United States Department of Agriculture

Wrangell Island Project 

Record of Decision DRAFT

Forest Service

Alaska Region

Tongass National Forest

Wrangell Ranger District R10-MB-634c July 2017

USDA 
Cover Photo: Pat Valley, Wrangell Island. Photograph by Andrea Slusser

NOTE: Every effort is made to create documents that are accessible to individuals of all abilities; however, 

limitations with our word processing programs may prevent some parts of this document from being readable 

by computer-assisted reading devices. If you need assistance with this document, please contact the Wrangell 

Ranger District at (907) 874-2323.
USDA 

~ 

Uruitedl States 

71 O,enab·tment of .. • Agi·iculture 

Fon.•st 

Service 

Dear Pllanni.ng Participant: 

Tcmgass National Forest 

Afaska Regforn 

File Code: 

Date: 

1950 

648 Mission Street 

KeGdtikain, AJ( 99901 

907-225-3101 

July rn, 2017 

I am pleased to announce the Final Envirnn.mental Impact Statement (FEIS) and drnft Recore!. of Decision 

(RO])) for the Wrangell Island !Project are available for review at the Ketchikan Fm-est Supervisor's 

Office, the Wrangell District Office, and\ on.line at http://www.fs.usda.gov/project/?project=3483 1. 

Hardcopies and digital copies of the documents are avai]able upon request. 

The draft d.ecision cfocunoents my intent to select Al!temative 2 from the FEIS, to make about 56 million 

board feet of sawlog and utility timber available for harvest frotn about 4,767 acres of comrnercial forest 

land on Wrangel.l Island . T imber harvest will be by partial cut and clearcut. A.bout 16.8 miles of · ational 

Forest System road construction, 4.4 m.i.les of road reconditioning, and 9.9 miles of te1111porary road 

construction would be required to harvest the timber. 

The WrangeU Island Project draft ROD is being made available for public review pri.or to the final 

deccsion. Please see the section "AdministratLve Review - Opportunity to Object" for information on filing 

an objection at the encl of the ROD. More information on the pre-decisional objection process can also be 

found a.t http://www.fs.fed.us/objections/i nclex.php. 

Under the 36 CFR 218 objectnon process, the public will be notified oft.he ava ilability of the clraft ROD 

through a legal notice published in the newspaper of record, the Ketchlkan Daily News, starting the 45-day 

objection ftl.ing petiocl. A copy of the legal notice will also be posted on the Wrangell Island IPtoject 

website at http://www.fs.usda.gov/project/?project=3483 l . 

If objections are received during the 45-day objection filing period, a 45-day administrative lfeview period 

wm begi.n during which time the Reviewing Officer, the Responsible Official, and any objectors may 

attempt to resolve concerns, with the goal of achieving a better, more-informed decision. The ROD will 

be signed after any concerns and i.nstrnctions i.dentifiecl by the Reviewing Officer in the obj ection 

response have been addressed . A fmal decision on prnjects subject to the objection process may occur on, 

but not before, 5 business clays from the close of the objection filing period, if no objections a.re received 

(36 CFR 218.12(c)(2}). 

Cop.ies of this Jetter have been distributed to those people and organizations on the project mailing list. 

For additional information, please contact Robert Dalrymple, WrangelJ District Ranger, at (907) 874-2323. 

I want to, thank you for your interest m the Wrangell Island Project 

M. EARL STEW ART 

Forest Supervisor, Tongass NF 

Caring fo r tbe ILand and Serving People 

#fl,; 

Pnnfcl 0 11 Rc:-.t.'.)-1(.,lcd P":tpcr .. , 

1 

Wrangell Island Project 

Record of Decision DRAFT 

United States Department of Agriculture

Lead Agency: USDA Forest Service

Tongass National Forest

Responsible Official: M. Earl Stewart, Forest Supervisor 

Federal Building

648 Mission Street

Ketchikan, AK 99901

For Information Contact: Robert Dalrymple, District Ranger

Wrangell Ranger District

PO Box 51

Wrangell, Alaska 99929

907-874-2323

Abstract

The Responsible Official intends to select Alternative 2 from the Wrangell Island Project Final 

Environmental Impact Statement (FEIS) as the Selected Alternative. The Selected Alternative makes 

about 56 million board feet of sawlog and utility timber available for harvest from about 4,767 acres of 

National Forest System land on Wrangell Island to contribute to the Tongass National Forest timber sale 

program. Both partial cut harvest and clearcut harvest methods will be used. To accomplish this timber 

harvest, approximately 16.8 miles of National Forest System road and 9.9 miles of temporary road will be 

constructed and 4.4 miles of system road will be reconditioned.

i 

Table of Contents

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

Decision ........................................................................................................................................................ 1

Features of the Selected Alternative ......................................................................................................... 7

Rationale for the Decision ............................................................................................................................ 9

Purpose and Need ..................................................................................................................................... 9

Key Issues ................................................................................................................................................. 9

Public Comments .................................................................................................................................... 19

Consistency with the Forest Plan and other Applicable Laws and Regulations ..................................... 20

Summary of the Rationale ...................................................................................................................... 20

Alternatives ................................................................................................................................................. 21

Alternatives Considered in Detail ........................................................................................................... 21

Alternatives Considered but Eliminated from Detailed Analysis ........................................................... 28

Environmentally Preferred Alternative ................................................................................................... 28

Public Involvement ..................................................................................................................................... 28

Mitigation .................................................................................................................................................... 29

Monitoring .................................................................................................................................................. 29

Project Record ............................................................................................................................................. 29

2016 Forest Plan ......................................................................................................................................... 29

Findings Required by Law and Regulation ................................................................................................. 31

Alaska National Interest Lands Conservation Act (ANILCA) of 1980; Section 810 ............................. 31

Bald and Golden Eagle Protection Act of 1940 (as amended) ............................................................... 32

Clean Air Act of 1970 (as amended) ...................................................................................................... 32

Clean Water Act (1977, as amended) ..................................................................................................... 32

Endangered Species Act of 1973 (as amended)...................................................................................... 33

Federal Cave Resource Protection Act of 1988 ...................................................................................... 33

National Forest Transportation System Final Administrative Policy and Final Rule ............................ 33

Magnuson-Stevens Fishery Conservation and Management Act ........................................................... 33

Marine Mammal Protection Act of 1972 ................................................................................................ 33

National Forest Management Act of 1976 (as amended) ....................................................................... 34

National Historic Preservation Act (NHPA) of 1966 (as amended) ....................................................... 34

Tongass Timber Reform Act (TTRA) of 1990 ....................................................................................... 35

Applicable Executive Orders ...................................................................................................................... 35

Executive Order 11988 (Floodplains) .................................................................................................... 35

Executive Order 11990 (Wetlands) ........................................................................................................ 35

Executive Order 12898 (Environmental Justice) .................................................................................... 35

Executive Order 12962 (Aquatic Systems, Recreational Fisheries) ....................................................... 35

Executive Order 13007 (Indian Sacred Sites) ........................................................................................ 36

Executive Order 13112 (Invasive Species) ............................................................................................. 36

Executive Order 13175 (Consultation and Coordination with Indian Tribal Governments) .................. 36

Executive Order 13186 Migratory Birds ................................................................................................ 36

Executive Order 13443 (Facilitation of Hunting Heritage and Wildlife Conservation) ......................... 36

Federal and State Permits ....................................................................................................................... 36

Implementation ........................................................................................................................................... 37

Administrative Review - Opportunity to Object ......................................................................................... 38

Implementation Date ................................................................................................................................... 39

Contact Information .................................................................................................................................... 39

Responsible Official .................................................................................................................................... 39

1 

Record of Decision DRAFT

Wrangell Island Project 

USDA Forest Service

Wrangell Ranger District, Tongass National Forest, Alaska Region

Introduction

This draft Record of Decision (ROD) is being made available for review under the project level predecisional administrative review, or “objection process” (Title 36 CFR 218, Subparts A and B). The 

objection process gives eligible individuals and entities the opportunity to voice concerns and file 

objections with the Reviewing Officer and Responsible Official prior to the final ROD.

This draft Record of Decision documents my decision to select Alternative 2 (hereafter referred to as the 

Selected Alternative) from the Wrangell Island Project FEIS. The ROD contains a summary of the 

environmental analysis completed for this project and the rationale for my decision. It also contains my 

findings required by law and prior to the final ROD. 

The Selected Alternative will make approximately 56 million board feet of sawlog and utility timber 

available for harvest from about 4,767 acres of National Forest System land on Wrangell Island (in its 

entirety Wrangell Island is the project area) to contribute to the Tongass National Forest timber sale 

program. The harvest of this timber will require construction of about 16.8 miles of National Forest 

System (NFS) road, and construction of about 9.9 miles of temporary road. It also proposes 

reconditioning 4.4 miles of existing NFS road. Approximately 0.2 mile of NFS road will be 

decommissioned and an additional 15.9 miles of NFS road will be closed to public motorized use. 

Approximately 86.0 miles of NFS road and 14.5 miles of motorized trail will remain open for public use. 

See the Selected Alternative map (figure 2), and Selected Alternative Access Management map (figure 3).

Decision 

Based upon my review of public comments, the analysis contained in the FEIS, the project record, and the 

recently implemented 2016 Forest Plan, I intend to select Alternative 2 as the Selected Alternative. The 

Selected Alternative is displayed in figure 2 and figure 3 in this draft Record of Decision. 

I am incorporating the project design features and measures to minimize adverse environmental effects of 

the Selected Alternative as part of my decision. These are described generally in chapter 2 of the FEIS 

and site-specifically in the unit cards and road cards (appendices 1 and 2 of this draft ROD, which are 

located on the Wrangell Island Project webpage http://www.fs.usda.gov/project/?project=34831). I am 

satisfied that these are practicable and effective in avoiding or minimizing environmental effects. I have 

found them to be effective when implemented elsewhere on the Forest. 
Wrangell Island Project

2 

Figure 1. Wrangell Island Project vicinity map

~ ProjectArea 

~ Non-National Forest 

~ Lakes 

-- Class I Streams 

--Existing Road s 

1 

' Wrangell Island J 

Juneau• _ 

Al n,k a· 

\l\h"angell Island Project 

Vicinity Map 

N 

A 

0 1.25 2.5 5 ••==i•••• Mile s 
DRAFT Record of Decision

3 

Figure 2. Selected Alternative for the Wrangell Island Project

N Etolin Island 

A 

0 Q5 2 3 4 •-m::::::i--c:::::=-----c:::======::::::11----•Miles 

Wrangell Island Project 

Selected Alternative 

CJ Even-aged Harvest -- 0% Retention -- 500ft Contour 

1111 Even-aged Harvest -- 15% Retention Proposed NFS Road 

\ 1111 Uneven-aged Harvest-- 33% Removal Proposed Temporary Road 

c:::J ProjectArea Boundary Reconditioned Road 

~ Non-National Forest Existing Roads 

CJ Young Growth ----- Closed Roads 

-- Class I Stream 

DRAFT Record of Decision

5 

Figure 3. Road status and locations for the Selected Alternative

N 

A 

,,..., ,r,r"\ 

\ ~/ ' . Thoms '--, 

Lake " 

')/ 

Etolin Island 

(/) 

Wrangell Island Project 

Selected Alternative 

Access Management 

... -... i_._j ProjectArea Boundary 

!=i Non NF Lands 

Lakes/Salt Water 

= Roads Open to Public Motorized Use -All Vehicles 

Roads Open to Public Motorized Use -All Vehicles 50" or Less In Width 

••••• Closed Roads 

••••• Roads to be Closed 

- Roads to be Decommissioned 

.. 

• 

) 

\ Wrangell Island 

-

I 

.. 

" 

.. 

.. 

\ 

' . .. 

o•--==o::1!..-==----•2c:::=======3----•4 Miles i L.._ __________________________________ _.o,.._ ___ _,_::..._ _____ __,L,_ _____________ __J,~ 

DRAFT Record of Decision

7 

Features of the Selected Alternative 

The Selected Alternative is designed to provide the greatest supply of timber volume for the timber 

industry, while protecting scenic quality, old-growth habitat and wildlife habitat connectivity. 

The Selected Alternative proposes even-aged and uneven-aged timber harvest on suitable lands, and the 

construction of new and temporary roads. It also proposes road management objectives which define 

public motorized access.

The Selected Alternative is designed to harvest timber in the Timber Production and Modified Landscape 

land use designations (LUDs). This alternative provides timber volume opportunities for both large and 

small sales within the suitable land base under the 2016 Forest Plan. This alternative includes harvest in 

the mill basin area, and near Long Lake. This alternative addresses Issue 1 (Timber Economics) by 

providing the greatest timber volume from which to offer individual timber sales. It also addresses Issue 4 

(Access Management) by providing the most motorized public access following harvest. 

The Selected Alternative is summarized in table 1 and illustrated in figure 2 and figure 3. 

Timber Harvest: The Selected Alternative will produce an estimated 56 MMBF of old-growth 

saw/utility timber volume from approximately 4,767 acres. Silvicultural prescriptions include 

approximately 3,359 acres of uneven-aged management (partial harvest) and 1,408 acres of even-aged 

management (clearcut) using conventional cable, shovel, and helicopter logging systems. The partial 

harvest systems are designed to retain at least 67 percent of the stand’s basal area to protect the scenic 

value, but also to reduce negative effects to wildlife. Where there are no safety or resource concerns, this 

alternative will allow for limited, short-term public access to gather firewood from temporary roads once 

timber harvest activities are complete. No young-growth harvest is included in the project. 

Roads: The Selected Alternative will construct 16.8 miles of new NFS roads and 9.9 miles of temporary 

roads. It will also recondition 4.4 miles of existing NFS roads. All temporary roads will be 

decommissioned after activities are complete. Existing marine access facilities at Pats Creek and Earl 

West may be used.

Motorized Access Management: The motorized access management proposed in this alternative was 

developed through a collaborative process between the IDT and the Wrangell Borough. The process 

identified the roads associated with the alternative that are the most important to the community for 

subsistence and recreation access. Then the roads were evaluated based on resource protection needs and 

future maintenance costs. Alternative 2 proposes closing 15.9 miles of existing and proposed NFS road to 

public motorized use and decommissioning 0.2 mile. Approximately 86 miles of NFS road would be 

available for public motorized access, of which 14.5 miles would be restricted to motorized trail use.
Wrangell Island Project

8 

Table 1. Summary table of the selected alternative for the Wrangell Island Project

Measure Selected Alternative

BASIC PROJECT DATA

Timber Harvest (acres) 4,767

Volume of Harvest (MMBF) 56 

TIMBER SUPPLY

Timber Volume (MBF)

Sawtimber 50,885

Utility 4,885

Total Net Volume 55,770

Logging System (acres)

Cable 998

Shovel 528

Helicopter 3,241 

Total Harvest Acres 4,767

SILVICULTURE

Silvicultural system and harvest method

Uneven-aged Management – Single tree selection 

(removal of up to 33% of basal area) (acres)

Shovel 118

Helicopter 3,241 

Even-aged Management – Clearcut (acres)

Cable/Shovel 1,340 

Clearcut with reserves (acres)

Cable/Shovel 68

Helicopter 0

Total Acres Harvested 4,767

Timber Volume by Species (MBF)

Sitka spruce 11,195

Hemlock 26,460

Western redcedar 4,071

Yellow-cedar 9,159

ACCESS MANAGEMENT

NFS road construction (miles) 16.8

Temp road construction (miles) 9.9 

Road reconditioning (miles) 4.4

Estimated total road costs (in millions of dollars) $4.5

NFS Road Designations, following implementation 

(total, island-wide) 

Open to all vehicles (miles) 86.0

Motorized trails (miles) 14.5

Closed to public motorized use (miles) 15.9

NFS roads to be decommissioned (miles) 0.2
DRAFT Record of Decision

9 

Rationale for the Decision 

I believe it is important to clearly explain why I intend to select Alternative 2. 

I considered a combination of factors in making my decision: 

• I looked at how each alternative responded to the Purpose and Need for the project. 

• I considered how each alternative addressed the key issues developed from scoping.

• I reviewed the environmental effects of each alternative.

• I reviewed and considered the public comments to see how the alternatives responded to the issues 

and management concerns raised by the public other agencies, and the interdisciplinary team 

members.

• I verified that the decision is consistent with the Forest Plan as well as applicable laws, regulations, 

and policies. 

A detailed discussion of how each of these factors were considered is presented below.

Purpose and Need

I looked at how each alternative responded to the Purpose and Need for action (described in the FEIS 

chapter 1) of meeting the Timber Goals and Objectives and the Economic Goals and Objectives of the 

Forest Plan offering a supply of timber for harvest to meet the needs of the industry. The Purpose is to 

respond to the Timber, Economic, and other goals and objectives of the Forest Plan and help move the 

project area toward the desired conditions. The Need is to meet the requirements of TTRA to seek to meet 

the market demand. 

I have determined that the Selected Alternative best meets the Purpose and Need within Forest Plan 

direction for timber volume and economic opportunities. It will produce a supply of timber for the timber 

industry while minimizing effects to the environment. The direct, indirect, and cumulative environmental 

effects from project activities are consistent with the goals, objectives, and standards and guidelines in the 

Forest Plan.

The Selected Alternative will:

• Contribute an estimated 56 MMBF of timber to meet the annual and planning cycle market demand 

for Tongass National Forest timber in an orderly flow to large and small timber purchasers, mill 

operators, and value-added wood product industries in Southeast Alaska. 

• Benefit the local and regional economies of Wrangell and Southeast Alaska by providing 

opportunities for resource uses to maintain and enhance local timber processing capacity.

• Support a wide range of natural resource employment opportunities within Wrangell and other 

Southeast Alaska communities.

• Manage the timber resource for production of sawtimber and other timber products from suitable 

forest lands made available for timber harvest, on an even-flow, long-term sustained yield basis and 

in an economically efficient manner while also improving forest resource conditions. 

• Provide a supply of “bridge” timber that would support local jobs and facilitate the industry 

transition to a sustainable wood product industry based on young-growth management on the 

Tongass National Forest.

Key Issues

An important consideration in making my decision is how each alternative addressed the key issues 

developed from input received during project scoping. After carefully reviewing the key issues (FEIS 

chapter 1), I find that the Selected Alternative best addresses these key issues when considered as a 

whole. 
Wrangell Island Project

10

Issue 1: Timber Supply and Timber Sale Economics 

The forest products industry has been a part of Wrangell Island and the Southeast Alaska economy since 

the 1950s. While the forest products industry is a fraction of what it once was, it is still an important 

contributor to the economy and important in economic diversification. Both the timber supply and the 

associated economic effects produced from National Forest System lands on Wrangell Island affect the 

stability of Southeast Alaska’s forest products industry and the ability of the industry to provide 

employment and contribute to the local and regional economies. The timber industry in Southeast Alaska 

includes large and small timber purchasers, mill operators, and value-added wood product industries that 

are dependent upon a reliable supply of timber. 

I considered the need to manage the timber resource in the Wrangell Island Project area in order to 

produce an even flow of timber on an economical basis from the Tongass National Forest. The Selected 

Alternative provides the most timber volume, about 56 MMBF, toward meeting annual and planning 

cycle market demand. This timber volume will be offered in a variety of sale sizes to meet the needs of 

both large and small operators.

The Selected Alternative will contribute timber volume to meet industry needs. Although there is 

currently no young-growth timber mature enough for economical harvest in the Wrangell Island Project 

area, the Selected Alternative contributes to the supply of “bridge” timber needed to maintain the timber 

industry during the transition to young-growth management. A reliable supply of economically viable 

timber is critical to maintain the expertise and infrastructure of the existing timber industry during the 

transition.

I evaluated the concerns for providing for economical timber sale offerings within the context of 

fluctuating timber markets, the amount of timber volume currently available for offer from the Tongass 

National Forest, and the relative environmental effects of the Selected Alternative, and find that the 

Selected Alternative provides the best balance overall. The results of the financial efficiency modeling 

indicate a deficit value based on past market performance for all alternatives. While the Selected 

Alternative is not the most economical alternative, because it requires the highest amount of helicopter 

yarding, it produces the most timber volume. Under the current limited export policy, the indicated 

advertised rate is negative $59.23/net MBF for the Selected Alternative and negative $220.64/net MBF 

under the 100 percent domestic processing scenario. 

Economic and timber market conditions continue to fluctuate dramatically. The financial efficiency 

analysis model used for the Wrangell Island Project relies on past values and costs and can only provide a 

relative comparison of values between the alternatives as a whole. It cannot predict market conditions at 

the time of offer for a particular sale, since timber markets and values are extremely volatile. The actual 

economic values of timber from the project will not be known until the timber sales, which are offered by 

competitive bid, are awarded to the highest bidder. These timber sales must have a positive appraisal 

value before they can be advertised for sale. 

The Selected Alternative could support an estimated 222 annualized jobs, including logging, sawmilling, 

transportation and other services. Of the action alternatives, it provides the highest timber volume and 

supports the highest number of jobs. 

The NFS roads built under the Selected Alternative will also become part of the infrastructure necessary 

to manage the young growth in the future.

Issue 2: Wildlife Habitat

The FEIS disclosed the possible adverse effects of each alternative on wildlife habitat. These effects will 

be mitigated or reduced through the use of Forest Plan standards and guidelines, including best 

management practices. Site-specific mitigation measures are listed on the unit and road cards 

(http://www.fs.usda.gov/project/?project=34831).
DRAFT Record of Decision

11

Many commenters expressed concern that timber harvest would reduce old-growth forest habitat in the 

project area, thereby reducing the preferred habitat for old-growth associated species. I carefully assessed 

these direct, indirect, and cumulative impacts to wildlife habitat in making my Decision. 

While Alternative 5 has the least overall effect on wildlife habitat of the action alternatives, I find the 

Selected Alternative finds the best balance in meeting timber volume needs while also minimizing the 

effects to wildlife habitat from timber harvest. The extensive use of partial harvest in the Selected 

Alternative, will substantially reduce adverse effects to wildlife. Approximately 70 percent of the harvest 

area in the Selected Alternative will be partially harvested using a single-tree selection prescription, where 

33 percent or less of the basal area of the stand is removed. This prescription leaves 67 percent or more of 

the stand remaining to provide habitat components and retain old-growth characteristics within the stand. 

Sixty-eight percent of the harvest area will use helicopter yarding which also eliminates the need for 

temporary roads and their associated impacts. Harvest unit design incorporated provisions for elevational 

travel corridors where possible. Known or suspected heron rookeries or raptor nests will be protected with 

no-harvest buffers.

I have determined that the Selected Alternative maintains enough old-growth forest to provide the full 

range of matrix functions in order to meet the Tongass Conservation Strategy on Wrangell Island. Oldgrowth wildlife habitat will be maintained within T77 VCU 4790, the 2001 inventoried roadless areas, 

and the old-growth reserves on Wrangell Island. There will be adequate habitat connectivity on Wrangell 

Island (see figure 4). 

The analysis included an assessment of old-growth reserve boundaries on Wrangell Island and possible 

modifications to them. This included a report with a recommendation from an interagency team of 

wildlife biologists for a biologically preferred change to increase the size and provide more connectivity 

to the Fools and Thom’s Medium old-growth reserves. I find that the existing old-growth reserves, by 

themselves, provide the necessary reserve habitat on Wrangell Island to meet the Tongass Conservation 

Strategy. Now, however, Wrangell Island has even more protected habitat with the 2001 inventoried 

roadless area designations, and VCU 4790, as a T77 Watershed and The Nature Conservancy / Audubon 

conservation priority area. Over 75 percent of the NFS land on Wrangell Island is now protected from 

development and will continue to provide wildlife habitat. Figure 4 illustrates the protected areas in 

relation to the areas available for harvest.

I have determined that the decision will not have a significant direct, indirect, or cumulative effect on any 

migratory bird species in the project area. There may be moderate direct effects on individuals or small 

groups and their nests from the harvest of timber or the disturbance caused by harvest and related 

activities. Goshawk surveys were conducted and known nest and probable nest locations were protected 

with no-harvest buffers to comply with Forest Plan. Should other raptor nests or great blue heron 

rookeries be discovered during implementation, they will be protected. 

The Selected Alternative will have minimal to no impact on Threatened, Endangered, or Alaska Region 

Sensitive species. The Biological Assessment findings for humpback whale is “Not likely to adversely 

affect”. The Biological Evaluation findings for goshawk, as a sensitive species, is “May adversely affect 

individuals but not likely to result in a loss of viability in the planning area nor cause a trend toward 

federal listing”. Detailed information is in the Biological Evaluation and Biological Assessment and is 

summarized in the FEIS, chapter 3. 

DRAFT Record of Decision

13

Figure 4. National Forest System lands available for timber harvest as established by the 2016 Forest Plan 

7 

0 0.75 

- -

Etolin Island 

N 

A 

1.5 3 

~ \ 

4.5 ._\ 

Mainland 

Coast Range 

0 

Wrangell Island Project 

National Forest System Lands 

Available for Harvest 

(=i ProjectArea Boundary 

~ Available for Timber Harvest 

1111 Not Available for Timber Harvest 

~ Previous Harvest 

II IJ VCU 4790 2016 Forest Plan Amendment 

~ Inventoried Roadless Areas 

1//j Old-growth Reserves 

~ Non-National Forest 

~ Lakes 

-- Open Roads 

-- Class I Stream 

<:) 

~ 

~ 

0 

0 

..,_ 

~ 

Q, 

0 

,~ X,-

)~ JI', f'l ( 

DRAFT Record of Decision

15

The Selected Alternative and the other action alternatives will have minimal effect on the management 

indicator species. The estimates of effects are related to the acres of harvested habitat. No change in the 

existing trend for any management indicator species is anticipated. The amount of partial harvest in the 

Selected Alternative is expected to reduce the effect on these species.

Deer, wolves, goshawks, and marten were identified as species of special interest by the Forest Service, 

the public and wildlife agencies.

Deer habitat: Deer are habitat generalists but the habitat used in the winter is the most limiting factor 

when discussing habitat needs. The Selected Alternative will have the most effect of the action 

alternatives on deer habitat but it is relatively minor. Deer modelling indicates that on National Forest 

System lands, the Selected Alternative will reduce the deer habitat capability (which is a theoretical 

number of deer that habitat is expected to support) by less than approximately 8 percent from the existing 

condition at the time of stem exclusion. It would reduce deep-snow winter habitat (high-volume POG 

below 800 feet elevation on south-facing aspects) by less than 2 percent, reduce the average winter habitat 

(all POG below 1,500 feet in elevation) by less than 9 percent, and reduce the non-winter habitat by less 

than 1 percent from the existing condition. The cumulative reduction in deer habitat capability would be 

approximately 22 percent from historical condition on all land ownerships in the analysis area at time of 

stem exclusion. The reduction in deep-snow winter habitat would be reduced by 34 percent of historical 

condition, the reduction in average winter habitat would be reduced by 25 percent, and the reduction in 

the non-winter habitat would be reduced by 5 percent from the historic condition. The deer modelling 

treats all timber harvest as though it were clearcut whereas single-tree selection partial harvest may 

actually be applied. Therefore, in the Selected Alternative, impacts are not expected to be as severe in the 

single-tree selection units as the deer model predicts, because 67 percent or more of a stand’s pre-harvest 

basal area would be maintained. Ninety-one percent or more of the deer habitat on National Forest 

System lands on Wrangell Island (POG) would remain after the Selected Alternative is implemented.

Wolves: Wolves are habitat generalists but productive old growth provides habitat for their prey. Deer 

density derived from habitat modelling is used to measure effects of timber harvest and road density is 

used to measure potential adverse effects from human access for trapping and hunting wolves. Of the 

action alternatives, the Selected Alternative would have the most effect on wolves but all effects are 

expected to be minor. The current deer density on National Forest System lands in the project area is 12.8 

deer/mi2

. Under the Selected Alternative, the deer density is estimated to decrease by 1 deer/mi2 to 11.8 

deer/mi2

. The road density below 1,200 feet is estimated to increase by 0.2 mi/mi2 from the existing 

condition on National Forest System lands. For the cumulative effects on all land ownerships in the 

analysis area, deer density would decrease to 10.0 deer/mi2

 and road density would increase to 1.3 mi/mi2. 

Wolf mortality: No wolf mortality concerns have been identified in GMU 3, which includes Wrangell 

Island. 

Goshawk nesting habitat: The Biological Evaluation for goshawks determined that the Selected 

Alternative may adversely affect individuals but not likely to result in a loss of viability in the planning

area nor cause a trend toward Federal listing. Of the action alternatives, the Selected Alternative has the 

most effect on goshawks because it harvests the most acres. The Selected Alternative would reduce 

productive old-growth habitat at all elevations by an estimated 8 percent from the existing condition and 

reduce the high-volume productive old-growth habitat at all elevations by less than 12 percent on 

National Forest System lands. For the cumulative effects on all land ownerships in the analysis area, the 

Selected Alternative would reduce the productive old-growth habitat at all elevations by an estimated 21 

percent from historic conditions and reduce the high-volume productive old-growth habitat at all 

elevations by an estimated 39 percent.
Wrangell Island Project

16 

All known goshawk nests are protected by the Forest Plan standard and guideline that requires 100-acre 

no timber harvest zone around the nest (2016 Forest Plan, WILD4 II C, p. 4-95). All other areas where 

goshawks were detected but no nests were found are protected by a no-harvest buffer.

Marten habitat: Habitat requirements for martens reflect a strong interaction between food, cover, 

climate, predation, with forest cover being particularly important for travel, dens, resting sites, hunting, 

and avoiding inclement weather, so habitat below 1,500 feet in elevation is more important in the winter. 

The Selected Alternative has the most effect on marten habitat of the action alternatives because it 

harvests the most acres. The Selected Alternative would reduce productive old-growth habitat at all 

elevations by an estimated 8 percent from the existing condition and reduce the productive old-growth 

habitat at elevations lower than 1,500 feet in elevation by less than 12 percent on National Forest System 

lands. For the cumulative effects on all land ownerships in the analysis area, the Selected Alternative 

would reduce the productive old-growth habitat at all elevations by an estimated 39 percent from historic 

conditions. 

Wrangell southern red-backed vole habitat: The Wrangell southern red-backed vole was identified as a 

concern by some commenters. It is considered an endemic mammal, currently known only to occur on 

Wrangell and Sergief Islands. A southern red-backed vole was also detected on Etolin Island but has not 

been categorized into a subspecies. There is a limited understanding of the populations and habitat of the 

Wrangell southern red-backed vole but old-growth habitat was used as indicator to estimate the effects 

from timber harvest. The Selected Alternative would have the most effect on the southern red-backed vole 

because it harvests the most acres. The Selected Alternative would reduce productive old-growth habitat 

by an estimated 8 percent from the existing condition on National Forest System lands. For the 

cumulative effects on all land ownerships in the analysis area, the Selected Alternative would reduce the 

productive old-growth habitat at all elevations by an estimated 21 percent from historic conditions. 

Issue 3: Scenic Quality

Scenic quality was a key issue in the analysis. The proposed timber harvest, combined with past and 

reasonably foreseeable timber harvest, could affect scenic integrity from visual priority travel routes and 

use areas identified in the Forest Plan, and in areas of particular scenic importance to the community of 

Wrangell. 

The concern for maintaining scenic quality in the analysis area was one of the driving factors used in 

designing the harvest units and developing the alternatives. The Forest Plan established scenic integrity 

objectives for all the visual priority routes in the project area. In order to meet the scenic integrity 

objectives, partial harvest, rather than clearcut, was proposed in visually sensitive areas. 

While Alternative 5 has the least potential adverse effect to visual quality because it has the fewest acres 

harvested and the least amount of road construction, I find that the Selected Alternative provides the 

necessary scenic quality protection while also providing the most timber volume toward meeting annual 

and planning cycle market demand. Approximately 70 percent of the harvest area in the Selected 

Alternative will be partially harvested using a single-tree selection prescription where only 33 percent or 

less of the basal area of the stand will be removed. This leaves 67 percent or more remaining which will 

continue to provide the visual characteristics of an old-growth stand. All timber harvest in the Selected 

Alternative will meet the scenic integrity objectives. The scenic effects from harvest were of special 

concern in the mill basin, Long Lake, and Highbush Lake areas. The use of partial harvest will be only 

slightly evident to the average viewer in these areas. 

Issue 4: Access Management

Roads and road access were a key issue in the analysis. Public motorized access is an important concern 

for many Wrangell residents who expressed concerns that the roads involved in the project will be closed 

limiting their access to subsistence resources and recreation opportunities on the National Forest. The 
DRAFT Record of Decision

17

public uses the roads for subsistence hunting and gathering of firewood, timber, berries and other 

subsistence resources. 

The City and Borough of Wrangell worked with the IDT to develop the access management proposed in 

the Selected Alternative. When assessing whether to close each road or keep it open to public motorized 

access after timber harvest activities were completed, the IDT considered the subsistence, hunting, and 

recreation values of keeping roads open to the public against the maintenance costs of keeping roads 

open, and the potential impacts of open roads to soils, water quality, fish, and wildlife. 

The Selected Alternative provides the most public motorized access of the action alternatives. While the 

Selected Alternative will close a total of approximately 15.9 miles of NFS road to public motorized use 

(existing and proposed) and will decommission 0.2 mile of NFS road, approximately 86.0 miles of NFS 

road and 14.5 miles of trail will remain open for public motorized use, as shown on the Selected 

Alternative Access Management map (figure 3). All temporary roads will be decommissioned and 

allowed to revegetate. 

I find that the access management in the Selected Alternative provides the best balance between providing 

motorized access to the public while considering maintenance costs and protecting the forest resources. It 

is the minimum road system necessary to achieve the multiple use objectives of this alternative.

Other Environmental Effects 

The analysis documented in the FEIS disclosed the possible adverse effects of implementing the actions 

proposed under each alternative. These effects were mitigated or reduced through the use of Forest Plan 

standards and guidelines, including best management practices. Specific mitigation measures are listed on 

the unit cards and road cards in appendices 1 and 2, which are located on the Wrangell Island Project 

webpage (http://www.fs.usda.gov/project/?project=34831). These are also discussed in FEIS chapters 2 

and 3 and summarized in table 2 of the Wrangell Island Project FEIS.

I considered the direct, indirect, and cumulative environmental effects of the alternatives in making my 

decision. Alternative 5 creates the least overall environmental effects of the action alternatives because it 

proposes the least amount of timber harvest and road construction. However, I find that the Selected 

Alternative provides the best balance between providing an adequate supply of timber and minimizing the 

overall environmental effects from the timber harvest. The FEIS and project record display the effects, 

both positive and negative, resulting from the action alternatives.

While I reviewed all of the resource effects in addition to the key issues, the public raised some specific 

concerns, which I will address below. More information on these effects is summarized in the FEIS.

Yellow-cedar decline in Alaska: There is concern for yellow-cedar decline in Alaska and the 

regeneration and persistence of yellow-cedar in stands where it is present. There is a petition currently 

under review by the US Fish and Wildlife Service to list yellow-cedar under the Endangered Species Act. 

The scientific understanding of this species is still developing as additional research results become 

available. A recent article by T.M. Barrett and R.R. Pattison published by NRC Research Press September 

27, 2016 found that yellow-cedar may be increasing across its range, despite its decline in some parts of 

Southeast Alaska. I have examined the silvicultural prescriptions and determined that appropriate 

measures are provided by the Selected Alternative to ensure establishment of yellow-cedar in regenerated 

stands where appropriate. Recent research publications regarding yellow-cedar decline have been 

considered and are included in the project record. 

Aquatic effects: I considered the direct, indirect, and cumulative effects of the Selected Alternative 

combined with past harvest on the aquatics resources. While Alternative 5 has the least overall effect on 

fish habitat of the action alternatives, I find the Selected Alternative finds the best balance in meeting 

timber volume needs while also minimizing the effects to water quality and fish habitat from timber 
Wrangell Island Project

18

harvest. The project design and implementation of Forest Plan standards and guidelines, best management 

practices, and buffers will limit the effects to the watersheds and fisheries habitat. 

Soil stability: While Alternative 5 has the least potential adverse effect to the resource because it has the 

fewest acres harvested and the least amount of road construction, I find that the Selected Alternative 

provides the necessary soils protection while also providing the most timber volume toward meeting 

annual and planning cycle market demand. The effects to soils from the Selected Alternative will be 

minimized by the project design and the implementation of Forest Plan standards and guidelines and best 

management practices. All areas with slopes greater than 72 percent will have a site stability analysis 

prior to implementation, and unstable slopes will be avoided or addressed through geotechnical design to 

minimize adverse impacts to soil and water resources.

Plants: While the Selected Alternative has the most potential effect on plants due to the number of acres 

of potential disturbance from timber harvest and road construction, the effects are expected to be minor. 

There may be minor effects to one rare plant and five of the listed Alaska Region sensitive plants. The 

risk of adverse impacts to inundated clubmoss, a Region 10 rare plant, is low to moderate. 

The Biological Evaluation determination of effects is that Selected Alternative “May affect” individuals, 

but is not likely to result in a trend toward Federal listing or loss of viability for edible thistle, mountain 

lady’s slipper, Calder’s lovage, Alaska rein orchid, and lesser round-leaved orchid. Detailed information is 

in the Plant Biological Evaluation and summarized in the FEIS, chapter 3. The action alternatives avoid 

all known occurrences of the sensitive plant species. 

Measures described in the Unit Cards (appendix 1) will be implemented to reduce the possibility of 

invasive plant species that may compete with native species.

Climate change: Climate change is an important consideration, however, the magnitude of this project is 

so small compared to the factors that contribute to climate change that foreseeable effects would be 

immeasurably small for all alternatives and would not contribute to a meaningful choice among the 

alternatives. The Forest Plan FEIS discusses climate change factors and discloses the risk of possible 

effects. The Tongass National Forest will continue to monitor potential effects of climate change through 

the existing Forest Plan monitoring programs, and other studies that are occurring regionally and 

nationally. 

Recreation: While recreation occurs throughout the project area and recreation sites are interspersed in 

areas with timber harvest, the adverse effects to recreation are expected to be minor. Implementation of 

the Selected Alternative would not noticeably decrease or change the current recreational opportunities. 

Past timber harvest has provided access and views from recreation sites. The primary effects to recreation 

users will be effects to the scenery. Partial harvest of timber (removing 33 percent or less of a stand’s 

basal area), and unit design is being used along visual priority routes and recreation sites to minimize the 

effects on scenery and recreation. Recreational driving is one of the most popular activities on Wrangell 

Island. The Selected Alternative provides the most miles of road and motorized trail available for public 

use. 

Alaska Mental Health Trust Land Exchange: Congress enacted an exchange of lands between the 

Alaska Mental Health Trust and the USDA Forest Service. As a result, approximately 1,071 acres of land 

on Wrangell Island will become part of the National Forest. The legislation contains specific provisions 

that lands transferred to the Forest Service will be managed to preserve its undeveloped natural character, 

and provide for recreational opportunities. The exchange will have overall beneficial effects for the 

resources of Wrangell Island, when it is completed, in several years’ time. 
DRAFT Record of Decision

19

Public Comments

I want to thank the individuals, organizations and agencies that participated and provided comments for 

this analysis. I want to especially acknowledge the City and Borough of Wrangell, the Alaska Department 

of Natural Resources, and the U.S. Fish and Wildlife Service for their cooperative work in developing the 

alternatives and providing information for this project. 

I have carefully considered the comments. The input was valuable to me in identifying issues, creating 

alternatives for this project, and making a more-informed decision. I have reviewed the many public and 

agency comments we received during this analysis and the responses to those comments provided in the 

FEIS appendix B. 

In making my Decision, I considered the proposals made by commenters. Some of these were 

incorporated into the alternatives and others were considered but eliminated from further study. These are 

documented in chapter 2 of the FEIS. There are also some general categories of comments I want to 

address specifically. These are addressed in the paragraphs below. 

Timber economics was a concern of many commenters, and I share that concern. The timber market 

conditions fluctuate dramatically over time. The current market conditions are very poor and are driven 

by international markets. The Selected Alternative’s economic assessment indicates a negative advertised 

rate for the alternative as a whole. By law, the timber cannot be advertised for sale unless it appraises 

positively so the actual timber values of individual sales from this project will not be known until the 

sales are advertised and awarded to the highest successful bidder. However, it is important to have the 

timber from this project available to offer when the market conditions change. The timber industry in 

Southeast Alaska needs a reliable source of timber in order to survive and I am selecting the alternative 

that provides the greatest timber volume while minimizing the environmental impacts from the timber 

harvest. There were requests to drop environmental protections in order to improve timber economics but 

I feel those protection measures are effective and necessary.

The volume of timber being made available to industry was also a concern. I am selecting the alternative 

that provides the most timber volume because the timber will provide a greater timber supply to meet the 

needs of the timber industry and serves as “bridge” timber to facilitate the Tongass National Forest 

transition to young-growth harvest. That timber volume will also provide more benefit to the local and 

regional economies. The Selected Alternative will provide for the most jobs, which is especially important 

to those smaller communities where the timber industry is located. The State and Southeast region 

economy is currently in a downward trend and additional jobs are especially important. The January 2017 

Economic Trends report published by the Alaska Department of Labor and Workforce Development 

provides the most recent snapshot of economic conditions and employment forecasts in the State.

There were comments requesting access to firewood, a subsistence resource. To address the request, I will 

allow limited, short-term public access to gather firewood from along temporary roads once timber 

harvest activities are complete if there are no safety or resource concerns. These firewood gathering 

opportunities will be posted at the Wrangell Ranger District Office. All temporary roads will be 

decommissioned and allowed to revegetate after activities are complete.

There were many comments on effects to wildlife. I feel that the Selected Alternative design and 

protection measures will minimize the effects to wildlife from timber harvest. While some may consider 

the amount of harvest to be too large, the Selected Alternative affects only a small portion of Wrangell 

Island. The Selected Alternative will clearcut about 1 percent and will partially harvest about 3 percent of 

NFS lands on Wrangell Island. The partial harvest systems are designed to retain at least 67 percent of the 

stand’s basal area, in part to reduce negative effects to wildlife. Over 60 percent of the NFS lands on the 

island will remain undeveloped and will continue to provide wildlife habitat. These areas are protected by 

2001 inventoried roadless areas, old-growth reserves, T77 VCU 4790, beach fringe and riparian zones. 
Wrangell Island Project

20

Figure 4 displays the areas protected from development along with the limited area available for timber 

harvest.

To address the US Fish and Wildlife Service concerns of timber harvest in deep-snow winter habitat, the 

Forest Service will conduct a joint post-harvest assessment with the USFWS on the effects on deer in the 

harvest units containing deep-snow winter habitat.

There were comments on the effects of timber harvest and road building on the other forest resources. I 

find that the Selected Alternative will minimize the environmental effects through alternative design and 

the use of best management practices (BMPs), Forest Plan standards and guidelines, and standard 

operating procedures. 

There were many comments in support of and in opposition to public motorized access on the roads 

following timber harvest. I find that the Selected Alternative best meets the desires of the community of 

Wrangell by providing some public motorized access while closing other roads for environmental and 

economic reasons. Public road access is closely tied to subsistence use in the rural subsistence 

communities such as Wrangell. 

Many comments were on topics analyzed at the Forest Plan level, such as regional policies on export, 

regional market demand calculations, viability of wildlife species and interpretation of law which are 

considered outside the scope of this project analysis. These topics were analyzed in the 1997 Forest Plan 

revision and the 2008 and 2016 amendments to that revision. 

Consistency with the Forest Plan and other Applicable Laws and 

Regulations 

As the Responsible Official, it is my responsibility, prior to making a decision, to ensure that this project 

is consistent with the Tongass National Forest Land and Resource Management Plan (Forest Plan) and 

other applicable laws and regulations. The Forest Plan describes in detail Forest-wide management 

direction, goals, objectives, research needs, desired conditions, standards, and guidelines. 

I have determined that the Selected Alternative is consistent with the Forest Plan and other applicable 

laws and regulations. The Selected Alternative will meet Forest Plan standards and guidelines, and will 

contribute toward reaching Forest Plan goals and objectives. The Selected Alternative is consistent with 

all land use designation standards and guidelines. I also find that my decision to implement the Selected 

Alternative is consistent with all applicable laws and regulations including National Forest Management 

Act (NFMA), National Environmental Policy Act (NEPA), Alaska National Interest Lands Conservation 

Act (ANILCA), Endangered Species Act (ESA), and the other laws presented in the section “Findings 

Required by Other Laws and Regulations” in this ROD. 

My decision is consistent with Forest Service policy outlined in agency directives. By providing timber 

for offer and supporting jobs, the Selected Alternative also contributes to the USDA Investment Strategy 

for Creating Jobs and Healthy Communities in Southeast Alaska.

Summary of the Rationale

In making this decision I considered how the alternatives responded to the Purpose and Need, key issues, 

environmental effects, public comments, Forest Plan and applicable laws, regulations, and policy. 

I found that the Selected Alternative provides the best mix of beneficial resources for the public, within a 

framework of existing laws, regulations, policies, public needs and desires, and the capabilities of the 

land. None of the alternatives can provide benefits for and meet the needs of all members of the public. 

My decision includes the evaluation of the trade-offs between effects to resources, desired products, and 

social values.
DRAFT Record of Decision

21

The Selected Alternative best meets the stated Purpose and Need for the project. It makes approximately 

56 MMBF of timber available to the timber industry while minimizing effects to the environment. 

It also best addresses the key issues as a whole by providing a supply of timber, maintaining old-growth 

forest habitat, preserving scenic quality, and providing and maintaining public access to the National 

Forest System lands on Wrangell Island. 

The Selected Alternative will meet the Forest Plan direction and conforms to the National Forest 

Management Act. The direct, indirect, and cumulative environmental effects from project activities are 

consistent with the goals, objectives, and standards and guidelines in the Forest Plan. I have found that the 

design features and mitigation measures in Appendix 1 – Wrangell Island Project Unit Cards, and design 

criteria in Appendix 2 – Wrangell Island Project Road Cards, are effective in reducing environmental 

impacts based upon the Forest Plan analysis and experience in using these measures. 

Alternatives

Alternatives Considered in Detail 

The Forest Service designed five alternatives for detailed analysis as part of the Wrangell Island Project. 

These include the no action alternative, the proposed action, and three alternatives developed in response 

to key issues to provide a reasonable range of alternatives. With the exception of Alternative 1, all were 

designed to achieve the Purpose and Need for the Wrangell Island Project. All five alternatives are 

described in detail in chapter 2 of the FEIS.

Alternative 1

Alternative 1, the no action alternative, proposed no new timber harvest or road construction in the project 

area. It does not preclude timber harvest from other areas or from the project area in the future. This 

alternative represents the existing conditions and serves as a baseline for comparing the action 

alternatives. 

Road access management would fully implement the 2007 Wrangell Ranger District Access and Travel 

Management Plan decision (ATM) for Wrangell Island. The ATM deferred closure of some roads until the 

Wrangell Island Project EIS is complete. Under Alternative 1, approximately 23.5 miles of NFS road 

currently open to motorized use would be closed, and 2.5 miles of existing NFS road would be 

decommissioned. Approximately 73.7 miles of existing NFS road would be open for public use for 

motorized vehicles of all types.

Alternative 2 

Alternative 2, the proposed action, is the Selected Alternative. See page 7 (“Features of the Selected 

Alternative”) for discussion related to this alternative. 

Alternative 3 

Alternative 3 was designed to harvest timber in Timber Production and Modified Landscape LUDs while 

maintaining scenic quality, old-growth habitat and habitat connectivity as specified in the Forest Plan. 

Alternative 3 is designed to address Issues 2 (Wildlife Habitat), 3 (Scenic Quality) and 4 (Access 

Management). Alternative 3 would yield an estimated 41 MMBF from approximately 2,648 acres. 

Alternative 3 would construct 15.4 miles of new NFS roads, 8.9 miles of temporary roads and the 

reconditioning of 4.4 miles of existing NFS roads. Alternative 3 would implement road management 

objectives which define public motorized access, by closing 16.4 miles of road to public motorized use 

and decommissioning 0.2 mile of road. Approximately 85.4 miles of NFS road would be open for public 

motorized access of all types and 13.2 miles would be open to off-highway vehicles (motorized trail). 
Wrangell Island Project

22

Alternative 4 

Alternative 4 was designed to harvest timber in Timber Production and Modified Landscape LUDs. The 

alternative was designed to maximize the economic value of the timber harvest from which to offer 

individual timber sales (Issue 1) while protecting scenic quality, old-growth habitat and connectivity. 

Alternative 4 would yield an estimated 43 MMBF from approximately 2,992 acres. Alternative 4 would 

construct 15.9 miles of new NFS roads, 10.3 miles of temporary roads and the reconditioning of 4.0 miles 

of existing NFS roads. Alternative 4 would implement road management objectives which define public 

motorized access, by closing 16.8 miles of road to public motorized use and decommissioning 0.2 mile of 

road. Approximately 85.7 miles of NFS road would be open for public motorized access of all types and

12.9 miles would be open to off-highway vehicles (motorized trail). 

Alternative 5 

Alternative 5 was designed to harvest timber in the Timber Production and Modified Landscape LUDs. 

The alternative emphasized Issue 2 (Wildlife Habitat) while providing timber harvest. Alternative 5 would 

yield an estimated volume of 39 MMBF from approximately 3,440 acres. Alternative 5 would construct 

12.7 miles of new NFS roads, 6.6 miles of temporary roads and the reconditioning of 2.9 miles of existing 

NFS roads. Alternative 5 would implement road management objectives which define public motorized 

access. Alternative 5 would fully implement the ATM and close all newly constructed roads. 

Approximately 37.0 miles of road (existing and proposed) would be closed and 2.5 miles of existing road 

would be decommissioned. Approximately 72.9 miles of existing NFS road would be available for public 

use for motorized vehicles of all types and no road would be open to off-highway vehicles (motorized 

trail).Comparison of Alternatives

Table 2 compares outputs and provides a summary of the effects of implementing each alternative for all 

resources.

Table 2. Alternative comparison table

Measure or Question Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Basic Project Data

Timber Harvest (acres) 0 4,767 2,648 2,992 3,440

Volume of Harvest (MMBF) 0 56 41 43 39

Road construction (total 

miles of NFS and 

temporary road 

construction)

0 31.1 28.7 30.2 22.2

ISSUE 1: TIMBER 

SUPPLY AND 

ECONOMICS

Timber Volume 

Millions of 

Board Feet 

(MMBF)

Sawtimber 0 51 36 38 35

Utility 0 4.9 4.6 4.8 4.4

Total Net Volume 0 55.8 40.7 43.3 39.1

Logging System (Acres)

Cable 0 998 969 1,010 576

Shovel 0 528 411 543 343

Helicopter 0 3,241 1,268 1,439 2,521

Total Harvest Acres 0 4,767 2,648 2,992 3,440
DRAFT Record of Decision

23

Measure or Question Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Timber Volume by 

Species 

Millions of 

Board Feet 

(MMBF)

Sitka spruce 0 11.2 8.0 8.5 7.6

Hemlock 0 26.5 18.8 20.0 18.0

Western redcedar 0 4.1 2.9 3.1 2.8

Yellow-cedar 0 9.2 6.5 6.9 6.2

Financial Efficiency 

Analysis 

(Current 

Region 10 

Export 

Policy)

Indicated Advertised Rate 

($/thousand board feet 

(MBF) net removed)

$0.00 ($59.23) ($55.00) ($61.54) ($92.74) 

Road Construction and 

Reconditioning Costs 

($/MBF net removed)

$0.00 $81.60 $96.80 $98.20 $85.40

Logging Costs ($/MBF net 

removed) $0.00 $325.55 $298.66 $303.96 $352.30

Financial Efficiency 

Analysis

(Domestic 

Processing)

Indicated Advertised Rate 

($/MBF net removed)

$0.00 ($220.64) ($216.41) ($222.95) ($254.15) 

Road Construction and 

Reconditioning Costs 

($/MBF net removed)

$0.00

$81.60 $96.80 $98.20 $85.40

Logging Costs ($/MBF net 

removed)

$0.00 $325.55 $298.66 $303.96 $352.30

Employment 

Number of 

Annualized 

Jobs 

Supported

Total Jobs Estimated 

under Current Region 10 

Policy (includes export and 

domestic processing)

0 222 158 168 151

100% Domestic Processing 0 267 190 202 182
Wrangell Island Project

24

Measure or Question Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

ISSUE 2: WILDLIFE 

HABITAT 

Cumulative Change to 

Deer Habitat on All Land 

Ownerships

Percent 

Change 

From 

Historical 

Acres

Historical Deep Snow 

Winter Habitat (highproductivity old growth 

(POG) ≤800’ elevation on 

south-facing aspects)

-33% -34% -34% -34% -33%

Historical Average Winter 

Habitat (POG ≤1,500’ 

elevation)

-18% -25% -22 -22% -23%

Historical Non-winter 

Habitat (all habitats except 

older young growth)

-4% -5% -5% -5% -5%

Cumulative Change in 

Deer Model Habitat 

Capability (DHC) on All 

Land Ownerships

Percent 

Change in 

DHC Since 

1954 

(at stem 

exclusion)

1954 Theoretical Number of 

Deer -17% -22% -20% -21% -21% 

Effects on Wolves on All 

Land Ownerships

Deer Density 

Compared to 

Historical 

Deer Density 

(deer/mi2 at 

stem 

exclusion)

Deer Model Deer Density – 

1954 10.6 10.0 10.3 10.2 10.2

Road Density below 

1,200’ for all roads (open 

and closed)

Road

Density

(mi/mi2) 

Road Density 1.1 1.3 1.2 1.3 1.2

Cumulative Change to 

Bear Habitat on All Land 

Ownerships

Percent 

Change 

From 

Historical 

Habitat

Historical POG within 500’ 

of Class I fish streams -17% -19% -18% -18% -18%
DRAFT Record of Decision

25

Measure or Question Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Cumulative Change to 

American Marten Habitat 

on All Land Ownerships

Percent 

Change 

From 

Historical 

Habitat

Historical Winter Habitat – 

High-volume POG < 1500’ 

in elevation

-34% -40% -38% -38% -39%

Historical Year-round 

Habitat – POG -15% -21% -18% -19% -19%

Cumulative Change to 

Goshawk Habitat on All 

Land Ownerships

Percent

Change 

From 

Historical 

Habitat

Historical Nesting Habitat 

by WAA – High-Volume 

POG 

-32% -39% -36% -36% -37%

Historical Foraging Habitat 

by WAA – All POG -15% -21% -18% -19% -19%

Cumulative Changes to 

High-Volume POG and all 

POG Habitat on All Land 

Ownerships

Percent 

Change 

From 

Historical 

Habitat

High-volume POG -32% -39% -36% -36% -37%

All POG -15% -21% -18% -19% -19%

ISSUE 3: SCENIC 

QUALITY

Scenic integrity objectives 

met? yes yes yes yes yes

Relative impact on scenery 

as a result of proposed 

timber harvest (lowest=1 to 

highest=5)

1 5 4 3 2 

Relative impact on scenery 

as a result of proposed 

road construction (lowest=1 

to highest=5)

1 4 3 5 2 

ISSUE 4: ACCESS 

MANAGEMENT

Proposed NFS road 

construction (miles) 0 16.8 15.4 15.9 12.7

Proposed temporary road 

construction (miles) 0 9.9 8.9 10.3 6.6

Proposed road 

reconditioning (miles) 0 4.4 4.4 4.0 2.9

Estimated total road costs 

(in millions of dollars) $0 $4.5 $3.9 $4.2 $3.3
Wrangell Island Project

26

Measure or Question Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Road designations, 

following implementation 

(total, island-wide)

Open to all vehicles (miles) 73.7 86.0 85.4 85.7 72.9

Motorized trails (miles) 0 14.5 13.2 12.9 0 

Closed to all vehicles 

(miles) 23.5 15.9 16.4 16.8 37.0

Decommissioned (miles) 2.5 0.2 0.2 0.2 2.5

AIR QUALITY AND 

CLIMATE CHANGE

Contribute to the effects of 

or current rate of climate 

change, including carbon 

sequestration?

not likely slight 

increase

slight 

increase

slight 

increase

slight 

increase

Contribute to Yellow-cedar 

decline? not likely not likely not likely not likely not likely

Contribute to greenhouse 

gas emissions? no yes yes yes yes

AQUATICS

NFS road stream 

crossings 

Class I 0 2 2 1 1 

Class II 0 8 5 6 3 

Class III 0 29 25 21 21

Temporary road stream 

crossings

Class I 0 0 0 0 0 

Class II 0 2 1 1 1 

Class III 0 11 7 4 8 

CULTURAL RESOURCES

Impacts to cultural 

resources? no no no no no

ENVIRONMENTAL 

JUSTICE

Disproportionately high or 

adverse impact on lowincome or minority 

populations who use the 

project area?

no no no no no

INVENTORIED 

ROADLESS AREAS

Impact on inventoried 

roadless areas? no no no no no

I I I I I 
DRAFT Record of Decision

27

Measure or Question Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

PLANTS: SENSITIVE AND 

RARE

Sensitive plants: lung lichen 

and Henderson’s 

checkermallow

No risk of 

adverse 

impact

No risk of 

adverse 

impact

No risk of 

adverse 

impact

No risk of 

adverse 

impact

No risk of 

adverse 

impact

Sensitive plants: Alaska 

rein orchid, Calder’s lovage, 

edible thistle, mountain 

lady’s slipper

No risk of 

adverse 

impact

Minor risk of 

adverse 

impact

Minor risk of 

adverse 

impact

Minor risk of 

adverse 

impact

Minor risk of 

adverse 

impact

Sensitive Plant: lesser 

round-leaved orchid

No risk of 

adverse 

impact

Minor to 

moderate risk 

of adverse 

impact

Minor to 

moderate risk 

of adverse 

impact

Minor to 

moderate risk 

of adverse 

impact

Minor to 

moderate risk 

of adverse 

impact

PLANTS: INVASIVE

Risk of introduction and 

spread of invasive species Low Moderate Moderate Moderate Low

RECREATION

Relative ranking of impacts 

to inventoried recreation 

sites on Wrangell Island, 

not including roads (1 = 

least impact, 5 = most

impact)

1 5 3 4 2 

SILVICULTURE

Silvicultural system and 

harvest method 

Even-aged management - 

clearcut 

Cable/Shovel 0 1,340 1,269 1,352 737

Clearcut with reserves

Cable/Shovel 0 68 68 68 68

Helicopter 0 0 0 0 0 

Uneven-aged 

management – single-tree 

selection (up to 33% 

removal)

Shovel 0 118 43 133 114

Helicopter 0 3,241 1,268 1,439 2,521

Total Acres Harvested 0 4,767 2,648 2,992 3,440

SOILS

Estimated acres of 

detrimental soil 

disturbance

 

Yarding 0 70 65 75 45

Temporary Roads 0 54 48 56 36

Landings 0 19 17 18 13

Rockpit 0 27 24 26 19

Total acres 0 170 154 175 113
Wrangell Island Project

28

Measure or Question Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Estimated harvest acres 

and road miles on steep 

slopes

Acres of harvest proposed 

on slopes > 72% (all 

harvest methods)

0 199 132 153 177

Miles of proposed road on 

slopes > 67% 0 0.5 0.5 0.5 0.3

WETLANDS

Acres of wetlands 

impacted by activity 

Harvest (acres) 0 1,554 871 927 1,082

Rock quarry (acres) 0 11 10 11 8 

Road construction (acres) 0 55 50 56 39

Alternatives Considered but Eliminated from Detailed Analysis

Ten alternatives were considered but eliminated from detailed analysis throughout the planning process. 

These are presented in the FEIS chapter 2, under “Alternatives Considered but Eliminated from Detailed 

Study”. 

Environmentally Preferred Alternative

The Council on Environmental Quality defines the environmentally preferred alternative as “the 

alternative that will promote the national environmental policy as expressed in NEPA's Section 101”. 

Ordinarily, this means the alternative that causes the least damage to the biological and physical 

environment; it also means the alternative which best protects, preserves, and enhances historic, cultural, 

and natural resources. 40 CFR 1505.2(b) requires that one or more environmentally preferable 

alternatives be disclosed. The environmentally preferable alternative is not necessarily the alternative that 

will be implemented, and it does not have to meet the underlying need for the project. It does, however, 

have to cause the least damage to the biological and physical environment and best protect, preserve, and 

enhance historical, cultural, and natural resources. 

I have reviewed the direct, indirect, and cumulative effects of each alternative. 

I have determined that Alternative 1, the no-action alternative, is the environmentally preferable 

alternative. This alternative is environmentally preferable because it would result in no environmental 

effects and thereby best protects, preserves, and enhances historical, cultural, and natural resources on the 

National Forest. Alternative 1 does not meet the purpose and need, but it does provide me with a baseline 

to measure the direct and indirect effects of the action alternatives.

Of the action alternatives, I have identified Alternative 5 as the environmentally preferred alternative 

because it describes the fewest acres of timber harvest, requires the fewest miles of road construction, and 

as a result, would cause the fewest environmental impacts. 

Public Involvement

The Wrangell Island Project included an extensive public involvement process, as documented in the 

FEIS chapter 1 and in the project record. I want to thank the individuals, organizations and agencies that 

participated and provided comments that helped to shape this analysis. The public and agency comments 

received during scoping helped me to define the key issues, which in turn helped to develop the 
DRAFT Record of Decision

29

alternatives. Public comments on the draft EIS were addressed in the final EIS and responses to those 

comments are presented FEIS appendix B. 

Mitigation

My decision includes the project design criteria and measures to minimize adverse environmental effects 

of the Selected Alternative as described in the unit and road cards, located on the Wrangell Island Project 

webpage (http://www.fs.usda.gov/project/?project=34831). I am satisfied that these are practicable and 

effective in avoiding or minimizing environmental effects. I have found them to be effective when 

implemented elsewhere on the Forest. 

Monitoring

Monitoring is a tool which involves observing the results of management activities as a basis for 

evaluation. The NFMA requires national forests to monitor and evaluate their Forest Plans (36 CFR 

219.12). Monitoring of the Selected Alternative will be performed during implementation and as part of 

the Forest Plan monitoring program as shown on the Tongass public website. Specific monitoring items 

are outlined in chapter 2 of the Wrangell Island Project FEIS and are included in the unit and road cards, 

located on the Wrangell Island Project webpage. 

Project Record 

The project record for this project includes the DEIS and FEIS, reports containing analyses by resource 

with supporting documentation, public communication and comments, all material incorporated by 

reference (except those documents readily available, such as the Forest Plan and Forest Service 

directives) and other materials produced during the environmental analysis of this project. The project 

record is available electronically upon request from the Wrangell Ranger District.

2016 Forest Plan 

The Selected Alternative is consistent with the 2016 Tongass National Forest Land and Resource 

Management Plan (2016 Forest Plan) which was signed on December 9, 2016. 

The 2008 Forest Plan was developed under a prior planning regulation (1982 Planning Rule) and was 

amended by the 2016 Forest Plan pursuant to the 2012 Planning Rule (36 CFR 219). Project consistency 

requirements depend upon the origin of plan direction applicable to the project. Project consistency for 

plan direction which was developed under the previous planning rule requires that the project be 

consistent only with plan standards and guidelines (chapters 3 and 4 of the 2016 Forest Plan, and FSH 

1909.12, ch. 20, sec. 21.33). Project consistency requirements for plan components added or modified in 

conformance with the 2012 Planning Rule (chapter 5 of the 2016 Forest Plan) are governed by 36 CFR 

219.15(d). 

The Wrangell Island Project includes design features intended to avoid or minimize environmental 

impacts and must be complied with by law, regulation, or policy. These design features include, but are 

not limited to BMPs, Forest Plan standards and guidelines, and standard operating procedures. The 

Selected Alternative is compliant with all applicable LUD-specific and forest-wide standards and 

guidelines in chapters 3 and 4 of the 2016 Forest Plan. 

The Selected Alternative also complies with the applicable forest-wide plan components in chapter 5 of 

the 2016 Forest Plan (see table 3). 
Wrangell Island Project

30

Table 3. Compliance of the Selected Alternative with applicable forest-wide plan components found in 

chapter 5 of the 2016 Forest Plan Amendment

Plan Component Selected Alternative 

DC-01. The Desired Condition of the Tongass National 

Forest is characterized by extensive, unmodified 

natural environments. Old-growth forests are one of 

the predominant vegetation types on the Tongass and 

connections between patches of old growth are 

evident. 

Ninety-two percent of the old growth on the Tongass 

National Forest is still in an unmodified condition. The 

Selected Alternative will modify approximately 4,767 

acres of old growth by timber harvest. Over 70 percent 

of National Forest old growth will remain in a natural 

state on Wrangell Island after the Selected Alternative 

is implemented. See Error! Reference source not 

found.. 

O-TIM-01. Seeking to accelerate a transition to 

primarily young-growth harvest, offer an average of 46 

MMBF annually in a combination of old growth and 

young growth. When young growth offered is less than 

41 MMBF, provide old growth to make up the 

difference and achieve the average annual projected 

timber sale quantity of 46 MMBF. After the transition, 

offer an average of 5 MMBF of old growth annually to 

support Southeast Alaska mills.

The Selected Alternative makes available up to 56 

MMBF of old-growth timber in multiple sales, which 

contributes to the Tongass timber program’s average 

annual projected timber sale quantity of 46 MMBF. No 

commercial young growth timber is currently available 

within the project area.

O-TIM-02. Seek to provide an economic timber supply 

sufficient to meet the annual market demand for 

Tongass National Forest timber, and the market 

demand for the planning cycle. The volume of young 

growth as part of the yearly offer will increase from an 

average of 9.2 MMBF annually in the first decade to an 

average of 25 MMBF annually in years 11-15 as the 

program nears full transition.

The Selected Alternative seeks to provide an 

economic timber supply sufficient to meet the annual 

market demand for Tongass National Forest timber, 

and the market demand for the planning cycle.

S-TIM-01. Not including salvage or sanitation harvest, 

the quantity of timber sold in a decade may not exceed 

the sustained yield limit of 2,480 MMBF.

The Selected Alternative contributes to the Sustained 

Yield Limit by providing approximately 56 MMBF of 

timber.

G-WILD-02. The National Bald Eagle Management 

Guidelines (USFWS 2007, or current) should be used 

when working or authorizing activities near eagle 

nests.

The Selected Alternative follows the latest National 

Bald Eagle Management Guidelines. All known bald 

eagle nest sites within the project area fall within the 

established 1,000-foot beach fringe buffer; therefore, 

the Forest Plan guideline for bald eagles is being met.

S-WILD-03. The intent of this standard is to use the 

Chapter 4 Forest Plan direction for seabird colonies to 

address the addition of the Aleutian tern as an Alaska 

Region sensitive species.

The Selected Alternative provides for the protection 

and maintenance of seabird (marine bird) colonies. 

Sensitive species such as the Aleutian tern are not 

found within the analysis area. Timber harvest is not 

planned within the beach fringe buffer; therefore, 

seabird colonies are protected which meets Forest 

Plan standards and guidelines.

S-WILD-04. Provide a minimum distance of 330 feet 

from human activities on the ground and waterfowl or 

shorebird intertidal concentration or nesting areas.

The Selected Alternative maintains a minimum 330-

foot distance from waterfowl or shorebird intertidal 

concentrations or nesting areas. Timber harvest is not 

planned within the beach fringe buffer and MAFs are 

not located near shorebird nesting areas; therefore, 

the black oystercatcher is protected, and Forest Plan

standards and guidelines are met. 

Former Management Indicator Species: The Wrangell Island Project analyzed the 13 management 

indicator species (MIS) from the 2008 Forest Plan, which was in effect at the time analysis was started. 

The 2016 Forest Plan used the 2012 Planning Rule to amend the 2008 Forest Plan. Although the 2012 

Planning Rule does not require the use of MIS to analyze project effects, the 2016 Forest Plan 

Amendment FEIS included these same 13 species in its effects analysis under the heading of “Former 

Management Indicator Species” (Forest Plan FEIS, page 3-230). The Wrangell Island Project 
DRAFT Record of Decision

31

interdisciplinary team has reviewed the new references used in the 2016 Forest Plan FEIS for 

applicability to the Wrangell Island project activities, and updated the effects analysis as needed. 

Therefore, Wrangell Island Project analysis for wildlife is consistent with the best available science used 

in the 2016 Forest Plan. 

Suitability of Lands for Timber Production: The Selected Alternative complies with direction in 

appendix A of the 2016 Forest Plan. In the Development land use designations (LUDs), old-growth forest 

located within Phases 2 and 3 of the Tongass Timber Sale Program Adaptive Management Strategy, or 

within the Tongass 77 Watersheds (T77 VCUs) and The Nature Conservancy / Audubon conservation 

priority areas are identified as not suitable for old-growth harvest. Under the Selected Alternative, there 

will be no timber harvest in the T77 VCU 4790 (Thoms Lake), which is no longer suitable for old-growth 

harvest.

Findings Required by Law and Regulation

Alaska National Interest Lands Conservation Act (ANILCA) of 1980; 

Section 810

Subsistence Evaluation: The subsistence analysis is presented in chapter 3 of the FEIS. Based on the 

information in the FEIS, effects within the foreseeable future from this project alone would not result in a 

significant possibility of a significant restriction on any subsistence resources. However, cumulatively 

under full implementation of the Forest Plan itself including this project, 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. Because there was a finding of a 

significant possibility of a significant restriction to subsistence use of deer, two subsistence hearings were 

held in Wrangell.

Finding: In accordance with Alaska National Interest Lands Conservation Act (ANILCA) Section 810, I 

have made a determination for the subsistence evaluation that the direct effects of the Selected Alternative 

will not result in a risk of a significant restriction on the subsistence use of any resources, including deer 

(FEIS, chapter 3 in the “Subsistence” section). Cumulatively, since additional timber harvest may occur at 

some future time in the development LUDs in WAA 1903, there may be a significant possibility of a 

significant restriction on subsistence use of deer in WAA 1903 in the future due to additional reductions in 

habitat capability. This is consistent with the Forest Plan finding that full implementation of the Plan 

could lead to a significant possibility of a significant restriction on subsistence use of deer. The potential 

foreseeable effects, directly and cumulatively, from the Selected Alternative will not have a significant 

possibility of a significant restriction on subsistence uses for other resources including bears, furbearers, 

marine mammals, waterfowl, salmon, other finfish, shellfish, and other foods such as berries and roots. 

The evaluation determined that this project has complied with ANILCA by considering the following 

three considerations.

Necessary and Consistent with Sound Management of Public Lands

I have determined that the Selected Alternative is necessary and consistent with sound management of 

public lands. In this regard, I have evaluated this project against the National Forest Management Act, the 

Alaska National Interest Lands Conservation Act, the Tongass Timber Reform Act, the Wilderness Act, 

the Tongass Land and Resource Management Plan, and the Alaska State Forest Resources and Practices 

Act. Based on the analysis presented in the Wrangell Island Project Final EIS, the findings I have made in 

this ROD and the analysis for the Forest Plan, I have determined that the Selected Alternative strikes a 

balance between meeting the resource needs of the public and protecting the forest resources.
Wrangell Island Project

32

Amount of Public Land Necessary to Accomplish the Proposed Action 

I have determined that the amount of land necessary to implement the Selected Alternative is, considering 

sound multiple-use management of public lands, the minimum necessary to accomplish the purpose of 

this project. 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, and attempting to 

reduce effects in some areas can mean increasing the effects in other areas. The Forest-wide standards and 

guidelines and LUD prescriptions provide for management or limit activities in many of the area’s most 

important for subsistence uses, such as beaches and estuaries, and areas with high fish and wildlife habitat 

values.

Reasonable Steps to Minimize Adverse Impacts to Subsistence Uses and Resources 

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. I have determined that fish and wildlife habitat productivity will be 

maintained at the highest level possible for the Selected Alternative, consistent with the overall multipleuse goals and improved protection of the Forest Plan. 

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

I have determined that the Selected Alternative complies with the most recent information for the 

protection of bald eagle protection requirements in 50 CFR Part 22. 

Clean Air Act of 1970 (as amended)

I have determined that emissions from the implementation of the Selected Alternative will be of short 

duration and are not expected to exceed State of Alaska ambient air quality standards (18 AAC 50). 

Clean Water Act (1977, as amended)

I have determined that the project activities meet all applicable State of Alaska Water Quality Standards. 

Section 313 of the Clean Water Act and Executive Order 12088 of January 23, 1987 addresses Federal 

agency compliance and consistency with water pollution control mandates. Agencies must be consistent 

with requirements that apply to “any governmental entity” or private person.

Compliance is to be in line with “all Federal, State, interstate, and local requirements, administrative 

authority, and process and sanctions respecting the control and abatement of water pollution.” 

Clean Water Act Sections 208 and 319 address nonpoint source pollution caused by activities such as 

timber harvest. Soil and water conservation practices are recognized by EPA as the primary control 

mechanisms for nonpoint source pollution on National Forest System lands. The site-specific application 

of best management practices (BMPs), with a monitoring and feedback mechanism, is the approved 

strategy for controlling nonpoint source pollution as defined by Alaska’s Nonpoint Source Pollution 

Control Strategy (ADEC 2007). In 1997, the State of Alaska approved the BMPs in the Forest Service’s 

Soil and Water Conservation Handbook (USFS 2006) as consistent with the Alaska Forest Resources and 

Practices Regulations. The BMPs are incorporated into the Tongass Land Management Plan. My finding 

is based in part on the fact that annual Tongass National Forest BMP monitoring results consistently 

report a high success rate at applying BMPs (USFS 2005-2012). 

A discharge of dredge or fill material from normal silvicultural activities such as harvesting for the 

production of forest products is exempt from Section 404 permitting requirements in waters or the United 

States, including wetlands (404(f)(1)(A)). Forest roads, as defined by US Army Corps of Engineers 

guidance, are exempt from Clean Water Act Section 404 permitting if they are constructed and maintained 

in accordance with State-approved BMPs and the 15 Federal baseline provisions to assure that flow and 
DRAFT Record of Decision

33

circulation patterns and chemical and biological characteristics of the waters are not impaired 

(404(f)(1)(E)). The baseline provisions are incorporated into the Alaska Region Soil and Water 

Conservation Handbook under BMP 12.5. I have determined that all roads approved in this project are 

exempt from Section 404 permitting requirements in waters of the United States, including wetlands 

(404(f)(1)(A)).

The Wrangell Island Project will implement both the National BMPs and Alaska Region BMPs.

Endangered Species Act of 1973 (as amended) 

A biological assessment for this project was prepared for the threatened and endangered fish species and 

humpback whale. I concur with the finding of “No effect” for the threatened and endangered fish species 

and “May affect, but is not likely to adversely affect” for the humpback whale (Mexico DPS). The 

biological assessment was sent to the National Marine Fisheries Service as part of the Section 7 

consultation under the Endangered Species Act. 

Federal Cave Resource Protection Act of 1988

I have determined that the activities of the Selected Alternative will not have a direct, indirect, or 

cumulative effect on any significant cave (karst) resource in the Wrangell Island Project area, since these 

features do not exist in the project area. 

National Forest Transportation System Final Administrative Policy 

and Final Rule

The FEIS and this ROD are prepared to be consistent with the National Forest System Transportation 

Final Administrative Policy and Final Rule (2001), as well as the Tongass National Forest Level Road 

Analysis (2003), the 2005 Travel Management Rule (36 CFR 212). I have determined the proposed road 

system in the Selected Alternative is the minimum road system needed for safe and efficient travel and for 

administration, utilization, and protection of National Forest System lands (36 CFR 212.5). 

Magnuson-Stevens Fishery Conservation and Management Act

The Magnuson-Stevens Fisheries Conservation Act requires the Forest Service to consult with the 

National Marine Fisheries Service on projects that may affect essential fish habitat (EFH). The potential 

effects of the project on EFH are discussed in chapter 3 of the FEIS. Chapter 3 also includes a description 

of the EFH in the project area, a description of the proposed activities, and a description of the measures 

that will protect these essential habitats. I have reviewed the potential effects of the project on EFH 

discussed in the FEIS chapter 3 and have determined that this project may adversely affect EFH because 

of the effects of timber harvest activities, road construction, and log transfer activities at the log transfer 

facilities but these effects will be minimized through the use of Forest Plan requirements, BMPs, and 

design measures. 

National Marine Fisheries Service was formally consulted on the project. Information on applicable 

BMPs, standards and guidelines, and design measures and criteria to minimize effects to EFH are 

presented in appendices 1 and 2 of this draft ROD, and in chapter 3 of the FEIS. 

Marine Mammal Protection Act of 1972 

Actions authorized in the Selected Alternative will not have a direct, indirect, or cumulative effect on 

marine mammals. All marine wildlife guidelines, including special prohibitions on approaching 

humpback whales in Alaska as defined in 50 CFR 216 will be followed during project implementation. 

These marine mammal viewing guidelines are administered by the National Marine Fisheries Service and 

enforced by the Coast Guard, and are deemed sufficient for their protection.
Wrangell Island Project

34

A biological assessment for this project was prepared for the humpback whale. I concur with the finding 

of “May affect, but is not likely to adversely affect” for the humpback whale (Mexico DPS). The 

biological assessment was sent to the National Marine Fisheries Service as part of the Section 7 

consultation under the Endangered Species Act. 

National Forest Management Act of 1976 (as amended)

The National Forest Management Act requires several specific determinations in the Record of Decision. 

These are consistency with the governing Forest Plan, a determination of clearcutting as the optimal 

method of harvesting, if used, and specific authorizations to create openings over 100 acres in size. 

Tongass Land and Resource Management Plan (as amended)

Based on the discussion that follows, as well as that of the 2016 Forest Plan, I have determined that this 

decision is consistent with the Forest Plan as amended.

Clearcutting as the Optimal Method of Harvesting

Based on the information presented in the FEIS and Forest Plan direction, I have determined that 

clearcutting is the optimal method of harvesting where it is applied. Site-specific information and 

rationale where clearcutting is optimal is presented in the silvicultural prescriptions. Clearcutting (an 

even-aged method) has been prescribed in this project to preclude or minimize the occurrence of 

potentially adverse impacts from windthrow where the potential is moderate to high, to remove or reduce 

mistletoe infestations, and to reduce wounding due to logging damage to adjacent trees. 

Harvest Openings Over 100 Acres in Size

I have determined that there will be no created openings in excess of 100 acres with the harvest of the 

Selected Alternative units.

National Historic Preservation Act (NHPA) of 1966 (as amended) 

The NHPA requires the agency to consider the effects of its actions on historic properties that are eligible 

or listed on the National Register of Historic Places, and to consult with the State Historic Preservation 

Officer, Indian tribes, and interested stakeholders.

Under the provisions of Section 106 of the National Historic Preservation Act, I have made a finding of 

“No Historic Properties Affected”, with a concurrence of opinion by the Alaska State Historic 

Preservation Officer. There will be no effects to known sites listed in or eligible for listing in the National 

Register of Historic Places.

Cultural resource surveys were conducted in the analysis area in accordance with the inventory strategy 

procedures in the Third Programmatic Agreement between the Forest Service, Alaska State Historic 

Preservation Officer, and the Advisory Council on Historic Preservation. 

The State Historic Preservation Officer was consulted, following Standard procedures, in accordance with 

36 CFR Part 800, Subpart B for the evaluation of National Register eligibility and for assessment of 

effects on historic properties.

Local Indian tribes have been contacted during this process, and government-to-government consultations 

have been completed for the purposes of fulfilling Section 106 obligations. 

While no known historic properties will be affected, unanticipated discoveries of cultural resources 

requires immediate cessation of activities nearby, protection of the site, and notification of the State 

Historic Preservation Officer as soon as practicable but not later than 48 hours in accordance with 36 CFR 

800.13. In the case of the inadvertent discovery of human remains, the State of Alaska and local Indian 

tribes are immediately notified in accordance with State laws, and the Native American Graves Protection 

Act (NAGPRA).
DRAFT Record of Decision

35

Tongass Timber Reform Act (TTRA) of 1990

I have determined this project is in compliance of the relevant provisions of TTRA. Any timber harvested 

under the Selected Alternative will provide part of the timber supply to the Tongass National Forest’s 

timber program as stated in Section 101 of TTRA “... the Secretary shall, to the extent consistent with 

providing for the multiple use and sustained yield of all renewable forest resources, seek to provide a 

supply of timber from the Tongass National Forest which (1) meets the annual market demand for timber 

from such forest and (2) meets the annual market demand from such forest for each planning cycle.” 

No commercial timber harvest will occur within 100 feet of any Class I stream or any Class II stream 

flowing directly into a Class I stream, as required in Section 103 of the TTRA. 

Applicable Executive Orders 

Executive Order 11988 (Floodplains)

Per Executive Order 11988, I have determined that the Selected Alternative avoids occupation and 

alteration of floodplains. 

Executive Order 11990 (Wetlands)

I have determined that the long- and short-term adverse effects associated with the destruction or 

modification of wetlands in the implementation of the Wrangell Island Project will be avoided to the 

extent possible. The techniques and practices required by the Forest Service serve to maintain the wetland 

attributes, including values and functions. In some areas, soil moisture regime and vegetation composition 

or structure may be altered; however, these altered acres would still be classified as wetlands and would 

function as wetlands in the ecosystem.

Where wetlands cannot be avoided, road construction will adhere to BMPs, which include at a minimum 

the Federal baseline provisions in 33 Code of Federal Regulation (CFR) 323 and State-approved BMPs. 

There will be approximately 92 acres of wetland that will no longer function as wetland due to road 

construction in the Selected Alternative.

Executive Order 12898 (Environmental Justice)

The FEIS analyzed environmental justice to determine whether a disproportionately high and adverse 

human health or environmental impact on minority populations, low-income populations, or Indian tribes 

was likely to result from the proposed action and any alternatives. The Executive Order specifically 

directs agencies to consider patterns of subsistence hunting and fishing when an agency action may affect 

fish or wildlife. I have determined that no communities are identified as being adversely affected in this 

area and that none of the alternatives would have a disproportionately high and adverse effect on the 

health of the environment of the minority, low-income, or Indian populations that use the Wrangell Island 

Project area.

Executive Order 12962 (Aquatic Systems, Recreational Fisheries) 

Per Executive Order 12962, I have determined that the Selected Alternative minimizes the effects on 

aquatic systems through project design, application of standards and guidelines, BMPs, and site-specific 

mitigation measures. In the Wrangell Island Project area, opportunities for recreational fishing are limited. 

For the Selected Alternative, recreational fishing opportunities would remain essentially the same as the 

current condition, because aquatic habitats are protected through implementation of BMPs and riparian 

standards and guidelines.
Wrangell Island Project

36

Executive Order 13007 (Indian Sacred Sites)

Executive Order 13007 directs Federal agencies to consider the protection of American Indian sacred sites 

and allow access where feasible. In a government-to-government relationship, the tribal government is 

responsible for notifying the agency of the existence of a sacred site. A sacred site is defined as a site that 

has sacred significance due to established religious beliefs or ceremonial uses, and which has a specific, 

discrete, and delineated location that has been identified by the tribe. I have determined that tribal 

governments or their authorized representatives were consulted and they did not identify any specific 

sacred site locations in the project area.

Executive Order 13112 (Invasive Species)

A risk assessment completed for the FEIS evaluated the status of invasive species in the project area and 

the effects from the proposed activities on them. The specific measures to minimize the introduction and 

spread of invasive plant species in the Selected Alternative are provided in Appendix 1 – Wrangell island 

Project Unit Cards.

Executive Order 13175 (Consultation and Coordination with Indian 

Tribal Governments)

Executive Order 13175 directs Federal agencies to respect tribal self-government, sovereignty, and tribal 

rights, and to engage in regular and meaningful government-to-government consultation with tribes on 

proposed actions with tribal implications. I have complied with this Order and have consulted with and 

provided information to the Wrangell Cooperative Association, a federally recognized tribal government 

about this project.

This consultation is documented in chapter 1 of the FEIS and in the public involvement records.

Executive Order 13186 Migratory Birds

The Migratory Bird Treaty Act of 1918 (amended in 1936 and 1972) prohibits the taking of migratory 

birds, unless authorized by the Secretary of Interior. The law provides the primary mechanism to regulate 

waterfowl hunting seasons and bag limits, but its scope is not just limited to waterfowl. The migratory 

species that may stay in the area utilize most, if not all, of the habitats described in the analysis for 

breeding, nesting, and raising their young. The effects on these habitats were analyzed for this project. I 

have determined that the decision will not have a significant direct, indirect, or cumulative effect on any 

migratory bird species in the project area. There may be moderate direct effects on individuals or small 

groups and their nests from the harvest of timber or the disturbance caused by harvest and related 

activities.

Executive Order 13443 (Facilitation of Hunting Heritage and Wildlife 

Conservation)

Executive Order 13443 directs Federal agencies to facilitate the expansion and enhancement of hunting 

opportunities and the management of game species and their habitat. The analysis considered and 

disclosed the effects on hunting activities. I have determined that the Selected Alternative will maintain 

hunting opportunities by adhering to the Forest Plan standards and guidelines that maintain habitat for 

hunted species.

Federal and State Permits

Federal and State permits necessary to implement the authorized activities are listed at the end of chapter 

1 in the FEIS.
DRAFT Record of Decision

37

Implementation

The timber from the Wrangell Island project will be offered in a variety of sale sizes to meet the needs of 

both large and small timber operators. Market conditions will be considered when offering sales. The City 

and Borough of Wrangell and other interested stakeholders will be consulted during the implementation 

design phase. 

Appendices 1 and 2 contain the Selected Alternative unit cards and road cards, respectively, which are 

located on the Wrangell Island Project webpage (http://www.fs.usda.gov/project/?project=34831). These 

cards are an integral part of this decision because they document the specific resource concerns, 

management objectives, and mitigation measures to govern the layout of the harvest units and 

construction of roads. These cards will be used during the implementation process to ensure that the 

project is implemented within applicable standards and guidelines and that resource effects will not be 

greater than those described in the FEIS. Similar cards will document any changes to the planned layout, 

which may occur during implementation. 

Minor changes are expected during implementation to better meet on-site resource management and 

protection objectives. Minor adjustments to unit boundaries are also likely during final layout to improve 

logging system efficiency. This usually entails adjusting the boundary to coincide with logical logging 

setting boundaries. Proposed changes to the authorized project actions will be subject to the requirements 

of the National Environmental Policy Act the National Forest Management Act, and other laws 

concerning such changes.

This project will be implemented in accordance with Forest Service Manual (FSM) 2430 and Forest 

Service Handbook FSH 2409.18 direction for timber sale project implementation. This direction provides 

a bridge between project planning and implementation and will ensure execution of the actions, 

environmental standards, and mitigations approved by this decision, and compliance with the Forest Plan 

and all applicable laws, policy and direction. The current applicable BMPs will be applied to the Selected 

Alternative.

Changes made during implementation will be reviewed, documented, and approved by the Responsible 

Official through the Tongass Supplement to FSH 1909.15-2009-1. In determining whether and what kind 

of NEPA action is required for changes during implementation, the Forest Supervisor will consider the 

criteria in the Code of Federal Regulations (40 CFR 1502.9(c)), and Forest Service Handbook (FSH) 

1909.15, sec. 18 to determine whether to supplement or revise an existing environmental impact 

statement. I will determine whether the proposed change is a substantial change to the Selected

Alternative as planned and already approved, and whether the change is relevant to environmental 

concerns. I will consider connected or interrelated changes to particular areas or specific activities in 

making this determination. The cumulative impacts of these changes will also be considered.

The implementation unit and road cards, as approved by this process, are incorporated into the timber sale 

contract. The sale administrators and road inspectors then enforce the contract requirements with the 

operators.

The implementation record for this project will display the following: 

• Each harvest unit, transportation facility, and other project components as actually implemented,

• Any proposed changes to the design, location, standards and guidelines, or other mitigation 

measures for the project, and

• Authorization of the proposed changes. 
Wrangell Island Project

38

Administrative Review - Opportunity to Object

This decision is subject to the project-level pre-decisional administrative review process pursuant to Title 

36 CFR Part 218, subparts A and B. Individuals or organizations who submitted specific written 

comments regarding the proposed project either during scoping or other designated opportunity for public 

comment in accordance with 36 CFR 218.5(a) may file objections to this draft decision. Issues raised in 

objections must be based on previously submitted, timely, specific written comments regarding the 

proposed project unless based on new information arising after previous designated opportunities. 

Individual members of organizations must have submitted their own comments to meet the requirements 

of eligibility as an individual; objections received on behalf of an organization are considered as those of 

the organization only. If an objection is submitted on behalf of a number of individuals or organizations, 

each individual or organization listed must meet the eligibility requirement of having previously 

submitted comments on the project (36 CFR 218.7). Names and addresses of objectors will become part 

of the public record. 

Incorporation of documents by reference in the objection is permitted only as provided for at 36 CFR 

218.8(b). 

The objection must be in writing and meet the objection content requirements at 36 CFR 218.8(d). 

The objection must be filed with the Reviewing Officer: 

Beth Pendleton, Regional Forester 

USDA Forest Service, Alaska Region 

709 W. 9th Street 

P.O. Box 21628 

Juneau, AK 99802-1628 

Email address: objections-alaska-regional-office@fs.fed.us

Fax: (907) 586-7840 

Phone: (907) 586-8863 

Written objections, including attachments, must be filed (US mail, fax, email, hand delivery, or express 

delivery) with the Reviewing Officer at the correct location within 45 calendar days of the date that the 

legal notification of opportunity to object to this draft decision is published in the Ketchikan Daily News, 

the official newspaper of record. The publication date in the newspaper of record is the exclusive means 

for calculating the time to file an objection. 

Those wishing to submit objections to this draft decision should not rely upon dates or timeframe 

information provided by any other source. The regulations prohibit extending the time to file an objection. 

A copy of the legal notice will also be posted on the Forest Service project website 

at http://www.fs.usda.gov/project/?project=34831. 

Hand-delivered written objections will be accepted at the Regional Office during normal business hours 

(8:00 am through 4:30 pm) Monday through Friday, excluding holidays. Electronic objections must be 

submitted in a format such as an email message, portable document format (.pdf), plain text (.txt), rich 

text format (.rtf), or MSWord (.doc or .docx). It is the responsibility of objectors to ensure their objection 

is received in a timely manner (36 CFR 218.9). All objections are available for public inspection during 

and after the objection process. 

If objections are received, there is a 45-day objection review period in which the Responsible Official, the 

Reviewing Officer, and the objectors may meet to attempt to resolve issues. At the end of the 45 days, the 

Reviewing Officer will issue a written response detailing how the objections have been addressed, which 

may also include instructions to the Responsible Official (36 CFR 218.11(b)). 
DRAFT Record of Decision

39

Implementation Date

A final decision on projects subject to the objection process may occur on, but not before, 5 business days 

from the close of the objection filing period, if no objections are received (36 CFR 218.12(c)(2)). 

If objections are received, the final decision will not be signed until all concerns and instructions 

identified by the Reviewing Officer in the objection response have been addressed by the Responsible 

Official (36 CFR 218.12(b)). 

Implementation of decisions subject to the objection process may commence immediately after a final 

decision is signed. There is not a requirement to publish notification of the decision. 

Contact Information

For additional information concerning this draft decision, contact Robert Dalrymple, District Ranger, 

Wrangell Ranger District, P.O. Box 51, Wrangell, AK 99929, or call (907) 874-2323. 

Responsible Official

The Responsible Official for the Wrangell Island Project is M. Earl Stewart, Forest Supervisor of the 

Tongass National Forest.

In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights 

regulations and policies, the USDA, its Agencies, offices, and employees, and institutions 

participating in or administering USDA programs are prohibited from discriminating based on 

race, color, national origin, religion, sex, gender identity (including gender expression), sexual 

orientation, disability, age, marital status, family/parental status, income derived from a public 

assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any 

program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies 

and complaint filing deadlines vary by program or incident. 

Persons with disabilities who require alternative means of communication for program information 

(e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the 

responsible Agency or USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact 

USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information 

may be made available in languages other than English. 

To file a program discrimination complaint, complete the USDA Program Discrimination 

Complaint Form, AD-3027, found online at http://www.ascr.usda.gov/complaint_filing_cust.html

and at any USDA office or write a letter addressed to USDA and provide in the letter all of the 

information requested in the form. To request a copy of the complaint form, call (866) 632-9992. 

Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, Office 

of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, D.C. 

20250-9410; (2) fax: (202) 690-7442; or (3) email: program.intake@usda.gov. 

USDA is an equal opportunity provider, employer and lender.

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