6). 

Comment: One respondent offered the following detailed comment: The Forest-wide old-growth 

reserve review erroneously excluded acreage of private lands in calculating mapped reserves. It 

is impossible to properly design OGRs without taking into account the cumulative impacts of 

logging and development of all lands within the VCU. In discussing the basic criteria for 

allocating small OGRs, the Proposed Forest Plan defines such reserves as “a contiguous 

landscape of at least 16 percent of the area of each VCU.” If the intent of the Forest Plan is to 

create these reserves based only on Forest Service land it would clearly state so. 

Response: Prior to the 2006-2007 Interagency small old-growth reserve review, there was no specific 

protocol describing how to complete or implement project-level interagency reviews. As a result, small 

old-growth reserve reviews have occurred in a variety of ways and with varying degrees of quality. One 

of the aspects of the review process that make it difficult to complete is that some of the Forest Plan 

criteria are subject to interpretation, such as the 16 percent area requirement. Some project level reviews 

have taken all land ownerships into account, others have not. The revised Appendix K of the Final 

Proposed Forest Plan clarifies that this should include only NFS lands. 

Comment: The adverse effects of fragmentation, increased forest edge, small mammal isolation, 

and increased predation in harvest areas are greatly exaggerated and not founded in science. 

Response: Additional citations of peer-reviewed literature have been added to the discussions of these 

topics in the Final EIS. 

Comment: The Old-growth Habitat LUD allows activities that are not consistent with habitat 

reserves (i.e., allows roads to access adjacent timber lands if no other feasible option exists, 

salvage logging, and OHV use) and needs to be updated. This high likelihood of road 

construction through OGRs represents a failure of the old-growth reserve system and the viability 

strategy of the current Forest Plan and shows why legal protection of wilderness is necessary. 

Stronger wording should also be included in Appendix K criteria for designating small OGRs to 

ensure that they represent big-tree stands, and that no roading or OHV use is allowed. The 

Appendix K criteria for small OGRs should also be revised to require at least 800 acres of POG, 

rather than the minimum of 400 acres, because the 400-acre minimum is almost always chosen. 

Response: The conservation strategy is one developed through an interagency approach along with the 

best available science information at that time. Through a series of science review panels and many 

other efforts it was deemed to provide for a moderate to high likelihood of achieving its objectives. The 

2006 review of the conservation strategy brought forward new science and much other information 

relative to the strategy since 1997. The review also brought together many of the foremost experts on 

subjects relative to the conservation strategy and its implementation. That effort, which included a paper 

reviewing published research on conservations strategy design (Haufler 2006), resulted in the Forest 

Service being able to conclude the conservation strategy and its basic design is still valid. In addition, we 

believe that the limited activities allowed in the Old-growth reserve standard and guidelines are consistent 

with the conservation strategy. Further, Chapter 6 of the Plan describes a monitoring plan for old growth 

that will ensure activities, over time, are consistent with the intent of this strategy. 
Appendix H

Final EIS H-149 Comments and Responses

Comment: There are a number of medium and large reserves throughout the Forest that fail to 

meet the minimum criteria in Appendix K for total acres and acres of productive old-growth 

habitat. Please identify all medium and large OGRs and display these criteria to identify the 

reserves that do not meet them. Then please give rationale as to why medium and large reserves 

not meeting these criteria were not adjusted. 

Response: As stated in Appendix K of the Final Proposed Forest Plan, large and medium OGRs were 

designed based on the most restrictive requirements of species with large home ranges and for which 

there were viability and distribution concerns. They were designed to provide for source populations of 

species, specifically brown bear, marten, northern goshawk, and wolf, and to provide refugia for 

dispersing animals. These reserves received rigorous review during the development of the 1997 Forest 

Plan and, when considered within the context of the entire strategy, are likely adequate considering the 

logistics of where each reside within the overall strategy. 

Comment: Section VII.A.3 of Appendix K of the Draft EIS appears to mean that in VCUs where any 

portion is designated as a very large, large, or medium old-growth reserve, these VCUs do not 

need to contain additional productive old-growth to meet the minimum requirements of small 

OGRs. This is difficult to interpret because the Draft EIS fails to provide a map depicting these 

reserves, and large and medium reserves are often identified not as Old-growth Habitat LUD but 

as one of several other Non-development LUDs. 

Response: This interpretation of the criteria is correct. The rationale for not requiring a small old-growth 

reserve in a VCU which has a portion designated as a medium, large, or very large old-growth reserve is 

that it is assumed that these reserves in combination with old-growth retained by standards and 

guidelines will provide sufficient productive old-growth to ensure connectivity across the landscape 

through time. Old-growth Habitat LUDs are depicted on the Forest Plan maps. 

Comment: How much is enough [adequate portion of each ecosystem type maintained in an 

unmanaged state]? Ten to 30 percent of a biogeographic region is the generally accepted 

minimum. Most expert landscape ecologists would suggest 30 to 40 percent. 

Response: Targets for landscape level conservation features are partially defined as the percentage of a 

resource’s overall distribution that is contained within a given area (Dunn et al. 1999), but also must take 

into account specific planning objectives as well as the identification of vulnerable habitat types and 

critical habitats for vulnerable species. There are no defined thresholds for how much old-growth should 

remain within a biogeographic province on the Tongass. The Final EIS displays the amount of old growth 

that is predicted to remain after 100 years for each biogeographic province and identifies the resulting 

effects to wildlife and biodiversity. Table 3.9-14 in the Biodiversity section shows that none of the 

biogeographic provinces would have less than 53 percent of its original POG remaining on NFS lands 

after 100+ years of implementation under any of the alternatives at the maximum level allowed. Even if 

all lands in Southeast Alaska are considered together, the minimum percent of original POG remaining on 

all lands among all provinces would be 44 percent (see Table 3.9-20) 

Comment: The Draft EIS fails to disclose the opposition to, and uncertainty behind, the 

Conservation Strategy. 

Response: Additional discussion of risk and uncertainty related to the conservation strategy and wildlife 

viability assessments has been added to the Wildlife section of the Final EIS and Appendix D has been 

added which addresses these topics in more detail. 

Comment: Some respondents felt that the process for preparing the amendment was flawed. 

They believe that the results of the conservation strategy review were not incorporated and that 
Appendix H 

Comments and Responses H-150 Final EIS 

the conservation strategy review itself was flawed because not all key experts were invited, the 

observers were not allowed to participate, and some key issues were not brought up. 

Response: The conservation strategy review was designed as an interagency review of the 

conservation strategy focusing on new information and knowledge developed since 1997. As a 

structured information assessment it was not intended to be an all encompassing review of all aspects of 

the conservation strategy or to involve special interest groups with other agendas. The review focused on 

new information relative to implementation and monitoring of components of the strategy, especially 

within the matrix part of the strategy where development activities will occur through time. The review 

involved numerous interagency meetings to develop the agenda, much preparation time by the speakers 

and a full week meeting in Ketchikan in April of 2006. Expanding the meeting to encompass all subjects 

and all interested parties would have made it even more time consuming. 

The information was very useful in the Forest Plan Amendment process but there was never any intent 

that the Amendment would address all of the ideas brought forward in the review. As noted on the 

Conservation Strategy Review Website at the time of the review: 

“The new information and knowledge will be presented at a science-based technical workshop designed to 

rigorously explore the subjects and to develop a suite of potential actions and investments the Tongass 

and its interagency partners can consider related to new information needs or exploring changes in how 

the conservation strategy is designed, implemented or monitored. The suite of considerations could lead to 

conservation strategy-related adjustments to the Tongass Forest Plan as well.” 

The planning record shows the findings from the review and the plan for how each finding will be 

addressed over time. 

Comment: Some respondents also believed the process was flawed because changes to the 

small OGRs were completed after the Draft EIS was published. They also stated that the 

comment period was not long enough. 

Response: Alternatives in the Draft EIS included those small old-growth reserve adjustments that had 

been completed by the interagency team at a point prior to the time of publication. The Draft EIS solicited 

comments on these changes and the interagency process in general. All of the small old-growth reserve 

adjustments were completed and posted on the Website with over 30 days of the comment period 

remaining. The comment period was then extended for an additional 18 days, because of the weather 

and because we wanted to ensure that those interested had a chance to comment on these changes. 

Even after the comment period closed, the Website was quite clear that we would continue to welcome 

comments on the small old-growth reserve changes. 

The formal comment period on the Draft EIS lasted for a total of 108 days. In addition, most of the 

proposed changes to the Forest Plan were on the Website months in advance of the comment period. 

The public had a considerable amount of time to consider the changes we were proposing. 

Old-Growth Mapping 

Comment: Several comments were received regarding the use of the size-density model (SDM) 

for vegetation versus the original Vol-Strata vegetation model in the deer habitat capability model. 

Some feel this is unimportant provided model results are only used to make a relative comparison 

among alternatives. Others feel this is a modest improvement but that condensing the model into 

only three categories masks the loss of the highest value deer winter habitat due to past and 

future timber harvest. These respondents supported the modification of the model to represent 

all seven SDM vegetation classes. 

Response: The deer model provides a means for making relative comparisons among alternatives in 

terms of their effects to deer winter range. The existing model parameters are based on the three volume 
Appendix H

Final EIS H-151 Comments and Responses

strata categories. In addition to this fact and the fact that sufficient information to accurately update the 

model to use all seven categories does not exist, the statistical precision of the SDM classification into the 

seven classes is low. New deer models are in development, but are not ready for use at the Forest 

planning scale. 

Specific concerns regarding deer and the deer model are discussed in a following subsection of this 

appendix under the heading “Deer.” 

Comment: Much of the biodiversity and wildlife analysis in the Draft EIS is too “productive oldgrowth (POG)-centric” and the Draft EIS has violated NEPA by not disclosing this shortcoming. 

Some respondents felt that the general reference to POG as a key indicator for effects to many 

wildlife species made in Chapter 2 is incorrect in that many species have more specialized habitat 

requirements (i.e., coarse canopy productive old-growth provides higher quality winter habitat for 

deer) and the Draft EIS should have disclosed effects to individual SDM categories, particularly 

those that represent high-value POG including “big-tree” POG (i.e., SD67, SD5N, and SD5S 

categories). 

Response: The summary statement in Chapter 2 that POG is a key indicator of effects to many wildlife 

species on the Tongass is correct, as this is the primary resources affected by timber harvest. Where 

appropriate, the wildlife analysis does separate out effects to the most important SD7 model categories of 

POG. A full analysis has been added to the Biodiversity section of the Final EIS showing effects to high 

volume (SD5N, SD5S, SD67) vegetation categories and large-tree (SD67) vegetation category POG, 

both on NFS lands alone, and on all lands in Southeast Alaska combined (by biogeographic province). 

Comment: The Draft EIS fails to disclose how the assumed harvest of vegetation categories 

SD4N, SD4S, SD5H, SD5N, SD5S, and SD67 prior to 1954 was distributed among these categories 

for the estimate of 1954 deer habitat capability, and therefore violates NEPA. 

Response: To estimate 1954 or original POG, it was necessary to “grow back” previously harvested 

units. Previously harvested units identified in the vegetation layer (HS1, HS2, and HS3 categories in the 

SDM GIS coverage) were assumed to have been stands of POG. To estimate original high volume and 

SD67 POG, an estimate was made of the percentage of past harvest in these categories using timber 

type mapping from the mid-1980s. Based on this analysis, prior harvest on NFS lands was estimated to 

have been 29 percent SD67 and 64 percent high volume (see Appendix B) These estimates are higher 

than estimates made by Audubon Alaska and The Nature Conservancy (Albert and Schoen 2007). 

Comment: Populations of some species (bear, goshawk, marten, and wolf) occur at viable levels 

in habitats containing substantially less old-growth and greater levels of development than the 

Tongass. This suggests that habitat associations of species considered in the Proposed Forest 

Plan are in some instances less linked to old-growth than assumed. 

Response: On the Tongass all of the species listed above are considered old-growth associates, being 

most closely associated with this habitat type. However, as described in their respective subsections in 

the Wildlife section of the Draft EIS, these species are all wide-ranging and their home ranges may 

encompass a variety of habitat types. Species-specific standards and guidelines focus on protecting oldgrowth because this is the habitat type most affected by timber harvest activity. Where new science has 

indicated that certain species are more adaptable than once thought, information from pertinent peerreviewed literature has been included in the Final EIS. 

Comment: The focus on retention of high-volume timber stands in the Proposed Forest Plan is 

based on the assumption that past harvesting targeted these stands. However, for purposes of 

economical and operational efficiency, harvests prior to 1976 more typically involved entire 
Appendix H 

Comments and Responses H-152 Final EIS 

watersheds or portions of entire watersheds and the range of volumes associated with stands 

occurring there. 

Response: This is true to some degree, but there is no doubt that the lower elevation stands, which 

generally have the highest volume and wildlife values, were harvested at a disproportionate rate (Table 

3.9-7 in the Biodiversity section). 

Comment: The Draft EIS does not disclose the continued effects of high-grading on the forest or 

the cumulative effects of continued high-grading on non-federal lands. The Final Proposed Forest 

Plan must address past high-grading of the most productive forest types on federal and nonfederal lands. Some respondents contend that because past high-grading has reduced forest and 

habitat diversity, additional conservation measures need to be applied on the Tongass to 

minimize the loss of additional diversity; others expressed opposition to all high-grading. Others 

brought up timber harvest statistics suggesting that the Forest Service’s estimate that only 8 

percent of the timber harvested on the Tongass is cedar is actually closer to 20 to 40 percent, 

based on independent ground truthing, evidence that the Draft EIS and market demand analysis 

under represent the role cedar exports play in the Tongass timber program and the corresponding 

impact on the environment. 

Response: Additional discussion of the historical disproportionate harvest on certain landforms and of 

certain forest types has been added to the Biodiversity section of the Final EIS and includes NFS and 

non-NFS lands. The Biodiversity section also includes an expanded discussion of old-growth 

representation within reserves and matrix lands for high-volume and large-tree POG and the effects of the 

alternatives on this representation, as well as an expanded cumulative effects analysis evaluating future 

disproportionate harvest on non-NFS lands. We assume that this comment actually refers to the 

statement in the Draft EIS that 8 percent of POG historically occurring on the Forest has been harvested, 

not yellow cedar. As noted on page 3-241 of the Draft EIS, our records indicate that hemlock and spruce 

account for 94 percent of trees harvested in most sales on the Tongass. Cedar occurs as a minor tree 

species in most stands. The comment that cedar represents up to 40 percent of the total past harvest is 

not supported by historical data. 

Comment: Historically, the most productive forest types have been disproportionately targeted 

for logging. As an example, low elevation karst and valley-floor forests have been logged at 560 

percent and 160 percent of their proportional availability, respectively. 

Response: More information on the disproportionate nature of past timber harvest in Southeast Alaska 

has been added to the Biodiversity section of the Final EIS. 

Comment: A number of comments were received regarding the protection of high-value or rare 

habitats (e.g., large-tree old-growth, karst lands, yellow cedar) and the natural range of 

environmental variability across the forest. Some respondents asked the Forest Service to 

protect these habitats, some suggested that new standards and guidelines need to be developed 

for remaining rare and large-tree forests and others suggested these elements be protected in 

each biogeographic province. Others commented that areas of intense logging seem to 

correspond with areas of concentrated wildlife use. 

In their comments TNC and Audubon describe an analysis in which they used the protection of 

high-value habitats as a measure of the effectiveness of the conservation strategy and analyzed 

the existing protection afforded to focal species and ecosystems (large tree forests, deer, bear, 

salmon, and marbled murrelet) within existing reserves by biogeographic province. This analysis 

revealed that, in general, the provinces with the highest biological value are also those with the 

greatest vulnerability (i.e., least amount of high-value habitats protected). North Prince of Wales, 

East Chichagof, Revilla/Cleveland, Kupreanof/Mitkof, and others rank as the highest priorities for 
Appendix H

Final EIS H-153 Comments and Responses

additional conservation and restoration measures. The analysis also looked at cumulative 

ecological risk, recommending this as a tool to be used for adjusting the Tongass Conservation 

Strategy to prioritize conservation and restoration actions. 

Response: Harvesting high-value stands, which has affected high-value habitats such as large-tree oldgrowth, karst lands, and cedar) is discussed in detail in the Biodiversity section of the Final EIS. The fact 

that some areas of high value to wildlife coincide with areas of high value for timber harvest is also 

discussed in the Biodiversity section. Of note is that while it is true that there is high biological value in 

areas where timber harvest is allowed, there are also many high biological value areas on the Tongass 

(as ranked by TNC and Audubon) that are fully protected (for example, Admiralty Island National 

Monument). 

Comment: Page 3-120 in the Biodiversity section of the Draft EIS states that “Albert and Schoen 

(2006) estimate that region-wide approximately 29 percent of 242,211 acres harvested since 1986 

occurred in large-tree (SD67) ecosystems, and approximately 72 percent of these forests remain 

intact.” This statement occurred in an earlier report to ADF&G prior to completion of our 

conservation assessment. The statement was preliminary and needs additional clarification. In 

our final conservation assessment (Albert and Schoen 2007) we stated the following: “Regionwide only 12 percent of all productive old-growth has been harvested since 1954, but at least 28 

percent of Southeast’s large-tree forest types have been cut. It is important to recognize, 

however, that this percentage-derived from post-1986 selectivity coefficients-represents a 

significant underestimate of the original high-grading of the large-tree stands.” This should be 

corrected in the Final EIS. 

Response: Additional information from Albert and Schoen 2007 has been added to the Biodiversity

section of the Final EIS. Our independent estimate of the percentage of past harvest of large-tree POG 

is higher than the percentage calculated by Albert and Schoen (2007). Using timber type mapping from 

the mid-1980s, we estimated that 29 percent of the large-tree POG on NFS lands and 37 percent of the 

large-tree POG on non-NFS lands was previously harvested, for a cumulative harvest rate of 32 percent 

(see Appendix B). 

Comment: The Size-density Model should have been used throughout the Draft EIS analysis and 

tables in Section 3.9 and 3.13 should be revised to provide a summary by SDM class. The fact 

that the ecological sensitivity analysis of the Size-density Model was omitted from the biodiversity 

analysis of the Draft EIS is a major flaw and should be corrected in the Final EIS. It would also be 

useful if the Final EIS could also account for the SD7 class separately from the SD6 class because 

of their great rarity and value on the Forest. 

Response: Tables showing the amount of POG, high-volume POG (SD5N, SD5S, SD 67), and largetree POG (SD67) harvested and remaining, and a cumulative effects discussion on future harvest of 

POG, high volume POG, and large-tree POG, have been expanded in the Biodiversity section of the Final 

EIS. SD7 is not one of the types in the Size-Density model. It is assumed the commenter is referring to 

the old volume class 7, which is not statistically distinguishable from other types, based on existing 

mapping. 

Comment: One respondent discussed the new tools that are available such as the Size Density 

Vegetation Model and the modeling work recently completed by The Nature Conservancy. They 

suggest that implementation not begin until these new tools have been incorporated. 

Response: The Size Density model has been used throughout the analysis. The Nature Conservancy’s 

work has been examined closely and has informed the analysis, especially in the areas of biodiversity 

and roadless area evaluation. 
Appendix H 

Comments and Responses H-154 Final EIS 

Legacy and Goshawk/Marten Standards and Guidelines 

Comment: Some respondents supported Alternative 7 with some modifications. They felt that 

some of the Conservation Strategy Standards and Guidelines lacked a basis in science and 

should be removed from Alternative 7. These standards and guidelines include the 1000-foot 

beach buffer, OGRs, Class III stream buffers, the Legacy standard, and the Goshawk and Marten 

standards. 

Response: Table 2-16, page 2-41 of the Draft EIS illustrates that Alternative 7 has none of these 

standards and guidelines except for the Class III riparian standard. Alternative 7 has been modified in the 

Final EIS and it no longer includes buffers on Class III stream. See Appendix D of the Final EIS for more 

information about the scientific rationale behind the conservation strategy. 

Comment: The Draft EIS provides no supporting science for adopting the Forest Legacy standard 

and guideline as a replacement of the Marten Habitat and Goshawk Foraging Standards and 

Guidelines. Without this assessment there is no way to evaluate any benefits of the standard and 

guideline to wildlife. The Final EIS should include a qualitative and quantitative analysis of how 

the Marten Habitat and Goshawk Foraging Standards and Guidelines have been applied and the 

extent to which these requirements have impacted timber harvest activities. 

Response: Appendix D of the Final EIS provides the rationale behind the development of the Forest 

Legacy standard and guideline as well as an assessment of how it compares to the existing Marten 

Habitat and Goshawk Foraging Standards and Guidelines. 

Comment: Risk levels (i.e., low, medium, and high) of VCUs used to determine application of the 

Legacy Standards and Guidelines in the Final EIS and Final Proposed Forest Plan should 

incorporate timber harvest on all land ownerships. 

Response: The Final Proposed Forest Plan specifies only higher-risk VCUs in the application of the 

Legacy standard and guideline; the harvest level for determining risk category does not include all land 

ownerships, though it is anticipated that harvest on these lands will continue into the future. The overall 

conservation strategy design accounts for cumulative effects on non-NFS lands, and therefore the 

analysis of VCUs for application of Legacy has considered only the NFS portion of VCUs. 

Comment: Because natural openings in old-growth forest on the Tongass average 2 acres, the 

Legacy standard and guideline should be implemented in all harvest units greater than 2 acres, as 

required under the existing Goshawk Foraging and Marten Habitat Standards and Guidelines, 

versus the 20 acre requirement under the Legacy standard and guideline. The loss of legacy 

retention in units between 2 and 10 acres in High Risk VCUs would increase impacts of logging on 

the goshawk and other old-growth associated species in landscapes where they are already most 

at risk. 

Response: The use of 20-acres for the minimum unit size where the Forest-wide Legacy standard and 

guideline applies was selected because it represents a typical logical logging system setting, based on 

analysis of the LSTA. In order to better balance wildlife conservation concerns and timber sale operability 

concerns, this unit size was selected. This change may not be as beneficial as the 1997 Plan Goshawk 

Foraging and Marten Habitat Standards and Guidelines for some species. For wildlife species sensitive 

to forest fragmentation, clearly smaller units would have less impact than larger units. However, there is 

no strong empirical evidence on what the maximum unit size is before a clearcut becomes a barrier. It is 

also important to consider that wildlife encounter a range of conditions and natural fragmentation on the 

Tongass. Opening sizes from natural wind events range up to 1,000 acres, but are typically less than 40 

acres (Nowacki and Kramer 1998). While there could be openings up to 20 acres without retention of 

legacy, we anticipate that there would be a mix of openings in a typical timber sale layout because of the 
Appendix H

Final EIS H-155 Comments and Responses

OGRs in buffers, over-steepened slopes, and other protection measures associated with those units. 

Appendix D of the Final EIS provides additional discussion of the rationale behind the development of the 

Legacy standard and guideline. 

Comment: The Forest Legacy standard and guideline could result in trees retained along the 

perimeter of a harvest unit, unlike the Marten Habitat and Goshawk Foraging Standards and 

Guidelines which require that trees be individually spaced or retained in clumps. 

Response: The legacy standard and guideline is simpler and clearer than the goshawk and marten 

standards. The intent is similar – retain forest structure in units. The standard is clear that this structure 

is meant to be within the harvest units, not on the edge, though it does provide for exceptions when 

logging systems preclude this. Continued Forest Plan monitoring provides for continual monitoring of this 

to ensure that legacy retention within units is occurring. Adjustments can be made through adaptive 

management if it is determined that objectives are not being met. Additional technical information has 

been added to the Timber and Forest Health sections to discussions regarding legacy and other retention 

standards and guidelines and to Appendix D of the Final EIS. 

Comment: Several comments were received requesting clarification as to what harvest units the 

Legacy Standards and Guidelines would apply. One respondent stated that neither the Proposed 

Forest Plan nor the Draft EIS provide a scientific rationale for the criteria for defining the 

maximum sizes of units that can be harvested and still retain legacy forest structure, and how 

much legacy forest structure should be maintained, because both the maximum size of openings 

allowed and the amount of forest structure to be left depend on the risk level within the VCU. 

Other respondents were opposed to applying the Legacy Standards and Guidelines to all harvest 

units (or altogether), suggesting this would hamper timber sale economics by distributing timber 

harvest and setting aside the most economic timber stands in areas that are managed for multiple 

use. 

Response: Based on further analysis and public comment, the Legacy standard has been refined for the 

Final Proposed Forest Plan. The Legacy Standards and Guidelines are to be applied only in higher-risk 

VCUs where 33 percent or more of the POG has been harvested as of 2005, or VCUs where less than 33 

percent has been harvested but more than 67 percent of the POG is projected to be harvested by the end 

of the Forest Plan planning horizon. Within these VCUs the only criterion related to unit size is that the 

standard is to be applied to the original planned harvest units of 20 acres or greater. Appendix D of the 

Final EIS provides information on the rationale behind the development of the Legacy standard and 

guideline. 

Comment: Several respondents questioned whether a mechanism would be in place for ensuring 

that legacy retention is protected from future removal, be it salvage or commercial harvest, 

firewood collection or personal use. A suggestion was made to develop a legacy structure 

tracking system. 

Response: Standard and guideline IV.B of the Final Proposed Forest Plan states that Legacy forest 

structure should remain indefinitely after harvest and shall be tracked through the life of the next stand. 

Salvage logging of legacy trees is generally prohibited unless the rationale is clearly documented and the 

effects are clearly neutral or an improvement.

Comment: The Forest Legacy standard and guideline is a cookie-cutter approach that is 

inappropriate for an island archipelago. This approach fails to account for island size, 

fragmentation, the uniqueness of the area, the presence of karst or other landscape features, or 

the presence of endemic mammals. It also fails to account for impacts on adjacent private lands. 
Appendix H 

Comments and Responses H-156 Final EIS 

Response: The design of the conservation strategy took into account a variety of factors, including 

biogeographic province differences (which incorporates the fact that the Tongass is an island 

archipelago), fragmentation, and endemics. The OGR system in the conservation strategy fundamentally 

is a ‘coarse filter’ approach to addressing wildlife viability and the conservation of biodiversity. In addition, 

a variety of other coarse filter standards and guidelines provided connectivity between the reserves. At 

the “fine filter” level, species-specific standards were fully considered in light of additional information 

such as conservation assessments, panel assessment results, etc. and appropriate standards and 

guidelines were incorporated for species that needed additional protection measures to assure their 

viability and well-distributed status. The design of Forest Legacy standard and guideline also took into 

account past and future harvest within a VCU. 

Comment: The Reserve Tree/Cavity-nesting standard and guideline leaves unanswered the 

question of how many trees and what sizes. 

Response: The generality of these standards and guidelines is intended to leave some flexibility in its 

implementation as the quantity and quality of available reserve trees will vary by project location. This 

standard and guideline has not changed since 1997. 

Comment: There is no science behind the 100-acre goshawk nest buffers. It is likely that the nest 

buffers afforded bald eagles would be sufficient for goshawks (8 acres versus 100 acres). 

Response: Much information, including peer reviewed science, related to goshawk nest sites and use 

areas exists. Such information was used to inform development of the standard and guideline requiring 

the nest buffer included in the Final Proposed Forest Plan. 

Comment: Foresters have recently field-applied the proposed Legacy standard and guideline and 

have concluded that it only slightly improves the economics of timber sales over the current 

Forest Plan and only marginally offsets the impacts of the OGRs and other conservation strategy 

measures in place. The commenter indicated they would like to see the research called for in the 

May 1994 “Response to the peer review of: a proposed strategy for maintaining well-distributed 

viable populations wildlife associated with old-growth forest in Southeast Alaska” completed and 

a full NEPA analysis made prior to proposing implementation of this standard and guideline. 

Response: The various peer reviews conducted for the 1997 Forest Plan Revision were incorporated as 

applicable into the associated analyses which lead to the 1997 Forest Plan. That information is available 

in the 1997 Forest Plan planning record. The conservation strategy included in the 1997 Forest Plan was 

reviewed in 2006 and the Forest Service concludes the conservation strategy is still sound and an 

appropriate approach for the Tongass National Forest. The Legacy Standard has been modified for the 

Final Proposed Forest Plan. 

Population Viability 

Comment: The rating for Alternative 4 needs to be corrected on page 2-51 of the Draft EIS. 

Response: This has been corrected in the Final EIS. 

Comment: Carrying over results of the 1997 expert panel risk assessments and associated 

“likelihood ratings” into the Draft EIS should be justified, particularly in the case of wolves and 

endemic species in light of recent scientific findings.. 
Appendix H

Final EIS H-157 Comments and Responses

Response: Appendix D of the Final EIS contains a detailed description of the 1997 panel assessment 

process, results, rationale for carrying over applicable results into the Final EIS, and a discussion of 

where new science differs from information used by the panel to rate alternatives. 

Comment: Several comments were received about the population levels managed for under the 

Proposed Forest Plan. Some felt that the standard for fish and wildlife population levels should 

be based on sustainability rather than viability because a sustainable population provides for both 

human use and biological survival whereas viability only guarantees survival in the absence of 

human use. These respondents noted that the standard of sustainability is consistent with the 

State of Alaska’s constitution. Others felt that the conservation strategy should focus on 

“abundant or moderate,” “abundant and useable,” or “sustainable and normally distributed” 

populations because they are more likely to sustain moderate levels of human use or meet 

regional subsistence needs. 

Response: The Forest Service is complying with direction under the NFMA to maintain viable wildlife 

populations. It is recognized that minimum viable populations for many species may not satisfy the public 

need for wildlife populations depended upon to meet subsistence and/or sport hunting uses. Lengthy 

discussion is found in the Subsistence and Wildlife sections of the Final EIS regarding such species. 

Comment: The characterization of Alternative 7 as having a moderate to low likelihood of 

maintaining viable and well-distributed wildlife populations across the Tongass because of the 

elimination of the old-growth reserve system is not founded in science. The fact that this 

alternative is the least protective does not automatically translate into a risk for a species. 

Response: This statement has been modified to indicate risk relative to Alternative 5 No Action, which is 

equivalent to Alternative 11 of the 1997 EIS that had been evaluated by a risk assessment panel using 

the best available science. Due to elimination of the old-growth reserve system under Alternative 7 and 

the increase in area of development LUDs, Alternative 7 would have a reduced likelihood of maintaining 

viable, well distributed populations relative to Alternative 5. 

Comment: The Draft EIS does not adequately address the potential value of harvest regulations 

and access control, in combination with habitat management, in helping assure the viability of 

some wildlife species. 

Response: While the Forest Service has a role in setting harvest regulations through the Federal 

Subsistence Board, the Forest Service, by itself, cannot set or manipulate wildlife harvest levels. 

Therefore, harvest regulations are not considered as a sole means to mitigate effects to wildlife. 

However, we do recognize our ability to work within the federal system and to work cooperatively with the 

State in considering harvest regulations if needed. This is discussed as a specific means for mitigating 

the effects of timber harvest on species that are sensitive to over harvest (legal and illegal) due to 

increased human access along roads (e.g., marten, wolves). Access control is discussed in the Wildlife

section of the Final EIS where appropriate; however decisions to close or maintain open roads are made 

at a district or project level and therefore are described only generally in the Final EIS. 

Comment: The Draft EIS fails to address the joint statements issued by the Peer Review 

Committee, a distinguished panel of 12 PhD scientists assembled by the PNW Research Station, 

in 1996 in response to the release of the Draft EIS of the 1997 Forest Plan, and in 1997 after the 

release of the Final EIS. The 1996 statement concluded that (1) the best available science 

indicated substantial risk to the viability of wildlife associated with old-growth forests of 

Southeast Alaska; (2) none of the action alternatives included measures which would ensure the 

continued viability of all old-growth associated species on the Tongass; (3) deferring adoption of 

an effective plan to ensure viability of wildlife populations entails serious risk to Tongass wildlife; 
Appendix H 

Comments and Responses H-158 Final EIS 

and (4) the Forest Service should address new alternatives that a full array of necessary 

conservation measures. The 1997 statement concluded that the final management plan did not 

incorporate any of the review committee’s findings in fundamental ways and the plan would not 

protect viable, well-distributed populations of vertebrate species on the Tongass. 

Response: The Tongass conservation strategy has been implemented for 10 years and has not resulted 

in the decreased viability or listing of any species. It continues to be one of the most detailed and 

comprehensive strategies among national forests. In addition, over the course of its implementation the 

level of harvest has been substantially less than that anticipated by the peer review committee during 

their review. The 2008 alternatives also consider the peer review committee recommendations. The 

conservation strategies of Alternatives 1, 2, 3, 5 and 6 include enhanced connectivity through maintaining 

the 1,000-foot beach fringe, Riparian Standards and Guidelines, and other standards and guidelines that 

together would protect at least 66 to 74 percent of the existing POG inside the matrix (development 

LUDs) after 100+ years of maximum Forest Plan implementation (harvesting at the maximum harvest 

level). Further, from 71 to 93 percent of all existing POG on the Tongass would be protected in reserves. 

These alternatives would also provide at least one very large reserve within each biogeographic province. 

Appendix D has more information about the conservation strategy and the science that led to its 

development. 

Comment: Several respondents expressed confusion over the conclusions drawn in Table 2-17 of 

the Draft EIS regarding viability ratings for some of the species under consideration. 

Response: Appendix D of the Final EIS provides detailed background information on the viability 

panel assessments convened prior to the 1997 Forest Plan, and their application to the 2008 Final EIS. 

Comment: Much of the Proposed Forest Plan deals with the management of “buzz words.” The 

terms biodiversity, old-growth, endemics, extinction, protection, and endangered are not 

concisely defined or clearly set in the context of forest management. Old-growth appears to refer 

to “forest that has not been previously harvested by humans.” Local extinction can be at any 

scale and should be defined, as should the term protect, which appears it the context of the 

Forest Plan to be protection from timber harvest. The Final Proposed Forest Plan should also 

define at what level endemism is considered (population, subspecies, species); the plan is also 

contradictory in describing “well-distributed” populations of endemic mammals across the 

Forest” (i.e., if populations are not well-distributed they are not endemic). 

Response: The Glossary, which is located in Chapter 7 of the Proposed Forest Plan, defines these 

terms. Biological diversity is defined as “The variety of life forms and processes, including the complexity 

of species, communities, gene pools, and ecological functions, within the area covered by a land 

management plan.” Endemic is defined as “restricted to a particular locality, or occurring at low levels” 

giving the example of “a particular species or subspecies may occur on only one or a few islands.” 

Extinction is defined as “any species of animal or plant that is in danger of extinction throughout all or a 

significant portion of its range,” the definition given under the ESA. An endemic population may occur 

within a restricted range (i.e., island or group of islands), but can be widely-distributed within this range. 

Extinction, as described under the definition of Endangered, relates to all or a significant portion of a 

species range. 

Management Indicator Species 

Comment: Several respondents made suggestions for species that should be added to the list of 

MIS, including the marbled murrelet, Canada lynx, and wolverine. One respondent believed that 

recommendations made in 1999 by the Interagency Monitoring and Evaluation Group MIS 

subcommittee to reduce the current list of 13 species to 6 had been accepted and implemented on 

the ground for numerous timber sales. This respondent also felt that a discussion of changes to 
Appendix H

Final EIS H-159 Comments and Responses

the MIS list should have been disclosed in the Draft EIS. Another respondent felt that use of the 

MIS concept was appropriate only at very broad scales (i.e., indicators of old-growth) because but 

was not sufficient for finer levels of habitat selection such as specific features within old-growth 

forest (i.e., canopy openings, snags, or downed wood). 

Response: An effort to re-evaluate the current list of MIS has been ongoing since 1999; however it is 

separate from this Forest Plan Amendment because any changes will depend, in part, on the selected 

alternative. Any changes to this list will be considered during this process. As noted in the Final EIS, 

there are currently 13 MIS wildlife species, each of which was addressed in the analysis. Each of these 

species was selected for different reasons. Some are representative of large tracts of old-growth habitat, 

however others were selected for their use of other habitat types, sensitivity to human disturbance, 

importance as subsistence/hunting resources, or use of specific features within old-growth forest (i.e., 

cavity nesters). 

Comment: The Forest Service should not use MIS that are introduced on islands because they 

often do not adequately represent the responses of native fauna to habitat conversion and human 

disturbance. Red squirrels and marten are two examples of MIS that have been introduced to 

several islands in the archipelago and therefore should not be used as MIS in these locations. 

Response: The MIS for the Tongass were selected so under the auspices of the 1982 Planning 

Regulations in which species of interest, whether native or non-native, could be considered as MIS. The 

list of MIS is currently under review and is likely to change in the future. This is based in part on 

evaluations of monitoring information since 1997 and associated analyses summarized in Chapter 3 of 

the Final EIS. 

Wildlife Cumulative Effects 

Comment: The cumulative loss of habitat value for deer, bear, large-tree forests, marbled 

murrelets, and salmon under Alternatives 4, 5, 6, and 7, when considered in combination with 

activities on adjacent non-NFS lands, represents greater than 45 percent of habitat forest-wide, 

and greater than 67 percent of habitat value in the North Prince of Wales and Kupreanof/Mitkof 

biogeographic provinces, as demonstrated by the Coastal Mountains and Forests Ecoregional 

Assessment (Albert and Schoen 2007). 

Response: It is true that two of the most heavily developed provinces are North Prince of Wales and 

Kupreanof/Mitkof. The cumulative loss of old-growth habitat, taking all land-ownerships into account, is 

quantified and discussed in the Wildlife and Biodiversity sections of the Final EIS. Table 3.9-20 in the 

Biodiversity section indicates that the cumulative loss of POG after 100+ years of Forest Plan 

implementation at maximum levels would be 24 to 29 percent for all of Southeast Alaska under these four 

alternatives counting all ownerships. For the North Central Prince of Wales province the cumulative loss 

would be 49 to 56 percent and the cumulative loss would be 39 to 47 percent for the Kupreanof/Mitkof 

province.. 

Comment: Assumptions that non-federal lands have zero habitat capability and that there is a 

direct relationship between the amount of productive old-growth and the abundance of marbled 

murrelets and flying squirrels are incorrect. 

Response: Substantial timber harvest has occurred on non-federal lands adjacent to the Tongass. 

Therefore the analysis in the Wildlife section takes a conservative approach by assuming that these lands 

provide little habitat value because continuing harvest activities are expected to occur in the future. The 

Wildlife section recognizes that relatively little is known about the terrestrial habitat relationships or 

population trends and abundance of marbled murrelets in Southeast Alaska, though nesting has been 

documented in old-growth. Therefore, the analysis focuses primarily on harvest of productive old-growth 
Appendix H 

Comments and Responses H-160 Final EIS 

and because the scope of the analysis for this Forest Plan Amendment is related to timber demand. 

Harvest of productive old-growth is listed in the Final EIS as one of several possible causes of the 

estimated overall declines documented in the Alaska marbled murrelet population. Similarly, the Final 

EIS does not assume that flying squirrel abundance is solely dependent on old-growth but cites recent 

research that has documented their use of peatland-scrub-mixed conifer forests. 

Comment: Table 3.4-3 of the Draft EIS suggests that Alternative 7 would reduce the productive 

old-growth by 31 percent. How is this possible when we will harvest less than 21 percent of the 

commercial timberland? Is the table referring to just the commercial old-growth outside of the 

congressional set-asides? 

Response: Table 3.4-3 of the Draft EIS states that currently 88 percent of the POG existing in 1954 

remains on the Tongass. Under Alternative 7, 69 percent of 1954 POG would remain long-term if percent 

Alternative 7 is selected and harvests at the highest rate modeled. The table also includes non-NFS 

harvests and the 31 percent refers to the reduction about 100 years from now relative to 1954 levels. In 

the Final EIS, this estimate has been refined to a 30 percent reduction relative to original POG levels. 

Restoration and Young-Growth Management 

Comment: Silvicultural treatments have been shown to be effective on the Tongass in increasing 

the amount of understory shrubs important as deer forage and as habitat for small mammals and 

shrub-nesting birds and should be recognized for their current and future contributions to habitat. 

Several respondents requested that the Final EIS acknowledge that there are many uncertainties 

related to the benefits and application of young-growth management as a tool for enhancing 

wildlife habitat given that some studies have documented correlations that indicate adverse 

effects (i.e., increased risk of black-tailed deer fawn mortality associated with pre-commercial 

thinning). 

Response: A statement about the uncertainties related to young-growth management has been added 

to the text. 

Comment: The Forest Service should shift priorities from timber harvest and road building to 

stream restoration and habitat enhancement. 

Response: Stream restoration and habitat enhancement have been priorities on the Tongass for many 

years. The Final Proposed Forest Plan lists the maintenance and restoration of aquatic habitats as a 

forest-wide multiple use goal and lists designing and implementing structural and non-structural wildlife 

habitat improvement projects as a management objective (Forest Plan 2-3). 

Comment: Please explain why you are adding “habitat restoration treatment” as a reason that 

programmed timber harvest can be done in the beach buffer. We fully support such restoration 

treatments, including commercial thinning, but this needs to be done with particular caution. The 

beach fringe should not be logged for commercial gain in anything other than a way that 

specifically benefits the beach fringe buffer values. When those interests overlap, then 

commercial timber harvest should be pursued. 

Response: No programmed timber harvest would occur in the beach buffer; however, thinning or other 

treatments could occur if it is designed to improve wildlife habitat in dense young-growth stands. Timber 

cut for this purpose, if excess to down woody debris needs, could be sold, but this volume would not 

contribute to ASQ. 
Appendix H

Final EIS H-161 Comments and Responses

Comment: We recommend allowing selective harvest of second-growth timber in portions of the 

beach and estuary buffers that is more than 500 feet from the water, and in portions of riparian 

buffers that are more than 100 feet from rivers and streams; we do not support old-growth harvest 

in these buffers. 

Response: The Final Proposed Forest Plan permits thinning dense young-growth stands in beach and 

riparian buffers to improve habitat. 

Threatened, Endangered and Sensitive Species 

Comment: Several suggestions were made to add species to the Regional Forester’s Sensitive 

Species list as part of the Forest Plan Amendment. Several respondents suggested listing the 

marbled murrelet, given that the recent USGS status review indicates declines in the available 

habitat and the population in Southeast Alaska. Suggestions were also made to list Martes 

caurina, given its low numbers on Kuiu Island. Another respondent suggested adding endemic 

species.

Response: The Regional Forester’s Sensitive Species list is currently undergoing review but this 

endeavor is separate from this Forest Plan Amendment and will occur on a separate time frame. 

Comment: The U.S. Department of the Interior concluded that because the Kittlitz’s murrelet, 

found in marine waters north of the Tongass, is most susceptible to recreation near tidal glaciers 

and high elevation land activities such as mining, changes reflected in the Proposed Forest Plan 

do not appear to pose a significant risk to this species. 

Response: We concur with this conclusion, as indicated in the Final EIS. 

Comment: No threatened or endangered species under the jurisdiction of the Fish and Wildlife 

Service exist within the project area. In response to the court-ordered remand the USFWS is 

currently evaluating the status of the Queen Charlotte goshawk and its habitat to determine if 

Vancouver Island is a significant portion of its range and, if so, whether listing under the ESA is 

warranted for all or part of the goshawk’s range. In addition to the goshawk, the Alexander 

Archipelago wolf has previously been petitioned for listing; and the Kittlitz’s murrelet is a 

candidate species. In addition there are numerous other endemic and sensitive species on the 

Tongass that will require continued collaboration between the Forest Service and USFWS in 

developing conservation provisions. 

Response: The only federally listed species under the jurisdiction of the Fish and Wildlife Service 

determined in the past to occur on the Tongass National Forest is the peregrine falcon, which was 

delisted in 1999. An updated biological assessment has been prepared that addresses effects to this 

species. Information from the recent goshawk status review and 12-month finding has been incorporated 

into the Final EIS. Information regarding the Kittlitz’s murrelet is also incorporated. We agree that there 

are many opportunities for collaboration with the Fish and Wildlife Service and are committed to 

continuing these endeavors. 

Endemic Species 

Comment: Standards and guidelines related to endemic mammals should emphasize climate 

change and connectivity between populations. Marten should be an emphasis of survey efforts. 

Response: Standard and guideline VIII.A.2 of the Final Proposed Forest Plan relates to connectivity 

between populations of endemic mammals. Regarding species to survey, the species listed in standard 

and guidelines VIII.A.1.C of the Final Proposed Forest Plan are given as examples; it is inferred that 
Appendix H 

Comments and Responses H-162 Final EIS 

marten are included in the medium-sized mammal category. Also see comments and responses in the 

Climate and Air section of this appendix. 

Comment: The Draft EIS fails to adequately assess impacts to endemic mammals and the 

proposed plan fails to ensure viability of these species. The Draft EIS does not address impacts 

of the proposed plan on endemic mammals. It also fails to list specific islands or groups of 

islands with endemic fauna or recognize that a different management scheme may be warranted 

for such areas. Despite concerns about the inadequacy of the conservation strategy to protect 

endemic species expressed at the recent 2006 Conservation Strategy Review Workshop the Draft 

EIS fails to recognize these concerns. 

 

Response: Additional information, much of which was presented at the 2006 Tongass Conservation 

Strategy Review workshop, has been added to the Final EIS text, including the opinion of some scientists 

that an island-centered management plan would be appropriate for the Tongass. Effects of the proposed 

plan on endemic mammals are discussed in the Wildlife section; additional discussion related to the 

ability of the conservation strategy to support viable endemic mammal populations is included in 

Appendix D. 

Comment: Several comments were received regarding the project-level Forest Plan requirement 

for mammal surveys. Suggestions included requiring surveys for endemic mammals on all 

islands, not just those less than 50,000 acres; requiring surveys for all timber sales; requiring that 

surveys be conducted for rare and endemic birds, amphibians, and insects; and that the Final 

Proposed Forest Plan include considerations for adjusting timber harvest on islands as more 

information is gained on the habitat associations and population status of endemic species. 

Suggestions were also given for the intensity of surveys. 

Related comments suggested that standards and guidelines basing the need for endemic mammal 

surveys on whether there is a “high likelihood” of the presence of an endemic mammal is too low 

a standard, given the lack of knowledge about endemics on the Forest. 

Response: Surveys are required on all islands smaller than 50,000 acres and on islands larger than 

50,000 acres if there is a high likelihood that endemic taxa are present and a high likelihood that these 

species would be affected by the proposed project (Wildlife Standards and Guidelines). Survey intensity 

will be decided on a project by project basis, depending on the size and type of project and level of 

anticipated disturbance, and information gained from these surveys (as well as from ongoing research) 

will be used to minimize the effects of forest management activities on endemic species. In addition, sitespecific NEPA analysis generally consider the effects of the project on a wide range of wildlife species. 

Biologists use a combination of existing information, surveys and habitat assessment to determine 

effects. While having survey information is valuable, biologists generally assess the effects to species 

habitat if the species is suspected to be present, whether or not actual presence is verified. 

The OGR system in the conservation strategy fundamentally is a ‘coarse filter’ approach to addressing 

wildlife viability and the conservation of biodiversity. In addition, a variety of other coarse filter standards 

and guidelines provided connectivity between the reserves. At the “fine filter” level, species-specific 

standards were fully considered in light of additional information such as conservation assessments, 

panel assessment results, etc. and appropriate standards and guidelines were incorporated for species 

that needed additional protection measures to assure their viability and well-distributed status. 

The Wildlife Standards and Guidelines direct the Forest to conduct surveys when existing information on 

the distribution of endemic mammals is inadequate to assess project-level effects. It states that surveys 

should be conducted if there is a “high likelihood” that an endemic mammal could be affected by the 

proposed project, not if there is a high likelihood of its presence. Thus a proposed timber harvest in an 

area with little or no information on endemic mammals would require surveys. 
Appendix H

Final EIS H-163 Comments and Responses

As new information on endemics or other species is obtained, changes to the amended Forest Plan can 

be considered through the periodic Forest Plan review process, which occurs every 5 years, or at any 

time through an amendment. 

Comment: Some respondents suggested that removing islands less than 1,000 acres from the 

timber base (to eliminate risk associated habitat loss or alteration) was sufficient to ensure 

viability of the 14 endemic mammals considered by the risk assessment panel and that other 

protective measures were unnecessary and costly, resulting in road construction and 

development in areas that would otherwise be untouched. 

Response: Since 1997 a wealth of new information has been gained regarding endemic mammals on 

the Tongass which, in addition to expanding the knowledge base, has highlighted the substantial 

uncertainties that exist related to the population status and distribution of many species. Recent studies 

have also identified species in addition to the 14 species considered by the risk assessment panel and 

indicated that within Southeast Alaska the Prince of Wales Island complex is an endemism hot spot. 

Protective measures for endemic mammals include conducting surveys in areas where knowledge about 

the presence or distribution of endemic species is lacking and where projects could affect endemic 

species. Given the uncertainties that exist and the prevalence of endemism, these protective measures 

are appropriate for minimizing effects to endemic species. Moreover, conducting project-specific surveys 

for endemic mammals has no relation to the expansion of road construction and development in 

undeveloped areas. 

Comment: Given that the insular landscape of the Alexander Archipelago has produced highly 

endemic populations, and is considered a hotspot for lineage diversity. The 2006 Conservation 

Strategy Review indicated that endemism was a “top priority” for the Tongass and that the 

Conservation Strategy fails to adequately address endemism on the Tongass. A new 

conservation paradigm should be developed for the Tongass under which each island is 

considered a unique biological unit until a better understanding of connectivity among these 

divergent populations is developed. Similar comments related to the lack of alternative 

conservation strategies considered in the Draft EIS. 

Response: The general structure of the conservation strategy includes a system of OGRs and speciesspecific standards and guidelines that apply to matrix lands. Furthermore, the development of this 

strategy for the 1997 plan did take into account endemic species. Given that there are many 

uncertainties related to the effectiveness of the conservation strategy, each element of the conservation 

strategy requires consistent implementation across all islands. However, during project implementation, 

characteristics of individual islands are taken into account. All islands less than 1,000 acres are also fully 

protected. In addition, in a review of the conservation strategy, which has been incorporated into the 

Final EIS, Haufler (2007) indicated that a complete revision of the conservation strategy is not needed. 

Increasing our knowledge of endemic mammals continues to be a high priority for information needs on 

the Tongass (Appendix B of the Final Proposed Forest Plan) and as new information on endemics or 

other species is obtained, changes to the amended Forest Plan can be considered through the review 

process. See also related comments and responses above. 

Comment: The location and status of endemic species is absent from the Draft EIS. The Forest 

Service is not incorporating scientific information on sensitive species into its management plans 

and not trying to locate this information. Arthropods, birds, and plants have not been surveyed as 

thoroughly as mammals, though there is a high likelihood that endemic forms will be found 

across these groups. Surveys should be required for non-mammalian rare and endemic species. 

Response: Knowledge related to endemism on the Tongass (i.e., number of endemic species, 

distributions, and population status) is constantly expanding and being refined. The Final EIS addresses 

this by referencing some of the most recent peer-reviewed publications on this topic, but focusing the 
Appendix H 

Comments and Responses H-164 Final EIS 

discussion of endemics on larger, Forest-level issues including landscape connectivity and fragmentation 

which relate to all endemics. We agree with the statement that survey efforts and existing scientific 

information are skewed toward endemic mammals but that there are likely many more non-mammalian 

endemic species on the Tongass. See also related comments and responses above. 

Comment: The second definition for endemic in the Proposed Forest Plan glossary (“low 

occurrence of individual trees blowing over in a particular location”) should be removed as this 

definition does not appear anywhere in the Proposed Forest Plan or Draft EIS. 

Response: This term is used in the EIS. The definition in the glossary has been modified to better 

explain how it is used in the text. 

Comment: The process for designating a subspecies is subjective and imprecise, and there are 

no quantitative criteria on which to base such designations. Therefore, it is inappropriate to 

uncritically accept designations such as the Queen Charlotte Goshawk and the Alexander 

Archipelago Wolf, which figure prominently in the Proposed Forest Plan. 

Response: The Forest Service does not have legal authority to make determinations about the 

taxonomic status of a species. Subspecies addressed by forest planning documents are those currently 

recognized by the U.S. Fish and Wildlife Service. 

Comment: The “Island Theory of Biodiversity” does not fit well with the Tongass. We have 

islands of development in a sea of old-growth. The short reaches of water between islands have 

proven not to be a barrier. Animals swim from island to island quite easily, which is why even 

very small islands have a diversity of wildlife. Differing areas traditionally have more or less of a 

particular species regardless of logging. 

Response: It is true that some larger, more mobile species do swim between islands; however there are 

many smaller, less mobile species that are not capable of swimming and thus do not interact with 

subpopulations on other islands. It is likely that these less mobile animals populated the islands during 

periods when low sea levels created land connections. 

Comment: Due to levels of past timber harvest, every timber sale on Prince of Wales Island 

should go through a rigorous scientifically designed inventory to assess impacts on endemic 

plants, birds, amphibians, and mammals. 

Response: Endemic species were considered in the conservation strategy and some standards and 

guidelines, including Legacy, also take them into account. As noted in the Wildlife section of the Final 

EIS, there are likely many endemic non-mammalian species on the Tongass. However, current Forest 

Plan standards and guidelines focus on endemic mammals. Under the Forest Plan, surveys will be 

required for timber harvests on larger islands where there is a high likelihood that endemic taxa are 

present and a high likelihood that they would be affected by the proposed project. The extent and rigor of 

surveys will be commensurate with the degree of existing and proposed forest fragmentation, and 

potential risk to endemic mammals that may be present. See also related comments and responses 

above. 

Birds—General 

Comment: The selection of bald eagle nest sites in proximity to the shoreline makes it unlikely 

that a reduction in the beach buffer under Alternative 7 would result in risk to bald eagle 
Appendix H

Final EIS H-165 Comments and Responses

populations. Given the federal regulation for a 330-foot zone around bald eagle nests, a 330-foot 

beach buffer should be more than adequate. 

Response: There is no statement in the analysis of effects to bald eagles that a reduction in the beach 

fringe under Alternative 7 would result in risk to the bald eagle population but rather it would reduce 

protection of nests located beyond 500 feet of shoreline to the 330-foot buffer surrounding them. Thus 

nesting habitat beyond 500 feet of the shoreline and outside of the nest buffers could be removed by 

timber harvest or road building. As stated in the Draft EIS, recent research indicates that nesting activity 

is reduced within 948 feet (300 m) of clearcuts, indicating that the 330-foot buffer may be inadequate to 

mitigate effects of harvest (Gende et al. 1998). 

Comment: The local distribution of breeding birds may change but it is unlikely that any species 

will be at risk of major population declines. Timber harvest may create suitable habitat conditions 

for a number of species.

Response: It is true that timber harvest may adversely affect some species while benefiting others. A 

statement regarding the potential benefits of timber harvest to some bird species has been added to the 

Final EIS. 

Comment: Surveys for raptors in proposed management areas should include forest owls, 

specifically western screech owls, barred owls, and northern saw-whet owls. 

Response: The Wildlife standard and guideline for Heron and Raptor Nest Protection in the Final 

Proposed Forest Plan specifies that surveys required for raptor nesting habitat include the habitat of 

hawks and owls. 

Comment: Classical fragmentation and effects of habitat loss (I.e., nest parasitism, loss of 

species, increased predation) are unlikely to be realized on the Tongass National Forest given the 

amount of remaining old-growth habitat, the rapid reestablishment of young forest on harvested 

sites, and the fact that some studies in western forests have not documented the same 

fragmentation/edge effects found in eastern forests. 

Response: While studies of bird community response to timber harvest alternatives to clearcutting in 

Southeast Alaska indicate that creation of forest edge may increase nest predation rates, it is true that the 

actual response depends on a broad array of factors and is highly variable. This has been clarified in the 

Final EIS text. 

Comment: Resident and migratory landbirds have been neglected in the planning process. 

Monitoring and habitat management considerations of cavity-nesters, other forest-associated 

species, and other species identified by state and national conservation plans as vulnerable (i.e., 

the olive sided flycatcher) should be incorporated into the Final Proposed Forest Plan. 

Response: Maintenance of the biodiversity of all species was considered in the development of the 

conservation strategy. The Forest Service cooperates in the Alaska Landbird Monitoring System (ALMS) 

and other bird monitoring programs. Additional information needs by program area, including wildlife, will 

continue to be evaluated and prioritized using the framework described in Appendix B of the Final 

Proposed Forest Plan. 
Appendix H 

Comments and Responses H-166 Final EIS 

Marbled Murrelet 

Comment: Respondents expressed opposing views on the status of marbled murrelet 

populations in Southeast Alaska. Some respondents were under the impression that the 

population was stable and did not appear to be in trouble, suggesting that the species was 

unlikely to be affected by levels of timber harvest proposed under the alternatives. Others cited 

the recent USGS status review (Piatt et al. 2007) which indicates that the population has declined 

substantially, as has suitable habitat. These respondents requested that this status review be 

referenced in the Final EIS and that additional species-specific standards and guidelines be added 

to the Final Proposed Forest Plan. One respondent commented that the analysis should consider 

effects of timber harvest on marbled murrelet habitat and should quantitatively evaluate how 

much marbled murrelet habitat is protected by OGRs and the effectiveness of this protection.

Response: Information on marbled murrelet ecology and status in Southeast Alaska published in 2007 

has been added to the text. Effects of timber harvest on old-growth habitat are discussed under the 

marbled murrelet subsection of the wildlife analysis and tables indicating the distribution and protected 

status of this habitat are provided in the Biodiversity section. 

Comment: Uneven-aged management should be specifically defined in relation to its use as 

mitigation for loss of marbled murrelet habitat and information on gap sizes and interspersion of 

individual trees or patches in cutting units should be provided to judge the effectiveness of this 

prescription.

Response: The definition and application of uneven-aged management is provided in the Timber section 

of the Final EIS. As noted in the Timber section, there is a lack of scientifically documented information 

on uneven-aged harvest in Southeast Alaska from which to document the effectiveness of this 

prescription. This has been the subject of retrospective study and is outside the scope of the Final EIS 

analysis. In terms of marbled murrelet habitat, uneven-aged management by definition reduces the loss 

of suitable habitat by maintaining mature forest within harvested units. 

Comment: Providing 600-foot buffer zones around marbled murrelet nests provides no effective 

benefit because nests are difficult to detect. Respondents suggested eliminating this S&G and 

reinitiating marbled murrelet at-sea surveys. Other respondents voiced support for project-level 

surveys.

Response: A statement about the difficulty of detecting marbled murrelet nests has been added to the 

text. Given the current legal status of the marbled murrelet, it is unlikely that either at-sea or forest-wide 

nest surveys would be reinitiated or required. However, the Forest Service recognizes that declines in 

the population and available nesting habitat in Southeast Alaska have been documented. Information 

from the recent USGS status review (Piatt et al. 2007) has been added to the Final EIS text. The 

occurrence of marbled murrelets is assessed at the project level and surveys within suitable habitat could 

be conducted concurrently with other studies. 

Comment: It is unclear what Forest Service supported marbled murrelet research is ongoing as 

stated in Appendix B.

Response: Appendix B of the Final Proposed Forest Plan has been modified to reflect the overall 

information needs program and acknowledges the many efforts to gain such information that is ongoing 

by state and federal agencies, academia, and many others. Specifics to marbled murrelet are not 

included in Appendix B now, but left to the appropriate entities that continue to study the species. 

Appendix B includes a greater intent to share and coordinate between those entities so all can benefit 

more readily when such information is available, as well as explore opportunities to share in the 

investments for new information. 
Appendix H

Final EIS H-167 Comments and Responses

Comment: For marbled murrelets, maintaining old-growth habitat for nesting is essential to the 

persistence of the species. When fully implemented the Tongass conservation strategy should 

provide adequate nesting habitat, therefore the old-growth reserve network should be maintained 

in the Final Proposed Forest Plan. 

Response: The 1997 marbled murrelet panel assessment determined that the conservation strategy, 

including the old-growth reserve system, would have a high likelihood of maintaining well-distributed, 

viable populations in Southeast Alaska. 

Comment: There is no science to support the conclusion that Alternative 7 would harm the 

viability of marbled murrelets. 

Response: Additional information has been added to the Wildlife section of the Final EIS and Appendix 

D has been added which summarizes the 1997 marbled murrelet panel assessment. 

Comment: The Draft EIS does not explicitly evaluate the cumulative effects of the alternatives on 

the long-term sustainability of marbled murrelets in Southeast Alaska. 

Response: The effects analysis for marbled murrelets draws on the findings of the 1997 expert panel 

assessment. It is important to note that the conclusions drawn by the panel took into account the level of 

past and likely future harvest on non-NFS lands. Likelihood scores, which are described in more detail in 

Appendix D of the Final EIS, recognized this cumulative harvest. Therefore, the viability ratings represent 

a cumulative effects prediction for each alternative. The Biodiversity section quantifies the amounts of 

total POG, POG in reserves, POG in matrix, high-volume POG, large-tree POG, and other categories of 

POG at present and in the future under the alternatives. 

Goshawk 

Comment: Several respondents expressed concern that the existing and proposed Goshawk Nest 

Standards and Guidelines do not provide adequate protection. Reasons cited were that only a 

small number of nests have been found; proposed standards and guidelines potentially allow all 

the trees around a nest site be cut as long as there are 300 acres old-growth within a 0.75 mile 

radius (Threatened and Endangered Species II.K.1.e); and that a minimum no-harvest buffer of 500 

acres surrounding active and alternate nests is needed to protect active goshawk nests from 

disturbance, preserve most alternate goshawk nests, and provide suitable goshawk post-fledging 

areas. Some respondents also requested that the Final Proposed Forest Plan retain the 

requirement for pre-project surveys using current protocols developed in cooperation with other 

agencies and that the Forest Service adopt an inventory and monitoring program for goshawk 

nests consistent with the guidance found in its recent publication on the topic (Woodbridge and 

Hargis 2006). 

Response: Existing standards and guidelines require that a 100-acre no-harvest buffer be maintained 

around confirmed and probable active goshawk nest sites. The allowance for harvest in the future 

applies only to probable nest sites, not documented nest sites, and only if there is no evidence of 

occupancy in the future after two years. Though there is some risk that an occasional inactive nests may 

be affected by timber harvest, a majority of goshawk nests on the Tongass are protected by virtue of the 

fact that OGRs, beach and stream buffers and other standards and guidelines, and additional acreage 

removed from the timber base due to economic reasons protect over 90 percent of the existing POG over 

the life of the Forest under Alternatives 1, 2, 3, and 6. Additionally, on a forest stand level, most goshawk 

nests that have been found on the Tongass within timber sale project areas were included within the 

boundaries of small OGRs when districts were doing project level adjustments. This resulted in larger 

protection for most goshawk nests than just the nest stand. In regards to nest surveys, the Tongass will 

continue to do goshawk surveys for timber sale planning prior to NEPA decisions. Actual protocols will 
Appendix H 

Comments and Responses H-168 Final EIS 

consider current research on goshawk inventory and monitoring, including Woodbridge and Hargis 

(2006). This requirement was mistakenly deleted from the Proposed Forest Plan, but has been added to 

the Final Proposed Forest Plan. Appendix D of the Final EIS provides additional discussion of the 

rationale behind the proposed changes to the Goshawk Standards and Guidelines. 

Increasing nest buffers to greater than 100 acres was considered by USFWS in their November 2007 

finding (Federal Register vol 72, no. 216 page 63123). While they acknowledge that larger buffers would 

likely enhance goshawk conservation by providing better habitat for fledglings in the immediate vicinity of 

the nest, they conclude that lack of larger buffers is not expected to reduce fecundity or survival to an 

unsustainable level because of the amount of nesting habitat that is retained in OGRs in nondevelopment LUDs and other retained forest patches retained in the matrix. We concur with this and 

therefore, did not consider an increase in nest buffers. 

Comment: Several respondents requested the inclusion of recent peer-reviewed literature on 

goshawk habitat requirements needs to be expanded to include annual and final Southeast Alaska 

specific reports produced by ADF&G (e.g., Flatten 2001), diet studies published by Lewis and 

colleagues (2006), and other published studies from the Pacific Northwest. Some respondents 

also requested the clarification that goshawks inhabit western forests rather than all forests in 

North America, and that the statement that the Queen Charlotte goshawk is a distinct subspecies 

be attributed to a primary reference rather than the 1996 status review (Iverson et al. 1996). 

Response: Additional scientific information on goshawks, including that listed above, has been added to 

the Final EIS. 

Comment: The Forest Service should consider using habitat associations of key goshawk prey 

species as a tool for sustaining goshawks on the Tongass. 

Response: This comment stems from a consideration suggested during the 2006 Conservation Strategy 

Review Workshop. We believe that the conservation strategy coupled with application of site-specific 

nesting habitat standards and guidelines in the Proposed Forest Plan provide adequate protection to 

maintain sustainable goshawk populations. We have however, added the prey habitat relationship topic 

to Appendix B of the Final Proposed Forest Plan as one of the higher priority information need categories. 

Comment: Several comments were received regarding the association of goshawks with oldgrowth forests. Some respondents felt that the statement in the Draft EIS regarding goshawks 

nesting in forest types other than old-growth (Draft EIS p 3-161 to 3-162) incorrectly implied that 

goshawk telemetry data from Southeast Alaska has produced similar results to those observed in 

the Southwestern United States which showed use of a greater range of forest types for nesting, 

clarifying that telemetry data from the Tongass still suggests a strong selection for old-growth. In 

contrast, other respondents felt that the relationship between goshawks and old-growth forest 

was overemphasized, given new research, citing a study (Flatten et al. 2001) on the east side of 

Douglas Island, which had been clearcut in the early 1900s. 

Response: As noted in the Wildlife section of the Draft EIS, recent research indicated that goshawks use 

a greater variety of habitats than once thought and that there is some documented use of second-growth 

by nesting goshawks, though most goshawks in Southeast Alaska are associated with older forests. 

Goshawks can nest successfully in relatively young stands if adequate-sized trees are available to 

support a nest; however a majority of the second-growth on the Tongass is less than 50 years old and 

lacks these conditions. Flatten et al. (2001) documented higher nesting activity in the contiguous secondgrowth forests of northern Southeast Alaska (Douglas Island) compared to the more fragmented forests 

of southern Southeast, which they attributed to the fact that as second-growth stands mature they 

increase in contiguousness and thus in forest-dwelling prey and suitable hunting habitat. The authors 

noted that this trend may also reflect the lack of prey (squirrels and blue grouse) in southern Southeast 
Appendix H

Final EIS H-169 Comments and Responses

Alaska, though they emphasized that region-wide there is a lack of prey associated with open habitat, 

rendering fragmented forests less productive for goshawks. 

Comment: The Draft EIS fails to discuss the scientific opposition to the current 100-year harvest 

rotation in relation to its effects on goshawks and is therefore in violation of NEPA. The Goshawk 

Conservation Assessment prepared for the 1997 EIS recognized a rotation of 300 years as 

adequate for regaining old-growth forest characteristics in harvest units; a 300-year rotation was 

also recommended by the Department of the Interior and by the 2002 Supplemental Wilderness 

Review. 

Response: In the Goshawk Conservation Assessment, Iverson et al. (1996) differentiated two types of 

rotations: a 300-year “ecological” rotation applied to all old-growth as a means to express age class 

distribution over time, and a silvicultural rotation applied to suitable acres scheduled for timber harvest. 

Iverson et al. (1996) concluded that landscapes that maintained a forest age structure consistent with a 

300-year ecological rotation would provide a high likelihood of sustaining goshawks. This composition 

would generally consist of one-third each of 0- to 100-year old stands, 100- to 200-year old stands, and 

200-year old or older stands, categories with increasing value to goshawks, which can be accomplished 

by implementing a shorter harvest rotation. Notice that this is on a landscape scale like at the VCU scale 

or larger. Text has been added to the Final EIS to clarify this. 

Marten 

Comment: The statement in the Draft EIS about the lack of clear correlation between marten 

population trends and habitat alteration is related to the lack of effort to study this dynamic or 

lack of data (i.e., no long-term datasets), rather than there being no relationship. Some 

respondents requested that marten harvest on Kuiu Island be separated out from the rest of 

harvest in GMU 3 for clarification because of low marten numbers on that island. The lack of 

information regarding the distribution of the endemic M. caurina marten subspecies on the 

Tongass needs to be emphasized in the EIS, particularly the fact that many unsampled islands 

could support endemic marten populations, and made a high priority issue. The EIS should 

devote larger attention to fragmentation of marten habitat.

Response: These points have been clarified in the text in the Final EIS. Information on marten harvest 

on Kuiu Island has been added to the Final EIS text. A statement about the status of information on the 

distribution of endemic marten has been added to the Final EIS text. Additional discussion of 

fragmentation has been added to the marten subsection of the Final EIS. 

Comment: Available data suggest old forest is important for marten, but they will also use other 

habitats including younger forest provided that structural features such as large downed logs are 

present. Plan alternatives with the highest level of timber harvest retain 76 percent of productive 

old-growth suggesting suitable marten habitat will continue to exist across the Tongass. A more 

apparent contribution to population levels is fur trapping which confounds interpretation of 

habitat need and which should be amenable to regulatory controls. 

Response: We agree with the statements regarding marten use of younger forests and that plan 

alternatives will retain a substantial amount of marten habitat, as stated in the Draft EIS. It is true that 

trapping is one of many factors that affect marten population levels. 

Comment: There is no science that suggests that marten require legacy trees. 

Response: Additional information related to marten use of legacy structure has been added to the Final 

EIS text and in Appendix D. 
Appendix H 

Comments and Responses H-170 Final EIS 

Comment: Some respondents were concerned that the Draft EIS relied on the marten model to 

predict marten habitat capability due to various inadequacies. 

Response: The marten habitat capability model was not specifically used in the Draft or Final EIS; 

however, the acreage of high-volume POG below 1,500 feet elevation was used as one measure of 

habitat. 

Comment: Marten viability is only guaranteed by large, unfragmented areas of high volume oldgrowth that is not accessible to legal or illegal trapping. Rather than disclose or analyze this, the 

Draft EIS relies on the Proposed Forest Plan to adequately protect this species. The Draft EIS fails 

to analyze how various alternatives will affect marten survival across the landscape and 

particularly within islands such as Kuiu where concerns for this species have been documented 

by the scientific community. 

Response: As stated in the Draft EIS, marten are wide ranging and require large tracts of contiguous 

habitat to move across the landscape. Further, the Draft EIS notes that although marten populations 

appear to be sensitive to habitat alteration, there is no clear correlation between population trends and 

habitat change. This is due to the lack of research on this dynamic and the absence of long-term 

population datasets, in addition to the many unknowns related to marten distributions on the Tongass. 

Therefore the effects analysis focuses on habitat alternation. 

Maintaining viability and well distributed population of marten is dependent on many factors, including 

habitat, prey abundance and trapping mortality. Assuring viable marten populations through trapping 

regulations involves cooperation with the State and the Federal Subsistence Board. While the Forest 

Service has a role in setting harvest regulations through the Federal Subsistence Board, the Forest 

Service, by itself, cannot set or manipulate wildlife harvest levels. 

Comment: Some respondents expressed concern over the Kuiu Island population of endemic 

marten because there are two approved timber sales (Crane Rowan and Threemile) and one 

planned timber sale (Kuiu Timber Project) proposed on a proportion of the island where this 

species is known to occur. 

Response: The Final EIS discloses effects to marten and the likelihood of maintaining viable and welldistributed populations, based in a large part on the amount of land within the suitable timber base. 

Timber sales fall within the suitable land and therefore, viability concerns have already been addressed at 

the Forest Plan scale. The NEPA analysis for these timber sales considered site-specific issues, 

including marten habitat, documented in their EISs, and included mitigation to protect marten (i.e., Marten 

Standards and Guidelines). Individual timber sales are not the appropriate scale to address issues 

related to viability on a wide-ranging species such as marten. 

Comment: Several comments were received regarding guidelines marten and road closures. One 

respondent felt that Marten standard and guideline XVIII. A.1.3 requiring road closures where 

roads are a significant factor in unsustainable mortality is important. In contrast, another 

respondent commented that it is unnecessary to perform specific road closures in areas of 

identified marten mortality due to trapping because ADF&G is capable of implementing 

appropriate enforceable regulations restricting trapping. 

Response: The Final Proposed Forest Plan clarifies open and closed road density analysis 

requirements for consistency in helping to determine road influences on marten mortality that can be 

incorporated into Travel Management planning with the objective of reducing mortality risk using local 

knowledge of habitat conditions, spatial location of roads, and other factors rather than solely relying upon 

road densities. This analysis would be a collaborative effort between the Forest Service and ADF&G to 

assess the relationship between hunter/trapper marten harvest and human access. Note also that the 
Appendix H

Final EIS H-171 Comments and Responses

open road density restrictions do not need to be applied without consideration of marten trapping harvest 

levels. Several thousand marten are trapped on a sustainable basis each year in Southeast Alaska. 

Wolf 

Comment: Some comments stated that the Draft EIS failed to consider the effects of climate 

change and other stochastic events on wolves and the predator-prey dynamic of wolves and deer. 

Wolves are depended on deer and the EIS needs to consider how declines in deer populations 

due to climate change will affect wolves. 

Response: The exact effect of climate change on deer and wolves is uncertain; however, most 

researchers expect warmers winters. Current science supports that severe winters are the greatest threat 

to deer populations, as some comments state. Juday et al, (1998) predict that it is likely that there will be 

warmer winters and low snowfall in low elevation forests and this will lead to higher deer populations, 

which would increase prey for wolves. Conversely, Juday et al. also predict increased large-scale blow 

down from the increased in storm activity, though, as the Final EIS notes, this has not occurred even 

though the number of days with gale-force winds has doubled since 1950. Models cannot accurately 

predict whether snowfall will increase or decrease or whether blow down will increase or decrease in lowelevations; therefore, they cannot predict the effect on deer and wolves. This is why monitoring the 

effects of climate change on wildlife habitat was incorporated into Chapter 6 of the Proposed Forest Plan. 

One strategy the Forest is strongly considering is thinning dense young-growth stands in low-elevation 

areas, such as the beach fringe, to increase forage and to speed the development of mature forest 

structure. This may improve low-elevation winter habitat for deer, and therefore for wolves. 

Comment: Some respondents questioned the statement in paragraph 2 on 3-170 of the Draft EIS 

that no clear link had been established between wolf population numbers and changes in habitat 

characteristics.

Response: This paragraph is referring to a direct link between project level habitat changes caused by 

forest management activities (e.g., timber harvest) and wolf population change on the Tongass. As 

noted, datasets available for monitoring wolves are insufficient for detecting all but very large changes in 

the wolf population and are not designed to track trends in the population resulting from changes in their 

habitat due to Forest Service actions. The Final EIS states that deer are the primary prey of wolves in 

Southeast Alaska, and the significance of predator/prey interactions indicates that wolf persistence is 

directly linked to deer habitat capability. That said, data on deer population trends across the Forest are 

also inadequate (i.e., consisting of limited pellet count data in heavily hunted GMUs) to enable a direct 

comparison between habitat changes associated with forest management activities and the Tongass deer 

population. 

Comment: Respondents pointed out that a substantial decline in deer population could result in 

gaps in wolf distribution, particularly on islands, but a more likely outcome would be that wolf 

population density would be reduced as pack home range size increases. They also suggested 

that if deer numbers decline substantially wolves may experience increased harvest pressure 

from subsistence users in an effort to protect deer, which could ultimately further reduce wolf 

genetic diversity.

Response: Information on the potential response of the wolf population to changes in the deer population 

has been added to the Final EIS. This is speculative at best. If decreases in prey reduced wolf 

populations, density of wolves would also be reduced, decreasing opportunities to harvest wolves, 

despite potentially increasing pressure to harvest wolves. If over harvest of wolves were to become a 

concern, harvest regulations and closure of specific areas are tools the State and Federal Subsistence 

Board may use to limit that harvest. 
Appendix H 

Comments and Responses H-172 Final EIS 

Comment: Density-dependent population change in relation to habitat carrying capacity and the 

non-linear relationship between predation, carrying capacity, and deer population numbers 

should be discussed in relation to deer and wolves. Information from Person (2001) and Person 

and Bowyer (1997) regarding wolf population viability and the effects of the 1997 Forest Plan 

alternatives on the wolf population should be included in the Final EIS. New information 

presented at the Conservation Strategy Review regarding the ratio of recruitment to mortality in 

an unmanaged landscape should be included; respondents suggest using this ratio to compare 

OGRs in terms of their ability to support sources wolf populations.

Response: Additional discussion of density-dependence, predator suppression of declining deer 

populations, and other related information has been added to the Final EIS. 

Comment: Several respondents noted that some of the new information presented at the 2006 

Conservation Strategy Review workshop has not been incorporated into Wolf Standards and 

Guidelines. This includes information presented during the 2006 Conservation Strategy Review 

indicated that the den buffer standard and guideline needs revision. 

Response: The Conservation Strategy Review workshop represents one step in the Forest Plan review 

process, with the purpose of identifying considerations to be addressed in the overall review of the 

Conservation Strategy. Subsequent steps will include an assessment of each consideration identified 

during the work shop based on workshop information, peer-reviewed scientific literature, the recent 

Review of Conservation Science Produced Since 1997 and Its Relationship to the Tongass National 

Forest Land and Resources Management Plan (Haufler 2006), as well as input from various state and 

federal agencies. These assessments will culminate in a determination of how each consideration will 

dealt with. Some considerations have been addressed in time for incorporation in the Final EIS however 

others, like the Wolf Standards and Guidelines, require additional interagency consultation, the formation 

of specialized workgroups, and more detailed development, and therefore will be implemented after the 

Final EIS. These long term considerations could lead to conservation strategy-related adjustments to the 

amended Forest Plan through additional amendments or may be identified as information needs.

Comment: The 2007 Proposed Forest Plan standards and guidelines for wolves specify an 

optimal deer density of 17 deer per square mile. This is incorrect and should be 18 deer per 

square mile, consistent with the Draft EIS and the science underlying the standard and guideline, 

however should not be confused with the 13 deer per square mile specified in the 1997 Forest 

Plan. The respondents note that there has been much confusion with these numbers, clarifying 

that the latter number represents population density, based on Person (1996), whereas the other 

numbers represent a habitat capability (18 deer per square mile being the accepted, correct 

number). The respondents request that the Final Proposed Forest Plan include specific guidance 

for computing the habitat capability deer density (using the deer multiplier to convert deer winter 

habitat capability models into deer densities) and clearly differentiate between the recommended 

actual deer density and habitat capability. 

Response: The Forest Service primarily manages habitat and assesses effects to deer and wolves based 

on habitat capability rather than actual population numbers. The deer habitat capability density specified 

in the Wolf Standards and Guidelines has been corrected in the Final Proposed Forest Plan. Guidance for 

using the deer model is too detailed for inclusion in the Forest Plan, and may change as newer models are 

developed. Using the deer model is only one method of assessing effects to wolves and deer. The Final 

Proposed Forest Plan directs use of variety of methods, including the deer model, in assessing effects. 

This includes local knowledge of habitat conditions, spatial location of habitat, and other factors that need 

to be considered by the biologist rather than solely relying upon model outputs. In addition, the Plan 

allows for alternative tools to be developed as new information on assessing habitat for deer and wolves 

evolves. 
Appendix H

Final EIS H-173 Comments and Responses

Comment: The deer analysis is inadequate in that it does not quantitatively evaluate the risks 

under each of the alternatives associated with providing an adequate supply of deer for wolves 

and hunters and does show whether the alternatives meet the standard and guideline for 

maintaining a threshold habitat capability of 18 deer per square mile (as determined by the deer 

habitat capability model). 

Response: Using a habitat capability of 18 deer/square mile is not a threshold. It is only one of several 

tools that can be used at the project scale to assess if sufficient deer habitat capability exists to maintain 

sustainable wolf populations. Other tools include local knowledge of habitat conditions and spatial 

location of habitat.. Other factors need to be considered by the biologist rather than solely relying upon 

model outputs. Habitat capability is also a tool to determine effects of a project on, human deer harvest 

demands. An analysis of the ability of the alternatives to meet the Wolf standard and guideline deer 

habitat capability has been added to the Final EIS text. 

Comment: The Wolf standard and guideline for road density was based on the analyses 

described in Person et al. (1996) but has never been implemented in a manner consistent with 

Person et al. (1996). The 0.7 mile per square mile road density should account for all open, 

closed, and overgrown roads in areas below 370 meters elevation, not simply open roads. This is 

because it is hard to distinguish between open and closed roads (i.e., close roads may still be 

used by hikers and OHV users), and both may provide easier access for wolf hunting and 

trapping. Additionally, a majority of wolf activity occurs below 370 meters elevation (Person et al. 

1996, 2001). The road density guideline should be applied at a scale equal to an average wolf 

pack home range (e.g., 300 km; Person et al. 1996). The incorrect use of this guideline has been 

brought up in interagency meetings since 1997, but has never been corrected in the Forest Plan. 

A respondent suggested that consideration should be given to peak road density. 

In regards to the range or road densities, one respondent commented that an open road density 

requirement of 0.7 to 1.0 miles per square mile to reduce “human-caused mortality” of wolves is 

unnecessary because ADF&G is capable of applying and enforcing appropriate regulations to 

provide for abundant wolf populations. Conversely, another respondent felt that a less 

discretionary standard of 0.7 miles per square mile should be set. 

Response: Specification of total road density for analysis purposes has been added to the Final Proposed 

Forest Plan to promote consistent interpretation and use. The misinterpretation of the guideline was 

described in the Wildlife section and, as stated, the analysis in the Final EIS accounts for lands below 1,200 

feet in elevation, included both open and closed roads, evaluated road densities by WAA which are 

approximately equal in size to wolf pack home ranges in Southeast Alaska, and included all land 

ownerships. Because this EIS covers the entire Forest, all WAAs were included in the analysis. The wolf 

guideline of 0.7 miles per square mile road density is not a limit, but the lower end of a range of road 

densities (up to 1.0 miles per square mile) recommended if road access and associated human-caused 

mortality has been determined to be the significant contributing factor to unsustainable wolf mortality. Note 

that the 0.7 to 1.0 miles per square mile guideline does not need to be considered until that determination 

has been made and that consideration of wolf hunting and trapping harvest is also considered. In addition, 

local knowledge of habitat conditions, spatial location of roads, and other factors would also need to be 

considered by the biologist rather than solely relying upon road densities. As noted in the Wildlife section, 

the ADF&G currently enforces a harvest cap in GMU 2 to ensure that a viable wolf population is maintained, 

however there are other key components of wolf conservation, in addition to harvest regulations, including 

maintaining adequate deer habitat capability and minimally roaded core areas. 

Comment: Transportation Standards and Guidelines need to implement the Wolf Standards and 

Guidelines for road density. 

Response: Standards and guidelines in TRAN4.I.A requires the Forest Service to “perform route or site 

selection, location, geotechnical investigations, survey, and design to a technical level sufficient to meet 
Appendix H 

Comments and Responses H-174 Final EIS 

the intended use and commensurate with both ecological objectives and the investment to be incurred” 

and to “ensure consistency with Forest-wide Standards & Guidelines and Best Management Practices.” 

This includes the Wolf Standards and Guidelines. 

Comment: The discussion of habitat use by wolves needs to summarize Person (2001) otherwise 

it is outdated. 

Response: Information from Person et al. (2001) has been added the Final EIS text.

Comment: Wolf numbers are limited by prey availability, not social interactions. The discussion 

in the affected environment section should refer to and summarize the appropriate sections in 

Mech et al. (1998) and Fuller et al. (2003). The density limit of 10 wolves per square mile stated in 

the Draft EIS is incorrect. For example, Isle Royale has had densities of wolves that substantially 

exceed that limit. 

Response: Information from Mech et al. (1998) and Fuller et al. (2003) has been added to the Final EIS 

text. In regards to wolf density, the Draft EIS actually states that “Due to social interactions, wolf densities 

do not exceed certain levels even when prey abundance is high. A density of one adult wolf per 10 

square miles is considered high, and this density is often considered as a saturation point beyond which 

wolf populations would not expand. Wolves have large home ranges (about 100 square miles per pack), 

use a wide variety of habitats, and are very mobile.” This information came from the Alexander 

Archipelago wolf conservation assessment (Person et al. 1996) which presented wolf densities for 9 study 

areas in Minnesota, Ontario, Quebec, Vancouver Island, and Prince of Wales/Kosciusko islands. Wolf 

densities reported from these study areas ranged from 1 to 1.7 wolves per 10 square miles (8 study areas 

had densities of 1 wolf per 10 square miles or less). 

Comment: Units 2 and 3 support modest wolf densities compared to other areas where wolves 

prey on deer rather than moose, caribou, bison, or other large prey. While wolf densities are high 

in Units 2 and 3 compared to other parts of Alaska (where deer are absent), they are not high 

when compared to other areas where deer are the principle prey (i.e., northern Minnesota, 

southeastern Ontario, and British Columbia). More information on this is available in Person et al. 

(1996, 2001). The wolf population in Unit 2 is currently healthy but that does not imply it will be in 

the future when more of the landscape is in stem-exclusion forest. Current populations are not 

indicators of the future. Reference should be made to the concept of “succession debt” 

described by Person (2001). 

Response: Information from Person et al. (2001) has been added to the Final EIS text.

Comment: Prince of Wales Island wolves seem to be a distinct population segment. However, the 

Draft EIS fails to disclose what those profound implications are or take them into account in the 

impact analysis. Weckworth et al. (2005) should be reviewed and cited in the Final EIS. 

Response: Information from Weckworth et al (2005) regarding the distinct wolf population on Prince of 

Wales Island has been added to the Final EIS. 

Comment: Factors affecting the Alexander Archipelago wolf are primarily density of black-tailed 

deer and road access for wolf hunters/trappers. A strong inverse relationship between wolf home 

range size and critical deer winter range was found. Wolves are highly mobile and move between 

islands in Southeast Alaska, some being separated by up to 2.5 miles. Between 1993 and 2000, 85 

percent of radio-collared wolf mortality was due to trapping, with equal amounts of legal and 
Appendix H

Final EIS H-175 Comments and Responses

illegal harvest. The presence of roads has a significant effect on wolf harvest. Historically, the 

ADF&G allowed year-round no-limit wolf harvest. 

Response: Deer populations and road access were identified in the Draft EIS as important components 

in wolf conservation. The Draft EIS also discussed harvest regulations in GMUs 2 and 3. The Forest 

Service, by itself, does not have the authority to regulate wolf harvest. 

Comment: The Draft EIS and Proposed Forest Plan fail to adequately protect this wolves from 

human disturbance. In fact the proposed plan would weaken the protections already in place. 

The plan does not trigger action until road density is determined to be the significant contributing 

factor to unsustained wolf mortality. This is a very discretionary standard. The trigger should be 

when road density is determined to contribute to unsustained wolf mortality. The plan also lacks 

teeth in its remedial action to protect wolves when the road densities are exceeded; it should 

trigger road closures and road building prohibitions. 

Response: If and when open roads contribute to unsustainable mortality, actions to reduce that factor 

can and will be considered. This would be guided by the appropriate Forest Plan standards and 

guidelines including the wolf mortality guideline. The extent of actions taken will be in consultation with 

other agencies and the affected publics as well. 

Deer 

Comment: Assumptions of the Tongass deer habitat capability model need to be evaluated and 

updated and model results should be ground-truthed.

Response: The 1997 deer model habitat capability model represents the most current tool available for 

evaluating deer winter range conditions on the Tongass. The habitat types included in the model are 

broad and general, and they are not based on any particular site-specific data which would enable 

ground-truthing. Given the large differences in deer habitat value between many of these broad classes 

of habitat, the model provides a useful and reasonable estimate of deer habitat value for large-scale 

analyses. Despite limitations to the existing model, which are discussed in the Wildlife section of the EIS, 

the model provides a relative estimate of deer habitat value which is appropriate for comparing 

management alternatives. Modifications to the model, such as refining coefficients due to changes in 

vegetation mapping on the Tongass, are forthcoming but will occur outside of the timeframe for the Forest 

Plan Amendment. Scientific research published after the 1997 has increased knowledge about deerhabitat relations in Southeast Alaska, but does not contain anything that would change the 1997 expertbased model significantly. However, a nutritional-based model has recently been developed that could 

provide the basis for completely re-evaluating our analysis of deer habitat. However, since, it is an 

entirely data-driven system, and its data requirements cannot be met with existing Forest data it will take 

additional time to fully implement this new analysis. See Appendix B of the Final EIS for additional 

information on the deer model. 

Comment: Clearcuts have been assigned high value by the deer model but during severe winters 

these habitats provide little value to deer.

Response: This comment is incorrect in that the 1997 deer model, which is currently the only model 

available for conducting large-scale analyses of deer habitat on the Tongass, assigns the highest values 

to forests with closed canopy (based on volume class rather than canopy cover), maritime influence, 

south facing slopes, and low average snow depth. Recent clearcuts are assigned moderate values. See 

Appendix B of the Final EIS for additional information on the deer model. 
Appendix H 

Comments and Responses H-176 Final EIS 

Comment: Some respondents expressed concern that the cumulative loss of deer habitat will 

result in catastrophic population crashes, reflecting lost winter habitat, that may have cascading 

effects to wolves and bears, and that deer will be extirpated from some islands or will fall into 

predator pits. Related comments suggested that restoration of deer winter range is needed. 

Response: The deer model presents a worst-case scenario by assuming that all suitable acres are 

harvested under each alternative. However, the current level of road construction and timber harvest on 

the Tongass is at a 5-decade low and the life of this Amendment is expected to be 10 to 15 years at most, 

at which time a Plan Revision will likely be undertaken. In addition, there will be a period of preparation 

prior to the implementation of any sale during which no harvest will occur, even if the timber industry 

responds rapidly. The management of second-growth stands on the Tongass has helped offset the 

cumulative loss of winter range by accelerating the stem exclusion phase of forest development, which 

occurs roughly 15 to 25 years following a major disturbance when the growing space is fully occupied, 

tree crowns are crowded, and forage is limited. The creation of new foraging habitat is not reflected by 

the current deer habitat capability model. 

The analysis of effects to deer winter range provided in the Wildlife section takes into account past timber 

harvest and therefore serves as an assessment of cumulative effects. This assessment is conservative in 

that it assumes that non-NFS lands provide no habitat capability. Currently there is no defined threshold 

for loss of winter range with which to predict the likelihood of a population crash. We can only speculate 

that losses could be amplified during severe winters; however, one expected result of the current warming 

trend is warmer winters. Management of young-growth was discussed in the Wildlife section of the Draft 

EIS as a potential way to improve the quality of deer winter range. 

Comment: The second paragraph under Deer in the description of the affected environment for 

wildlife in the Draft EIS, fourth sentence should read: “the quantity, quality, distribution, and 

arrangement of winter habitat are considered the most important limiting factors for deer.”

Response: This sentence has been corrected in the Final EIS text. 

Comment: Several respondents questioned the use of the 1997 deer habitat capability model in 

relation to the application of the deer multiplier (i.e., high HSI scores, whether 1.3 or rescaled to 

1.0, should correspond to a deer habitat capability density of 100 deer per square mile).

Response: A re-occurring appeal point against the interagency deer model is the proper use of the deer 

density multiplier. The Final EIS uses the currently approved version of the model. In the Draft EIS the 

deer model was employed only to compare alternatives based on HSI scores rather than population 

numbers in the deer and wolf effects analyses. However, to compare the alternatives in terms of their 

ability to meet the Wolf standard and guideline for deer habitat capability (expressed in terms of the 

number of deer per square mile), an analysis using the deer multiplier has been added to the Final EIS. 

Comment: One comment stated that the deer habitat capability model is not a valid risk 

assessment tool because it does not provide probabilities of risk with which to compare 

alternatives. 

Response: The term “risk assessment” has been removed from this sentence in the Final EIS. 

Comment: The Draft EIS only mentions the FRESH-Deer model as an alternative to the deer 

habitat capability model, however this model can not be expanded from a stand-level to a 

landscape-level analysis. 
Appendix H

Final EIS H-177 Comments and Responses

Response: This statement is not correct. The FRESH-Deer model consists of two levels of application: a 

web-based, stand-level module; and a GIS-based, landscape-level module. For more information on 

model specifics please see the FRESH-Deer model home page located at 

http://cervid.uaa.alaska.edu/Home.aspx. 

Comment: Respondents clarified that black bears were primary predators of newborn black-tailed 

deer fawns on Prince of Wales Island, rather than Heceta Island. 

Response: This statement has been corrected in the Final EIS. 

Comment: The analysis of effects to deer is insufficient in that the use of POG as an indicator is 

an overly broad classification, there is no means provided to assess the implications of 

percentage changes in habitat because there is no established threshold beyond which 

reductions in habitat capability are deemed unacceptable, and relative rather than direct 

comparisons among alternatives is made. This type of comparison does not facilitate meaningful 

analysis of impacts to wolves or subsistence due to changes in deer population numbers. The 

Draft EIS should include a comparison among the alternatives based on their ability to provide the 

required 18 deer/square mile density standard and guideline.

Response: The deer analysis does not use POG as a means for comparing alternatives with respect to 

deer, rather the tables in the discussion of effects to deer present percentage changes in deer habitat 

capability, as quantified by the deer model. As described in the affected environment section under deer, 

the deer habitat capability model takes into account the value of individual SD7 model POG categories to 

deer. The tables provided in the deer section displays the existing percentage of remaining deer habitat 

capability relative to 1954 levels, indicative of baseline pre-large-scale timber harvest conditions, and 

percentages projected under each alternative. This enables a relative comparison among the alternatives 

in terms of how each alternative will directly affect baseline deer habitat capability. Additional information 

on the deer model, including how these numbers are derived, is provided in Appendix B of the Final EIS. 

As noted by the respondents, currently there is no threshold reduction in habitat capability that has been 

identified by science and therefore the effects of reductions in deer habitat capability are appropriately 

discussed in general terms. An analysis of changes to deer habitat capability expressed in terms of a 

deer density has been added to the analysis of effects to wolves. 

Comment: The Draft EIS evaluates reductions in deer habitat capability on Tongass National 

Forest lands only and disregards substantial past and future anticipated losses on other land 

ownerships in the region. 

Response: The Draft EIS states that for the deer habitat capability analysis lands under non-federal 

ownership have an assumed habitat capability of zero because these lands have been, or will be, 

developed for intensive timber production and are expected to have lower habitat capability over time. 

Comment: The definition and analysis of “high value deer winter range” are inaccurate because 

by defining quartiles by equal land area what is considered high value may differ by WAA. 

Response: There is natural variation among WAAs in what is considered high-value winter range. For 

example, maritime and interior WAAs naturally show differences in habitat capability due to differences in 

winter severity (i.e., snow levels during average winters are typically different). Consequently, high quality 

habitat within the home range from a deer’s perspective may differ depending on the location of that 

home range within a particular WAA. Thus, defining high value winter range as the quartile of acreage 

within a WAA with the highest HSI scores allows a more accurate, and conservative, portrayal of lost 

habitat capability, given that there are WAAs where there is no habitat that falls within the upper quartile 

of possible HSI scores (i.e., scores above 75 on a scale of 0 to 100) yet they are inhabited by deer. 
Appendix H 

Comments and Responses H-178 Final EIS 

Comment: Critical deer winter habitat, especially in areas relied on for hunting, should be 

protected and not slated for logging under the amended Forest Plan. 

Response: Effects to deer winter range are discussed in the Wildlife section of the Final EIS. The 2006-

2007 Interagency Forest-wide Small Old-growth Reserve review considered deer winter range as a factor 

when evaluating the placement and configuration of small OGRs. Though this effort eliminates the need 

to conduct project level reviews for the most part, additional reviews that take place on the project level 

will follow a standardized protocol, developed as part of this forest-wide effort. This includes using the 

Tongass deer winter habitat capability model to identify high value deer winter range that warrants 

protection. 

Comment: Winter range should be more clearly defined as it applies to the deer habitat capability 

model to incorporate severe, rather than average, winters. The Draft EIS fails to evaluate the 

effects of severe winters on deer, particularly in areas where there are no wolves. 

Response: The Forest Service feels that the Draft EIS adequately addresses the subject of severe 

winters by noting that effects of reductions in carrying capacity for deer would be greatest during severe 

winters when resources are most limited. Severe winters are stochastic events that are highly variable. 

Heavy snowfall may occur with increased or decreased frequency or magnitude as a result of global 

climate change, there are many uncertainties and differences of opinion related to these predictions. 

Information on these uncertainties has been added to the Final EIS. As the Climate and Air section of the 

Draft EIS states, models available for estimating climate change are designed to predict changes on a 

regional level and are not detailed enough to predict changes to the Tongass. Consequently, they do not 

agree on how global warming will affect Southeast Alaska. Thus, it is impossible to accurately predict the 

frequency or magnitude of severe winters, much less the effects of severe winters on deer under each of 

the management alternatives. 

Comment: It should be noted that the forage production in recent clearcuts is of lower nutritional 

quality than the same forage types found in old-growth. 

Response: This statement has been added to the Final EIS text. 

Comment: Deer and bear are abundant on Native Corporation lands where silvicultural 

management of harvest units provides forage and cover for these species, compensating for lost 

habitat capability. 

Response: We agree that young-growth management can potentially benefit wildlife; however, there are 

many uncertainties related to appropriate young-growth treatment designs, specific beneficial effects of 

such treatments, and implications for deer and other wildlife species. In addition, some studies have 

shown the opposite results. Additional discussion of uncertainties related to young-growth management 

has been added to the Wildlife section of the Final EIS text. 

Comment: The likelihood of long-lasting declines in deer population under all alternatives 

appears to be low; the potential for stand treatments to improve forage conditions in young 

stands is high. 

Response: We concur that the effects of the alternatives are unlikely to result in long-term population 

declines. A discussion of young-growth management was included in the Timber and Wildlife sections. 

Comment: Several comments were received regarding timber harvest and road construction in 

specific areas. On respondent stated that targeting important deer areas like Tenakee Inlet will 
Appendix H

Final EIS H-179 Comments and Responses

have long-lasting impacts on deer populations and subsistence. Another respondent stated that 

timber harvest and road building in the Bostwick Inlet/Gravina Island area could jeopardize 

subsistence and hunting resources. Another respondent expressed concern over effects to 

eagles in the 11 Mile area. 

Response: Any timber harvest planned for the Tenakee Inlet (or any other part of the Tongass) will 

require a site-specific environmental analysis which will consider effects on deer and subsistence 

resources. 

Comment: Forest Service planning assumes a static average deer density needed to support 

hunter demand and proposes restricting federally ineligible hunters when habitat impacts from 

the Forest Plan result in a density below levels needed for local subsistence. This is a false tradeoff because hunting and habitat loss due to clearcut logging affect deer populations in different 

ways; hunting tends to stabilize deer populations in areas with few predators whereas logging 

winter range is a destabilizing force. Restricting non-local hunting effort will not maintain deer for 

subsistence but will amplify deer population cycles ultimately reducing the number of deer 

available to subsistence hunters during population lows. 

Response: The Forest Service does not assume static deer densities, but recognizes cycles. Hunting 

may need to be regulated in some areas if deer numbers decline and that could include restrictions to 

non-federally qualified hunters.

Comment: Some young-growth stands, particularly those located on hillsides where sunlight can 

reach the forest floor, and noncommercial forests provide forage for deer. Thus, the deer model 

is conservative. 

Response: It is true that habitats other than productive old-growth provide habitat for deer. The 

conservative nature of the deer model analysis was noted in the Wildlife section of the Draft EIS. 

Comment: The statement in the Draft EIS that the deer populations in GMU 2 are at moderate 

levels and expected to decline is incorrect because an article in the Ketchikan Daily News (2006) 

states that Prince of Wales deer populations are sky-rocketing. 

Response: The statement in the Draft EIS refers to long-term population trends and is correct. The 

2005 ADF&G harvest summary for deer in GMU 2 (Porter 2005) states “as clearcut logging continues to 

reduce old-growth habitat in GMU 2, deer populations are expected to decline.” This report also states 

that based on deer pellet-group counts, Unit 2 pellet-group densities represent low to moderate 

population levels relative to high pellet-group densities documented in Unit 4; they attributed this disparity 

to the presence of wolves in Unit 2 and their absence from Unit 4. 

Comment: Every acre of high-quality old-growth cut greatly reduces the chance of survival of 

deer in hard winters. In areas that are clearcut deer are dying by the thousands and if the 

proposed alternative is implemented, that situation will only be made worse when we get another 

severe winter. 

Response: The fact that effects to deer due to the loss of critical winter habitat would be of greatest 

concern during severe winters was noted in the Draft EIS. Individual timber sales will undergo 

appropriate environmental analysis and will address deer winter range at the project level. 

Comment: The Proposed Forest Plan fails to adequately protect black-tailed deer; there is no 

definition of “critical winter range” and there is no means to ensure that an adequate number of 
Appendix H 

Comments and Responses H-180 Final EIS 

deer are maintained for wolves and subsistence use; standards and guidelines focus on 

assessing impacts to winter range as part of project-level analysis but do not require that an 

adequate amount of quality habitat be maintained. No mention of the Forest Service deer habitat 

capability model is made. 

Response: The conservation strategy was designed to adequately maintain populations of wildlife, 

including deer. However, the Final EIS acknowledges that there may be impacts to deer in specific 

geographic areas due to timber harvest. The Proposed Forest Plan sets broad direction for project-level 

actions due to the variability in site-specific conditions. No definition is given for “critical” deer winter 

range because its identification will occur during project-level analysis and will involve local knowledge of 

habitat conditions, spatial locations of habitat, and other factors, in addition to outputs of the deer winter 

habitat capability model. Wolf standard and guideline XII.A.2 2 of the Final Proposed Forest Plan directs 

the Forest to provide for sufficient deer habitat capability to first maintain sustainable wolf populations and 

then to consider meeting estimated human deer harvest demands. It also requires use of the most recent 

deer habitat capability model along with field verification to estimate deer habitat capability in 

biogeographic provinces where there are wolves. 

Comment: One comment noted that Southeast Alaska communities could face significant 

restriction to their deer hunting as a result of past and anticipated clearcutting and road building. 

The comment stated that the Forest should not log areas that provide corridors for deer and areas 

that are critically over-logged should be restored. They also note that thinning projects could 

provide valuable employment to residents in rural communities. 

Response: Effects to subsistence and deer harvest in rural communities are discussed in the 

Subregional Overview and Communities section. Forest Plan Wildlife Habitat Planning (WILD1) standard 

and guideline VI directs the Forest to maintain landscape connectivity and standard and guideline VI.C 

requires the Forest to consider black-tailed deer habitat needs before or as part of project analysis. 

Forest Plan Wildlife Habitat Improvement Standards and Guidelines (WILD2) describe wildlife habitat 

improvement projects. 

Comment: One comment noted that when Ketchikan Pulp was logging in the Thorne Bay area it 

was common to see deer with twins or triplets, probably due to good forage quality, but today, 

singles are more common. This, they conclude, suggests that timber harvest and deer exist well 

together. Another comment stated that more deer and more diverse wildlife habitat occurs forest 

edges and therefore timber harvest creates more wildlife habitat. 

Response: There are numerous factors that can affect deer reproductive success, forage quantity and 

quality being one of them. Although timber harvest temporarily increases forage production in recently 

cut areas by increasing the amount of sunlight that reaches the forest floor, timber harvest also reduces 

other habitat elements that are important to deer, such as hiding cover and overstory cover for 

intercepting snow, and increases habitat fragmentation. 

It is true that deer prefer to live on the forest edge adjacent to open habitat types where many resources 

(e.g., forage and cover) are available in proximity to each other. Though timber harvest does create more 

edge habitat, it also increases habitat fragmentation, resulting in remaining forested patches becoming 

smaller, more isolated, and less functional and therefore should always be considered in a landscape 

context. In addition, it is well known that old-growth forest provides important deer winter habitat. 

Comment: The deer model is biased toward old-growth and over states the impact of timber 

harvest on deer habitat capability. 

Response: The conservative nature of the deer model analysis is noted in the description of the affected 

environment under Deer in the Wildlife section of the Final EIS. 
Appendix H

Final EIS H-181 Comments and Responses

Comment: Important deer winter range should be displayed by development and nondevelopment LUDs for each VCU to determine how much is fully protected under the reserve 

system and how much is partially protected in the matrix. 

Response: Important deer winter range is identified by ground-truthing deer habitat capability model 

results and incorporating deer use levels, when available. This is required as part of the project planning 

process under the Forest Plan. 

Comment: The standards and guidelines for deer, wolves, and subsistence are interrelated and 

all fail to define objectives in one or more of their sections; there is a lack of logic in how deer 

issues are distributed among the three broad standard and guideline topics. Some respondents 

felt that there needed to be a stated purpose or objective for protecting deer populations. Others 

commented that the focus was on assessing habitat rather than assuring an adequate amount or 

quality of habitat. 

Response: It is true that deer, wolf, and subsistence issues are related, as discussed in the Wildlife

section of the EIS. Standards and guidelines are included for species that were felt to be at risk or 

needed extra consideration at the project level. The extra consideration at the project level for deer that 

is provided under the Deer Habitat Standards and Guidelines is believed to be adequate. 

Comment: Mitkof Island has some of the most restrictive deer seasons in all of Southeast Alaska 

due to the inability of the deer population to recover from several consecutive severe winters 

coupled with the effects of timber harvest, road construction, and habitat fragmentation. 

Response: It is true that there are many factors at play in the status of Southeast Alaska deer 

populations and that the ADF&G takes these factors into account when setting harvest levels. 

Comment: During severe winters, deer prefer southerly aspects below 500 feet elevation within 

1,000 feet of the shoreline, medium- and high-volume stands, and forest edges; they avoid 

unforested and noncommercial habitats, predominantly north-facing gap phase old-growth and 

sheltered areas above 1,500 feet elevation. During summer and low-snow winters deer are habitat 

generalists and occupy a variety of habitats. 

Response: Deer habitat relationships are described in the description of the affected environment of the 

Wildlife section of the Final EIS. 

Comment: Past clearcutting, which has targeted high value deer winter habitat, has increased the 

likelihood of deer collapses during severe winters, and decreased the recovery potential when 

recoveries do happen. The occurrence of severe winters will remain a fact of life in Southeast 

Alaska in spite of climate change and this is beyond the control of the Forest Service. What is not 

beyond the control of the Forest Service is to limit the cutting of additional high quality deer 

habitat, and to not allow clearcutting where correct application of the deer model indicates that 

there is not sufficient habitat capacity to sustain sufficient deer numbers to provide for wolf needs 

and human consumption. 

Response: As part of timber sale planning, Forest Plan standards and guidelines are applied to assure 

that sufficient deer habitat capability is maintained to provide for wolves and human consumption. 
Appendix H 

Comments and Responses H-182 Final EIS 

Elk 

Comment: Although a radio-collared elk was located on Farm Island, at the mouth of the Stikine 

River, there is no evidence the elk have migrated up the river drainage.

Response: This statement has been corrected in the Final EIS text. 

Brown Bear and Black Bear 

Comment: Brown bears do not occur on all islands north of Frederick Sound.

Response: The description of the distribution of brown bears in the Final EIS has been modified to reflect 

this. 

Comment: Some respondents requested clarification that hunting of brown bears is allowed 

throughout other parts of Southeast Alaska, outside of GMU 4, and a statement about outfitter 

uses of brown bears and available viewing areas.

Response: The statement about brown bear harvest has been clarified in the Final EIS. Outfitter and 

viewing uses have been noted in the text. 

Comment: There is a lack of references provided for statements about the late-summer season 

being the most critical time for brown bears.

Response: Additional references for this information have been added to the Final EIS. 

Comment: Black bears den in both harvested and unharvested forest stands. Because some 

dens on the Tongass have been documented in clearcuts it seems likely that black-bears prefer 

denning in clearcuts. 

Response: It is true that black bears are habitat generalists and will use both early- (clearcuts and young 

growth) and late-seral (old-growth) forests. This was noted in the Draft EIS, though the focus of the 

analysis was road construction given that this species is sensitive to overhunting which can result from 

increased road access. 

Comment: One respondent commented that he would like to see commercial black-bear hunting 

on Prince of Wales Island abolished.

Response: Sport hunting regulations are under the jurisdiction of ADF&G, and therefore not an issue 

that can be addressed by the Forest Plan Amendment process. 

Comment: Several respondents cited information presented in Flynn (2007) regarding brown bear 

use of riparian areas along streams in two drainages, one intact and one heavily logged, 

requesting that it be incorporated into the Wildlife section of the Final EIS. They also requested 

that the recommendations provided by the authors for maintaining 500-foot no-cut buffers along 

all salmon streams in landscapes used by brown bears, and 1000-foot buffers along all streams 

(or complete watershed protection) in areas where bear management objectives are to maintain 

abundant healthy brown bear populations, be incorporated into the Final Proposed Forest Plan. 

Respondents noted that there are substantial risks to maintaining viable and well-distributed 

brown bear and black bear populations in some biogeographic provinces, particularly those 

where there is a low proportion of watershed-scale habitat protection, and that these areas may 
Appendix H

Final EIS H-183 Comments and Responses

warrant additional protective measures that maintain adequate habitat, minimize road densities, 

and maintain roadless areas.

Response: Information from Flynn (2007), which was also discussed at the 2006 Tongass Conservation 

Strategy Review workshop, was included in the Draft EIS. The recommendation for applying no-cut 

buffers to all salmon streams was initially made during the 2006 workshop, along with a number of other 

suggested items to be considered by the Forest Service. Some items were addressed in time for 

incorporation in the Final EIS, whereas others, such as the no-cut buffers, which might require additional 

interagency consultation, the formation of specialized workgroups, and more detailed development, may 

be considered after the Final EIS. These long term considerations could lead to conservation strategyrelated adjustments to the amended Forest Plan through additional amendments or identified as 

information needs. The Final Proposed Forest Plan includes 500-foot buffers on important brown bear 

feeding streams. A discussion regarding brown bears can be found in Appendix D of the Final EIS. 

Comment: The ADF&G allows a relatively substantial annual harvest of brown bears on 

northeast Chichagof Island, where one of the highest densities of this species occurs in 

Southeast Alaska; the area also experienced a high level of road building and timber harvest in 

the 1970s and 1980s. This brings the need for Brown Bear Standards and Guidelines into 

question.

Response: Species-specific standards and guidelines form the fine filter component of the Tongass 

conservation strategy. They are designed to ensure that the Forest’s multiple use objectives are met, as 

directed by the National Forest Management Act, which include enabling continued subsistence and 

recreational uses (consumptive and non-consumptive) of wildlife resources. Therefore, the brown bear 

standards and guidelines, which work to minimize the effects of timber harvest on brown bears and 

reduce human-brown bear conflicts, contribute to the maintenance of sustainable brown bear populations 

and continue to let the ADF&G allow brown bear harvest on northeast Chichagof Island. A discussion 

regarding brown bears can be found in Appendix D of the Final EIS. 

Comment: Several respondents commented on brown bear use of second-growth forest, some 

suggesting that brown bears do well in young-growth areas, and others stating that old-growth 

forests provide the only suitable habitat for brown bears. Respondents with the latter view 

suggested that the Forest maintain roadless areas to prevent clear-cut logging and attributed 

more restrictive regulations on outfitters and hunters to the loss of old-growth forest.

Response: Brown bears are habitat generalists in that they use a variety of habitats including younggrowth. However, mature and old-growth forest, particularly in the form of riparian habitat along salmon 

streams, plays an essential role in brown bear population viability, both in terms of the maintaining 

adequate vegetative cover to support anadromous fish production (i.e., regulate stream temperature) and 

providing visual obscurity of bears from humans and other bears. The reserve system, including OGRs 

and other non-development LUDs, protects approximately 57 to 93 percent of the productive old-growth 

existing in 1954 on the Tongass, much of which is roadless, depending on the alternative. 

Comment: The Draft EIS fails to adequately analyze direct, indirect, and cumulative impacts to 

brown bears and black bears, especially increased hunter access to bears (direct take, reduction 

in prey base, and human presence). 

Response: The potential for increased human access under each of the alternatives was discussed in 

detail in the Draft EIS analysis of effects to both black and brown bears (pages 3-203; 3-205 to 3-207). 

The discussions focused on direct take, or other mortality associated with human-bear interactions, and 

the effects of human disturbance. The ability of each alternative to maintain important roadless refugia 

was highlighted for brown bears. Reductions in the prey base for each species was not discussed as 
Appendix H 

Comments and Responses H-184 Final EIS 

neither species is a predator that specializes in one type of prey whose population has the potential to be 

affected by increased human access. 

Comment: One respondent stated that she was quite appalled to discover that the Forest 

Service’s Proposed Action would “essentially render the Tongass uninhabitable by grizzly bears.” 

Response: The analysis does not indicate that any of the alternatives would render the Tongass 

uninhabitable by grizzly bears, known as brown bears in Southeast Alaska. Even Alternatives 4 and 7 

which propose the highest levels of harvest and reduce or eliminate the reserve system, respectively, 

rank as having moderately high likelihoods of maintaining well-distributed, viable brown bear populations. 

Alternatives 1, 2, 3, 5, and 6 rank as having a high likelihood of maintaining well-distributed, viable brown 

bear populations. 

Comment: Standards and guidelines IX.A, C, D in the Proposed Forest Plan regarding 

management of human-bear encounters should be effectively incorporated into road management 

and timber harvest planning at the project level. 

Response: Forest Plan standards and guidelines are incorporated into road management and timber 

harvest plans. 

Comment: Standard and Guideline IX.D, of the Proposed Forest Plan regarding roads, should be 

strengthened by closing more roads because roads are correlated with bear mortality. 

Response: Site-specific needs to minimize human/bear conflicts will be taken into account at project 

level planning including assess and travel management planning with regard to road management. 

Comment: There is no science to suggest that brown bears require a 500-foot buffer for foraging. 

For areas where human bear encounters are predicted (i.e., Anan Creek, Pack Creek, Salmon 

River) this may be appropriate but otherwise is not needed, considering that the highest 

concentration of brown bears in Southeast Alaska occurs in an area with substantial past timber 

harvest and road building and harvest of brown bears is permitted on the Admiralty, Baranof, and 

Chichagof islands. 

Response: As stated in the Wildlife section of the Draft EIS, cover for visual obscurity, provided by 

riparian buffers, is important for minimizing interactions among bears and between humans and bears. 

During the salmon spawning season bears concentrate their use within 500 feet of salmon spawning 

streams (Schoen and Beier 1990, Titus and Beier 1999), though will make greater use of upland areas in 

watersheds with greater development. The 500-foot buffers required by the Final Proposed Forest Plan 

are intended to provide visual cover in the areas that receive the greatest use. 

Comment: One comment requested that the Forest Service adopt the Flynn et al. (2007) 

recommendations for bear buffers of 500 feet along each side of all salmon streams that are used 

by brown bears, and a buffer of 1,000 feet along each side in areas where ADF&G management 

objectives are for a brown bear population that exceeds the level of minimum viability. 

Response: Standard and Guideline WILD1 IX.B, (Bear Habitat Management) in the Wildlife section of 

Chapter 4 of the Final Proposed Forest Plan requires consultation with ADF&G to determine the best 

application of needed buffers. Some sites might warrant these types of buffers, but this is best 

determined at the project level. 
Appendix H

Final EIS H-185 Comments and Responses

Plants 

Comment: The Forest Service and the Tribes must work together to address the issues of 

noxious or invasive animal and plant species. 

Response: The Forest Service works with the Tribes, as well as with other agencies and organizations, 

on issues related to noxious and invasive species. 

Comment: One comment noted that the Proposed Forest Plan does little to prevent the spread of 

invasive plants. 

Response: The Final Proposed Forest Plan has been modified to include a section on invasive plants. 

The standards and guidelines reference the direction in the recently completed (November 2007) Region 

10 supplement to Forest Service Handbook 2000, Noxious Weed Management, Chapter 2080. 

Standards and guidelines in the Final Proposed Forest Plan implement direction in this Regional 

Supplement. 

Comment: One comment asked how many of the 46 species classified as invasive plants present 

on the Tongass are the result of logging operations. 

Response: It is likely that many of these plants were spread by logging operations, especially prior to the 

Forest implementing measures to halt their spread. However, invasive plants are also spread by 

recreational traffic and by natural means. The Forest Service has recently completed a regional 

supplement to Forest Service Handbook 2000 Noxious Weed Management, Chapter 2080. Standards 

and guidelines in the Final Proposed Forest Plan implement the direction from this Regional Supplement. 

Comment: One comment requested that the Final Proposed Forest Plan protect orchids and 

goldenthreads. 

Response: Bog orchid is listed on the Regional Forester's sensitive plant list. The Final Proposed 

Forest Plan contains standards and guidelines to protect sensitive species, as identified in the effects 

analysis in the Final EIS. There are two species of goldenthread on the forest. One is found in bogs and 

is not likely to be disturbed by harvest operations. The other is found in moist forests where some 

populations may be disturbed by logging. Neither species is listed as sensitive, threatened or 

endangered because neither is uncommon. 

Specific Geographic Area Comments 

The following section presents comment summaries and responses that address specific geographic 

areas. These comment summaries are organized into two sections. The first section presents comments 

that requested information or suggested management direction for specific places. The second section 

lists and discusses specific places that were more generally identified for protection from timber harvest 

and road construction. 

Specific Geographic Area Comments and Responses 

Comment: Several comments expressed concern about the recommendation that the existing 

Young Bay Experimental Forest be declassified as an Experimental Forest and assigned to the 

Remote Recreation LUD under management of the Juneau Ranger District. These comments 

argued that the Young Bay should become part of the adjoining Kootznoowoo Wilderness and 

Admiralty National Monument. Respondents stated that this would be inconsistent with President 

Carter’s Proclamation 4611 and ignores ANILCA. One comment encouraged the Forest Service to 
Appendix H 

Comments and Responses H-186 Final EIS 

consult with the Kootznoowoo to determine the potential impacts of this designation on the 

unique coastal island ecosystem. Another comment emphasized the value of Young Bay to the 

public and as a “crucial wildlife linkage” between Mansfield Peninsula and the rest of Admiralty 

Island. This comment recommended that the mineral entry withdrawal for this area remain in 

effect. 

Response: The recommended declassification of the Young Bay Experimental Forest will be addressed 

in a separate decision outside of this Forest Plan Amendment effort. The above concerns are noted and 

will be considered in that decision process. However, it is important to note that adding this area to the 

Kootznoowoo Wilderness would require Congressional action. 

Comment: One comment requested that Corner Bay on Chichagof Island be classified as a new 

Experimental Forest, not the Cowee Creek-Davies Creek area, which is recommended for this 

designation in the Proposed Forest Plan. The comment author would prefer the Forest Plan 

recommend Corner Bay because it has an established road system and has been logged in the 

past. 

Response: The Corner Bay area was examined as a potential Experimental Forest location, but the 

PNW Research Station recommended that the Cowee-Davis area be classified as an Experimental 

Forest. Their preference is reflected in the recommendation in the Final Proposed Forest Plan. A final 

decision on changes to the Experimental Forest will be made outside of this Forest Plan Amendment 

effort.

Comment: Some respondents want the name of Admiralty Island National Monument Wilderness 

changed to the Kootznoowoo Wilderness with appropriate legal boundaries identified in the Final 

Proposed Forest Plan and supporting maps. Others asked that the name Kootznoowoo be spelled 

with an “X” as they felt that was more traditional. Another comment pointed out that Angoon 

elders maintain that “Young Bay” should in fact be “Young’s Bay” and requested that the Forest 

Service make the applicable changes as soon as possible 

Response: The alternative maps in the Draft and Final EIS documents clearly show both Admiralty 

Island National Monument and Kootznoowoo Wilderness. Text in the Final EIS refers to Kootznoowoo 

Wilderness. The boundaries of the wilderness were legislated by Congress, as was the name and 

spelling. Changing the name of the area is beyond the scope of this Forest Plan Amendment. This is 

also the case with the suggested change from Young Bay to Young’s Bay. 

Comment: A number of respondents from the community of Angoon expressed concern about a 

proposal by the Borough of Juneau to extend the Borough boundaries to include Admiralty 

Island. They asked that the Forest Service stop this effort. 

Response: Annexation proposals by the Borough of Juneau are outside the scope of this Forest Plan 

Amendment. 

Comment: One comment requested that the Final Proposed Forest Plan clearly identify the 

following areas of subsistence-related concern in the text and also depict them graphically: 

Chatham Strait Sockeye returns, voluntary closures, and migratory maps; Mitchell Bay Coho 

returns and existing commercial fishing areas; Southeast Herring Stocks, returns and commercial 

fishing harvest areas; and all areas within the Kootznoowoo Wilderness currently open to 

commercial fishing. 

Response: The Forest Plan guides natural resource management activities on the Tongass. 

Subsistence fisheries management issues and mapping are outside the scope of the Forest Plan. 
Appendix H

Final EIS H-187 Comments and Responses

Comment: Some respondents stated that the navigable waters in the Angoon area such as 

Kootznoowoo Inlet, Favorite Bay, Mitchell Bay and Kanalku belong to the Kootznoowoo.

Response: This issue is beyond the scope of decisions made in this Forest Plan Amendment. 

Comment: Some respondents felt that Admiralty Island should either be removed from the 

Tongass or at least put into a different category that would foster more attention to this island and 

the people that live there. They also suggest that an integrated management plan needs to be 

developed with Kootznoowoo. Several respondents felt that the Admiralty Island District office 

should be in Angoon rather than in Juneau.

Response: The Final Proposed Forest Plan provides broad strategic direction for the Forest as a whole, 

but it also recognizes the differences between areas and allocates areas to different LUDs for 

management purposes. Most of Admiralty Island is a National Monument and a Congressionally 

designated Wilderness, and this is reflected in the LUD designations and the management direction 

associated with them. 

Location of Forest Service offices is an administrative decision and beyond the scope of this Forest Plan 

Amendment. 

Comment: One comment asked for a detailed analysis of Goldbelt Corporation’s proposed 

tourism activities in Hobart Bay. 

Response: This Final EIS is a programmatic forest-wide analysis appropriate for a strategic Forest Plan 

Amendment. Site-specific projects or activities are best examined locally during the decision making 

process as appropriate for that action. Tourism and recreation developments are considered in 

cumulative effects analysis. 

Comment: One comment recommended the LUD boundaries of the Greater Situk Watershed be 

moved to protect an important fisheries resource. 

Response: The alternatives in the Final EIS are designed to show varying levels of development in this 

watershed, including Alternative 1, which would have no development LUDs. The Forest Service will 

consider the importance of the resources and potential level of effects if a timber sale is proposed in this 

area in the future. 

Comment: One comment recommended that the Forest Service increase stream buffers from 200 

to 500 feet in the Yakutat Ranger District for some streams. This request was based on a 

recommendation for this size buffer in a 1996 Forest Service document. 

Response: All of the past information, including the Panel Assessments (referenced in the comment), 

was considered when developing the standards and guidelines for stream buffers. There is leeway in the 

guidelines to increase buffers on a case-by-case basis if on-site evaluations determine that greater 

buffers are need to protect the function of the system. This is a Forest-wide programmatic amendment; 

therefore, site-specific buffer requirements for individual areas are not included. 

Comment: One comment recommended that small patch cuts and selective harvest be used in 

the Yakutat area. 
Appendix H 

Comments and Responses H-188 Final EIS 

Response: These prescriptions are available for consideration by Interdisciplinary Teams planning 

harvests in the Yakutat Ranger District, and elsewhere on the Forest. Additional information on selective 

harvest has been added to the Timber section of Final EIS 

Comment: Some respondents requested adjustments to the proposed LUD boundaries and 

placement in the Niblack and Hyder areas where minerals activity is high or has the potential to 

increase in the future. A number of comments were opposed to the Wild and Scenic River and 

Old Growth LUDs in the NIblack area and wanted to see the Minerals LUD overlay extended. 

Response: The alternatives include a range of levels of development LUDs in these two areas. It is 

possible in the future also, to make a LUD change if and when specific mining operations are proposed 

and approved.. Extension of the Minerals LUD overlay in these two areas is evaluated in the action 

alternatives of the Final EIS. These changes were made to recognize the valid existing rights in these 

areas along with the potential for additional minerals activity in these areas because of their minerals 

potential. 

Comment: One comment proposed that all non-Wilderness lands in the Petersburg Creek 

watershed be designated Wilderness, with the remaining lands within the “Petersburg Creek Land 

Acquisition” designated Remote Recreation. 

Response: No additional areas are considered for wilderness under this Forest Plan Amendment. 

Wilderness recommendations were considered in detail in the 2003 SEIS. The area would be allocated 

to Semi-remote Recreation under Alternatives 1, 2, 3, 5, and 6. It would be allocated to a mixture of 

Semi-remote Recreation and Timber Production under Alternatives 4 and 7. 
Appendix H

Final EIS H-189 Comments and Responses

Specific Places Identified for Protection 

Many respondents wrote to urge protection of specific places from timber harvest and road construction. 

The importance of subsistence in these areas was often the main rationale, as was recreation use. In 

other cases the identified areas were viewed has having unique values. Legislative protection of some 

sort was often requested. 

Each alternative was designed to include these areas needed to achieve the timber harvest levels 

established for that alternative. So Alternative 1, with the lowest harvest level, excludes most of the areas 

mentioned from development. On the other hand, Alternative 7, with the highest harvest level, has the 

potential to impact many of the identified areas. 

This section identifies many of the areas identified for protection and discusses the LUDs allocated to 

these areas under each alternative. The list of places presented in Table H-2 includes the majority of the 

areas that were identified by more than one respondent, but is not intended to be fully inclusive. Readers 

concerned about specific places not included in this section can find the same type of information by 

reviewing the large alternative maps that accompany this EIS. 

The places identified in Table H-2 are organized by Ranger District. In many cases, identified areas were 

located in proximity to one another. These areas are grouped by general area in Table H-2 and the 

following discussion. The text discusses these places by Ranger District and geographic area.

Table H-2 

Specific Places by Ranger District 

Ranger District Geographic Area Specific Place 

Yakutat Situk Watershed Situk Watershed 

Hoonah Elfin Cove Elfin Cove 

Chicken Creek Chicken Creek 

Sitka Tenakee Inlet Crab Bay 

Kadashan Watershed 

Long Bay 

Saltery Bay 

Seal Bay 

Tenakee Inlet 

Neka Bay Neka Bay 

Peril Strait Broad Creek 

Broad Finger 

Deep Bay 

Finger Creek 

Peril Strait 

Poison Cove 

Saook Bay 

Ushk Bay 

Redoubt Lake Redoubt Lake 

Sitka North Katlian Watershed 

Nakwasina Straits 

Starrgavan Watershed 

Silver Bay Silver Bay 

Kruzof Island Kalinin Bay 

Krestof Sound 

Kruzof Island 

Juneau Homeshore Homeshore 

Taku Inlet Rhine Creek 

Slocum Inlet 

Taku River 

 Sweetheart Sweetheart Creek 
Appendix H 

Comments and Responses H-190 Final EIS 

Table H-2 

Specific Places by Ranger District 

Ranger District Geographic Area Specific Place 

Juneau (cont.) Port Houghton Hobart Bay 

Port Houghton 

Sanborn Canal 

Windham Bay 

Petersburg Farragut Bay Farragut Bay 

 Cape Fanshaw 

North Kuiu Island Kadake Creek 

Port Camden 

Saginaw Bay 

Security Bay 

Three Mile Arm 

North shore of Rowan Bay 

South Kuiu Island No Name Bay 

 Reid Bay 

 South Kuiu Island 

Duncan Canal Castle River 

Duncan Canal 

Kah Sheets Creek 

Petersburg Watershed Petersburg Watershed 

Wrangell Narrows Mountain Point 

Peterburg Creek 

Tonga Mountain Point 

Kushneahin Creek Kushneahin Creek 

South Mitkof Island Southeast Mitkof Island 

Wrangell Madan Bay Madan Bay 

Bradfield Canal Bradfield Canal 

Navy Lake Navy Creek 

Anan Creek Anan Creek 

Ketchikan Cleveland Peninsula Cleveland Peninsula 

 Spacious Bay 

 Union Bay 

 Yes Bay 

Gravina Island Bostwick Inlet 

Gravina Island 

Thorne Bay Honker Divide Honker Divide 

Calder Holbrook Calder Holbrook 

20 Road 20 Road 

Eleven Mile Eleven Mile 

Craig Cat Island/Duke Island Cat Island 

Duke Island 

Salmon Lake Salmon Lake 

Sea Otter Sound North Sea Otter Sound 

Dall Island Dall Island 

Outside Islands Outside Islands 

South Prince of Wales Clover Bay 

 Kassa Inlet 

 Keete Inlet 

 Mabel Bay 

 Moira Sound 

 Monie Lake 

 Niblack 

 Sunny Cove 

 Trollers Cove 
Appendix H

Final EIS H-191 Comments and Responses

Yakutat Ranger District 

Situk Watershed: This area is not available for timber management under Alternative 1. Portions of the 

upper watershed would be available for timber management under all other alternatives. All alternatives 

except 4 and 7 include a small old-growth reserve in the upper watershed. OGRs are withdrawn from 

timber management. 

Hoonah Ranger District 

Elfin Cove: This area is allocated to LUDs that do not allow timber management under all alternatives. 

Chicken Creek: This creek is within an old-growth reserve under all alternatives except Alternatives 4 and 

7. The area would be available for timber management under these two alternatives. 

Sitka Ranger District 

Tenakee Inlet: The southeast side of Tenakee Inlet includes Long Bay, Saltery Bay, Seal Bay, and Crab 

Bay. These areas would not be available for timber management under Alternative 1 and only small 

portions would be available under Alternatives 2 and 3. Nearly all of these areas are allocated to 

development LUDs under Alternatives 4 and 7. While most of these areas are within development LUDs 

under Alternatives 5 and 6, key portions are allocated to old-growth reserve, especially under Alternative 

6. The Kadashan Watershed is allocated to LUD II under all alternatives. LUD II is withdrawn for timber 

management. 

Neka Bay: The area around the bay would be entirely allocated to non-development LUDs under 

Alternative 1 and primarily to non-developement LUDs under Alternatives 2, 3, 5, and 6. This area would 

be allocated to a development LUD under Alternatives 4 and 7. 

Peril Strait: Ushk Bay and Poison Cove are allocated to LUDs that do not allow timber management 

under Alternatives 1, 2, and 3 and to a mix of development and non-development LUDs under 

Alternatives 5 and 6. These areas would be allocated to development LUDs under Alternatives 4 and 7. 

Saook Bay would be allocated to a non-development LUD under Alternative 1 and primarily to nondevelopment LUDs under Alternatives 2 and 3. The area would be allocated to development LUDs under 

Alternatives 4, 5 and 7 and to a mix of development and non-development LUDs under Alternative 7. 

Deep Bay would primarily be within an old-growth reserve under all alternatives except 4 and 7, which 

would allocate the area to development LUDs. Upper Peril Strait would remain LUD II under all 

alternatives. The Broad Finger or Broad Creek area to the southeast of the Pelican LUD II area would be 

an old-growth reserve under all alternatives except Alternatives 4 and 7. It would be available for timber 

harvest under those two alternatives. 

Redoubt Lake: This area would not be available for timber management under any alternative. 

Sitka North: This area, which includes Starrigavan Bay, Katlian Bay, and Nakwasina Sound, would not 

be available for timber management under any alternative, except for the area north of Nakwasina Sound 

which would be allocated to development LUDs under Alternatives 4 and 7. 

Silver Bay: The area along Silver Bay would be allocated to LUDs that do not allow timber management 

under Alternative 1 and primarily to non-development LUDs under Alternatives 3, 4, 5, and 6. Most of the 

area would be allocated to development LUDs under Alternatives 4 and 7. 

Kruzof Island: This island would not be available for timber management under Alternative 1. All other 

alternatives would allocate the island to a mix of development and non-development LUDs. The southern 

third of the island would be a special interest area under all alternatives. The northern portion of the 

island, including Kalinin Bay, would be an old-growth reserve under all alternatives except Alternatives 4 

and 7. This portion of the island would have a development LUD under these two alternatives. 

Portofshikof Island to the east would be allocated to a non development LUD under all alternatives except 

Alternatives 4 and 7. 
Appendix H 

Comments and Responses H-192 Final EIS 

Juneau Ranger District 

Homeshore: This area would be allocated to a non-development LUD under Alternative 1 and to 

development LUDs under all other alternatives. 

Taku Inlet: Rhine Creek and Slocum Inlet near the entrance to Taku Inlet would be allocated to nondevelopment LUDs under Alternatives 1, 2, and 3 and to LUDs that permit timber management under all 

other alternatives. Taku River would be allocated to non-development LUDs under all alternatives. There 

would be a Transportation and Utility LUD on the south side of the river under all alternatives. 

Sweetheart: Both Sweetheart Creek and Sweetheart Lake would be allocated to non-development LUDs 

under all alternatives. 

Port Houghton: The Windham Bay, Hobart Bay, and Port Houghton area would not be available for 

timber management under Alternative 1. Alternative 3 would allow some timber harvest near Port 

Houghton, while remaining areas would be allocated to non-development LUDs. Most of these areas 

would be allocated to development LUDs under Alternatives 4, 5, 6, and 7. The Sanborn Canal area 

would be within an old-growth reserve under all alternatives except Alternatives 4 and 7. The area would 

be allocated to development LUDs under those two alternatives. 

Petersburg Ranger District 

Farragut Bay: The Cape Fanshaw and Farragut Bay area would not be available for timber management 

under Alternative 1. Only a small area near Farragut Bay would be allocated to LUDs that allow timber 

management under Alternative 2. Alternative 3 would allow some timber harvest near Farragut Bay, 

while the Cape Fanshaw area would be allocated to non-development LUDs. These areas would be 

allocated to a mix of development and non-development LUDs under Alternatives 4, 5, 6, and 7, with 

Alternatives 4 and 7 allowing the most timber management.

North Kuiu Island: This area includes Port Camden, Security Bay, Saginaw Bay, Kadake Creek, Rowan 

Bay, and Three Mile Arm (Table H-2). These areas would not be available for timber management under 

Alternative 1. Most of North Kuiu Island would be allocated to development LUDs under the remaining 

alternatives. The west side of Security Bay would have a non-development LUD under all alternatives. 

The north side of Rowan Bay would be allocated to a non-development LUD under Alternative 1; to a 

mixture of development and non-development LUDs under Alternatives 2, 3, 5, and 6; and to 

development LUDs under Alternatives 4 and 7. 

South Kuiu Island: This area includes Reid Bay and No Name Bay. No timber management would be 

permitted in these areas under Alternatives 1, 2, and 3. Both areas would be allocated to development 

LUDs under the other alternatives. Only Alternatives 4 and 7 would permit timber management in the 

Roadless Area south of the Kuiu Wilderness. 

Duncan Canal: The west side of Duncan Canal, which includes Kah Sheets Creek and Castle River, 

would be allocated to non-development LUDs under Alternatives 1, 2, and 3 and to a mix of development 

and non-development LUDs under the other alternatives. The east side of Duncan Canal would have a 

mix of development and non-development LUDs under all alternatives, with Alternatives 4 and 7 allowing 

the most timber management. 

Wrangell Narrows: The area along the Narrows would be allocated primarily to a mix of development and 

non-development LUDs under all alternatives, with Alternatives 4 and 7 allowing the most timber 

management and Alternative 1 the least. 

Kushneahim Creek: The southwest corner of Kupeanof Island would be allocated to non-development 

LUDs under Alternatives 1, 2, and 3 and primarily to development LUDs under Alternatives 4, 5, 6, and 7. 

However, Alternatives 5 and 6 would include three OGRs in southwest Kupreanof Island, while 

Alternatives 4 and 7 would not. 
Appendix H

Final EIS H-193 Comments and Responses

South Mitkof Island: This area would have a mix of development and non-development LUDs under all 

alternatives, with Alternatives 4 and 7 allowing the most timber management and Alternative 1 the least. 

Wrangell Ranger District 

Madan Bay: The Madan area would be allocated to non-development LUDs under Alternatives 1 and 2 

and to a mix of development and non-development LUDs under the other alternatives. Most of Madan 

Bay borders an old-growth reserve under all alternatives except Alternatives 4 and 7. 

Bradfield Canal: The Bradfield Canal area would be allocated to non-development LUDs under 

Alternatives 1 and 2 and to a mix of development and non-development LUDs under the other 

alternatives. 

Navy Lake: This area would be allocated to development LUDs under all alternatives except Alternative 

1. 

Anan Creek: The Anan Creek area is allocated to LUD II under all alternatives. 

Ketchikan Ranger District 

Cleveland Peninsula: The peninsula southwest of Yes Bay would be allocated to non-development LUDs 

under Alternatives 1 and 2. The area southwest of Spacious Bay would be allocated to non-development 

LUDs under Alternative 3 while the area to the north would be a mix of development and nondevelopment LUDs. The area southwest of Meyers Chuck/Helm Bay would be allocated to nondevelopment LUDs under Alternatives 4, 5, and 6, while the remainder of the peninsula would have a mix 

of development and non-development LUDs. Nearly all of the peninsula would be allocated to 

development LUDs under Alternative 7. 

Gravina Island: All but a very small portion of the island would be allocated to non-development LUDs 

under Alternative 1. The small area of development LUD is not near Bostwick Inlet. Most of the island 

would have non-development LUDs under Alternatives 2, 3, 4, 5, and 6, with a development LUD 

extending north from Bostwick Inlet to California Ridge. Most of the island would be allocated to 

development LUDs under Alternative 7. 

Cat Island/Duke Island: Both islands would be contained in the Duke Island Zoological Special Interest 

Areas under all alternatives. This area was designated because of its abundant wildlife, especially 

waterfowl. 

Thorne Bay Ranger District 

Honker Divide: This area would be allocated to non-development LUDs under all alternatives except 

Alternative 7, which would allocate the area to development LUDs, except for the Recreational and 

Scenic River corridor along the Thorne River/Hatchery Creek. 

Calder Halbrook: The Mt. Calder/Mt. Halbrook area is allocated to LUD II under all alternatives. The area 

immediately to the northeast of the LUD II area would be allocated to development LUDs under all 

alternatives. 

20 Road: The area along the 20 Road would be allocated to a mix of development and non-development 

LUDs under all alternatives. 

Eleven Mile: The Eleven Mile Watershed would be allocated non-development LUDs under Alternatives 

1 and 2; to a mix of development and non-development LUDs under Alternatives 3, 5, and 6; and to 

development LUDs under the Alternatives 4 and 7. 
Appendix H 

Comments and Responses H-194 Final EIS 

Craig Ranger District 

Salmon Bay Lake: This area is allocated to LUD II under all alternatives. The area to the east would 

have development LUDs under all alternatives except Alternative 1. The area to the west would be 

allocated to non-development LUDs under all alternatives except Alternative 7. 

Salmon Lake: This area is allocated to LUD II under all alternatives. Adjacent areas would have varying 

levels of development LUDs depending on the alternative. 

Sea Otter Sound: Most of the area along Sea Otter Sound would be allocated to development LUDs 

under all alternatives. 

Dall Island: NFS land on the island south of Diver Bay (which is on the north end of the island) would be 

allocated to non-development LUDs under all alternatives. The area north of Diver bay would be 

allocated to non-development LUDs under Alternatives 1, 2, and 3 and development LUDs under the 

other alternatives. The island would have several Special Interest Areas under all alternatives. 

Outside Islands: With the exception of San Juan Bautista Island, all the islands west of Craig would be 

allocated to Wilderness, LUD II, or other non-development LUDs under all alternatives. San Juan 

Bautista Island would be allocated primarily to a development LUD under Alternatives 4, 5, 6, and 7 and 

to a non-development LUD under Alternatives 1, 2, and 3. 

South Prince of Wales Island: Nine specific places were identified on south Prince of Wales Island were 

identified for protection (Table H-2). The south half of the island includes Keete Inlet, Mabel Bay, Kassa 

Inlet, Sunny Cove, Niblack, Clover Bay, and Moria Sound. These areas would be allocated to nondevelopment LUDs under Alternative 1. Under Alternative 2, most of south Prince of Wales Island would 

be allocated to non-development LUDs except for the Cholmondeley Sound area, which includes Sunny 

Cove. This area would be allocated to development LUDs. Keete Inlet, Mabel Bay, Kassa Inlet, Sunny 

Cove, Niblack, and Moria Sound would primarily be allocated to development LUDs under Alternatives 4, 

5, 6, and 7. As noted in the preceding section, the Minerals LUD overlay was extended in the Niblack 

area under all of the action alternatives. 

The south side of Clover Bay would be allocated to a non-development LUD under all alternatives but the 

north side of the bay, and the Monie Lake area, would be allocated to development LUDs under all 

alternatives except 1 and 2. Trollers Cove would be allocated to non-development LUDs under all 

Alternatives 1 and 2 and to a mix of development and non-development LUDs under all other alternatives. 

The west side of south Prince of Wales Island would be allocated to non-development LUDs under 

Alternative 3, while most of the east side would be allocated to LUDs that permit timber management. 

C. References 

The references cited in this appendix are included in the reference section presented in Volume I, 

Chapter 6 of this EIS. 
Attachment A 

Letters from Agencies, Elected Officials, and 

Tribal Governments 
Final EIS H-A-i Comments and Responses

Attachment A 

Contents 

Federal Agency/Elected Official 

Agency/Organization Name Page Number

U.S. Department of Commerce, National Oceanic and Atmospheric 

Administration, National Marine Fisheries Service 

H-A1 

Congress of the United States H-A7 

United States Department of the Interior, Office of Environmental Policy and 

Compliance H-A10 

United States Environmental Protection Agency H-A22 

State Agency/Elected Official 

Agency/Organization Name Page Number

Governor of Alaska H-A27 

Alaska State Legislature – Wilson H-A46 

Alaska State Legislature – Harris H-A47 

Alaska State Legislature – Stedman H-A48 

Alaska Dept. of Transportation and Public Facilities H-A49 

Alaska Energy Authority H-A58 

Tribal Government 

Agency/Organization Name Page Number

Central Council Tlingit & Haida Tribes of Alaska H-A65 

Central Council Tlingit & Haida Tribes of Alaska H-A66 

Douglas Indian Association Tribal Government H-A68 

Hydaburg Cooperative Association H-A69 

Organized Village of Kake H-A71 

Klawock Cooperative Assoc., Tribe H-A72 

Kuiu Thlingit Nation H-A74 

Metlakatla Indian Community H-A77 

Organized Village of Saxman H-A78 

Organized Village of Saxman H-A79 

Organized Village of Saxman H-A80 

Sitka Tribe of Alaska/Tribal Government for Sitka H-A81 

Yakutat Tlingit Tribe H-A84 

Local Government (Boroughs, Cities, and Towns) 

Agency/Organization Name Page Number

City of Coffman Cove H-A85 

City of Craig H-A86 

City & Borough of Juneau H-A87 

Ketchikan Gateway Borough H-A89 

City of Ketchikan H-A91 

City of Kupreanof H-A92 

City of Pelican H-A93 

City of Port Alexander H-A94 

City of Thorne Bay H-A94 

City of Wrangell H-A95 

City & Borough of Yakutat H-A97 
Comments and Responses H-A-i Final EIS i

Civic Groups 

Agency/Organization Name Page Number

Craig Community Association H-A101 

Prince of Wales Community Advisory Council H-A102 

Southeast Alaska Regional Advisory Council H-A104 

Yakutat Salmon Board H-A108 
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Printed on Recycled Paper

Photograph taken looking northeast with Lindenberg Peninsula on Kupreanof Island and 

the mouth of Petersburg Creek (front cover) in the foreground, Petersburg Mountain (front 

cover) in the middleground, and Frederick Sound and the mainland in the background.